ST-HL-AE-4176, Submits Supplemental Info to 901221 Application for Amends to Licenses NPF-76 & NPF-80,changing TS 3/4.4.4 & 3/4.4.9 Re PORV & Block Valve Reliability Per GI 70 (NUREG-1316) & GI 94 (NUREG-1326),identified in Generic Ltr 90-06

Submits Supplemental Info to 901221 Application for Amends to Licenses NPF-76 & NPF-80,changing TS 3/4.4.4 & 3/4.4.9 Re PORV & Block Valve Reliability Per GI 70 (NUREG-1316) & GI 94 (NUREG-1326),identified in Generic Ltr 90-06

ML20099H665
Person / Time
Site:	South Texas
Issue date:	08/10/1992
From:	Rosen S HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17349A920	List: ST-HL-AE-4176, Submits Supplemental Info to 901221 Application for Amends to Licenses NPF-76 & NPF-80,changing TS 3/4.4.4 & 3/4.4.9 Re PORV & Block Valve Reliability Per GI 70 (NUREG-1316) & GI 94 (NUREG-1326),identified in Generic Ltr 90-06
References
REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, RTR-NUREG-1316, RTR-NUREG-1326, TASK-070, TASK-094, TASK-70, TASK-94, TASK-OR GL-90-06, GL-90-6, ST-HL-AE-4176, TAC-M77380, TAC-M77381, NUDOCS 9208190148
Download: ML20099H665 (10)

Text

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'The Light company '"9'2'I*'P llouston 1.ighting & PowerI_ $19""M"'"ajnspation ppfyy n{ yffwagij pyf a 773]

August 10, 1992 ST-HL-AE-4176 File No.t G9.06 G20.01 10CFR50.90 10CFR50.92 10CFR50. 54 (f)

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Supplemental Information Regarding l Proposed Amendment to the Unit 1 and Unit 2 Technigal Specifications 3/*.4.4 and 3/4.4.9

References:

1. Letter dated December 21, 1990 (ST-ilL-AE-3642), Proposed Amendment to the Unit 1 and Unit 2 Technical Specifications '

3/4.4.4 and 3/4  %.s.3

2. Letter dated November 8, 1991, Issuance of Amendment Nos. 31 and 22 to Facility Operating License Nos. NPF-76 and NPF South Texas Project, Units 1 and 2 (TAC Nos. 77380 and 77381)

Pursuant to 10CFR50.90, Houston Lighting & Power Company (HL&P) hereby proposes to amend its Operating Licenses NPF-76 and NPF-80 by incorporating the attached proposed change to the Technical Specifications for the South Texas Projc t Electric Generating Station (STPEGS) Units 1 and 2.

Based on technical studies for GI-70 (NUREG 1316) and GI-94 (NUREG; 1326) , . pursuant to 10CFR50.54 (f) the staff requested

-that actions identifiad in Generic Letter 90-06,-Enclosure (s) A and.D of Section 3, be taken byclicensees in order to increase plant safety and reliabilit". Implementation of the 10CFR50.54(f) request requi is HL&P to modify Technical Specifications 3/4.4.4 and 4.4.9.

920819014R 920810 g' C

PDR ADOCA 05000498 p PDR . g L W2 m - A Subsidiary of Ilouston industries incorporated 1

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lloustonlighting & Power Company ST-llL-AE- 417 6 l South Texas Projut Elutric Genciating Station File No.: G9.06  !

G20.01 Page 2 A proposed amendment to the Unit 1 and Unit 2 Technical Specifications 3/4.4.4 and 3/4.4.9 was submitted on

-December 21, 1991, (ref. 1), and a portion of the proposed amendment was approved per Reference 2. Additional justification for the unapproved portion of the proposed amendment to the Technical Specification was requested per telecon by the-NRC Project Manager for the South Texas Project.

Attached is the proposed change to the STPEGS Technical l Specifications and the additional justification as requested. l Upon approval of the proposed change by the Staff, IIL&P requests j a 10 days implementation period following the date of issuance of  ;

the 31 cense amendment. This will allow adequate time for reproduction and distribution of the change and to bring STP '

procedures into compliance.

IIL&P has reviewed the proposed amendment pursuant to 10CFR50.92 and determined that it does not involve a significant

-hazards considere. tion. The basis for this determination is provided in the attachments. In addition, based on the information contained-in this submittal and in the NRC Final Environmental Statement related to the operation of STPEGS Units 1 and 2, ifL&P has concluded that, pursuant to 10CFR51, there are no significant radiological or non-radiological impacts associated with the proposed action and the proposed license amendment will not have a sfgnificant effect on the quality of the environment.

The STPEGS Nuclear Safety Review Board has reviewed and ,

approved the proposed changes.

In accordance-with 10CFR50.91(b), HL&P is providing the State of Texas with a copy of this proposed amendment. .

