ST-HL-AE-4178, Application for Amends to Licenses NPF-76 & NPF-80,changing Wording in TS 3.6.3 Action Statement to Require That at Least One Isolation Barrier Instead of One Isolation Valve Be Maintained Operable

Application for Amends to Licenses NPF-76 & NPF-80,changing Wording in TS 3.6.3 Action Statement to Require That at Least One Isolation Barrier Instead of One Isolation Valve Be Maintained Operable

ML20114A878
Person / Time
Site:	South Texas
Issue date:	08/18/1992
From:	Rosen S HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20114A879	List: ML20114A880 ST-HL-AE-4178, Application for Amends to Licenses NPF-76 & NPF-80,changing Wording in TS 3.6.3 Action Statement to Require That at Least One Isolation Barrier Instead of One Isolation Valve Be Maintained Operable
References
ST-HL-AE-4178, NUDOCS 9208240051
Download: ML20114A878 (9)

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f7f 83 August 18, 1992 ST-HL-AE-4178 File lios.: G20.02.01 G21.02.01 10CFR50.90 10CFR50.91 10CFR50.92 10CFR51 U. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Units 1 &2 Docket Nos. STN 50-498, STN 50-499 Proposed Amendment to the linit. y and Unit 2 Technical Sp3cification 3.6.3 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 Technical Specification 3.6.3 (Containment Isolation Valves) for South Texas Project (STP) Units 1 and 2. The proposed change would change the wording in the Action Statement to require at least one isolation

" barrier" to be maintained OPERABLE, as opposed to at least one isolation " valve". A footnote would also be added to clarify that an isolation barrier may either be an isolation valve or a closed system as defined b/ General Design Criteria (GDC) 57 of Appendix A to 10 CFR Part 50.

HL&P has reviewed the attached proposed amendment pursuant to 10CFR50.92 and determined that it'does not involve a significant hazards consideration. Additionally, pursuant to 10CFR51 and based on information contained in this submittal and in the final Environmental Statement Related to the_.___Qperation of South Texas Project. Units 1 and 2, HL&P has concluded that the proposed amendment . poses no significant radiological or non-radiological impacts, and will not have a significant effect on environmental quality. The STP 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.

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- - August 18, 1992 ST-HL-AE-4178 )

File Nos.: G20.02.01 G21.02.01 i Page 2 I

If you should have any questions concerning this matter, please  ;

contact Mr. W. J. Jump at (512) 972-7205. ,

S. L.-Rosen Vice President, Nuclear Engineering AMR/ag Attachments: 1. No Significant Hazards Consideration Determination

2. Proposed Change To Technical Specification 3.6.3 s

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llouston tighting & Power Company South Texas Project Electric Generating Station S[11L-E-41, Pago 3 G21.02.01 cc Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associato General Counsol 611 Ryan Plaza Drive, Suito 400 Houston Lighting & Power company Arlington, TX 76011 P. O. Box 61867 -

Houston, TX 77208 ,

George Dick, Project Manager U.S. Nuclear-Rogulatory Commission INPO Washington, DC 20555 Records Contor 1100 Circle 75 Parkway J.'I. Tapia Atlanta, GA 30339-3064 Senior Resident Inspector c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bollport Lane P. O. Box 910 Bollport, NY 11713 Bay City, TX 77414 D. K. Lackor J. R. Newman, Esquire Bureau of Radiation Control Newman-& lioltzinger, P.C. Texas Department of Health 1615 L Strcot, N.W. 1100 West 49th Stroot Washington, DC 20036 Austin, TX 78756-3189 /

D. E. Ward /T. M. Puckett Central Power and Light Company 1P. O. Box.2121' Corpus Chriuti, TX 78403 s

J. C. Lanior/M. B. Leo City of Austin.

' Electric Utility Department P.O. Box 1088.

Austin, TX 78767

- K. - J.- Fiedler/M. T. Hardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296 Revised 10/11/91 L4/NRC/

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Ul11TED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter )

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llouston Light ng & Power ) Docket Nos. 50-498 Company, et al., ) 50-499

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South Texas Project )

Units 1 and 2 )

AFFIDAVIT S. L. Rosen being duly sworn, hereby deposes and says that

- he is Vice President, Nuclear Engineering, of flouston Lighting &

Power Company; that he is duly authorized to sign and file with the Nuclear Regulatory Corls, ' * >n the attached proposed revision to the South Texas Project E)Schri <*? eating Station Technical +

Specification 3.6.3; i) twis. w> the content thereof; and that the matters set forth \; g er,r ,,g !<co and correct to the best of his knowledge and bellet.

S. L. Rosen Vice President, Nuclear Engineering Subscribed and sworn to efore me, a Notary Public in and for The State of Texas this /f day of dc ,qs,7 , 1992.

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k Attachment 1 ST-HL-AE-4178 l Page 1 of 4 <

l HO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Dackground Technical Specification (Tech Spec) 3.6.3, Containment

-Isolation Valves, applies to all containment isolation valves at STP, except for the Main Steam Isolation Valves (MSIVs) and Feedwater Isolation Valves (FWIVs) which have separate Specifications. As outlined in the BASES for Specification 3.6.3:

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 i

Criteria 54 through 57 of Appendix A to 10 CFR Part 50.

