Tu Electric Comanche Peak Steam Electric Station, Units 1 and 2; Environmental Assessment and Finding of No Significant Impact

NUCLEAR REGULATORY COMMISSION

[Docket Nos. 50-445 and 50-446]

Tu Electric Comanche Peak Steam Electric Station, Units 1 and 2;

Environmental Assessment and Finding of No Significant Impact

The U.S. Nuclear Regulatory Commission (the Commission) is

considering issuance of an amendment to Facility Operating Licenses No.

NPF-87 and No. NPF-89 that were issued to TU Electric (the licensee)

for operation of the Comanche Peak Steam Electric Station (CPSES),

Units 1 and 2, located in Somervell County, Texas.

Environmental Assessment

Identification of the Proposed Action

The proposed amendment will revise the existing, or current,

Technical Specifications (CTS) for CPSES in their entirety based on the

guidance provided in NUREG-1431, ``Standard Technical Specifications,

Westinghouse Plants,'' Revision 1, dated April 1995, and in the

Commission's ``Final Policy Statement on Technical Specifications

Improvements for Nuclear Power Reactors,'' published on July 22, 1993

(58 FR 39132). The proposed amendment is in accordance with the

licensee's amendment request dated May 15, 1997, as supplemented by

eleven letters in 1998 dated June 26, August 5, August 28, September

24, October 21, October 23, November 24 (two letters), December 11,

December 17, December 18, and three letters in 1999 dated February 3.

The Need for the Proposed Action

It has been recognized that nuclear safety in all nuclear power

plants would benefit from an improvement and standardization of plant

Technical Specifications (TS). The ``NRC Interim Policy Statement on

Technical Specification Improvements for Nuclear Power Plants,'' (52 FR

3788) contained proposed criteria for defining the scope

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of TS. Later, the Commission's ``Final Policy Statement on Technical

Specifications Improvements for Nuclear Power Reactors,'' published on

July 22, 1993 (58 FR 39132), incorporated lessons learned since

publication of the interim policy statement and formed the basis for

revisions to 10 CFR 50.36, ``Technical Specifications.'' The ``Final

Rule'' (60 FR 36953) codified criteria for determining the content of

TS. To facilitate the development of standard TS for nuclear power

reactors, each power reactor vendor owners' group (OG) and the NRC

staff developed standard TS. For CPSES, the Improved Standard Technical

Specifications (ISTS) are in NUREG-1431. This document formed the basis

for the CPSES Improved Technical Specifications (ITS) conversion. The

NRC Committee to review Generic Requirements (CRGR) reviewed the ISTS,

made note of its safety merits, and indicated its support of the

conversion by operating plants to the ISTS.

Description of the Proposed Change

The proposed changes to the CTS are based on NUREG-1431 and on

guidance provided by the Commission in its Final Policy Statement. The

objective of the changes is to completely rewrite, reformat, and

streamline the CTS (i.e., to convert the CTS to the ITS). Emphasis is

placed on human factors principles to improve clarity and understanding

of the TS. The Bases section of the ITS has been significantly expanded

to clarify and better explain the purpose and foundation of each

specification. In addition to NUREG-1431, portions of the CTS were also

used as the basis for the development of the CPSES ITS. Plant-specific

issues (e.g., unique design features, requirements, and operating

practices) were discussed with the licensee, and generic matters with

Westinghouse and other OGs.

This conversion is a joint effort in concert with three other

utilities: Pacific Gas & Electric Company for Diablo Canyon Power

Plant, Units 1 and 2 (Docket Nos. 50-275 and 323); Union Electric

Company for Callaway Plant (Docket No. 50-483); and Wolf Creek Nuclear

Operating Corporation for Wolf Creek Generating Station (Docket No. 50-

482). It was a goal of the four utilities to make the ITS for all the

plants as similar as possible. This joint effort includes a common

methodology for the licensees in marking-up the CTS and NUREG-1431

Specifications, and the NUREG-1431 Bases, that has been accepted by the

staff.

