ML20247M114

Forwards Request for Addl Info Re Proposed License Amend to Convert to Format of Improved Standard TSs for South Texas Projects,Units 1 & 2.Addl Info Needed in Sections 3.0 & 3.5

ML20247M114
Person / Time
Site:	South Texas
Issue date:	05/20/1998
From:	Alexion T NRC (Affiliation Not Assigned)
To:	Cottle W HOUSTON LIGHTING & POWER CO.
References
TAC-M95529, TAC-M95530, NUDOCS 9805260177
Download: ML20247M114 (6)

Text

, Mr. William T. Cottle May 20,1998 President and Chief Executiva Officer STP Nuclear Operating Company i South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SOUTH TEXAS PROJECT, UNITS 1 AND 2 (STP) (TAC NOS. M95529 AND M95530)

Dear Mr. Cottle:

The Nuclear Regulatory Commission (NRC) staff is reviewing STP Nuclear Operating Company's (STPNOC's) proposed license amendment to convert to the format of the Improved Standard Technical Specifications (ISTS). STPNOC provided a major supplement to the proposed license amendment (Supplement 1) by letter dated July 22,1997.

The staff has reviewed selected portions of the application and its supplements. Based on its review, the staff has determined that additional information is needed in Sections 3.0 and 3.5, as discussed in the enclosure.

Also, per STPNOC's request by letter dated April 29,1998, to defer any further review of the ISTS application until it can be reactivated in support of a 2001 implementation date, and per discussions with your staff on April 30,1998, it was agreed thai .he NRC staff will issue questions for those sections where NRC's preliminary review is completed or nearly completed.

These Sections are 3.0,3.5, and 3.7 (3 train questions only). As this letter is providing questions for Sections 3.0 and 3.5, questions for Section 3.7 will be provided at a later date.

If you have any questions regarding the enclosed request for additional information or with the agreement discussed above, please contact me at (301) 415-1326.

Sincerely, ,

ORIGINAL SIGNED BY:

Thomas W. Alexion, Project Manager Project Directorate IV-1 9805260177 980520 Division'of Reactor Projects Ill/IV PDR ADOCK 05000498 Office of Nuclear Reactor Regulation P PDR ,

Docket Nos. 50-498 and 50-499

Enclosure:

As stated cc w/ encl: See next page ,

DISTRIBUTION:

Docket File PUBLIC PD4-1 r/f hh ["p {i*T"7m aq, EAdensam (EGA1) JHannon CHawes TAlexion OGC ACRS TGwynn, RIV WBeckner  ;

Document Name: STP95529.LTR '

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May 20,1998 l Mr. William T. Cottle President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station ,

P. O. Box 289 Wadsworth,TX 77483

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SOUTH l TEXAS PROJECT, UNITS 1 AND 2 (STP) (TAC NOS. M95529 AND M95530)

Dear Mr. Cottle:

l I' The Nuclear Regulatory Commission (NRC) staff is reviewing STP Nuclear Operating Company's (STPNOC's) proposed license amendment to convert to the format of the Improved Standard Technical Specifications (ISTS). STPNOC provided a major supplement to the proposed license amendment (Supplement 1) by letter dated July 22,1997. l The staff has reviewed selected portions of the application and its supplements. Based on its review, the staff has determined that additional information is needed in Sections 3.0 and 3.5, as discussed in the enclosure.

l Also, per STPNOC's request by letter dated April 29,1998, to defer any further review of the ISTS application until it can be reactivated in support of a 2001 implementation date, and per i discussions with your staff on April 30,1998, it was agreed that the NRC staff will issue l questions for those sections vyhere NRC's preliminary review is completed or nearly completed.

These Sections are 3.0, 3.5, and 3.7 (3 train questions only). As this letter is providing questions for Sections 3.0 and 3.5, questions for Section 3.7 will be provided at a later date.

If you have any questions regarding the enclosed request for additional information or with the I agreement discussed above, please contact me at (301) 415-1326.

Sincerely, l

/ f r W

WWl -

Thomas W. Alexion, Project Manager i Project Directorate IV-1 Division of Reactor Projects lil/lV office of Nuclear Reactor Regulation l Docket Nos. 50 498 and 50-499

Enclosure:

As stated

, cc w/ encl: See next page o

l

)

Mr. Willi:m T. Cottle i STP Nuclear Operating Company South Texas, Units 1 & 2 1 1 cc:

Mr. David P. Loveless Jack R. Newman, Esq.

Senior Resident inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1800 M Street, N.W.

P. O. Box 910 Washington, DC 20036-5869 l Bay City, TX 77414 Mr. Lawrence E. Martin A. Ramirez/C. M. Canady Vice President, Nuc. Assurance & Licensing City of Austin STP Nuclear Operating Company Electric Utility Ospartment P. O. Box 289 721 Barton Springs Road Wadsworth, TX 77483 Austin, TX 78704 Office of the Govemor Mr. M. T. Hardt ATTN: John Howard, Director Mr. W. C. Gunst Environmental and Natural City Public Service Board Resources Policy P. O. Box 1771 P. O. Box 12428 l San Antonio, TX 78296 Austin, TX 78711 )

Mr. G. E. Vaughn/C. A. Johnson Jon C. Wood Central Power and Light Company Matthews & Branscomb P. O. Box 289 One Alamo Center l Mail Code: N5012 106 S. St. Mary's Street, Suite 700 l Wadsworth, TX 74483 San Antonio,TX 78205-3692 INPO Arthur C. Tate, Director ,

Records Center Division of Compliance & Inspection  !

