CPSES-200300095, (CPSES) - License Amendment Request (LAR) 03-01, Revision to Technical Specification (TS) Bases

From kanterella
Jump to navigation Jump to search
(CPSES) - License Amendment Request (LAR) 03-01, Revision to Technical Specification (TS) Bases
ML030710322
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/06/2003
From: Terry C, Walker R
TXU Energy, TXU Generation Co, LP
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
00236, CAW-03-1598, CPSES-200300095, LAR 03-01, TXX-03012, WPT-16357, WPT-16412
Download: ML030710322 (32)
v • d • e


Text

SATXU 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 corn CPSES-200300095 Log # TXX-03012 File # 00236 March 6, 2003 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) 03-01 REVISION TO TECHNICAL SPECIFICATION (TS) BASES Gentlemen:

Pursuant to 10CFR50.90, TXU Generation Company LP (TXU Energy) hereby transmits a request for NRC review and approval of our application of WCAP-14036 P-A, "Elimination of Periodic Protection Channel Response Time Tests", Revision 1 dated October 1998 for Comanche Peak Steam Electric Station (CPSES) Unit 1 and Unit 2. This request applies to both units.

The CPSES Technical Specifications (TS) Section 1.1 "Definitions" for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time require NRC review and approval of any methodology used to allocate response times in lieu of measuring them. NRC review and approval of our application of WCAP 14036-P-A, Revision 1 will allow the use of allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time for CPSES Units 1 and 2. The methodology described in WCAP 14036-P-A, "Elimination of Periodic Protection Channel Response Time Tests",

Revision 1 was accepted by the NRC staff for reference in license amendment applications in their Safety Evaluation dated October 6, 1998 (SE page 9 revised by NRC on November 3, 1998) and traveler TSTF-1 11, Revision 6.

Attachment 1 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 TS Bases pages marked-up to reflect the proposed changes. Attachment 3 provides retyped TS Bases which incorporate the requested changes. These changes A member of the STARS (Strategic Teaming and Resource Sharing) Alliance `DQ31 Callaway - Comanche Peak

  • Diablo Canyon - Palo Verde
  • Wolf Creek

STXU TXX-03012 Page 2 of 3 will be processed per CPSES site procedures. Attachment 4 provides marked-up pages of the Final Safety Analysis Report (FSAR) (for information only) to reflect the proposed changes to the FSAR.

Enclosed are:

1. 4 copies of Westinghouse Proprietary Letter WPT-16357, "Evaluation of 11 NLP and 6 NSA 7300 Cards" (Enclosure 1)
2. 2 copies of Westinghouse Proprietary Drawing 1061E26, Sheet 1, Rev. B and Sheet 2, Rev. -, "Printed Wiring Assembly Ppower Range Amplifier 414 NI Subassembly", dated 11/22/91. (Enclosure 2)

Also enclosed are a Westinghouse authorization letter, CAW-03-1598, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As items 1 and 2 contain information proprietary to Westinghouse Electric Company, it is supported by an affidavit signed by Westinghouse, the owner of the information.

The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-03-1598 and should be addressed to H. A. Sepp, Manager of Regulatory and Licensing Engineering, Westinghouse Electric Company, P. 0. Box 355, Pittsburgh, Pennsylvania 15230-0355.

TXU Energy requests approval of the proposed application of WCAP-14036-P-A, Revision 1 by August 1, 2003, to be implemented within 60 days of approval, in order to eliminate the need to complete related testing activities prior to the start of the fall refueling outage. The approval date was administratively selected to allow for NRC review, but the plant does not require this amendment to allow continued safe full power operation.

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. Robert A. Slough at (254) 897 5727

STXU TXX-03012 Page 3 of 3 I state under penalty of perjury that the foregoing is true and correct.

Executed on March 5, 2003 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:

RoK4 D. ýValker Regulatory Affairs Manager RAS/gp Attachments 1. Description and Assessment

2. Markup of Technical Specifications Bases pages
3. Retyped Technical Specification Bases Pages
4. Proposed FSAR changes (for information)

Enclosures 1. 4 copies of Westinghouse Proprietary Letter WPT-16357, "Evaluation of 11NLP and 6NSA 7300 Cards". Madison, PA; August 22, 2002.

