CP-200700169, Supplement to License Amendment Request (LAR) 06-012, Response to Request for Additional Information Related to Administrative Controls

Supplement to License Amendment Request (LAR)06-012, Response to Request for Additional Information Related to Administrative Controls

ML073410294
Person / Time
Site:	Comanche Peak
Issue date:	11/30/2007
From:	Blevins M Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-200700169, LAR 06-012, TAC MD4070, TAC MD4071, TXX-07174
Download: ML073410294 (3)

Text

Mike Blevins Luminant Power Executive Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Mike. Blevins@Lurninant.com Glen Rose, TX 76043 Luml-T-]ý7,-2mV. T 254 897 5209 C 817 559 9085 F 254 897 6652 CP-200700169 Ref. # 10CFR50.90 Log # TXX-07174 November 30, 2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NOS. 50-445 AND 50-446, SUPPLEMENT TO LICENSE AMENDMENT REQUEST (LAR)06-012, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO ADMINISTRATIVE CONTROLS (TAC NOS. MD4070 AND MD4071)

REFERENCE:

1. Letter logged TXX-06189 dated December 19,2006, License Amendment Request (LAR)06-012, revision to Technical Specification (TS) 3.7.5, "Auxiliary Feedwater (AFW) System," TS 3.8.1, "Ac Sources - Operating," TS 3.8.9, "Distribution Systems - Operating," And TS Example 1.3-3" from Mike Blevins to the NRC.

Dear Sir or Madam:

Per Reference 1, Luminant Generation Company LLC (Luminant Power) submitted proposed changes to the Comanche Peak Steam Electric Station, herein referred to as Comanche Peak Nuclear Power Plant (CPNPP), Unit 1 and 2 Technical Specifications to allow the deletion of second completion times.

Included in Reference 1 was a discussion of administrative controls. As a result of subsequent discussions on November 28, 2007, between the NRC Staff (Fred Lyon, et.al.) and Luminant Power (Tim Hope, et.al.), Luminant Power is providing additional information related to administrative controls.

Page 2 of Enclosure 1 to, Reference 1 proposed to revise TS Example 1.3-3 by eliminating the second Completion Times and replacing the discussion regarding second Completion Times with the following:

"It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended."

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway . Comanche Peak - Diablo Canyon . Palo Verde - South Texas Project . Wolf Creek Aýod

U. S. Nuctear Regutatory Commission TXX-07174 Page 2 11/30/2007 The administrative controls described in the above insert will be captured by the following new licensing basis commitment regarding Comanche Peak Units 1 and 2.

Number Commitment Due Date/Event 27488 There shall be administrative controls to limit the Commitment maximum time allowed for any combination of Conditions 27488 will be that result in a single contiguous occurrence of failing to implemented in meet the LCO for TS 3.7.5*Auxiliary Feedwater (AFW) conjunction with System, TS 3.8.1, A.C. Sources - Operating, and TS 3.8.9, the license Distribution Systems - Operating. These administrative amendment.

controls shall ensure that the Completion Times for those Conditions are not inappropriately extended. The administrative controls will ensure that Completion Time is NOT extended beyond the additive Completion Times of the two (2) Required Actions for restoration of OPERABILITY unless a risk evaluation is performed. If Unit Operation within an LCO will exceed the maximum Completion Time, then either the shutdown Condition within the LCO should be entered OR a risk evaluation shall be performed and the risk impact managed under the Configuration Risk Management Program (CRMP).

The site procedure for the LCO tracking program will be revised to incorporate Commitment 27488 and will be effective upon implementation of the license amendment.

The commitment number is used by Luminant Power for the internal tracking of Comanche Peak commitments.

The No Significant Hazards Considerations provided in Reference I remains valid and is not changed by this supplement to LAR 06-012.

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

Should you have any questions, please contact Mr. Carl Corbin at (254) 897-0121 or carl.corbin@luminant.com.

U. S. Nuclear Regulatory Commission TXX-07174 Page 3 11/30/2007 I state under penalty of perjury that the foregoing is true and correct.

Executed on November 30, 2007.

Sincerely, Luminant Generation Company LLC Mike Blevins By: _ _ _ _ _ _ _ _ _

(reYTW. Madden Director, Oversight & Regulatory Affairs c- E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Ms. Alice Rogers Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78756-3189