CP-200900980, (CPSES) - Supplement to License Amendment Request (LAR) 09-006 to Provide Updated Information

(CPSES) - Supplement to License Amendment Request (LAR)09-006 to Provide Updated Information

ML091910103
Person / Time
Site:	Comanche Peak
Issue date:	07/09/2009
From:	Flores R Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-200900980, LAR 09-006, TAC ME1002, TAC ME1003, TXX-09089
Download: ML091910103 (8)

Text

Rafael Flores Luminant Power Senior Vice President P.O. Box 1002

& Chief Nuclear Officer 6322 North FM 56 rafael.flores@luminant.com Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-200900980 Ref: 10 CFR 50.90 TXX-09089 July 9, 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) DOCKET NOS. 50-445 AND 50-446, SUPPLEMENT TO LICENSE AMENDMENT REQUEST (LAR)09-006 TO PROVIDE UPDATED INFORMATION (TAC NOS. ME1002, ME1003)

Reference 1. Letter logged TXX-09046 dated April 1, 2009, License Amendment Request (LAR)09-006, for adoption of TSTF-511, rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to support compliance with 10 CFR Part 26, from Rafael Flores to the NRC.

Dear Sir or Madam:

In 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to as Comanche Peak Nuclear Power Plant (CPNPP), Unit 1 and 2 Technical Specifications to delete portions of TS superseded by 10 CFR Part 26, Subpart I. As a result of subsequent discussions on July 8, 2009, between the NRC Staff (Alan Wang) and Luminant Power (Carl Corbin), Luminant Power is providing updated marked-up Technical Specification pages (Attachment 1) and retyped Technical Specification pages (Attachment 2). Attachments 1 and 2 of this letter replace Attachments 2 and 3 of Reference 1. These changes are editorial. The No Significant Hazards Considerations provided in Reference 1 remains valid and is not changed by this supplement to LAR 09-006. This supplement to LAR 09-006 applies to both Units.

A reference in Technical Specification section 5.2.2.b is updated to reflect the re-numbering of section 5.2.2.f to section 5.2.2.e.

In accordance with 10 CFR 50.91(b), Luminant Power is providing the State of Texas with a copy of this proposed amendment.

This communication contains no new licensing basis commitments regarding Comanche Peak Units 1 and 2.

If you should have any questions regarding this submittal, please contact Mr. Carl Corbin at (254) 897-0121.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

U. S. Nuclear Regulatory Commission TXX*09089 Page 2 07/09/2009 I state under penalty of perjury that the foregoing is true and correct.

Executed on July 9, 2009.

Sincerely,

P;

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Rafael Flores CBC Attachments: 1. Proposed Technical Specification Change (Mark-Up)

2. Proposed Technical Specification Change (Re-Typed) c - E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, CPNPP Alice Hamilton Rogers, P.E.

Inspection Unit Manager Texas Department of State Health Services Mail Code 1986 PO Box 149347 Austin, Texas 78714-9347

ATTACHMENT 1 to TXX-09089 PROPOSED TECHNICAL SPECIFICATION CHANGE (MARK-UP)

Pages 5.0-3 5.0-4

Organization 5.2 5.2 Organization (continued) 5.2.2 Unit Staff The unit staff organization shall include the following:

a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned if either unit is operating in MODES 1, 2, 3, or 4.

With both units shutdown or defueled, a total of three non-licensed operators for the two units is required. e

b. Shift crew composition may be one less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c. -------------------------------------------NOTE---------------------------------------------

A single Radiation Protection Technician and a single Chemistry Technician may fulfill the requirements for both units.

A Radiation Protection Technician and Chemistry Technician shall be on site when fuel is in the reactor. The positions may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required positions.

d. Administrative procedures shall be developed and implemented to limit the working hours of personnel who perform safety related functions (e.g., licensed Senior Reactor Operators (SROs), licensed Reactor Operators (ROs), Radiation Protection Technicians, auxiliary operators, and key maintenance personnel).

The controls shall include guidelines on working hours that ensure adequate shift coverage shall be maintained without routine heavy use of overtime. Any deviation from the above guidelines shall be authorized in (continued)

COMANCHE PEAK - UNITS 1 AND 2 5.0-3 Amendment No. 64

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued) advance by the Plant Manager or the Plant Manager's designee, in accordance with approved administrative procedures, and with documentation of the basis for granting the deviation. Routine deviation from the working hour guidelines shall not be authorized. Controls shall be included in the procedures to require a periodic independent review be conducted to ensure that excessive hours have not been assigned.

d e. The Shift Operations Manager shall hold an SRO license.

e f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This shall be assigned to both units when either unit is in MODE 1, 2, 3, or 4. The STA position may be filled by the shift manager or an on-shift SRO providing the individuals meet the dual role qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

COMANCHE PEAK - UNITS 1 AND 2 5.0-4 Amendment No. 64, 134

ATTACHMENT 2 to TXX-09089 PROPOSED TECHNICAL SPECIFICATION CHANGE (RE-TYPED)

Pages 5.0-3 5.0-4

Organization 5.2 5.2 Organization (continued) 5.2.2 Unit Staff The unit staff organization shall include the following:

a. A non-licensed operator shall be assigned to each reactor containing fuel and an additional non-licensed operator shall be assigned if either unit is operating in MODES 1, 2, 3, or 4.

With both units shutdown or defueled, a total of three non-licensed operators for the two units is required.

b. Shift crew composition may be one less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.e for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c. -------------------------------------------NOTE---------------------------------------------

A single Radiation Protection Technician and a single Chemistry Technician may fulfill the requirements for both units.

A Radiation Protection Technician and Chemistry Technician shall be on site when fuel is in the reactor. The positions may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required positions.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 5.0-3 Amendment No. 64,

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

d. The Shift Operations Manager shall hold an SRO license.

e. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This shall be assigned to both units when either unit is in MODE 1, 2, 3, or 4. The STA position may be filled by the shift manager or an on-shift SRO providing the individuals meet the dual role qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

COMANCHE PEAK - UNITS 1 AND 2 5.0-4 Amendment No. 64, 134,