2. 2 copies of Westinghouse Proprietary Drawing 1061E26, Sheet 1, Rev. B and Sheet 2, Rev. - , "Printed Wiring Assembly Ppower Range Amplifier 414 NI Subassembly", dated 11/22/91.
3. Westinghouse authorization letter, CAW-03-1958, accompanying affidavit, Proprietary Information Notice, and Copyright Notice.

c - E. W. Merschoff, Region IV U/'oc- Mr. Authur C. Tate W. D. Johnson, Region IV "A/* enc. Bureau of Radiation Control D. H. Jaffe, NRR ,/o w/Iel. Texas Department of Public Health Resident Inspectors, CPSES ,/ .,,i 1100 West 49th Street Austin, Texas 78704 W/1 e /d/,

Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Mr. C. L. Terry, Senior Vice President Direct tel (724) 722-5490 and Principal Nuclear Officer Direct fax" (724) 722-5166 Nuclear Production e-mail wybleljs@westinghouse.com TXU Generation Company LP P.O. Box 1002 Glen Rose, Texas 76043 WPT-16412 Attention: R. Slough February 10, 2003 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 & 2 Transmittal of Proprietary Documents to the U.S. Nuclear Regulatory Commission

Dear Mr. Terry:

The following documents were previously transmitted to Comanche Peak:

Westinghouse Proprietary Letter WPT-16357, "Evaluation of 11 NLP and 6 NSA 7300 Cards" S Westinghouse Proprietary Drawing 1061 E26, Sheet 1, Rev. B, and Sheet 2, Rev. -, "Printed Wiring Assembly Power Range Amplifier 414 NI Subassembly" The above documents can be used for your submittal to the NRC for review and approval. Westinghouse Drawing 1061E26, Sheet 1, Rev. B, and Sheet 2, Rev -, "Printed Wiring Assembly Power Range Amplifier 414 NI Subassembly" are Westinghouse Proprietary Class 2 documents and should be so marked before being submitted to the NRC.

Attached are four enclosures for your use:

1. Information which should be included in your NRC transmittal letter.
2. Proprietary Information Notice to be attached to your NRC transmittal letter.
3. Copyright Notice to be attached to your NRC transmittal letter.
4. Westinghouse letter, "Application for Withholding Proprietary Information from Public Disclosure" (CAW-03-1598) with Affidavit CAW-03-1598.

Official record electronically approved in EDMS 2000 A BNFL Group company

WPT-16412 Please transmit the original of Item 4 to the NRC in your transmittal.

If you have any questions, please do not hesitate to contact-us.

Very truly yours, J. S. Wyble, Manager Comanche Peak Project Enclosures cc: C. L. Terry 1L, 1A J. Kelley 1L, 1A M. R. Blevins IL, IA S. Smith 1L, IA R. Flores IL, 1A M. R. Killgore 1L, 1A D. Moore 1L, 1A W. G. Choe 1L, IA R. Slough 1L, 1A (original attachment)

VETIP Coordinator E02 1L, 1A CCG 006A IL, IA A BNFL Group company

Westinghouse Electric Company OWestinghouse Nuclear Services P.O. Box 355 Pittsburgh. Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-5282 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: Sepplha@westinghouse.com Our ret CAW-03-1598 February 10, 2003 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Subject. Transmittal of Westinghouse Proprietary Class 2 Documents:

"* Westinghouse Proprietary Letter WPT-16357, "Evaluation of 11 NLP and 6 NSA 7300 Cards"

"* Westinghouse Proprietary Drawing 1061E26, Sheet 1, Rev. B, and Sheet 2, Rev. -, "Printed Wiring Assembly Power Range Amplifier 414 NI Subassembly" The proprietary information for which withholding is being requested in the above-referenced letter and drawing is further identified in Affidavit CAW-03-1598 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.790 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by TXU Energy.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-03-1598 and should be addressed to the undersigned.

