ST-HL-AE-5491, Application for Amends to Licenses NPF-76 & NPF-80, Incorporating Proposed Change to TS 3.4.6.1, Reactor Coolant Leakage Detection Sys
| ML20134E237 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/23/1996 |
| From: | Cloninger T HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20134E239 | List: |
| References | |
| ST-HL-AE-5491, NUDOCS 9611010062 | |
| Download: ML20134E237 (13) | |
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The Light company Houston Lightmg & Power,th Texas Project Electric Generating Station P.O. Box 289 Wad, worth, Texas 77483 i
l October 23, 1996 i
ST-HL-AE-5491 File No.: G09.06 10CFR50.90, 10CFR50.92,10CFR51 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 i
South Texas Project j
l Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 i
Unit I and Unit 2 Technical Specification 3.4.6.1 1
The South Texas Project proposes to amend its Operating Licenses NPF-76 and NPF-80 for the l
South Texas Project (STP), Units 1 and 2, by incorporating the attached proposed change to i
Technical Specifications 3.4.6.1, Reactor Coolant Leakage Detection Systems. This amendment will adopt the requirements found in NUREG 1431, Standard Technical Specifications Westinghouse Plants, for the Leakage Detection Systems.
The South Texas Project has reviewed the attached proposed amendment pursuant to 10CFR50.92 l
and determined that it does not involve a significant hazards consideration. In 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 for an environmental assessment. The South Texas Project Electric Generating Station Nuclear Safety Review Board has reviewed and approved the l
proposed changes.
l The required affidavit, along with a Safety Evaluation and No Significant Hazards Consideration Determination associated with the proposed changes, and the marked up affected pages of the Technical Specifications are included as attachments to this letter.
9611010062 961023 l
PDR ADOCK 05000498 4
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- e Houston Lighting & Power Company South Texas Project Electric Generating Station ST-HL-AE-5491 File No.: G09.06 Page 2 In accordance with 10CFR50.91(b), HL&P is providing the State of Texas with a copy of this
.l proposed amendment.
l If you should have any questions concerning this matter, please call Mr. M. A. McBumett at (512) 972-7206 or myself at (512) 972-8787.
T. H. Clo mger Vice Pr ide,
Nucle E ineering l
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Attachment:
1.
Affidavit 2.
Safety Evaluation and No Significant Hazards Consideration Determination 3.
Proposed Replacement Page for Change to Technical Specification 3.4.6.1.
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Houston Lighting & Power Company ST-HL-AE-5491 South Texas Project Electric Generating Station File No.: G09.06 Page 3 Leonard J. Callan Rufus S. Scott Regional Administrator, Region IV Associate General Counsel U. S. Nuclear Regulatory Commission Houston Lighting & Power Company l
611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8064 Houston, TX 77208 Thomas W. Alexion Institute of Nuclear Power j
Project Manager, Mail Code 13H3 Operations - Records Center l
U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, GA 30339-5957 i
i David P. Loveless Dr. Bertram Wolfe Sr. Resident Inspector 15453 Via Vaquero j
c/o U. S. Nuclear Regulatory Comm.
Monte Sereno, CA 95030 P. O. Box 910 i
Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Stre,:t, N.W.
Austin, TX 78756-3189 l
Washington, DC 20036-5869 j
J. R. Egan, Esquire M. T. Hardt/W. C. Gunst Egan & Associates, P.C.
l City Public Service 2300 N Street, N.W.
I P. O. Box 1771 Washington, D.C. 20037 i
San Antonio, TX 78296 J. C. Lanier/M. B. Lee U. S. Nuclear Regulatory Commission City of Austin Attention: Document Control Desk Electric Utility Department Washington, D.C. 20555-0001 721 Barton Springs Road Austin, TX 78704 Central Power and Light Company J. W. Beck ATTN: 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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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
In the Matter of
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South Texas Project
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Docket Nos. 50-498 Company, et al.,
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50-499
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South Texas Project
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Units 1 and 2
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AFFIDAVIT I, T. H. Cloninger, being duly sworn, hereby depose and say that I am Vice President, Nuclear Engineering, of Seuth Texas Project Company; that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached revision to proposed changes to Technical Specification 3.4.6.1; 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.
