CPSES-200300325, License Amendment Request (LAR) 02-10 Revision to Technical Specification (TS) 3.6.3, Containment Isolation Valves

License Amendment Request (LAR) 02-10 Revision to Technical Specification (TS) 3.6.3, Containment Isolation Valves

ML030860407
Person / Time
Site:	Comanche Peak
Issue date:	03/18/2003
From:	Walker R TXU Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
+sunsi/sispmjr=200603, 00236, CPSES-200300325, TXX-03040
Download: ML030860407 (59)

Text

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

Glen RoseTX 76043 Tel. 254 897 8920 Fax 254 897 6652 lance terry@txu com CPSES-200300335 Log # TXX-03040 File # 00236 March 18, 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) 02-10 REVISION TO TECHNICAL SPECIFICATION (TS) 3.6.3, CONTAINMENT ISOLATION VALVES 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 will delete two of the Surveillance Requirements (SR) in TS 3.6.3 entitled "Containment Isolation Valves." Specifically, safety injection valves 8809A, 8809B, and 8840 and containment spray valves HV-4776, HV-4777, CT-142, and CT-145 will no longer be leak tested.

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 Technical Specification pages marked-up to reflect the proposed changes.

Attachment 3 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 ihcorporate the proposed changes.

Attachment 6 provides marked-up pages of the Final Safety Analysis Report (FSAR)

A member of the STARS (Strategic Teaming and Resource Shanng) Alliance ý.53 Callaway - Comanche Peak

• Diablo Canyon

• Palo Verde - South Texas Project

• Wolf Creek

STXU TXX-03040 Page 2 of 3 to reflect the proposed changes to the FSAR for information only.

TXU Energy requests approval of the proposed License Amendment by September 15, 2003. The Unit 2 Cycle 7 refueling outage is scheduled for October 4, 2003, and the revised TS will be made effective within 30 days of NRC approval. Although receipt of the Amendment is not required to conduct the outage or to restart the unit following the outage, implementation of the requested TS change prior to the outage will allow planned outage work to proceed in conjunction with critical path activities, thereby shortening the outage. In addition, there will be a significant reduction in radiation exposure to personnel over the life of the plant by deleting these testing requirements.

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.

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

Executed on March 18, 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: RaqP4 Af eZ R~gerk. Walker Regulatory Affairs Manager JCH/jrh

Qm-TXU TXX-03040 Page 3 of 3 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. Markup of Final Safety Analysis Report Pages (for information) 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 4 1 A, '

ATTACHMENT 1 to TXX-03040 DESCRIPTION AND ASSESSMENT to TXX-03040 Page 2 of 24 LICENSEE'S EVALUATION

4.0 TECHNICAL ANALYSIS

4.1 Design Basis and Safety Analysis Consideration 4.2 Radioactive Systems Leakage Inspection (RSLI) Program 4.3 Tables

-Table 1: SR 3.6.3.12 and SR 3.6.3.13 Containment Penetrations

-Table 2: FMEA Cold Leg Injection Valves 8809A & 8809B

-Table 3: FMEA Hot Leg Injection Valve 8840

-Table 4: FMEA ECCS Closed System Isolation

-Table 5: FMEA Containment Spray Valves HV-4776 & CT-142, HV-4777 & CT-145

-Table 6: FMEA Containment Spray Closed System Isolation 4.4 Figures

-Figure 1: Simplified ECCS Diagram

-Figure 2: Simplified Containment Spray Diagram 5.0 REGULATORY SAFETY ANALYSIS 5.1. No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/criteria

7.0 REFERENCES

to TXX-03040 Page 3 of 24

1.0 DESCRIPTION

By this letter, TXU Energy 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 Units 1 and 2 Technical Specifications. Proposed LAR 02-10 is a request to revise Technical Specification (TS) 3.6.3, "Containment Isolation Valves," for CPSES Units 1 and 2.

Implementation of the requested TS change is acceptable because the affected containment penetrations are not a credible containment atmosphere leakage path during and after a LOCA.

The surveillances are not commensurate with the design and licensing basis of the plant.

Currently, initial conditions for testing require the RCS in Mode 5 with the RHR train to be tested inoperable, isolated, and at ambient temperature. Due to the requirements for ambient conditions, test duration per valve is normally six hours. The average dose received per test is 100-120 mRem. Deletion of these testing requirements will result in a significant reduction in radiation exposure to personnel over the life of the plant. Implementation of the requested TS change would also allow planned outage work to proceed in conjunction with critical path activities, thereby shortening outages.

The CPSES Final Safety Analysis Report (FSAR) (Chapter 6) will be updated as required to reflect this License Amendment Request (LAR). The FSAR will be updated after the LAR has been approved and implemented. See Attachment 6 for the proposed markup of Section 6 of the FSAR.

2.0 PROPOSED CHANGE

The proposed change modifies the Surveillance Requirements for TS 3.6.3, "Containment Isolation Valve".

The proposed change will delete Surveillance Requirements(SR) 3.6.3.12 and 3.6.3.13 for safety injection valves 8809A, 8809B, and 8840 and containment spray valves HV-476, HV-4777, CT 142, and CT-145.

The proposed changes to TS 3.6.3 will make Comanche Peak's Surveillance Requirements consistent with other Westinghouse 4-loop plants.

3.0 BACKGROUND

Supplement 22 of Comanche Peak Safety Evaluation Report (SER) contains the NRC staff s evaluation and acceptance of the CPSES program for local leakage rate testing of containment isolation valves in accordance with Type C testing requirements in Appendix J to 10 CFR Part 50.

Section 6.2.3.1, Elimination of Type C Leakage Tests for Certain Containment Isolation Valves, to TXX-03040 Page 4 of 24 item (3), discusses the testing for the following containment isolation valves: HV-4776, HV-4777, CT-142, CT-145, 1-8840, 1-8809A, and 1-8809B.

Containment isolation valves HV-4776, HV-4777, CT-142, and CT-145 on the spray systems are to be leak rate tested with water at a pressure of not less than 1.1 P.. The justification is that these penetrations have a water-filled loop seal on the containment side of the valves for more than 30 days following the accident. It was noted that the surveillance requirements and acceptance criteria should be included in the plant's Technical Specifications (TS).