Very truly yours, H. A. Sepp, M&arager Regulatory and Licensing Engineering Enclosures cc. S. J. Collins G. Shukla/NRR A BNFL Group company

CAW-03-1598 bcc: H. A. Sepp (ECE 4-7A) IL, IA R. Bastien, IL, LA (Nivelles, Belgium)

L. Ulloa (Madrid, Spain) IL, 1A C. Brinkman, 1L, IA (Westinghouse Electric Co, 12300 Twinbrook Parkway, Suite 330, Rockville, MD 20852)

RLE Administrative Aide (ECE 4-7A) IL, 1A (letters wlaffidavits only)

A BNFL Group company

CAW-03-1598 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared H. A. Sepp, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse"), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

H. A. Sepp, Manager Regulatory and Licensing Engineering Sworn to and subscribed before me this 10 .' day of Notarial Seal Lorraine M. Piplica, Notary Public Monroeville Boro, Allegheny County My Commission Expires Dec. 14, 2003 Member, Pennsylvania Association at Notanes

2 CAW-03-1598 (1) I am Manager, Regulatory and Licensing Engineering, in Nuclear Services, Westinghouse Electric Company LLC ("Westinghouse"), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Electric Company LLC.

(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by the Westinghouse Electric Company LLC in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-03-1598 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-03-1598 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is 1) Westinghouse Proprietary Letter WPT-16357, "Evaluation of 11 NLP and 6 NSA 7300 Cards" and

2) Westinghouse Proprietary Drawing 1061E26, Sheet 1, Rev. B, and Sheet 2, Rev. -,

"Printed Wiring Assembly Power Range Amplifier 414 NI Subassembly" for submittal to the Commission, being transmitted by TXU Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk.

This information is part of that which will enable Westinghouse to:

(a) Provide or endorse documentation in support of methods for the elimination of protection channel response time testing requirements.

5 CAW-03-1598 (b) Provide the applicable engineering evaluation and/or failure modes and effects analysis, which establishes justification for response time testing elimination of protection channel response time testing Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purposes of the elimination of response time testing requirements.

(b) Westinghouse can sell support and defense of the methodology in the licensing process.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar methodologies and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

CAW-03-1598 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary versions of documents furnished to the NRC in connection with requests for plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

CAW-03-1598 COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

TXU Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

1. 4 copies of Westinghouse Proprietary Letter WPT-16357, "Evaluation of 11 NLP and 6 NSA 7300 Cards"
2. 2 copies of Westinghouse Proprietary Drawing 1061E26, Sheet 1, Rev. B, and Sheet 2, Rev. -,

"Printed Wiring Assembly Power Range Amplifier 414 NI Subassembly", dated 11/22/91 Also enclosed are a Westinghouse authorization letter, CAW-03-1598, accompanying affidavit, Proprietary Information Notice, and Copyright Notice.

As Items 1 and 2 contain information proprietary to Westinghouse Electric Company, it is supported by an affidavit signed by Westinghouse, the owner of the information The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.790 of the Commission's regulations Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-03-1598 and should be addressed to H. A. Sepp, Manager of Regulatory and Licensing Engineering, Westinghouse Electric Company, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

ATTACHMENT 1 to TXX-03012 DESCRIPTION AND ASSESSMENT to TXX-03012 Page 1 of 8 LICENSEE'S EVALUATION

1. DESCRIPTION
2. PROPOSED CHANGE
3. BACKGROUND
4. TECHNICAL ANALYSIS
5. REGULATORY SAFETY ANALYSIS 5.1. No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria
6. ENVIRONMENTAL CONSIDERATION
7. REFERENCES to TXX-03012 Page 2 of 8

1.0 DESCRIPTION

By this letter, TXU Generation Company LP (TXU Energy) requests NRC review and approval of our application of the methodology described in WCAP-14036-P-A, "Elimination of Periodic Protection Channel Response Time Tests", Revision 1 dated October 1998 (Reference 8.1) for Comanche Peak Steam Electric Station (CPSES) Unit 1 and Unit 2 in order to eliminate the requirement to perform periodic response time testing of selected Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) protection channel equipment. Proposed change LAR-03-01 is a request to use allocated signal processing and actuation logic response times in the overall verification of the protection system channel response times for CPSES Units 1 and 2. TXU Energy requests approval by August 1, 2003 in order to support activities for the fall refueling outage.

Attachment 4 provides marked-up pages of the Final Safety Analysis Report (for information only) to reflect the proposed changes to the FSAR.