This common methodology is discussed at the end of Enclosure 2,

``Mark-Up of Current TS''; Enclosure 5a, ``Mark-Up of NUREG-1431

Specifications''; and Enclosure 5b, ``Mark-Up of NUREG-1431 Bases,''

for each of the 14 separate ITS sections that were submitted with the

licensee's application. For each of the ITS sections, there is also the

following enclosures:

Enclosure 1, ``Cross-Reference Tables,'' the cross-

reference table connecting each CTS specification (i.e., LCO, required

action, or SR) to the associated ITS specification, sorted by both CTS

and ITS specifications.

Enclosures 3A and 3B, ``Description of Changes to Current

TS'' and ``Conversion Comparison Table,'' the description of the

changes to the CTS section and the comparison table showing which

plants (of the four licensees in the joint effort) that each change to

the CTS applies to.

Enclosure 4, ``No Significant Hazards Considerations,''

the no significant hazards consideration (NHSC) of 10 CFR 50.91 for the

changes to the CTS with generic NHSCs for administrative, more

restrictive, relocation, and moving-out-of-CTS changes, and individual

NHSCs for less restrictive changes and with the organization of the

NHSC evaluation discussed in the beginning of the enclosure.

Enclosures 6A and 6B, ``Differences From NUREG-1431'' and

``Conversion Comparison Table,'' the descriptions of the differences

from NUREG-1431 Specifications and the comparison table showing which

plants (of the four licensees in the joint effort) that each difference

to the ISTS applies to.

The common methodology includes the convention that, if the words in an

CTS specification are not the same as the words in the ITS

specification, but the CTS words have the same meaning or have the same

requirements as the words in the ITS specification, then the licensees

do not have to indicate or describe a change to the CTS. In general,

only technical changes have been identified; however, some non-

technical changes have also been identified when the changes cannot

easily be determined. The portion of any specification which is being

deleted is struck through (i.e., the deletion is annotated using the

strike-out feature of the word processing computer program or crossed

out by hand). Any text being added to a specification is shown by

shading the text, placing a circle around the new text, or by writing

the text in by hand. The text being struck through or added is shown in

the marked-up CTS and ISTS pages in Enclosures 2 (CTS pages) and 5

(ISTS and ISTS Bases pages) for each ITS section attachment to the

application. Another convention of the common methodology is that the

technical justifications for the less restrictive changes are included

in the NHSCs.

The proposed changes can be grouped into the following four

categories: relocated requirements, administrative changes, less

restrictive changes involving deletion of requirements, and more

restrictive changes. These categories are as follows:

1. Relocated requirements (i.e., the licensee's LG or R changes)

are items which are in the CTS but do not meet the criteria set forth

in the Final Policy Statement. The Final Policy Statement establishes a

specific set of objective criteria for determining which regulatory

requirements and operating restrictions should be included in the TS.

Relocation of requirements to documents with an established control

program, controlled by the regulations or the TS, allows the TS to be

reserved only for those conditions or limitations upon reactor

operation which are necessary to obviate the possibility of an abnormal

situation or event giving rise to an immediate threat to the public

health and safety, thereby focusing the scope of the TS. In general,

the proposed relocation of items from the CTS to the Updated Safety

Analysis Report (USAR), appropriate plant-specific programs, station

procedures, or ITS Bases follows the guidance of NUREG-1431. Once these

items have been relocated to other licensee-controlled documents, the

licensee may revise them under the provisions of 10 CFR 50.59 or other

NRC-approved control mechanisms, which provide appropriate procedural

means to control changes by the licensee.

2. Administrative changes (i.e., the licensee's A changes) involve

the reformatting and rewording of requirements, consistent with the

style of the ISTS in NUREG-1431, to make the TS more readily

understandable to station operators and other users. These changes are

purely editorial in nature, or involve the movement or reformatting of

requirements without affecting the technical content. Application of a

standardized format and style will also help ensure consistency is

achieved among specifications in the TS. During this reformatting and

rewording process, no technical changes (either actual or

interpretational) to the TS will be made unless they are identified and

justified.

