Text

License Amendment Request (LAR) 02-09 Revision to Technical Specifications Regarding Suspension of Positive Reactivity Additions
	ML023450281
Person / Time
Site:	Comanche Peak
Issue date:	12/04/2002
From:	Walker R; TXU Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	00236, CPSES-200203861, TXX-02201
	Download: ML023450281 (103)
	v • d • e

TXU TXU Energy C.Lance Terry Comanche Peak Steam Senior Vice President & Ref: 10CFR50.90 Electric Station Principal Nuclear Officer P.O. Box 1002 (E01)

Glen Rose, TX 76043 Tel: 254 897 8920 Fax: 254 897 6652 lance.terry@txu.com CPSES-200203861 Log # TXX-02201 File # 00236 December 4, 2002 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 LICENSE AMENDMENT REQUEST (LAR) 02-09 REVISION TO TECHNICAL SPECIFICATIONS REGARDING SUSPENSION OF POSITIVE REACTIVITY ADDITIONS Gentlemen:

Pursuant to 10CFR50.90, TXU Generation Company LP (TXU Energy) hereby requests an amendment to the CPSES Unit 1 Operating License (NPF-87) and CPSES Unit 2 Operating License (NPF-89) by incorporating the attached change into the CPSES Unit 1 and 2 Technical Specifications. This change request applies to both units.

The proposed amendment revises several of the Required Actions in the Comanche Peak Plant Technical Specifications (TS) that require suspension of operations involving positive reactivity additions or suspension of operations involving reactor coolant system (RCS) boron concentration reductions. In addition, the proposed amendment revises several Limiting Condition for Operation (LCO) Notes that preclude reductions in RCS boron concentration. This amendment revises these Required Actions and LCO Notes to allow controlled, safe insertions of positive reactivity, but limits the introduction of positive reactivity such that compliance with the required shutdown margin or refueling boron concentration limits will still be satisfied. This amendment is based on an NRC-approved traveler, TSTF-286 Revision 2.

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

Comanche Peak

Diablo Canyon

Palo Verde

South Texas Project

Wolf Creek

STXU TXX-02201 Page 2 of 3 provides a detailed description of the proposed changes, a safety analysis of the proposed changes, TXU Energy's determination that the proposed changes do not involve a significant hazard consideration, a regulatory analysis of the proposed changes and an environmental evaluation. Attachment 2 provides the affected Technical Specification pages marked-up to reflect the proposed changes. provides proposed changes to the Technical Specification Bases for information only. These Technical Specification Bases changes will be processed per CPSES site procedures. Attachment 4 provides retyped Technical Specification pages which incorporate the requested changes. Attachment 5 provides retyped Technical Specification Bases pages which incorporate the proposed changes. provides a correlation of proposed changes to the approved TSTF-286, Revision 2, STS changes.

TXU Energy requests approval of the proposed License Amendment by June 1, 2003 to be implemented within 60 days of the issuance of the license amendment. The approval date was administratively selected to allow for NRC review but the plant does not require this amendment to allow continued operations.

TXU Energy is submitting this license amendment application as a result of a mutual agreement by an industry consortium of six plants known as Strategic Teaming and Resource Sharing (STARS). The STARS group consists of the six plants operated by TXU Energy, AmerenUE, Wolf Creek Operating Corporation, Pacific Gas and Electric Company, STP Nuclear Operating Company, and Arizona Public Service Company. Callaway is the lead plant for this license amendment.

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

This communication contains no new or revised commitments.

Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725.

4 TXU TXX-02201 Page 3 of 3 I state under penalty of perjury that the foregoing is true and correct.

Executed on December 4, 2002.

Sincerely, TXU Generation Company LP By: TXU Generation Management Company LLC Its General Partner C. L. Terry Senior Vice President and Principal Nuclear Officer By:

ogD. Walker Regulatory Affairs Manager JCH Attachments 1. Description and Assessment

2. Markup of Technical Specifications Pages

3. Markup of Technical Specifications Bases Pages (for information)

4. Retyped Technical Specifications Pages

5. Retyped Technical Specifications Bases Pages (for information)

6. A Correlation of Proposed Changes to Approved TSTF-286, Revision 2, STS Changes c - E. W. Merschoff, Region IV W. D. Johnson, Region IV D. H. Jaffe, NRR Resident Inspectors, CPSES Mr. Authur C. Tate Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78704

ATTACHMENT 1 to TXX-02201 DESCRIPTION AND ASSESSMENT to TXX-02201 Page 2 of 14 LICENSEE'S EVALUATION

1.0 DESCRIPTION

This amendment application revises several of the Required Actions in the Comanche Peak Technical Specifications (TS) that require suspension of operations involving positive reactivity additions or suspension of operations involving reactor coolant system (RCS) boron concentration reductions. In addition, the proposed amendment revises several Limiting Condition for Operation (LCO) Notes that preclude reductions in RCS boron concentration. This amendment revises these Required Actions and LCO Notes to allow controlled, safe insertions of positive reactivity, but limits the introduction of positive reactivity such that compliance with the required shutdown margin (SDM) or refueling boron concentration limits will still be satisfied.

No changes to the CPSES Final Safety Analysis Report are anticipated as this time as a result of this License Amendment Request.

2.0 PROPOSED CHANGE

The proposed changes modify the Required Actions and LCO Notes that direct the suspension of activities that involve positive reactivity changes or RCS boron concentration reductions, with the exception of Required Action A.2 of TS 3.9.1 (however, TS Bases changes are attached for that Action). Clarifications are provided in the proposed TS Bases changes as to which plant evolutions are acceptable when operating under a Condition or LCO Note requiring suspension of positive reactivity additions or RCS boron concentration reductions.

The proposed changes will allow limited insertions of positive reactivity that are associated with routine plant operations. The proposed changes will limit the amount of positive reactivity additions that are allowed consistent with assuring appropriate reactivity limits are met, either SDM or refueling boron concentration The proposed TS changes are identical to those previously approved in License Amendment 190 for H. B. Robinson Unit 2 (Reference 2), and are based on approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-286, Revision 2, "Define 'Operations Involving Positive Reactivity Additions'," (Reference 3). The associated TS Bases changes include plant specific deviations where required, as noted in the applicable descriptions of changes below or summarized in Attachment 6. References are listed in Section 7.0 of this Evaluation.

Attachment I to TXX-02201 Page 3 of 14 The proposed TS changes are as follows:

I. Add a Note to TS 3.3.1, "RTS Instrumentation," Required Action G.1 that states:

"Limited boron concentration changes associated with RCS inventory control or limited plant temperature changes are allowed."

Condition G is applicable when the two required Intermediate Range Neutron Flux channels are inoperable. Required Action G. 1 currently states: "Suspend operations involving positive reactivity additions." The proposed Note will allow limited plant temperature changes or boron concentration fluctuations associated with RCS temperature control or inventory management.

Required Action G.1 will continue to require suspension of operations involving positive reactivity additions. Therefore, this proposed change simply clarifies the Required Action. The proposed change to TS 3.3.1 Required Action G.1 differs from TSTF-286, Revision 2 (Reference 3). TSTF-286, Revision 2, Insert 1 adds a Note stating: "Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM." Our proposed change does not include "...provided the change is accounted for in the calculated SDM." In MODES 1 and 2 with keff> 1.0, SDM is not a "calculated" value. Rather, SDM is assured by operation within the rod insertion limits of LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6 "Control Bank Insertion Limits" and by operating the plant per the requirements of LCO 3.4.2, "RCS Minimum Temperature for Criticality." This clarification is also described in the proposed Bases discussion of the new Note. The use of the words "temperature changes" in lieu of "cooldown" is considered more accurate since the Comanche Peak TS allow positive Moderator Temperature Coefficient (MTC) values at reduced power levels.

Under positive MTC conditions a temperature increase would cause a positive reactivity addition. The wording "temperature changes" refers to the fact that the MTC must be considered both during cooldown and heatup operations. The use of the words "Limited boron concentration changes associated with RCS inventory control" in lieu of "boron dilution" is consistent with the intent of TSTF-286, Revision 2, as expressed in Insert B I of the traveler, and provides further clarification of the Note. This wording is more descriptive of Comanche Peak operations than "boron dilution." This wording is more accurate with regard to the existing plant design which features two independent reactivity control systems: one using the movable control and shutdown rod cluster control assemblies (RCCAs), and the other using the chemical volume and control system (CVCS). This wording is identical to that approved for H. B. Robinson Unit 2 (Reference 2).

2. Add a Note to TS 3.3.1, "RTS Instrumentation," Required Action 1.1 that states: "Limited boron concentration changes associated with RCS inventory control or limited plant temperature changes are allowed."

Condition I is applicable when one of the two required Source Range Neutron Flux channels is inoperable in MODE 2 below P-6. Required Action 1.1 currently states:

"Suspend operations involving positive reactivity additions." The proposed Note will allow limited plant temperature changes or boron concentration fluctuations associated to TXX-02201 Page 4 of 14 with RCS temperature control or inventory management.

Required Action 1.1 will continue to require suspension of operations involving positive reactivity additions. Therefore, this proposed change simply clarifies the Required Action. The proposed change to TS 3.3.1 Required Action 1.1 differs from TSTF-286, Revision 2, in the same fashion, and for the same reasons, as described above for Required Action G. 1 of TS 3.3.1.

This wording is identical to that approved for H. B. Robinson Unit 2 (Reference 2).

3. Revise TS 3.4.5, "RCS Loops - MODE 3," LCO Note a, TS 3.4.6, "RCS Loops - MODE 4," LCO Note 1.a, TS 3.4.7, "RCS Loops - MODE 5, Loops Filled," LCO Note L.a, and TS 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," LCO Note 1.b, to state: "No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1." These Notes currently state: "No operations are permitted that would cause reduction of the RCS boron concentration."

These Notes are intended to preclude dilution of the RCS when no forced mixing (i.e.

coolant circulation by RHR pumps or reactor coolant pumps) is taking place. The proposed changes allow dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the SDM requirement of LCO 3.1.1. These proposed changes are identical to Insert 5 of TSTF-286, Revision 2.

4. Revise TS 3.4.5 Required Action D.2, TS 3.4.6 Required Action B. 1, TS 3.4.7 Required Action B. 1, and TS 3.4.8 Required Action B. 1 to state: "Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1." These Required Actions currently state: "Suspend all operations involving a reduction of RCS boron concentration."

These Required Actions are intended to preclude dilution of the RCS when no forced mixing is taking place. The proposed changes allow dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the SDM requirement of LCO 3.1.1. These proposed changes are identical to Insert 3 of TSTF-286, Revision 2.

5. Revise TS 3.8.2, "AC Sources - Shutdown," Required Actions A.2.3 and B.3, TS 3.8.5, "DC Sources - Shutdown," Required Action A.2.3, TS 3.8.8, "Inverters - Shutdown,"

Required Action A.2.3, and TS 3.8.10, "Distribution Systems - Shutdown," Required Action A.2.3 to state: "Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration." These Required Actions currently state: "Initiate action to suspend operations involving positive reactivity additions."

These Required Actions are intended to initiate suspension of operations involving positive reactivity additions based on the loss of required electrical sources and to TXX-02201 Page 5 of 14 distribution equipment. The proposed changes allow dilution of the RCS, but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the SDM requirement of LCO 3.1.1 or the refueling boron concentration of LCO 3.9.1. The proposed changes will also allow temperature changes that could increase reactivity provided the reactivity insertions do not result in a loss of required SDM or required refueling boron concentration. These proposed changes are identical to Insert 8 of TSTF 286, Revision 2.