2.0 PROPOSED CHANGE

The proposed change would revise the Bases for TS 3.3.1 and TS 3.3.2 to indicate that the response time for selected RTS and ESFAS protection channel equipment may be determined using the methodology described, and may be based on, the analysis presented in Reference 8.1 for these systems. The Bases for TS 3.3.1 and 3.3.2 would be revised to include WCAP-14036-P-A, Revision 1 on TS Bases pages B 3.3-63 and B 3.3 119. These Bases changes have been generically approved by the NRC in their Safety Evaluation for WCAP-14036-P-A, Revision 1, dated October 6, 1998 (SE page 9 revised by NRC on November 3, 1998) and traveler TSTF-111, Revision 6.

3.0 BACKGROUND

On January 22, 1998, the WOG submitted proprietary topical report WCAP-14036, "Elimination of Periodic Protection Channel Response Time Tests", Revision 1 dated December 1995. This WCAP report provided a description of a WOG program to eliminate response time testing (RTT) requirements for selected RTS and ESFAS protection channel equipment based on the results of a Failure Modes and Effects Analysis (FMEA) in combination with data from actual tests of the circuitry. This analysis and testing showed that component failures will result in either a limited response failure or in a failure time which is detectable via routine surveillance or calibration other than RTT.

The NRC staff has reviewed WCAP-14036-P-A, "Elimination of Periodic Protection Channel Response Time Tests", Revision 1. The NRC staff s Safety Evaluation Report (SER) (Reference 8.4) approved WCAP-14036-P-A, Revision 1 for reference in plant specific license amendment requests. The staff required that licensees referencing WCAP-14036-P-A, Revision 1 in plant specific TS change amendment requests to eliminate RTT requirements for selected RTS and ESFAS protection channel equipment should:

to TXX-03012 Page 3 of 8

1. Verify that the FMEA performed by the WOG is applicable to the equipment actually installed in the licensees facility and,
2. Verify that the analysis is valid for the versions of the boards used in the protection system.

4.0 TECHNICAL ANALYSIS

WCAP-14036-P-A, Revision 1 provides the technical justification for deletion of periodic response time testing of the electronic signal processing hardware between the primary sensor and the final actuated device. To support an amendment request, the licensee must verify that the Failure Modes and Effects Analysis (FMEA) in the WCAP is applicable to the equipment actually installed in the facility and that the analysis is valid for the versions of the boards used in the protection system.

Attachment 1 to WOG letter OG-98-086 in Appendix C of the WCAP contains a list of the schematics used for the FMEA that may be used for this verification. WOG letters WOG-98-238 and WOG-98-244 provide methods to comply with this verification requirement. These letters also provide an alternate method of verification for the 7300 system. The alternate method described in WOG-98-238 specified verifying the installed cards used in the 7300 System are 4NCH, 7NRA, 6NLP, 4NSA, and 9NAL or older artwork. This list of cards was incorrect and was subsequently corrected in WOG-98-244 identified the correct list as 7NMD, 4NCH, 4NRA, 6NLP, 4NSA, and 9NAL or older artwork levels.

The CPSES protection system consists of the Westinghouse 7300 System, Solid State Protection System (SSPS), and Nuclear Instrumentation System (NIS). The SSPS and NIS used at CPSES are those identified in the schematics provided in Attachment 1 to WOG letter OG-98-086 in Appendix C of Reference 8.1. Thus, the FMEA is applicable for the SSPS and NIS installed at CPSES Unit 1 and Unit 2.

Reference 8.1 section 4.4 identifies the 7300 System cards that were evaluated in the FMEA. This evaluation concluded that the NMD, NCH, NRA, NLP, NSA, and NAL cards are subject to response time testing. The remaining cards listed in section 4.4 of Reference 8.1 did not require testing because either their only function is to interrupt the protection signal for testing purposes or they have no dynamic response characteristic.

Additionally, section 4.0 excludes 7300 System cards with dynamic functions as their response time is verified during periodic calibrations.