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N H. Cionin r ice Presi nt, Nuclear g'
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STATE OF TEXAS
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i Jbof Subscribed and sworn to before me, a Notary Public in and for the State of day of Octo ba r,499+: LM--
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l ATTACHMENT 2 SAFETY EVALUATION AND NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION i
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.c ST-HL-AE-5491 Page 1 of 7 Backoround The leakage detection systems at the South Texas Project consist of two atmosphere radioactivity monitors, one gaseous and one particulate, and a containment normal sump level and flow monitoring system. For Technical Specifications 3.4.6.1 the Limiting Condition for Operation l
l requires the following equipment to be OPERABLE in Modes 1,2,3 and 4.
The Containment Atmosphere Gaseous Radioactivity Monitoring System.
a.
b.
The Containment Normal Sump Level and Flow Monitoring System, and The Containment Atmosphere Particulate Radioactivity Monitoring System.
c.
The following actions are applicable depending on the equipment that is inoperable, With n. or c. inoperable, operation may continue for up to 30 days provided grab a.
samples of the containment atmosphere are obtained and analyzed for gaseous and particulate radioactivity at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b.
With b. inoperable, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c.
With a. and c. inoperable:
1)
Restore either Monitoring System (a. or c.) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 2)
Obtain and analyze a grab sample of the containment atmosphere for gaseous l
and particulate radioactivity at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and l
3)
Perform a Reactor Coolant System water inventory balance at least once per 8 i
hours.
Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
-In addition to the instrumentation required by Technical Specification 3.4.6.1, the South Texas Project has many additional methods of detecting Reactor Coolant Leakage. These additional i
methods include the Reactor Coolant System precision water inventory balance required by Technical Specification Surveillance 4.4.6.2.1.c, containment pressure, temperature and humidity indicators and i
advanced trending displays for the volume control tank and pressurizer level. All of these methods are available to the Operator in the control room for evaluating any possible leakage.
ST-HL-AE-5491 Page 2 of 7 This request is being submitted to allow the calibration of the containment normal sump level transmitter during power operations. Due to a misunderstanding about the system configuration, the containment normal sump level transmitter loop was not calibrated during the previous outage.
While the calibration can physically be done during power operations, the actual time to perform the calibration work will take approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to complete. During this time the containment normal sump level and flow monitoring system will be inoperable. This amendment will permit the calibration to be completed without forcing a unit shutdown.
Description of Change This amendment to Technical Specification 3.4.6.1 Limiting Condition for Operation would change the equipment required to be OPERABLE in Modes 1,2,3 and 4 as follows:
One Containment Atmosphere Radioactivity Monitor (gaseous or particulate), and a.
b.
The Containment Normal Sump Level and Flow Monitoring System.
This amendment will require the following actions depending on the equipment that is inoperable.
With the required containment atmosphere radioactivity monitor inoperable:
a.
1)
Restore one containment atmosphere monitoring system to OPERABLE status within 30 days and, 2)
Obtain and analyze a grab sample of the containment atmosphere for gaseous and particulate radioactivity at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or 3)
Perform a Reactor Coolant System water inventory balance at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
b.
With the required containment normal sump level and flow monitoring system inoperable:
1)
Restore the containment n;s. mal sump level and flow monitoring system to OPERABLE status within 30 days and, 2)
Perform a calculation of sump inflow leak rate at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or 3)
Perform a Reactor Coolant System water inventory balance at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
These changes are consistent with NUREG 1431 and do not involve any changes unique to the South Texas Project.