6. Revise TS 3.9.3, "Nuclear Instrumentation," Required Action A.2 to state: "Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1 ." This Required Action currently states:" Suspend positive reactivity additions."

This Required Action is intended to initiate suspension of operations involving positive reactivity additions when there is a loss of one required Source Range Neutron Flux monitor, thereby rendering inoperable the redundant channel for monitoring core reactivity. The proposed change allows dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the minimum refueling boron concentration requirement of LCO 3.9.1. This proposed change also removes the implicit limitation on temperature changes that could result in a positive reactivity addition. No limitation on temperature change-induced reactivity insertion is needed, because appropriate shutdown margin in MODE 6 is maintained by compliance with LCO 3.9.1. This proposed change is identical to Insert 4 of TSTF-286, Revision 2.

7. Revise the LCO Note for TS 3.9.5, "RHR and Coolant Circulation - High Water Level," to state: "The required RHR loop may be removed from operation for*< 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1." This LCO Note currently states: "The required RHR loop may be removed from operation for _<1 hour per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause reduction of the Reactor Coolant System boron concentration."

This note is intended to preclude dilution of the RCS when no forced mixing is taking place. The proposed change allows dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the minimum refueling boron concentration requirement of LCO 3.9.1. This proposed change is identical to the markups and Insert 7 of TSTF-286, Revision 2.

8. Revise TS 3.9.5, "RHR and Coolant Circulation - High Water Level," Required Action A. 1 and TS 3.9.6, "RHR and Coolant Circulation - Low Water Level," Required Action B.1 to state: "Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1."

These Required Actions currently state: "Suspend operations involving a reduction in reactor coolant boron concentration."

to TXX-02201 Page 6 of 14 These Required Actions are intended to preclude dilution of the RCS when no forced mixing is taking place. The proposed changes allow dilution of the RCS, but the source of the boric acid is required to contain a soluble boron concentration greater than that required to meet the minimum refueling boron concentration requirement of LCO 3.9.1.

These proposed changes are identical to Insert 4 of TSTF-286, Revision 2.

The associated TS Bases will be revised accordingly; see the proposed changes in Attachment 3. describes additional LCO 3.3.1, 3.3.9, and 3.4.5 through 3.4.8 Bases changes required to reflect the analysis of an inadvertent boron dilution event for Comanche Peak. The following two additional TS Bases changes were taken from TSTF-286, Revision 2:

1. The Bases for TS 3.9.1, "Boron Concentration," Required Action A.2 will be revised to add the following: "Operations that individually add limited positive reactivity (e.g.,

temperature fluctuations, inventory addition, or temperature control fluctuations), but when combined with all other operations affecting core reactivity (e.g., intentional boration) result in overall net negative reactivity addition, are not precluded by this action."

2. An editorial change is made to the Bases for TS 3.9.1 Required Action A.3. The discussion regarding immediately suspending CORE ALTERATIONS or positive reactivity additions is corrected. The word "or" between "CORE ALTERATIONS" and "positive reactivity additions" should be "and" consistent with the requirements of the TS 3.9.1 Required Actions.

Finally, the Bases for TS 3.9.3, "Nuclear Instrumentation," Required Action B.2 will be revised for consistency with the changes made to TS 3.9.3 Required Action A.2. This change was not included in TSTF-286, Revision 2, but is needed since the revised Action A.2 would no longer absolutely preclude positive reactivity additions. This was an oversight in TSTF-286. The list of affected TS in TSTF-286 included "Action 3.9.3.B Bases, Nuclear Instrumentation, NUREG-1431 Only"; however, there were no changes to the Action 3.9.3.B Bases marked on page B 3.9-9 of the traveler.

3.0 BACKGROUND

Comanche Peak implemented the Improved Technical Specifications (ITS) in July 27, 1999 under License Amendment 64 (Reference 1). S ince then the industry and the NRC staff have been working to improve the Standard Technical Specifications (STS) NUREGs and, as a result, generic changes have been incorporated into Revision 2 of the STS NUREGs. This proposed amendment adopts generic changes from TSTF-286, Revision 2, which were incorporated into the STS by the NRC staff on July 6, 2000.

Comanche Peak has two independent reactivity control systems. One uses the movable control and shutdown RCCAs, and the other uses the CVCS to adjust the soluble boron concentration. In MODES 1 and 2, both systems are used to compensate for the reactivity effects from the fuel and coolant temperature changes in the RCS during power operation from full load to no load to TXX-02201 Page 7 of 14 conditions. In MODES 3, 4, and 5, the CVCS is used to compensate for the reactivity effects from temperature and xenon changes. In MODE 6, the CVCS is used to maintain the refueling boron concentration within the required limits.

The Comanche Peak SDM limits provide sufficient reactivity margin to ensure that the specified acceptable fuel design limits will not be exceeded for normal shutdown and Anticipated Operational Occurrences (AOOs). The SDM definition assumes that the single RCCA with the highest reactivity worth remains fully withdrawn. In MODES 1 and 2, the TS satisfy the required SDM (which is the amount of subcriticality that would immediately occur following the insertion of control and shutdown RCCAs that had been withdrawn, assuming the fuel and moderator temperatures are at hot zero power values) by limiting the insertion of the control and shutdown banks. Small reactivity changes due to RCS coolant inventory management and temperature control are also considered in specifying SDM, including MTC effects. In MODES 3, 4, and 5, the TS specify the required SDM (which is the reactivity margin by which the reactor will remain subcritical with the RCCAs fully inserted) by reference to the Core Operating Limits Report (COLR).

In MODE 6, reactor subcriticality margin is ensured by the limit on the boron concentration of all filled portions of the RCS and the refueling pool that have direct access to the reactor vessel.

The TS will be modified by this amendment to permit the addition of positive reactivity and changes to the RCS boron concentration as long as the change preserves the margin to core criticality as defined by the SDM and refueling boron concentration limit specifications.

NEED FOR CHANGE The proposed changes are needed to address operational considerations. During Conditions in which these Required Actions are entered, various plant operations must be continued. These activities make it necessary to sometimes add cooler water to the RCS (a positive reactivity change in most cases) or warmer water to the RCS and may involve inventory makeup from sources that are at a boron concentration less than that in the RCS.

Operational considerations may make it necessary or prudent to use a different residual heat removal (RHR) loop from the one in operation. With the proposed changes, if the newly selected RHR loop is sampled and the boron concentration is slightly lower than that of the RCS, but sufficiently high that SDM and refueling boron concentration limits continue to be met, the switch to a different loop would be acceptable. Alternatively, if the RHR loop is at a different temperature than the RCS average temperature, but the reactivity effects are small enough to assure that SDM and refueling boron concentration limits will continue to be met, again the swap over to the alternate RHR loop should be allowed. Inventory management evolutions will permit blended makeup to the RCS from the CVCS in MODES 3, 4, and 5 as long as both source range neutron flux channels are OPERABLE and at least one RCS loop is in operation, consistent with the mitigation equipment and mixing volume assumptions used in FSAR Section 15.4.6.

These types of activities should not be precluded as long as the required SDM or refueling boron concentration is maintained. The proposed changes provide the flexibility necessary to provide for to TXX-02201 Page 8 of 14 continued, safe reactor operations while also limiting any potential for excess positive reactivity additions.

4.0 TECHNICAL ANALYSIS

Design Basis and Safety Analysis Considerations The changes in TSTF-286, Revision 2, revise the following: 1) Required Actions that require suspension of operations involving positive reactivity additions or suspension of RCS boron concentration reductions and 2) various LCO Notes precluding reduction in boron concentration.

The revised TS limit the introduction of positive reactivity into the RCS of reactivity to that which would maintain the TS-required SDM or refueling boron concentrations, as applicable.

Additionally, the TS Required Actions that will still require the suspension of positive reactivity changes have Bases additions that clarify the intent is to preclude a loss of required SDM.

The TS Required Actions and LCO Notes that preclude positive reactivity additions and reductions in boron concentration are intended to maintain the required SDM or refueling boron concentration. During Conditions in which these Required Actions are invoked, various plant operations (e.g., maintaining RCS inventory and controlling RCS temperature) must be continued.

These necessary activities may involve additions to the RCS of different temperature makeup and may involve makeup from borated sources of water that are at boron concentrations less than the RCS boron concentration. These activities should not be precluded if the overall effect would still assure the required SDM or refueling boron concentration is maintained.

Small changes in reactivity occur as a result of temperature changes that accompany RCS inventory management or RCS temperature control. At the beginning of core life, positive MTC must also be considered.

The RCS boron concentration is maintained greater than or equal to the concentration required to maintain the required SDM in MODES 3, 4, and 5 or to maintain the required minimum refueling boron concentration in MODE 6. The TS Required Actions and LCO Notes that preclude decreasing the RCS boron concentration in the event that the plant has entered the revised TS Conditions are unduly restrictive if the overall effect on the core would still assure that the required LCO 3.1.1 SDM or LCO 3.9.1 boron concentration is maintained. The proposed change would allow using borated water sources that may decrease the RCS boron concentration while assuring the LCO 3.1.1 SDM or LCO 3.9.1 boron concentration limits are maintained.

The TS-required SDM at Comanche Peak is determined during the reload core design and is ensured during plant operation by the positioning of the RCCA control and shutdown rod banks and through adjustments of the soluble boron concentration in the reactor coolant.

The minimum required SDM is assumed as an initial condition in the safety analyses to ensure that the specified acceptable fuel design limits will not be exceeded for normal shutdown and AGOs, assuming that the highest worth RCCA remains stuck out following a reactor scram. The main steamline break (MSLB) is the most limiting event to establish the minimum SDM value for to TXX-02201 Page 9 of 14 LCO 3.1.1, and this ensures that the departure from nucleate boiling ratio safety limit is not exceeded.

In MODES 3, 4, and 5, the reactivity of the core must be consistent with the initial conditions assumed for the boron dilution accident analysis to ensure the minimum time required to terminate the event is met. This is satisfied by complying with the requirements of LCO 3.1.1 for the minimum SDM. Additionally, for MODE 6, the required boron concentration of LCO 3.9.1 ensures subcriticality during refueling operations.

As described in the SDM LCO 3.1.1 Bases, a sufficient shutdown margin ensures that: (1) the reactor can be made subcritical from all operating conditions, transients, and Design Basis Events; (2) the reactivity transients associated with postulated accident conditions are controllable within acceptable limits; and (3) the reactor will be maintained sufficiently subcritical to preclude inadvertent criticality in the shutdown condition. The Bases for the LCO 3.9.1 refueling boron concentration similarly indicate that the limitations on reactivity conditions during refueling ensure that the reactor will remain subcritical during MODE 6. Since the proposed changes will not alter the limits established in these specifications, there will be no effect on the ability to shutdown and maintain the reactor in a subcritical condition.

During certain conditions that are addressed in this proposed change, addition of water with a reduced boron concentration compared to the RCS and temperature changes will be allowed when forced circulation is not occurring. The proposed changes only permit the addition of inventory from sources whose boron concentration is sufficient to maintain the required boron concentration if the entire RCS inventory was replaced from the selected source. That is, the source of the water being added must be of high enough boron concentration that the effects of stratification, and subsequent mixing upon restoration of forced flow, cannot result in failure to meet the required boron concentration limits. This limitation addresses potential concerns with stratification and subsequent introduction of the "reduced" concentration borated water into the reactor vessel when forced circulation is re-established.