3. Less restrictive changes and the deletion of requirements

involves portions of the CTS (i.e., the licensee's LS and TR changes)

which (1) provide

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information that is descriptive in nature regarding the equipment,

systems, actions, or surveillances, (2) provide little or no safety

benefit, and (3) place an unnecessary burden on the licensee. This

information is proposed to be deleted from the CTS and, in some

instances, moved to the proposed Bases, USAR, or procedures. The

removal of descriptive information to the Bases of the TS, USAR, or

procedures is permissible because these documents will be controlled

through a process that utilizes 10 CFR 50.59 and other NRC-approved

control mechanisms. The relaxations of requirements were the result of

generic NRC actions or other analyses. They will be justified on a

case-by-case basis for the CPSES and described in the safety evaluation

to be issued with the license amendment.

4. More restrictive requirements (i.e., the licensee's M changes)

are proposed to be implemented in same areas to impose more stringent

requirements that are in the CTS. These more restrictive requirements

are being imposed to be consistent with the ISTS. Such changes have

been made after ensuring the previously evaluated safety analysis for

the CPSES was not affected. Also, other more restrictive technical

changes have been made to achieve consistency, correct discrepancies,

and remove ambiguities from the TS. Examples of more restrictive

requirements include: placing a Limiting Condition for Operation (LCO)

on station equipment which is not required by the CTS to be operable;

more restrictive requirements to restore inoperable equipment; and more

restrictive surveillance requirements.

There are nineteen other proposed changes to the CTS that may be

included in the proposed amendment to convert the CTS to the ITS. These

are beyond-scope issues (BSIs) changes in that they are changes to both

the CTS and the ISTS. For the CPSES, these are the following:

1. ITS 3.1.7, a new action added for more than one digital rod

position indicator per group inoperable.

2. ITS surveillance requirement (SR) 3.2.1.2, frequency, within 24

hours for verifying the axial heat flux hot channel factor is within

limit after achieving equilibrium conditions.

3. ITS SR 3.6.3.7, note added to not require leak rate test of

containment purge valves with resilient seals when penetration flow

path is isolated by leak-tested blank flange.

4. ITS LCO 3.7.15, changes reference for the spent fuel pool level

from that above top of fuel stored in racks to that above the top of

racks.

5. ITS 5.6.5a.8, adds refueling boron concentration limits to the

core operating limits report.

The above five BSIs are given in the licensee's application. The

remaining fourteen BSIs may have been revised by the licensee's

responses to the NRC requests for additional information (RAIs). The

format for the fourteen BSIs listed below is the associated change

number, RAI number, RAI response submittal date, and description of the

change.

6. Change 10-3-LS-37 (ITS 3/4.4), question Q5.5-2, response letter

dated September 24, 1998, the change added an allowance to CTS SR 4.4.9

for the reactor coolant pump flywheel inspection program (ITS 5.5.7) to

provide an exception to the examination requirements specified in the

CTS SR (i.e., regulatory position C.4.b of NRC Regulatory Guide (RG)

1.14, Revision 1).

7. Change 1-22-M (ITS 3/4.3), question Q3.3-49, response letter

dated November 24, 1998, the change is given in the application.

Quarterly channel operational tests (COTs) would be added to CTS Table

4.3-1 for the power range neutron flux-low, intermediate range neutron

flux, and source range flux trip functions. The CTS only require a COT

prior to startup for these functions. New Note 17 would be added to

require that the new quarterly COT be performed within 12 hours after

reducing power below P-10 for the power range and intermediate range

instrumentation (P-10 is the dividing point marking the Applicability

for these trip functions), if not performed within the previous 92

days. In addition, Note 9 is revised such that the P-6 and P-10

interlocks are verified to be in their required state during all COTs

on the power range neutron flux-low and intermediate range neutron flux

trip functions.

8. Change 1-7-LS-3 (ITS 3.4/3), question Q3.3-107, response letter

dated November 24, 1998, the changes are given in the application and

would (1) extend the completion time for CTS Action 3.b from no time

specified to 24 hours for channel restoration or changing the power

level to either below P-6 or above P-10, (2) reduce the applicability

of the intermediate range neutron flux channels and deleted CTS Action

3.a as being outside the revised applicability, and (3) add a less

restrictive new action that requires immediate suspension of operations

involving positive reactivity additions and a power reduction below P-6

within 2 hours, but no longer requires a reduction to Mode 3. The

changes would be to CTS Table 3.3-1 (Action 3 and New Action 3.1, and

Function #5 and Footnote h to its applicable modes).

