CP-201201253, Supplement to License Amendment Request (LAR) 12-001, Revision to Technical Specification 5.7, High Radiation Area and Technical Specifications Table 3.3.3-1, Post Accident Monitoring Instrumentation.

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Supplement to License Amendment Request (LAR)12-001, Revision to Technical Specification 5.7, High Radiation Area and Technical Specifications Table 3.3.3-1, Post Accident Monitoring Instrumentation.
ML12310A197
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/23/2012
From: Flores R
Luminant Power, Luminant Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201201253, TAC ME9065, TAC ME9066
Download: ML12310A197 (11)


Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Glen Rose, TX 76043 Luminant rafaelflores@Luminant.com T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201201253 Ref: 10CFR50.90 Log # TXX-12153 October 23, 2012 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 SUPPLEMENT TO LICENSE AMENDMENT REQUEST (LAR)12-001, REVISION TO TECHNICAL SPECIFICATION 5.7, "HIGH RADIATION AREA" AND TECHNICAL SPECIFICATIONS TABLE 3.3.3-1,"POST ACCIDENT MONITORING INSTRUMENTATION." (TAC NOS. ME9065 AND ME9066)

REF: 1. Letter logged TXX-12092 dated July 12, 2012, from Rafael Flores to the NRC requesting an amendment to the CPNPP Unit 1 Operating License (NPF-87) and CPNPP Unit 2 Operating License (NPF-89) by incorporating the attached change into the Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 and 2 Technical Specifications (ADAMS Accession Number ML12202A085)

Dear Sir or Madam:

In Reference 1, Luminant Generation Company LLC (Luminant Power) submitted proposed changes to the Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 and Unit 2 Technical Specifications (TS),

Section 5.2, "High Radiation Areas." As a result of subsequent discussions on September 7, 2012 with NRC Staff (Balwant Singal) and Luminant Power (Steve Dixon), Luminant Power is submitting this supplement to LAR 12-001. This supplement will incorporate the pre-job briefing requirements contained in Revision 4 of the Standard Technical Specifications (NUREG 1431) into CPNPP TS 5.7.1e and TS 5.7.2e. Attachments 1 and 2 of this letter replace Attachments 2 and 3 of reference 1. The No Significant Hazards Considerations provided in Reference 1 remains valid and is not changed by this supplement to LAR 12-001.

Attachment 1 provides the affected TS pages marked-up to reflect the proposed changes. Attachment 2 provides retyped TS pages for review.

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

This communication contains no new licensing basis commitments regarding CPNPP Unit 1 and Unit 2.

A member of the STARS Alliance Callaway

  • Comanche Peak Diablo Canyon Palo Verde- San Onofre . South Texas Project- Wolf Creek At"I

U. S. Nuclear Regulatory Commission TXX-12153 Page 2 of 2 10/23/2012 Should you have any questions, please contact Mr. Steve Dixon at (254) 897- 5482.

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

Executed on October 23, 2012.

Sincerely, Luminant Generation Company LLC Rafael Flores Fred W. Madden Director, Oversight & Regulatory Affairs Attachments 1. Proposed Technical Specifications Changes (Mark-Up Pages)

2. Retyped Technical Specifications Pages (For Information) c- E. E. Collins, Region IV W. C. Walker, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Alice Hamilton Rogers, P.E.

Inspection Unit Manager Texas Department of State Health Services Mail Code 1986 P. 0. Box 149347 Austin TX 78714-9347

ATTACHMENT 1 to TXX-12153 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP) 3.7-37 5.7-2 5.7-3

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION ED.1

1. Refueling Water Storage Tank Level 2
2. Subcooling Monitors 2
3. Reactor Coolant System (RCS) Hot Leg 1 per loop Temperature (Wide Range) (That)
4. RCS Cold Leg Temperature (Wide Range) 1 per loop (Tcold)
5. RCS Pressure (Wide Range) 2
6. Reactor Vessel Water Level 2(a)
7. Containment Sump Water Level (Wide Range) 2
8. Containment Pressure (Intermediate Range) 2
9. Steam Line Pressure 2 per steam line
10. Containment Area Radiation (High Range) 2
11. Deleted
12. Pressurizer Water Level 2
13. Steam Generator Water Level (Narrow Range) 2 per steam generator
14. Condensate Storage Tank Level 2
15. Core Exit Temperature - Quadrant 1 2 (c)
16. Core Exit Temperature - Quadrant 2 2(c)
17. Core Exit Temperature - Quadrant 3 2(c) E
18. Core Exit Temperature - Quadrant 4 2(c) E
19. Auxiliary Feedwater Flow
a. AFW Flow 2 per steam generator E OR
b. AFW Flow and Steam Generator Water 1 each per steam E Level (Wide Range) generator (a) A channel is eight sensors in a probe. A channel is OPERABLE if four or more sensors, one or more in the upper section and three or more in the lower section, are OPERABLE.