In addition, the following three valves were added to be leak rate tested with water: 1-8840, 1-8809A, and 1-8809B of penetrations MIII-23, MIII-4, and MIII-5. These valves are outboard containment isolation valves in the RHR discharge lines, which satisfy the following design criteria: -The systems are protected against missiles and pipe whip.

-The systems are designed seismic Category 1.

-The systems are classified as ASME safety Class 2.

SSER 22 stated: "At the penetrations, a pressurized water seal will be maintained throughout the entire 30-day accident-mitigation period. The water seal is on the containment side so that the accident pressure will push the water seal against the valves from inside containment towards outside containment. In accordance with paragraph III.C.3 of Appendix J to 10 CFR Part 50, these valves are not required to be Type C tested. Furthermore, the plant's TS include surveillance requirements and acceptance criteria for leak testing. Therefore, the proposed leak testing with water for the valves listed above is acceptable."

TXU has contacted a number of plants whose RHR and Containment Spray system designs are essentially equivalent to Comanche Peak (Westinghouse 4 Loop plants) to ascertain the testing requirements for the valves for which this elimination of testing is being requested.

The Byron/Braidwood Stations, Diablo Canyon Station, and Wolf Creek/Callaway Stations do not perform LLRTs for these RHR and Containment Spray Valves. The technical justification for not performing local leak rate testing of these valves is described in their respective UFSARs. A similar discussion forms the basis for Comanche Peak's request for elimination of these tests.

4.0 TECHNICAL ANALYSIS

The RCS Cold Leg Injection valves (1-8809A, 2-8809A, 1-8809B and 2-8809B) and the RCS Hot Leg Injection valves (1-8840 and 2-8840) are currently required by SR 3.6.3.12 to be leak tested to be within limits with a gas at a pressure not less than Pa, 48.3 psig, or with water at a pressure not less than 1.1 P.. However, these valves are not a credible containment atmosphere leakage path during and after a LOCA.

Likewise, the Containment Spray injection valves (1-HV-4776, 2-HV-4776, 1-HV-4777, 2-HV 4777, 1-CT-142, 2-CT-142, 1-CT-145, and 2-CT-145) are currently required by SR 3.6.3.13 to be leak tested to be within limits with water at a pressure not less than 1.1 Pa. However, these valves are also not a credible containment atmosphere leakage path during and after a LOCA.

to TXX-03040 Page 5 of 24 The unit designator 1- and 2- is not used when describing these valves herein similar to the CPSES FSAR when the information is equally applicable to both units. For example, 8809A means "1-8809A AND 2-8809A".

The volume of the inboard water seal for each valve is the basis for the Maximum Allowed Leakage Rate (MALR) defined in the Technical Specification 3.6.3 BASES required to maintain the water seal for 30 days. The surveillance testing is performed with the outboard side drained and vented; however, the maintenance of a water seal for 30 days is assured by a closed system outside containment which is not drained or vented post-LOCA. Containment pressure is significantly reduced in the short term after a LOCA and a water seal is maintained on both sides of these valves during and after a LOCA by a closed system in accordance with Standard Review Plan (SRP) 6.2.4. Therefore, the surveillance testing is not commensurate with the design and safety analysis.

SR 3.6.3.12 and SR 3.6.3.13 are not required to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

4.1 Design Basis and Safety Analysis Consideration Containment isolation valves 8809A, 8809B, 8840, HV-4776 and HV-4777 valves are motor operated valves (MOVs) located outside reactor containment (ORC). Containment isolation valves CT-142 and CT-145 are check valves located inside reactor containment (IRC). These valves are located in "Essential Penetrations" as defined by Item II.E.4.2 of NUREG-0737.

Essential penetrations such as these include remote-manual containment isolation valves. The MOVs are provided with handwheels for local manual operation if required. Automatic isolation is not required to meet GDC-55 and GDC-56 [See CPSES FSAR Section 6.2.4.1.3, Special Containment Isolation Provisions]. The penetrations do not communicate with the containment atmosphere (i.e., do not provide a direct connection between the inside and outside atmospheres of the primary reactor containment under normal operation). Provisions to detect possible leakage from the lines outside containment during normal operation are required by Technical Specification Program 5.5.2 Primary Coolant Sources Outside Containment. A description of this program is provided in Section 4.2 of this Attachment..

The design of the Emergency Core Cooling System (ECCS) and its operation during and after a LOCA is described in CPSES FSAR Section 6.3. The design of the Containment Spray System and its operation during and after a LOCA is described in CPSES FSAR Section 6.2.2. The containment isolation design is described in CPSES FSAR Section 6.2.4. The applicable containment penetrations are listed under Items 35, 36, 54, 55, and 63 in CPSES FSAR Tables 6.2.4-1, 6.2.4-2, 6.2.4-3, 6.2.4-4 and 6.2.4-6(see Attachment 6).

Because these lines are designed to be in service recirculating reactor coolant after a LOCA, the systems are designed as closed systems outside containment (See CPSES FSAR Section 6.2.1.4.5 which is based on SRP 6.2.4, Sections II.6.e and II.6.o).

to TXX-03040 Page 6 of 24 The RHR and Containment Spray systems which recirculate coolant outside containment meet the following requirements for a closed system outside containment:

• missile protected (from both internal and external missiles),

• Seismic Category I,

• Safety Class 2,

• design temperature and pressure at least equal to containment, and

• tested per the requirements of NUREG-0737,Section III.D.1.

In addition to the NUREG-0737 testing, the closed loops outside containment are tested and inspected in accordance with ASME Section XI.

Thus, the design of these systems ensure an additional containment boundary for protection from leakage in addition to the redundant containment isolation valves.

All Containment piping penetrations, including the closed systems outside containment, are located in radiation controlled areas of the Auxiliary, Fuel and Safeguards buildings which are monitored by radiation monitors for Containment leakage after a LOCA as described in CPSES FSAR Section 7.5. This is consistent with GDC-54 requirements for leak detection.