Based on the evaluation above, it is appropriate to make the proposed changes to the affected specifications and similar requirements. The proposed changes will not affect the limits on reactivity control, and will not permit operations that could result in exceeding these limits.

Therefore, the proposed change will not affect any safety margin or safety limit applicable to the facility.

Probabilistic Risk Assessment (PRA) Evaluation There is no impact on the Comanche Peak PRA since that study is concerned mainly with time averaged equipment functionality during full power operation, not actions to be taken to limit minor positive reactivity additions during operation below the P- 10 permissive. In any event, functional capabilities of the systems in the LCOs will continue to be met. Required SDM and refueling boron concentration limits will continue to be met.

to TXX-02201 Page 10 of 14 Summary/Conclusion The proposed amendment revises several of the Required Actions in the Comanche Peak Technical Specifications that require suspension of operations involving positive reactivity additions or suspension of operations involving RCS boron concentration reductions. In addition, the proposed amendment revises several LCO Notes that preclude reductions in RCS boron concentration. This amendment revises these Required Actions and LCO Notes to allow controlled, safe insertions of positive reactivity, but limits the introduction of positive reactivity such that compliance with the required SDM or refueling boron concentration limits will still be satisfied. The analyses presented above assess the potential impact of the proposed changes on applicable safety analyses. The assessments demonstrate that the change will not adversely affect the design basis, safety analyses, or the safe operation of the plant.

5.0 REGULATORY SAFETY ANALYSIS 5.1. No Significant Hazards Consideration This amendment application revises several of the Required Actions in the Comanche Peak Technical Specifications that require suspension of operations involving positive reactivity additions or suspension of operations involving RCS boron concentration reductions. In addition, the proposed amendment revises several LCO Notes that preclude reductions in RCS boron concentration. This amendment revises these Required Actions and LCO Notes to allow controlled, safe insertions of positive reactivity, but limits the introduction of positive reactivity such that compliance with the required SDM or refueling boron concentration limits will still be satisfied.

The proposed amendment does not involve a significant hazards consideration for Comanche Peak based on the three standards set forth in 10CFR50.92(c) as discussed below:

(1) Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No Overall protection system performance will remain within the bounds of the previously performed accident analyses since there are no hardware changes. The RTS instrumentation and reactivity control systems will be unaffected. Protection systems will continue to function in a manner consistent with the plant design basis. All design, material, and construction standards that were applicable prior to the request are maintained.

The probability and consequences of accidents previously evaluated in the FSAR are not adversely affected because the changes to the Required Actions and LCO Notes assure the limits on SDM and refueling boron concentration continue to be met, consistent with the analysis assumptions and initial conditions included within the safety analysis and licensing basis. The activities covered by this amendment application are routine operating evolutions. The proposed

Attachment 1 to TXX-02201 Page 11 of 14 changes do not reduce the capability of reborating the RCS.

The proposed changes will not involve a significant increase in the probability of any event initiators. The initiating event for an inadvertent boron dilution event, as discussed in FSAR Section 15.4.6, is a failure in the reactor makeup control system (RMCS) or operator error such that inventory makeup with the incorrect boron concentration enters the RCS by way of the CVCS. Since the RMCS design is unchanged, there will be no initiating event frequency increase associated with equipment failures. However, there could be an increased exposure time per operating cycle to potential operator errors during TS Conditions that, heretofore, prohibited positive reactivity additions. As such, the RTS Instrumentation and RCS Loops TS Bases changes from TSTF-286, Revision 2, have been augmented to preclude the introduction of reactor makeup water into the RCS via the CVCS when one source range neutron flux channel is inoperable or when no RCS loop is in operation. The equipment and processes used to implement RCS boration or dilution evolutions are unchanged and the equipment and processes are commonly used throughout the applicable MODES under consideration. There will be no degradation in the performance of, or an increase in the number of challenges imposed on, safety related equipment assumed to function during an accident situation. There will be no change to normal plant operating parameters or accident mitigation performance.

The proposed changes will not alter any assumptions or change any mitigation actions in the radiological consequence evaluations in the FSAR.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No There are no hardware changes nor are there any changes in the method by which any safety related plant system performs its safety function. This amendment will not affect the normal method of plant operation or change any operating limits. The proposed changes merely permit the conduct of normal operating evolutions when additional controls over core reactivity are imposed by the Technical Specifications. The proposed changes do not introduce any new equipment into the plant or alter the manner in which existing equipment will be operated. The changes to operating procedures are minor, with clarifications provided that required limits must continue to be met. No performance requirements or response time limits will be affected. These changes are consistent with assumptions made in the safety analysis and licensing basis regarding limits on SDM and refueling boron concentration.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this amendment. There will be no adverse effect or challenges imposed on any safety-related system as a result of this amendment.

This amendment does not alter the design or performance of the 7300 Process Protection System, to TXX-02201 Page 12 of 14 Nuclear Instrumentation System, or Solid State Protection System used in the plant protection systems.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

(3) Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed changes do not alter the limits on SDM or refueling boron concentration. The nominal trip setpoints specified in the Technical Specifications Bases and the safety analysis limits assumed in the transient and accident analyses are unchanged. None of the acceptance criteria for any accident analysis is changed. There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, heat flux hot channel factor (FQ), nuclear enthalpy rise hot channel factor (FDH), loss of coolant accident peak cladding temperature (LOCA PCT), peak local power density, or any other margin of safety. The radiological dose consequence acceptance criteria listed in the Standard Review Plan will continue to be met.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

==

Conclusion:==

Based on the above, TXU Energy concludes that the proposed amendment 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.

5.2 Applicable Regulatory Requirements/criteria The regulatory requirements associated with reactivity control include the following:

Criterion 10 -- Reactor design. The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

Criterion 11 -- Reactor inherentprotection. The reactor core and associated coolant systems shall be designed so that in the power operating range the net effect of the prompt inherent nuclear feedback characteristics tends to compensate for a rapid increase in reactivity.

Criterion 12 -- Suppression of reactorpower oscillations.The reactor core and associated coolant, control, and protection systems shall be designed to assure that power oscillations to TXX-02201 Page 13 of 14 which can result in conditions exceeding specified acceptable fuel design limits are not possible or can be reliably and readily detected and suppressed.

Criterion25 -- Protectionsystem requirementsfor reactivity control malfunctions. The protection system shall be designed to assure that specified acceptable fuel design limits are not exceeded for any single malfunction of the reactivity control systems, such as accidental withdrawal (not ejection or dropout) of control rods.

Criterion26 -- Reactivity control system redundancy and capability.Two independent reactivity control systems of different design principles shall be provided. One of the systems shall use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions.

Criterion 27 -- Combined reactivity control systems capability. The reactivity control systems shall be designed to have a combined capability, in conjunction with poison addition by the emergency core cooling system, of reliably controlling reactivity changes to assure that under postulated accident conditions and with appropriate margin for stuck rods the capability to cool the core is maintained.

Criterion28 -- Reactivity limits. The reactivity control systems shall be designed with appropriate limits on the potential amount and rate of reactivity increase to assure that the effects of postulated reactivity accidents can neither (1) result in damage to the reactor coolant pressure boundary greater than limited local yielding nor (2) sufficiently disturb the core, its support structures or other reactor pressure vessel internals to impair significantly the capability to cool the core. These postulated reactivity accidents shall include consideration of rod ejection (unless prevented by positive means), rod dropout, steam line rupture, changes in reactor coolant temperature and pressure, and cold water addition.

Criterion29 -- Protectionagainst anticipatedoperationaloccurrences.The protection and reactivity control systems shall be designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences.

10CFR50.46, Acceptance Criteriafor Emergency Core Cooling Systems for Light Water Nuclear Power Reactors -

a. Maximum fuel element cladding temperature is < 2200'F;

b. Maximum cladding oxidation is < 0.17 times the total cladding thickness before oxidation;

c. Maximum hydrogen generation from a zirconium-water reaction is < 0.01 times the to TXX-02201 Page 14 of 14 hypothetical amount generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react;

d. Core is maintained in a coolable geometry; and

e. Adequate core cooling capability is maintained.

There have been no changes to the plant design such that any of the regulatory requirements in Section 4.0 would come into question. This amendment application revises Required Actions and LCO Notes dealing with the suspension of positive reactivity additions or RCS boron concentration reductions. The evaluation performed by TXU Energy in Section 5.0 concludes that Comanche Peak will continue to comply with all applicable regulatory requirements.

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

TXU Energy has determined that the proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in I OCFR20, or would change an inspection or surveillance requirement. TXU Energy has evaluated the proposed change and has determined that the change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10CFR51.22 (c)(9).

Therefore, pursuant to 10CFR51.22 (b), an environmental assessment of the proposed change is not required.

7.0 REFERENCES

The TS changes requested in this amendment application are identical to those previously approved for H. B. Robinson Steam Electric Plant Unit 2 and are based on consistent with changes approved in TSTF-286, Revision 2. See Appendix A for additional discussion.

1. Comanche Peak License Amendment 64 dated July 27, 1999, Conversion to Improved Technical Specifications.

2. H. B. Robinson Steam Electric Plant Unit 2 License Amendment 190 dated March 14, 2001.

3. Industry/TSTF Standard Technical Specification Change Traveler TSTF-286, Revision 2, "Define 'Operations Involving Positive Reactivity Additions'."

ATTrACHMENT 2 TO TXX-02201 MARKED-UP TECHNICAL SPECIFICATION PAGES PAGES 3.3-4 3.3-5 3.4-8 3.4-9 3.4-11 3.4-12 3.4-14 3.4-15 3.4-17 3.4-18 3.8-18 3.8-19 3.8-28 3.8-36 3.8-40 3.9-5 3.9-9 3.9-12 to TXX-02201 Page 2 of 19 RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One channel inoperable. -------------- NOTE---------

The inoperable channel or another channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

E.1 Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR E.2 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. One Intermediate Range F.1 Reduce THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Neutron Flux channel POWER to < P-6.

inoperable.

OR F.2 Increase THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months POWER to > P-10.

G. Two Intermediate Range G.1 Sus.p. d,p.r..i:n.

Neutron Flux channels d.nVe..g

" Positive inoperable. .. additions.

,rAivity SNOTE ------------- Immediately Limited boron concentration changes associated with RCS inventory control or limited plant temperature changes are allowed.

Suspend operations involving positive reactivity additions.

AND G.2 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months POWER to < P-6.

H. Not used.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-4 Amendment No. 64 1 to TXX-02201 Page 3 of 19 RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME I. One Source Range Neutron 1.1 Suspend operation*.

Flux channel inoperable. .... ""Ii .pesiti"e reactivity additions.

----------NOTE --------- Immediately Limited boron concentration changes associated with RCS inventory control or limited plant temperature changes are allowed.

Suspend operations involving positive reactivity additions.

J. Two Source Range Neutron J.1 Open reactor trip Immediately Flux channels inoperable, breakers (RTBs).

K. One Source Range Neutron K.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Flux channel inoperable. OPERABLE status.

OR K.2.1 Initiate action to fully 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months insert all rods.

AND K.2.2 Place the Rod Control 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months System in a condition incapable of rod withdrawal.

