ML20078S089

Application for Amends to Licenses NPF-87 & NPF-89, Requesting Approval of Converted TSs to Format & Content of Improved STSs

ML20078S089
Person / Time
Site:	Comanche Peak
Issue date:	12/19/1994
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20078S092	List: ML20078S089 ML20078S099
References
TXX-94327, NUDOCS 9412280086
Download: ML20078S089 (9)

Text

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M Log # TXX 9/'327 9 '"" File # 10010 1 .

916.5 (GEN)

C C Ref. # 10CFR50.90 7UELECTR/C 10CFR50.36a December 19, 1994 l c.xmc Tnry j ar e v aarra a a ,

1 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 l

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50 445 AND 50 446 LICENSE AMENDMENT REQUEST 94 023 TECHNICAL SPECIFICATION CONVERSION PROJECT (GENERIC SUBMITTAL)

REF: 1) TV Electric letter logged, TXX-94069 from William J. Cahill, Jr. to the NRC dated March 4, 1994

2) NUPEG 1431, " Standard Technical Specifications Westinghouse Plants," Draft Revision 1 Gentlemen:

Pursuant to 10CFR50.90 TU Electric hereby requests an amendment to the CPSES Unit 1 facility operating licensing (hPF-87) and Unit 2 facility operating license (NPF 89) by incorporating changes to the CPSES Units 1 and 2 Technical Specifications (TS) as provided in future supplements to this license amendment request. The purpose of this initial request is to provide a submittal pursuant to Reference 1 which will (1) docket TV Electric's request for NRC approval of the converted CPSES Unit 1 and Unit 2 Technical Specification to the format and content of the improved Standard Technical Specifications (STS) [ Reference 2] and to adopt a plant specific version of the expanded Bases from the STS: (2) provide a preliminary "information only" copy of the CPSES specific mark up of NUREG 1431, draft Revision 1 (Reference 2) excluding the expanded Bases: and (3) provide a docketed request under which the NRC may perform the reviews and approvals needed to ultimately issue the requested license amendment.

TU Electric has prepared this submittal to be consistent with 10CFR50.36a and requests that the proposed changes as described in the future supplements be incorporated into the Technical Specifications. Attachment 1 is an affidavit: Attachment 2 provides a generic description and assessment of the proposed changes. Enclosed is a preliminary "infortation only" copy of the CPSES specific mark up of NUREG 1431, draft Revision 1 excluding the plant specific version of the expanded Bases from the STS. TU Lic;tric intends to supplement this License Amendment Request (LAR) with detailed descriptions and assessments and final proposed technical specifications with their associated expanded Bases.

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TXX 94327 Page 2 of 2 In accordance with 10CFR50.91(b), TV Electric is providing the State of Texas with a copy of this proposed amendment.

Because implementation of the converted technical specifications involves significant training and revisions to implementing procedures. TU Electric will request an implementation date or period in a later supplement to this LAR.

Should you have any questions, please contact Mr. Tho,das B. Light at (214) 812 8879.

Sincerely

& S. l C. L. Terry By: M Roger (e Walker '

Regulatory Affairs Manager l RSB/gp l Attachments: 1. Affidavit

2. Description of Assessment

Enclosure:

Preliminary "information only" copy of the CPSES specific mark-up excluding the expanded Bases of NUREG 1431, " Standard Technical Specifications Westinghouse Plants", Draft Revision 1.

c- Mr. L. J. Callon, Region IV Mr. D. D. Chamberlain, Region IV Resident Inspectors (2)

Mr. T. J. Polich, NRR Mr. D. K. Lacker Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78704

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! to TXX-94327 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )  !

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Texas Utilities Electric Company ) Docket Nos. 50 445

) 50 446 (Comanche Peak Steam Electric Station, )  !.icense Nos. NPF 87 Units 1 & 2 ) NPF 69 AFFIDAVIT Roger D. Walker being duly sworn, hereby deposes and says that he is Regulatory Affairs Manager of TV Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 94 023: that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

(JCM -

N Roger D.64alker Regulatory Affairs Manager STATE OF TEXAS )

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COUNTY OF DALLAS )

Subscribed and sworn to before me, on this l7Ib day of "W M ,

1994.

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Attachment 2 to TXX-94327 Page 1 of 3 I. BACKGROUND TU Electric has initiated a project to renvert the CPSES Technical Specifications (TS) to the format and expanded Bases of the improved Standard Technical Specifications, a', developed by the Westinghouse Owners Group and the NRC. The conv.trted CPSES Technical Specifications will be transmitted to the NRC as follows.

The initial License Amendment Rec,uest (Generic Submittal) will provide the generic justifications for tne new format and expanded Bases and an "information only" preliminary CPSES specific mark up of NUREG-1431, draft Revision 1 (excluding the expanded Bases) [ Reference 1]

and proposed line item changes. This mark up will serve to identify the general direction being taken by TU Electric in the conversion program and be useful in understanding the supplements to this initial License Amendment Request.

The supplements will be structured as individual license amendment requests which will provide the final CPSES specific mark ups to the format and expanded Bases of the improved Standard Technical Specifications (STS). Six supplemental submittals are scheduled to be transmitted tc the NRC beginning in the third quarter 1995.

In most cases, numerical values represented in this markup and in current CPSES Technical Specifications represent " indicated" values, providing the control room operator with a reading that, when satisfied, assures that the subject parameter has satisfied operability requirements according to the associated instrumentation provided. As part of the technical specification conversion process, 1 TV Electric is evaluating the use of " actual" values to be provided in l the technical specifications, with representative " indicated" values l to be provided in the BASES or other controlled document for use by  !

