NOC-AE-18003583, License Amendment Request to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using the Consolidated Line Item ...

License Amendment Request to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using the Consolidated Line Item ...

ML18270A319
Person / Time
Site:	South Texas
Issue date:	09/27/2018
From:	Connolly J South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-18003583, STI: 34687751
Download: ML18270A319 (12)

Text

Nuclear Operating Company South Texas Pmlect Electric Generating Station 1>0. Boil 289 Wadamrth, Texas 77483 September 27, 2018 NOC-AE-18003583 10CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 License Amendment Request to Revise Technical Specifications to adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month,"

Usjnfl the Consolidated Line Item Improvement Process Pursuant to 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) hereby requests a license amendment to South Texas Project (STP) Renewed Operating Licenses NPF-76 and NPF-80 to revise Technical Specification Surveillance Requirement 4.7,7.b ("Control Room Makeup and Cleanup Filtration System") to operate for at least 15 continuous minutes at a frequency controlled in accordance with the Surveillance Frequency Control Program by adoption ofTSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month".

The Enclosure to this letter provides a description and assessment of the proposed changes including technical and regulatory evaluations and a No Significant Hazards Consideration Analysis. Markups and retyped (clean) Technical Specification pages are provided in Attachments 1 and 2, respectively. Attachment 3 provides an existing Technical Specification Bases page markup to show the proposed changes for information only.

STPNOC will implement the amendment within 90 days of the NRC approval date.

In accordance with 10 CFR 50.91 (b), STPNOC is notifying the State of Texas of this license amendment request by transmitting a copy of this letter and Enclosure to the designated State Official. The proposed amendment has been reviewed and approved by the STPNOC Plant Operations Review Committee and has undergone an independent organizational unit review.

There are no regulatory commitments in this amendment request.

If there are any questions or if additional information is needed, please contact Nic Boehmisch at (361) 972-8172 or me at (361) 972-7344.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on S^^^A. ^ ^Q/^

James Connolly Executive VP and CN kv/nb

Enclosure:

Evaluation of the Proposed Change STI:34687751

NOC-AE-18003583 Page 2 of 2 cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (O9E01) 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483

Enclosure NOC-AE-18003583 Page 1 of 4 ENCLOSURE Evaluation of the Proposed Change

Subject:

License Amendment Request to Revise Technical Specifications to adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month

1. DESCRIPTION

2. ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Determination

4. ENVIRONMENTAL EVALUATION ATTACHMENTS:

1. Technical Specification Page Markups

2. Retyped Technical Specification Pages

3. Technical Specification Bases Changes (for information only)

Enclosure NOC-AE-18003583 Page 2 of 4

1. DESCRIPTION The proposed change revises the Surveillance Requirement which currently requires operating the ventilation system with the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the Surveillance Frequency Control Program. The Surveillance Requirement would be revised to require operation of the system for 15 continuous minutes at a frequency controlled in accordance with the Surveillance Frequency Control Program.

The proposed amendment is consistent with TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month.

2. ASSESSMENT 2.1 Applicability of Published Safety Evaluation STP Nuclear Operating Company (STPNOC) has reviewed the model safety evaluation published September 20, 2012, as part of the Federal Register Notice for Comment. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-522. STPNOC has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to South Texas Project (STP)

Units 1 and 2 and justify this amendment for the incorporation of the changes to the STP Technical Specifications.

2.2 Optional Changes and Variations The STP Technical Specifications utilize different numbering and titles than the Standard Technical Specifications on which TSTF-522 was based. Specifically, STP Technical Specification 3.7.7 (Control Room Makeup and Cleanup Filtration System) relates to the WOG Standard Technical Specification 3.7.10 (Control Room Emergency Filtration System (CREFS)). In addition, the TSTF frequency of 31 days will be replaced with at a frequency controlled in accordance with the Surveillance Frequency Control Program, as described in STP Technical Specification 3.7.7 currently. These differences are administrative and do not affect the applicability of TSTF-522 to the STP Technical Specifications.

3. REGULATORY ANALYSIS 3.1 No Signification Hazards Consideration Determination South Texas Project (STP) Units 1 and 2 request adoption of an approved change to the standard technical specifications and plant-specific Technical Specifications, to revise Technical Specification 3.7.7 (Control Room Makeup and Cleanup Filtration System) to revise the Surveillance Requirement to operate the Control Room Makeup and Cleanup Filtration System with the heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the Surveillance Frequency Control Program. The Surveillance Requirement is revised to require operation of the system for 15 continuous minutes at a frequency controlled in accordance with the Surveillance Frequency Control Program.

Enclosure NOC-AE-18003583 Page 3 of 4 As required by 10 CFR 50.91(a), an analysis of the issue of no signification hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the Control Room Makeup and Cleanup Filtration System with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the Surveillance Frequency Control Program with a requirement to operate the system for 15 continuous minutes with the heaters operating.

This system is not an accident initiator, and therefore, the changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these system perform their design function which may include mitigating accidents. Thus, the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the Control Room Makeup and Cleanup Filtration System with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the Surveillance Frequency Control Program with a requirement to operate the system for 15 continuous minutes with the heaters operating.

The change proposed for the system does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Enclosure NOC-AE-18003583 Page 4 of 4

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the Control Room Makeup and Cleanup Filtration System with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period at a frequency controlled in accordance with the Surveillance Frequency Control Program with a requirement to operate the system for 15 continuous minutes with the heaters operating.

