ML20012B681

Application for Amends to Licenses NPF-76 & NPF-80,changing Tech Spec 3.3.3.6 Re Pressurizer Level,Eliminating Requirement to Shutdown If One of Four Pressurizer Level post-accident Monitoring Channels Inoperable

ML20012B681
Person / Time
Site:	South Texas
Issue date:	03/07/1990
From:	Vaughn G HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20012B682	List: ML20012B681 ML20012B686
References
ST-HL-AE-3394, NUDOCS 9003160101
Download: ML20012B681 (7)

Text

[4

.x m o . . ,

The Light e

companySwt Houston Lighting & Power sas Prohet &ctric Generating Station P. O. Box 289 Wadsworth. Tesas 77483 March 7s 1990 .i

$T HL AE-3394  !

File No.: G9.06, G20.01  ;

10CFR50.90

• 10CFd50.92 l 10CFR51 f

U. S.. Nuclear Regulatory Commission  ;

Attention: Document Control Desk ,

Washington, DC 20555  ;

South Texas Project Elisctric Generating Station .y Units 1 & 2 t Docket Nos. STN 50 498, STN 50 499 l Proposed Amendment to the Unit 1 and Unit 2 i Technical Specification 3.3.3.6 for Pressurizer Level

' Pursuant to 10CFR50.90, llouston Lighting & Power Company (llL&P) hereby proposes to amend its Operating Licenses NPF 76 and NPF-80 by incorporating the attached proposed change to the Technical Specificatinns for the South Texas Project Electric Generating Station (STPEGS) Units 1 and 2. {

The proprud change consists of eliminating the requirement to shutdown

.if one of four pressurizer level post accident monitoring channels is .

inoperable. The proposed change will maintain a conservative design and reduce the potential for unnecessary unplanned shutdowns, thereby increasing -

plant safety and reliability.  ;

llL&P has reviewed the attached proposed' amendment pursuant to 10CFR50.92 ,

and determined that it does not involve a significant hazards consideration. ,

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,'HL&P has concluded that, pursuant to 10CFR$1, there.are no significant radiological .

-or non radiological impacts associated with the proposed action and the proposed license amendment will not have a significant effect on the quality l of the environment. -

STPEGS Unit 2 has been operating under the conditions of Specification 3.3.3.6 ACTION 38a since January 16, 1990; therefore expeditious processing of ,

this proposed change is requested in order to prevent a potential unscheduled .

shutdown initiation on April 16,.1990.  !

The STPECS Nuclear Safety Review Board has reviewed and approved the proposed changes.

I LIC\ak A Subsidiary of flouston Industries incorporated ,

=9000160101 900307 S i

.PDR ADOCK 05000498 l I ('I ..

'P PDC '

Houston Lighting & Power Company 'l South Temas Project Dectric Generating Station '

ST-HL AE 3394 File No.: C9.06, G20.01 l Page 2  !

1 In accordance with 10CPR50.91(b), HL&P is providing the State of Texas l with'a copy of this. proposed amendment.  !

If you should have any questions concerning this matter, please contact.  :

Mr. A. W. Harrison at (512) 972 7298 or myself at (512) 972 7921. i 9

G. E. Vaughn Vice President 1 Nuclear Operations AWil/hg

Attachment:

1. Significant Hazards Evaluation for  ;

Eliminating from Technical Specification i 3.3.3.6 the Shutdown Requirement for Loss t of One of Tour Channels of Pressurizer Level instrumentation

2. Proposed Technical Specification Change 3.3.3.6 Table 3.3 10. .

l t

t 1

0 b

L4\LIC\ak L

. C

. .y , _ _ _ - .

e

.4 9 .g ,

i ,5 i ST.HL.AE.3394 i Houston Lighting & Power Company- File No.: 09.06,C20.01

. South Tesas Project Electric Generating Station  !

Page 3 '

.cc:

l Regional Administrator, Region IV Rufus S. Scott I Nuclear Regulatory Commicsion Associate Ceneral Counsel l 611 Ryan Plazu Drive, suite 1000 Houston Lighting & Power Company Arlington, TX -76011 P. O. Box 61867 i Houston, TX 77208 l Ceorge' Dick, Project Manager j U.S. Nuclear-Regulatory Commission- INPO j

t. - Washington, DC. 20555 Records Center 1100 Circle 75 Parkway J. I. Tapia ..

Atlanta, CA 30339-3064 i Senior Resident Inspector '

c/o-U..S. Nuclear Regulatory Dr. Joseph M. Hendrie i Commission' 50 Be11 port Lane i LP. 0, Box 910 Be11 port, NY 11713 l Bay City, TX 77414 ll D. K. Lacker ~t

. J. R. Newman, Esquire Bureau of Radiation Control Newman & Holtzinger, P.C. Texas Department of Health .i' 1615'L Street, N.W. 1100 West 49th Street Washington, DC 20036 Austin, TX 78704  ;

D.'E. Ward /R P. Verret Central-Power & Light Company  :

P. 0. Box 2121 '

Corpus Christi, TX 78403 J. C, Lanier ,

LDirector of Ceneration l City of Austin Electric Utility  :

721.Barton Springs Road' .

Austin, TX 78704 R.LJ Costello/M..T. Hardt City Public Service Board i P.' O. Box 1771- .

San Antonio, TX 78296 Revised 12/15/89

[( 14/NRC/

U s

g..

s.~., .. .

I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

In the Matter 6 I

llouston Lighting & Power i Docket Nos. 50 498 Company, et al., 6 50 499 l I  !

South Texas Project i  !