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Safety Evahmtion The proposed change reduces the number of containment atmospheric radioactivity channels which must be OPERABLE when operating in MODES 1,2,3, and 4 from two to one. This change does l
not significantly increase the probability or consequences of a previously evaluated accident since the plant will continue to have diverse and independent means of detecting significant changes in the amount ofleakage from the Reactor Coolant System (RCS); including the containment normal sump l
level and flow monitoring system and at least one of the two containment atmospheric radiation.
monitors. These methods along with the periodic precision RCS water inventory balance required by l
TS surveillance requirement 4.4.6.2.1.c and trending displays which can assist in detecting leakage based on changes in the volume control tank or pressurizer level. Other instruments, which are not j
listed in the Technical Specification related to leakage, but which can provide indication of leakage, are the containment pressure, temperature and humidity indicators.
The proposed change also revises the limitation on continued operation with both containment atmospheric radiation monitors inoperable from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 30 days. This change is based on the continued availability of diverse and redundant instrumentation discussed above to detect and indicate RCS leakage and the compensatory requirements in the Action statements. The Actions required as a result of this change include analysis of a containment atmospheric grab sample or performance of a precision RCS water inventory balance in accordance with surveillance requirement 4.4.6.2.1.c. The containment normal sump level and flow monitoring system will also promptly identify changes in RCS leakage. Other installed instrumentation, such as containment pressure, temperature, and j
humidity indicators, will provide indications of significant increases in leakage. Slower increases will be detected by the daily inventory balance or the daily grab sample analysis, and the three day inventory balance.
=1 The proposed 30 day allowed outage time instead of the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to HOT STANDBY requirement for an inoperable on-line automatic containment normal sump level and flow monitoring system is based on the compensatory Actions required by the amendment. These Actions require the performance of a daily manual calculation or a precision RCS inventory balance as described in surveillance requirement 4.4.6.2.1.c. Other indicatiens of increases in leakage such as the containment atmospheric radiation monitoring instruments and installed containment temperature, pressure and humidity instrumentation are also available. The STP control room design also incorporates features which allow rapid detection of unexpected changes in the volume control tank and pressurizer level i
through available instrument trend displays. The combination of the compensatory measures, diverse i
and separate channels, and non-TS required instrumentation provides a sufficient level of detection to assure prompt identification and quantification ofleakage with an inoperable containment normal i
sump level and flow monitoring system, i
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ST-HL-AE-5491 4
Page 4 of 7 Conclusion Based on information discussed above, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. Therefore, there is reasonable assurance that the operation of the South Texas Project in the proposed manner will not endanger the public health and safety. In addition, the proposed amendment is consistent with the Improved Technical Specification requirements found in NUREG 1431.
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Imnlementation Schedule.
South Texas Project requests this amendment be approved by January 10,1997 to allow for the timely implementation of the change. The containment normal sump level calibration will exceed its frequency on February 1,1997.
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ST-HL-AE-5491 Page 5 of 7 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION j
Pursuant to 10CFR50.91, this analysis provides a determination that the proposed change 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 The proposed change reduces the number of containment atmospheric radioactivity channels which must be OPERABLE when operating in MODES 1,2,3, and 4 from two to one. This change does not significantly increase the probability or consequences of a previously evaluated accident since the plant will continue to have diverse and independent means of detecting significant changes in the amount of leakage from the RCS; the normal sump level and flow monitoring system, at least one of the two containment atmospheric radiation monitors, and the periodic precision RCS water inventory balance required by Technical Specification surveillance requirement 4.4.6.2.1.c. In addition, STP design includes advanced '
trending displays which can assist in detecting leakage based on changes in the volume control tank or pressurizer level. Other instruments, which are not listed in the Technical Specification related to leakage, but which can provide indication of leakage, are the l
containment pressure, temperature and humidity indicators. Good operating practice and commercial risk associated with long term inoperability of both monitors assures that an j
inoperable containment atmospheric radiation monitor will be promptly returned to service.