The Train A injection valves are located in separate penetration rooms from the Train B injection valves. These would be accessible prior to the onset of core damage after a LOCA which is not expected for hours after an accident. With the assumption of a post accident release of radioactivity equivalent to that described in Regulatory Guides 1.3 and 1.4 (i.e., the equivalent of 50% of the core radioiodine, 100% of the core noble gas inventory, and 1% of the core solids are contained in the primary coolant), if the single active failure is loss of a train of power, the associated room would be accessible within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the design basis event. [See CPSES Figure 12.3.-6 (rooms 77A and 77B) for Unit 1 and Figure 12.3-23.4 (rooms 77A and 77B) for Unit 2. See CPSES FSAR Response to the NRC Action Plan Section II.B.2 for post accident plant shielding.]

The valves which are subject to SR 3.6.3.12.and 3.6.3.13 are associated with 5 essential containment penetrations for each Unit. Table 1, in Section 4.3 below, details the containment isolation valves in each of these penetrations. Note 1 designation is for the valves for which this Technical Specification change is being requested. Note 2 is for valves in these penetrations which are not currently required to be leak tested and provides the current licensing basis for not requiring Type C testing (CPSES FSAR Table 6.2.4-2). Test header isolation valves 8890A, 8890B, and 8825 located IRC are currently Type C leak tested and any change thereto is not part of this LAR. Any changes to the LLRT of these valves will be performed under 10 CFR 50.59.

Figure 1 and Figure 2, in Section 4.4 below, show the valve and system arrangement for the Cold and Hot Leg Injection penetrations and Containment Spray penetrations, respectively.

to TXX-03040 Page 7 of 24 RHR Cold Leg Injection Valves 8809A and 8809B The ECCS system is required to operate during a design basis accident. The RHR Cold Leg Injection valves (8809A and 8809B) are normally open valves that are required to be open for Cold Leg (CL) Injection and Cold leg Recirculation (CLR). They are procedurally required to be closed when the plant transitions to Hot Leg Recirculation (HLR) Mode. The switchover toCLR and to HLR is described in CPSES FSAR Table 6.3-7. RHR loop cross-tie valves 8716A and B are a back-up to the 8809A and B valves should either 8809A or B fail to close when HLR Mode is required to be entered. Additionally, both 8809A and B are provided with handwheels should a loss of Train A or B electrical power occur and either valve is required to be closed.

As can be seen in Tables 2 and 4 (Section 4.3, below), these valves are open with injection flow provided during CL Injection. Flow through the valve is maintained until the switchover to CLR.

During CLR and HLR, either flow through the valves or a closed system boundary is maintained regardless of any single active failure.

On failure of the train related power 8809A (or 8809B) remains open until power is restored or it is closed locally. Leak rate testing is not relevant for this failure as the valve is open and the containment isolation is provided by the check valve and test header isolation valve IRC and the closed system ORC. If manual actions to close 8809A (8809B) are successful, there would be three containment barriers in place. After 8809A (8809B) is closed, 8716B (8716A) can be re opened to provide seal water on the outboard side of 8809A (8809B).

On a failure of an RHR pump to start in response to ESFAS actuation, flow is maintained through 8809A and 8809B until entry into Cold Leg Recirculation. In this case, 8809A (8809B) can be closed remotely to provide the three containment barriers. 8716A and 8716B could be re-opened during HLR to provide seal water on the outboard side of 8809A (8809B).

Failure of the valve (8809A or 8809B) to close on demand would result in continuation of cold leg injection flow through the failed valve. HLR would be provided by the opposite train pump.

Failure of the test header isolation valves is bound-ed by the base case of no single active failures.

Therefore, in all design basis cases, 8809A and 8809B are either open or are closed providing a third barrier to containment leakage. A water seal is maintained both inside and outside containment. Therefore, there are three barriers between the containment atmosphere and the outside atmosphere when these valves are closed after a LOCA as opposed to a single barrier assumed for Appendix J leak rate testing.

to TXX-03040 Page 8 of 24 RHR Hot Leg Injection Valve 8840 RHR HLR valve 8840 is a normally closed valve. As such, either RHR pump can provide upstream pressure on the valve via the loop crosstie header and valves 8716A or B. Upon initiation of HLR Mode, valve 8840 is designed to be opened.

As described in Tables 3 and 4 (Section 4.3 below), a secondary containment boundary is maintained under system operation post accident including single active failures. During CL injection, a pumped water seal is maintained on the outboard side of 8840 regardless of single active failure. When 8716A and 8716B close, they provide the third closed system boundary during CLR.

For loss of Train A power, the third barrier is maintained by the closed system (same as for 8809A, above) until 8809A or 8716A can be closed. Once either 8809A or 8716A are closed, the Train B pump can be used to provide flow through 8840 or to provide a pumped water seal. For loss of Train B power, the third barrier is maintained by the closed system (same as for 8809B, above) until 8809B or 8716B can be closed. Then the Train A pump can be used to provide a pumped water seal.

Failure of the valve to open on demand would result in continuation of cold leg injection flow through 8809A and 8809B. HLR would be provided by the Safety Injection pumps via valve 8835. 8716A or 8716B could be re-opened to provide a pumped water seal on the outboard side.

Failure of the test header isolation valve is bounded by the base case of no single active failures.

Therefore, in all design basis cases, 8840 is either open or is closed providing a third barrier to containment leakage. A water seal is maintained both inside and outside containment. Therefore, there are three barriers between the containment atmosphere and the outside atmosphere when these valves are closed after a LOCA as opposed to a single barrier assumed for Appendix J leak rate testing.

