ST-HL-AE-5443, Application for Amends to Licenses NPF-76 & NPF-80, Incorporating Tech Specs 3.7.1.2 Re Auxiliary Feedwater Pump Operable

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Application for Amends to Licenses NPF-76 & NPF-80, Incorporating Tech Specs 3.7.1.2 Re Auxiliary Feedwater Pump Operable
ML20113G462
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/08/1996
From: Cloninger T
HOUSTON LIGHTING & POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20113G464 List:
References
ST-HL-AE-5443, NUDOCS 9609270241
Download: ML20113G462 (11)
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The Light l

company South Texas Fnqlect Doctric Generutlag Station F.O. Box 289 Wadrwerth, Texas 77483 Bouston Lighting & Power August 8, 1996 ST-HL-AE-5443 FileNo.: G20.02.01 10 CFR 50.90,

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10 CFR 50.92, 10 CFR 51 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington,DC 20555 South Texas Project Units 1 & 2 Docket No. STN 50-498 and STN 50-499 Unit I and Unit 2 Technical Soecifications 3.7.1.2 The South Texas Project proposes to amend its Operating Licenses NPF-76 and NPF-80 for the South Texas Project Electric Generating Station, Units 1 and 2, by incorporating the following changes to Technical Specifications 3.7.1.2. The proposed change would allow the transition from Mode 4 to Mode 3 with the Turbine Driven Auxiliary Feedwater pump inoperable and allow a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period after the entry into Mode 3 to complete all necessary operability testing.

These changes will allow the plant to achieve the secondary temperatures and pressures required

, to perform the post maintenance and surveillance testing necessary to declare the Turbine Driven j Auxiliary Feedwater pump OPERABLE.

l The required affidavit (Attachment 1), along with a Safety Evaluation and No Significant Hazards Consideration Determination (Attachment 2) associated with the proposed changes, and the marked up affected pages of the Technical Specifications (Attachment 3) are included as attachments to this letter.

The South Texas Project has reviewed the attached proposed amendment pursuant to  ;

10CFR50.92 and determined that it does not involve a significant hazards consideration. In i addition, the South Texas Project has determined that the proposed amendment satisfies the {

criteria of 10CFR51.22(c)(9) for categorical exclusion from the requirement of an environmental assessment. The South Texas Project Electric Generating Station Nuclear Safety Review Board l has reviewed and approved the proposed changes.

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9609270241 960808 8 .i PDR ADOCK 0500

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, ST-HL-AE-5443 File No.: G20.02.01 Page 2 If you should have any questions concerning this matter, please call Mr. M. A. McBurnett (512) 972-7206 or myself at (512) 972-8787.

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. H. Cl ger )

Vice sid l Nucl E in TCK/

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Attachment:

1. Affidavit
2. Safety Evaluation and No Significant Hazards Consideration Determination
3. Mark-ups of Proposed Changes to Technical Specification 3.7.1.2.

a I Houston Lighting & Power Company ST-HL-AE-5443 i j, South Texas Project Electric Generating Station 2

File No.: G20.02.01

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! Leonard J. Callan Rufus S. Scott i Regional Administrator, Region IV Associate General Counsel l U. S. Nuclear Regulatory Commission Houston Lighting & Power Company j

611 Ryan Plaza Drive, Suite 400 P. O. Box 61067

, Arlington, TX 76011-8064 Houston, TX 77208 4

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'Ihomas W. Alexion Institute of Nuclear Power .

Project Manager, Mail Code 13H3 Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 David P. Loveless Dr. Beitran Wolfe Sr. Resident Inspector 15453 Via Vaquero ,

c/o U. S. Nuclear Regulatory Comm. Monte Sereno, CA 95030 l P. O. Box 910 )

Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health 1 Morgan, Lewis & Bockius 1100 West 49th Street i

1800 M Street, N.W. Austin, TX 78756-3189 Washington, DC 20036-5869 U. S. Nuclear Regulatory Comm.

M. T. Hardt/W. C. Gunst Attn: Document Control Desk City Public Service Washington, DC 20555-0001 P. O. Box 1771 San Antonio, TX 78296 i

J. C. Lanier/M. B. Lee J. R. Egan, Esquire City of Austin Egan & Associates, P.C.

Electric Utility Department 2300 N Street, N.W.

721 Barton Springs Road Washington, D.C. 20037 Austin, TX 78704 Central Power and Light Company J. .W. Beck ATIN: G. E. Vaughn/C. A. Johnson Little Harbor Consultants, Inc.

