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

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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
ML20238F077
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/28/1998
From: Cottle W
HOUSTON LIGHTING & POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20238F079 List:
References
NOC-AE-000280, NOC-AE-280, NUDOCS 9809030093
Download: ML20238F077 (9)
v • d • e


Text

. .

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August 28,1998 {

NOC-AE-000280 )

File No.: G21.02.01 STI : 30702090 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Proposed Exigent Amendment to South Texas Project Technical Specification 4.0.5 for Surveillance Requirements for Inservice Insoection and Testing of ASME Components STP Nuclear Operating Company (STPNOC) proposes to revise Technical Specification 4.0.5 to exclude specified containment isolation valves from the inservice testing requirements as stated in Section XI of the ASME Boiler and Pressure Vessel Code.

South Texas Project has reviewed the proposed amendment pursuant to 10CFR50.92 and determined that it does not involve a significant hazards consideration. In addition, 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 Plant Operations Review Committee and the Nuclear Safety Review Board have reviewed and approved the proposed amendment.

The required affidavit, a Safety Evaluation and Determination of No Significant Hazards Consideration, and the marked-up affected pages of the Technical Specifications are included as attachments to this letter. /,

/

In accordance with 10 CFR 50.91(b), South Texas Project is notifying the State of Texas O l- of this request for license amendment by providing a copy of this letter and its attachments.

This exigent Technical Specification change is in support of a request for enforcement l discretion granted by the Nuclear Regulatory Commission at 1605 on August 27,1998. The l-conditions requiring the enforcement discretion and this exigent Technical Specification change resulted from a review of surveillance test data. This development was not foreseen and once identified could not reasonably have been avoided. Upon discovery of the situation South Texas 9809030093 980828 -

PDR ADOCK 05000498' P PDR j

. NOC-AE-000280 File No.: G21.02.01 Page 2 Project imrnediately commenced testing those valves that could be tested at power. Further

- review revealed that there were some valves that would require a plant shutdown to complete testing. At this point South Texas Project contacted the Nuclear Regulatory Commission to inform them of the situation and that a request for enforcement discretion was being considered.

' South Texas Project requests 7 days to implement this change after receipt.

If there are any questions regarding the proposed amendment, please contact Mr. M. A.

McBurnett at (512) 972-72% or me at (512) 972-8434.

l l

M i-W. T. Cottle l President and Chief Executive Officer l

Attachments:

1. Affidavit
2. Description of Change and Safety Evaluation
3. Determination of No Significant Hazards
4. Environmental Assessment l - 5. Annotated Technical Specifications
6. Containment Isolation Valves affected

! 7. Affected Containment Isolation Valve Test Results

8. Risk Perspective on Containment Isolation Check Valves.

t l:

i

_____a

, NOC-AE-000280 File No.: G21.02.01 Page 3 Ellis W. Merschoff Jon C. Wood Regional Administrator, Region IV Matthews & Branscomb U. S. Nuclear Regulatory Commission One Alamo Center 611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700 Arlington, TX 76011-8064 San Antonio,TX 78205-3692 i

Thomas 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 Cornelius F. O'Keefe Richard A. Ratliff Sr. Resident Inspector Bureau of Radiation Control c/o U. S. Nuclear Regulatory Commission Texas Department of Health (

P. O. Box 910 1100 West 49th Street l Bay City,TX 77404-0910 Austin, TX 78756-3189 l l

J. R. Newman, Esquire D.G. Tees /R. L. Balcom Morgan, Lewis & Bockius Houston Lighting & Power Co. ,

1800 M. Street, N.W. P. O. Box 1700 Washington, DC 20036-5869 Houston,TX 77251 M. T. Hardt/W. C. Gunst Central Power and Light Company City Public Service A'ITN: G. E. Vaughn/C. A. Johnson P. O. Box 1771 P. O. Box 289, Mail Code: N5012 San Antonio,TX 78296 Wadsworth,TX 77483 i A. Ramirez/C.M. Canady U.S. Nuclear Regulatory Commission City of Austin Attention: Document Control Desk Electric Utility Department Washington, DC 20555-0001 721 Banon Springs Road Austin,TX 78704 i

