NOC-AE-05001901, Proposed Amendment to Technical Specification 4.0.5 for Applicability of Surveillance Requirements

Proposed Amendment to Technical Specification 4.0.5 for Applicability of Surveillance Requirements

ML051940288
Person / Time
Site:	South Texas
Issue date:	07/04/2005
From:	Halpin E South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-05001901
Download: ML051940288 (10)

Text

Nuclear Operating Company nadh Icw d Akdrk GndeUnmStaton P.C &w28.9 adsnnrth, T 77483 we July 4, 2005 NOC-AE-05001901 File No.: G25 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, STN 50-499 Proposed Amendment to Technical Specification 4.0.5 for Applicability of Surveillance Requirements Pursuant to 10CFR50.90, the STP Nuclear Operating Company (STPNOC) requests Nuclear Regulatory Commission (NRC) approval of an amendment to Unit 1 Operating License NPF-76 and Unit 2 Operating License NPF-80. The proposed changes affect Technical Specification 4.0.5, "Applicability - Surveillance Requirements."

Technical Specification 4.0.5 requires inservice inspection and testing of ASME Code Class 1, 2, and 3 components in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code except where relief has been approved by the NRC. The proposed change adds a reference to the NRC-approved exemption of selected pumps, valves, and other components from special treatment requirements. As an editorial change, references to 10CFR50.55a(f) and 10CFR50.55a(f)(6)(i) are added to the paragraph for inservice testing, similar to the existing references for inservice inspection.

STPNOC has reviewed the attached 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.

A safety evaluation of the proposed change and the proposed revised pages of the Technical Specifications are included as attachments to this letter. The Plant Operations Review Committee has reviewed this amendment request and recommended it for approval. In accordance with 10CFR50.91(b), STPNOC is providing the State of Texas with a copy of this proposed amendment.

There are no commitments made in this Technical Specification change application.

STPNOC requests NRC review and approval of the proposed change by September 30, 2005, to support implementation of changes to surveillance and test procedures. STPNOC requests 90 days following approval by the NRC to allow for updating of affected documentation.

If there are any questions, please contact either Mr. P. L. Walker at 361-972-8392 or me at 361-972-7849.

STI: 31897203 A q ) T Project Manager on Behalf of the Participants in the South Texas Project

NOC-AE-05001 901 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on X el  ?

1.2 a gg :S Edward D. alpin Vice President, Oversight PLW Attachments: 1) Licensee Evaluation

2) Proposed Technical Specification Changes

NOC-AE-05001 901 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 David H. Jaffe Arlington, Texas 76011-8064 U. S. Nuclear Regulatory Commission Richard A. Ratliff Jon C. Wood Bureau of Radiation Control Cox Smith Matthews Texas Department of Health 1100 West 49th Street C. Kirksey Austin, TX 78756-3189 City of Austin Jeffrey Cruz J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN1 16 E. Alarcon Wadsworth, TX 77483 City of San Antonio C. M. Canady Jack A. Fusco City of Austin Michael A. Reed Electric Utility Department Texas Genco, LP 721 Barton Springs Road Austin, TX 78704

NOC-AE-05001 901 ATTACHMENT 1 SOUTH TEXAS PROJECT LICENSEE EVALUATION PROPOSED AMENDMENT TO TECHNICAL SPECIFICATION 4.0.5 FOR APPLICABILITY OF SURVEILLANCE REQUIREMENTS

1.

SUMMARY

2. PROPOSED CHANGES

3. BACKGROUND

4. TECHNICAL ANALYSIS

5. REGULATORY ANALYSIS 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements 5.3 Analysis

6. ENVIRONMENTAL CONSIDERATION

7. IMPLEMENTATION

Attachment 1 NOC-AE-05001901 Page 1 of 4 LICENSEE EVALUATION 1.0

SUMMARY

STPNOC proposes to revise the Technical Specifications for Unit 1 Operating License NPF-76 and Unit 2 Operating License NPF-80. The proposed changes affect Technical Specification 4.0.5, "Applicability - Surveillance Requirements."

Technical Specification 4.0.5 requires inservice inspection and testing of ASME Code Class 1, 2, and 3 components in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code except where relief has been approved by the NRC. The proposed change adds a reference to the NRC-approved exemption of selected pumps, valves, and other components from special treatment requirements. References to paragraphs 10CFR50.55a(f) and 10CFR50.55a(f)(6)(i) are also added to include the regulatory criteria for inservice testing similar to the existing references for inservice inspection [10CFR50.55a(g) and 10CFR50.55a(g)(i)].

2.0 PROPOSED CHANGE

S

• Surveillance Requirement 4.0.5.a currently states:

Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(i);

• The revised surveillance requirement will state:

Inservice testing of ASME Code Class 1, 2, and 3 pumps and valves, and inservice inspection of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a(f) and Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(f)(6)(i) or Section 50.55a(g)(6)(i), or where the component has been found to qualify for exemption from special treatment; In addition, uinservice testing" and "inservice inspection" are reordered for consistency with the sequence of the regulations in 10CFR50.55a.

3.0 BACKGROUND

By correspondence dated August 3, 2001, "Safety Evaluation on Exemption Requests from Special Treatment Requirements of 10 CFR parts 21, 50, and 100 (TAC Nos.

MA6057 and MA 6058)," the NRC approved a request from the South Texas Project to exempt selected components from special treatment requirements. The exemption releases some components from regulations that impose controls intended to ensure the quality of components that are safety-related, important to safety, or otherwise within the scope of the regulations. Specifically, Parts 21, 50, and 100 contain special treatment requirements that go beyond normal commercial and industrial practices, and include quality assurance requirements, environmental and seismic qualification requirements, inspection and testing requirements, and Maintenance Rule requirements. The scope of

Attachment 1 NOC-AE-05001 901 Page 2 of 4 these regulations includes some components with little or no significance regarding safety or risk.

