NOC-AE-00187, Application for Amends to Licenses NPF-76 & NPF-80, Relocating RCS Design Features from TS 5.4 to UFSAR

Application for Amends to Licenses NPF-76 & NPF-80, Relocating RCS Design Features from TS 5.4 to UFSAR

ML20236M992
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
ML20236M994	List: ML20236N000 NOC-AE-00187, Application for Amends to Licenses NPF-76 & NPF-80, Relocating RCS Design Features from TS 5.4 to UFSAR
References
NOC-AE-00187, NOC-AE-187, NUDOCS 9807140352
Download: ML20236M992 (11)

Text

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i July 6, 1998 NOC-AE-00187 File No.: G20.02.01 G21.02.01 10 CFR 50.90

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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 1

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South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Proposed Amendment to Relocate Reactor Coolant System Design Features from Technical Specification 5.4 to the Updated Final Safety Analysis Report

Reference:

Letter from L.E. Martin to U.S. Nuclear Regulatory Commission dated May 7,1998 (ST-NOC-AE-00159)

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l The STP Nuclear Operating Company (STPNOC) proposes to amend the South Texas Project Technical 2 specifications by incorporating the attached amendment to Technical Specification 5.4.

These changes will relocate the description of the Reactor Coolant System design features to the Updated Final Safety Analysis Report (UFSAR).

l STPNOC intends to replace the original Westinghouse Model E steam generators in South Texas Project Units 1 and 2 with Westinghouse Delta (A) 94 steam generators. The Unit I steam I generators are scheduled to be replaced at the end of Cycle 9, currently planned for spring,2000. '

The schedule for the Unit 2 replacement is the end of Cycle 9, currently planned for 2002.

Currently, Technical Specification 5.4 includes a description of the design pressure, temperature j and volume of the Reactor Coolant System. The repla:ement A94 steam generators increase the i Reactor Coolant System v clume. The description of the Reactor Coolant System is beyond the criteria of 10CFR50.36(c)(4) for inclusion of Design Features in the Technical Specifications.

Relocation of Specification 5.4 to the UFS AR will allow licensee control of any future changes to the description of the Reactor Coolant System design features in accordance with 10CFR50.59 and 50.71. The proposed amendment is consistent with NUREG-1431 Standard Technical t

Specifications, Westinghouse Plants.

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Additional changes to the South Texas Project Technical Specifications, other than those identifieu (N

herein, will be required to support the modifications associated with the replacement steam HTWPWL\NRC-WKTTsC-98\TsC 217. Doc STI 30631399 9007140352 90070648 DR ADOCK O y

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generators. Separate submittals will addmss those other changes as described in the referenced letter.

STPNGC has reviewed the proposed amendment pursuant to 10CFR50.92 and determined that it does not involve a significant hazards consideration. In addition, STPNOC 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 Project Plant Operations Review Committee and the Nuclear Safety Review Board have reviewed and approved the proposed amendment.

The proposed amendment consists of the following attachments:

a. Affidavit,

b. Description, justification and safety evaluation,

c. No Significant Hazards Determination, and

d. Marked-up affected pages of the Technical Specifications.

' In accordance with 10CFR50.91(b), STPNOC is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments.

STPNOC requests that this proposed emendment be reviewed and approved prior to November 1999 with a 30 day implementation period to support the replacement of the Unit 1 steam generators.

If there are any questions regarding the proposed amendment, please contact Mr. M. A. McBurnett at (512) 972-7206 or me at (512) 972-8787.

. H. Clon' er  ;

Vice Pre ' dent, ucle Engineering i bjs/

I Attachments: i

~ A. Affidavit for Proposed Amendment

-l B. Description of Proposed Amendment and Safety Evaluation i C. Determination of No Significant Hazards

- D. Proposed Changes to Technical Specifications IH AWPWLWRC.WK\TsC-98\TsC_217. doc STI: 30631399

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NOC-AE-00187 Page 3 of 3 1

cc:

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 76011-8054 San Antonio,TX 78205-3692' Thomas W. Alexion Institute of Nuclear Power Operations

Project Manager, Mail Code 13H3 Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957

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David P. Loveless Richard A.Ratliff

Senion Resident Inspector Bureau of Radiation Control U. S. Nuclear Regulaton 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.

