ML021140101

Attachment 10, E-Mailed on April 10, 2002 (Docket Nos. 50-445 and 50-446). Draft RAI Response for LAR 01-008

ML021140101
Person / Time
Site:	Comanche Peak
Issue date:	04/10/2002
From:	Slough R TXU Electric
To:	Jaffe D NRC/NRR/DLPM
References
LAR 01-008
Download: ML021140101 (11)

Text

C:\WINDOWS\TEMP\GW}O000 .TMP Page 1 Mail Envelope Properties (3CB43A9B.ACB : 8: 39627)

Subject:

Draft RAI Response for LAR 01-008 Creation Date: 4/10/02 9:14AM From: <rsloughl @txu.com>

Created By: rsloughl@txu.com Recipients nrc.gov owf4_po.OWFN_DO DHJ (David Jaffe) txu.com DennisBuschbaum/CPSES/Texas Utilities C Post Office Route owf4_po.OWFNDO nrc.gov txu.com Files Size Date & Time MESSAGE 436 04/10/02 09:14AM TXX02073.pdf 69572 Mime.822 97494 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard Attachment 10

iDavid Jaffe - Draft RAI Response for LAR 01-008 DRPage 1 From: <rsloughl@txu.com>

To: <dhj@nrc.gov>

Date: 4/10/02 9:14AM

Subject:

Draft RAI Response for LAR 01-008 Mr. Jaffe, Attached is a draft of the letter responding to the RAI and revised TS Bases pages. The letter is dated April 12, however I expect the letter will be signed today, in which case the date will be changed. When the letter is signed and mailed, I will e-mail you the final copy containing a signature.

If you or Keith have any further questions, please call me.

Thanks, Rob Slough (See attached file: TXX02073.pdf)

CC: <Den nisBuschbaum/CPSES/TexasUtilities@txu.com>, <rsloughl@txu.com>

Ref: 10CFR50.90 CPSES-200201164 Log # TXX-02073 File # 00236 April 12, 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 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION TO LICENSE AMENDMENT REQUEST (LAR) 01-008: REVISION TO TECHNICAL SPECIFICATION (TS) 3.3.2. ESFAS INSTRUMENTATION AND 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION (TAC NO. 2810)

REF: TXU Electric Letter logged TXX-01092, from C. L. Terry to the NRC dated August 24, 2001 Gentlemen:

Pursuant to 10CFR50.90, TXU Generation Company LP (TXU Energy) requested, via Reference, an amendment to the CPSES Unit I Operating License (NPF-87) and CPSES Unit 2 Operating License (NPF-89) by incorporating a change to the CPSES Units 1 and 2 Technical Specifications (TS) 3.3.2 and 3.3.6.

The proposed change will revise TS 3.3.2 entitled "ESFAS Instrumentation" and TS 3.3.6 entitled "Containment Ventilation Isolation Instrumentation". The proposed change will revise the CPSES Units 1 and 2 Technical Specifications to change the surveillance frequency for Westinghouse type AR relays, used as Solid State Protection System slave relays or auxiliary relays, from quarterly to refueling outage frequency. Surveillance Requirements (SR) 3.3.2.6 and 3.3.6.5 would be revised to change the frequency from "92 days" to "92 days OR 18 months for Westinghouse type AR relays."

The purpose of this letter is to respond to the NRC Staff Requests for Additional Information (RAIs).

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

• Diablo Canyon

• South Texas Project Wolf Creek

TXX-02073 Page 2 of 2 This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2.

Should you have any questions, please contact Mr. Robert A. Slough at (254) 897 5727.

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

Executed on April 9, 2002.

Sincerely C. L. Terry By:

David R. Moore Plant Manager RAS Attachment c- E. W. Merschoff, Region IV W. D. Johnson, Region IV D. H. Jaffe, NRR J. N. Donohew, NRR Resident Inspectors, CPSES Mr. Arthur C. Tate Bureau of Radiation Control Texas Department of Public Health 1100 West 4 9 th Street Austin, Texas 78704

Attachment I to TXX-02073 Page 1 of 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 01-008 The following are questions on the application dated August 24, 2001, (CPSES 200101191), for Comanche Peak Steam Electric Station (CPSES), that proposed changes to Technical Specifications (TS) 3.3.2 and 3.3.6 to change the surveillance frequency for Westinghouse type AR relays, used as Solid State Protection System slave relays or auxiliary relays, from quarterly to refueling outage frequency.

Ouestion 1:

The licensee's submittal states, "The report can also be applied to ARD relays (DC coils) which are not used as slave relays, but are used in interposing relay applications." It should be noted that the Westinghouse Owner's Group Topical report (WCAP-13877) does not cover AR relays with DC coils. Therefore, if AR relays with DC coils are to be included in the extension request, please provide the basis for extending the applicability of the topical report to these relays. Such basis should be similar to the analysis for the AC relays.

TXU Energy Response:

Due to the expenditure of resources required in order demonstrate the applicability of the topical report to AR relays with DC coils, TXU Energy elects to revise our request to exclude AR relays with DC coils. Therefore, TXU Energy requests that the NRC withdraw the ARD relay from consideration in the proposed amendment request.

TXU Energy's proposed amendment request will continue to apply to Westinghouse Type AR relays with AC coils used in both SSPS slave relay and interposing relay applications, but will not include any DC relay applications at this time. This revised scope has been reflected in markups of the original proposed text for Technical Specifications Bases for Surveillance Requirements (SR) 3.3.2.6 and 3.3.6.5. These markups are provided in Attachment 2. The revised TS Bases pages which incorporate the marked-up information are provided in Attachment 3.

