ML20217E582

Forwards Request for Addl Info on Proposed License Amend to Convert to Format of Improve Std TS

ML20217E582
Person / Time
Site:	South Texas
Issue date:	04/22/1998
From:	Alexion T NRC (Affiliation Not Assigned)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
TAC-M95529, TAC-M95530, NUDOCS 9804270342
Download: ML20217E582 (7)

Text

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4 Mr. William T. Cottle April 22, 1998 President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SOUTH TEXAS PROJECT, UNITS 1 AND 2 (STP) (TAC NOS. M95529 AND M95530)

Dear Mr. Cottle:

The Nuclear Regulatory Commission staff is reviewing STP Nuclear Operating Company's (STPNOC's) proposed license amendment to convert to the format of the improved Standard Technical Specifications. STPNOC provided a major supplement to the proposed license amendment (Supplement 1) by letter dated July 22,1997.

! The staff has reviewed selected portions of the application and its supplements. Based on its review, the staff has determined that additional information is needed in Section 3.8, as discussed in the enclosure. Note the staff is still reviewing your classification of Discussion of Changes for this section.

If you have any questions regarding the enclosed request for additional information please contact me at (301) 415-1326. The staff is prepared to discuss these items and establish a schedule for your response.

Sincerely, ORIGINAL SIGNED BY: 1. blich for Thomas W. Alexion, Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499 '

Enclosure:

As stated em : n m n n, Idd:tg fi!f @Z??D fug7 cc w/ encl: See next page DISTRIBUTION:

Docket File PUBLIC PD4-1 r/f EAdensam (EGA1) JHannon CHawes TAlexion OGC ACRS TGwynn, RIV WBeckner CShiraki

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Document Name: ST95529A.RAI *See previous concumince OFC PM/PD4-1 LA/PD4-1 BC/TSB* D/PD4-1//

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NAME kAlexion/vw CHa WBeckner JHannob DATE ( /t -/98 8

M45/98 04/22/98 98 COPY YES/NO YES/NO YES/NO / YEShO OFFICIAL RECORD COPY V 9804270342 980422 PDR ADOCK 05000498 P PDR

i a cac yo 4 UNITED STATES i < o NUCLEAR REGULATORY COMMISSION f WASHINGTON, D.C. 20666-0001

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/ April 22, 1998 l

l Mr. William T. Cottle President and Chief Executive Officer l STP Nuclear Operating Company i

South Texas Project Electric Generating Statien P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SOUTH TEXAS PROJECT, UNITS 1 AND 2 (STP)(TAC NOS. M95529 AND M95530)

Dear Mr. Cottle:

The Nuclear Regulatory Commission staff is reviewing STP Nuclear Operating Company's l (STPNOC's) proposed license amendment to convert to the format of the Improved Standard l Technical Specifications. STPNOC provided a major supplement to the proposed license l amendment (Supplement 1) by letter dated July 22,1997.

The staff has reviewed selected portions of the application and its supplements. Based on its

! review, the staff has determined that additional information is needed in Section 3.8, as l discussed in the enclosure. Note the staff is still reviewing your classification of Discussion of Changes for this section.

If you have any questions regarding the enclosed request for additionalinformation please contact me at (301) 415-1326. The staff is prepared to discuss these items and establish a schedule for your response.

l Sincerely, l

f

' Thomas W. Alexion, Project Manager l Project Directorate IV-1 i Division of Reactor Projects lil/IV l Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499 Enc:osure: As stated l

l cc vdencl: See next page

. Mr. William T. Cottle STP Nuclear Operating Company South Texas, Units 1 & 2 cc:

Mr. David P. Loveless Jack R. Newman, Esq.

Senior Resident inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1800 M Street, N.W.

P. O. Box 910 Washington, DC 20036-5869 Bay City, TX 77414 i Mr. Lawrence E. Martin i A. Ramirez/C. M. Canady Vice President, Nuc. Assurance & Licensing City of Austin STP Nuclear Operating Company Electric Utility Department P. O. Box 289 721 Barton Springs Road Wadsworth, TX 77483 i Austin, TX 78704 '

Office of the Govemor Mr. M. T. Hardt ATTN: John Howard, Director Mr. W. C. Gunst Environmental and Natural  :

City Public Service Board Resources Policy P. O. Box 1771 P. O. Box 12428 San Antonio,TX 78296 Austin, TX 78711 Mr. G. E. Vaughn/C. A. Johnson Jon C. Wood Central Power and Light Company Matthews & Branscomb P. O. Box 289 One Alamo Center Mail Code: N5012 106 S. St. Mary's Street, Suite 700 Wadsworth, TX 74483 San Antonio, TX 78205-3692 INPO Arthur C. Tate, Director Records Center Division of Compliance & Inspection 700 Galleria Parkway Bureau of Radiation Control Atlanta, GA 30339-3064 Texas Department of Health 1100 West 49th Street Regional Administrator, Region IV Austin, TX 78756 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Jim Calloway Arlington, TX 76011. Public Utility Commission of Texas Electric Industry Analysis D. G. Tees /R L. Balcom P. O. Box 13326 Houston Lighting & Power Co. Austin, TX 78711-3326 P. O. Box 1700 Houston, TX 77251 Judge, Matagorda County .

Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414

SOUTH TEXAS PROJECT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS CONVERSION SECTION 3.8 ELECTRICAL POWER SYSTEMS Section 3.8.1

1. The rewrite of current technical specifications (CTS) Action 3.8.1.1.f into Actions C and G is l bevond scope.

2. Discussion of Changes (DOCS) A.6, A.11, and A.22 are not administrative changes.

3. The addition of Action I, for 4 or more AC sources inoperable is bevond the scope of a t

conversion.

l For this same proposed Action I, the action is to immediately restore at least 2 AC sources to l operable. However, there is no time limit on the restoration. Is it safer to operate with only 1 AC l source available than to shutdown per 3.0.37 If only 1 AC source is restored, and Action G is entered, when did the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time in Action G start?

l l 4. CTS surveillance requirement (SR) 4.8.1.1.2.a.3) requires loading the SDG to 5000-5500 kW.

l The improved technical specification (ITS) load is 4500-5000 kW, but no DOC is provided.

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j 5. STS SR 3.8.1.12.d (ITS SR 3.8.1.9.d) is deleted with no justification for deviation (JD).

6. ITS SR 3.8.1.3 adds a Note 3 which is not in CTS and does not provide a DOC.

7. STS SR 3.8.1.1b provides a load reject range of 4500-5000 kW. CTS SR 4.8.1.1.2.e.3) gives l

a load reject load of 5500 kW. ITS SR 3.8.1.7 does not adopt either the CTS or STS requirement, specifying instead a load reject requirement of 5000-5500 kW. This is a bevond scope chanoe.

i 8. STS SR 3.8.1.9.a specifies the frequency of 5 63 Hz. CTS 4.8.1.1.2.e.2) specifies a frequency l of 6014.5 Hz. ITS 3.8.1.6 specifies a frequency of 5 64.5 Hz. This chanae is bevond scope.

9. CTS SR 4.8.1.1.2.f) requires SR performance during shutdown. Consistent with the STS, ITS l SR 3.8.1.17 deleted this requirement. However, no DOC is provided.

l 10. CTS SRs 4.8.1.1.2.e.4)b) and 4.8.1.1.2.e.6)b) verify the SDG starts in 510 seconds.

Consistent with the STS, ITS SRs 3.8.1.8.c.1 and 3.8.1.16.c.1 verify the SDG eneraizes the Class 1E buses in 510 seconds. However, no DOC is provided.

11. CTS 4.8.1.1.2.e)7) is the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SDG run. This is followed by a hot restart in ITS 3.8.1.12.

Consistent with STS, Note 1 of ITS 3.8.1.12 allows momentary transients to not invalidate the hot i restart test. However, this same Note is not in CTS and there is no DOC.

12. CTS markup indicates 4.8.1.1.3 (Reports) is relocated to 5.6.7. In actuality,5.6.7 has been deleted.

13. CTS 4.8.1.1.2.e.7) uses foot note 6. ITS SR 3.8.1.11 uses the STS note which also addresses power factor transients. There is no DOC that addresses the power factor issue.

ENCLOSURE l l

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! Section 3.8.2 f 1. The ITS LCO adds the automatic load sequencer. This is not in the CTS or the STS and is a bevond scope chanoe.

l l 2. CTS Action and STS Action A.2.2 and B.2 address suspension of movement ofirradiated l fuel. ITS deletes this requirement. This is a bevond scope chance.

l 3. Addition of ITS Note allowing use of RWST or isolated RHR loop water (JD 19) is a beyond scope chances l 4. CTS 4.8.1.2.1.s requires voltage i 10% and frequency 12%. ITS does not retain these l requirements. DOC LA.21 is referenced, but does not apply. I

5. In ITS Actions A, C, and E, the allowance to declare the affected required features inoperable QB suspend core alterations, positive reactivity additions, and initiate actions to restore the inoperable system (s) is bevond scope. l

6. CTS 4.B.1.2.1.b requires a breaker alignment check every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS B.3 states to verify by

administrative means the AOEPS is capable of being aligned to supply power. No DOC is

! provided for this change.

l Section 3.8.3

1. The addition of the automatic load sequenceris a bevond scope chanoe.

2. Addition of the Note (JD 19) for the use of RWST or isolated RHR loop water is a bevond 1900e chanae.

l 3. CTS actions require immediate suspension of all operations involving core alterations, l positive reactivity changes, movement of irradiated fuel and immediate action to restore the l

inoperable AC electiical source. Consistent witn STS, ITS makes all these immediate actions optional if the required features with no off site power are declared inoperable. There is no DOC that justifies this change.