P. O. Box 289, Mail Code: N5012 44 Nichols Road Wadsworth, TX 77483 Cohassett, MA 02025-1166

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ATTACHMENT 1

. AFFIDAVIT

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i UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION In the Matter )

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South Texas Project, et al., ) Docket Nos. 50-498

) 50-499

South Texas Project Unit 1 & 2 )

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AFFIDAVIT I, T. H. Cloninger, being duly sworn, hereby depose and say that I am Vice President, Nuclear j Engineering, of the South Texas Project; that I am duly authorized to sign and file with the

Nuclear Regulatory Commission the attached revision to proposed change to Technical Specifications 3.7.1.2; that I am familiar with the content thereof; and that the matters set forth therein are true and correct to the best of my knowledge and belief.

l .N.Clo'ger j Vice Pre dent, lear gineering STATE OF TEXAS ) g

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f COUNTY OF /Flaf afa<do )

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i Subscribed and sworn to before me, a Notary Public in and for the State of Texas, this I SU day of Avfvff,1996.

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  • . , / * * "# l Notad Public in and for the State of Texas a-k

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4 ATTACHMENT 2 SAFETY EVALUATION AND NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION i

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. Attachment 2 ST-HL-AE-5443 Page 1 of 5 l SAFETY EVALUATION i AND NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION I J

BACKGROUND r

L 'Ibe AFW System automatically supplies feedwater to the steam generators to remove l decay heat from the Reactor Coolant System upon the loss of normal feedwater supply.

'Ibe AFW pumps take suction through separate and indapaad-at suction lines fmm the Auxiliary Feedwater Storage Tank (AFST) and ptnp to the steam generator secondary ,

side via separate and independent connections to the steam generators. The steam  :

generators function as a heat sink for core decay heat. The heat load is dissipated by -

seleasing steam to the atmosphere from the steam generators via the main steam wfety l valves (MSSVs) or steam generator powet aperated relief valves (PORVs). If the main l

= '=== is available, steam may be released via the steam bypass valves.

'Ibe AFW System consists of three motor u 7en AFW pumps and one steam turbine )

driven pump configured into four trains. Each motor driven pump and the turbine driven  !

! pump provide.,100% of the required canacity to the steam generators, as assumed in toe 1 accident analysis. The pumps are equipped with independent recirculation lines to psevent pump operation againsu closed system. Each mctor driven AFW pump is ]

although each pump hts the capability to be realigred from the control room to feed other

! sacam generators. The steam turbine driven AFW pump receives steam from train D l l namin steam line upstream of the main steet isolation valve. It also has the capability to i

. be realigned from the control room to feed any of the other steam generators.

'Ihe turbine driven AFW pump supplies AFW to the train D steam generator with DC powered control valves actuated by the Engineered Safety Feature Actuation System j (ESFAS). Any one of the AFW pumps at full flow is sufficient to remove decay heat and l

cool the unit to residual heat removal (RHR) entry conditions. Thus, the requirement for diversity in motive power sources for the AFW System is met.

PROPOSED CHANGE DESCRIPTION

'Ibe proposed change will revise Technical Speciiication 3.7.1.2 by adding a new l ACTION that will state the provisions of Specification 3.0.4 are not applicable for the

turbine driven auxiliary feedwater pump. Additionally, Technical Specification i Surveillance Requirement 4.7.1.2.1.a.2) will be revised to ensure the surveillance testing i is performed within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after entry into Mode 3.

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. Attachrnent 2 ST-HL-AE-5443 Page 2 of 5 SAFETY ANALYSIS The AFW System mitigates the consequences of any event with loss of normal femiwater.

The design basis of the AFW System is to .,9 ply water to the steam generators to remove decay beat and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest steam generator safety

[ valve set pressure plus 3%. In addition, the AFW System must supply enough makeup water to replace steam generator secondary inventory lost as the unit cools to MODE 4 conditions. Sufficient AFW flow must also be available to account for flow losses such as pump recirculation and line breaks.

The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows:

l Feedwater Line Break (FWLB);or I h of MFW (with or without ATWS) (ATWS is not important in the Mode of operation being considered for this change.)

The AFW System design is such that it can perform its function following a FWLB '

between the MFIVs and containment, combined with a loss of offsite power following l turbine trip, and a single active failure of the A train AFW actuation logic causing failure i

of the A and D AFW pumps. For the design basis FWLB, operator action is required within 30 minutes to open the AFW cross connection valves to preclude the pressurizer from becoming water solid. While sufficient AFW flow is available from one AFW pump, cross connecting the steam generators is required because a single steam generator does not provide sufficient heat transfer area to remove decay heat under natural circulation conditions. However, for the proposed change, cross connecting the steam generators is not required because of the relatively low decay heat present during start-up.

'Ibe ESFAS automatically actuates the AFW turbine driven pump and associated power  ;

operated valves and controls when required to ensure an adequate feedwater supply to the l train D steam generator during loss of power. DC power operated valves are provided for the train D AFW line to control the AFW flow to traita D steam generator.