The Graded Quality Assurance program at STPNOC includes a risk-informed process for determining the safety/risk significance of structures, systems, and components.

Using this process, certain safety-related components in the plant were determined to be of "low safety significance" or "non-risk significant". The exemption excludes components with low safety significance and non-risk significant components from the scope of regulations imposing special treatment requirements.

4.0 TECHNICAL ANALYSIS

Surveillance Requirement 4.0.5 includes "specific written relief' consistent with 10CFR50.55a(g)(6)(i) as a criterion for not performing ASME Section Xl inservice inspection and inservice testing. The exemption granted in 2001 is not directed at a specific component as would relief from an ASME Code Section XI requirement.

However, the exemption is consistently applied to defined classes of components using consistent criteria for classification. Inclusion of the reference in 4.0.5 has no actual impact on current testing and inspection practices. This is an administrative change to more accurately describe the current practices being followed at STPNOC.

Addition of references to 10CFR50.55a(f) in parallel with 10CFR50.55a(g) is an administrative change to provide a complete set of relevant sources for regulatory requirements.

The proposed changes will not adversely affect nuclear safety or continued safe plant operation.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Pursuant to 10CFR50.91, this analysis provides a determination that the proposed change to the Technical Specifications does not involve any significant hazards consideration as defined in 10CFR50.92, as described below:

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

No. Including the reference to the exemption in the Technical Specifications establishes consistency between the surveillance requirements for inservice inspection and testing and the exemption as approved by the NRC. There are no changes in the inspection and testing procedures as a result of adding the reference because the exemption already removes low safety significance and non-risk significant components from the requirements for special treatment. The proposed changes are administrative in nature and do not have a significant adverse effect on plant operation or personnel safety. Consequently, the changes will not affect the probability or consequences of an accident previously evaluated.

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

No. Including the reference to the exemption in the Technical Specifications establishes consistency between the surveillance requirements for inservice inspection and testing and the exemption as approved by the NRC. There are no changes in the inspection and testing procedures as a result of adding the reference

Attachment 1 NOC-AE-05001 901 Page 3 of 4 because the exemption already removes low safety significance and non-risk significant components from the requirements for special treatment. The proposed changes are administrative in nature and do not have a significant adverse effect on plant operation or personnel safety. Consequently, the changes do not create the possibility of a new or different kind of accident from any previously evaluated.

. Does the proposed change involve a significant reduction in a margin of safety?

No. Including the reference to the exemption in the Technical Specifications establishes consistency between the surveillance requirements for inservice inspection and testing and the exemption as approved by the NRC. There are no changes in the inspection and testing procedures as a result of adding the reference because the exemption already removes low safety significance and non-risk significant components from the requirements for special treatment. The proposed changes are administrative in nature and do not have a significant adverse effect on plant operation or personnel safety. Consequently, the changes do not significantly reduce a margin of safety.

Based on the above evaluation, STPNOC concludes that the proposed changes present no significant hazards consideration under the standards set forth in 10CFR50.92(c),

and accordingly, a finding of "no significant hazards consideration' is justified.

5.2 Applicable Regulatory Requirements 10CFR50.55a(f) - Inservice testing of pumps and valves under ASME Section Xl 10CFR50.55a(g) - Inservice inspection of components under ASME Section Xl 5.3 Analysis 10CFR50.55a applies the criteria of ASME Section XI for inservice testing of pumps and valves and inservice inspection of components. The Technical Specifications implement the specific actions needed to meet the criteria under 10CFR50.55a. Provision has already been made for obtaining relief from specific Section XI criteria. Similarly, the NRC has approved the exemption from special treatment where qualified. This is an administrative change and does not affect current practices at STPNOC.

Based upon the considerations discussed above:

• There is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner;

• Such activities will be conducted in compliance with the Commission's regulations; and

• Issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

STPNOC has reviewed the proposed amendment and determined the proposed changes to the Technical Specifications do not involve:

• A significant hazards consideration;

. A significant change in the types or significant increase in the amounts of any effluent that may be released offsite; or

Attachment 1 NOC-AE-05001 901 Page 4 of 4 A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendments meet the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment is required to be prepared in connection with these proposed changes.

7.0 IMPLEMENTATION STPNOC requests NRC review and approval of the proposed change by September 30, 2005, to support implementation of changes to surveillance and test procedures.

STPNOC requests 90 days following approval by the NRC to allow for updating of affected documentation.

NOC-AE-05001 901 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

Failure to meet a. Surveillance Requirement, whether such a failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Conditions for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4.0.2), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, arid the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met and the applicable Condition(s) must be entered.

4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the Surveillance Requirement(s) associated with the LCO have been met within their specified Frequency, except as provided by Specification 4.0.3. When an LCO is not met due to Surveillance Requirement(s) not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with Specification 3.0.4. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:

a. neictstinig of ASM toeClas 1,2 'n pumps and valves,:and inservice nspection of ASME Code Class 1 2an 3 components shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, V iona Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 0.55a(f)(6) i) or Section 50.55a(g)(!2(i), rwahrlethecompo t b f tqif or exemption itreatment; SOUTH TEXAS - UNITS 1 & 2 3/4 0-3 Unit 1 - Amendment 21, 95, 141, 115, 170 Unit 2 - Amendment 11, 82, 129, 133, 158