NOC-AE-04001780, License Amendment Request Proposed Revision to the Technical Specifications Regarding Deletion of Requirements Related to Hydrogen Recombiners and Hydrogen Analyzers Using the Consolidated Line Item Improvement Process

License Amendment Request Proposed Revision to the Technical Specifications Regarding Deletion of Requirements Related to Hydrogen Recombiners and Hydrogen Analyzers Using the Consolidated Line Item Improvement Process

ML042520321
Person / Time
Site:	South Texas
Issue date:	08/26/2004
From:	Jordan T South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G-25, NOC-AE-04001780, STI: 31784365
Download: ML042520321 (19)

Text

Nuclear Operating Company South Tea~s PmCCElrdricGnentngSbtion P.Ba2839 adsrth TcZs 77483 August 26,2004 NOC-AE-04001780 File: G-25 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 License Amendment Request Proposed Revision to the Technical Specifications Regarding Deletion of requirements related to Hydrogen Recombiners and Hvdrogen Analyzers Using the Consolidated Line Item Improvement Process STP Nuclear Operating Company (STPNOC) submits the attached proposed amendment to South Texas Project Operating Licenses NPF-76 and NPF-80. This license amendment request proposes revising the Technical Specifications (TS) to delete the TS requirements related to Hydrogen Analyzers and Hydrogen Recombiners in Specifications 3.6.4.1 and 3.6.4.2, respectively, consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Traveler number TSTF-447 Revision 1, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this Technical Specification improvement was announced in the Federal Register on September 25, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

STPNOC requests approval of the proposed amendment by August 1,2005 and requests 60 days for implementation of the amendment after it is approved.

The STPNOC Plant Operations Review Committee has reviewed and concurred with the proposed change to the Technical Specifications. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides revised TS pages. Implementation of TSTF-447 also involves various changes to the TS Bases. Attachment 4 provides marked-up TS Bases for information. The TS Bases changes will be submitted with a future update in accordance with TS 6.8.3 m, "Technical Specifications (TS) Bases Control Program."

(t STI:31784365

NOC-AE-04001780 Page 2 of 3 STPNOC has determined that this License Amendment Request (LAR) does not involve a significant hazard consideration as determined per 10 CFR 50.92.

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

Commitments made in this license amendment request are identified in , section 6.0.

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

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

W. R. Bealefield at (361) 972-7696 or me at (361) 972-7902 I declare under penalty of perjury that the foregoing is true and correct.

Executed on A +024)Z04-T. J. ordan Vice President, Engineering & Technical Services wrb/

Attachments:

1. Description of Changes and Safety Evaluation

2. Annotated Technical Specification Pages

3. Retyped Technical Specification Pages

4. Annotated Technical Specifications Bases Changes (Information Only)

NOC-AE-04001780 Page 3 of 3 cc:

(paper copy) (electronic copy)

Bruce S. Mallett A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission David H. Jaffe Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP Texas Central Company Jeffrey Cruz Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-04001 780 Attachment 1 Page 1 of 4 Attachment 1 Description of Changes and Safety Evaluation

NOC-AE-04001780 Attachment 1 Page 2 of 4 Description of Changes and Safety Evaluation 1.0 Description The proposed amendment would delete Technical Specification (TS) requirements related to hydrogen analyzers and hydrogen recombiners in Specifications 3.6.4.1 and 3.6.4.2, respectively. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) change TSTF-447, Revision 1, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors",

as noticed in the Federal Register published on September 25, 2003 reference 9.1. That Federal Register Notice announced the availability of this TS improvement through the Consolidated Line Item Improvement Process (CLIIP).

The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors,"

A summary of the proposed changes and their justification, presented in table format, is provided below.

TS Number Description- Proposed Change Justification Table 3.3-10 Accident Monitoring Delete instrument 20 TSTF-447 revision 1 Instrumentation-Instrument 10 CFR 50.44 20 Containment Hydrogen Concentration Table 4.3-7 Accident Monitoring Delete instrument 20 TSTF 447 revision 1 Instrumentation 10 CFR 50.44 Surveillance Requirements-Instrument

20. Containment Hydrogen Concentration 3.6.4.1 Combustible Gas Control Delete Limiting Condition TSTF-447 revision 1 Hydrogen Analyzers for Operation and 10 CFR 50.44 Surveillance Requirements 3.6.4.2 Combustible Gas Control Delete Limiting Condition TSTF-447 revision 1 Electric Hydrogen for Operation and 10 CFR 50.44 Recombiners Surveillance Requirements The TS Bases will be revised to reflect these changes to the affected bases sections in accordance with TS 6.8.3.m, "Technical Specifications (TS) Bases Control Program," as part of the implementation of this amendment, upon NRC approval of this amendment application. Proposed changes to the TS Bases are provided for information only in Enclosure 4.