9. Change 1-9-A (ITS 5.0), question Q5.2-1, response letter dated

September 24, 1998, a new administrative change added to the

application. The CTS 6.2.2.e requirements concerning overtime would be

replaced by a reference to administrative procedures for the control of

working hours.

10. Change 1-15-A (ITS 5.0), question Q5.2-1, response letter dated

September 24, 1998, a new administrative change added to the

application. The purposed change would revise CTS 6.2.2.G to eliminate

the title of Shift Technical Advisor. The engineering expertise is

maintained on shift, but a separate individual would not be required as

allowed by a Commission Policy Statement.

11. Change 2-18-A (ITS 5.0), question Q5.2-1, response letter dated

September 24, 1998, a new administrative change added to the

application. The dose rate limits in the Radioactive Effluent Controls

Program for releases to areas beyond the site boundary would be revised

to reflect 10 CFR Part 20 requirements.

12. Change 2-22-A (ITS 5.0), question Q5.2-1, response letter dated

September 24, 1998, a new administrative change added to the

application. The Radioactive Effluents Controls Program would be

revised to include clarification statements denoting that the

provisions of CTS 4.0.2 and 4.0.3, which allow extensions to

surveillance frequencies, are applicable to these activities.

13. Change 3-11-A (ITS 5.0), question Q5.2-1, response letter dated

September 24, 1998, the proposed change would revise the 3-11-A change

submitted in the application. CTS 6.12, which provides high radiation

area access control alternatives pursuant to 10 CFR 20.203(c)(2), would

be revised to meet the current requirements in 10 CFR Part 20 and the

guidance in NRC RG 8.3.8, on such access controls.

14. Change 3-18-LS-5(ITS 5.0), question Q5.2-1, response letter

dated September 24, 1998, a new less restrictive change added to the

application. The CTS 6.9.1.5 requirement to provide documentation of

all challenges to the power operated relief valves (PORVs) and safety

valves on the reactor coolant system would be deleted. This is based on

NRC Generic Letter 97-02 which reduced requirements for submitting such

information to the NRC and did not include these valves for information

to be submitted.

15. Change 3.19-A (ITS 5.0), question Q5.2-1, response letter dated

September 24, 1998, the administrative change is

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being withdrawn with the licensee submitting change 3-11-A above.

16. Change 10-20-LS-39 (ITS 3/4.7), question Q3.7.10-14, response

letter dated October 21, 1998, the change is given in the application

and would revise and add an action to CTS LCO 3.7.7.1, for ventilation

system pressure envelope degradation, that allows 24 hours to restore

the CR pressure envelope through repairs before requiring the unit to

perform an orderly shutdown. The new action has a longer allowed outage

time than LCO 3.0.4 which the CTS would require to be entered

immediately. This change recognizes that the ventilation trains

associated the pressure envelope would still be operable.

17. Change 4-8-LS-34 (ITS 3/4.4), question Q3.4.11-2, response

letter dated September 24, 1998, the change is given in the application

and would limit the CTS SR 4.4.4.2 requirement to perform the 92 day

surveillance of the pressurizer PORV block valves and the 18 month

surveillance of the pressurizer PORVs (i.e., perform one complete cycle

of each valve) to only Modes 1 and 2.

18. Change 4-9-LS-36 (ITS 3/4.4), question Q3.4.11-4, response

letter dated September 24, 1998, the Change 4-9-LS-4 is revised to add

a note to Action d for CTS LCO 3.4.4 that would state that the action

does not apply when the PORV block valves are inoperable as a result of

power being removed from the valves in accordance Action b or c for an

inoperable PORV.