L______.-- - - - _ _ _ _-- - - -

Attachment 1 NOC-AE-000280 Page 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter )

)

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

) STN 50-499 South Texas Project Units 1 and 2 )

i l

AFFIDAVIT i

I, W. T. Cottle, being duly sworn, hereby depose and say that I am President and Chief Executive Officer of STP Nuclear Operating Company; that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached proposed Technical Specification change to modify requirements associated wits Technical Specification 4.0.5; that I am familiar with the content thereof; and that the matters o t forth therein are true and correct to the best of my knowledge and belief.

eO V W W. T. Cottle President and Chief

, Executive Officer l

STATE OF TEXAS )

)

COUNTY OF A1MA66Ab8 )

Subscribed and sworn to before me, a Notary Public in and for the State of Texas, this l M dayof Mase ,1998, i

h L J. M M ,

i. * . NotaryPsc,8meofTexas uy ce=*mn > Notary Public in a,nd for the

'___ JULY 27,1999 ---

State of Texas

Attachment 2 NOC-AE-000280 Page1 Description of Change and Safety Evaluation Description of Change:

Technical Speci6 cation 4.0.5 (page 3/4 0-3) is modified by adding an astetisk, with a note at the-bottom of the page, that reads:

  • 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.

Technical Specification 4.0.5 requires that inservice testing of ASME Code Class 1,2, and 3 valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(i). STPNOC has established relief to test the affected valves at a periodicity of each cold shutdown of sufficient duration or refueling outage.

The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment and is consistent with the mquirements of General Design Criteria 54 through 57 of Appendix A to 10 CFR Part 50.

During a review of the Inservice Test Plan for Unit 1, it was determined that 17 specific containment isolation check valves had not been tested in the required position for performing a specific safety function (closed) within the required testing periodicity of the Section XI ASME Code. Evaluation has shown that 9 of the identified valves should be able to be tested on line, and 8 (shown in Attachment 6) will require a plant shutdown to Mode 5 for testing.

1 Relief from the ASME Code requirements to extend the test frequency to cold shutdowns of l sufficient duration or a refueling outage had previously been established for the check valves.

The valves have met Section XI ASME Code requirements for testing in the open direction.

These valves have been historically tested in the closed direction by performance oflocal leak l

' rate te_ sting required by Appendix J of 10CFR50. STPNOC received a license amendment to Technical Specifications in August 1996 for allowing performance-based containment leak testing per Appendix J, Option B of 10CFR50. Ieak rate performance allowed extension of the localleak rate test frequency to periodicities beyond each refueling cycle. The frequency of the appropriate plant surveillance for leak rate testing was extended for the affected valves.

However, an alternate test method to test the valves in the closed direction was not developed to meet the Section XI ASME Code test frequency requirements. As a result, these check valves would only be tested in the closed direction when the localleak rate test was performed.

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Attachment 2 NOC-AE-000280 Page 2 Since these valves were deternuned to be inoperable because of the missed surveillance, the ACTION requimments of Technical Specification 3.6.3 for containment isolation valves was entered for each valve at 1830 hours0.0212 days <br />0.508 hours <br />0.00303 weeks <br />6.96315e-4 months <br /> on August 26,1998, and a Request for Enforcement Discretion was approved at 1605 hours0.0186 days <br />0.446 hours <br />0.00265 weeks <br />6.107025e-4 months <br /> on August 27,1998, to allow submission and approval of this Technical Specification change request for the 8 valves that are the subject of this change.

A separate Enforcement Discretion has been granted to complete testing for the remaining 9 valves.

Prompt action is requested to approve this exigent Technical Specification change postponing the testing of these valves for the period from the time tne valves wem last tested until the next

- cold shutdown period of sufBeient duration or the next mfueling outage.

Safety Evaluation:

The purpose of the containment isolation valves ensures that the contamment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment. The valves for which this change is being requested tested satisfactorily in the closed position in accordance with ASME Code requirements the last time that the test was performed. Performance-based local leak rate testing results have demonstrated the leak tightness of these valves such that leak rate testing periodicities have been extended beyond the periodicity of a normal refueling cycle. Maintenance history has demonstrated reliable performance of these valves.

A summary of recent test results is included in Attachment 7.

