ST-HL-AE-3704, Application for Amends to Licenses NPF-76 & NPF-80,changing TS 3.3.3.1,Table 3.3-6,Functional Unit 1.a Re Operability Action Statement for Containment Atmosphere Radioactivity High Monitor

Application for Amends to Licenses NPF-76 & NPF-80,changing TS 3.3.3.1,Table 3.3-6,Functional Unit 1.a Re Operability Action Statement for Containment Atmosphere Radioactivity High Monitor

ML20070D330
Person / Time
Site:	South Texas
Issue date:	02/22/1991
From:	Kinsley W HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20070D332	List: ML20070D339 ST-HL-AE-3704, Application for Amends to Licenses NPF-76 & NPF-80,changing TS 3.3.3.1,Table 3.3-6,Functional Unit 1.a Re Operability Action Statement for Containment Atmosphere Radioactivity High Monitor
References
ST-HL-AE-3704, NUDOCS 9102280205
Download: ML20070D330 (8)

Text

- - -- - -

The Light company PR lim 1700 l tomton. ' lim 77001 (713) 228 9211 Ilomton 1.ighting& Power February 22, 1991 ST litr AE 3704 File No.: 09 06 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Unita 1 and 2 Docket Nos. STN 50 498, STN 50 499 Proposed Amendment to Technical Epgel ficat ion 3. 3. 3.1. Table 3. ') 6. Furic t ional Uni t 1.n Thlu stiomittal proposes a change to South Texas Project Electric Generating Station (STPEGS) Technical Specification 3.3.3.1. Table 3.3 6, Functional Unit 1.a. This proposed change af fects the operability action statement for the containment atmosphere radioactivity-high monitor. This chang. will allow the contaitunent atmosphero radioactivity-high monitor to be isolated from contaitunent for the duration of an Integrated Lenk Rate Test (IIRT) . fhis change was the subject of a Waiver of Compliance granted by the Nuc1 car Regulatory Commission (NRC) on January 8, 1991, that provided relief f rom the requirements of Technical Specification 3.3.3.1 during the recent IIRT perf ormed during the current Unit I refueling outage, llouston Lighting 6 Power Company (IllAP) has reviewed the attached proposed amendment pursuant to 10CFR50.92 and determined that it does not involve a significant hazardn consideration. The basta for this determination is provided in the attachment. In addition, based on the information contained in this submittal and the NRC Final Environmental Assessment for STPEGS Units 1 and 2, lit 4P has concluded that, pursuant to 10CFRS1, there are no significant radiological or non radiological impacts associated with the proposed action, and the proposed license amendment will not have a e significant effect on the quality of the environment.

The STPEGS Nuclear Safety Review Board has reviewed and approved the proposed change.

In accordance with 10CFR50.91(b), Ill4P is providing the State of Texas with a copy of this proposed aniendment.

MiO (' 01 l

Al/009.N20 A Subsidiary of llomtal: Indust t irt .tu orporated j (

9102280205 910222 t PDR ADOCK 05000498 i g\

P PDR \

. , llouston' Lighting & Power Company

- South Texas Project Electric Generating Station

. ST llL AE 3704 F;le No.: G9.06 q P6te 2 If you should have any questions concerning this nu tter, please contact Mr. A. W. liarrison at (512) 972 7298 or myself at (512) $72 7921.

fi&g i . \

W. P. Kinsey -

i'J,;e President

'.uclear Generation BR/sgs Attachments: 1. Significant llazards Evc.luation for a .

Proposed Change to Technical Specification 3.3.3.1 Table 3.3-6, Functional Unit 1.a.

2. Proposed Technical Specification 3.3.3.1. Tabic 3.3 6 Functional Unit 1.a.

I 1

f I

A1/009.N20

1

- llouston Lighting & Powe: Comp:ny ST HL AE 3704 ,

South Texas Proj,ect Electric Generating Station rile No. G9.06

, Page 3 cc:

Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 George Dick, Project Manager U.S. Nuclear Regulatory Commission INPO Washington, DC 20555 Records Center 1100 Circle 75 Parkway J. I. 1apia Atlanta, CA 30339-3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendric Commission 50 Be11 port Lane P. O. Box 910 Be11 port, NY 11713 Bay City, TX 77414 D. K. Lacker J. R. Newman, Esquire Bureau of Radiation Control '

Newman & Holtzinger, P.C. Texas Department of Health 1615 L Street, N.W. 1100 West 49th Street Washington, DC 20036 Austin, TX 78756 3189 D. E. Ward /T. M. Puckett Central Power ar.d Light Company P. O. Box 2121 Corpus Christi, TX 78403

-J. C. Lanier/M. B. Lee City of Austin Electric Utility Department P.O. Box 1088 Austin,.TX 78767 R. J. Costello/M. T. Hardt City Public Service Board

-P. O. Box 1771 San Antonio, TX 78296 Revised 01/29/91 L4/NRC/

l

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!CIISSION In the Matter )

)

llouston Lighting 6 Power ) Docket Nos. 50-498 Compar . et al., ) 50 499

)

South Texas Project )

Units 1 and 2 )

AFFIDAVIT W.11. Kinsey being duly sworn, hereby denoses and says that he is Vice President, Nuclear Generation, of flouston Lighting 6 Power Company; that he is duly authorized to sign and file with the Nuc1 car Regulatory Commission the attached proposed changes to the South Texas Projact Electric Generating Station Technical Specification 3.3.3.1, Table 3.3 6, Functional Unit 1.a; is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge and belief, h I we x _ _ _

W. 11. Kin'sey %A Vice President, Nucle (ct@deration STATE OF TEXAS )

)

)

Subscribed and sworn to before me, a Notary Public in and for The Stato of Texas this aard day of Febru.a.rq , 1991.

i am mmsmswww w

/k

( ~ ff).y u,ym$$/07o.,,,

o nw ng n i u m 4 Qh @

Notaly Publile in and for the msmwwas State of Texas A1/000.N20

- . _ - . _ . . . . . -- .- _ . . - _ . - . . - - , ~. - ..