Containment Spray Discharge Header Valves HV-4776, HV-4777, CT-0146, and CT-0147 Similarly, for the Containment Spray Discharge Header Valves HV-4776, HV-4777, CT-0142, and CT-0145, water is applied to both sides of these valves during all modes of operation. These valves are normally closed and open ONLY on a HI-3 Containment Pressure actuation signal. A water filled standpipe located on each spray header inside containment provides a water seal on the downstream (inboard) side of these valves. Each Containment Spray header riser is provided with a pressure switch to alarm in the Control Room if the level in the riser falls below the minimum level required. On the upstream side of the valves, Containment Spray pump discharge pressure is applied (pump is started on a Safety Injection Actuation signal) to the valves prior to the valves opening to perform its safety function. During normal operation, Refueling Water Storage Tank hydrostatic pressure provides a water seal on the valve upstream side. This pressure is greater than the normal Containment Building pressure.

to TXX-03040 Page 9 of 24 As described in Tables 5 and 6, below, the valves are open during spray injection and recirculation. In the event of a single active failure, the closed system outside containment provides a secondary boundary to the containment isolation valves. Therefore, there are three barriers between the containment atmosphere and the outside atmosphere when these valves are closed after a LOCA as opposed to a single barrier assumed for Appendix J leak rate testing.

Any water leakage from inside containment to the closed system outside containment would pressurize the closed system until the pressures equalized which would stop outleakage. With three barriers in series, it is unlikely that leakage would be significant during 30 days post-LOCA.

Summary In summary, the deletion of SR 3.6.3.12 and 3.6.3.13 is acceptable because the penetrations are not a credible containment atmosphere leakage path during and after a LOCA. The maintenance of a water seal for 30 days is assured by a closed system outside containment which is not drained or vented post-LOCA. This secondary boundary would be available even in the event of a single active failure. Furthermore, there are three containment isolation barriers between the containment atmosphere and the outside atmosphere when these valves are closed after a LOCA as opposed to a single barrier assumed for Appendix J leak rate testing.

Therefore, the surveillance required by Technical Specifications SR 3.6.3.12 and SR 3.6.3.13 is not commensurate with the design and licensing basis. These surveillance requirements are not required to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

4.2 The Radioactive System Leakage Inspection (RSLI) Program The overall objective of the RSLI program is to monitor and reduce leakage from those portions of systems outside containment that contain highly radioactive fluids during post accident operation to as low as reasonably achievable levels. Leakage from radioactive systems outside containment are monitored to meet the commitments in CPSES FSAR Section III.D.1.1 (CPSES Response to the NRC Action Plan for the TMI Accident) and the requirements of Section 5.5.2, Primary Coolant Sources Outside Containment of the Technical Specifications.

The RSLI program includes the following:

a. Preventive maintenance and periodic visual inspection requirements; and

b. Integrated leak test requirements for each system at refueling cycle intervals or less.

The leakage criteria for the RSLI Program are as follows: The limiting leakage value based on a cumulative amount from all liquid systems tested under the RSLI Program is 1.0 gpm per unit.

An additional criterion for liquid leakage on individual systems is administratively applied.

Leakage greater than 1.0 gpm does not violate a Technical Specification limit and there is no direct impact on system/Unit Operability/operation. The 1.0 gpm is based on accident analysis assumptions for radiological consequences of engineered safety features equipment leakage outside containment [See CPSES FSAR 15.6.5.4]. All abnormal leakage is evaluated and to TXX-03040 Page 10 of 24 corrected under the Appendix B corrective action program in accordance with NRC Generic Letter 91-18, Revision 1.

Each RSLI system is inspected at intervals not to exceed each refueling cycle. Testing is performed at normal system operating pressures. In order to have appropriate portions of systems pressurized, inspection of the Containment Spray, Residual Heat Removal, and Safety Injection systems are scheduled to coincide with the operability tests of those systems, when possible.

Operations, Engineering, and Maintenance personnel perform tests, identify/quantify leakage and initiate corrective actions (e.g. work orders, SmartForms) as necessary.

System engineering reviews RSLI test data and other significant leakage data and applicable corrective action documents on RSLI system components to maintain a RSLI Program Leakage Table for each unit. This will ensure that the unit's cumulative leakage for portions of systems covered by this program remain within the leakage criteria.

Maintenance personnel implement corrective actions as soon as reasonably possible identified by RSLI tests or other inspections. These corrective actions include adjusting packing or replacement of seals, gaskets, o-rings, etc. on RSLI system components.

The RSLI program ensures that the closed systems outside containment provide an acceptable secondary containment boundary during and after a LOCA.

4.3 Tables

Attachment I to TXX-03040 Page 11 of 24 Table I SR 3 6.3.12 and SR 3.6 3.13 CONTAINMENT PENETRATIONS [REF. 1]

PEN. VALVE LINE OR SERVICES GDC FLUID FLOW DIAGRAM LEAK RATE NO. NO. CONTAINED TEST MII-4 8809A RtH.R. TO COLD LEG 55 WATER FSAR Fig. 6.3-I NOTE I 8818A LOOPS NO 1 AND MI(M2)-0263 NR (NOTE 2) 8818B NO. 2 M 1-0263-B NR (NOTE 2) 8890A M2-0263-A C MII-5 8809B RtH R. TO COLD LEG 55 WATER FSAR Fig. 6.3-1 NOTE I 8818C LOOPS Ml(M2)-0263 NR (NOTE 2) 8818D NO. 3 AND NO. 4 Ml-0263-B NR (NOTE 2) 8890B M2-0263-A C MIII-23 8840 RtH R. TO HOT LEG 55 WATER FSAR Fig. 6.3-1 NOTE 1 8841A LOOPS NO. 2 AND M I(M2)-0263 NR (NOTE 3) 8841B NO. 3 M2-0263-A NR (NOTE 3) 8825 Ml (M2)-0263-B C MIII-15 HV-4776 CONTAINMENT 56 WATER FSAR Fig. 6.2.2-1 C (NOTE 1)

CT-0142 SPRAY TO M I(M2)-0232 C (NOTE 1)

SPRAY HEADER (TRAIN A)

MIII-14 HV-4777 CONTAINMENT 56 WATER FSAR Fig. 6.2.2-1 C (NOTE 1)

CT-0145 SPRAY TO Ml(M2)-0232 C (NOTE 1)

SPRAY HEADER (TRAIN B)

These valves are part of closed systems outside containment tested per NUREG-0737 Section III.D. I which are in service post accident and have a water filled loop seal on the containment side of the valves for a period greater than 30 days following the accident. These valves are currently leakrate tested with water at a pressure of not less than I.1Pa, as required by SR 3 6.3.12 AND SR 3.6.3.13.