(b) Deleted (c) A channel consists of two core exit thermocouples (CETs).

COMANCHE PEAK - UNITS 1 AND 2 3.3-37 Amendment No. 460-,

High Radiation Area 5.7 5.7 High Radiation Area 5.7.1 High Radiation Areas with Dose Rates not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation (continued) ii. Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.

e. Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.

5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation:

a. Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and, in addition:
1. All such door and gate keys shall be maintained under the administrative control of the [shift manager], or his or her designee.
2. Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.
b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.
d. Each individual or group entering such an area shall possess:

COMANCHE PEAK - UNITS 1 AND 2 5.7-2 Amendment No. 464-,

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation: (continued)

1. A radiation monitoring device that continuously integrates the radiation rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or
2. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area with the means to communicate with and control every individual in the area, or
3. A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and, Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or ii. Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area.
4. In those cases where options (2) and (3), above, are impractical or determined to be inconsistent with the Low As is Reasonably Achievable principle, a radiation monitoring device that continuously displays radiation dose rates in the area.
e. Except for individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.
f. Such individual areas that are within a larger area , such as PWR containment, where no enclosure exists for the purpose of locking and where COMANCHE PEAK- UNITS 1 AND 2 5.7-3 Amendment No. 4W

ATTACHMENT 2 to TXX-12153 RETYPED TECHNICAL SPECIFICATION PAGES (For Information)

Pages 3.7-37 5.7-2 5.7-3 5.7-4

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED CHANNEL S REQUIRED ACTION D.1

1. Refueling Water Storage Tank Level 2 E
2. Subcooling Monitors 2 E
3. Reactor Coolant System (RCS) Hot Leg 1 per loop E Temperature (Wide Range) (Thot)
4. RCS Cold Leg Temperature (Wide Range) 1 per loop E (Tcold)
5. RCS Pressure (Wide Range) 2 E
6. Reactor Vessel Water Level 2 (a) F
7. Containment Sump Water Level (Wide Range) 2 E
8. Containment Pressure (Intermediate Range) 2 E
9. Steam Line Pressure 2 per steam line E
10. Containment Area Radiation (High Range) 2 F
11. Deleted
12. Pressurizer Water Level 2 E
13. Steam Generator Water Level (Narrow Range) 2 per steam generator E
14. Condensate Storage Tank Level 2 E
15. Core Exit Temperature - Quadrant 1 2 (c) E
16. Core Exit Temperature - Quadrant 2 2 (c) E
17. Core Exit Temperature - Quadrant 3 2 (c) E
18. Core Exit Temperature - Quadrant 4 2 (c) E
19. Auxiliary Feedwater Flow
a. AFW Flow 2 per steam generator E OR
b. AFW Flow and Steam Generator Water 1 each per steam E Level (Wide Range) generator (a) A channel is eight sensors in a probe. A channel is OPERABLE if four or more sensors, one or more in the upper section and three or more in the lower section, are OPERABLE.

(b) Deleted (c) A channel consists of two core exit thermocouples (CETs).

COMANCHE PEAK - UNITS 1 AND 2 3.3-37 Amendment No. 44&,

High Radiation Area 5.7 5.7 High Radiation Area 5.7.1 High Radiation Areas with Dose Rates not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation (continued) ii. Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.

e. Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.

5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation:

a. Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and, in addition:
1. All such door and gate keys shall be maintained under the administrative control of the [shift manager], or his or her designee.
2. Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.
b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.
c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.
d. Each individual or group entering such an area shall possess:

COMANCHE PEAK - UNITS 1 AND 2 5.7-2 Amendment No. 464;

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation: (continued)

1. A radiation monitoring device that continuously integrates the radiation rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or
2. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area with the means to communicate with and control every individual in the area, or
3. A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and, Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or ii. Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area.
4. In those cases where options (2) and (3), above, are impractical or determined to be inconsistent with the Low As is Reasonably Achievable principle, a radiation monitoring device that continuously displays radiation dose rates in the area.
e. Except for individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.
f. Such individual areas that are within a larger area , such as PWR containment, where no enclosure exists for the purpose of locking and where COMANCHE PEAK - UNITS 1 AND 2 5.7-3 Amendment No. 460-,

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation: (continued) no enclosure can reasonably be constructed around the individual area need not be controlled by a locked door or gate nor continuously guarded, but shall be barricaded, conspicuously posted, and a clearly visible flashing light shall be activated at the area as a warning device.

COMANCHE PEAK - UNITS 1 AND 2 5.7-4 Amendment No.