NOC-AE-04001816, License Amendment Request Supplement to Proposed Revision to the Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

License Amendment Request Supplement to Proposed Revision to the Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

ML043490337
Person / Time
Site:	South Texas
Issue date:	12/01/2004
From:	Jordan T Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-04001816, TAC MC1944, TAC MC1945
Download: ML043490337 (10)

Text

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Nuclear Operating Company South Tcxzs Procd Ekdc Gc gStation PO. 8ox2839 f8dUth T= 77483 December 1, 2004 NOC-AE-04001816 10CFR50.90 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 and STN 50-499 License Amendment Request Supplement to Proposed Revision to the Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process

Reference:

Letter from T. J. Jordan, STPNOC, to NRC Document Control Desk, dated February 3, 2004 (NOC-AE-04001668) (TAC Nos. MC1944 / MC1945)

STP Nuclear Operating Company (STPNOC) submitted the referenced proposed amendment to South Texas Project Operating Licenses requesting revision of mode change limitations associated with Technical Specifications 3.0.4 and 4.0.4 consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Traveler number TSTF-359, "Increase Flexibility in Mode Restraints," and the Consolidated Line Item Improvement Process (CLIIP).

The attachment to this letter responds to NRC staff reviewer comments on the proposed change and proposes an additional change to Technical Specification (TS) 3.4.8. A revised TS page 3/4 4-26 is attached. This additional proposed change is consistent with TSTF-359. STPNOC considers this additional proposed change to be bounded by the original licensee evaluation and the No Significant Hazards Determination submitted in the referenced letter remains valid.

The STPNOC Plant Operations Review Committee has reviewed and concurred with the proposed change to the Technical Specifications.

STPNOC is submitting this license amendment request application as a result of a mutual agreement by an industry consortium of six plants known as Strategic Teaming and Resource Sharing (STARS). The STARS group consists of the six plants operated by TXU Energy, AmerenUE, Wolf Creek Nuclear Operating Corporation, Pacific Gas and Electric Company, STPNOC, and Arizona Public Service Company. Each of the STARS plants has or will be submitting a similar license amendment request on a staggered basis.

STI: 318068 16 7 0p

NOC-AE-04001 816 Page 2 of 3 In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this license amendment request by providing a copy of this letter and its attachments.

If there are any questions regarding the proposed amendment, please contact Mr. J. R. Morris at (361) 972-8652 or me at (361) 972-7902 I declare under penalty of perjury that the foregoing is true and correct.

Executed on £Ycf#iq1; 20C 9 Vice President, Engineering & Technical Services jnn/

Attachments:

1. Description of Changes and Safety Evaluation

2. Annotated Technical Specification Page

3. Technical Specification Bases Changes (Information Only)

NOC-AE-04001816 Page 3 of 3 cc:

(paper copy) (electronic copy)

Bruce S. Mallett 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 Arlington, Texas 76011-8064 City Public Service Richard A. Ratliff David H. Jaffe Bureau of Radiation Control U. S. Nuclear Regulatory Commission Texas Department of Health 1100 West 49th Street R. L. Balcom Austin, TX 78756-3189 Texas Genco, LP Jeffrey Cruz A. Ramirez U. S. Nuclear Regulatory Commission City of Austin P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. A. Johnson AEP Texas Central Company C. M. Canady Jon C. Wood City of Austin Matthews & Branscomb Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-04001816 Attachment 1 Page 1 of 6 Attachment 1 Description of Changes and Safety Evaluation

NOC-AE-04001816 Attachment 1 Page 2 of 3 Description of Changes and Safety Evaluation

Reference:

Letter from T. J. Jordan, STPNOC, to NRC Document Control Desk, dated February 3, 2004 (NOC-AE-04001668) 1.0 Description STP Nuclear Operating Company (STPNOC) submitted the referenced proposed amendment to South Texas Project Operating Licenses requesting revision of mode change limitations associated with Technical Specifications 3.0.4 and 4.0.4 consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Traveler number TSTF-359, "Increase Flexibility in Mode Restraints," and the Consolidated Line Item Improvement Process (CLIIP).