Section 3.8.4

1. CTS 4.8.1.1.2.b requires that every 31 days, and after each operation of > 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, check and remove water from fuel tank. STS requirement is 31 days, too. ITS changes frequency to 92 days and is a bevond scope chance.

i in addition, there is no QOC to justify deletion of the > 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> operation time of the SDG.

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2. CTS does not specify a starting air receiver pressure. STS Bases E.1 states a lower limit that should allow 5 successive SDG start attempts. The ITS has reduced this to 4 successive SDG l start attempts. Generic JD 4 states that this change may be to reflect the facility specific 1

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I characteristics. Provide further details to justify 4 start attempts instead of 5, and the air pressures specified.

Section 3.8.5

1. CTS SR 4.8.2.1.a.2) and STS SR 3.8.4.1 both require a float voltage of 129 volts. ITS 3.8.5.1 changes this to 127 volts and is a bevond scope chanoe.

2. CTS SR 4.8.2.1.c.2) and STS 3.8.4.4 both say " clean and tight." ITS SR 3.8.5.4 has deleted i this requirement and is a beyond scope chanoe.

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! 3. In CTS 4.8.2.1.f a degraded battery uses the " average on previous performance tests."

l Consistent with STS, when this was moved to the Bases for ITS SR 3.8.5.8, the word " average" was left out. However, a DOC is necessary to justify the deletion.

Section 3.8.6

1. Note at Action A.2.3 for JD 19 and L.23 involving addition of RWST or isolated RHR loop is bevond scope.

2. In the CTS Action, the QR does not apply to the initiation of corrective actions (notice the semi-colon instead of a comma). A DOC is needed to justify the change.

l Section 3.8.7 l

1. CTS SR 4.8.2.1.b.3) requires verification that electrolyte temperature is > 65 degrees F. ITS SR 3.8.7.3 replicates this requirement. ITS Action B requires action if electrolyte temperature is

< 65 degrees F. If electrolyte temperature is equal to 65 degrees F, the requirements of SR 3.8.7.3 are not met. However, a temperature equal to 65 degrees F does not meet the condition l of Action B. The STS SR 3.8.6.3 specifies > .

2. DOC M-14 restates the deletion of the temperature compensation but gives no technical justification.

3. Note (4) of CTS Table 4.8-2 requires correction of specific gravity fo'r electrolyte temperature and level. When CTS Notes (4) and (5) were combined, a caveat was added that if battery charge < 2 amps, level correction is not required. Although this is consistent with STS, a technical DOC must be provided.

4. CTS note (1) of Table 4.8-2 states a battery may be considered operable provided that for any l Cat A parameter outside the LIMITS, w/in 24 hrs all Cat C measurements are taken and found w/in ALLOWABLE VALUES AliQ provided all Cat A and B parameters restored within limits within 31 days.

CTS note (2) of Table 4.8-2 states a battery may be considered operable provided that any Cat B i parameter outside LIMIT is still within ALLOWABLE VALUE (Cat C) and provided the Cat B l parameter is restored to within LIMIT within 7 days.

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i The ITS places the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CTS requirement on verifying a Cat B parameter that is outside

! LIMIT is still within ALLOWABLE VALUE. This is a more restrictive change because it places a time limit on the verification. CTS requires restoration of a Cat B parameter within 7 days. ITS allows 31 days. This is a less restrictive change.

No DOCS address these changes.

5. CTS note (3) of Table 4.8-2 states that if a Cat B parameter is outside its allowable value, the battery is inoperable. This requirement is changed in the ITS to be a Cat C parameter. This change is consistent with STS but it does not have a DOC.

l l Section 3.8.8

1. ITS SR 3.8.8.1 deletes the STS requirement to verify inverter frequency. No JD is provided.

2. It is not obvious that ITS SR 3.8.8.1 and CTS SR 4.8.3.1 verify the same breakers. Do they?

Section 3.8.9 l 1. ITS 3.8.9.1 deletes the frequency verification without a JD.

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2. Same issue as with ITS SR 3.8.8.1. l l 3. Add Tan of Note allowing use of RWST or isolated RHR loop water, as justified in L.23, is

! bevond scope.

Section 3.8.10

1. Actions A.2.4 and A.2.5 should not be part of the QR section. l l 2. Addition of Note allowing use of RWST or isolated RHR loop water, as justified in L.23, is

! bevond scope.

Section 3.8.11 No Comments.