700 Galleria Parkway Bureau of Radiation Control Atlanta, GA 30339-3064 Texas Department of Health 1100 West 49th Street Regional Administrator, Region IV Austin,TX 78756 U.S. Nuclear Regulatory Commission '

611 Ryan Plaza Drive, Suite 400 Jim Calloway I Arlington, TX 76011 Public Utility Commission of Texas Electric Industry Analysis D. G. Tees /R. L. Balcom P. O. Box 13326 Houston Ughting & Power Co. Austin, TX 78711-3326 P. O. Box 1700 Houston, TX 77251 Judge, Matagorda County .

Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414

g REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATIONS CONVERSION APPLICATION SOUTH TEXAS PROJECT. UNITS 1 AND 2 Section 3.0. Limitina Condition for Operation (LCO) and Surveillance Requirement (SR)

Acolicability 3.0 NUREG Markup

1. JFD 9 (Bases JFD 10) states that the elimination of LCO and SR 3.0.4 in other than Modes 1- 4 are not selected for implementation at STP. As a result of this position portions of LCO 3.0.4 are deleted on pages 3.0-2,3.0-5, B3.0-6, B3.0-14, and B3.0-15 of the NUREG markup. The STP position which results in deleting portions of LCO and SR 3.0.4 is not acceptable. The STP should revise the ITS to include the deleted portions of LCO and SR 3.0.4 and review existing TS to determine where specific restrictions on Mode changes or Required Actions should be included in the individual LCOs.

2. JFD 5 (Bases JFD 5) adds LCO 3.0.8 and SR 3.0.5 to reflect the current licensing l basis / technical specifications for STP. We agree with the concept to provide instructions  !

for applying all or parts of TS to a single unit for combined unit TS. We pmpose a slightly different approach that relies on the addition of an LCO 3.0.8 requirement without use of l SR 3.0.5. The attemate proposal for LCO 3.0.8 is the following: j LCO 3.0.8 Unless specifically noted, all the information provided in the LCO including the associated ACTION requirements shall apply to each unit individually.

In those cases where a specification makes reference to systems or components which are shared by both units, the affected systems or components will be clearly identified in parentheses or footnotes declaring ,

the reference to be " common." Whenever the LCO refers to systems or components which are common, the ACTION requirements will apply to both units simultaneously. (This will be indicated in the ACTION section.)

Whenever certain portions of a specification refer to' systems, components, operating parameters, setpoints, etc., which are different for each unit, this will be identified in parentheses or footnotes or in the Applicability section as appropriate.

3. Bases J! D 8 modifies the STS to apply TSTF-08. TSTF-08, Rev 2 is the approved j version of the original proposal. Modifications from Rev 2 are not applied to the STP Bases markup. Provide a revised markup that includes the changes approved in TSTF-l 08 Rev 2.

I

4. Bases JFD 9 modifies the STS to apply TSTF-52. Insert SR 3.0.2 is included as part of l the Bases markup. Delete insert 3.0.2 because it makes changes to approved TSTF-52.

l t

h ENCLOSURE

1 CTS 3.0 Markuo

5. DOC A.2 states that inclusion of LCO 3.0.7 in LCO 3.0.1 is part of the changes made to CTS without stating why CTS requirements are essentially unchanged with this addition.

6. Revise DOC A.5, as required, to reflect conformance to NUREG-1431 LCO and SR 3.0.4.

7. DOCS L.1 and M.2 are used to Justify changes to CTS SR 4.0.3. L1 does not clearly identify the less restrictive change proposed for the iTS and L.1 does not specifically provide a statement to explain why the proposed L1 change is safe.

Section 3.5. Emeroency Core Coolina Systems Section 3.5.1 No comments Section 3.5.2 Questions already provided by NRC letter dated March 5,1998.

Section 3.5.3

1. The changes to the

• Note of CTS 4.5.3.1.2 when it was paraphrased as Note 2 are less restrictive and not administrative. CTS allows an inoperable HHSI pump to be energized for testing or filling the accumulators if the pump is isolated from the RCS. The ITS wording of the Note would allow an operable pump to be used in this manner. This is a change to the manner in which the plant is operated, and is, therefore, not an administrative change.

2. By deleting the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> limit in the

• Note for CTS LCO 3.5.3.1.a, but retaining the 325 degrees F and 225 degrees F temperature relaxations, hvo temperature bands are created when going from Mode 5 to Mode 4 and from Mode 3 to Mode 4 in which the plant can remain indefinitely without having to comply with the LCO requirements. Since the STS does not have the same temperature band allowance, and since the licensee did not adopt its current licensing basis, this change is beyond scope.

3. The

• Note that applies to CTS LCO 3.5.3 specifies a maximum of one HHSI pump shall be operable and a second HHSI pump shall be operable except that its breaker shall be racked out. In addition, the third HHSI pump shall have its breaker racked out. This note was adapted to the ITS 3.5.3 LCO. However, the work maximum was not retained. Per the ITS LCO,2 trains shall be operable with one HHSI pump breaker racked in. This LCO does not limit the number of HHSI pumps that may have their breaker racked in as the CTS does. Note 1, for approaching Mode 4 from Mode 3 specifies that until one or more RCS cold legs is less than 325 degrees F, more than one HHSI pump breaker may be racked in. This Note restricts the number of HHSI pump breakers that may be racked i in once 325 degrees F is reached, and appears satisfactory. However, Note 3, for j

approaching Mode 4 from Mode 5, specifies that all HHSI pump breakers may be racked out until one or more RCS cold legs is greater than 225 degrees F. Since there are no maximum HHSI pump breaker restrictions in the LCO or Note 3, following an approach to Mode 4 from Mode 5, once the 225 degree limit is reached, and while in Mode 4 (when approached from Mode 5) all HHSI pump breakers could be racked in. The change in wording of the CTS

• Note is beyond scope and is not an administrative change.

Section 3.5.4 No comments l

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