2. This penetration is an engineered safety feature system supplying RHR pump flow (valves opened) to the cold legs of the RCS during cold leg injection and cold leg recirculation modes of operation. During hot leg recirculation this penetration is not in service (valves closed) but is pressurized by the residual heat removal pumps to a pressure in excess of 1.1 times the containment design pressure. In addition, the outside containment motor generated valves are Type C tested, thus any Leakage at the penetration would be contained at the motor operated valves. These valves are therefore not required to be Type C tested.

3. This penetration is an Engineered Safety Feature System supplying RHR pump flow (valves opened) to the hot legs of the RCS during hot leg recirculation mode of operation. During cold leg injection and cold leg recirculation this penetration is not in service (valve closed) but is pressurized by the residual heat removal pumps to a pressure in excess of containment design pressure. In addition, the outside containment motor operated valve is Type C tested, thus any leakage at the penetration would be contained at the motor operated valve. These valves are therefore not required to be Type C tested.

REF. 1 FSAR Table 6.2.4-2 to TXX-03040 Page 12 of 24 Table 2 FAILURE MODES AND EFFECTS ANALYSIS COLD LEG INJECTION VALVES 8809A and 8809B VALVE SINGLE ACTIVE ECCS OPERATION EFFECTS NO. [1] [2] FAILURE PHASE 8809A None (Base Case) Cold Leg Injection 8809A (8809B) is open and ECCS water is (8809B) being injected by the respective RHR pump.

Cold Leg Recirculation 8809A (8809B) is open and ECCS water is being injected by the respective RHR pump.

11 Hot Leg Recirculation 8809A (8809B) is closed and RHR pump discharge pressure is maintained on the outboard side of the valve by the respective RHR pump.

8809A Loss of Train A related Cold Leg Injection 8809A (8809B) is open and injection flow (8809B) AC power through the valve is provided by the RHR (Loss of Train B related pump in the opposite train.

AC power)

Cold Leg Recirculation 8716B (8716A) is manually closed during switchover to separate the RHR pumps to prevent runout due to this single active failure. Check valves inside containment close to provide the first containment isolation boundary. Any leakage past the check valves is contained by the closed system outside containment. When the pressure across the check valve equalizes, leakage is terminated. Manual actions to close 8809A (8809B) would be taken prior to switchover to hot leg recirculation.

Hot Leg Recirculation Loss of Train A related AC power:

After 8809A is closed, 8716B is opened to provide flow to the hot leg via 8840 and provide RHR pump discharge pressure on the outboard side of valve 8809A by the Train B RHR pump Loss of Train B related AC power.

After 8809B is closed, 8716A may be re opened to provide RHR pump discharge pressure on the outboard side of the valve by the Train A RHR pump (8840 remains closed and Hot leg Recirculation is provided by Train A Safety Injection Pump) 8809A Failure of Associated Cold Leg Injection Same as for loss of Train associated power (8809B) Pump to start (apply above.

upstream pressure on valve)

Cold Leg Recirculation Same as for loss of Train associated power above.

to TXX-03040 Page 13 of 24 Table 2 (continued) 11 Hot Leg Recirculation 8809A (8809B) is closed, 8716A and 8716B are opened to provide flow to the hot leg via 8840 and provide RHR pump discharge pressure on the outboard side of the valve from the opposite train pump.

8809A Failure of valve to close Cold Leg Injection N/A. Valve is required to be open.

(8809B) on demand Cold Leg Recirculation N/A. Valve is required to be open. Injection flow is maintained.

Hot Leg Recirculation If 8809A (8809B) failed to close during switchover to HLR, 8716A (8716B) would be closed and the Train A (Train B) RHR pump would remain in Cold Leg Recirculation.

8890A Failure of valve to close Cold Leg Injection 8809A and 8809B are open and ECCS water (8890B) on demand is being injected by both RHR pumps.

Cold Leg Recirculation 8809A and 8809B are open and ECCS water is being injected by both RHR pumps.

Hot Leg Recirculation 8809A and 8809B are closed. This could result in loss of some of the water seal inside containment; however, RHR pump discharge pressure is maintained on the outboard side of the valves by the RHR pumps.

[1] 8809A is Class 1E Train A powered (8809B is Class 1E Train B powered) 8890A (Train A) and 8890B (Train B) are air operated valves and fail closed on loss of air or power. Both power and air are terminated by safety injection actuation signals.

[2] See Figure 1, Section 4.4.

to TXX-03040 Page 14 of 24 Table 3 FAILURE MODES AND EFFECTS ANALYSIS HOT LEG INJECTION VALVE 8840 VALVE SINGLE ACTIVE ECCS OPERATION EFFECTS NO. [1] [2] FAILURE PHASE 8840 None (Base Case) Cold Leg Injection 8840 is closed and a secondary boundary is being maintained on the outboard side of 8840 by RHR pump discharge pressure in the closed system outside containment.

Cold Leg Recirculation 8716A and 8716B are closed. 8840 remains closed and a secondary boundary is being maintained by the closed system outside containment. Pump discharge pressure is maintained on the outboard of valves 8716A and 8716B.

Hot Leg Recirculation 8840 is open and RHR pump hot leg injection is maintained.

8840 Loss of Train A related Cold Leg Injection 8840 is closed and a secondary boundary is AC power being maintained by the Train B (Train A)

(Loss of Train B related RHR pump discharge pressure in the closed AC power) system outside containment.

11 11 Cold Leg Recirculation Same as for 8809A (8809B) in Table 2.:

8716B (8716A) is closed to separate the RHR pumps 8840 remains closed and a secondary boundary is being maintained by the closed system outside containment. Any leakage past the check valves and 8840 is contained by the closed system outside containment. When the pressure across 8840 equalizes, leakage is terminated.

11 Hot Leg Recirculation Same as for 8809A (8809B) Table 2 above.

Loss of Train A related AC power:

After 8809A is closed, 8716B is opened to provide flow to the hot leg via 8840 and provide RHR pump discharge pressure on the outboard side of valve 8809A by the Train B RHR pump.

Loss of Train B related AC power After 8809B is closed, 8716A may be re opened to provide RHR pump discharge pressure on the outboard side of the valve by the Train A RHR pump (8840 remains closed and Hot leg Recirculation is provided by Train A Safety Injection Pump).