L. Not used.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-5 Amendment No. 641 to TXX-02201 Page 4 of 19 RCS Loops -MODE 3 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Loops -MODE 3 LCO 3.4.5 Two RCS loops shall be OPERABLE, and either:

a. Two RCS loops shall be in operation when the Rod Control System is capable of rod withdrawal; or

b. One RCS loop shall be in operation when the Rod Control System is not capable of rod withdrawal.

NOTE- -----------------------

All reactor coolant pumps may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

- I..I ..... A &L -a .~ IA .- A. .- 4: - - -S 4L, - M r, t1_

a. N

.. . . . e*.. . .. . . . .. ";;;;;* ;; . ... .. . . .. . . .. .. . . . ... . . .

b*orn conc.ntratien; and No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature.

APPLICABILITY: MODE 3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RCS loop A.1 Restore required RCS 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable, loop to OPERABLE status.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-8 Amendment No. 64 1 to TXX-02201 Page 5 of 19 RCS Loops--MODE 3 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met.

C. One required RCS loop not C.1 Restore required RCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in operation, with Rod loop to operation.

Control System capable of rod withdrawal. OR C.2 Place the Rod Control 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months System in a condition incapable of rod withdrawal.

D. Four RCS loops inoperable. D.1 Place the Rod Control Immediately System in a condition OR incapable of rod withdrawal.

No RCS loop in operation.

AND D.2 Suspend all op1r,.tiosn.

involving a rd*Uctien of RCS boron cOnccntration.

Suspend operations that Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

AND D.3 Initiate action to restore Immediately one RCS loop to OPERABLE status and operation.

COMANCHE PEAK - UNITS 1 AND 2 3.4-9 Amendment No. 64 1 to TXX-02201 Page 6 of 19 RCS Loops--MODE 4 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops - MODE 4 LCO 3.4.6 Two loops consisting of any combination of RCS loops and residual heat removal (RHR) loops shall be OPERABLE, and one loop shall be in operation.

NOTES ---------------------

1. All reactor coolant pumps (RCPs) and RHR pumps may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations arc pcrmnittcd that would causc rcdUctiGn Of the RCS boron concentration; and No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10OF below saturation temperature.

2. No RCP shall be started with any RCS cold leg temperature < 350°F unless the secondary side water temperature of each steam generator (SG) is < 50°F above each of the RCS cold leg temperatures.

APPLICABILITY: MODE 4 COMANCHE PEAK - UNITS 1 AND 2 3.4-11 Amendment No. 64 1 to TXX-02201 Page 7 of 19 RCS Loops--MODE 4 3.4.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required loop A.1 Initiate action to restore a Immediately inoperable, second loop to OPERABLE status.

AND A.2 -------- NOTE -----------

Only required if one RHR loop is OPERABLE Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Two required loops B.1 Suse. nd all,p..atin.*.

inoperable, . a .du.ti, n of i nvolving RS boron cOn"entraWion.

OR Suspend operations that Immediately would cause introduction No RCS or RHR loop in into the RCS, coolant with operation. boron concentration less than required to meet SDM of LCO 3.1.1.

AND B.2 Initiate action to restore Immediately one loop to OPERABLE status and operation.

COMANCHE PEAK - UNITS 1 AND 2 3.4-12 Amendment No. 64 1 to TXX-02201 Page 8 of 19 RCS Loops--MODE 5, Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops- MODE 5, Loops Filled LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either:

a. One additional RHR loop shall be OPERABLE; or

b. The secondary side water level of at least two steam generators (SGs) shall be _>10%.

NOTES ----------------------

1. The RHR pump of the loop in operation may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No eperatiens arc pcfRmittcd that would cause reduction of the ROS boFro conccntratien; and No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10OF below saturation temperature.

2. One required RHR loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

3. No reactor coolant pump shall be started with any RCS cold leg temperature < 350°F unless the secondary side water temperature of each SG is < 50°F above each of the RCS cold leg temperatures.

4. All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.

APPLICABILITY: MODE 5 with RCS loops filled COMANCHE PEAK - UNITS 1 AND 2 3.4-14 Amendment No. 64 1 to TXX-02201 Page 9 of 19 RCS Loops- MODE 5, Loops Filled 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.I Initiate action to restore a Immediately second RHR loop to AND OPERABLE status.

Required SGs secondary OR side water levels not within limits. A.2 Initiate action to restore Immediately required SG secondary side water levels to within limits.

B. Required RHR loops B.1 Suspend all .pe..,tien, inoperable, invol'ing a r 'du'ti"nof RCS boFro cOnccntration, OR Suspend operations that Immediately would cause introduction No RHR loop in operation. into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

AND B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-15 Amendment No. 64 1 to TXX-02201 Page 10 of 19 RCS Loops -MODE 5, Loops Not Filled 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops -MODE 5, Loops Not Filled LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

NOTES ---------------------

1. All RHR pumps may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided:

a. The core outlet temperature is maintained at least 10°F below saturation temperature.

L I II i i i I *o f li

b. No opcratins arc pcrmittca that would causc a rcauciion of m

AA i HR:M n~r~n coc~rnin: rlf I

No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

c. No draining operations to further reduce the RCS water volume are permitted.

2. One RHR loop may be inoperable for < 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY: MODE 5 with RCS loops not filled

NOTE While this LCO is not met, entry into MODE 5, Loops Not Filled from MODE 5, Loops filled is not permitted.

COMANCHE PEAK - UNITS 1 AND 2 3.4-17 Amendment No. 64 1 to TXX-02201 Page 11 of 19 RCS Loops--MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore Immediately RHR loop to OPERABLE status.

B. Required RHR loops B.1 Susep. d all opratien, inoperable. i nvoling r.ducti,, in RCS boFIr cn*ncntration*

OR Suspend operations that Immediately would cause introduction No RHR loop in operation. into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

AND B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.8.2 Verify correct breaker alignment and indicated power are 7 days available to the required RHR pump that is not in operation.

COMANCHE PEAK - UNITS 1 AND 2 3.4-18 Amendment No. 64 1 to TXX-02201 Page 12 of 19 AC Sources - Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit NOTE --------- --------

inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with the required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 initiate action to cucpcna opcrti*n* involving positive reactivit Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.4 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-18 Amendment No. 641 to TXX-02201 Page 13 of 19 AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG B.1 Suspend CORE Immediately inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated fuel assemblies.

AND I ;+;-+-,÷ ,^+;,__, +* .--... A B.3 oprations positive rcactiit additions.

Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.4 Initiate action to restore Immediately required DG to OPERABLE status.

COMANCHE PEAK - UNITS 1 AND 2 3.8-19 Amendment No. 64 1 to TXX-02201 Page 14 of 19 DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown LCO 3.8.5 The Train A or Train B DC electrical power subsystem shall be OPERABLE to support one train of the DC electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required DC electrical A.1 Declare affected required Immediately power subsystems feature(s) inoperable.

inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to suspend opcation, involving pesitivc reactiit addiions.

Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-28 Amendment No. 64 1 to TXX-02201 Page 15 of 19 Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 The train A or Train B inverters shall be OPERABLE to support one train of the onsite Class 1 E AC vital bus electrical power distribution subsystems required by LCO 3.8. 10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6 ACTIONS ACTI NS CONDITION REQUIRED ACTION COMPLETION TIME I- I A. One or more required A.1 Declare affected required Immediately inverters inoperable. feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 lno+qn+ý ý,,+enn 4n ougnand

.p.rations i"nvelyng positive roactiVit additions.

Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

________________________ J COMANCHE PEAK - UNITS 1 AND 2 3.8-36 Amendment No. 64 1 to TXX-02201 Page 16 of 19 Distribution Systems- Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems- Shutdown LCO 3.8.10 The necessary portion of the Train A or Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support one train of equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC, A.1 Declare associated Immediately DC, or AC vital bus supported required electrical power distribution feature(s) inoperable.

subsystems inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 lnitiatc action to suspend opcrations involying pozitivc rcactiVity Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-40 Amendment No. 64 1 to TXX-02201 Page 17 of 19 Nuclear Instrumentation 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Nuclear Instrumentation LCO 3.9.3 Two source range neutron flux monitors shall be OPERABLE.

APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required source range A.1 Suspend CORE Immediately neutron flux monitor ALTERATIONS.

inoperable.

AND A.2 Suspend

. psit,*ve rcactivity additiens.

Suspend operations that Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

B. Two required source range B.1 Initiate action to restore Immediately neutron flux monitors one source range neutron inoperable, flux monitor to OPERABLE status.

AND B.2 Perform SR 3.9.1.1. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months COMANCHE PEAK - UNITS 1 AND 2 3.9-5 Amendment No. 64 1 to TXX-02201 Page 18 of 19 RHR and Coolant Circulation - High Water Level I 66 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation High Water Level LCO 3.9.5 One RHR loop shall be OPERABLE and in operation.

- IMLJ C:--------- --------- --------- --------- --------

The required RHR loop may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause oduction of the Rcactr Coolant System boron concentration.

introduction into the Reactor Coolant System, coolant with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1.

APPLICABILITY: MODE 6 with the water level > 23 ft above the top of reactor vessel flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RHR loop requirements not A.1 Suspend operations met. bnvelving a reducstion in reactor coolant boFro conccntration.

Suspend operations that Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

AND A.2 Suspend loading irradiated fuel assemblies Immediately in the core.

AND (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.9-9 Amendment No. 66 1 to TXX-02201 Page 19 of 19 RHR and Coolant Circulation - Low Water Level 3.9.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR loop in operation. B.1 Supepnd

,*,, atin, Immediately ianveo,,ng a rcduin in rcactOr coolant boron conenG9tratomn-.

Suspend operations that would cause introduction into the RCS, coolant with boron concentration less Immediately than required to meet the boron concentration of LCO 3.9.1.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B.2 Initiate action to restore one RHR loop to operation.

AND B.3 Close all containment penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of > 1000 gpm.

SR 3.9.6.2 Verify correct breaker alignment and indicated power 7 days available to the required RHR pump that is not in operation.

COMANCHE PEAK - UNITS 1 AND 2 3.9-12 Amendment No. 64 1

ATTTACHMENT 3 TO TXX-02201 MARKED-UP TECHNICAL SPECIFICATION BASES PAGES (FOR INFORMATION ONLY)

PAGES B 3.3-44 B 3.3-45 B 3.3-46 B 3.4-25 B 3.4-27 B 3.4-30 B 3.4-32 B 3.4-36 B 3.4-38 B 3.4-41 B 3.4-42 B 3.8-35 B 3.8-58 B 3.8-75 B 3.8-89 B 3.9-4 B 3.9-10 B 3.9-11 B 3.9-19 B 3.9-20 B 3.9-24 to TXX-02201 Page 2 of 22 RTS Instrumentation B 3.3.1 BASES ACTIONS G.1 and G.2 (continued)

Condition G applies to two inoperable Intermediate Range Neutron Flux trip channels in MODE 2 when THERMAL POWER is above the P-6 setpoint and below the P-10 setpoint. Required Actions specified in this Condition are only applicable when channel failures do not result in reactor trip. Above the P-6 setpoint and below the P-1 0 setpoint, the NIS intermediate range detector performs the monitoring Functions. With no intermediate range channels OPERABLE, the Required Actions are to suspend operations involving positive reactivity additions immediately.

