ST-HL-AE-5547, Application for Amends to Licenses NPF-76 & NPF-80,revising TS 6.2.3 to Remove Reference to Independent Safety Engineering Group (Iseg) & Relocate All Details and Functions of Iseg to UFSAR

Application for Amends to Licenses NPF-76 & NPF-80,revising TS 6.2.3 to Remove Reference to Independent Safety Engineering Group (Iseg) & Relocate All Details and Functions of Iseg to UFSAR

ML20134F578
Person / Time
Site:	South Texas
Issue date:	01/28/1997
From:	Cloninger T HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20134F582	List: ML20134F592 ST-HL-AE-5547, Application for Amends to Licenses NPF-76 & NPF-80,revising TS 6.2.3 to Remove Reference to Independent Safety Engineering Group (Iseg) & Relocate All Details and Functions of Iseg to UFSAR
References
ST-HL-AE-5547, NUDOCS 9702100056
Download: ML20134F578 (9)

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The Light company Houston Light ng & Power 1euth Texas Project Electric Generating Station P.O. Box 289 Wadsworth. Tesas 77483 l

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January 28,1997 i ST-HL-AE-5547 File No.: G20.02.01 10 CFR 50.90, 10 CFR 50.92, '

10 CFR 51 4 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 & 2 Docket No. STN 50-498 and STN 50-499 Unit I and Unit 2 Technical Snecification 6.2.3 The South Texas Project proposes to amend its Operating Licenses NPF-76 and NPF-80 for the South Texas Project Electric Generating Station, Units I and 2, by incorporating the following changes to Technical Specification 6.2.3. The proposed change would remove reference to the Independent Safety Engineering Group (ISEG) from current Technical Specifications. All details and functions of ISEG will be relocated to the Updated Final Safety Analysis Report (UFSAR).

The required affidavit (Attachment 1), along with a Safety Evaluation and No Significant Hazards Consideration Determination (Attachment 2) associated with the proposed changes, I the marked up affected pages of the Technical Specifications (Attachment 3), and the marked l up pages of the UFSAR (Attachment 4) are included as attachments to this letter.

l The South Texas Project has reviewed the attached proposed amendment pursuant to  ;

10CFR50.92 and determined that it does not involve a significant hazards consideration. In  !

addition, the South Texas Project has determined that the proposed amendment satisfies the criteria of 10CFR51.22(c)(9) for categorical exclusion from the requirement of an environmental assessment. The South Texas Project Electric Generating Station Nuclear  ;

Safety Review Board has reviewed and approved the proposed changes.

9702100056 DR 970128~ f ADOCK 05000498 PDR 070106 l

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l Houston Lighting & Power Company ST-HL-AE-5547 l South Texas Project Electric Generating Station File No.: G20.02.01 l Page 2 If you should have any questions concerning this matter, please call Mr. M. A. McBurne at (512) 972-7206 or myself at (512) 972-8787.

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l T. H. Cl ingej i Vice eside(t, I Nucl ar Edineering MLF/

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Attachment:

1. Affidavit

2. Safety Evaluation and No Significant Hazards Consideration i Determination

3. Mark-ups of Proposed Changes to Technical Specification 6.2.3

4. Mark-ups of Proposed Changes to UFSAR 13.4.2.2 j i

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i Houston L.i5hting & Power Company ST-HL-AE-5547 So'u'th Texas Project Electric Generating Station File No.: G20.02.01 Page 3  !

Leonard J. Callan Rufus S. Scott Regional Administrator, Region IV Associate General Counsel U S. Nuclear Regulatory Commission Houston Lighting & Power Company e'i Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8064 Houston, TX 77208 Thomas W. Alexion Institute of Nuclear Power

Project Manager, Mail Code 13H3 Operations - Records Center l U. S. Nuclear Regulatory Commission 700 Galleria Parkway l Washington, DC 20555-0001 Atlanta, GA 30339-5957 ,

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David P. Loveless Dr. Bertram Wolfe Sr. Resident Inspector 15453 Via Vaquero c/o U. S. Nuclear Regulatory Comm. Monte Sereno. CA 95030 P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Street, N.W. Austin, TX 78756-3189 Washington, DC 20036-5869 l

J. R. Egan, Esquire M. T. Hardt/W. C. Gunst Egan & Associates, P.C.

City Public Service 2300 N Street, N.W.

P. O. Box 1771 Washington, D.C. 20037 San Antonio, TX 78296 J. C. Lanier/M. B. Lee. U. S. Nuclear Regulatory Commission City of Austin Attention: Document Control Desk Electric Utility Depaitment Washingtoa, D.C. 20555-0001 721 Barton Springs Road Austin, TX 78704 Central Power and Light Company J. W. Beck ATTN: G. E. Vaughn/C. A. Johnson Little Harbor Consultants, Inc.