8840 Failure of Associated Cold Leg Injection Same as for loss of Train associated power Pump to start above.

Cold Leg Recirculation Same as for loss of Train associated power above.

Attachment I to TXX-03040 Page 15 of 24 Table 3 (continued) 11 Hot Leg Recirculation 8840, 8716A and 8716B would be opened and the running pump would provide hot leg injection.

8840 Failure of valve to open Cold Leg Injection N/A. Valve is required to be closed.

on demand 11 Cold Leg Recirculation N/A. Valve is required to be closed.

Hot Leg Recirculation Hot Leg Recirculation is provided by the Safety Injection Pumps. The RHR pumps remain in Cold Leg recirculation. 8840 remains closed and a secondary boundary is being maintained by the closed system outside containment Any leakage past the check valves and 8840 is contained by the closed system outside containment.

8825 Failure of valve to close Cold Leg Injection None. 8840 is closed and a secondary on demand boundary is being maintained on the outboard side of 8840 by RHR pump discharge pressure in the closed system outside containment.

Cold Leg Recirculation None. 8716A and 8716B are closed. 8840 remains closed and a secondary boundary is being maintained by the closed system outside containment. Pump discharge pressure is maintained on the outboard of valves 8716A and 8716B.

.1 Hot Leg Recirculation None. 8840 is open delivering flow from both RHR pumps. Loss of water from the 10" SI header via the 3/4" connection would be negligible. HLR is also being supplied by both SI pumps via 8802A and 8802B.

[1] 8840 is Class 1E Train B powered 8825 (Train A) is air operated valves and fail closed on loss of air or power. Both power and air are terminated by safety injection actuation signals

[2] See Figure 1, Section 4.4.

to TXX-03040 Page 16 of 24 Table 4 FAILURE MODES AND EFFECTS ANALYSIS ECCS CLOSED SYSTEM ISOLATION VALVE SINGLE ACTIVE ECCS OPERATION EFFECTS NO [1] [2] FAILURE PHASE LCV-01 12B Failure to Auto-close (or Cold Leg Injection None. VCT is isolated from charging pump (LCV-01 12C) Train failure) suction. LCV-01 12B and LCV-01 12C are in series Redundant, single active failure isolation is provided.

HV-8220 Failure to Auto-close (or Cold Leg Injection None. Charging pump suction high point (HV-8221) Train failure) vent line is isolated 8220 and 8221 are in series. Redundant, single active failure isolation is provided.

8110 Failure to Auto-close (or Cold Leg Injection None. Charging pump minimum flow line is (8111) Train failure) isolated. 8110 and 8111 are in series.

Redundant, single active failure isolation is provided.

8440 Failure to close on Cold Leg Injection None. Boundary is provided by containment demand isolation valves 8112 and 8100.

8202A Failure to Auto-close Cold Leg Injection None. Charging pump suction stabilizer (8202B) VCT vent line is isolated. 8202A and 8202B are redundant fail closed solenoid valves in series Redundant, single active failure isolation is provided 821 OA Failure to Auto-close Cold Leg Injection None. Charging pump suction stabilizer VCT (8210B) supply line is isolated 821 OA and 821 OB are redundant fail closed solenoid valves in series. Redundant, single active failure isolation is provided HV-4178 Failure to Auto-close Cold Leg Injection None. RHR Sample line can be isolated by (HV-4179) remote manual actuation or by local manual valve RH-0026.

HV-4182 Failure to Auto-close Cold Leg Injection None. PASS sample line can be isolated by remote manual actuation or by local manual valve PS-0007. [Fig. 9.3-4, M1-0228, M2 0228, Loc. A-4]

8812A Failure to close on Switchover to Cold Leg None. RWST is isolated from RHR pump (8812B) demand (or Train failure) Recirculation suction Check valves 8958A (8958B) is in series. Redundant, single active failure isolation is provided.

8814A Failure to close on Switchover to Cold Leg None. RWST is isolated from Safety

& demand (or Train A Recirculation Injection pump minimum flow lines. 8814A 8814B failure) and 8814B are both Train A valves in parallel. 8813 is a Train B isolation valves provided in series. Redundant, single active failure isolation is provided.

8511A Failure to close on Switchover to Cold Leg None. RWST is isolated from Charging (851 1B) demand (or Train failure) Recirculation pump alternate minimum flow lines 8512B (8512A) provided in series. Redundant, single active failure isolation is provided.

to TXX-03040 Page 17 of 24 Table 4 (continued)

LCV-01 12D Failure to close on Switchover to Cold Leg None. RWST is isolated form Charging (LCV-O01 12E) demand (or Train failure) Recirculation pump suction. Check valve 8546 is in series with both valves. Redundant, single active failure isolation is provided.

8806 Failure to close on Switchover to Cold Leg None. RWST is isolated form Safety demand (or Train failure) Recirculation Injection Pump suction. Check valve 8926 is in series. Redundant, single active failure isolation is provided.

[1] Valves powered by Class IE Train A (valves powered by Class IE Train B)

[2] See CPSES FSAR Figure 6.3-1

Attachment I to TXX-03040 Page 18 of 24 Table 5 FAILURE MODES AND EFFECTS ANALYSIS CONTAINMENT SPRAY VALVES HV-4776 & CT-142, HV-4777 & CT-145 VALVE SINGLE ACTIVE ECCS OPERATION EFFECTS NO FAILURE PHASE HV-4776 & None (Base Case) Spray Injection Valves are open and spray water is being CT-142 injected by the respective spray pump.

(HV-4777 &

CT-145)

Spray Recirculation Valves are open and spray water is being injected by the respective spray pump.

HV-4776 & Loss of Train AC power Spray Injection Valves remain closed and a secondary CT-142 boundary is being maintained by the closed (HV-4777 & system outside containment (check valves in CT-145) the pump discharge) Any leakage past the redundant closed valves is contained by the closed system outside containment. When the pressure across HV-4776 (HV-4777) equalizes, leakage is terminated.

11 11 Spray Recirculation Same as above.

