ST-HL-AE-4734, Application for Amends to Licenses NPF-76 & NPF-80,revising TS 4.6.1.3.e to Add Option Which Will Allow Personnel Airlock Pneumatic Sys Leak Test to Be Completed Either 8 H W/Pressure Drop of 0.50 Psi or 24 H w/1.5 Psi Pressure Drop

Application for Amends to Licenses NPF-76 & NPF-80,revising TS 4.6.1.3.e to Add Option Which Will Allow Personnel Airlock Pneumatic Sys Leak Test to Be Completed Either 8 H W/Pressure Drop of 0.50 Psi or 24 H w/1.5 Psi Pressure Drop

ML20029C944
Person / Time
Site:	South Texas
Issue date:	04/28/1994
From:	Groth J HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029C945	List: ML20029C949 ST-HL-AE-4734, Application for Amends to Licenses NPF-76 & NPF-80,revising TS 4.6.1.3.e to Add Option Which Will Allow Personnel Airlock Pneumatic Sys Leak Test to Be Completed Either 8 H W/Pressure Drop of 0.50 Psi or 24 H w/1.5 Psi Pressure Drop
References
ST-HL-AE-4734, NUDOCS 9405030068
Download: ML20029C944 (10)

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Houston Lighting & Power April 28, 1994 ST-HL-AE-4734 File No.: G20.02 G21.02 10CFR50.90 U.

S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 Proposed Amendment to the Technical Snecification 4.6.1.3.e Pursuant to 10CFR50.90, Houston Lighting & Power Company (HL&P) hereby proposes to amend its Operating Licenses NPF-76 and NPF-80 for the South Texas Project Electric Generating Station (STPEGS), Unit 1 and Unit 2, by incorporating the attached proposed change to Technical Specification 4.6.1.3.e.

The purpose of this proposed amendment is to add an option which will allow the personnel airlock pneumatic system leak test to be completed in either 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with a pressure drop of 0.50 psi, or in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a 1.5 poi pressure drop.

The proposed optional 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test would provide South Texas Project with a cost beneficial change in that it would help shorten a critical path item and thus expedite return to power following an outage.

HL&P has reviewed the attached proposed amendment pursuant to 10CFR50.92 and deterrined that it does not involve a significant hazards consideration.

In addition, Houstcn Lighting & Power has determined that the proposed amendment satisfies the criteria of 10CFR51. 22 (c ) ( 9 ) for categorical exclusion from the requirement for an environm-ral assessment.

The STPEGS Nuclear Safety Review y

Board has revaowed and approved the proposed change.

The required affidavit, along with a Safety Evaluation and No e

Significant Hazards Consideration Determination associated with the proposed change and marked-up effected pages of the Technical Specification are included as attachments to this letter.

In accordance with 10CFR50. 91(b), Houston Lighting & Power is providing the State of Texas with a copy of this proposed amendment.

9405030069 940428 PDR ADOCK 05000498 P

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,J Project Manager on nehatt or the Participant, in the south Tex.i Projeci Tsc\\93-182, cia j

Ilouston Lighting & Power Company ST-HL-AE-4734 South Texas Project Electric Generating Station File No.: G20.02 G21.02.

Page 2 If you have any questions, please contact Mr. A.

W.

Harrison at (512) 972-7298 or me at (512) 972-866.,.

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Groth Vice President, Nuclear Generation LRW/eg Attachments:

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Affidavit 2)

Safety Evaluation And No Significant. Hazards Consideration Determination i

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Technical Specification Mark-up

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Houston Lighting & Power Company ST-HL-AE-4734 South Texas Project Electric Generating Station File No.:

G20.02 G21.02 Page: 3 c:

Leonard J.

Callan Rufus S.

Scott Regional Administrator, Region IV Associate General Counsel U.

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Nuclear Regulatory Commission Houston Lighting & Power Company 611 Ryan Plaza Drive, Suite 400 P.