Containment penetrations are required to have two barriers so that no single failure can prevent isolation. General Design Critoria (GDC) 57 of Appendix A to 10 CFR Part 50 requires Criterlon 57 - Closed system isolation valves. Each line ... shall have at least one containment isolation valve which shall be either automatic, or locked closed,.or capable of remote manual operation.

For GDC 57 penetrations, the closed system represents one of the two isolation barriers; the isolation valve required by GDC 57 is the second barrier.

The Action Statement for Tech Spec 3.6.3. states that "(w]ith one or_ more -isolation valve (s) inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open ..." Based on this wording, if a GDC 57 containment penetration isol tion ~ valve is declared' inoperable, there may not I

be another isolation valve available to be maintained OPERABLE.

On April 28, 1992, a plant shutdown was commenced. in STP- Unit 2 due to entry into Tech Spec -3.0.3 when the Action Statement of Tech Spec 3.6.3-could not be met. (

Reference:

LER 92-004 (South Texas Project, Unit 2)-) . In this event, two containment isolation valves -

L (SB-FV-4187 and SB-FV-4187A) on a Steam Generator sample line were

-'not able1to-be closed._- -(Norma 1 lineup with no-sample flow 11s SB-FV-4187 closed and SB-FV-4187A open.) Attempts to close either valve ~ were . unsuccessful,_ and being unable to meet the specific wording of the Tech Spec.3,6.3 Action Statement, the Unit entered

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Tech Spec 3.0.3 and an Unusual Event was declared. However, if the Action Statement had contained the proposed wording, entry into Tech Spec 3.0.3 would have_been avoided.

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Attachment 1 ST-HL-AE-4178 Page 2 of 4 ProDosed Chanciq HL&P proposes to amend Tech Spec 3.6.3 to take credit for closed systems as isolation barriers for GDC 57 containment penetrations.- The Action Statement would address isolation

" barriers" as opposed to isolation " valves," and a footnote would be added to clarify what constitutes an isolation barrier. No changes to the BASES would be required due to the proposed change.

Safety Evaluation ,

GDC 57 applies to "[ejach line that penetrates primary reactor containment and is neither part of the reactor coolant pressure boundary nor connected directly -to the containment atmosphere."

This wording defines a closed system for the purposes of containment isolation. Only one isolation valve is required in GDC 57 penetrations because the closed system accounts for the second barrier required so that a single failure does not prevent isolation. 1 Changing the wording of the Action Statement to require at least one isolation barrier to be maintained OPERABLE would not affect situations concerning GDC 54 through 56 penetrations; GDC 54 concerns leak detection and testing of lines which penetrate containment, and GDC 55 and 56 apply to containment penetrations which contain at least two isolation valves. Therefore, for GDC 55 and 56 penetrations with one isolation valve inoperable, there would still be another valve which can be maintained OPERABLE.

Applying the revised wording to GDC 57 penetrations would allow credit to be taken for maintaining the closed system OPERABLE while the inoperable. valve.is either restored to' OPERABLE status or the penetration is isolated within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.- If.these actions are not met, then shutdown of the unit would be required. There would be no . af f ect on the method of operation of the isolation valves because - of the proposed change, and the accident mitigation requirements of the valves would also remain unchanged. The

' Limiting Condition- for Operation (LCO) and Surveillance Requirements are also unaffected by the proposed change.

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Attachment i ST-llL-AE-4178 Page 3 of 4 j No Sinnificant 11azards Co.nsideratjon DeterminatLED i

Pursuant to 10CFR50.91 this analysis provides a determination that the proposed cP nge to Technical Specification 3.6.3 does not involve a significant hazards consideration as defined in l 10CFR50.92:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The accident mitigation requirements of the containment isolation valves are not affected by_the proposed chango. The proposed _ change clarifies the applicability o ." GDC 57 penetrations and their associated isolation valvos to Tech Spec 3.6.3, as intended by referencing the BASES. Thereforo, the >

proposed change does not involve a significant increase in the probability __ :or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a now or different kind of accident from any previously evaluated.

-There would be no new modos of operation introduced by the proposed chango. Also, the containment isolation valves would not .be operated in any new or different way from what is currently allowed. Thereforo, the propose + change-does not create the possibility of a new or different kind of accident.

3. The proposed change does not involve a significant reduction in a margin of safety.

The proposed change does not change a safety limit, a Limiting Condition For Operation, or a Surveillanco Requirement. There would also be no affect on the method of operation of the containment isolation valves. Therefore, the propocod change does not involve a significant reduction in any -margins of safety.

Dased on the reasoning stated above and the previous discussion of the amendment request, !!L&P has determined that the requested change does not involve a significant hazards consideration.

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3 Attachmont 1 ST-IIL-AE-4178 Page 4 of 4 Imp)ernentation PlaD Implementation of the proposed amendacnt, should it be approved, would not require any new surveillances to be performed nor would it affect any surveillanco schedules. IIL&P requests a 10 day implementation period following issuance of the approved amendment to facilitate reproduction and distribution of the revised document pages to controlled copy holders of the Technical Specifications.

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