HV-4776 & Valve fails to open Spray Injection Same as for loss of train.

CT-142 (HV-4777 &

CT-145)

Spray Recirculation Same as for loss of train.

[I] HV-4776 powered by Class IE Train A (HV-4777 powered by Class 1E Train B)

[2] See Figure 2, Section 4 4.

to TXX-03040 Page 19 of 24 Table 6 FAILURE MODES AND EFFECTS ANALYSIS CONTAINMENT SPRAY CLOSED SYSTEM ISOLATION VALVE SINGLE ACTIVE OPERATION PHASE EFFECTS NO. [1] FAILURE FV-4772-1 Failure to close (Train Injection None. The spray pumps do not start, the

& Failure) containment spray injection valves do not FV-4772-2 open The secondary containment boundary (FV-4773-1 is maintained by check valves CT-0065 and

& CT-0094 (CT-0042 and CT-0013) Single FV-4773-2) active failure proof secondary isolation is provided.

FV-4772-1 Failure to close on Injection None. The spay pump minimum flow line

& demand must be isolated prior to switchover to FV-4772-2 recirculation. If either minimum flow line is (FV-4773-1 not isolated, the spray pumps are stopped

& The secondary containment boundary is FV-4773-2) maintained by check valves CT-0065 and CT-0094 (CT-0042 and CT-0013) Single active failure proof secondary isolation is provided.

CT-0082 Failure to close on Injection None. The spray pump eductor line is not

& demand required to be isolated with the pump CT-0072 running. Failure of the check valve is not (CT-0031 assumed coincident with any single active

& failure which requires the pumps to be CT-0020) stopped. Single active failure proof secondary isolation is provided by the check valves in the pump discharge.

HV-4758 Failure to close on Switchover to Recirculation None. RWST is isolated form spray pump (HV-4759) demand (or Train failure) suction. Check valve CT-0077 (CT-0025) is in series. Redundant, single active failure proof secondary isolation is provided

[11 Valves powered by Class IE Train A (valves powered by Class lE Train B)

[2] See CPSES FSAR Figure 6 2.2-1

I, Attachment I to TXX-03040 Page 20 of 24 4.4 Figures

REFERENCE:

FSAR FICURE 6.3-1 CCP SUCTION 515 TES T EAgER ASGA nHPHX-R jIA COL c3LEO SI, I I I T6 UP I

8T30A F.O.

rl 8818A

• PENETRATION

,Mf"-O004-'

0809A

'TPAIN A

-I-I LWNA--

MNA

-- M -

TRAIN B C?ýT EG TRAIN Aý TRAIN A I 8958A I TRAI 8T00AI RCS LOOP 2

.- 882 TRA N HOTLEO8'1>

RCS LOOPZ 99 81 rSIS TEST TRICHEADER S8840 8 TRAIN LIOP 3 I M IN IIIIDII,_ L. .

j 8949C -PENETRATION MM"r-0023 T

I 4 8 COLDLEO SI <1 RCS LOOP3 aar8C SIS TEST HEADER 8I> TRAN S0 TRAIN Bý ITRAIN8005 FO i89588.. .

TRAIN889OB I-LOOP 4 7j: I1-, F.0.

I CO -

-I=-- IPENETRATION I AI TRAIN0 RCS LOOP 4 T

87305 S TRAIN B i "

S~TRAZIA

.... 1 IN ft (88095\

NT O OTSD i ¢NE~4 A '1-- Is 8

I TRAIN NO 2iL-- I PENETRATION TRAIN 8 I PR6,;I-SP )"

I MS-2 SUCTION r STRAIN I 8

PENETRATION TýRAINa Ms-t COi7NTAINMENT CONTAINMIENIT SIMP LJFIED ECCS FLOW DIAGRAM

• 1. LAR-02-10 FIGURE 1 dsOOOOrn.dgn to TXX-03040 Page 21 of24 REFERENCC:

FSAR FIGURE 6.2.2-1 L.FlED CONTAINMENT LAR-02-10 SPRAY DIAGRAM FIGURE 2 O)U~vurnIo.

dsOOOOrn.dgn to TXX-03040 Page 22 of 24 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 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 Overall protection system performance will remain within the bounds of the previously performed accident analyses since there are no hardware changes. 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.

The proposed changes will not involve a significant increase in the probability of any event initiators. 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 The proposed change does not involve any physical alteration of the units. No new equipment is being introduced, and installed equipment is not being operated in a new or different manner.

There are no setpoints at which protective or mitigative actions are initiated that are affected by the proposed change. The proposed change will not alter the manner in which equipment operation is initiated, nor will the function demands on credited equipment be changed. No alteration in the procedures, which ensure the unit remains within analyzed limits, is proposed, and no change is being made to procedures relied upon to respond to an off-normal event. As such, no new failure modes are being introduced. The proposed change does not alter to TXX-03040 Page 23 of 24 assumptions made in the safety analyses.

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 change will not adversely affect operation of plant equipment and will not result in a change to the setpoints at which protective actions are initiated. 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 10 CFR 50, Appendix A, General Design Criteria (GDC) 54, "Systems penetrating containment" 10 CFR 50, Appendix A, General Design Criteria (GDC) 55, "Reactor coolant pressure boundary penetrating containment" 10 CFR 50, Appendix A, General Design Criteria (GDC) 56, "Primary containment isolation" 10 CFR 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors" 10 CFR 50.36, Technical specifications NUREG -0737,Section III.D.1.1 Post TMI - Primary Coolant Sources Outside the Containment Structure to TXX-03040 Page 24 of 24 CPSES Units 1 and 2 Technical Specifications - Section 5.5.2 Primary Coolant Sources Outside Containment 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 deletes several of the Surveillance Requirements associated with Containment Isolation Valves. 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 10CFR20, 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 IOCFR51.22 (c)(9).

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

7.0 REFERENCES

As indicated throughout the Description and Assessment.

ATTACHMENT 2 TO TXX-03040 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKUP)

Page 3.6-15 to TXX-03040 Page 2 of 2 Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.12 Safety ineion valves. 8809A, 8091,3and 8840 shall he In accorda.nce. with lea;-k testded to- beR within limits with a gar, at a pressure Ane the Containment l *essthan-PH, 18.3 psig, or with water at a pressure not Leakagý-Rate le~ss th;an 1.IPa.- Test~ Prg9am Not used.

