ML20151P259

Advises of Position on Applying Tech Spec Improvements to Tech Spec Under Development.Suggests Considering Preparing Tech Specs Based on New Westinghouse STS If Fuel Load Date Postponed

ML20151P259
Person / Time
Site:	Comanche Peak
Issue date:	07/29/1988
From:	Partlow J NRC OFFICE OF SPECIAL PROJECTS
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8808090280
Download: ML20151P259 (5)

Text

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e *Rg Kf C i* +f o,, UNITED STATES y g NUCLEAR REGULATORY COMMISSION

, WASHINGTON, D. C. 20555 l

,,,,, +# July 29, 1988 Docket Nos. 50-445 and 50-446 Mr. William G. Counsi~

Executive Vice President Texas Utilities Electric Company 400 North Olive Street, L.B. 81 Dallas, Texas 75201

SUBJECT:

APPLICATION OF THE TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM TO COMANCHE PEAK UNIT 1 TECHNICAL SPECIFICATIONS The purpose of this letter is to advise you of the NRC staff position on applying technical specification (TS) improvements, as discussed in a recent Comission interim policy statement, to the TS under development for the Comenche Peak Steam Electric Station (CPSES), Unit 1. This subject has been discussed on a number of occasions by the staff and TV Electric representatives.,

in particular, during meetings held on April 12, 1988 and January 11-15, 1988 and in a telephone conference call held on July 14, 1988. Comanche Peak Unit 1 TS, based ou Revision 4a of the Westinghouse Standard Technical Specifications (STS), do not meet the criteria of the policy statement for priority treatment, and NRC does not have sufficient resources at this time to treat Comanche Peak as a specie.1 case, as explained further below.

The Commission's interim policy statement on technical specification improvements for nuclear power reactors (52 FR 3788) was published on February 6, 1987 for public coment. It encourages Tndustry owner groups to initiate programs to rewrite and streamline existing STS, making human factors and other improvements to add clarity and greater ease of use. The policy statement also encourages licensees to implement voluntary programs to update their TS consistent with the revised vendor-specific TS. The policy statement indicates that NRC would consider requests for TS amendments that evaluate all of the limiting conditions for operation (LCOs) for an individual plant, and does not intend that the criteria set forth therein be used as the basis for relocating individual LCOs.

The policy states that NRC will give first priority in TS improvements to review and approval of the revised STS and plant-specific license amendment applica-tions based on approved STS. Further, requests submitted based on the policy statement are to incorporate all tenns and provisions of the policy statement.

The staff has begun implementing this interim policy statement by not permitting the removal of existing requirements from TS based solely on the policy statement criteria, unless such action is in response to a generic letter implementing a .

short-term line item improvement under the overall Technical Specification Im-provement Program (TSIP). (For example, Generic Letter 88-06, issued on March 22, 1988, permits the removal of organization charts.from TS.) For Comanche Peak, "current" Westinghouse STS (i.e., Revision 4a) requirements are considered as "existing" requirements.

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Mr. W. G. Counsil Many of the changes to the current Westinghouse STS presently being proposed by TV Electric for CPSES, Unit 1, fall under the broad TSIP and are too numerous for the staff to consider as short-term line item improvements. At the meetings helo in January and April 1988, the staff advised TV Electric that it was unable to consider all of proposed changes in this category due to resource constraints. However, the staff offered to consider specific changes as line item improvements, as time and resources permitted, provided that TV Electric prioritized the changes. TV Electric has repeatedly resisted prioritizing these changes, insisting that Comanche Peak Unit 1 TS should be given consideration under the Comission's interim policy statement. When last discussed during the telephone conference call on July 14, 1988, our project manager and technical specification reviewer advised TV Electric that the latest submittal of proposed changes to the second draf t Unit 1 TS (TXX-88512 dated June 23, 1988) contained a number of TSIP changes which would not be permitted in the "Proof and Review" TS, scheduled to be issued by the end of the calendar year. Our schedule calls for issuance of the "Proof and Review" version of the Unit 1 TS by the end of 1988 in order to support your scheduled fuel load date of June 1,1989.

I fully support the staff position with regard to the proposed TSIP-type changes.

Additionally, you should understand that we will not be in a position to review TSIP-type changes in the course of our ongoing general review of Comanche Peak FSAR amendments and update of the safety evaluation report without jeopardizing-our review schedule. However, the staff will consider specific areas of change, provided they are discussed in advance and agreement is reached on pursuing the changes as short-term line item improvements under the overall TSIP.

Westinghouse is scheduled to complete the new Westinghouse STS by April 1989.

NRC has committed to complete the review and approval of those new STS within six to nine months after receipt. As an alternative to processing short-term line item improvements as described above, we suggest that you consider the feasibility of preparing the Unit 1 TS based on the new STS should there be a possibility of your fuel load date being postponed. If your fuel load date for Unit 1 is postponed beyond June 1, 1989, the staff believes it could support simultaneous review of the new Westinghouse STS and your Unit 1 TS based on them.