NOC-AE-04001780 Attachment 1 Page 3 of 4 2.0 Assessment Applicability of Published Safety Evaluation STP Nuclear Operating Company (STPNOC) has reviewed the safety evaluation dated August 4, 2003, as part of TSTF447 Rev. 1 reference 9.2. This review included the NRC staff evaluation and the supporting information provided to support TSTF-447 Rev. 1. STPNOC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to South Texas Project (STP) Units 1 and 2, and justify this amendment for incorporating the changes into the STP TS.

3.0 Regulatory Analysis No Significant Hazards Determination STPNOC has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the CLI1P.

STPNOC has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to STP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

4.0 Regulatory Requirements and Guidance The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416-55421), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 Technical Analysis STPNOC has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416-55421), as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE, as well as the supporting information provided to support TSTF-447, Revision 1. STPNOC has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to South Texas Project Electric Generating Station, Units 1 and 2, and justify this amendment for the incorporation of the changes to the STP TS.

NOC-AE-04001780 Attachment 1 Page 4 of 4 6.0 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416-55421), for this TS improvement, STPNOC is making the following verifications and regulatory commitments:

1. STPNOC has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at STP and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual (TRM). This regulatory commitment will be implemented within 60 days of issuance of the license amendment.

2. STP does not have an inerted containment.

7.0 Environmental Evaluation STPNOC has reviewed the environmental evaluation included in the model safety evaluation dated August 4, 2003, as part of TSTF-447 rev. 1 reference 9.2 and the environmental consideration in NRC staff model published on September 25, 2003 (68 FR 55416-55421). STPNOC has concluded that the staff's findings presented in those evaluations are applicable to STP and the evaluations are hereby incorporated by reference for this application.

8.0 Precedent This application is being made in accordance with the CL11P. STPNOC is not proposing variations or deviations from the TS changes described in TSTF-447, Revision 1, or the NRC staffs model Application published on September 25, 2003 (68 FR 55416-55421) for Pressurized Water Reactors.

9.0 References 9.1 Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416-55421).

9.2 Technical Specification Task Force Traveler TSTF447 Revision 1.

Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors

NOC-AE-04001780 Attachment 2 Page 1 of 5 Attachment 2 Annotated Technical Specification Pages

TABLE 3.3-10 (Continued)

ACCIDENT MONITORING INSTRUMENTATION TOTAL MINIMUM NO. OF CHANNELS INSTRUMENT CHANNELS OPERABLE ACTION

13. Containment Water Level 2 1 36 (Narrow Range)

14. Containment Water Level (Wide Range) 3 1 37

• • 2

15. Core Exit Thermocouples 42 I

16. Steam Line Radiation Monitor 1/steam line 1/steam line 40

17. Containment - High Range Radiation Monitor 2 1 39

18. Reactor Vessel Water Level (R\VWL) 2* 1* 41

19. Neutron Flux (Extended Range) 2 1 36

20. Containmont Hydrogen Concentration 12 4 36

21. Containment Pressure (Extended Range) 2 1 36

22. Steam Generator Blowdown Radiation Monitor 1/blowdown line 1/blowdown line 40

23. Neutron Flux - Startup Rate 2 1 36 (Extended Range)

• A channel is eight sensors in a probe. A channel is OPERABLE if four or more sensors, one or more in the upper section section and three or more in the lower section, are OPERABLE.

• • A channel is OPERABLE if at least two core exit thermocouples per core quadrant are OPERABLE, and at least one quadrant has at least four OPERABLE thermocouples.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-69 Unit 1 - Amendment No. 77 Unit 2 - Amendment No. 66

TABLE 4.3-7 (Continued) cn 0

C ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS I-i CHANNEL CHANNEL INSTRUMENT CHECK CALIBRATION C

18. Reactor Vessel Water Level (RVWL) M R z

19. Neutron Flux (Extended Range) M R to

20. Containmont Hydrogon Concentration M R

21. Containment Pressure (Extended Range) M R

22. Steam Generator Blowdown Radiation Monitor M R

23. Neutron Flux - Startup Rate (Extended Range) M R 9-.4

CONTAINMENT SYSTEMS 3/4.6.4 COMBUSTIBLE GAS CONTROL HYDROGEN ANALYZERS LIMITING CONDITION FOR OPERATION 3.6.4.1 T'.vo independent containment hydrogon analyzore shall bo OPER.A.BLE.

