CP-201101663, License Amendment Request (LAR)11-003 for Adopting of TSTF-491, Rev. 2, Removal of the Main Steam and Main Feedwater Valve Isolation Time from Tech Specs Using Consolidated Line Item Improvement Process.

License Amendment Request (LAR)11-003 for Adopting of TSTF-491, Rev. 2, Removal of the Main Steam and Main Feedwater Valve Isolation Time from Tech Specs Using Consolidated Line Item Improvement Process.

ML11356A219
Person / Time
Site:	Comanche Peak
Issue date:	12/13/2011
From:	Flores R, Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201101663, TXX-11144
Download: ML11356A219 (16)

Text

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

& Chief Nuclear Officer 6322 North FM 56 Luminant rafael.flores@luminant.com Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201101663 Ref: 10 CFR 50.90 TXX-11144 December 13, 2011 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP) DOCKET NOS. 50-445 AND 50-446, LICENSE AMENDMENT REQUEST (LAR)11-003, FOR ADOPTION OF TSTF-491, REV. 2, "REMOVAL OF THE MAIN STEAM AND MAIN FEEDWATER VALVE ISOLATION TIME FROM TECHNICAL SPECIFICATIONS USING CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS."

Dear Sir or Madam:

Pursuant to 10CFR50.90, Luminant Generation Company LLC (Luminant Power) hereby requests an amendment to the CPNPP Unit I Operating License (NFP-87) and CPNPP Unit 2 Operating License (NFP-89) by incorporating the attached change into the CPNPP Unit 1 and 2 Technical Specifications (TS).

This change request applies to both Units.

The proposed amendment would modify the CPNPP Unit 1 and 2 Technical Specifications (TS) by removing the specific isolation time for the isolation valves from the associated Technical Specification Surveillance Requirements. The availability of this TS improvement was announced in the Federal Register on December 29, 2006 (71 FR 78472) as part of the consolidated line item improvement process (CLIIP).

Attachment I provides a description of the proposed change, the required confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (retyped) TS pages. Attachment 4 provides the marked up existing TS Bases in support of the proposed change (for information only).

Luminant Power requests approval of the proposed license amendment by June 30, 2012, with the amendment being implemented within 120 days of approval. The approval date was administratively selected to allow for NRC review but the plant does not require this amendment to allow continued safe full power operations.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Ace I Callaway - Comanche Peak . Diablo Canyon ' Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek Ili Ot

U. S. Nuclear Regulatory Commission TXX-11144 Page 2 12/13/2011 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 licensing basis commitments regarding CPNPP Units 1 and 2.

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

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

Executed on December 13, 2011.

Sincerely, Luminant Generation Company, LLC Rafael Flores By: ___

FrY e W. Madden Director, Oversight & Regulatory Affairs CBC Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Proposed Technical Specification Changes (Re-Typed)

4. Proposed Technical Specification Bases Changes (for information only mark-up) c - E. E. Collins, Region IV W. C. Walker, 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-11144 DESCRIPTION OF ASSESSMENT I

to TXX-11144 Page 1 12/13/2011 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of TSTF 491 and Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

to TXX-11144 Page 2 12/13/2011

1.0 DESCRIPTION

The proposed amendment would modify technical specifications by removing the specific isolation time for the isolation valves from the associated Technical Specification (TS) Surveillance Requirements (SRs) 3.7.2.1 and 3.7.3.1.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) TSTF-491 Revision 2. The availability of this TS improvement was published in the Federal Register on December 29, 2006 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of TSTF-491 and Published Safety Evaluation Luminant Generation Company LLC (Luminant Power) has reviewed TSTF-491 (Reference 1), and the NRC model safety evaluation (SE) (Reference 2) as part of the CLIIP. Luminant Power has concluded that the information in TSTF-491, as well as the SE prepared by the NRC staff are applicable to Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2 and justify this amendment for the incorporation of the changes to the CPNPP TS.

2.2 Optional Changes and Variations Luminant Power is not proposing any variations or deviations from the TS changes described in TSTF-491 or the NRC staff's model safety evaluation dated October 5, 2006 (71 FR 58884).

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Luminant Power has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

Luminant Power has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to CPNPP, Units 1 and 2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on December 29, 2006 for this TS improvement, plant-specific verifications were performed as follows:

Luminant Power has proposed TS Bases consistent with TSTF-491 which provide guidance and details on how to implement the new requirements. Additionally, Luminant Power has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).

to TXX-11144 Page 3 12/13/2011 4.0 ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF-491, Rev 2, involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that TSTF-491, Rev 2, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Notice 71 FR 58884, October 5, 2006. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 REFERENCES

1. TSTF-491, Revision 2, "Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications, " Accession Number ML061500078, dated May 18, 2006.

2. NRC Model Safety Evaluation Report published on October 5, 2006 (71 FR 58884).

ATTACHMENT 2 to TXX-11144 PROPOSED TECHNICAL SPECIFICATION CHANGE (MARK-UP)

Pages 3.7-7 3.7-9

MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 ------------------------- NOTE -------------------

Only required to be performed in MODES 1 and 2.

Verify the isolation time of each MSIV is - 5 seconds In accordance with the Inservice in lim Testing Program SR 3.7.2.2 ------------------------- NOTE -------------------

Only required to be performed in MODES 1 and 2.

Verify each MSIV actuates to the isolation position on an 18 months actual or simulated actuation signal.

COMANCHE PEAK- UNITS 1 AND 2 3.7-7 Amendment No. 150

FIVs and FCVs and Associated Bypass Valves 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more FIV or FCV C.1 Close or isolate bypass valve. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> bypass valves inoperable.