O.

Box 61067 Arlington, TX 76011 Houston, TX 77208 Lawrence E.

Kokajko Institute of Nuclear Power Project Manager Operations - Records Center U.

S.

Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 13H15 Atlanta, GA 30339-5957 David P.

Loveless Dr. Joseph M. Hendrie Sr. Resident Inspector 50 Bellport Lane c/o U.

S.

Nuclear Regulatory Comm.

Bellport, NY 11713 P.

O.

Box 910 Bay City, TX 77404-910 D.

K.

Lacker Bureau of Radiation Control J.

R. Newman, Esquire Texas Department of Health Newman, Bouknight & Edgar, P.C.

1100 West 49th Street STE 1000, 1615 L Street, N.W.

Austin, TX 78756-3189 i

Washington, DC 20036 U.

S.

Nuclear Regulatory Co m.

i K. J. Fiedler/M.

T. Hardt Attn: Document Control Desk City Public Service Washington, D.

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20555-0001 P.

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Box 1771 San Antonio, TX 78296 J.

C. Lanier/M.

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Lee City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 G.

E..Vaughn/C. A. Johnson Central Power and Light Company P.

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Box 2121 Corpus Christi, TX 78403

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ST-HL-AE-4734 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter

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Housten Lighting & Power

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Docket Nos. STN 50-498 Company, et al.,

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STN 50-499

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South Texas Project

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Units 1 and 2

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AFFIDAVIT I,

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F.

Groth, being duly sworn, hereby depose and say that.

I am Vice President, Nuclear Generation, of Houston Lighting &

Power Company; that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached Proposed Amendment to the Technical Specification 4. 6.1.3.e; that am familiar with the content thereof; and that the matters set fo th therein are true and correct to the best of my kn d

and elief.

M F. GYbth Vice President, Juclear Generation STATE OF TEXAS

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Subscribed and sworn to before me -,a Notary Public in and-for the State of. Texas, this M day of kl 1994.

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- g ccNNit MONICOMEin Notary Public/).n for the ww, swe. w. o""'5 State of Texad ff.'

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' I ATTACHMENT 2 SAFETY EVALUATION AND NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 4

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l ST-HL-AE-4734 Page 1 of 4 BACKGROUND The South Texas Project Electric Generating Station main personnel airlock (1 per unit) consists of an inner door (Reactor Containment Building side) and outer door (Mechanical Auxiliary Building side).

With a door in the closed position, two seals are inflated against the airlock barrel to provide containment-integrity' Each seal is provided with a three-way. ball valve, an air reservoir tank, and a check valve.,

The three-way ball valve directs air to or from the seal to inflate or deflate the seal depending on whether the door is open or closed.

The air reservoir tank provides sufficient capacity to maintain 65 psig in the seal for a minimum of 15 days in the event a loss of instrument air to the personnel airlock is experienced.

The check valve ensures no loss of reservoir tank capacity in the event instrument air is lost.

These components are commonly referred to as the door seal pneumatic system.

In accordance with Technical Specification 4.6.1.3.e, the door seal pneumatic system must be verified operable at least once per 18 months by " verifying that system pressure does not decay more than

1. 5 psi f rom 90 psig minimum within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. "

This requirement is satisfied by performance of OPSP11-XC-0009,

" Personnel Airlock Pneumatic Seal System Pressure Drop Test."

A minimum of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> is required to complete test OPSP11-XC-0009 for both personnel airlock doors leaving the auxiliary airlock as the only means of personnel entry or exit.

For this reason, the test is scheduled at the outage conclusion to minimize access through the auxiliary a

airlock.

As a result the test is always on critical path-for i

restart following an outage.

PROPOSED CHANGE q

i The proposed change to South Texas Project Electric Generating i

Station Technical Specification 4.6.1.3.e-would.a110w the personnel.

airlock pneumatic system leak test to be completed in-either 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with a pressure drop of 0.50 psi, or in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a 1.5 pai pressure drop.