As_noted above, the subject valves have exhibited a history of satisfactory operation. Based on this, the current Probabilistic Safety Analysis (PSA) modeling of the failure rates for these valves is still accurate. Irrespective of the failure rate modeling, the South Texas Project PSA model indicates that the potential failure of these valves to close has no impact on core damage frequency. In addition, the impact of these valves [ assuming complete failure] from a Large Early Release standpoint is minimal. Additional discussion of the PSA' modeling aspects for the subject valves is included in Attachment 8.

Based on the above, it is evident that in the event that containment isolation is necessary, the subject valves will have a high probability of performing their intended safety function.

Therefore, STPNOC concludes that safety significance and potential consequences of the

. proposed plan of action are minimal.

l

mm 1 Attachment 3 NOC-AE-000280 Page1 No Significant Hazards Determination:

In accordance with the criteria set forth in 10CFR50.92, the South Texas Project has evaluated the proposed Technical Specification change and determined it does not represent a significant hazard consideration. The following is provided in support of this conclusion.

1. - Does the change involve a significant increase in the probability or consequence of an accident previously evaluated?

No.

The proposed change would relieve the requirement to apply Surveillance 4.0.5 to the subject check valves. Specifically, STPNOC would not have to perform the ASME Section XI exercise of the valves. Neither the valves nor the systems of which they are a part are accident initiators. The proposed change is essentially a deferral of surveillance test intervals, which has no potential effect on accident initiation.

'Ihemfom, there is no significant increase in the probability of occurrence of an accident previously evaluated in the Safety Analysis Repon.

Previous testing of the valves has demonstrated that they are capable of performing their design function. Therefore, the systems of which they are a part would be expected to perform accident mitigation and safe shutdown functions as designed.

There is no effect on safety analysis assumptions from the proposed discretion.

Consequently, there is no significant increase in the consequences of an accident previously evaluated in the Safety Analysis Repon.

There is no significant increase in the probability of malfunction of equipment important to safety previously evaluated in the Safety Analysis Report because past leak testing of the subject check valves has shown the valves to be able to close and seal as required. The extended surveillance test intervalinvolves no challenge to the function of the valves.

2. Does the change create the possibility of a new or diffemnt kind of accident from any accident pmvlously evaluated?

No.

l The effect of the proposed change is to extend the surveillance test interval. This extension has no effect on the way the subject systems are operated, nor does it affect the configuration of the station. It does not introduce the potential for any

- new failure modes. Therefore, the change does not involve a possibility of an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report. i

Attachment 3 NOC-AE-000280 Page 2

3. Does this change involve a significant nduction in a man:in of safety?

No.

The proposed extension of the testing will not affect a margin of safety for any Technical Specincation because there is no change in the design functions or performance of any of the subject systems. All design margins remain unchanged from the existing design basis. Therefore, the proposed extension of the testing does not involve a significant reduction in a margin of safety.

Based on the above evaluation, no Significant Hazard exists.

Since there is no Significant Hazard associated with the missed surveillance, there is no potential detriment to the public heath and safety as a result of this request.

p. .

Attachment 4 NOC-AE-000280 Page1

. ENVIRONMENTAL ASSESSMENT This proposed Technical Specification Change has been evaluated against the criteria for and l . identification oflicensing and regulatory actions requiring environmental assessment in i - accordance with 10CFR51.21. It has been determined that the proposed changes meet the criteria L

for categorical exclusion as provided for under 10CFR51.22 (c) (9). The following is a discussion

. of how the proposed Technical Specification Change meets the criteria for categorical exclusion.

!' 10CFR51.22 (c) (9): Although the proposed change involves changes to requirements with respect to inspection or surveillance requirements; (i)- The proposed change involves no Significant Hazards Consideration (refer to the No Significant Hazards Consideration section of this Technical Specification Change Request),

l (ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed changes do not affect the .

generation of any radioactive effluents nor do they affect any of the permitted release paths, and

- (iii) - There is no significant increase in individual or cumulative occupational radiation exposure.

- Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22 (c)(9). Based on the aforementioned and pursuant to 10CFR51.22 (b), no environmental assessment or environmentalimpact statement need be prepared in connection with

. issuance of an amendment to the Technical Specifications incorporating the proposed changes of this request.

L

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