ML20236K344

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Application for Amends to Licenses NPF-76 & NPF-80,to Relocate TS 3/4.7.13 Requirements for Area Temperature Monitoring Sys to Technical Requirements Manual.Affidavit, SE & Determination of NSHC & marked-up TS Pages Encl
ML20236K344
Person / Time
Site: South Texas  
Issue date: 07/06/1998
From: Cloninger T
HOUSTON LIGHTING & POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236K346 List:
References
ST-NOC-AE-00020, ST-NOC-AE-20, NUDOCS 9807090282
Download: ML20236K344 (8)


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Nuclear Operating Company S

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July 6,1998 ST-NOC-AE-000204 File No.: G20.02.01 G21.02.01 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Proposed Amendment to South Texas Project Technical Specifications to Relocate Technical Specification 3/4.7.13 to the Technical Requirements Manual STP Nuclear Operating Company (STPNOC) proposes to relocate the Technical Specification 3/4.7.13 requirements for the Area Temperature Monitoring System to the Technical Requirements Manual.

South Texas has reviewed the proposed amendment pursuant to 10CFR50.92 and determined that it does not involve a significant hazards consideration. In addition, South Texas has determined that the proposed amendment satisfies the criteria of 10CFR51.22(c)(9) for categorical exclusion from the requirement for an environmental assessment. The South Texas Plant Operations Review Committee and the Nuclear Safety Review Board have reviewed and appoved the proposed amendment.

The required affidavit, a Safety Evaluation and Determination of No Significant Hazards Consideration, and the marked-up affected pages of the Technical Specifications are included as J

attachments to this letter.

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Jn accordance with 10 CFR 50.91(b), South Texas Project is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments.

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9807090282 980706 PDR ADOCK 05000498 P

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1 ST-NOC-AE-000204 Page 2 South Texas requests that this proposed amendment be reviewed and approved by November 19,1998 to allow early implementation of the change. South Texas also requests 30 days for implementation following approval.

If there are any questions regarding the proposed amendment, please contact Mr. A. W.

Harrison at (512) 972-7298 or me at (512) 972-8787.

e T. H. Clo mger Vice Pr side uc ar Engineering AWH/

Attachments:

1. Affidavit
2. Description of Change and Safety Evaluation
3. No Significant Hazards Determination
4. Annotated Technical Specifications and Bases Pages i

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NOC-AE-000204 File No.: G20.02.01

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G21.02.01 Page 3 Ellis W. Merschoff Jon C. Wood Regional Administrator, Region IV Matthews & Branscomb U. S. Nuclear Regulatory Commission One Alamo Center 611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700 Arlington, TX 76011-8064 San Antonio,TX 78205-3692 Thomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code 13H3 Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 David P. Loveless Richard A. Ratliff Sr. Resident Inspector Bureau of Radiation Control c/o U. S. Nuclear Regulatory Commission Texas Department of Health P. O. Box 910 1100 West 49th Street Bay City,TX 77404-0910 Austin, TX 78756-3189 J. R. Newman, Esquire D. G. Tees /R L. Balcom Morgan, Lewis & Bockius Houston Lighting & Power Co.

I 800 M. Street, N.W..

P. O. Box 1700 Washington, DC 20036-5869 Houston,TX 77251 M. T. Hardt/W. C. Gunst Central Power and Light Company City Public Service ATTN: G. E. Vaughn/C. A. Johnson P. O. Box 1771 P. O. Box 289, Mail Code: N5012 San Antonio,TX 78296 Wadsworth,TX 77483 A. Ramirez/C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin,TX 78704 i

ST-NOC-AE-000204 Affidavit Page1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1

i In the Matter of

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STP Nuclear Operating Company

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Docket Nos. STN 50-498

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STN 50-499 South Texas Project Units 1 and 2

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i AFFIDAVIT I, T. II. Cloninger, being duly sworn, hereby depose and say that I am Vice President, Nuclear Engineering of the STP Nuclear Operating Company; that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached proposed relocation of Technical Specification 3/4.7.13 to the Technical Requirements Manual; that I am familiar with the content thereof; and that the matters set forth therein are true and correct to the best knowledge and belief.

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. :loning ce Preside t, uclear En ineer' g 4

STATE OF TEXAS

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COUNTY OF

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Subscribed and sworn to before me, a Notary Public in and for the State of Texas, this 4 *

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day of 39 Iy,1998.

UNDA RITTENBERRY d

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, Notary Public, State of Texas i

Mycommemanne Notary Public in and for the l

OCT. 9,2001 State of Texas I

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ST-NOC-AE-000204 Description of Change and Safety Evaluation Page 1 l

Description of Change:

The proposed change will relocate Technical Specification 3/4.7.13, " Area Temperature Monitoring," and its associated Bases to the South Texas Project (STP) Technical Requirements Manual (TRM). The Technical Specification page for the relocated speciDeation is annotated "NOT USED" and the page for the relocated Table 3.7-3 is annotated "Page Intentionally Blank".