AND C.2 Verify bypass valve is closed or Once per 7 days isolated.

D. Two valves in the same D.1 Isolate affected flow path. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> flowpath inoperable E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND E.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the isolation time of each FIV, FCV, and associated In accordance with bypass valves is - 5 second . the Inservice whliTesting Program SR 3.7.3.2 Verify each FIV, FCV, and associated bypass valves 18 months actuates to the isolation position on an actual or simulated actuation signal.

COMANCHE PEAK - UNITS 1 AND 2 3.7-9 Amendment No. 150

ATTACHMENT 3 to TXX-11144 PROPOSED TECHNICAL SPECIFICATION CHANGE (RE-TYPED)

Pages 3.7-7 3.7-9

MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 ----------------------- NOTE ------------------

Only required to be performed in MODES 1 and 2.

Verify the isolation time of each MSIV is within limits. In accordance with the Inservice Testing Program SR 3.7.2.2 ----------------------- NOTE ------------------

Only required to be performed in MODES 1 and 2.

Verify each MSIV actuates to the isolation position on an 18 months actual or simulated actuation signal.

COMANCHE PEAK - UNITS 1 AND 2 3.7-7 Amendment No. 4ýý

FIVs and FCVs and Associated Bypass Valves 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more FIV or FCV C.1 Close or isolate bypass valve. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> bypass valves inoperable.

AND C.2 Verify bypass valve is closed or Once per 7 days isolated.

D. Two valves in the same D.1 Isolate affected flow path. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> flowpath inoperable E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND E.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 verify the isolation time of each FIV, FCV, and associated In accordance with bypass valves is within limits, the Inservice Testing Program SR 3.7.3.2 Verify each FIV, FCV, and associated bypass valves 18 months actuates to the isolation position on an actual or simulated actuation signal.

COMANCHE PEAK - UNITS 1 AND 2 3.7 -9 Amendment No. 4fig-,

ATTACHMENT 4 to TXX-11144 PROPOSED TECHNICAL SPECIFICATION BASES CHANGE (for information only mark-up)

Pages B 3.7-12 B 3.7-18 B 3.7-19

within the limit given in Reference MSIVs ry-C-Y-Yf-ry'-ý 5 and iswithin that assumed in B3.2 rN--Y-)of each MSIV the accident and containment Sthe analyses BASES (continued)

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that MSI losure time is -5 seconds;The hand switch may be used as the actuation signal to perform this surveillanc__e£. The MV MS SR.isolation time is assumed in the accident and containment analyses. _his

• (Suveilanc*is normally performed upon returning the unit to operati following a refueling outage.T

• This SR also * ~

verifies the valve The Frequency is in accordance with the Lnservice Te ogram.

closure time is in This test is allowed to be conducted in MODE 3 with the unit at operating accordance with the temperature and pressure. This SR is modified by a Note that allows entry Inservice Testing into and operation in MODE 3 prior to performing the SR. This allows a (IST) Program. delay of testing until MODE 3, to establish conditions consistent with those under which the acceptance criterion was generated.

SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated main steam line isolation actuation signal. This Surveillance is normally performed upon returning the unit to operation following a refueling outage.

The frequency of MSIV testing is every 18 months. The 18 month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

This test is allowed to be conducted in MODE 3 with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows a delay of testing until MODE 3, to establish conditions consistent with those under which the acceptance criterion was generated.

REFERENCES 1. FSAR, Section 10.3.

2. FSAR, Section 6.2.

3. FSAR, Chapter 15.

4. 10 CFR 100.11. 5. Technical Requirements Manual.

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-12 Revision 64

FIVs and FCVs and Associated Bypass Valves B 3.7.3 BASES ACTIONS E.1 and E.2 (continued)

Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.1 within the limit given in Reference 2 and is within that REQU IREMENTS _________________

This SR verifies that the closure tim4jof each bypass valves is__ 5 seconds. The FIV and FCV FIV, FCV, and associated isolation times are ThsS lovrfe ssumed in the accident and containment analyses. This Surveillance is*/

the valve closure time normally performed upon returning the unit to operation followin refueling is in accordance with outage. This is consistent with RG 1.22 (Ref. 4).

the Inservice Testing Program. The Frequency for this SR is in accordance with the Inservice Testing Program. Per Ref. 5, ifit is necessary to adjust stem packing to stop packing leakage and if a required stroke test is not practical in the current plant mode, it should be shown by analysis that the packing adjustment is within torque limits specified by the manufacturer for the existing configuration of packing, and that the performance parameters of the valve are not adversely affected. A confirmatory test must be performed at the first available opportunity when plant conditions allow testing. Packing adjustments beyond the manufacturer's limits may not be performed without (1) an engineering analysis and (2) input from the manufacturer, unless tests can be performed after adjustments.

SR 3.7.3.2 This SR verifies that each FIV and associated bypass valve can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the unit to operation following a refueling outage.

The frequency of this surveillance is every 18 months. The 18 month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-18 Revision 64

FIVs and FCVs and Associated Bypass Valves B 3.7.3 BASES (continued)

REFERENCES 1. FSAR, Chapters 6, 7, 10 and 15.

2. Not used.T Rn

3. NUREG-0138, "Staff Discussion of Fifteen Technical Issues Listed in Attachment to November 3, 1076 Memorandum from Director, NRR to NRR Staff," November 1976.

4. RG 1.22, "Periodic Testing of Protection System Actuation Functions," (2/17/72).

5. NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants."

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-19 Revision 64