'Ihe revision to Surveillance Requirement 4.7.1.2.1.a.2 will provide alignment between the LCO allowed outage time requirements and the completion of the surveillance testing.

j If the Turbine Driven AFW pump is not declared operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of entering I l Mode 3, the unit must exit the mode of applicability to comply with the Action j

! Statement. I I

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. Attachment 2 i ST HL-AE-5443 Page 3 of 5 STATION BLACKOUT CONSIDERATIONS Since the South Texas Project is a two-unit site with three dedicated Standby Diesel l Generators (Standby Diesel Gerurators) per unit and all of the Standby Diesel Generators l are identical units, each STPEGS unit is considered to have three dedicated Emergency l AC (EAC) power supplies, anyone of which may be utilized as the Alternate AC (AAC) l source for the Station Blackout event. The safe shutdown design basis for STPEGS is hot

! standby (Mode 3), as stated in Section 5.4.A of the South Texas Project L7SAR. Upon j loss ofpower to the reactor coolant pumps (RCPs), coolam flow &<ary for core

! cooling and removal of decay heat is maintained by nattual circulation of the reactor

! coolant loops. Any one of the three motor driven South Texas Project Auxiliary -

l Feedwater trains can maintain hot standby conditions for the postulated four-hour coping

! duration of a Station Blackout condition, since each of the three Standby Diesel

) Generators powers an identical train of Steam Generator (SG) Power Operated Relief Valves (PORVs), an identical motor-driven Auxiliary Feedwater pump and associated cubicle cooler for decay heat removal from the Reactor Coolant System (RCS).

3 Analyses performed in support of the South Texas Project Fire Hazards Analyses - Cold Shutdown Report demonstrate that a single train of equipment can support achieving cold i shutdown conditions. These studies also determined that cold shutdown could be l achieved utilizing a single active Steam Generator. Reaching cold shutdown may require over 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, which is enveloped by the time limits of a postulated Station Blackout event. The analysis results alsojustify the use of a single train of Auxiliary Feedwater

, feeding a single steam generator as an acceptable Station Blackout coping mechanism.

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' Based on this analysis, the ability to enter Mode 3 with an inoperable steam driven Auxiliary Feedwater pump will not result in a significant reduction in the margin to safety since there will be three Standby Diesel Generator backed motor driven Auxiliary Feedwater pumps OPERABLE prior to entry into Mode 3. This condition ensures that for all postulated events, ewn the Station Blackout event, a minimum of one motor driven Auxiliary Feedwater pump will be able to supply the necessary feedwater to the steam generators for decay heat removal.

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, Attachment 2 ST-HL-AE-5443 Page 4 of 5 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMU4ATION  !

Pursuant to 10CFR50.91, this analysis provides a determination that the proposed change l to the Technical Specifications described previously, does not involve any significant hazards consideration as defined in 10CFR50.92, as described below:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. l i '

The proposed change will allow entry into Mode 3 with an inoperable Turbine Driven Auxiliary Feedwater pump. Since the operability test on the Turbine Driven Auxiliary Feedwatu pump can only be performed once steam pressure is  ;

, 21000 psig, this change will allow the plant to reach the Mode where steam )

pressure 21000 psig is available to perfonn the operability testing on the Turbine Driven Auxiliary Feedwater pump. The allowance of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to complete the

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surveillance testing will make the surveillance requirements consistent with the allowed outage time already established in the Action Statements. He proposed change does not affect the probability of an accident. The Turbine Driven Auxiliary Feedwater pump is not assumed to be an initiator of any analyzed event.

The consequences of an accident previously evaluated remain unchanged by allowing the pump to be inoperable until suitable conditions exist to perform the operability testing. He operability testing will continue to demonstrate that the i Turbine Driven Auxiliary Feedwater pump will perform as required prior to entry into Mode 2. This change will not alter assumptions relative to the mitigation of an accident or transient event. Therefore, this change will not involve a i significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different 4 kind of accident from any accident previously evaluated. l This change will not physically alter the plant (no new or different type of equipment will be installed). He changes in methods governing normal plant operation are consistent with current safety analysis assumptions. He proposed cimnge will allow entry into Mode 3 with the Turbine Driven Auxiliary Feedwater pump inoperable in order to perform the pump Operability Test on the turbine driven AFW pump once stcam pressure 21000 psig. Herefere, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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3. The proposed change does not involve a significant reduction in a margin of j safety.

The propo cd change will allow entry into Mode 3 with the Turbine Driven AFW pump io iole in order to perfonn the pump Operability Test on the turbine driven AFW pump once steam pressure 21000 psig. His will allow time for the i

plant to obtain suitable test conditions with steam pressure 21000. The margin of safety is not affected by this change. The operability testing will continue to i maintain assurance that the AFW Pumps will perform as required prior to entry l into Mode 2. He safety analysis assumptions will still be maintained, thus, no

! question of safety exists. Therefore, this change does not involve a significant reduction in a margin ofsafety.

1 IMPLEhENTATION SCHEDULE l The South Texas Project requests an implementation time of 30 days from the effective.

! date of the approved license amendment to facilitate distribution and to make appropriate J

changes to plant documents.

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