Sections 6.4 and 7.6 of ANSI N45.4-1972 state l

that a test duration of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is permissible provided.

O it can be demonstrated that the. leak rate can be accurately.

determined.

Adoption of the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test provides-South Texas Project with a cost ef fective change which can reduce the time from-containment closure to restart.

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4 ST-HL-AE-4734 Page 2 of 4 SAFETY EVALUATION By establishing an acceptance criteria based on a linear relation between leakage and time, the duration of

a. leak test can be shortened provided the actual test data can be shown to be less than an established acceptance criteria. A linear relation between leakage and time would result in a slope of 0.0625 psi / hour for the test parameters dictated by the South Texas Project Technical-Specification Surveillance Requirement, i.e.

1.5 psi within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Such a slope would predict a pressure drop of 0.5 psi in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Experience has shown however, that the relationship between leakage and time is not linear in nature.

Higher leakage at the beginning of the test period is generally experienced during actual leak testing.

This is due to the differential pressure being higher at the beginning of the test period than later'in the test.

Test experience has demonstrated that test failures can be predicted from short duration (as little as 15 minutes) monitoring of pressure drop.

Test experience has also demonstrated that leaks do t

j not suddenly manifest themselves late.in the test, i.e.,

leaks are always identified and corrected early in the test.

By assuming a pressure. drop based on a linear relationship between leakage and

time, which is not linear, the proposed change to permit-an optional 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> leak test'with an acceptance criteria of 0.50 psi, t

will conservatively predict compliance with_ the-Surveillance Requirement of 1.5 psi in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The proposed Technical Specification change does not alter the door pneumatic seal system pressure drop test except for providing an optional 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test.

With an assigned acceptance criteria of 0.50 psi for the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test this option will still assure air lock

- sealing capability and containment integrity _ during normal operations or during loss of instrument air for a minimum of 15 l

- days. Due to containment integrity being maintained, this proposed option will not. increase the probability of. accidents and'posta accident radiological releases or radiological plant effluents above established values.

The proposed Technical-Specification change features the personnel airlock pneumatic seal system which-

. is located entirely within the restricted area.

It does not affect non-radiological plant effluents and has no environmental impact.

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ST-HL-AE-4734 Page 3 of 4 i

NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 1.

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

l The door pneumatic seal system pressure drop test is not altered l

except for providing an option to utilize a reduced test duration.

A conservative acceptance criteria of 0.50 psi will be assigned to the optional short duration test thus maintaining the operability of the pneumat.ic seal system.

Tht. proposed change does not alter equipment or assumptions made in previously evaluated accidents, therefore the consequences of previously evaluated accidents are not increased.

The probability of an accident is also unaffected because the seals are not a potential accident initiator.

2.

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

With a conservative acceptance criteria of 0.50 psi assigned to the optional 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> door pneumatic seal system pressure drop test the capability of the door pneumatic seal system to maintain 65 psig to the airlock seals, for a minimum of 15 days upon a loss of instrument air, is assured.

Loss of plant supply air is the accident evaluated in UFSAR section 3.8.2.1.2 and plant specification 2C269SS0006.

The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

To ensure the pneumatic seal system pressure drop test is not compromised, a conservative acceptance criteria of 0.50 psi will be assigned to the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test. With the conservative acceptance

criteria, the proposed change does not involve a significant reduction in the margin of safety previously evaluated.

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ST-HL-AE-4734 Page 4 of 4 J_MEldMENTATION PLAN

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Implementation of the proposed change to Technical Specification 4.6.1.3.e is not contingent of any plant. changes.

Once the proposed change is in effect, OPSP11-XC-0009 will be revised to permit the option of a short duration pneumatic seal system drop test.

Houston Lighting and' Power requests an implementation time of 10 days from the effective date of the Technica1' Specification amendment to complete procedure changes and to make appropriate document distribution.

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