The changes proposed in this supplement address NRC staff reviewer comments regarding the original proposed amendment and propose an additional change to Technical Specification (TS) 3.4.8.

2.0 Assessment 2.1 Applicability of Published Safety Evaluation STPNOC has reviewed the safety evaluation dated August 2, 2002, as part of the CLIIP.

This review included the NRC staff evaluation and the supporting information provided to support TSTF-359, Revision 9. STPNOC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to South Texas Project (STP) Units 1 and 2, and justify incorporation of these additional proposed changes into the STP TS.

2.2 Discussion of Proposed Change Based on NRC staff review comments, and in order to improve consistency with Improved Technical Specifications, TSTF-359, and the proposed changes to Specification 3.0.4 documented in the referenced letter, Specification 3.4.8 (Reactor Coolant System - Specific Activity) is being modified to permit the application of TS 3.0.4.c for entry into Modes 1, 2, and 3.

NOC-AE-04001816 Attachment 1 Page 3 of 3 A summary of the proposed change and associated justification, presented in table format, is provided below.

TS Number Descrption D - -- PrpsedChange Jst e fication - - ,

3.4.8 Reactor Coolant System - Added ACTION c. which Provide consistency with Specific Activity states that Specification NUREG-1431 Improved 3.0.4.c is applicable for entry Technical Specifications, into Modes 1, 2, and 3 (with TSTF-359, and associated Tavg greater than or equal to CLIIP guidance.

5000 F) 3.0 Regulatory Analysis 3.1 No Significant Hazards Determination STPNOC has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. STPNOC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to STP and to the additional changes proposed in this letter, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments The plant-specific verifications and commitments in the referenced letter are applicable to the proposed changes to TS 3.4.8 described herein.

The TS Bases for Specification 3.4.8 will be revised to reflect the proposed changes, upon NRC approval of this amendment application.

4.0 Environmental Evaluation STPNOC has reviewed the environmental evaluation included in the model safety evaluation dated August 2, 2002, as part of the CLIIP. STPNOC has concluded that the staff's findings presented in that evaluation are applicable to STP and the additional changes proposed in this letter, and the evaluation is hereby incorporated by reference for this application.

NOC-AE-04001816 Attachment 2 Page 1 of 2 Attachment 2 Annotated Technical Specification Pages

NOC-AE-04001816 Attachment 2 Page 2 of 2 REACTOR COOLANT SYSTEM 3/4.4.8 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the reactor coolant shall be limited to:

a. Less than or equal to 1 microCurie per gram DOSE EQUIVALENT 1-131, and

b. Less than or equal to 100// microCuries per gram of gross radioactivity.

APPLICABILITY: MODES 1, 2, 3, 4, and 5.

ACTION:

MODES 1, 2 and 3*:

a. With the specific activity of the reactor coolant greater than 1 microCurie per gram DOSE EQUIVALENT 1-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval, or exceeding the limit line shown on Figure 3.4-1, be in at least HOT STANDBY with Tavg less than 500OF within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; and

b. With-the gross specific activity of the reactor coolant greater than 100/E microCuries per gram, be in at least HOT STANDBY with Tavg less than 500OF within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

c-Specification 3.O.4.c isappiicabI I

MODES 1, 2,3,4, and 5:

With the specific activity of the reactor coolant greater than 1 microCurie per gram DOSE EQUIVALENT 1-131 or greater than 100/E micro-Curies per gram, perform the sampling and analysis requirements of Item 4.a) of Table 4.4-4 until the specific activity of the reactor coolant is restored to within its limits.

• With Tavg greater than or equal to 500 0F.

SOUTH TEXAS - UNITS 1 & 2 3/4 4-26

NOC-AE-04001816 Attachment 3 Page 1 of 2 Attachment 3 Technical Specifications Bases Changes (Information Only)

NOC-AE-04001816 Attachment 3 Page 2 of 2 Specification 3/4.4.8 (Reactor Coolant System - Specific Activity) Bases

[The following will be added to this Bases section.]

Action c. permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.