-If you should-have any questions concerning this matter, L please contact Mr. A. W. Ilarrison at (512) 972-7298 or myself at L (512) 972-7138.

S. I.-Rosen Vice President, ,

Nuclear Engineering SDP/ag Attachments: 1. Proposed Technical Specification Changes

2. Technical Specification Page Mark-ups.

-3. Significant liazards Evaluation Tsc\92 016.M1

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9 ST-HL-AE-4176 File No.: G9.06 G20.01 Page 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter )

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Houston Lighting & Power ) Docket Nos. 50-498 Company, et al., ) 50-499

)

South Texas Project )

Unit 1 and 2 )

AFFIDAVI" S. L. Rosen being duly sworn, hereby deposes and says that he in Vice President, Nuclear Engineering of Houston Lighting &

Power Company; that.he is duly authorized to sign and file with the Nuclear Regulatory Commission the Proposed Amendment to the Unit 1 and Unit 2 Technical Specificatio'..s 3/4.4.4 and 3/4.4.9; 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.

S . ' L. Rosen Vice President, Nuclear Engineering STATE OF TEXAS )

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a Notary Public in and for The Subscribed State of Texas and = this sworn /d/ddayto before of g me, lug 4 #1992. ,

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NW SAVANNA S. FRANXtlN w ar m k st.* stens- -

-otary Public in and for the Mr hamm twes M6 94 State of Texas l'

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lloustantighting & Power Company 1 South Terai Project E! ctric Generating Station L~

yi 6, G20.01 Page 4 cc: i Regiorsl Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 400 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. Tapia Atlanta, GA 30339-3064 Senior Resident Ir7pector

'c/o U. S. Nuclear-hegulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lano

, P. O. Box 910 Bellport, NY 11713 Bay City, TX -77414 D. K. Lacker J..R. Newman, Esquire Brreau of Radiation Control .

Newman &'Holtzinger, P.C. Texas Department of Health '

L 1615 L Street, N.W. 1100 West 49th Street Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M. Puckett Central Power and Light Company P. O.-Box 2121

' Corpus Christi, TX 78403

.J. C. Lanier/M. B. Lee City-of Austini LEloctric Utility Department P.O Box 1088 Austin, TX- 78767 ,

K. J. Fiedler/M. T.<Hardt i City Public Service Board P. O. Box'1771

San Antonio, TX 78296 '

Revised ' 0/11/91 h 'L4/NRC/

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ATTACIIMENT 1 PROPOSED TECHNICAL BPECIFICATION C1LANGES Igu T&C\92 016.001 .

l l s Attachment 1 ST-IIL-AE-4176 Page 1 of 5 PROPOSED TECHNICAL BPECIFICATION CHANGES The proposed changes made to thn current STPEGS Technical Specifications incorporate the recommendations provided in Generic Letter 90-06. Changes to improve clarity and accuracy of the Technical Specifications are also included. Additional changes are included to implement verification of PORV operability during MODES 5 & 6 as approved by the NRC in Reference 2.

CHANGES IN RESPONSE TO GENERIC LETTER 90-06 DfdCJllPTION OF CllANGES___Id!D_QUSTIFICATION Technical specification 3/4.4.4 LCO 3.4.4:

Change and Justification:

e The word "All" is replaced with "3oth". The Limiting Condition for Operation statement is clarified by replacing "All" with "Both" since the STPEGS COMS system consists of two PORVs. This change is considered editorial only.

Action (a.):

Changes and Justification:

• The word "more" is changed to "both". The action statement is clarified by changing "more" to "both" since only two PORVs are provided in the design. This change is considered editorial only, e The statement "with power maintained to the block valve (s)" is added. The requirement to maintain power to closed block valve (s) is included because removal of power would render the block valve (s) inoperable an. he e requirements of Action statement (b. or c.) would app y.

• The requirement to reach " 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 />" is changed to " HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />". This phrase hha been changed because the APPLICABILITY requirements of the LCO do not extend beyond the HOT STANDBY mode.

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Attachment 1 ST-HL-AE-4176 Page 2 of 5 Action (b.):

Change and Justification:

• The requirement to reach " COLD SHUTDOWN within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />" is changed to " HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />" because the APPLICABILITY requirements of the LCO do not extend beyond the HOT STANDBY mode.

Action (c.):

Changes and Justification:

• The reference to "PORV(s)" and " valve (s)" is changed to "PORVs" and " valves" since this action only applies when both PORVs are inoperable. This improves clarity and is considered editorial only, e The requirement to reach " COLD SHUTDOWN within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />" is changed to " HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />" because the APPLICABILITY requirements of the LCO do not extend beyond the HOT STANDBY mode.

e The statement "within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore each of the PORVs" is changed to "within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore one of the PORVs". The recommended Technical Specification changes provided in Attachment A-1 to the Generic Letter state that "within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restore at least one PORV".