TXU Energy has reviewed the cards installed in the 7300 System at CPSES Units 1 and 2 using the alternate method described in WOG letters WOG-98-238 and WOG-98-244 and, except as noted below, confirmed that the cards used for protection signals are the same card types specified in Reference 8.1 and that they are the specific versions identified in WOG letter WOG-98-244.

to TXX-03012 Page 4 of 8 The review of 7300 System cards used at CPSES identified a newer artwork for the NLP and NSA cards than was identified in letter WOG-98-244. Westinghouse letter WPT 16357 (Reference 8.6) provides the results of an evaluation performed by Westinghouse which demonstrated that the differences in the newer design NLP and NSA cards are insignificant with respect to the conclusions of the original FMEA documented in Reference 8.1 and that the bounding time response values determined by test and reported in Reference 8.1 are also valid for the newer artwork cards. Based on the evaluation documented in Reference 8.6, the FMEA and conclusions presented in Reference 8.1 are applicable to the 11NLP and 6NSA or older artwork. TXU Energy has confirmed that the NLP and NSA cards installed in the 7300 System at CPSES Units 1 and 2 comply with this artwork level requirement.

Due to the unique design of the CPSES N-16 power measurement system, two components were identified that were not included in the study documented in Reference 8.1. These components are the N-16 Power Monitor Module and the Power Range Module. Thus, the FMEA documented in Reference 8.1 is applicable for the 7300 System used at CPSES Units 1 and 2 with the exception of the N-16 Power Monitor Module and Power Range Module.

The Power Monitor Module processes the N-16 detector signal and is subject to time response testing. The Power Range Module provides a power range NIS neutron streaming compensation signal to the N- 16 instrument. For the N- 16 signal, the Power Range Module is not in the N-1 6 protection channel signal path which is subject to response time testing. For the NIS, the Power Range Module is in the NIS signal path which is subject to response time testing, however, the module has no dynamic response characterisics. Therefore it is not necessary to perform time response testing for the Power Range Module.

WCAP-14036-P-A, Revision 1 is applicable for the 7300 System, NIS, and SSPS equipment used at Comanche Peak Units 1 and 2 with the exception of the two unique N-16 components. TXU Energy has reviewed the cards used in the 7300 System at CPSES Units 1 and 2, as outlined in WOG letters WOG-98-238 and WOG-98-244 and, with the noted exceptions, confirmed that they are the same equipment type and versions as those identified in the FMEA used to support the WCAP. Therefore, the conclusion of WCAP-1403 6-P-A, Revision 1 to support elimination of periodic RTT is valid for the systems and equipment installed at CPSES Units 1 and 2 except for the N-16 Power Monitor Module and Power Range Module.

The Power Range Module is not in the N-16 protection signal path which is subject to RTT and, although it is in the signal path for the NIS, it has no dynamic response characteristics in the power range NIS signal path. Periodic demonstration of the actual response time of the Power Monitor Module will continue to be performed.

Attachment I to TXX-03012 Page 5 of 8 5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration TXU Energy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10CFR50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed change does not result in a condition where the design, material, and construction standards that were applicable prior to the change are altered. The same RTS and ESFAS instrumentation are being used and the time response allocations and modeling assumptions in the Chapter 15 safety analysis are unchanged. Only the method of verifying the time response is changed. The proposed change will not modify any system interface and could not increase the likelihood of an accident since these events are independent of this change. The proposed activity will not change, degrade, or prevent actions or alter any assumptions previously made in evaluating the radiological consequences of an accident described in the FSAR. Therefore, the proposed change does 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 The proposed change does not alter the performance of the process protection racks, the nuclear instrumentation, or the logic systems used in the plant protection systems. Periodic surveillance of these systems will continue and may be used to detect degradation that could cause the response time characteristics to exceed the total allowance. Changing the method of periodically verifying instrument response for these systems from response time testing to calibration and channel checks will not create any new accident initiators or scenarios. Periodic surveillance of these systems will continue and may be used to detect degradation that could cause the response time characteristic to exceed the total allowance. The total time response allowance for each function bounds all degradation that cannot be detected by periodic surveillance. Therefore, the proposed change does 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?

to TXX-03012 Page 6 of 8 Response: No The proposed change does not affect the total system response time assumed in the safety analysis. The periodic response time verification method for the Process protection racks, the nuclear instrumentation and the logic systems is modified to allow the use of actual test data or engineering data. The method of verification still provides assurance that the total system response time is within that defined in the safety analysis, since calibration tests will continue to be performed and may be used to detect any degradation which might cause the response time to exceed the total allowance. The total response time allowance for each function bounds all degradation that cannot be detected by periodic surveillance. Therefore the proposed change does not involve a reduction in a margin of safety.