This action will preclude any power level increase since there are no OPERABLE Intermediate Range Neutron Flux channels. The operator must also reduce THERMAL POWER below the P-6 setpoint within two hours. This action may require the use of the NIS source range channels or the neutron flux channels discussed in LCO 3.3.3, with action to reduce power below the count rate equivalent to the P-6 setpoint.

Below P-6, the Source Range Neutron Flux channels will be able to monitor the core power level. The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will allow a slow and controlled power reduction to less than the P-6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip.

Required Action G.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g.,

temperature or boron concentration fluctuations associated with RCS inventory or chemistry management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met and the requirements of LCOs 3.1.5, 3.1.6, and 3.4.2 are met.

H.1 Not Used.

1.1 Condition I applies to one inoperable Source Range Neutron Flux trip channel when in MODE 2, below the P-6 setpoint. With the unit in this Condition, the NIS source range performs the monitoring and protection (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-44 Amendment No. 64 1 to TXX-02201 Page 3 of 22 RTS Instrumentation B 3.3.1 BASES ACTIONS 1.1 (continued) functions. With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.

This action will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.

Required Action 1.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g.,

temperature or boron concentration fluctuations associated with RCS inventory or chemistry management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met, the requirements of LCOs 3.1.5, 3.1.6, and 3.4.2 are met, and the initial and critical boron concentration assumptions in FSAR Section 15 are satisfied.

J. 1 Condition J applies to two inoperable Source Range Neutron Flux trip channels when in MODE 2, below the P-6 setpoint, or in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, the NIS source range performs the protection functions. With both source range channels inoperable, the RTBs must be opened immediately. With the RTBs open, the core is in a more stable condition.

K.1, K.2.1 and K.2.2 Condition K applies to one inoperable source range channel in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, the NIS source range performs the protection functions. With one of the source range channels inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to restore it to an OPERABLE status. If the channel cannot be returned to an OPERABLE status, action must be initiated within the same 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to fully insert all rods. 1 additional hour is allowed to fully insert all rods and place the Rod Control System in a condition incapable of rod withdrawal (e.g., by de energizing all CRDMs, by opening the RTBs, or de-energizing the motor generator (MG) sets). Once these ACTIONS are completed, the core is in a more stable condition. The allowance of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-45 Amendment No. 64 1 to TXX-02201 Page 4 of 22 RTS Instrumentation B 3.3.1 BASES ACTIONS K.1, K.2.1 and K.2.2 (continued) channel to OPERABLE status, and the additional hour to place the Rod Control System in a condition incapable of rod withdrawal, are justified in Reference 5. Normal plant control operations that individually add limited positive reactivity (i.e., temperature or boron concentration fluctuations associated with RCS inventory or chemistry management or temperature control) are permitted provided the ADM limits specified in the COLR are met and the initial and critical boron concentration assumptions in FSAR Section 15 are satisfied.

L._1 Not Used.

M.1 and M.2 Condition M applies to the following reactor trip Functions:

Pressurizer Pressure-Low;

Pressurizer Water Level-High;

Reactor Coolant Flow-Low; 0 Undervoltage RCPs; and 0 Underfrequency RCPs.

With one channel inoperable, the inoperable channel must be placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . For the Pressrizer Pressure - Low, Pressurizer Water Level - High, Undervotage RCPs, and Underfrequency RCPs trip Functions, placing the channel in the tripped condition when above the P-7 setpoint results in a partial trip condition requiring only one additional channel to initiate a reactor trip. For the Reactor Coolant Flow Low trip Function, placing the channel in the tripped condition when above the P-8 setpoint results in a partial trip condition requiring only one additional channel in the same loop to initiate a reactor trip. Two tripped channels in two RCS loops are required to initiate a reactor trip when below the P-8 setpoint and above the P-7 setpoint. These Functions do not have to be OPERABLE below the P-7 setpoint because there are no loss of flow trips below the P-7 setpoint. There is insufficient heat (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-46 Amendment No. 64 1 to TXX-02201 Page 5 of 22 RCS Loops -MODE 3 B 3.4.5 BASES LCO is validation of the pump coastdown curve used as input to a number of (continued) accident analyses including a loss of flow accident. This test is generally performed in MODE 3 during the initial startup testing program, and as such should only be performed once. If, however, changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values of the coastdown curve must be revalidated by conducting the test again.

Utilization of the Note is permitted provided the following conditions are met, along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron dilution with coolant at boron concentrations lessthan required to assure the SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

b. Core outlet temperature is maintained at least 10OF below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

An OPERABLE RCS loop consists of one OPERABLE RCP and one OPERABLE SG in accordance with the Steam Generator Tube Surveillance Program, which has the minimum water level specified in SR 3.4.5.2. An RCP is OPERABLE if it is capable of being powered and is able to provide forced flow if required.

APPLICABILITY In MODE 3, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing.

The most stringent condition of the LCO, that is, two RCS loops OPERABLE and two RCS loops in operation, applies to MODE 3 with Rod Control System capable of rod withdrawal. The least stringent condition, that is, two RCS loops OPERABLE and one RCS loop in operation, applies to MODE 3 with the Rod Control System not capable of rod withdrawal.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-25 Amendment No. 64 1 to TXX-02201 Page 6 of 22 RCS Loops -MODE 3 B 3.4.5 BASES ACTIONS C.1 and C.2 (continued)

If the required RCS loop is not in operation, and the Rod Control System is capable of rod withdrawal, the Required Action is either to restore the required RCS loop to operation or to place the Rod Control System in a condition incapable of rod withdrawal (e.g., de-energize all CRDMs by opening the RTBs or de-energizing the motor generator (MG) sets).

When the Rod Control System is capable of rod withdrawal, it is postulated that a power excursion could occur in the event of an inadvertent control rod withdrawal. This mandates having the heat transfer capacity of two RCS loops in operation. If only one loop is in operation, the Rod Control System must be in a condition incapable of rod withdrawal. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the required RCS loop to operation or render the Rod Control System incapable of rod withdrawal is adequate to perform these operations in an orderly manner without exposing the unit to risk for an undue time period.

D.1, D.2, and D.3 If four RCS loops are inoperable or no RCS loop is in operation, except as during conditions permitted by the Note in the LCO section, place the Rod Control System in a condition incapable of rod withdrawal (e.g., all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets). All operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertent rod withdrawal. Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO3,1,1 is required to assure continued safe operation. With coolant addedwithout forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting theminimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-27 Amendment No. 64 1 to TXX-02201 Page 7 of 22 RCS Loops-MODE 4 B 3.4.6 BASES (continued)

LCO The purpose of this LCO is to require that at least two loops be OPERABLE in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. Any one loop in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide redundancy for heat removal.

Note 1 permits all RCPs or RHR pumps to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests that are required to be performed without flow or pump noise. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining themargin to criticality. Boron dilution with coolant at boronconcentrations less than required to assure the SDM is maintainedis prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

b. Core outlet temperature is maintained at least 10O]F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 requires that the secondary side water temperature of each SG be

< 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature < 350°F. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-30 Amendment No. 64 1 to TXX-02201 Page 8 of 22 RCS Loops- MODE 4 B 3.4.6 BASES ACTIONS A.1 and A.2 (continued)

If one required RHR loop is OPERABLE and in operation and there are no RCS loops OPERABLE, an inoperable RCS or RHR loop must be restored to OPERABLE status to provide a redundant means for decay heat removal.

If the parameters that are outside the limits cannot be restored, the unit must be brought to MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the unit to MODE 5 is a conservative action with regard to decay heat removal.

With only one RHR loop OPERABLE, redundancy for decay heat removal is lost and, in the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 (< 200 0 F) rather than MODE 4 (200 to 3500 F). The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time, based on operating experience, to reach MODE 5 from MODE 4 in an orderly manner and without challenging plant systems.

B.1 and B.2 If no loop is OPERABLE or in operation, except during conditions permitted by Note 1 in the LCO section, all operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and the margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant, into the RCS, with boron concentration less thanrequired to meet the minimum SDM of LCO 3.1.1 is required to assurecontinued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one RCS or RHR loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-32 Amendment No. 64 to TXX-02201 Page 9 of 22 RCS Loops -MODE 5, Loops Filled B 3.4.7 BASES LCO Utilization of Note 1 is permitted provided the following conditions are (continued) met, along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining themargin to criticality. Boron dilution with coolant at boron concentrations less than required to assure the SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.

Note 3 requires that the secondary side water temperature of each SG be

< 50°F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with an RCS cold leg temperature < 3500 F.

This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG can perform as a heat sink via natural circulation when it has an adequate water level and is OPERABLE in accordance with the Steam Generator Tube Surveillance Program.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-36 Amendment No. 64 1 to TXX-02201 Page 10 of 22 RCS Loops -MODE 5, Loops Filled B 3.4.7 BASES ACTIONS B.1 and B.2 (continued)

If no RHR loop is in operation, except during conditions permitted by Notes 1 and 4, or if no loop is OPERABLE, all operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimumSDM of LCO 3.1.1 must be suspended and action to restore one RHRloop to OPERABLE status and operation must be initiated. To prevent inadvertent criticality during a boron dilution, forced circulation from at least one RCP is required to provide proper mixing and preserve the margin to criticality in this type of operation.

Suspending the introductionof coolant, into the RCS, with boron concentration less than required tomeet the minimum SDM of LCO 3.1.1 is required to assure continued safeoperation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin tosubcritical operations. The immediate Completion Times reflect theimportance of maintaining operation for heat removal.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.7.2 Verifying that at least two SGs are OPERABLE by ensuring their secondary side narrow range water levels are _>10% ensures an alternate decay heat removal method via natural circulation in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this Surveillance is not needed. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-38 Amendment No. 64 1 to TXX-02201 Page 11 of 22 RCS Loops -MODE 5, Loops Not Filled B 3.4.8 BASES (continued)

LCO Note 1 permits all RHR pumps to be removed from operation for (continued) < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The circumstances for stopping both RHR pumps are to be limited to situations when the outage time is short and core outlet temperature is maintained at least 10°F below saturation temperature.

The Note prohibits boron dilution with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1 is maintained or draining operations when RHR forced flow is stopped.

Note 2 allows one RHR loop to be inoperable for a period of

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System. The Applicability is modified by a Note stating that entry into MODE 5 Loops Not Filled from MODE 5 Loops Filled is not permitted while LCO 3.4.8 is not met. This Note specifies an exception to LCO 3.0.4 and would prevent draining the RCS, which would eliminate the possibility of SG heat removal, while the RHR function was degraded.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops -MODES 1 and 2";

LCO 3.4.5, "RCS Loops--MODE 3";

LCO 3.4.6, "RCS Loops -MODE 4";

LCO 3.4.7, "RCS Loops -MODE 5, Loops Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation Low Water Level" (MODE 6).

(continued)

COMANCHE PEAK- UNITS 1 AND 2 B 3.4-41 j,,,, 27, 1999Revision I to TXX-02201 Page 12 of 22 RCS Loops- MODE 5, Loops Not Filled B 3.4.8 BASES (continued)

ACTIONS A.1 If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2 If no required RHR loops are OPERABLE or in operation, except during conditions permitted by Note 1, all operations involving introduction of coolant, into the RCS, with boronconcentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation. Boron dilution requires forced circulation for uniform dilution, and the margin to criticality must not be reduced in this type of operation.

Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meetthe minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin tosubcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one loop is in operation.