The INDEX, pages ix and xv are annotated to show the removal of the speciDeation and bases.

The Bases for the specification is removed and the Bases number is annotated "NOT USED".

The proposed change is included in the STP application for Improved Technical SpeciDeations (ITS). However, implementation of the STP ITS has been deferred. The station's plans to modify the Area Temperature Monitoring system and revise the required temperatures to reflect the Area Temperature Monitoring system design were originally based on the schedule for the ITS. The planned modification will minimize the present need for operators to occasionally check temperatures locally. Approval of the proposed relocation will facilitate the planned change.

Safety Evaluation:

This Specification provides area temperature monitoring to ensure that safety-related equipment in various areas would not be subjected to conditions beyond the defined environmental i

qualification envelope for the areas. The temperature monitoring meets none of the criteria of

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10CFR50.36(c)(2)(ii) for information or requirements to be included in the Technical Specifications. The area temperature monitors have no function with regard to detection of failure of the reactor coolant pressure boundary. The area temperatures are not accident analysis parameters. The temperature monitoring system does not serve any primary safety function and has no actuation functions for accident mitigation. The area temperature monitors are located in areas that are readily accessible to the operators. The loss of area temperature monitoring was found to be a non-significant risk contributor to core damage frequency and offsite releases.

Based on the evaluation above, it is appropriate to relocate the requirements for the area temperature monitors to the TRM. Since the STP TRM has been incorporated into the STP Updated Final Safety Analysis Report, any changes to the STP TRM will require a 10 CFR 50.59 evaluation. The 10 CFR 50.59 evaluation will ensure that changes to this requirement will not l

have any adverse impact on the safe operation of the plant, i

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ST-NOC-AE-000204 No Significant Hazards Determination Page1 I

No Significant Hazards Determination:

STPNOC has evaluated the current Technical Specifications for the Area Temperature Monitoring using the criteria in 10CFR50.36(c)(2)(ii) and determined that they do not meet the

. requirements for incorporation in the Technical Specifications. STPNOC proposes that the requirements for the Area Temperature Monitors be relocated from the current '"echnical Specifications to the Technical Requirements Manual.

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In accordance with the criteria set forth in 10 CFR 50.92, the South Texas Project has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.

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Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change relocates requirements and surveillance for Technical Specification 3/4.7.13, which does not meet the criteria for inclusion in Technical Specifications as identified in 10CFR50.36(c)(2)(ii). The affected systems and components are not assumed to be initiators of analyzed events and are not assumed to mitigate accident or transient events. The requirements and surveillance for these affected systems and components will be relocated from the Technical Specifications to the Technical Requirements Manual, which is incorporated in the STP UFSAR and will be maintained pursuant to 10 CFR 50.59. In addition, the Area Temperature Monitoring System components are addressed in existing surveillance procedures which are also controlled by 10 CFR 50.59 and subject to the change control provisions imposed by plant administrative procedures, which endorse applicable regulations and standards. The j

associated changes to the Index are administrative. Therefore, the change does not l

involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

I The proposed change relocates requirements and surveillance for the Area Temperature l

Monitoring System, which does not meet the criteria for inclusion in Technical Specifications as identified in 10CFR50.36(c)(2)(ii). The change does not involve a g

l physical alteration of the plant (no new or different type of equipment will be installed) or make changes in the methods governing normal plant operation. The change will not impose different requirements, and adequate control ofinformation will be maintained.

This change will not alter assumptions made in the safety analysis and licensing basis.

j The associated changes to the Index are administrative. Therefore, the change does not l

create the possibility of a new or different kind of accident from any accident previously j

evamated.

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ST-NOC-AE-000204 No Significant Hazards Determination Page 2 3.

Does this change involve a significant reduction in a margin of safety?

The proposed change relocates requirements and surveillance for the Area Temperature Monitoring System, which does not meet the 10CFR50.36 criteria for inclusion in Technical Specifications. The change will not reduce a margin of safety since it has no impact on any safety analysis assumptions. In addition, the relocated requirements and surveillance for the affected structure, system, component, or variable remain the same as the existing Technical Specifications. Since any future changes to these requirements or the surveillance procedures will be evaluated per the requirements of 10 CFR 50.59, there will be no reduction in a margin of safety. The associated changes to the Index are administrative and have no potential effect on the margin of safety, I

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ST-NOC-AE-000204 Annotated Technical Specifications and Bases Page1 i

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Annotated Technical Specification and Bases Pages i

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