Based on the above evaluations, TXU Energy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10CFR50.92(c) and, accordingly, a finding of"no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria The requirement for periodic testing of reactor trip and protection systems is established in 10CFR Part 50.55a paragraph (h), "Protection systems," which states, in part, that

"...protective systems must meet the requirements set forth in editions or revisions of the Institute of Electrical and Electronics Engineering (IEEE) Standard "Criteria for Protective Systems for Nuclear Power Generating Stations," (IEEE-279). In addition, 10CFR50.36 paragraph (c)(1)(ii)(A) requires limiting safety system settings to be included in the TS and to be "so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded." Finally, 10CFR50.36 paragraph (c)(3), "Surveillance requirements," states "Surveillance requirements are requirements related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within the safety limits, and that the limiting conditions of operation will be met."

The current licensing basis for response time testing of the 7300 System, NIS, and SSPS for CPSES Unit 1 and Unit 2 is expressed in FSAR Chapter 7.1.2.5 which references IEEE Standard 279-1971, "Criteria for Protection Systems for Nuclear Power Generating Stations"(Reference 8.2) and in Chapter 7.1.2.11 which endorses IEEE Standard 338 1971, "IEEE Trial-Use Criteriafor the Periodic Testing of Nuclear Power Generating Station Protection Systems" (Reference 8.3) with exceptions. IEEE-279-1971 requires that "A specific protection system design basis shall be provided for each nuclear power generating station....The design basis shall document.. .(9) minimum performance requirements including...(a) system response times..." IEEE-338-1971 does not specify any further requirements concerning response time testing of protection systems.

In 1975, the Nuclear Regulatory Commission (NRC) implemented a program making RTT a requirement of the TS. Consequently, RTT requirements were included in the Westinghouse Standard TS and were required for all Westinghouse plants licensed after to TXX-03012 Page 7 of 8 that date, including CPSES Unit 1 and Unit 2. IEEE Standard 338-1975, "Criteria for the Periodic Surveillance Testing of Class 1E Power and Protection Systems," and its later version IEEE Standard 338-1977, "Criteria for the Periodic Surveillance Testing of Nuclear Power Generating Station Safety Systems," provide generic guidance for the conduct of response time verification tests. The NRC staff endorsed IEEE Standard 338 1977 in Regulatory Guide 1.118, Revision 2, "Periodic Testing of Electric Power and Protection Systems," dated June 1978. Guidance on the performance of RTT is also provided in Instrument Society of America (ISA) Standard ISA-$67.06-1986, "Response Time Testing of Nuclear Safety-Related Instrument Channels in Nuclear Power Plants,"

dated August 29, 1986. ISA-$67.06-1986 has not been endorsed by the NRC staff, but its methodology is widely used.

In conclusion, 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) the 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 10CFR20, or would change an inspection or surveillance requirement.

TXU Energy has evaluated the proposed changes and has determined that the changes do 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

7.1 WCAP-14036-P-A, "Elimination of Periodic Protection Channel Response Time Tests", Revision 1, dated October 6, 1998.

7.2 IEEE Standard 279-1971, "Criteria for Protective Systems for Nuclear Power Generating Stations."

7.3 IEEE Standard 338-1971, "IEEE Trial-Use Criteriafor the Periodic Testing of Nuclear Power Generating Station Protection Systems."

7.4 United States Nuclear Regulatory Commission, Division of Reactor Program Management. "Evaluation of Westinghouse Electric Corporation Topical Report WCAP-14036, Revision 1, Elimination of Periodic Protection Channel Response Time Tests". Washington, D.C. USNRC; 1998.

7.5 United States Nuclear Regulatory Commission, Division of Licensing Project to TXX-03012 Page 8 of 8 Management. "Safety Evaluation by the Office of Nuclear Reactor Regulation Related to WCAP-14036 for Response Time Testing Elimination, Union Electric Company, Callaway Plant, Unit 1 Docket No. 50-483". Washington, D.C.:

USNRC; 2000.

