NOC-AE-03001455, Additional Information Regarding Proposed Changes to Administrative Technical Specifications

From kanterella
Jump to navigation Jump to search
Additional Information Regarding Proposed Changes to Administrative Technical Specifications
ML030230455
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 01/15/2003
From: Jordan T
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-03001455, STI: 31542887
Download: ML030230455 (3)
v • d • e


Text

Nuclear Operating Company South T7,s Pr'qtEtsmk CeFric t SngStaton PO. B&w 289 dMIworM,T As 77483 AA January 15, 2003 NOC-AE-03001455 10CFR50.90 STI: 31542887 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Additional Information Regarding Proposed Changes to Administrative Technical Specifications

Reference:

Letter from J. J. Sheppard to NRC Document Control Desk, "Proposed Amendment to South Texas Project Technical Specifications to Revise Administrative Control Requirements," dated November 5, 2001 (NOC-AE-01001146)

In the referenced letter, STP Nuclear Operating Company (STPNOC) submitted a proposed amendment to South Texas Project Operating Licenses NPF-76 and NPF-80. This license amendment request proposed revising various administrative Technical Specifications to be consistent with current industry standards and guidance.

In an e-mail received on January 6, 2003, the NRC stated:

"Please note and provide documentation that item 6.8.3k will be deleted from Section 6.0 'Administrative Control.'

Item 6.8.3k called the Configuration Risk Management Program (CRMP) should be deleted:

(1) Licensees are not required to place the CRMP in the TS Administrative Controls Section since the revision of the maintenance rule. The rule (a)(4) requires a program that could be a CRMP.

(2) However, the STP CRMP does not even come close to the CRMP as described in RG 1.177. The program to implement (a)(4) needs to cover what RG 1.177 specifies to qualify for RI-TS.

Please comment and document response."

NOC-AE-03001455 Page 2 The STP response to these comments is as follows:

Because the additional change proposed by the NRC was not evaluated or justified in the referenced submittal, STP would have to provide an additional Consideration of No Significant Hazards evaluation to address the elimination of Section 6.8.3k. This, in turn would require an additional notification in the Federal Register, would impact the development of the associated Safety Evaluation, and unnecessarily delay review and approval of the amendment.

Furthermore, Section 6.8.3k was added to the STP Technical Specifications as part of a specific amendment (Amendments 85 /72, dated October 31, 1996) and represents the current STP licensing basis. Additionally, Specification 6.8.3k does not conflict with any existing Specification or any revised Specification proposed in the referenced letter.

Therefore, it is our intent to not request the elimination of Specification 6.8.3k as part of the proposed amendment. Rather, STP will propose this change as part of a separate license amendment request, and currently is considering including the elimination of 6.8.3k as part of our Risk Informed Technical Specification license amendment request, scheduled for submittal in the near future as part of an industry pilot program for risk informed Technical Specifications.

If there are any questions regarding the proposed amendment, please contact Mr. J. R. Morris (361) 972-8652 or me at (361) 972-7902.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on Ja1*.,, ic, Z0o3 Date VT. .Jordan Vice President Engineering & Technical Services jrm

NOC-AE-003001455 Page 3 cc:

(paper copy) (electronic copy)

Ellis W. Merschoff A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock/W. C. Gunst Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission Mohan C. Thadani Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP Texas Central Company Cornelius F. O'Keefe Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

Retrieved from "https://kanterella.com/w/index.php?title=NOC-AE-03001455,_Additional_Information_Regarding_Proposed_Changes_to_Administrative_Technical_Specifications&oldid=2678088"