Operations personnel. This approach, when applied, may allow the use of alternate processes or instrumentation in satisfying LC0 or ,

surveillance requirements for a particular parametar.

II. DESCRIPTION OF PROPOSED TECHNICAL SPECIFICATION REOUESTS This initial License Amendment Request provides an "information only" i preliminary CPSES specific mark up of NUREG 1431, draft Revision 1 l excluding the expanded Bases. The generic changes being addressed in this document are the new format and orgenization, and the expanded Bases. 1 III. ANALYSIS I On July 22, 1993, the NRC issued the final policy statement titled

" Policy Statement on Technical Specification Improvements for Nuclear l Power Reactors" (58FR39132) [ Reference 2]. This policy statement encourages licensees to implement a voluntary program to update their l TS to be consistent with improved vendor specific STS issued by the 1

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. to TXX 94327 Page 2 of 3 NRC in September 1992. The NRC stated that the implementation of the improved STS (NUREG 1431) is expected to produce an improvement in safety of nuclear power plants through the use of more operator-oriented TS, improved TS Bases, reduced action statement induced plant transients, and more efficient use of the NRC and industry resources.

TV Electric proposes to use this guidance, the recommendations of NUREG 1366 (Reference 3), Generic Letter 93 05 (Reference 4), and the proposed administrative control changes specified in the NRR letter dated October 25, 1993, (Reference 5) for the conversion of the CPSES Technical Specification to the format and expanded Bases of the improved Standard Technical Specifications, as developed by the Westinghouse Owners Group and the NRC.

l IV. SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The following is an evaluation whether or not a significant hazards  !

consideration is involved with the proposed changes by focusing on the l three standards set forth in 10CFR50.92(c) as discussed below:

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes are to convert the CPSES Unit 1 and Unit 2 Technical Specifications to the format and content of the improved Standard Technical Specifications. TV Electric assembled a task team to assens the format and the expanded Bases of the improved Standard Technical Specification. It was a conclusion of this task teac thst the clarity, useability, and the increase in readily available Bases information was an improvement with the potential to enhance safety. The potential problems with " retraining" personnel already trained on the current technical specifications are minimized by the clarity and useability of the converted technical specifications, the minimal number of technical changes occurring, and the training which will result from the conversion process itself through the internal reviews required and the revisions required to the implementing procedures and other related documents. On this basis TU Electric has concluded that converting to the new format and expanded Bases will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Due to their administrative nature, the change in format and the expansion of the information in the Bases section of the technical specification will not, by themselves, result in any

Attachment 2 to TXX-94327 Page 3 of 3 failure modes or plant conditions that could create the possibility of a new or different kind of accident.

3. Do the proposed changes involve a significant reduction in a margin of safety?

The change in format and the expansion of the Bases do not affect the failure point of any systems or equipment and do not alter any acceptance limits. As such, these administrative changes do not involve a reduction in a margin of safety.

IV. ENVIRONMENTAL EVALUATION An evaluation of the proposed changes has determined that these generic changes do not involve (1) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increasing individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR50.22(b), an environmental assessment of the proposed changes is not required.

VI. REFERENCES

1. NUREG 1431 " Standard Technical Specifications Westinghouse Plants," Draft Revision 1.

2. Statement of Policy - Nuclear Regulatory Commission, July 22, 1993 (58 FR 39132).

3. NUREG 1366, " Improvements to Technical Specification Surveillance Requirements".

4. Generic Letter 93 05, "Line-Item Technical Specification Improvements to Reduce Surveillance Requirements for Testing During Power Operation".

5. NRC letter from Mr. William T. Russell to Messrs. Lee Bush, Blair Wunderly, Brian Woods and Ray Barker dated October 25, '

1993.

6. NUREG-1024. " Technical Specification - Enhancing the Safety Impact".

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Enclosure to TXX 94327 .

3 Preliminary "information only" copy of the CPSES specific mark up excluding the expanded Bases of NUREG 1431 " Standard Technical Spccifications Westinghouse Plants " Draft Revision 1 4

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TABLE OF CONTENTS Explanation of " mark up" methodology.

" Hark up" copy of NUREG 1431, draft Revision 1.

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HARK UP METHODOLOGY A partial copy of NUREG 1431 draft Revision 1, has been marked up through

. deletions, insertions and notations.

Deletions the deleted text is clearly crossed out using a line through the test or is enclosed with a line (e.g., a circle, oval, cloud, etc.) and a deletion symbol ( A ) attached.

Insertions inserted information has been added in the proper location; added in a adjacent open area on the page (e.g., margins, between paragraphs, etc.) and an arrow used to identify the correct location; or an Insert was prepared on a separate page.

Inserts are uniquely identified. The page with the Insert includes the unique identification number and the page where the Insert will be added. The page where the material is to be added uses the unique Insert identification number to locate where the Insert is to be added.

Notations The following notation are used.

LAR YY XX This change corresponds to a change requested in a separate License Amendment Request whose approval is expected prior to the approval of the converted technical ,

specifications. YY-XX reflects the year and sequential number of the referenced LAR.

S.S.S XX This is a specific change to section S.S.S. XX is the sequential number for that change in section S.S.S.

Specific descriptions and justifications will be provided for changes such as these.

ED - Editorial change.

PS - Minor plant specific changes (e.g. changing " plant" to

" unit").

Bracketed information in NUREG 1431 is to be replaced with plant specific information. TU Electric has inserted the plant specific information based on the current CPSES Technical Specifications or, when not included in the current technical specifications. based on the design basis of CPSES. No notation is provided for these changes to the NUREG.

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