19. Change 1-60-A (ITS 3/4.3), question TR 3.3-007, followup items

letter dated December 18, 1998, a new administrative change is being

added to the application. The change would revise the frequency for

performing the trip actuating device operational test (TADOT) in CTS

Table 4.3-1 for the turbine trip (functional units 16.a and 16.b) to be

consistent with the modes for which the surveillance is required. This

would be adding a footnote to the TADOT that states ``Prior to

exceeding the P-9 interlock whenever the unit has been in Mode 3.''

Environmental Impacts of the Proposed Action

The Commission has completed its evaluation of the proposed

conversion of the CTS to the ITS for CPSES, including the beyond-scope

issues discussed above. Changes which are administrative in nature have

been found to have no effect on the technical content of the TS. The

increased clarity and understanding these changes bring to the TS are

expected to improve the operators control of CPSES in normal and

accident conditions.

Relocation of requirements from the CTS to other licensee-

controlled documents does not change the requirements themselves.

Future changes to these requirements may then be made by the licensee

under 10 CFR 50.59 and other NRC-approved control mechanisms which will

ensure continued maintenance of adequate requirements. All such

relocations have been found consistent with the guidelines of NUREG-

1431 and the Commission's Final Policy Statement.

Changes involving more restrictive requirements have been found to

enhance station safety.

Changes involving less restrictive requirements have been reviewed

individually. When requirements have been shown to provide little or no

safety benefit, or to place an unnecessary burden on the licensee,

their removal from the TS was justified. In most cases, relaxations

previously granted to individual plants on a plant-specific basis were

the result of a generic action, or of agreements reached during

discussions with the OG, and found to be acceptable for the station.

Generic relaxations contained in NUREG-1431 have been reviewed by the

NRC staff and found to be acceptable.

In summary, the proposed revisions to the TS were found to provide

control of station operations such that reasonable assurance will be

provided that the health and safety of the public will be adequately

protected.

The proposed actions will not increase the probability or

consequences of accidents, no changes are being made in the types of

any effluents that may be released off site, and there is no

significant increase in the occupational or public radiation exposure.

Therefore, there are no significant radiological environmental impacts

associated with the proposed action.

With regard to potential non-radiological impacts, the proposed

action does not involve any historic sites. It does not affect non-

radiological plant effluents and has no other environmental impact.

Therefore, there are no significant non-radiological environmental

impacts associated with the proposed action.

Accordingly, the Commission concludes that there are no significant

environmental impacts associated with the proposed action.

Alternatives to the Proposed Action

As an alternative to the proposed action, the staff considered

denial of the proposed action (i.e., the ``no-action'' alternative).

Denial of the application would result in no change in current

environmental impacts. The environmental impacts of the proposed action

and the alternative action are similar.

Alternative Use of Resources

This action does not involve the use of any resources not

previously considered in the Final Environmental Statement for CPSES.

Agencies and Persons Consulted

In accordance with its stated policy, on January 26, 1999, the

staff consulted with the Texas State official, Mr. Arthur Tate of the

Texas Department of Health, Bureau of Radiation Control, regarding the

environmental impact of the proposed action. The State official had no

comments.

Finding of No Significant Impact

On the basis of the environmental assessment, the Commission

concludes that the proposed action will not have a significant effect

on the quality of the human environment. Accordingly, the Commission

has determined not to prepare an environmental impact statement for the

proposed action.

For further details with respect to the proposed action, see the

licensee's application dated May 15, 1997, as supplemented by the

eleven letters in 1998 dated June 26, August 5, August 28, September

24, October 21, October 23, November 24 (two letters), December 11,

December 17, December 18, and three letters in 1999 dated February 3,

which are available for public inspection at the Commission's Public

Document Room, The Gelman Building, 2120 L Street, NW., Washington, DC,

and at the local public document room located at the University of

Texas at Arlington Library, Government Publications/Maps, 702 College,

P.O. Box 19497, Arlington, TX 76019.

Dated at Rockville, Maryland, this 8th day of February 1999.

For the Nuclear Regulatory Commission.

John N. Hannon,

Director, Project Directorate IV-1, Division of Reactor Projects--III/

IV, Office of Nuclear Reactor Regulation.

[FR Doc. 99-3496 Filed 2-10-99; 8:45 am]

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