Units 1 and 2 6  !

t AFFIDAVIT i

G. E. Vaughn, being duly sworn, hereby deposes and says that he is Vice- t President, Nuclear Operations, of Houston Lighting & Power Company; that he is i duly authorized to sign and file with the Nuclear Regulatory Commission the attached proposed change to the South Texas Project Electric Generating i Station Technical Specification 3.3.3.6 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. ,

(e G. E. Vaughn /

Vice President, Nuclear Operations ,

i Subscribed and sworn to before me, a Notary Public in and for the State of Texas this '7 b ay d of $ W u , 1990.  ;

SHARON DONAHY 1h A Notary Pubhc T1MAv t 8"MA2,ft,,4-j . STATE OF TEXAS '

l Notary Public in and for the [/

My Comm. Exp. Apt. 6,1991 j State of Texas L4\LIC\ak2

L, '

!- .- 4 ATTACHMENT 1 l ST HL-AE 3394  !

PAGE __.1_0F -- 3  !

Attachment 1 l i

Significant Hazards Evaluation for Eliminating from the l Technical Specification 3.3.3.6 the Shutdown Requirement for j Loss of One of Tour Channels of Pressurizer Level Instrumentation j i

I

Background

The Post-Accident Monitoring (PAMS) instrumentation involved in the proposed change is pressurizer water level. These are Regulatory Guide 1.97 Rev. 2 category 1 instruments, as shown in STPEGS UFSAR Table 7.5 1. For this parameter there are four ,

safety grade channels that input into the Qualified Display Processing System (QDPS). The QDPS post accident monitoring function for the subject parameter will remain operable as long as I there is at least one valid input. This provides STPEGS a degree of redundancy and conservatism when compared to the requirements of Westinghouse Standard Technical Specifications.

P Requiring plant shutdown in the ACTION statement with the loss of only one channel is overly restrictive to plant operation and I unnecessarily creates the potential for unplanned plant shutdowns.

HL&P believes that eliminating this requirement will result in more reliable and safer operations. l Proposed Change HL&P proposes to revise Table 3.3 10 of Technical Specification 3.3.3.6 to eliminate the shutdown requirement of ACTION 38 for 1

loss of one of four channels of pressurizer level instrumentation.

Safety Evaluation ,

i The STPEGS Technical Specifications presently require the plant to ,

be shutdown if one channel is inoperable and cannot be restored in  ;

90 days. If the cause of inoperability is associated with the channel's tubing and valves, restoring operability at power may not be practical or possible because the high temperatures and pressures involved can be a threat to repair personnsl. HL&P believes that imposing a plant shutdown because of the unavailability of one of four channels of post accident monitoring i instrumentation is unjustified in view of the degree of redundancy and the undesirability of performing an unplanned shutdown with its attendant cycles on plant equipment. The Standard Technical Specifications for Westinghouse Pressurized Water Reactors, NUREG-0452, Revision 5 require a total of two channels for the Pressurizer Water Level PAMS. The minimum channels operable requirement is one and with one channel operable the allowed .

outage time (A0T) is 7 days, With both channels inoperable, the A0T is 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

L4\LIC\ak

ATTACHMENT 1 ST HL AE nW

[ PAGE IL_._0F 3

[ . .

The proposed Technical Specification change provides a 31 day A0T with only two channels operable which is conservative when compared to the Standard Technical Specifications and reflects the design of STPECS. The proposed 7 day A0T for only one channel operable and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for no channels operable follows the Standard Technical Specifications. Note that there are no changes to the existing STPEGS ACTIONS for more than one channel inoperable. Additionally, the proposed change vill not require a plant shutdown with one channel inoperable which will have a positive effect on plant reliability and reduces potential challenges to safety systems.

The proposed change to allow a new action statement (ACTION 43) involves no physical changes to the station. The plant design and instrumentation configuration and quality classification are unchanged. The proposed change does not in any way affect the requirements of Technical Specification 3.3.1 governing the Reactor Trip function associated with this instrumentation.

Based on the evaluation above, HilP concludes that the change in no way degrades the reliability or design of the post accident monitoring instrumentation and further reduces the potential for unplanned plant shutdowns and is consequently an overall improvement in station safety and reliability.

Determination of Significant Hazards Pursuant to 10CFR50.91, this analysis provides a determination that the proposed change to the Technical Specifications does not involve any significant haza.ds consideration as defined in 10CFR50.92.

1) The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. Eliminating the shutdown requirement in the ACTION statement for loss of one of four channels of post accident monitoring instrumentation has no bearing on the probability of an accident because monitoring instrumentation does not contribute to accident probability. The accident mitigation function of the subject instrumentation is addressed by other Technical Specifications, which are unaffected by this proposed change. Additionally, three channels of Pressurizer Level can monitor the pressurizer level in a post accident mode and provides one more channel than required in the Standard Technical Specifications. Consequently, the consequences of an accident are not affected by the proposed change.

lA\LIC\ak

. 4 ,

ATTACHMENT 4.  !

ST HL PAGE ___3AE-33W 0: r  ;

.n.  !

2). The proposed change does not create the possibility of a new or different kind of accident from that {

previously evaluated. The proposed change involves no  ;

changes to the station or its design bases nor does it i impose any new accident scenarios. ,

3) The proposed change does not involve a significant reduction in a margin of safety. There is no change  !

,s to the margin.of safety since there is no change to f the station or-its design bases, i

. Conclusion-l Based on the above, HL&P concludes that the proposed change satisfies the significant hazards considerations standards of t 10CFR50.92(c) and a no significant hazards consideration finding i is - justified.  ;

i i

5 h

h i

i x

7

(

k

.t 1

5 L4\LIC\ak P

a . - , - - - - -

- - - . ,