ML20238F084

Proposed Tech Specs Section 4.0.5,excluding Specified Containment Isolation Valves from ISI & Testing Requirements as Stated in Section XI of ASME Boiler & Pressure Vessel Code

ML20238F084
Person / Time
Site:	South Texas
Issue date:	08/28/1998
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20238F079	List: ML20238F084 NOC-AE-000280, Application for Exigent Amends to Licenses NPF-76 & NPF-80, Excluding Specified Containment Isolation Valves from ISI & Testing Requirements as Stated in Section XI of ASME Boiler & Pressure Vessel Code
References
NUDOCS 9809030096
Download: ML20238F084 (7)

Text

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Attachment 5 NOC-AE-000280 Page1 Annotated Technical Specification 9809030096 990828 '3; PDR ADOCK 05000499 P PDR

APPLICABILITY I

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL H0 DES cr other conditions specified for individual Limiting Conditions for j

Operation unless otherwise stated in an individual Surveillance Requirement.

i 4.0.2 Each Surveillance R'equirement shall be performed within the'specified 1 surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 Failure to perform a Surveillance Requirement within the allowed sur-veillance interval, defined by Specification 4.0.2, shall constitute a failure 4

- to meet the OPERABILITY requirements for a Limiting Condit' ion for Operation.

The time limits of the ACTION requirements are applicable at the time it is  ;

identified that a Surveillance Requirement has not been performed. The ACTION i requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the l survelliance when the allowed outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Surveillance Requirements do not have to be performed en inoperable equipment.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condi-tion for Operation has been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance Requirements for inservice inspection and testing of 4ASME Code Class 1, 2, and 3 components shall be applicable as follows: # j

a. Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and ap 10 CFR Part 50, Section 50.55a(plicable Addenda as required byg),

relief has been granted by the Commission pursuant to 10 CFR Part 50,  !

j Section50.55a(g)(6)(1);

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l 3/4 0-3 UNIT 1 - ANENOMENT NO. 21 SOUTH TEXAS - UNITS 1 & 2 UNIT 2 - AMENDMENT NO. 11

I Insert to page 3/4 0-3

• The Inservice testing requirement for exercise testing in the closed direction for the following listed valves shall not be required until the next plant shutdown to Mode 5 of sufficient duration to allow the testing or until the next refueling outage scheduled in March 1999. This exception shall apply to the following Unit 1 valves only: 1-CC-0319, 1-CV-0034A,1-CV-0034B,1-CV-0034C,1-CV-0034D,1-CV-0026,1-FP-0943, and 1-

'IA-0541.

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Attachment 6 NOC-AE-000280 Page1 Containment Isolation Valves affected Umt 1 CV-0034A, CV-0034B, CV-0034C, CV 0034D- Reactor Coolant Pump SealInjection Line Check Valves CC-0319 -

Reactor Coolant Pump Component Cooling Water Supply Inside Reactor Containment Check Valve CV-0026 -

Chemical & Volume Control System Charging Inside Reactor Containment Isolation Check Valve FP-0943 -

Inside Containment Fire Protection to the Reactor Containment Building Check Valve IA-0541 -

Inside Containment Instrument Air to the Reactor Containment Building Check Valve L _ -- _ - _

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Attachment 7 NOC-AE-000280 Page1 Recent Test Results The ability of these valves to act as a containment isolation boundary is demonstrated by the 10 CFR 50 Appendix J Program. The valve stroke exercise as identified in IWV-3522 is to identify valve degradation. A review of historical valve performance was performed for the past 3 local leakage tests in Unit 1. The results of these tests are as follows:

PENE # VALVE # VALVE TYPE DATE LEAK RATE GUIDELINE (SCCM) VALUE(SCCM)

UNIT 1 VALVES M39 CC0319 ICIV 9/27/93 7 6552 M39 CC0319 ICIV 3/16/95 20 6552 M39 CC0319 ICIV 5/26/96 85 6552 M48 CV0026 ICIV 10/18/93 1473 2184 M48 CV0026 ICIV 3/17/95 1472 2184 M48 CV0026 ICIV 5/27/96 802 2184 M51A CV0034A ICIV 9/24/93 258 1092 M51A CV0034A ICIV 3/18/95 27 1092 M51A CV0034A ICIV 5/23/96 162 1092 M51B CV0034B ICIV 9/24/93 21 1092 M51B CV0034B ICIV 3/18/95 0 1092 M51B CV0034B ICIV 5/23/96 0 1092 M52C CV0034C ICIV 10/11/93 6 1092 M52C CV0034C ICIV 3/18/95 30 1092 M52C CV0034C ICIV 5/24/96 0 1092 M52D CV0034D ICIV 10/4/93 0 1092 M52D CV0034D ICIV 3/18/95 5 1092 M52D CV0034D ICIV 5/24/96 0 1092 M58 IA0541 ICIV 9/12/93 43 1092 M58 IA0541 ICIV 3/21/95 229 1092 M58 IA0541 ICIV 5/19/96 31 1092 M77 FP0943 ICIV 12/16/93 3333 (*) 3276 M77 FP0943 ICIV 3/18/95 162 3276 M77 FP0943 ICIV 5/23/96 1024 3276

• Test performed without slipblind installed on the boundary valves.

