NOC-AE-08002301, Withdrawal of Proposed Exception to Technical Specification 6.8.3.p.3, Control Room Envelope Habitability Program

Withdrawal of Proposed Exception to Technical Specification 6.8.3.p.3, Control Room Envelope Habitability Program

ML081720131
Person / Time
Site:	South Texas
Issue date:	05/27/2008
From:	Bowman C South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-08002301, TAC MD5942, TAC MD5943
Download: ML081720131 (6)

Text

Nuclear Operating Company South Texas Procd Electric Generatin$Station PO. Box 289 Wadsworth, Texas 77483 ,A/\-

May 27, 2008 NOC-AE-08002301 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units I and 2 Docket Nos. STN 50-498 and STN 50-499 Withdrawal of Proposed Exception to Technical Specification 6.8.3.p.3, Control Room Envelope (CRE) Habitability Program TAC Nos. MD5942 and MD5943

Reference:

1. Letter from Charles T. Bowman to NRC Document Control Desk dated June 26, 2007, "Proposed Revision to Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process" (NOC-AE-07002165)

2. Letter from Charles T. Bowman to NRC Document Control Desk dated April 29, 2008, "Response to Request for Additional Information on Proposed Revision to Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (TAC Nos. MD5942 AND MD5943) (NOC-AE-08002292)

In reference 1, the STP Nuclear Operating Company (STPNOC) submitted a license amendment request to revise Technical Specifications by incorporating TSTF-448 for control room envelope habitability. In reference 2, STPNOC responded to a request for additional information on proposed TS 6.8.3.p, "Control Room Envelope (CRE) Habitability Program", by agreeing to withdraw a requestedexception to Sections C.1 and C.2-of Regulatory Guide 1.197, Revision 0. This letter withdraws that exception, which stated:

1). C. - Section 4.3.2 "Periodic CRH Assessment " from NEI 99-03 Revision 1 will be used as input to a. site specific Self Assessment procedure.

No other changes are being proposed to Reference 1 by this letter. Replace pages 4 and 5 of of Reference 1 with pages 1 and 2 of the Attachment to this letter. There are no commitments in this letter.

STI: 32308248 . ,

NOC-AE-08002301 Page 2 of 3 If you have any questions, please call Ted Koser at 361-972-8963 or me at 361-972-7454.

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

Executed on Charl-es Charles T Boma T. Bowman

<-b)ate ' General Manager, Oversight tck/

Attachment:

Proposed Technical Specification Changes (Mark up)

NOC-AE-08002301 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 612 East Lamar Blvd, Suite 400 Arlington, Texas, 76011-4125 Mohan C. Thadani U. S. Nuclear Regulatory Commission Mohan C. Thadani Thad Hill Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 7 D1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN1 16 Kevin Pollo Wadsworth, TX 77483 City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189

NOC-AE-08002301 PROPOSED TECHNICAL SPECIFICATION CHANGES (Mark-up)

NOC-AE-08002301 Page 1 of 2 6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3.o. (continued)

3. Ifcrack indications are found in any SG tube, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e. Provisions for monitoring operational primary-to-secondary leakage.

.3p. .Control Room Envelope Habitability Pro-gram Cdontrol Room Envelope (CRE) Habitability Program shall be established *anid

,implemented to ensure that CRE habitability is maintained such thatj with an'

'OPERABLE Control Room Makeup and Cleanup Filtration System, CRE occupaiiit can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The programishall ensure that adequate radiation protection is rprovided to permi taccess and occupancy-of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excessof 5 rem total dose equivalent (TEDE) for the duration of the accident. The prqgram

'shall include the followingelements:

iQThedefinition of the CRE and the CRE b~oundar~y.

'2. BRequirements for maintining the CRE bou ndaryin its design condition including configurationcontrol and preventive maintenance.

3sequirementsfor (i,)determining the unfiltered air inleakage/ past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies= specified in Sections C*. andC.2 of.Regulatory Guide 1.197, "'Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May, 2003, and (ii) assessing~~ CREhiab~itability at th~e Frequencies specfied ections CAl and C.2 of Regulatory Guide 1.197, Revision~0.

The following are exceptions to Sections CA and C.2 of Regulatory G ujide 1.197, Revision 0-:

~IDL112 .'peer reviews are__required to be performed.

SOUTH TEXAS - UNITS 1 .& 2 6-12c Unit 1 - Amendment No. 4-68 Unit 2 - Amendment No. 4-57

NOC-AE-08002301 Page 2 of 2 6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3.p_ _(qcontinued) 4_.7 Maueet tdsgae locations, of the CRE pressure relative to all-external areas adjacent to the CRE boundary during the pressurization mode of operation by two trains of the Control Room Makeup and Cleanup Filtration System, operating at the flow rate required by the Surveillance Requirement 4.7.7.c.3, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall.be trended and used as part of theý18 month assessment of the CRE boundary. _

5. The quantitative limits on unfiltered air inldakage into the CRE..

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph 3. The unfiltered air'inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequiences.Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE

,occupants to these hazards will be within the assumptions in the lic~ensing basis. .... ..................

6% Teeprovsinsof SR 3.0,2are appicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paraftraphs 3 and 4, respectively.

SOUTH TEXAS - UNITS- 1 & 2 6-12d Unit 1 - Amendment No. 1-68 Unit 2 - Amendment No. 4-57