Verification may include flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.8.2 Verification that the required number of pumps are OPERABLE ensures that additional pumps can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-42 ,,l, ,27, ! 999Revision I to TXX-02201 Page 13 of 22 AC Sources--Shutdown B 3.8.2 BASES ACTIONS A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2. B.3, and B.4 (continued)

With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result infailure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory mayallow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCSinventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to the required ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 would provide the appropriate restrictions for the situation involving a de-energized train.

(continued)

COMANCHE PEAK- UNITS 1 AND 2 B 3.8-35 Amendment No. 64 1 to TXX-02201 Page 14 of 22 DC Sources- Shutdown B 3.8.5 BASES LCO function(s) (implicitly required by the definition of OPERABILITY).

(continued) Otherwise, the supported components must be declared inoperable and the appropriate conditions of the LCOs for the redundant components must be entered.

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Required features needed to mitigate a fuel handling accident are available;

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meetthe minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-58 Amendment No. 64 1 to TXX-02201 Page 15 of 22 Inverters - Shutdown B 3.8.8 BASES (continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meetthe minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage output ensures that the required power is available for the instrumentation connected to the AC vital buses. The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES 1. FSAR, Chapter 6.

2. FSAR, Chapter 15.

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-75 Amendment No. 64 1 to TXX-02201 Page 16 of 22 Distribution Systems- Shutdown B 3.8.10 BASES (continued)

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, DC, and AC vital bus electrical power distribution subsystems requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions That could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boronconcentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical opeation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-89 Amendment No. 64 1 to TXX-02201 Page 17 of 22 Boron Concentration B 3.9.1 BASES ACTIONS A.1 and A.2 (continued)

Suspension of CORE ALTERATIONS and positive reactivity additions shall not preclude moving a component to a safe position. Operations that individually add limited positive reactivity (e.g., temperature fluctuations, inventory addition, or temperature control fluctuations), but when combined with all other operations affecting core reactivity (e.g.,

intentional boration) result in overall net negative reactivity addition, are not precluded by this action.

When determining compliance with actions, addition of borated water with a concentration greater than or equal to the minimum required RWST concentration shall not be considered a positive reactivity change (Ref.3).

A.3 In addition to immediately suspending CORE ALTERATIONS and positive reactivity additions, boration to restore the concentration must be initiated immediately.

In determining the required combination of boration flow rate and concentration, no unique Design Basis Event must be satisfied. The only requirement is to restore the boron concentration to its required value as soon as possible. In order to raise the boron concentration as soon as possible, the operator should begin boration with the best source available for unit conditions.

Once actions have been initiated, they must be continued until the boron concentration is restored. The restoration time depends on the amount of boron that must be injected to reach the required concentration.

SURVEILLANCE SR 3.9.1.1 REQUIREMENTS This SR ensures that the coolant boron concentration in the filled portions of the RCS, and all the filled portions of the refueling canal and the refueling cavity, that have direct access to the reactor vessel is within the COLR limits. The boron concentration of the coolant in each volume is determined periodically by chemical analysis.

A minimum Frequency of once every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is a reasonable amount of time to verify the boron concentration of representative samples. The Frequency is based on operating experience, which has shown 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to be adequate.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-4 Amendment No. 64 1 to TXX-02201 Page 18 of 22 Nuclear Instrumentation B 3.9.3 BASES (continued)

APPLICABLE Two OPERABLE source range neutron flux monitors from either set of SAFETY source range neutron flux monitor systems are required to provide a visual ANALYSES signal to alert the operator to unexpected changes in core reactivity such as with a boron dilution accident (Ref. 2) or an improperly loaded fuel assembly.

The source range neutron flux monitors satisfy Criterion 3 of 10CFR50.36(c)(2)(ii).

LCO This LCO requires that two source range neutron flux monitors be OPERABLE to ensure that redundant monitoring capability is available to detect changes in core reactivity. To be OPERABLE, each monitor must provide visual indication in the control room. Both monitors used to satisfy this LCO must be from the same set of available neutron flux monitoring systems.

APPLICABILITY In MODE 6, the source range neutron flux monitors must be OPERABLE to determine changes in core reactivity. There are no other direct means available to check core reactivity levels. In other MODES, the source range monitors are governed by LCO 3.3.1, LCO 3.3.3, and LCO 3.3.4.

ACTIONS A.1 and A.2 With only one required source range neutron flux monitor OPERABLE, redundancy has been lost. Since these instruments are the only direct means of monitoring core reactivity conditions, CORE ALTERATIONS and introduction of coolant into the RCS with boron concentration less than required to meet the minimum boron concentration of LCO 3.9.1 must be suspended immediately. Suspending positivereactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that hve a boron concentration. This mayresult in an overall reduction in RCS boron concentration, but providesacceptable margin to maintaining subcritical operation.

erformance of Required Action A.lshapl not preclude completion of movement of a component to a safe position. Addition to the RCS of borated water with a concentration greater than or equal to the minimum required RWST concentration shall not be considered to be a positive reactivity change (Ref 3).

B.1 With no required source range neutron flux monitor OPERABLE, action to restore a monitor to OPERABLE status shall be initiated immediately.

Once initiated, action shall be continued until a source range neutron flux monitor is restored to OPERABLE status.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-10 Revision 20 1 to TXX-02201 Page 19 of 22 Nuclear Instrumentation B 3.9.3 BASES (continued)

ACTIONS B.2 (continued)

With no required source range neutron flux monitor OPERABLE, there are no direct means of detecting changes in core reactivity. However, since CORE ALTERATIONS and boron concentration changes inconsistent with Required Action A.2 are not to bemade, the core reactivity condition is stabilized until the source range neutron flux monitors are OPERABLE.

This stabilized condition is determined by performing SR 3.9.1.1 to ensure that the required boron concentration exists.

The Completion Time of once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient to obtain and analyze a reactor coolant sample for boron concentration and ensures that unplanned changes in boron concentration would be identified. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is reasonable, considering the low probability of a change in core reactivity during this time period.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS SR 3.9.3.1 is the performance of a CHANNEL CHECK, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels, but each channel should be consistent with its local conditions.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is consistent with the CHANNEL CHECK Frequency specified similarly for the same instruments in LCO 3.3.1.

SR 3.9.3.2 SR 3.9.3.2 is the performance of a CHANNEL CALIBRATION every 18 months. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the source range neutron flux monitors includes obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage. Operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 13, GDC 26, GDC 28, and GDC 29.

2. FSAR, Section [15.2.4].

3. NRC letter (W. Reckley to N. Cams) dated November 22, 1993

'Wolf Creek Generating Station - Positive Reactivity Addition; Technical Specification Bases Changes" COMANCHE PEAK - UNITS 1 AND 2 B 3.9-11 Revision 2-9 to TXX-02201 Page 20 of 22 RHR and Coolant Circulation - High Water Level B 3.9.5 BASES (continued)

LCO Only one RHR loop is required for decay heat removal in MODE 6, with the water level Ž23 ft above the top of the reactor vessel flange. Only one RHR loop is required to be OPERABLE, because the volume of water above the reactor vessel flange provides backup decay heat removal capability. At least one RHR loop must be OPERABLE and in operation to provide:

a. Removal of decay heat;

b. Mixing of borated coolant to minimize the possibility of criticality; and

c. Indication of reactor coolant temperature.

An OPERABLE RHR loop includes an RHR pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and to determine the low end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs.

The LCO is modified by a Note that allows the required operating RHR loop to be removed from service for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to meet the minimum boron concentration of LCO 3.9.1. Boron concentration reduction with coolant at boron concentrations less than required to assure the minimum required RCS boron concentration is maintained is prohibited because uniform concentration distribution cannot be ensured without forced circulation. This permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation valve testing. During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, decay heat is removed by natural convection to the large mass of water in the refueling cavity.

APPLICABILITY One RHR loop must be OPERABLE and in operation in MODE 6, with the water level > 23 ft above the top of the reactor vessel flange, to provide decay heat removal. The 23 ft water level was selected because it corresponds to the 23 ft requirement established for fuel movement in LCO 3.9.7, "Refueling Cavity Water Level." Requirements for the RHR (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-19 Amendment No. 64 1 to TXX-02201 Page 21 of 22 RHR and Coolant Circulation - High Water Level B 3.9.5 BASES APPLICABILITY System in other MODES are covered by LCOs in Section 3.4, Reactor (continued) Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS). RHR loop requirements in MODE 6 with the water level < 23 ft are located in LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level."

ACTIONS RHR loop requirements are met by having one RHR loop OPERABLE and in operation, except as permitted in the Note to the LCO.

A._1 If RHR loop requirements are not met, there will be no forced circulation to provide mixing to establish uniform boron concentrations.

Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than the required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

A.2 If RHR loop requirements are not met, actions shall be taken immediately to suspend loading of irradiated fuel assemblies in the core. With no forced circulation cooling, decay heat removal from the core occurs by natural convection to the heat sink provided by the water above the core.

A minimum refueling water level of 23 ft above the reactor vessel flange provides an adequate available heat sink. Suspending any operation that would increase decay heat load, such as loading a fuel assembly, is a prudent action under this condition. Performance of Required Action A2 shall not preclude completion of movement of a component to a safe condition.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-20 Amendment No. 64 1 to TXX-02201 Page 22 of 22 RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES ACTIONS B..1 (continued)

If no RHR loop is in operation, there will be no forced circulation to provide mixing to establish uniform boron concentrations. Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than the required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

B.2 If no RHR loop is in operation, actions shall be initiated immediately, and continued, to restore one RHR loop to operation. Since the unit is in Conditions A and B concurrently, the restoration of two OPERABLE RHR loops and one operating RHR loop should be accomplished expeditiously.

B.3 If no RHR loop is in operation, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . With the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures that dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability of the coolant boiling in that time.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-24 Amendment No. 64 1

ATTTACHMENT 4 TO TXX-02201 RETYPED TECHNICAL SPECIFICATION PAGES PAGES 3.3-4 3.3-5 3.4-8 3.4-9 3.4-11 3.4-12 3.4-14 3.4-15 3.4-17 3.4-18 3.8-18 3.8-19 3.8-28 3.8-36 3.8-40 3.9-5 3.9-9 3.9-12 to TXX-02201 Page 2 of 19 RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One channel inoperable. ------------ NOTE ---------

The inoperable channel or another channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

E.1 Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR E.2 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. One Intermediate Range F.1 Reduce THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Neutron Flux channel POWER to < P-6.

inoperable.

OR F.2 Increase THERMAL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months POWER to > P-10.

G. Two Intermediate Range G.1 --------- NOTE -------- Immediately Neutron Flux channels Limited boron inoperable, concentration changes associated with RCS inventory control or limited plant temperature changes are allowed.

Suspend operations involving positive reactivity additions.

AND G.2 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months POWER to < P-6.

H. Not used.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-4 Amendment No-to TXX-02201 Page 3 of 19 RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

1. One Source Range Neutron 1.1 --------- NOTE --------- Immediately Flux channel inoperable. Limited boron concentration changes associated with RCS inventory control or limited plant temperature changes are allowed.

Suspend operations involving positive reactivity additions.

J. Two Source Range Neutron J.1 Open reactor trip Immediately Flux channels inoperable, breakers (RTBs).

K. One Source Range Neutron K.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Flux channel inoperable. OPERABLE status.

OR K.2.1 Initiate action to fully 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months insert all rods.

AND K.2.2 Place the Rod Control 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months System in a condition incapable of rod withdrawal.