APPLICABILITY: MODES 1 and 2.

a. With one hydrogeR anal inrble, eetre the inoperable a-nalyer to OPER ARIE etatur. within 30 dayc or be in at leact HOT STANDBY Wvithin the noxt 6 hou6.

b. With both hydrogen analyzeFr inoperable, roctore at least one analyzer to OPERABLE statuc within 72 houre or be in at leart HOT STANDBY within the next 6 houre.

SURVEILLAANCE REQUIREMEJNTS 1.6.1.1 Each hydroegenaRalyzer hall be dmornncRtratoed O)PEARABLE by the rerfrFoRrr of a CHGA.NNEL CHECK-at least once per 142 hour0.00164 days <br />0.0394 hours <br />2.347884e-4 weeks <br />5.4031e-5 months <br />, an ANALOG CHANNEL OPERA4TIONAL TEST at leact once per 31 dayr, a channel OPERABILITY verifiation at leact Rton per 092 dayc n-a ST.A.GGERED TEST BASIS ucing 6ample gar containing one volume percent hydrogen, balance nitrogen, and by peforming a CHANNEL CALIBRATION at least once per 18 monthe ucing cample

_ar cntai;nin tonR volume percent hydIrogn, balanc n;itrgen SOUTH TEXAS - UNITS I & 2 3/4 6-18 Unit 1 - Amendment No. 34, 42 Unit 2 - Amendment No. 24, 34

CONTAINMENT SYSTEMS ELECTRIC HYDROGEN RECOMBINERS LIMITING CONDITION FOR OPERATION 3.6.4.2 T4'v indlnponednt Hydrogen Rocombinor Systoms chall be OPER.BL-E.

ADDI1 11>AMII 1IT%. RlAtr'I'-CI 4 -- A n

. - . - _. . .. . . . . MvMwwF=_t3 M CIMM 32.

AGT4ON-With one Hydrogen Rocombiner Syctom inoperable, restore tho inoperable ycteom to OPER.ABLE status within 30 days or bo in at least HOT STANDBY within tho next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS A.6.1.2 Each HydUrogen Rocmbinor System shall be dmon trated- QPERABI E:

A. At leas;t oncepr 6 mnRths by vorifying, dFing a Hydrogen RRcomhinFe Syrtem functional tost, that the minimum heater sheath temperature increases to greater than or equal to 400-00 F w.ithin 00mintesU at 52 kW. Uponr reching

-- 1000F, iRnroae the power setting to maximum power far 2 minutes and verify that the power meter reads greater than or equal to 65 A., 1 and L AL I - - -.L AQ - - -Ar h-L..

I.

U MtL MdbtA UrdlLU ptJUI le MIIUilIl LUy.

1) Performing a CHANNEL CA.LIBR1ATION of all recombinor instrumentation and control circuits,

2) Verifying through a visual oxarTnination that there is no evidence of abnormal conelitions wthin the rocombin 4 Frenclorsue (i.e., loose wiring or 6tw tUral connections. deposits el foreigr nmaterials, etc.), and

3) Verifying the integrity of all heater electrical circuits by perfomming a resistance to ground test following the above requirod functional test. The resistance to ground for any heater phase Shall be greater than or equal to 1 0,000 ohm.

SOUTH TEXAS - UNITS 1 & 2 3/4 6-19 Unit 1 -Amendment No. 30, 42 Unit 2 - Amendment No. 24, 34

NOC-AE-04001 780 Attachment 3 Page 1 of 5 Attachment 3 Retyped Technical Specification Pages

CONTAINMENT SYSTEMS 3/4.6.4 COMBUSTIBLE GAS CONTROL HYDROGEN ANALYZERS LIMITING CONDITION FOR OPERATION 3.6.4.1 Section 3.6.4.1 has been deleted I

SOUTH TEXAS - UNITS I & 2 3/4 6-18 Unit 1 - Amendment No. 30,42 Unit 2 - Amendment No. 2, 34

CONTAINMENT SYSTEMS ELECTRIC HYDROGEN RECOMBINERS LIMITING CONDITION FOR OPERATION 3.6.4.2 Section 3.6.4.2 has been deleted I SOUTH TEXAS - UNITS 1 & 2 3/4 6-19 Unit 1 - Amendment No. 30, 42 Unit 2 - Amendment No. 24, 34

TABLE 3.3-10 (Continued)

