ML20059G177

Application for Amends to Licenses NPF-76 & NPF-80, Incorporating Changes to Tech Spec 4.0.2

ML20059G177
Person / Time
Site:	South Texas
Issue date:	09/05/1990
From:	Kinsey W HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059G179	List: ML20059G177 ST-HL-AE-3561, Proposed Changes to Tech Spec 4.0.2
References
ST-HL-AE-3561, NUDOCS 9009120181
Download: ML20059G177 (8)

Text

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' September 5, 1990  :

ST HL AE 3561 I File No.: 09.06, C20.01  !

10CFR50.90  !

10CFR50.92  !

10CFR$1  !

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U. S. Nuclear Regulatory Cos;nission -

Attention: Document Control-Desk t

Washington, DC 20555 South Texas Project Electric Generating Station l Units 1 & 2 r Docket Nos. STN 50 498, STN 50 499 ,

Proposed Amendment to the .

Unit 1 and Unit 2 Technical Soecification 4.0.2  :

Pursuant to 10CFR50.90, Houston Lighting & Power Company (HIAP) hereby proposes to amend its Operating Licenses NPF 76 and NPF 80 by incorporatir:3a .

proposed change to Technical Specification' 4.0.2 for the South Texas Project ,

Electric Cenerating Station (STPECS) Units 1 and 2. -

i HMP has rcviewed the attached proposed amendment pursuant to 10CFR50.92 l and determined that it does not involve a significant hazards consideration.

The basis for this determination is provided in the attachments. In addition, t based on the information contained in this aubmittal and in the NRC Final Envirotunental Statement related to operation of STPECS Units 1 and 2, HIAP has ,

concluded that, purauant to 10CFR51, there are no significant radiological or '

non radiological impacts associated with the proposed action and the proposed license amendment will not have a significant effect on the- quality of the environment.

The STPE;S Nuclear Safety Review Board has reviewed and approved the '

proposed changes.

In accordance with 10CFR50.91(b), H1AP is providing the State of Texas  !

with r copy of this proposed amendment.

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A1/035.N14 A Subsidiary of Houston Industries Incorporated 9009120181 900905  ;

PDR ADOCK 05000498 W[f? 3 P PNV b _ , _

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. .c Houston Lighting k Power Company  !

South Texas Project Electric Generating Station ST HL AE 3561 ,

File No.: 09.06, C20.01 Page 2 l

r if you should have any questions concerning this matter, please contact Mr. M. A. McBurnett at (512) 972 8530 or myself at (512) 972 7921.

Warren H. Kinsey, r.  ;

Vice President Nuclear Generation CCS/n1 3 Attachinents: 1. Significant Hazards Evaluation for the Proposed {

Change to Technical Specification 4.0.2 ,

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2. Proposed Change to Technical Specification 4.0.2  ;

and Bases ~

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A1/035,N14 i l

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Houuon Lighting & Power Compan), ST.HL AE.3561 South Texas Project Electric Generating Station 09.06

$18No.:

cc:

Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 George Dick, Project Manager U.S. Nuclear Regulatory Commission INPO .

Washington, DC 20555 Records Center 1100 Circle 75 Parkway J. 1. Tapia Atlanta, CA 30339 3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrie commission 50 Be11 port Lane P. O. Box 910 Be11 port, NY 11713 Bay City TX 77414 D. K. Lacker J. R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C. Texas Department of Health 1615 L Street, N.W. 1100 West 49th Street Washington, DC 20036 Austin, TX 78756 3189 R. P. Verret/D. E. Ward Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403 J . C. Lanie r/M . B . Le e Director of Generation City of Austin Electric Utility  !

721 Barton Springs Road Austin, TX 78704 R. J. Costello/M. T. Hardt  !

City Public Service Board P. O. Box 1771 San Antonio, TX 78296 I

Revised 08/31/90 L4/NRC/

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. t UNITED STATES OF AMERICA NUC1. EAR REGUIATORY COMMISSION I

In the Matter )

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Houston Lighting & Power ) Docket Nos. 50 498 Company, et al., ). 50 499

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South Texas Project )

Units 1 and 2 )

AFFIDAVIT Warren H. Kinsey, Jr. being duly sworn, hereby deposes and says that he-is Vice President, Nuclear Generation, of Houston Lighting & Power Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached proposed change to the South Texas Project Electric Generating Station Technical Specification 4.0.2; is familiar with the content thereof; and-that the matters set forth therein are true and correct to the best of his knowledge and belief.

W Y Mh%

Warren H. Kinsey, Jr. { /

Vice President

-Nuclear Generation Subscribed and sworn to before me, a Notary Public in and for The State of Texas this +/O day ofdg&nd.441990.

!, SHA N AHY g g

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• STATE OF TEXAS Notary' Public in and for the J

, ,,,,,, i- State of Texas l

A1/035.N14

ATTACHMENT I ST HL-AE+356 '

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l ATTACHMENT 1 SIGNIFICANT HAZARDS EVALUATION TOR THE PROPOSED CHANCE TO TECHNICAL SPECIFICATION 4.0.2 i

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ATTACHMENT I ST-HL AE 3% /

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SIGNIFICANT HAZARDS EVALUATION FOR THE  !

PROPOSED CHANGE TO TECHNICAL SPECIFICATION 4.0.2 ,

Backrround j i

Technical Specification 4.0.2 permits surveillance intervals to be '

extended up to 25 percent of the specified interval. This extension allows

.! .surveillances to be postponed when plant conditions are not suitable for conducting a surveillance. For example, the plant may be recovering from a- ,

transient condition, or surveillance or maintenance activities conflict with performing another surveillance. Technical Specification 4.0.2 also limits extending surveillance intervals so that the combined time interval for three consecutive intervals for a given surveillance cannot exceed 3.25 times the I

specified surveillance interval. The intent of the 3.25 limit is to preclude routine use of the provision for extencing a surveillance interval. q NRC Ceneric Letter 89 14 encouraged licensees to propose TechnPal i Specification changes removing the 3.25 limit on extending surveil b nce  ;

l intervals. This proposed Technical Specification change conforms with the l guidance of Generic Letter 89 14.