The design basis for the systems heater is to heat the incoming air which reduces the relative humidity. The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will perform their design function. The proposed change is consistent with regulatory guidance.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety. Based on the above, STP Nuclear Operating Company concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4. ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Enclosure NOC-AE-18003583 Attachment 1 Attachment 1 Technical Specification Page Markups

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.7 Each Control Room Makeup and Cleanup Filtration System shall be demonstrated OPERABLE:

a. At a frequency in accordance with the Surveillance Frequency Control Program by verifying that the control room air temperature is less than or equal to 78°F;

b. At a frequency in accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers of 15 the makeup and cleanup air filter units and verifying that the system operates for at least 10 continuous hours with the makeup filter unit heaters operating;

c. At a frequency in accordance with the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating minutes with the system by:

1) Verifying that the makeup and cleanup systems satisfy the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% for HEPA filter banks and 0.10% for charcoal adsorber banks and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/- 10% for the makeup units;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D3803-1989, Standard Test Method for Nuclear-Grade Activated Carbon, for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30°C and a relative humidity of 70%; and

3) Verifying a system flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/-

10% for the makeup units during system operation when tested in accordance with ANSI N510-1980.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D3803-1989 for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30°C and a relative humidity of 70%.

e. At a frequency in accordance with the Surveillance Frequency Control Program by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.1 inches Water Gauge for the makeup units and 6.0 inches Water Gauge for the cleanup units while operating the system at a flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/- 10% for the makeup units; SOUTH TEXAS - UNITS 1 & 2 3/4 7-17 Unit 1 - Amendment No. 127 188, 195 Unit 2 - Amendment No. 116 175, 183

Enclosure NOC-AE-18003583 Attachment 2 Attachment 2 Retyped Technical Specification Pages

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.7 Each Control Room Makeup and Cleanup Filtration System shall be demonstrated OPERABLE:

a. At a frequency in accordance with the Surveillance Frequency Control Program by verifying that the control room air temperature is less than or equal to 78°F;

b. At a frequency in accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers of the makeup and cleanup air filter units and verifying that the system operates for at least 15 continuous minutes with the makeup filter unit heaters operating;

c. At a frequency in accordance with the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

1) Verifying that the makeup and cleanup systems satisfy the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% for HEPA filter banks and 0.10% for charcoal adsorber banks and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/- 10% for the makeup units;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D3803-1989, Standard Test Method for Nuclear-Grade Activated Carbon, for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30°C and a relative humidity of 70%; and

3) Verifying a system flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/-

10% for the makeup units during system operation when tested in accordance with ANSI N510-1980.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D3803-1989 for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30°C and a relative humidity of 70%.

e. At a frequency in accordance with the Surveillance Frequency Control Program by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.1 inches Water Gauge for the makeup units and 6.0 inches Water Gauge for the cleanup units while operating the system at a flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/- 10% for the makeup units; SOUTH TEXAS - UNITS 1 & 2 3/4 7-17 Unit 1 - Amendment No. 127 188, 195 Unit 2 - Amendment No. 116 175, 183

Enclosure NOC-AE-18003583 Attachment 3 Attachment 3 Technical Specification Bases Changes (for information only)

PLANT SYSTEMS BASES The limitations Operation on minimum with the heaters water on for at level leastand 15 maximum minutes temperature demonstrates are based on providing a OPERABILITY 30-day cooling water supply to safety-related equipment without exceeding its design basis of the system. Periodic operation ensures that heater failure, blockage, fan or temperature and is consistent with the recommendations of Regulatory Guide 1.27, "Ultimate motor failure, Heat Sinkorfor excessive vibration Nuclear Plants," March can be detected for corrective action.

1974.

3/4.7.6 (NOT USED) 3/4.7.7 CONTROL ROOM MAKEUP AND CLEANUP FILTRATION SYSTEM The Control Room Makeup and Filtration System is comprised of three 50-percent redundant systems (trains) that share a common intake plenum and exhaust plenum. Each system/train is comprised of a makeup fan, a makeup filtration unit, a cleanup filtration unit, a cleanup fan, a control room air handling unit, a supply fan, a return fan, and associated ductwork and dampers. Two of the three 50% design capacity trains are required to remain operable during an accident to ensure that the system design function is met. The toilet kitchen exhaust (excluding exhaust dampers), heating, and computer room HVAC Subsystem associated with the Control Room Makeup and Filtration System are non safety-related and not required for operability.

The OPERABILITY of the Control Room Makeup and Cleanup Filtration System ensures that: (1) the ambient air temperature does not exceed the allowable temperature for continuous-duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel during and following most credible accident conditions. Operation of the system with the heaters operating for at least 10 continuous hours in a 92-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem total effective dose equivalent (TEDE). This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A, 10 CFR Part 50.

ANSI N510-1980 will be used as a procedural guide for surveillance testing.

There is no automatic actuation or Surveillance Requirements of the Control Room Makeup and Cleanup Filtration System for toxic gas or smoke because the analysis for the South Texas Project has determined no actuation is required.

The accidents postulated to occur during core alterations, in addition to the fuel handling accident, are: inadvertent criticality (due to a control rod removal error or continuous rod withdrawal error during refueling or boron dilution) and the inadvertent loading of, and subsequent operation with, a fuel assembly in an improper location. These events are not postulated to result in fuel cladding integrity damage. Since the only accident to occur during CORE ALTERATIONS that results in a significant radioactive release is the fuel handling accident and the accident mitigation features of the Control Room Makeup and Cleanup Filtration System are not credited in the accident analysis for a fuel handling accident, there are no OPERABILITY requirements for this system in MODES 5 and 6.

Actions a, b, c, and d The time limits associated with the ACTIONS to restore an inoperable train to OPERABLE status are consistent with the redundancy and capability of the system and the low probability of a design basis accident while the affected train(s) is out of service.

SOUTH TEXAS - UNITS 1 & 2 B 3/4 7-4 Unit 1 - Amendment No. 11-11813-8 Unit 2 - Amendment No. 11-11813-8