ACCIDENT MONITORING INSTRUMENTATION TOTAL MINIMUM NO. OF CHANNELS INSTRUMENT CHANNELS OPERABLE ACTION

13. Containment Water Level 2 I 36 (Narrow Range)

14. Containment Water Level (Wide Range) 3 I 37

• 2 42

15. Core Exit Thermocouples

16. Steam Line Radiation Monitor 1/steam line 1/steam line 40

17. Containment - High Range Radiation Monitor 2 1 39

18. Reactor Vessel Water Level (RVWL) 2* 1* 41

19. Neutron Flux (Extended Range) 2 1 36

20. Not Used

21. Containment Pressure (Extended Range) 2 1 36 I

22. Steam Generator Blowdown Radiation Monitor 1/blowdown line 1/blowdown line 40

23. Neutron Flux - Startup Rate 2 1 36 (Extended Range)

• A channel is eight sensors in a probe. A channel is OPERABLE if four or more sensors, one or more in the upper section section and three or more in the lower section, are OPERABLE.

• • A channel is OPERABLE if at least two core exit thermocouples per core quadrant are OPERABLE, and at least one quadrant has at least four OPERABLE thermocouples.

SOUTH TEXAS - UNITS 1 & 2 3/4 3-69 Unit I - Amendment No. 2-Unit 2 - Amendment No. 66

TABLE 4.3-7 (Continued)

U) 0 C ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS

--I I

CHANNEL CHANNEL INSTRUMENT CHECK CALIBRATION

18. Reactor Vessel Water Level (RVWL) M R C

z CL 19. Neutron Flux (Extended Range) M R

20. Not Used I

21. Containment Pressure (Extended Range) M R

22. Steam Generator Blowdown Radiation Monitor M R C;0

23. Neutron Flux - Startup Rate (Extended Range) M R

-!4

NOC-AE-04001 780 Attachment 4 Page 1 of 2 Attachment 4 Technical Specifications Bases Changes (Information Only)

FOR INFORMATION ONLY CONTAINMENT SYSTEMS BASES 3/4.6.2.3 CONTAINMENT COOLING SYSTEM (continued)

STPEGS has three groups of Reactor Containment Fan Coolers (RCFCs) with two fans in each group (total of six fans). Five fans are adequate to satisfy the safety requirements including single failure. If only one RCFC, out of six available, is inoperable, then there are no restrictions applied on the diesel generators by the RCFC condition and Action statement 3.8.1.1(d) (1)can be met. The fan cooler units are designed to remove heat from the containment during both normal operation and accident conditions. In the event of an accident, all fan cooler units are automatically placed into operation on receipt of a safety injection signal. During normal operation, cooling water flow to the fan cooler units is supplied by the non-safety grade chilled water system. Following an accident, cooling water flow to the fan coolers is supplied by the safety grade component cooling water system. The chilled water system supplies water at a lower temperature than that of the component cooling water system and therefore requires a lower flow rate to achieve a similar heat removal rate.

3/4.6.3 CONTAINMENT ISOLATION VALVES 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 requirements of General Design Criteria 54 through 57 of Appendix A to 10 CFR Part 50. Containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

Inthe event one containment isolation valve in one or more penetrations is inoperable, and the inoperable valve(s) cannot be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the affected penetration(s) must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and deactivated automatic isolation valve, a closed manual valve, a blind flange, or a check valve with flow through the valve secured (acheck valve may not be used to isolate an affected penetration flow path in which more than one isolation valve is inoperable or in which the isolation barrier is a closed system with a single isolation valve). For a penetration flow path isolated in accordance with Action b or c, the device used to isolate the penetration should be the closest available one to containment and does not have to be a General Design Criterion containment isolation valve.

Incases where multiple isolation valves use the same pipe going through the penetration and with one or more isolation valves inoperable, as long as the inoperable valve(s) is deactivated/manually isolated in its isolation position and the interconnecting isolation valves are operable, the appropriate Action statement is met. In these cases, the Action statement 'Isolate each affected penetration..." means 'Isolate each affected penetration flow path". (CR 97-908-1) 3/4.6.4 COMBUSTIBLE GAS CONTROL Tho OPERA.BILITY of the equipment and systems roquired for the detction and control ot hydrogen gas ensures that this equipmont will be s'ailable to maintain the hydrogen concentration within containment below its flammable limit during poet LOCA conditions. Either rocombiner unit is capable of controlling the oxpected hydrogen generation as6ociated with: (1) zirconium water reactions, (2) radiolyfio decomposition of wator, and (3) corrosion of metals wthin containment. These Hydrogon Control Systems are consistent with the recommendations of Regulatory Guide 1.7, "Control of Combustible Gs Concentrations in Containment Following a LOCA," Revision 2, November 1978.

SOUTH TEXAS - UNITS 1 & 2 B 3/4 6-4 Unit 1 - Amendment No.

Unit 2 - Amendment No.

02-6107