I800 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

- J. C. Lanier/A. Ramirez - U. S. Nuclear Regulatog Commission City of Austin Electric Utility Department Attention: Document Control Desk 72,1 Barton Springs Road Washington, DC 20555-0001 Austin,TX 78704 I

- IHAWPiNL\NRC.WK\TsC4BiTsC 217. DOC STI. 30631399 I

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4 ATTACHMENT A AFFIDAVIT FOR PROPOSED AMENDMENT IH AWPNL\N RC-WK\T SC-98iTSCJ 17. DOC STI 30631399 l'

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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STP Nuclear Operating Company ) Docket Nos. 50-498

) 50499 l South Texas Project Units 1 & 2 ) I AFFIDAVIT I, T. H. Cloninger, being; duly sworn, hereby depose and say that I am Vice President, Nuclear Engineering, of STP Nuclear Operating Company; that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached proposed amendment to the Technical Specifications; that I am familiar with the content thereof; and that the matters set fonh therein are true and correct to the best of my knowledge and belief.  ;

br> - l T H. Cloni er Vice Pres' ent, clear ngineering 4

STATE OFTEXAS )

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COUNTY OF MATAGORDA )

T Subscribedyu day of V Id swern to before me, a Notary Public in and for the

,1998.

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Notary Public in and for the State of Texas HAWPNL\NRC-WK\TsC 98\TSC_217. Doc STI: 30631399 L- --- - __ -- - - - - - - - - - - - - -- -- - --- - - - - - - - - - - - - - - - - - - - - - - -

4 e ATTACHMENT B DESCRIPTION OF PROPOSED AMENDMENT AND SAFETY l EVALUATION I 1

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, NOC-AE-00187 Attachment B Page 1 of 3 DESCRIPTION OF PROPOSED AMENDMENT AND SAFETY EVALUATION i l

BACKGROUND STPNOC intends to replace the original Westinghouse Model E steam generators in South Texas Project Units 1 and 2 with Westinghouse Delta (A) 94 steam generators. The Unit I steam generators are scheduled to be replaced at the end of Cycle 9, currently planned for spring,2000. .

The schedule for the Unit 2 replacement is the end of Cycle 9, currently planned for 2002. I I

Currently, Technical Specification 5.4 includes a description of the design pressure, temperature

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and volume of the Reactor Coolant System. The replacement A94 steam generators will increase j the Reactor Coolant System volume. Relocation of Specification 5.4 to the Updated Final Safety l Analysis Report (UFSAR) will allow licensee control of any future changes of the Reactor j Coolant System design features description in accordance with 10CFR50.59 and 50.71. I

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DESCRIPTION OF PROPOSED AMENDMENT i

The proposed amendment will relocate the description of the Reactor Coolant System design features from Technical Specification 5.4 to the Updated Final Safety Analysis Report. The text of Specification 5.4 will be replaced by the term "(Not Used)".

SAFETY EVALUATION The UFSAR currently reflects the Reactor Coolant System design pressure, temperature, and volume associr.ted with the existing Model E steam generators. Table 1 provides a correlation f

1 between the Reactor Coolant System design features listed in the current Specification 5.4 and the l existing UFSAR. Relocation of Specification 5.4 to the UFSAR will provide for the control and maintenance of changes to the Reactor Coolant System description by STPNOC ir. accordance with 10CFR50.59 and 50.71.

At this time, no changes to the UFSAR are required. The UFSAR will be revised to reflect the l

increased Reactor Coolant System volume associated with the A94 steam generators in accordance l with the requirements of 10CFR50.59 and 50.71 upon the implementation of the replacement steam generator modifications. Existing South Texas Project procedures ensure that any future changes to the facility as described in the UFSAR, including the replacement of the steam generators, are reviewed to determine if an unreviewed safety question exists. j l

! The Reactor Coolant System description is beyond the criteria of 10CFR5036(c)(4) for inclusion of Desiga Features in the Technical Specifications. Relocation of the Reactor Coolant System i

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NOC-AE-00137 Attachment B Page 2 of 3 des,ign feat;ures to the UFSAR is consistent with NUREG-1431, Standard Technical Specifications, Westinghouse Plants. In addition, the actual regulatory requirements of the Reactor Coolant System and related components still remain in Section 3/4.4 of the Technical Specifications. Therefore, relocation of the Reactor Coolant System design features to the UFSAR is considered acceptable.