Proposed Chance

.f I Change Technical Specification 4.0.2 and the bases for Technical -

l Specification 4.0.2 as shown in Attachment 2. i Safety Evaluation The proposed change is not a physical change or alteration to.any plant component or system, or a change to the design or operation of any plant component or system. Additionally, the 3.25 limit'of Technical Specification - 4.0.2 was not used in the Updated Final Safety Analysis Report (UFSAR) for any Chapter 15 accident analysis.

It is overly conservative to assume that components or systems are >

incperable because a surveillance has not been performed.within the L 25 limit of Technical Specification 4.0.2 when performance of the surveillance is othorwise possible within the allowable 25 percent extension limit. The 25 percent extension limit will continue to be used under the proposed change and equipment will continue to be proven operable on a regular basis in accordance with the proposed 4.0.2.

Based on STPEGS experience, implementation of an extended _

s surveillance interval will not impose a significant risk in terms'of equf.pment reliability. Other periodic tests, such as channel checks, have provided adequate assurance of instrument availability. Operational logs and operator ';

walkdowns provide another method to verify operability of components and systens. Where components or systems do not pass a surveillance test criterion, redundant and backup systems exist to ensure that STPEGS remains within its design bases.

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Attachment 1 Page 2- ,

i Safety Evaluation. Cont'd. '

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The liuit on surveillance extension of 25 percent in the proposed Technical Specification 4.0.2 is based on the nuclear industry's engineering judgment and the recognition that the most probable result of a surveillance ,

being performed is verification of conformance with the surveillance ~!

requirements. The' 25 percent limit is sufficient to ensure that reliability ,

of equipment verified through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval, i t

The proposed change will remove the 3.25 limit on any three  !

consecutive surveillance intervals. This can result in a safety benefit.

This proposed change will allow a surveillance to be extended when plant conditions are not suitable for performing a surveillance. Examples of conditions where performance of a surveillance should be avoided are during a plant transient, or under operating conditions where performance of the t surveillance could cause a reactor trip. Additionally, safety systems could be out of service due to other surveillances or maincenance activities and -

performance of the subject surveillance would be undesirable under these  ;

conditions. For these plant conditions, needless challenges to plant safety systems with associated risk of reactor trips may be avoided by delaying a ,

surveillance test until redundant equipment is operable. In these cases, the safety benefit of using the 25 percent allowance for extending.the l surveillance outweighs the benefit of a 3.25 limit on three consecutive  :

surveillance intervals.  !

Determination of Signifiesnt Hazards Pursuant to 10CFR50.91, this analysis provides a determination that the proposed change to Technical Specifications does not involve a significant

• hazards consideration as defined in 10CFR50.92.

1. The proposed change does not involve a significant increase in the ,

probability or consequences of an accident previously evaluated '

l because the proposed change does not-involve a physical change or i change the design or operation of a system or component at STPEGS.

The 3.25 limit of Technical Specification 4.0.2 was not used in the UFSAR for any Chapter 15 accident analysis. Therefore, removal of this limit from Technical Specification 4.0,2 cannot increase the probability or consequences of a previously evaluated accident.

The proposed change can have a net safety benefit in that surveillances can be delayed when the plant is in an operational i transient or other safety systems are out of' service for I

surveillance testing or maintenance activities.- Delaying the subject surveillance until redundant equipment is operable can reduce challenges to safety systems and reduce the risk of associated reactor trips.

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-. l Attachment 1 Page'3 Experience at STPECS hat shown that an extended surveillance -

interval will not . impose a significant risk in terms of equipment reliability. Other periodic tests, walkdowns and operational -

verifications provide another method of assuring continued operability. If a component er system does not pass a surveillance test, redundant and backup equipment is available to perform the-  !

safety function.

Therefore,.the proposed change does not significantly increase the h probability or consequences of a previously evaluated accident.

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

Surve111ances performed at STPECS must continue to use a maximum [

interval of the surveillance limit plus 25 percent of the limit. i The 25 percent limit will ensure that the expected reliability of  !

equipment is not significantly reduced beyond that obtained from the  :

specified surveillance interval. l The purpose of the 3.25 limit was to prevent routine use of the 25 l percent limit. The proposed change deleting the 3.25 limit can have  ;

a net safety benefit which outweighs the benefit of preventing the  ;

routine use of the 25 percent limit, t i

, The design of STPECS remains unchanged and no physical modification {

or alteration to the plant or operation of the plant occurs with the  :

proposed change. The proposed change does not modify the }

surveillance interval. Therefore, the proposed change does not create the possibility of a new or different accident; f

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3. The proposed change will not involve a significant reduction in a ,

margin of safety. Removal of the 3.25 limit has a positive effect {

! on safety because a surveillance can be delayed when the plant is in ,

an operational transient or when other surveillances or maintenance '

activities require that redundant saf ety systems be inoperable.

This safety benefit outweighs any benefit derived by limiting any three consecutive surveillances to the 3,25 limit. .

i Conclusion f

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l HMP has determined that the proposed change does not involve a significant hazards consideration and.that the-proposed change can have a net  ;

benefit in the safe operation of STPEGS. The NRC has reviewed removal of the

• 3.25 limit from Technical Specification 4.0.2 and concluded that this change

• results in a greater benefit to safety than limiting use of the 25 percent  :

allowance to extend surveillance intervals. HMP requests. that the proposed I change be approved. l A1/035.N14

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