7.6 Westinghouse Electric Company Nuclear Services. WPT-1 6357, "Evaluation of 11NLP and 6NSA 7300 Cards". Madison, PA; August 22, 2002. (Proprietary)

By letter dated December 3, 1999, the Union Electric Company requested NRC approval of its application of the methodology described in Reference 8.1 for the Callaway Plant.

The NRC staff's safety evaluation report (SER) (Reference 8.4) approving this topical report for reference in plant specific license amendment requests was transmitted by letter to Louis F. Liberatori, Jr. (Westinghouse Owner's Group) by Thomas H. Essig (USNRC),

dated October 6, 1998. The NRC staff's safety evaluation report (Reference 8.5) granting approval to apply the methodology described in Reference 8.1 at the Callaway Plant was transmitted by letter to Garry L. Randolph, Vice President and Chief Nuclear Officer (Union Electric Company) by Jack Donohew, Division of Licensing Project Management (USNRC), dated March 3, 2000.

ATTACHMENT 2 to TXX-03012 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)

Pages B 3.3-63 B 3.3-118 B 3.3-119 to TXX-03012 RTS Instrumentation Page 1 of3 B 3.3.1 BASES SURVEILLANCE SR 3.3.1.16 (continued)

REQUIREMENTS testing. Some portions of the response time testing cannot be performed during unit operation because equipment operation is required to measure response times. Experience has shown that these components usually pass this surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. Respo7nstimevei fication inlieu66f a*citual,. 625 te~s~tinga-y b~epepformed on RTS components in accordance with reference10:

SR 3.3.1.16 is modified by a Note stating that neutron and N-16 gamma detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

Response time of the neutron flux or N-16 signal portion of the channel shall be measured from detector output or input to the first electronic component in the channel.

REFERENCES 1. FSAR, Chapter 7.

2. FSAR, Chapter 15.
3. IEEE-279-1971.
4. 10 CFR 50.49.
5. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
6. Technical Requirements Manual.
7. Not Used.
8. Not used.
9. "Westinghouse Setpoint Methodology for Protection Systems Comanche Peak Unit 1, Revision 1," WCAP-12123, Revision 2, April, 1989.

1b ofPrioadi'cProection'Channel Response Time

Elir--irati6r*e 25 Wests", WCAP-1 4036-P-A, Revision*1 October 6, 1998.

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-63 *,,=,,u, F' t *u u Rvisionl 25 to TXX-03012 ESFAS Instrumentation Page 2 of 3 B 3.3.2 BASES SURVEILLANCE SR 3.3.2.10 (continued)

REQUIREMENTS Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be used for selected components provided that the components and methodology for verification have been previously NRC approved.

ESF RESPONSE TIME tests are performed on an 18 month STAGGERED TEST BASIS. The testing shall include at least one train such that both trains are tested at least once per 36 months. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. Therefore, staggered testing results in response time, verification of these devices every 18 months.

The 18 month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.

Rposetime verification in lieu ýo'f 'a~ctiial te'stingm Tayi ,b'e perfor'me on25 ESFAS.comppnents Jn accordance with, reference 10.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 532 psig in the SGs.

SR 3 3.2.11 SR 3.3.2.11 is the performance of a TADOT as described in SR 3.3.2.8, except that it is performed for the P-4 Reactor Trip Interlock. This Frequency is based on operating experience.

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-118 ýr,,,d*,n,,, 'W,,,,-ý,,k -t ev_"sion '25 to TXX-03012 ESFAS Instrumentation Page 3 of 3 B 3.3.2 BASES SURVEILLANCE SR 332.12 REQUIREMENTS (continued) SR 3.3.2.12 is the performance of a CHANNEL CALIBRATION.

A CHANNEL CALIBRATION is performed every 9 months. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology.

The Frequency of 9 months is based on the assumption of an 9 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.

REFERENCES 1. FSAR, Chapter 6.