Due to the schedule for replacement of the steam generators in both units, South Texas Project will, for a time, have two different model steam generators, and each South Texas Project unit will have its own unique Reactor Coolant System volume. The additional information would add complexity to the Technical Specifications that can be more readily described in the UFSAR.

The addition of this complexity to the Technical Specification is not warranted because describing Reactor Coolant System design features in the Technical Specifications is not required j by NUREG-1431.

l The South Texcs Project UFSAR will require extensive changes to reflect the installation of the A94 steam generators. Because South Texas Project will be operating with two different steam generator models for a period of time, the UFSAR will reflect both the A94 and Model E steam generators. STPNOC plans to provide one complete mark up of the UFSAR in a later submittal rather than identifying individual UFSAR changes for each licensing submittal.

IMPLEMENTATION STPNOC requests that this proposed amendment be reviewed and approved prior to November 1999 with a 30 day implementation period to support the replacement of the Unit 1 steam generators.

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NOC-AE-00187 Attachment B Page 3 of 3

. TABLE 1 COMPARISON OF SPECIFICATION 5.4 TO EXISTING UFSAR SPECIFICATION CORRESPONDING UFSAR SECTION 5.4.1. The Reactor Coolant system is designed and shall be maintained:

a. In accordance with the Code Section 5.2 provides a discussion of the Code requirements specified in Section 5.2 of requirements the UFSAR, with allowance for normal degradation pursuant to the applicable Surveillance Requirements,

b. For a pressme of 2485 psig, and Various sections of the UFSAR describe the design presr re of the Reactor Coolant System.

Two examples are Table 5.3-2 and Table 5.4-5.

c. For a temperature of 650 F, except for Various UFSAR Sections discuss the design the pressurizer which is 680 F. temperature of the Reactor Coolant System and pressurizer. Two examples for the Reactor Coolant System are Table 5.3-2 and Table 5.4-5.

For the pressurizer, two examples are Section 3.9.3.3.1.1 and Table 5.4-9.

5.4.2 The total water and steam volume UFSAR Section 5.1.1 refers to Table 5.1-I for of the Reactor Coolant System is the total Reactor Coolant System vobme.

between 13,364 and 13,914 cubic feet at a nominal To, of 561 F.

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ATTACHMENT C DETERMINATION OF NO SIGNIFICANT HAZARDS i

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NOC-AE-00107 Attachment C Page1of1 DETERMINATION OF NO SIGNIFICANT HAZARDS The proposed amendment will relocate the description of the Reactor Coolant System design features from Technical Specification 5.4 to the Updated Final Safety Analysis Report. In accordance with the criteria provided in 10CFR50.92, STPNOC has evaluated the proposed change and concluded that a significant hazard does n exist. In support of this conclusion, the following evaluation is provided:

1. The proposed change does not involve a significant increase in the probability or consequences of an ace! dent previously evaluated.

The proposed change relocates the description of the Reactor Coolant System design features to the Updated Final Safety Analysis Report (UFSAR), a licensee-controlled document. The description of the Reactor Coolant System design features, currently a part of the UFSAR, is maintained in accordance with 10CFR50.59 and 50.71. Existing South Texas Project 1 procedores ensure that changes to the facility as described in the UFSAR, such as the replacement of the steam generators, are reviewed to determine if an unreviewed safety question exists. The proposed amendment does not result in any hardware or operating procedure changes. The initiators of any accident previously evaluated are not affected by the l

relocation of the Reactor Coolant System design features. Therefore, the proposed change  !

does not involve a significant increase in the probability or consequences of an accident '

previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of i accident from any accident previously evaluated.

The change does not alter the plant configuration or make changes in the methods governing plant operation. The proposed change does not impose different requirements, and adequate control ofinformation will be maintained in accordance with existing procedures. The change does not alter assumptions made in the safety analysis and licensing basis. Therefore, the proposed change does not create the possibility of new or different kind of accident.

3. The proposed change does not involve a significant reduction in a margin of safety.

The relocation of a description of Reactor Coolant System design features has no impact on any safety analysis assumptions. There are no changes to the plant configuration or operating procedures. Future changes to the relocated information are governed by existing procedures in accordance with 10CFR50.59 and 50.71. Consequently, there is no significant reduction in a margin of safety.

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