The intent of this action is to provide for the removal of power from a closed block valve as additional assurance to preclude any inadvertent block valve opening at a time when the PORV may not be closed due to maintenance to restore it to operable condition. Since the entry condition for this action statement is both PORVs inoperable, it follows that one should be restored within i hour or its associated block valve closed.

Action (d.):

Change and Justification:

e This action applies to the case when one block valve is inoperable and is the result of splitting the previous Technical Specification action (d.) into two action statements for clarity. This change is made to provide an action statement applicable to one block valve inoperable and an action statement applicable to two block valves inoperable. The PORVs are to be placed in

" closed position" rather than " manual control" as recommended by Generic Letter 90-06. Placing the valves in " closed position" rather than " manual control" is appropriate since this action is required to prevent the automatic opening of the PORVs which is the intent of the step in the Technical Specification change recommended in Generic Letter 90-06, 1st\92-016.001

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Attachment 1 ST-HL-AE-4176 Page 3 of 5 Action (e.):

Change and Justification:

e This action applies to the case when both block valves are inoperable and is the result of splitting the previous Technical Specification action (d.) into two separate action statements for clarity. This change is made to provide an action statement applicable to one block valve inoperable and an action statement applicable to two block valves inoperable.

Action (f.):

Change and Justification:

e Action (f.) comes from the previous Technical Specification action (e.). This is a result of splitting the Previous Technical Specification action (d.) into two actions and re-numbering the actions.

This change is editorial only.

Surveillance Requirement 4.4.4.1.a:

Change and Justification:

e The statement "on the PORV actuation channel" is added to enhance clarity. There is no ch6nge to the existing requirements. This change provides consistency with Surveillance Requirement 4.4.9.3.1.b.

Surveillance Requirement 4.4.4.1.b:

Change and Justification:

e The statement "during MODES 3, 4, or 5" is incorporated. This is so testing can be performed prior to establishing conditions where the PORVs are used for low temperature overpressure protection but not during power operations. The addition of MODE 5 to this surveillance requirement provides additional operational flexibility in the performance of the required test.

Surveillance Requirement 4.4.4.2:

Change and Justification:

• The statement "with power removed" is deleted. This statement is r.ot required since it is incorporated into the requirements of ACTION b. and c. of specification 3.4.4.

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s 4 Attachment 1 ST-HL-AE-4176 Page 4 of 5

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7- Generic Letter Surveillance 'Aequb ament 4.4.4.3:

f* Respon",e and Justification:

• Surveillance-Requirement e.4.4.3, provided in the Gencric Letter, is not incorporated, i<is Surveillance Requirement is providtd in the Generic atter to require y testing of emergency (backup) power supplies for plants s sj with non-safety graue power. This surveillance j'gy ' '

requirament is not included in the STPEGS 'Aechnical Specifications since the STPEGS PORVs are pryered from class 1E buees.

4 Generic Lotter Surveillance Requirement 4.4.4.1.b:

4 Respor.se and Justification

y e Surveillance . t.4.4.1.b as provided in the Technical f ~

changes recommended by Goneric Letter 90-l -

Oorporated. This Surveillance Requirement _ f 21es to plants with air-operated PORVs.

hie is not applicable to STPEGS since solenoid operated PORV are installed. t Technical Ppo ife*2 tion 3/4.4.9 rimiting cendition for Operation 3.4.9.3: q Change and Justi*1 cation:

e Requested changes to this Technical Specification are i described in Reference 1. These changes were approved _

as an amendment per Reference 2.

Surveillance Requirement 4.4.9.1.2:

Change and Justification:

e Technical Specification Figure 3.4-4, " Nominal Maximum Allowable PORV Setpoint for the Cold Overpresu"a System," is added to the listing of figures to be updated based on the results of the Reactor Preseure Vessel (RPY, irradiation surveillance progrer. The change is made to emphasize the need to update the figure and the allowable PORV setpoint based on results of the RPV irradiation surveillance program.

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4 Attachment 1 ST-HL-AE-4176 Page 5 of 5 Basis 3/4.4.'4 RELIEF VALVES Change and Justification:

• Basis 3/4.4.4 is revised to clarify the functions for which operability of the FORV and blog.c valve are determined. Operability of the PORV is r.ot based on the automatic control function. Inoperdbility of the PORVs automatic function during normal operation does not result in inoperability of the PORVs manual operation. This clarification is consistent with the STP design.

Bases 3/4.4.9 Lqw Temperature Overoressure Protection change and Justification:

• The Low lamperature overpressur.3 Protection Bases is revised to add details concerning the use of RHR relief valvec_to provide COMS during'the stroke testing of inoperable PORV(s). This change is consistent wi',h Technical Specification 3.4.9.3 as approved in Unit 1 Amendment 31 and Unit 2 Amendment 22.

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