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Attachment 8 -

NOC-AE-000280 Page1 Risk Perspective on Containment Isolation Check Valves.

The containment isolation function is designed to limit the leakage of radioactive materials through lines penetrating the Reactor Containment Building (RCB) so that the site boundary dose guidelines specified in 10CFR100 are not exceeded following a Loss-of-Coolant Accident (LOCA) or other design basis accident. Upon receipt of the appropriate signals, isolation of the RCB is accomplished by automatic isolation of all non-essential fluid systems, which penetrate the RCB.

The plant specific Probabilistic Safety Analysis (PSA) analyzes containment isolation for mitigating releases to the environment. The index ofinterest is the Large Early Release Frequency (LERF). This measures the frequency of an event that will exceed 10CFR100 in a short period of time. This function is documented in the STPEGS Probabilistic Safety Assessment ContainmentIsolation Function Package.

Failure of containment penetrations less than 3" in diameter does not contribute to LERF in the j

South Texas Project PSA. The containment isolation fimetions discussed below have little risk )

impact on LERF at the South Texas Project. A PSA risk ranking sensitivity study demonstrates the low risk importance for the containment isolation function. Failute of the containment isolation function does not affect the core damage frequency.

I The following describes how each of the valves in this submittal are modeled in the plant-specific j

- PSA:

1 CV-0034A/B/C/D (IRC) Reactor Coolant Pump (RCP) Seal Injection Line Check Valves

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The check valves provide a second barrier to normally open Motor Operated Valves (MOVs)

MOV033A, B, C and D. RCP sealinjection is isolated upon receipt of a containment phase A isolation signal concurrent with a charging header low-pressure signal. Since continued seal  !

injection to the RCPs is highly desirable in order to prevent an RCP seal LOCA, the isolation i

valves are permitted to remain open as long as seal injection is actually occurring (i.e., the i charging system is providing seal injection). The sealinjection lines are less than 3" in diameter I E

and therefore do not contribute to LERF. i 1 CC-0319 Reactor Coolant Pump CCW Supply IRC Check Valves

- This check valve provides a second barrier to normally open MOVs CC-0318 and CC-0291. The CCW MOVs are isolated upon receipt of a containment phase B isolation signal. Since continued

- cooling to the RCPs is highly desirable, the isolation valves are permitted to remain open as long as cooling is actually occurring. These valves are credited in the PSA for remaining open to provide reactor coolant pump cooling during an accident.

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Attachment 8 NOC-AE-0(X)280 Page 2 CCW is supplied to the motor air coolers, the lube oil coolers and to the thermal barrier heat exchanger for the RCPs. Two additional check valves in the supply line to each RCP thermal barrier heat exchanger provides additional isolation capability. The supply to the motor and lube

oil coolers is a closed system inside containment.

Because CCW to the RCPs is a system inside containment or backed up by additional check valves, and the PSA function requires the valves remain open, these check valves are not included in the analysis of the containment isolation function.

1-CV-0026 CVCS Charging IRC Containment Isolation Check Valve 1-CV-0026 is credited for maintaining reactor coolant system water level (i.e., charging) by opening and remaining open. Since charging is desirable for accident mitigation, this isolation valve ; 4 redited in the PSA foi , maining open.

The CVCS system is a closed high-pressure system inside containment with additional pressure isolation provided by the normal charging supply check valves CV0001 and CV0002 (or CV0004 and CV0005). Therefore, this valve has no risk impact for LERF.

1-FP-0943 Fire Protection Isdation Normally isolated line. 1-FP-0943 is a check valve in series with normally closed MOV FP-0756.

For this reason, this containment penetration is not modeled in the PSA.

1-IA 0541 Instrument AirSupply Isolation The instrument air system is a closed high-pressure system, which does not communicate with the containment atmosphere, therefore this containment penetration is not modeled in the PSA.

In conclusion, from a risk perspective, the above valves have little impact on the frequency of a Large Early Release and no impact on core damage frequency. This is due, in part, to the plant design and the role the above check valves play in mitigating accidents.

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