ML20195J653
| ML20195J653 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/16/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20195J651 | List: |
| References | |
| NUDOCS 9906210072 | |
| Download: ML20195J653 (3) | |
Text
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4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION o
WASHINGTON, D.C. 20656-0001 t e,p
- SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.111 AND 98 TO FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 STP NUCLEAR OPERATING COMPANY. ET AL.
DOCKET NOS. 50-498 AND 50-499 SOUTH TEXAS PROJECT. UNITS 1 AND 2
1.0 INTRODUCTION
By a'pplication dated March 30,1999, STP Nuclear Operating Company, et al. (the licensee) requested changes to the Technical Specifications (TSs) for South Texas Project, Units 1 and 2 (STP). The proposed changes would delete TS 3/4.3.3.4, Meteorological j
instrumentation," and its associated Bases. The licensee stated that TS 3/4.3.3.4 and the j
associated Bases to oe deleted have been incorpcrated into the Technical Requirements J
Manual (TRM).
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2.0 BACKGROUND
^
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to state TSs to be included as part of the license. The Commission's regulatory requirements related to the contents of TSs are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs);
(3) sunteillance requirements (SRs); (4) design features; and (5) administrative controls.
However, the rule does not specify the particular requirements to be incbded in a plant's TSs.
On July 22,1993, the Commission issued its Final Policy Statement, expressing the view that satisfying the guidance in the policy statement also satisfies Section 182a of the Act and 10 CFR 50.36 (58 FR 39132). In particular, the Commiccion Indicated that certain items could be relocated to licensee-controlled documents consistent with the standard enunciated by the Atomic Safety and Licensing Appeal Board in Portland Genera / Electric Co. (Trojan Nuclear Plant), ALAB-531,9 NRC 263,273 (1979). There, the Appeal Board observed "that technical specifications are to be reserved for those matters as to which the imposition of rigid conoitions or limitatbns upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
By this approach, existing LCO requirements that fall within or satisfy any of the criteria in the Final Policy Statement should be retained in the TSs; those LCO requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents. The 9906210072 990616 PDR ADOCK 05000498 P
- .q 2-Commission codified the four criteria in 10 CFR 50.36 (as amended in 60 FR 36953, July 19, 1995). The four criteria are as follows
Criterion 1:
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
Criterion 2:
A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either
- assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion 3:
A structure, systerm or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion 4:
A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and cafety.
3.0 EVALUATION in its application, the licensee stated that the TSs for the meteorological instrumentation were provided to ensure that environmental meteorological parameters that may affect the distribution of radioactive fission products outside the plant following a design-basis accident are measured. Therefore, the TS requirements for this instrumentation do not meet the above criteria specified in 10 CFR 50.36. The licensee addressed each of the four criteria and provided its basic why the TS meteorological instrumentation requirements did not meet the above criteria in 10 CFR 50.36 and, therefore, why these requirements do not need to remain in the TSs.
The licensee stated that the meteorological inottumentation is (1) not used to detect a significant abnormal degradation of the reactor coolant system (RCS) pressure boundary; (2) not a process variable that is an initial condition of a design-basis accident or transient
' analysis that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier; (3) not assumed to function in a safety analysis as part of a primary success path or to mitigate a design-basis accident or transient; and (4) not a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. The instrumentation is used to determine the meteorological conditions for disperston of offsite releases of radioactivity for dose calculations.
The staff has reviewed the licensee's basis and has determined that the meteorological instrumentation TS requirements do not meet the criteria in 10 CFR 50.36. Therefore, the staff concludes that the TS meteorological instrumentation requirements are not required to be in ti e TSs.
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The Commission's intent in removing requirements from any TS for which controls other than a i
license amendment may be required was to relocate the requirements to a licenseA program or document (a licensee-controlled document) where any future change to the relocated j
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- requirements would be under the change control process of the regulations (e.g.,10 CFR 50.59 or 10 CFR 50.54) or in the administrative controls section of the TSs. The licensee has stated that the meteorological instrumentation requirements in the TSs and Bases to the TSs have been already been relocated to the TRM for STP. Because the TRM is incorporated within the STP updated final safety analysis report (UFSAR) for the units, changes to the requirements on
' the' meteorological instrumentation would be changed in accordance with 10 CFR 50.59. The 10 CFR 50.59 criteria are an acceptable change control process for the meteorological requirements that are proposed to be deleted. Therefore, the staff concludes that the TRM is an acceptable licensee-controlled document to contain the requirements proposed to be deleted.
In its application, the licensee provided the revised TRM pages that incorporate the LCOs and SRs from TS 3/4.3.3.4 and the associated Bases. The staff has reviewed the TRM changes and has verified that the information from TS 3/4.3.3.4 has been appropriately relocated.
Based on the above, the staff concludes that the proposed deletion of TS 3/4.3.3.4 and its associated Bases is acceptable.
The staff also corrected two typographical errors that were introduced by the staff with the issuance of Amendments 101 and 88. On page vi of the index the word "Instumentation"is corrected to read " Instrumentation," and the word "MonitorRn9" is corrected to read
" Monitoring." The staff discussed these corrections with the licensee and the licensee finds them acceptable.
4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect 16 installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposuro. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (64 FR 24201). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in cor;nection with the istuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, th,1 (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Jack Donohew Date: June 16, 1999
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