2. FSAR, Chapter 7.
3. FSAR, Chapter 15.
4. IEEE-279-1971.
5. 10 CFR 50.49.
6. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
7. Technical Requirements Manual.
8. Not used.
9. "Westinghouse Setpoint Methodology for Protection Systems Comanche Peak Unit 1, Revision 1," WCAP-12123, Revision 2, April, 1989.

i!0. 'Ehimination of Perio6dic Protection Channel Respnse T6ime9 25 Tests"i, WCAP-1 4036-P-A,* Revision 1,,October 6, ,1998.".......

COMANCHE PEAK- UNITS 1 AND 2 B 3.3-119 Revision 2+5

ATTACHMENT 3 to TXX-03012 RETYPED TECHNICAL SPECIFICATION BASES PAGES Pages B 3.3-63 B 3.3-118 B 3.3-119 to TXX-03012 RTS Instrumentation Page 1 of 3 B 3.3.1 BASES SURVEILLANCE SR 3 3 1.16 (continued)

REQUIREMENTS testing. Some portions of the response time testing cannot be performed during unit operation because equipment operation is required to measure response times. Experience has shown that these components usually pass this surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. Response time verification in lieu of actual 25 testing may be performed on RTS components in accordance with reference 10.

SR 3.3.1.16 is modified by a Note stating that neutron and N-16 gamma detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

Response time of the neutron flux or N-16 signal portion of the channel shall be measured from detector output or input to the first electronic component in the channel.

REFERENCES 1. FSAR, Chapter 7.

2. FSAR, Chapter 15.
3. IEEE-279-1971.
4. 10 CFR 50.49.
5. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
6. Technical Requirements Manual.
7. Not Used.
8. Not used.
9. "Westinghouse Setpoint Methodology for Protection Systems Comanche Peak Unit 1, Revision 1," WCAP-12123, Revision 2, April, 1989.
10. "Elimination of Periodic Protection Channel Response Time 25 Tests", WCAP-1 4036-P-A, Revision 1, October 6, 1998.

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-63 Revision 25 to TXX-03012 ESFAS Instrumentation Page 2 of 3 B 3.3.2 BASES SURVEILLANCE SR 3.3.2.10 (continued)

REQUIREMENTS Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be used for selected components provided that the components and methodology for verification have been previously NRC approved.

ESF RESPONSE TIME tests are performed on an 18 month STAGGERED TEST BASIS. The testing shall include at least one train such that both trains are tested at least once per 36 months. Testing of the final actuation devices, which make up the bulk of the response time, is included in the testing of each channel. The final actuation device in one train is tested with each channel. Therefore, staggered testing results in response time verification of these devices every 18 months.

The 18 month Frequency is consistent with the typical refueling cycle and is based on unit operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences.

Response time verification in lieu of actual testing may be performed onI 25 ESFAS components in accordance with reference 10.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 532 psig in the SGs.

SR 3.3.2.11 SR 3.3.2.11 is the performance of a TADOT as described in SR 3.3.2.8, except that it is performed for the P-4 Reactor Trip Interlock. This Frequency is based on operating experience.

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-118 Revision 25 to TXX-03012 ESFAS Instrumentation Page 3 of 3 B 3.3.2 BASES SURVEILLANCE SR 3.3 2.12 REQUIREMENTS (continued) SR 3.3.2.12 is the performance of a CHANNEL CALIBRATION.

A CHANNEL CALIBRATION is performed every 9 months. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology.

The Frequency of 9 months is based on the assumption of an 9 month calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology.

REFERENCES 1. FSAR, Chapter 6.

2. FSAR, Chapter 7.
3. FSAR, Chapter 15.
4. IEEE-279-1971.
5. 10 CFR 50.49.
6. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.
7. Technical Requirements Manual.
8. Not used.
9. "Westinghouse Setpoint Methodology for Protection Systems Comanche Peak Unit 1, Revision 1," WCAP-12123, Revision 2, April, 1989.

1 25

10. "Elimination of Periodic Protection Channel Response Time Tests", WCAP-1 4036-P-A, Revision 1, October 6, 1998.

COMANCHE PEAK- UNITS I AND 2 B 3.3-119 Revision 25

Retrieved from "https://kanterella.com/w/index.php?title=CPSES-200300095,_(CPSES)_-_License_Amendment_Request_(LAR)_03-01,_Revision_to_Technical_Specification_(TS)_Bases&oldid=2670739"