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The proposed change also revises the limitation on continued operation with both containment atmospheric radiation monitors inoperable from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 30 days. This change is based on -
the continued availability of diverse and redundant instrumentation discussed above to detect i
and indicate RCS leakage.
The Actions required as a result of this change include analysis of a containment atmospheric l
grab sample or performance of a precision RCS water inventory balance in accordance with surveillance requirement 4.4.6.2.1.c. The containment normal sump level and flow monitoring system will also promptly identify changes in RCS leakage. Other installed I
instrumentation, such as containment pressure, temperature, and humidity, will provide indications of significant increases in leakage. Slower increases will be detected by the daily j
inventory balance or the daily grab sample analysis, and the three day inventory balance.
Inoperability of the on-line automatic containment normal sump level and flow monitoring system can be compensated for by the performance of a daily manual caklation, a precision i
RCS inventory balance as described in surveillance requirement 4.4.6.2.1.c, or the other available indications of increases in leakage such as the containment atmospheric radiation i
monitoring instruments and installed containment temperature, pressure and humidity instrumentation. The STP control room design also incorporates features which allow rapid
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detection of unexpected changes in the volume control tank and pressurizer level through available instrument trend displays. The combination of the compensatory measures, diverse
3 ST-HL-AE-5491 i
Page 6 of 7 and separate channels, and non-TS required instrumentation provides a sufficient level of detection to assure prompt identification and quantification ofleakage with an inoperable containment normal sump level and flow monitoring system. The allowable outage time of 30 days provides assurance the normal containment sump level and flow monitoring system will be returned to service in a reasonable amount of time.
Based on the continued availability of adequate and redundant instrumentation to detect changes in RCS leakage rate, this change does not involve a 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 kind of 1
accident from any accident previously evaluated.
The proposed change does not require the installation of a / new or different kind of equipment. Nor does the change involve any significantly new or different MODE of operation of the plant. The proposed change reduces the number of required containment atmospheric radiation monitors, and provides a 30 day allowed outage time for either the containment atmosphere radioactivity monitor or the containment normal sump level and flow monitoring system. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed change does not involve a significant reduction in a margin of safety.
In addition, as described above, the proposed change does not significantly reduce a margin of safety. Small changes in RCS leak rates are typically detected over a relatively long period of time. Diverse instrumentation continues to be available to plant operators which i
will assist in early detection of any change. The STP design provides additional non-Technical Specification human factors which assist in assuring any changes in leakage will be
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quicgdetected.
The proposed change extends the amount of time that the containment atmospheric radiation monitors may be inoperable. The extension is based on the continued availability of equipment which provides a level of detection capability adequate to detect increases in RCS leakage and which continues to be diverse and independent. This protection is afforded by l
the continued OPERABILITY of the containment normal sump level and flow monitoring I
system, the daily performance of a precision RCS inventory balance as described by surveillance requirement 4.4.6.2.1.c or the daily analysis of containment atmospheric grab l
samples, and other instrumentation such as pressure, temperature and humidity indicators.
The combination of the compensatory measures, diverse and separate channels, and non-TS required instrumentation provides a sufficient level of detection to assure prompt identification 3
l and quantification of leakage with an inoperable containment normal sump level and flow monitoring system. Additionally, the compensatory measure of performing either a daily manual calculation or precision RCS inventory balance, provides assurance that the level of safety is maintained when the containment normal sump level and flow monitoring system is
l ST-HL-AE-5491 Page 7 of 7 inoperable. The allowable outage time of 30 days provides assurance the normal containment i
sump level and flow monitoring system will be returned to service in a reasonable amount of time.
1 Conclusion Based on information discussed above, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. Therefore, there is reasonable assurance that the operation of the South Texas Project in the proposed manner will not endanger the public health and safety. In addition, the proposed amendment is consistent with the Improved Technit:al Specification requirements found in NUREG 1431.
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