L. Not used.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-5 Amendment No.

to TXX-02201 Page 4 of 19 RCS Loops -MODE 3 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Loops- MODE 3 LCO 3.4.5 Two RCS loops shall be OPERABLE, and either:

a. Two RCS loops shall be in operation when the Rod Control System is capable of rod withdrawal; or

b. One RCS loop shall be in operation when the Rod Control System is not capable of rod withdrawal.

NOTE ------------------------

All reactor coolant pumps may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 1OLIF below saturation temperature.

APPLICABILITY: MODE 3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RCS loop A.1 Restore required RCS 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable, loop to OPERABLE status.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-8 Amendment No.

to TXX-02201 Page 5 of 19 RCS Loops--MODE 3 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A not met.

C. One required RCS loop not C.1 Restore required RCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in operation, with Rod loop to operation.

Control System capable of rod withdrawal. OR C.2 Place the Rod Control 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months System in a condition incapable of rod withdrawal.

D. Four RCS loops inoperable. D.1 Place the Rod Control Immediately System in a condition OR incapable of rod withdrawal.

No RCS loop in operation.

AND D.2 Suspend operations that Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1.

AND D.3 Initiate action to restore Immediately one RCS loop to OPERABLE status and operation.

COMANCHE PEAK - UNITS 1 AND 2 3.4-9 Amendment No.

to TXX-02201 Page 6 of 19 RCS Loops - MODE 4 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops-MODE 4 LCO 3.4.6 Two loops consisting of any combination of RCS loops and residual heat removal (RHR) loops shall be OPERABLE, and one loop shall be in operation.

NOTES -----------------------------------------

1. All reactor coolant pumps (RCPs) and RHR pumps may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10OF below saturation temperature.

2. No RCP shall be started with any RCS cold leg temperature 11 350 EF unless the secondary side water temperature of each steam generator (SG) is *50 EF above each of the RCS cold leg temperatures.

S...............................................................................................

APPLICABILITY: MODE 4 COMANCHE PEAK - UNITS 1 AND 2 3.4-11 Amendment No.

to TXX-02201 Page 7 of 19 RCS Loops - MODE 4 3.4.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required loop A.1 Initiate action to restore a Immediately inoperable, second loop to OPERABLE status.

AND A.2 .--------

NOTE -----------

Only required if one RHR loop is OPERABLE Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Two required loops B.1 Suspend operations that Immediately inoperable, would cause introduction into the RCS, coolant with OR boron concentration less than required to meet No RCS or RHR loop in SDM of LCO 3.1.1.

operation.

AND B.2 Initiate action to restore Immediately one loop to OPERABLE status and operation.

COMANCHE PEAK - UNITS 1 AND 2 3.4-12 Amendment No.

to TXX-02201 Page 8 of 19 RCS Loops -MODE 5, Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops-MODE 5, Loops Filled LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either:

a. One additional RHR loop shall be OPERABLE; or

b. The secondary side water level of at least two steam generators (SGs) shall be El 10%.

NOTES ---------------------

1. The RHR pump of the loop in operation may be removed from operation for El 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10ElF below saturation temperature.

2. One required RHR loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

3. No reactor coolant pump shall be started with any RCS cold leg temperature El 350EIF unless the secondary side water temperature of each SG is 11 50EIF above each of the RCS cold leg temperatures.

4. All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.

APPLICABILITY: MODE 5 with RCS loops filled COMANCHE PEAK - UNITS 1 AND 2 3.4-14 Amendment No.

to TXX-02201 Page 9 of 19 RCS Loops -MODE 5, Loops Filled 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore a Immediately second RHR loop to AND OPERABLE status.

Required SGs secondary OR side water levels not within limits. A.2 Initiate action to restore Immediately required SG secondary side water levels to within limits.

B. Required RHR loops B.1 Suspend operations that Immediately inoperable, would cause introduction into the RCS, coolant with OR boron concentration less than required to meet No RHR loop in operation. SDM of LCO 3.1.1.

AND B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-15 Amendment No.

to TXX-02201 Page 10 of 19 RCS Loops-MODE 5, Loops Not Filled 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops -MODE 5, Loops Not Filled LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and one RHR loop shall be in operation.

k IY1I'

'I -------------------------------------------

1. All RHR pumps may be removed from operation for E11 hour provided:

a. The core outlet temperature is maintained at least 10OF below saturation temperature.

b. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

c. No draining operations to further reduce the RCS water volume are permitted.

2. One RHR loop may be inoperable for El 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided that the other RHR loop is OPERABLE and in operation.

APPLICABILITY: MODE 5 with RCS loops not filled

NOTE While this LCO is not met, entry into MODE 5, Loops Not Filled from MODE 5, Loops filled is not permitted.

COMANCHE PEAK - UNITS 1 AND 2 3.4-17 Amendment No.

to TXX-02201 Page 11 of 19 RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore Immediately RHR loop to OPERABLE status.

B. Required RHR loops B.1 Suspend operations that Immediately inoperable, would cause introduction into the RCS, coolant with OR boron concentration less than required to meet No RHR loop in operation. SDM of LCO 3.1.1.

AND B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.8.2 Verify correct breaker alignment and indicated power are 7 days available to the required RHR pump that is not in operation.

COMANCHE PEAK - UNITS 1 AND 2 3.4-18 Amendment No.

to TXX-02201 Page 12 of 19 AC Sources - Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit -NOTE T E......

inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with the required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.4 Initiate action to restore Immediately required offsite power circuit to OPERABLE status.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-18 Amendment No.

to TXX-02201 Page 13 of 19 AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG B.1 Suspend CORE Immediately inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated fuel assemblies.

AND B.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.4 Initiate action to restore Immediately required DG to OPERABLE status.

COMANCHE PEAK - UNITS 1 AND 2 3.8-19 Amendment No.

to TXX-02201 Page 14 of 19 DC Sources-- Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources D1Shutdown LCO 3.8.5 The Train A or Train B DC electrical power subsystem shall be OPERABLE to support one train of the DC electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems El Shutdown."

APPLICABILITY: MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required DC electrical A.1 Declare affected required Immediately power subsystems feature(s) inoperable.

inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-28 Amendment No.

to TXX-02201 Page 15 of 19 Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 The train A or Train B inverters shall be OPERABLE to support one train of the onsite Class 1 E AC vital bus electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems [I Shutdown."

APPLICABILITY: MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected required Immediately inverters inoperable. feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-36 Amendment No.

to TXX-02201 Page 16 of 19 Distribution Systems-- Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems- Shutdown LCO 3.8.10 The necessary portion of the Train A or Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support one train of equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC, A.1 Declare associated Immediately DC, or AC vital bus supported required electrical power distribution feature(s) inoperable.

subsystems inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-40 Amendment No.

to TXX-02201 Page 17 of 19 Nuclear Instrumentation 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Nuclear Instrumentation LCO 3.9.3 Two source range neutron flux monitors shall be OPERABLE.

APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required source range A.1 Suspend CORE Immediately neutron flux monitor ALTERATIONS.

inoperable.

AND A.2 Suspend operations that Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

B. Two required source range B.1 Initiate action to restore Immediately neutron flux monitors one source range neutron inoperable. flux monitor to OPERABLE status.

AND B.2 Perform SR 3.9.1.1. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months COMANCHE PEAK - UNITS 1 AND 2 3.9-5 Amendment No.

to TXX-02201 Page 18 of 19 RHR and Coolant Circulation - High Water Level I 66 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation High Water Level LCO 3.9.5 One RHR loop shall be OPERABLE and in operation.

--- --- --- --- --- --- I'%,I

I' -

The required RHR loop may be removed from operation for < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided no operations are permitted that would cause introduction into the Reactor Coolant System, coolant with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1.

APPLICABILITY: MODE 6 with the water level Ž 23 ft above the top of reactor vessel flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RHR loop requirements not A.1 Suspend operations that Immediately met. would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

AND A.2 Suspend loading irradiated fuel assemblies Immediately in the core.

AND (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.9-9 Amendment No.

to TXX-02201 Page 19 of 19 RHR and Coolant Circulation- Low Water Level 3.9.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR loop in operation. B.1 Suspend operations that Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

AND B.2 Initiate action to restore 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months one RHR loop to operation.

AND B.3 Close all containment penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of > 1000 gpm.

SR 3.9.6.2 Verify correct breaker alignment and indicated power 7 days available to the required RHR pump that is not in operation.

COMANCHE PEAK - UNITS 1 AND 2 3.9-12 Amendment No.

ATTTACHMENT 5 TO TXX-02201 RETYPED TECHNICAL SPECIFICATION BASES PAGES (FOR INFORMATION ONLY)

PAGES B 3.3-44 B 3.3-45 B 3.3-46 B 3.4-25 B 3.4-27 B 3.4-30 B 3.4-32 B 3.4-36 B 3.4-38 B 3.4-41 B 3.4-42 B 3.8-35 B 3.8-58 B 3.8-75 B 3.8-89 B 3.9-4 B 3.9-10 B 3.9-11 B 3.9-19 B 3.9-20 B 3.9-24 to TXX-02201 Page 2 of 22 RTS Instrumentation B 3.3.1 BASES ACTIONS G.1 and G.2 (continued)

Condition G applies to two inoperable Intermediate Range Neutron Flux trip channels in MODE 2 when THERMAL POWER is above the P-6 setpoint and below the P-1 0 setpoint. Required Actions specified in this Condition are only applicable when channel failures do not result in reactor trip. Above the P-6 setpoint and below the P-1 0 setpoint, the NIS intermediate range detector performs the monitoring Functions. With no intermediate range channels OPERABLE, the Required Actions are to suspend operations involving positive reactivity additions immediately.

This action will preclude any power level increase since there are no OPERABLE Intermediate Range Neutron Flux channels. The operator must also reduce THERMAL POWER below the P-6 setpoint within two hours. This action may require the use of the NIS source range channels or the neutron flux channels discussed in LCO 3.3.3, with action to reduce power below the count rate equivalent to the P-6 setpoint.

Below P-6, the Source Range Neutron Flux channels will be able to monitor the core power level. The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will allow a slow and controlled power reduction to less than the P-6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip.

Required Action G.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g.,

temperature or boron concentration fluctuations associated with RCS inventory or chemistry management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met and the requirements of LCOs 3.1.5, 3.1.6, and 3.4.2 are met.

H.1 Not Used.

1.1 Condition I applies to one inoperable Source Range Neutron Flux trip channel when in MODE 2, below the P-6 setpoint. With the unit in this Condition, the NIS source range performs the monitoring and protection (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-44 Revision to TXX-02201 Page 3 of 22 RTS Instrumentation B 3.3.1 BASES ACTIONS 1.1 (continued) functions. With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.

This action will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.

Required Action 1.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (e.g.,

temperature or boron concentration fluctuations associated with RCS inventory or chemistry management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met, the requirements of LCOs 3.1.5, 3.1.6, and 3.4.2 are met, and the initial and critical boron concentration assumptions in FSAR Section 15 are satisfied.

J. 1 Condition J applies to two inoperable Source Range Neutron Flux trip channels when in MODE 2, below the P-6 setpoint, or in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, the NIS source range performs the protection functions. With both source range channels inoperable, the RTBs must be opened immediately. With the RTBs open, the core is in a more stable condition.