P. O. Box 289, Mail Code: N5012 44 Nichols Road Wadsworth, TX 77483 Cohassett, MA 02025-1166 b

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ATTACHMENT 1 AFFIDAVIT l

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' i UNITED STATES OF AMERICA I

.. NUCLEAR REGULATORY COMMISSION il In the Matter )

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South Texas Project, et al., ) Docket Nos. 50-498

) 50-499 South Texas Project Unit 1 & 2 )

, AFFIDAVIT l I, T. H. Cloninger, being duly sworn, hereby depose and say that I am Vice President, j Nuclear Engineering, of the South Texas Project; that I am duly authorized to sign and file ]

with the Nuclear Regulatory Commission the attached revision to proposed change to  ;

Technical Specification 6.2.3; that I am familiar with the content thereof; and that the matters l set forth therein are true and correct to the best of my knowledge and belief.

} l n 7 l/Cldninger  !

ice Preside , Nucl Engi eering  :

STATE OF TEXAS ) i

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i COUNTY OF Mda $ o r J( )

Subscribed and sworn to before me, a Notary Public in and for the State of Texas, thisTday of boar-g ,1997.

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t UNDA RITTENBERRY tr4  %

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- mrywcs*"""" d Notary Public in and for the Stfte of Texas y * ' '" ~ My Comensen f.xpres 10/9/97 o

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, e ATTACHMENT 2 SAFETY EVALUATION AND NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION ,

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i Attachment 2 ST-HL-AE-5547 Page 1 of 3 l SAFETY EVALUATION AND NO SIGNIFICANT HAZARDS i 1

CONSIDERATION DETERMINATION P

J- BACKGROUND  !

The Independent Safety Engineering Group (ISEG) functions to examine key elements l of Plant Operations for improvement in the area of Plant Safety. These elements

include but are not limited to Unit Operating Characteristics, NRC issuances, industry advisories, and Licensee Event Reports. ISEG is responsible for maintaining an independent verification of unit activities to ensure that these activities are performed correctly, and that human errors are reduced to as low a level as practical. The ISEG reports to the Director, Quality. Records of activities are forwarded each calendar

. month to the Chairman, Nuclear Safety Review Board. j

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j PROPOSED CHANGE DESCRll' TION -

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, The proposed change will relocate the details of Technical Specification 6.2.3 from the

! Administrative Controls section of Technical Specifications and place these details in South Texas Project's Updated Final Safety Analysis Report (UFSAR' Currently -

UFSAR Section 13.4.2.2 describes ISEG, but not in the detail as current Technical Specifications. UFSAR Section 13.4.2.2 will be revised to show that level of detail I

(Attachment 4). Also, Manager, Nuclear Safety Review Board title has been changed  ;

to Chairman, Nuclear Safety Review Board to reflect the actual title. l SAFETY EVALUATION

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The Independent Safety Engineering Group (ISEG) maintains an independent and objective viewpoint on unit activities. Areas for improvement in performance and human factors are identified. Reports of these findings are forwarded each month to the Chairman, Nuclear Safety Review Board.

ISEG's removal from Technical Specifications does not render any changes to any existing plant philosophies or safety analysis. This change is administrative only. The details previously listed in Technical Specifications will now be listed in the South Texas Project Updated Final Safety Analysis Report (UFSAR). The UFSAR is subject to the change control process in the Administrative Controls Section of the Technical Specifications, and any changes will be evaluated per 10CFR50.59. Therefore no accidents previously evaluated, no new or different kinds of accidents are created, and no reduction in the margin of safety will be allowed without prior NRC approval.

A Attachment 2 ST-HL-AE-5547

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Page 2 of 3 NO SIGNIFICANT HAZARDS CONSIDERATION l DETERMINATION Pursuant to 10CFR50.91, this analysis provides a determination that the proposed change to the Technical Specifications described previously, does not involve any significant hazards consideration as defined in 10CFR50.92, as described below:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes move details from the Technical Specifications to the

, Updated Final Safety Analysis Report (UFSAR). The changes do not result in any hardware or operating procedure changes. The details being removed from the Technical Specifications are not assumed to be an initiator of any analyzed event. The UFSAR, which will contain the removed Technical Specification details, will be maintained using the provisions of 10CFR50.59 and is subject  :

to the change control process in the Administrative Controls Section of the Technical Specifications. Since any changes to the UFSAR will be evaluated per 10CFR50.59, no increase in the probability or consequences of an accident previously evaluated will be allowed without prior NRC approval. Therefore, the changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change moves detail from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR). The changes will not alter the plant configuration (no new or different type of equipment will be installed) or make changes in methods governing plant operation. The changes will not impose different requirements, and adequate control ofinformation will be maintained. The changes will not alter assumptions made in the safety analysis and licensing basis. Therefore, the changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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ST-HL-AE-5547 Page 3 of 3 l i

3. The proposed change does not involve a significant reduction in a margin  !

of safety. '

The proposed changes move detail from Technical Specifications to the

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Updated Final Safety Analysis Report (UFSAR). The changes do not reduce i the margin of safety since the location of demils has no impact on any safety analysis assumpuons. In addition, the detail transposed from the Technical Specifications to the UFSAR are the same as the existing Technical Specification. Since any future changes to the UFSAR will be evaluated per the requirements of 10CFR50.59, no reduction in a margin of safety will be j allowed without prior NRC approval.  !

IMPLEMENTATION SCHEDULE t i

The South Texas Project requests an implementation time of 30 days from the i effective date of the approved license amendment to facilitate distribution and to make appropriate changes to plant documents.

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