ML20207A110
| ML20207A110 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/17/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20207A105 | List: |
| References | |
| NUDOCS 9905260146 | |
| Download: ML20207A110 (3) | |
Text
. mag j
g g
1 UNITED STATES j
NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20666 0001 l
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.109 AND 96 TO FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 STP NUCLEAR OPERATING COMPANY QOCKET NOS. 50-498 AND 50-499 SOUTH TEXAS PROJECT. UNITS 1 AND 2
1.0 INTRODUCTION
By application dated October 29,1998, as supplemented by letter dated March 15,1999, STP Nuclear Operating Company, et al., (the licensee) requested changes to the Technical Specifications (TSs) for the South Texas Project, Units 1 and 2. The proposed changes would relocate TS 3/4.7.9 and TS 6.10.3.1 that address snubber requirements and the associated Bases to the Technical Requirements Manual (TRM).
2.0 BACKGROUND
Section 182a of the Atomic Energy Act of 1954, as amended (the Act), requires that applicants for nuclear power plant operating licenses state TSs and that these TSs be included as a part of the license. The Commission's regulatory requirements related to the content of TSs are set forth in Title 10 of the Code of Federal Reoulations (10 CFR) Section 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; (3) surveillance requirements; (4) design features; and (5) administrative controls and states also that the Commission may include additional TSs as it finds to be appropriate. However, the regulation does not specify the particular TSs to be included in a plant's license.
The regulation sets forth four criteria to be used in determining whether a limiting condition for operation (LCO) is required to be included in the TS, as follows: (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (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; (3) a structure, system, or component that is part of the primary success path and which functions or Enclosure 9905260146 990517 PDR ADOCK 05000498 P
e.
l l
n l )
l 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; or (4) a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Existing LCOs and related surveillances included as TS requirements which fall within or satisfy any of the criteria must be retained in the TSs, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
While the four criteria specifically apply to LCOs, in adopting the revision to the rule, the Commission indicated that the intent of these criteria can be utilized to identify the optimum set of administrative controls in the TSs (60 FR 36957). Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure safe operation of the facility. The administrative controls section l
of the TSs should include the information that the Commission deems essential for safe l
operation of the facility that is not already covered by the regulations. Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5), and which are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, can be removed from administrative controls, relocated to more appropriate documents, and controlled by the i
applicable regulation.
3.0 EVALUATION The existing TS 3/4.7.9 conditions, actions, and surveillance requirements for snubbers have been relocated to the TRM. The",e requirements define inspection schedules, types, sampling methods, and acceptance criteria. Hydraulic and mechanical snubbers are included in the plant design to ensure that the structural integrity of the reactor coolant system and other safety-related systems is maintained during and following a seismic or other dynamic event. They serve as an aid to preventing pipe failure, but do not mitigate pipe failure. Also, the failure of a snubber on a particular pipe cannot, by itself, cause the pipe to fail. Consequently, the snubber l
requirements do not meet 10 CFR 50.36 criteria since they are not used as part of the primary success path in detecting or mitigating the consequences of a design-basis accident or transient event.
In addition, TS 6.10.3.1, which states that retention of " records of the service lives of all hydraulic and mechanical snubbers required by Specification 3.7.9 including the date at which the service life commences and associated installation and maintenance records," is relocated to the TRM. Record retention requirements are also located in 10 CFR Part 50, Appendix B, and in 10 CFR 50.71. It is not necessary to include redundant or additional requirements in the TS administrative controls.
Since the licensee has incorporated the TRM, by reference, into the Updated Final Safety j
Analysis Report, changes to the TRM would be controlled in accordance with approved station procedures and the requirements of 10 CFR 50.59. The staff, therefore, finds that sufficient regulatory controls exist. Accordingly, the staff has concluded that these requirements may be relocated from the TSs to the licensee's TRM.
In the October 29,1998, application, the licensee provided the revised TRM pages that incorporate the limiting conditions for operation and surveillance requirements from TS 3/4.7.9 and the associated Bases. In the March 15,1999, submittal, the licensee provided the revised TRM page that incorporates the record retention requirements. The staff has reviewed the
(
l
I 1
e f 1 l
TRM changes and has verified that the information from TS 3/4.7.9 and TS 6.10.3.1 has been appropriately relocated.
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 to 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 exposure. The Commission has previously issued proposed findings that the amendments involve no significant hazards consideration, and there has been no public comment on such findings (63 FR 69346 and 64 FR 17031). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). These amendments also change recordkeeping, reporting, or administrative procedures or requirements. Accordingly, with respect to these items, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (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: Marsha Gamberoni Date: May 17, 1999 l