1 ATTACllMEPT 1 SIC! LIFT ANT llAZARDS EVALUATION FOR A-PRGIOSED CilANGE TO TECilNICAL SPECIFICATION 3.3.3.1, TABI.E 3.3-6, FUNCTIONAL UNIT 1,a i

.l 1

A1/009.H2O-1

Attachment 1 ST HL AE 3704 Page l'of 3 SICNIFICANT HAZARDS EVALUATION FOR A PROPOSED CHANGE TO TECHNICAL SPECIFICATION 3.3.3.1 TABLE 3.3 6, FUNCTIONAL UNIT 1.a Baektround The Technical Specifications (T.S.) at STPEGS currently require that the containment atmosphere radioactivity-high monitor be operable in all modes of operation. The action statement-requires that when this condition cannot be met, operation may continue for 30 days provided grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

HL&P proposes that T.S. 3.3.3,1, Table 3.3 6, Functional Unit 1.a be amended ,

so that the subject requirements are not applicabic for the duration of an Integrated Leak Rate Test (ILRT). The subject monitor-is required to be isolated from containment for-the duration of an ILRT because it is not designed to withstand the pressure of an ILRT. HL&P has also-determined there is no practical method to obtain grab samples without compromising the data collection for an ILRT, which is expected to last less than 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br />. The ILRT for Unit 1, conducted during the second week of January,1991, was performed after a one time Waiver of Compliance was granted by the Nuclear Regulatory Commission (NRC) which waived the provisions of T.S. 3.3,3,1, Table 3.3-6, Functional Unit 1.a to allow HL&P to exceed the containment atmosphere grab sample tite requirement with the containment atmosphere radioactivity high monitor inoperable, This Waiver of Compliance was granted in a letter from the NRC to HL&P dated January 8,1991.

Proposed Channe Add a note to Action 31 of-T.S. Table 3.3-6 that roads as follows:

" Grab samples are not required to be -obtained for the duration of containment

_ pressurization for an Integrated Leak Rate Test (ILRT) provided that a grab sample is obtained and analyzed at the start of depressurization of containment following the ILRT."

The proposed change is provided in Attachment 2.

I-lt h Safety Evaluation l

L As indicated in STPECS UFSAR Chapter 11.5, the containment atmosphere -

radioactivity-high monitor's function is to support the reactor coolant pressure boundary leakage detection system. This function of the monitor is

-governed by T.S. 3.3.3.1, Table 3.3-6,-Functional Unit 1,b and T.S. 3.4.6.1, which are applicable in Modes 1, 2, 3, and 4. The proposed change is applicable only for the duration of an ILRT, which will not be performed in Made 1, 2, 3, or 4. .

- A1/009.b '

- . _ . _ . . . ._ _ ._ .. .__._.,.___._.m._.. __ . -. ..m.___._..

Attachment 1 I ST HL AE-3704 l Page 2 of 3 Safety Evaluntion'(cont'd) -

-The subject monitor has no ESFAS or reactor protection system i I

function, nor does it have any control function. In addition, alarm signals

-from the subject monitor are not used as isolation signals for any plant I system.

The -only function for the subject monitor when STPECS is in shutdown conditions (Mode 5 or 6) is as an additional radiological safeguard for perconnel. Alarm signals from the subject monitor are used as indicators of radiologically adverse conditions for station personnel in containment.

There-is no safety significance or potential consequences with the proposed change, as containment is isolated and personnel are not allowed in containment for the duration of _an ILRT. In addition, the proposed change

. requires that a grab sample of tha containment atmosphere be obtained and analyzed at the start of depressu.ization of the containment following an ILRT. These requirements ensure that there is no additional risk of personnel exposure due to_ unavailability af the subject monitor during an ILRT.

Determination of Sirnificant llazards

. Pursuant to 100FR50.91-this analysis provides a determination that the proposed changes to Technical Specifications do not involve any significant hazarca consideration as defined in 10CFR50.92.

~

1. The-proposed change does nor= involve a significant increase in the probabilitylor concequences of a-previously evaluated.

accident. The proposed change would'in effect allow the ,

L ' containment atmosphere radioactivity high monitor to be rendered l

inoperable during_ shutdown _ conditions:'(Mode 5_or 6). The subjec_t L monitor is not_relatodito any_ accident initiation scenarios in l shutdown conditions;: therefore .the_ proposed change does not j increase the probability of a previously evaluated accident. In

l. addition, the subject monitor is not used for mitigation of any accident conditions; therefore, the proposed change'does not increase the consequences of a previously evaluated accident.

2.- The proposed change.does not create the possibility of a new or different kind of accident from any accident previously evcluated. The radiation-monitor has no function. associated with accident initiation.

l l

A1/009,N20

.._7____.

j', ,

,e* .

n Attachment 1 ST HL AE 3704 '

Page 3 of 3 Determination of Sirnifiennt Hazards (cont'd)

3. The proposed change does not involve a significant reduction in a margin of safety, The proposed change allows for rendering the subject monitor temporarily inoperable during liRTs, which will normally be performed only in Mode 5. Since the subject monitor serves no control function or accident mitigation function in liode- 5 or 6, the proposed change does not' affect any margin of safety.

Based on the above evaluation, H14P has determined the proposed change.does not involve any significant hazards consideration.

E r

y A1/009 N20

- . , . - . , - - . .- , - ,