K.1, K.2.1 and K.2.2 Condition K applies to one inoperable source range channel in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, the NIS source range performs the protection functions. With one of the source range channels inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to restore it to an OPERABLE status. If the channel cannot be returned to an OPERABLE status, action must be initiated within the same 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to fully insert all rods. 1 additional hour is allowed to fully insert all rods and place the Rod Control System in a condition incapable of rod withdrawal (e.g., by de energizing all CRDMs, by opening the RTBs, or de-energizing the motor generator (MG) sets). Once these ACTIONS are completed, the core is in a more stable condition. The allowance of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-45 Revision to TXX-02201 Page 4 of 22 RTS Instrumentation B 3.3.1 BASES ACTIONS K.1, K.2.1 and K.2.2 (continued) channel to OPERABLE status, and the additional hour to place the Rod Control System in a condition incapable of rod withdrawal, are justified in Reference 5. Normal plant control operations that individually add limited positive reactivity (i.e., temperature or boron concentration fluctuations associated with RCS inventory or chemistry management or temperature control) are permitted provided the ADM limits specified in the COLR are met and the initial and critical boron concentration assumptions in FSAR Section 15 are satisfied.

L.1 Not Used.

MA and M.2 Condition M applies to the following reactor trip Functions:

Pressurizer Pressure-Low; Pressurizer Water Level-High; Reactor Coolant Flow-Low; Undervoltage RCPs; and Underfrequency RCPs.

With one channel inoperable, the inoperable channel must be placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . For the Pressrizer Pressure - Low, Pressurizer Water Level - High, Undervotage RCPs, and Underfrequency RCPs trip Functions, placing the channel in the tripped condition when above the P-7 setpoint results in a partial trip condition requiring only one additional channel to initiate a reactor trip. For the Reactor Coolant Flow Low trip Function, placing the channel in the tripped condition when above the P-8 setpoint results in a partial trip condition requiring only one additional channel in the same loop to initiate a reactor trip. Two tripped channels in two RCS loops are required to initiate a reactor trip when below the P-8 setpoint and above the P-7 setpoint. These Functions do not have to be OPERABLE below the P-7 setpoint because there are no loss of flow trips below the P-7 setpoint. There is insufficient heat (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-46 Revision to TXX-02201 Page 5 of 22 RCS Loops -MODE 3 B 3.4.5 BASES LCO is validation of the pump coastdown curve used as input to a number of (continued) accident analyses including a loss of flow accident. This test is generally performed in MODE 3 during the initial startup testing program, and as such should only be performed once. If, however, changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values of the coastdown curve must be revalidated by conducting the test again.

Utilization of the Note is permitted provided the following conditions are met, along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron dilution with coolant at boron concentrations less than required to assure the SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

b. Core outlet temperature is maintained at least 1 0°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

An OPERABLE RCS loop consists of one OPERABLE RCP and one OPERABLE SG in accordance with the Steam Generator Tube Surveillance Program, which has the minimum water level specified in SR 3.4.5.2. An RCP is OPERABLE if it is capable of being powered and is able to provide forced flow if required.

APPLICABILITY In MODE 3, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing.

The most stringent condition of the LCO, that is, two RCS loops OPERABLE and two RCS loops in operation, applies to MODE 3 with Rod Control System capable of rod withdrawal. The least stringent condition, that is, two RCS loops OPERABLE and one RCS loop in operation, applies to MODE 3 with the Rod Control System not capable of rod withdrawal.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-25 Revision to TXX-02201 Page 6 of 22 RCS Loops-- MODE 4 B 3.4.6 BASES ACTIONS C.1 and C.2 (continued)

If the required RCS loop is not in operation, and the Rod Control System is capable of rod withdrawal, the Required Action is either to restore the required RCS loop to operation or to place the Rod Control System in a condition incapable of rod withdrawal (e.g., de-energize all CRDMs by opening the RTBs or de-energizing the motor generator (MG) sets).

When the Rod Control System is capable of rod withdrawal, it is postulated that a power excursion could occur in the event of an inadvertent control rod withdrawal. This mandates having the heat transfer capacity of two RCS loops in operation. If only one loop is in operation, the Rod Control System must be in a condition incapable of rod withdrawal. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the required RCS loop to operation or render the Rod Control System incapable of rod withdrawal is adequate to perform these operations in an orderly manner without exposing the unit to risk for an undue time period.

D.1, D.2, and D.3 If four RCS loops are inoperable or no RCS loop is in operation, except as during conditions permitted by the Note in the LCO section, place the Rod Control System in a condition incapable of rod withdrawal (e.g., all CRDMs must be de-energized by opening the RTBs or de-energizing the MG sets). All operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and opening the RTBs or de-energizing the MG sets removes the possibility of an inadvertent rod withdrawal. Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3,1,1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations. The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-27 Revision to TXX-02201 Page 7 of 22 RCS Loops -MODE 4 B 3.4.6 BASES (continued)

LCO The purpose of this LCO is to require that at least two loops be OPERABLE in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. Any one loop in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide redundancy for heat removal.

Note 1 permits all RCPs or RHR pumps to be removed from operation for El1 hour per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to permit tests that are required to be performed without flow or pump noise. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time period is adequate to perform the test, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron dilution with coolant at boron concentrations less than required to assure the SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

b. Core outlet temperature is maintained at least 10 DF below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 requires that the secondary side water temperature of each SG be

< 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature < 350°F. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-30 Revision to TXX-02201 Page 8 of 22 RCS Loops -MODE 4 B 3.4.6 BASES ACTIONS A.1 and A.2 (continued)

If one required RHR loop is OPERABLE and in operation and there are no RCS loops OPERABLE, an inoperable RCS or RHR loop must be restored to OPERABLE status to provide a redundant means for decay heat removal.

If the parameters that are outside the limits cannot be restored, the unit must be brought to MODE 5 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Bringing the unit to MODE 5 is a conservative action with regard to decay heat removal.

With only one RHR loop OPERABLE, redundancy for decay heat removal is lost and, in the event of a loss of the remaining RHR loop, it would be safer to initiate that loss from MODE 5 (< 200 0 F) rather than MODE 4 (200 to 350 0 F). The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable time, based on operating experience, to reach MODE 5 from MODE 4 in an orderly manner and without challenging plant systems.

B.1 and B.2 If no loop is OPERABLE or in operation, except during conditions permitted by Note 1 in the LCO section, all operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing, and the margin to criticality must not be reduced in this type of operation. Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. The action to restore must be continued until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one RCS or RHR loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS and RHR loop performance.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-32 Revision to TXX-02201 Page 9 of 22 RCS Loops -MODE 5, Loops Filled B 3.4.7 BASES LCO Utilization of Note 1 is permitted provided the following conditions are (continued) met, along with any other conditions imposed by test procedures:

a. No operations are permitted that would dilute the RCS boron concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the margin to criticality. Boron dilution with coolant at boron concentrations less than required to assure the SDM is maintained is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

b. Core outlet temperature is maintained at least 1 0°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 allows one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.

Note 3 requires that the secondary side water temperature of each SG be

< 50°F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with an RCS cold leg temperature < 350 0 F.

This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE ifthey are capable of being powered and are able to provide flow if required. An OPERABLE SG can perform as a heat sink via natural circulation when it has an adequate water level and is OPERABLE in accordance with the Steam Generator Tube Surveillance Program.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-36 Revision to TXX-02201 Page 10 of 22 RCS Loops -MODE 5, Loops Filled B 3.4.7 BASES ACTIONS B.1 and B.2 (continued)

If no RHR loop is in operation, except during conditions permitted by Notes 1 and 4, or if no loop is OPERABLE, all operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. To prevent inadvertent criticality during a boron dilution, forced circulation from at least one RCP is required to provide proper mixing and preserve the margin to criticality in this type of operation.

Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

The immediate Completion Times reflect the importance of maintaining operation for heat removal.

SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loop is in operation. Verification may include flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.7.2 Verifying that at least two SGs are OPERABLE by ensuring their secondary side narrow range water levels are > 10% ensures an alternate decay heat removal method via natural circulation in the event that the second RHR loop is not OPERABLE. If both RHR loops are OPERABLE, this Surveillance is not needed. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-38 Revision to TXX-02201 Page 11 of 22 RCS Loops- MODE 5, Loops Not Filled B 3.4.8 BASES (continued)

LCO Note 1 permits all RHR pumps to be removed from operation for (continued) < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The circumstances for stopping both RHR pumps are to be limited to situations when the outage time is short and core outlet temperature is maintained at least 1 00 F below saturation temperature.

The Note prohibits boron dilution with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1 is maintained or draining operations when RHR forced flow is stopped.

Note 2 allows one RHR loop to be inoperable for a period of

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System. The Applicability is modified by a Note stating that entry into MODE 5 Loops Not Filled from MODE 5 Loops Filled is not permitted while LCO 3.4.8 is not met. This Note specifies an exception to LCO 3.0.4 and would prevent draining the RCS, which would eliminate the possibility of SG heat removal, while the RHR function was degraded.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops--MODES 1 and 2";

LCO 3.4.5, "RCS Loops -MODE 3";

LCO 3.4.6, "RCS Loops -MODE 4";

LCO 3.4.7, "RCS Loops -MODE 5, Loops Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation Low Water Level" (MODE 6).

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-41 Revision to TXX-02201 Page 12 of 22 RCS Loops -MODE 5, Loops Not Filled B 3.4.8 BASES (continued)

ACTIONS A.1 If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2 If no required RHR loops are OPERABLE or in operation, except during conditions permitted by Note 1, all operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation. Boron dilution requires forced circulation for uniform dilution, and the margin to criticality must not be reduced in this type of operation.

Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

The immediate Completion Time reflects the importance of maintaining operation for heat removal. The action to restore must continue until one loop is restored to OPERABLE status and operation.

SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one loop is in operation.

Verification may include flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to monitor RHR loop performance.

SR 3.4.8.2 Verification that the required number of pumps are OPERABLE ensures that additional pumps can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-42 Revision to TXX-02201 Page 13 of 22 AC Sources-Shutdown B 3.8.2 BASES ACTIONS A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 (continued)

With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to the required ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the off site circuit, whether or not a train is de-energized. LCO 3.8.10 would provide the appropriate restrictions for the situation involving a de-energized train.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-35 Revision to TXX-02201 Page 14 of 22 DC Sources -Shutdown B 3.8.5 BASES LCO function(s) (implicitly required by the definition of OPERABILITY).

(continued) Otherwise, the supported components must be declared inoperable and the appropriate conditions of the LCOs for the redundant components must be entered.

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Required features needed to mitigate a fuel handling accident are available;

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-58 Revision to TXX-02201 Page 15 of 22 Inverters - Shutdown B 3.8.8 BASES (continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage output ensures that the required power is available for the instrumentation connected to the AC vital buses. The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES 1. FSAR, Chapter 6.

2. FSAR, Chapter 15.

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-75 Revision to TXX-02201 Page 16 of 22 Distribution Systems- Shutdown B 3.8.10 BASES (continued)

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, DC, and AC vital bus electrical power distribution subsystems requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS A.1, A.2.1, A.2.2. A.2.3. A.2.4. and A.2.5 By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

(continued)

COMANCHE PEAK- UNITS 1 AND 2 B 3.8-89 Revision to TXX-02201 Page 17 of 22 Boron Concentration B 3.9.1 BASES ACTIONS A.1 and A.2 (continued)