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Jame ; G. Partlow, Director Offi :e of Special Projects i

cc: See next page

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W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Electric Company Units 1 and 2 CC:

Jack R. Newman, Esq. Asst. Director for Inspec. Programs Newman & Holtzinger, P.C. Comanche Peak Project Division Suite 1000 U.S. Nuclear Regulatory Comission 1615 L Street, N.W. P. O. Box 1029 Washington, D.C. 20036 Granbury Texas 76048 Robert A. Wooldridge, Esq. Regional Administrator, Region IV Worsham, Forsythe, Sampels & U.S. Nuclear Regulatory Comission Wooldridge 611 Ryan Plaza Drive, Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 Lanny A. Sinkin Mr. Homer C. Schmidt Christic Institute Director of Nuclear Services 1324 North Capitol Street Texas Utiiities Electric Company Washington, D.C. 20002 Skyway Tower 400 North Olive Street, L,B. 81 Ms. Billie Pirner Garde, Esq.

Dallas, Texas 75201 Government Accountabili cy Project' Midwest Office

r. R. U. Ackley 104 East Wisconsin Avenue Stone & Webster Appleton, Wisconsin 54911 Comanche Peak Steam Electric Station P. O. Box 1002 David R. Pigott, Esq.

Glen Rose, Texas 76043 Orrick, Herrington & Sutcliffe 600 Montgomery Street Mr. J. L. Vota San Francisco, California 94111 Wettinghouse Electric Corporation P. O. Box 355 Anthony Z. Roisman, Esq.

Pittsburgh, Pennsylvania 15230 Suite 600 1401 New York Avenue, NW Susan M. Theisen Washington, D.C. 20005 Assistant Attorney General Environmental Protection Division Robert Jablon P. O. Box 12548. Capitol Station Bonnie S. Blair Austin, Texas 78711-1548 Spiegel & McDiannid 1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C. 20005-4798 Citizens Association for Sound Energy 1426 Soui.h Polk George A. Parker, Chairman Dallas, Texas 75224 Public Utility Comittee Senior Citizens Alliance Of Ms. Nancy H. Williams Tarrant County, Inc. ,

CYGNA Energy Services 6048 Wonder Drive 2121 N. California Blvd., Suite 390 Fort Worth, Texas 76133 Walnut Creek, CA 94596

W. G. Counsil -

2- Comanche Peak Electric Station Texas Utilities Electric Company Units 1 and 2 cc:

Joseph F. Fulbright Fulbright & Jaworski 1301 McKinney Street Houston, Texas 77010 Rocer D. Walker Manager, Nuclear Licensing Texas Utilitie'. Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Callas, Texas 75201 Fr. Jack Redding c/o Bethesda Licensing Texas Utilities Electric Company 3 Metro Center, Suite 610 Bethesda, Maryland 20814

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William A. Burchette, Esq.

Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C. 20007 GDS ASSOCIATES, INC.

Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237

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Mr. W. G. Counsil July 29, 1988 Nany of the changes to the current Westinghouse STS presently being proposed by TV Electric for CPSES, Unit 1, fall under the broad TSIP and are too numerous for the staff to consider as short-term line item improvements. At the meetings held in January and April 1988, the staff advised TV Electric that it was unable to consider all of proposed changes in this category due to resource constraints. However, the staff offered to consider specific changes as line item improvements, as time and resources permitted, provided that TU Electric prioritized the changes. TV Electric has repeatedly resisted prioritizing these changes, insisting that Comanche Peak Unit 1 TS should be given consideration under the Commission's interim policy statement. When last discussed during the telephone conference call on July 14, 1988, our project manager and technical specification reviewer advised TV Electric that the latest submittal of proposed changes to th second draf t Unit 1 TS (TXX-88512 dated June 23,1988) contained a number of TSIP changes which would not be permitted in the "Proof and Review" TS, scheduled to be issued by the end of the calendar year. Our schedule calls for issuance of the "Proof and Review" version of the Unit 1 TS by the end of 1988 in order to support your scheduled fuel load date of June 1, 1989.

I fully support the staff position with regard to the proposed TSIP-type changes.

Additionally, you should understand that we will not be in a position to review TSIP-type changes in the course of our ongoing general review of Comanche Peak FSAR amendments and update of the safety evaluation report without jeoparoizing our review schedule. However, the staff will consider specific areas of change, provided they are discussed in advance and agreement is reached on pursuing the changes as short-term line item improvements under the overall TSIP.

Westinghouse is scheduled to complete the new Westinghouse STS by April 1989.

' MiC has comitted to complete the review and approval of those new STS within six to nine months after receipt. As an alternative to processing short-term line item improvenents as described above, we suggest that you consider the feasibility of preparing the Unit 1 TS based on the new STS should there be a possibility of your fuel load date being postponed. If your fuel load date for Unit 1 is postponed beyond June 1, 1989, the staff believes it could support simultaneous review of the new Westinghouse STS and your Unit 1 TS based on them.

Original sianed by James G. Partlow, Director Office of Special Projects 1

cc: See next page DISTRIBUTION Docket File JHWilson BGrimes

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