ATTACHMENT 2 to TXX-02073 MARKUP OF TECHNICAL SPECIFICATION BASES PAGES (For Information Only)

Pages B 3.3-115 B 3.3-168 to TXX-02073 ESFAS Instrumentation Page 1 of 2 B 3.3.2 BASES SURVEILLANCE SR 3.3.2.5 REQUIREMENTS (continued) SR 3.3.2.5 is the performance of a COT.

A COT is performed on each required channel to ensure the entire channel will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.2-1.

The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint calculation. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint calculation.

The Frequency of 92 days is justified in Reference 6.

SR 3.3.2.6 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation mode is either allowed to function, or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation mode is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing contacts operated by the slave relay. This test is 16 performed every 92 days. The Frequency is adequate, based on Industry operating experience, considering instrument reliability and operating history data.

For ESFAS slave relays and auxiliary relays which are Westinghouse 16 type AR relays, the SLAVE RELAY TEST is performed every 18 months. The Frequency is based on the slave relay reliability assessment presented in Reference 10. This reliability assessment is relay specific and applies only to Westinghouse type AR relays with AC coils. Note that, for normally energized applications, the relays may require periodic replacement in accordance with the guidance given in Reference 10.

SR 3.3.2.7 SR 3.3.2.7 is the performance of a TADOT every 31 days. This test is a check of the Loss of Offsite Power Function.

The SR is modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-115 Amendmen.... ' 6-4Revision 16 to TXX-02073 Containment Ventilation Isolation Instrumentation Page 2 of 2 B 3.3.6 BASES SURVEILLANCE SR 3.3.6.5 (continued) 16 REQUIREMENTS (eontited) For ESFAS slave relays and auxiliary relays which are Westinghouse type AR relays, the SLAVE RELAY TEST is performed every 18 months. The Frequency is based on the slave relay reliability assessment presented in Reference 3. This reliability assessment is relay specific and applies only to Westinghouse type AR relays with AC coils. Note that, for normally energized applications, the relays may require periodic replacement in accordance with the guidance given in Reference 3.

SR 3.3.6.6 Not Used.

SR 3.3.6.7 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Frequency is based on operating experience and is consistent with the typical industry refueling cycle.

REFERENCES 1. 10 CFR 100.11.

2. NUREG-1366, July 22, 1993.

3. WCAP-13877-P-A, Revision 2, August 2000. 116 COMANCHE PEAK - UNITS 1 AND 2 B 3.3-168 Armend~ment, No*. 6G4Revision 16

ATTACHMENT 3 to TXX-02073 RETYPED TECHNICAL SPECIFICATION BASES PAGES (For Information Only)

Pages B 3.3-115 B 3.3-168 to TXX-02073 ESFAS Instrumentation Page 1 of 2 B 3.3.2 BASES SURVEILLANCE SR 3.3.2.5 REQUIREMENTS (continued) SR 3.3.2.5 is the performance of a COT.

A COT is performed on each required channel to ensure the entire channel will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.2-1.

The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint calculation. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint calculation.

The Frequency of 92 days is justified in Reference 6.

SR 3.3.2.6 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in the design mitigation mode is either allowed to function, or is placed in a condition where the relay contact operation can be verified without operation of the equipment. Actuation equipment that may not be operated in the design mitigation mode is prevented from operation by the SLAVE RELAY TEST circuit. For this latter case, contact operation is verified by a continuity check of the circuit containing contacts operated by the slave relay. This test is 16 performed every 92 days. The Frequency is adequate, based on industry operating experience, considering instrument reliability and operating history data.

For ESFAS slave relays and auxiliary relays which are Westinghouse 16 type AR relays, the SLAVE RELAY TEST is performed every 18 months. The Frequency is based on the slave relay reliability assessment presented in Reference 10. This reliability assessment is relay specific and applies only to Westinghouse type AR relays with AC coils. Note that, for normally energized applications, the relays may require periodic replacement in accordance with the guidance given in Reference 10.

SR 3.3.2.7 SR 3.3.2.7 is the performance of a TADOT every 31 days. This test is a check of the Loss of Offsite Power Function.

The SR is modified by a Note that excludes verification of setpoints for relays. Relay setpoints require elaborate bench calibration and are (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-115 Revision 16 to TXX-02073 Containment Ventilation Isolation Instrumentation Page 2 of 2 B 3.3.6 BASES SURVEILLANCE SR 3.3.6.5 (continued) 16 REQUIREMENTS For ESFAS slave relays and auxiliary relays which are Westinghouse type AR relays, the SLAVE RELAY TEST is performed every 18 months. The Frequency is based on the slave relay reliability assessment presented in Reference 3. This reliability assessment is relay specific and applies only to Westinghouse type AR relays with AC coils. Note that, for normally energized applications, the relays may require periodic replacement in accordance with the guidance given in Reference 3.

SR 3.3.6.6 Not Used.

SR 3.3.6.7 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Frequency is based on operating experience and is consistent with the typical industry refueling cycle.

REFERENCES 1. 10 CFR 100.11.

2. NUREG-1 366, July 22, 1993.

3. WCAP-13877-P-A, Revision 2, August 2000. 116 COMANCHE PEAK - UNITS 1 AND 2 B 3.3-168 Revision 16