SR 3.6.3.13 Containment spray valves HV-776, HV-1777, CT_112, In accordance with and CT- 415 shal be leak tested to be within limits with the Gontainmen water at a pressure net less than 1.1 P,. LeakageRate Not used. Testing Program COMANCHE PEAK - UNITS 1 AND 2 3.6-15 Amendment No. 64

ATTACHMENT 3 TO TXX-03040 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARKUP)

(For Information Only)

Page B 3.6-29 to TXX-03040 Page 2 of 2 Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.10 REQUIREMENTS (continued)

Not used.

SR 3.6.3.11 Not used.

SR 3.6 3.12 and SR 3.6.3 13 For 6pecific system configurations, credit may be taken for a 30 day water seal tha;t will be maintained to prevent containment atmosphere leakage through the penetration to the envir.n.m.ent. The following isalist o the containment isolation valvos that meet this system configurationand the Ma;ximum Allowed Leakage Rate (MAILR) required to- maintain the wator ea! for-3 ,days.

V/*h11A, No* M/AI RI','lr 1-8809A 77 I-8809B 77 2- 8809A 75 2-8809B 73 4-8840 2577 2 -88!.0 2382 CT 142 4734 CT- 45 4731 HV1-776 4734 HV-1777 4734 The surveillance) testing for measuring leakage rates, as specGified inthe Containment Leakage Rate Testing Program, is consistent with Reg.

Guide 1.163, 1995 (Ref. 11) and the requiremts Of Option Bet 1 CF=R5O Appendix J(Ref. 10).

Not used.

SR 3.6.3.13 Not used.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.6-29 Amendment No. r94

ATTACHMENT 4 TO TXX-03040 RETYPED TECHNICAL SPECIFICATION CHANGES Page 3.6-15 to TXX-03040 Page 2 of 2 Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.12 Not used.

SR 3.6.3.13 Not used.

COMANCHE PEAK - UNITS 1 AND 2 3.6-15 Amendment No.

ATTACHMENT 5 TO TXX-03040 RETYPED TECHNICAL SPECIFICATION BASES CHANGES (For Information Only)

Page B 3.6-29 to TXX-03040 Page 2 of 2 Containment Isolation Valves B 3.6.3 BASES SURVEILLANCE SR 3.6.3.10 REQUIREMENTS (continued)

Not used.

SR 3.6.3.11 Not used.

SR 3.6.3.12 Not used.

SR 3 6 3.13 Not used.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.6-29 Amendment No.

ATTACHMENT 6 TO TXX-03040 FINAL SAFETY ANALYSIS REPORT PAGES (MARKUP)

(For Information Only)

Pages 6.2-57 Table 6.2.4-1 (Sheet 4) No Change Table 6.2.4-1 (Sheet 5) No Change Table 6.2.4-2 (Sheet 3)

Table 6.2.4-2 (Sheet 4)

Table 6.2.4-2 (Sheet 5)

Table 6.2.4-2 (Sheet 6)

Table 6.2.4-2 (Sheet 10)

Table 6.2.4-2 (Sheet 11)

Table 6.2.4-3 (Sheet 4 of 13) No Change Table 6.2.4-3 (Sheet 6 of 13) No Change Table 6.2.4-3 (Sheet 7 of 13) No Change Table 6.2.4-4 No Change Table 6.2.4-6 (Sheet 7) No Change Table 6.2.4-6 (Sheet 9) No Change Table 6.2.4-6 (Sheet 10) No Change Figure 6.3-2, Sheet 1 No Change Figure 6.3-2, Sheet 2 No Change Notes to Figure 6.3-2 (Sheet 1 of 16) No Change Notes to Figure 6.3-2 (Sheet 2 of 16) No Change Notes to Figure 6.3-2 (Sheet 3 of 16)

Notes to Figure 6.3-2 (Sheet 4 of 16) No Change

CPSES/FSAR function of the Containment isolation barriers (i.e., Containment isolation valves) assuming a "P" signal has occurred.

6.2.4.4 Tests and Inspections A rigorous program of tests and inspections is performed in accordance with 10 CFR Part 50, Appendix J, Option B, to ensure Containment Isolation System pressure integrity, leakage rate, and reliability of operation. Subsection 6.2.6 gives a detailed description.

These tests ensure that the leakages from the Containment Isolation System are held within allowable Appendix J, Option B leakage rate limits. Furthermore, these tests verify the operability of the Containment isolation valving. Detailed test procedures utilized and results of tests performed are provided following completion of the tests.

Table 6.2.4-2 list the isolation valves provided for each penetration and indicates the direction in which the isolation valves will be tested. The testing arrangement for containment isolation valves will be controlled via administrative procedures and as described in FSAR Section 6.2.4 and 6.2.6.

All containment penetrations that utilize expansion bellows can be tested at Pa. Table 6.2.4-2 lists all the containment penetrations which are part of fluid system process and instrumentation piping and shows the type of local leakage testing for each penetration.

Typical electrical penetration assembly is shown in Figure 3.8-8. List of all electrical penetration assemblies is shown on Figure 8.3-16. Testing of electrical penetration assemblies is described in Section 6.2.6.

Type C tests are performed on Containment isolation valves as indicated in Table 6.2.4-2.

Specific exemptions from Type C testing are provided as footnotes to the table. In general these justifications include but are not limited to:

closed systems meeting the requirements of NUREG-0800 Section 6.2.4, 11.6 paragraph-O hand .

valves in systems which are inservice post accident at a pressure in excess of containment design pressure.

valves in systems which are water filled for a period of 30 days following an accident.

Figure 6.2.4-1 shows the arrangement of test connections and test vent which permit the isolation valves to be leak tested. During testing the test vent (TV) connection is open and the pressure is applied through the test connection (TC). Test gas is applied at each test connection to establish a test volume in the piping so that the valve is exposed to gas at Containment calculated peak internal pressure. Equipment is laid out in order to minimize the size of the test volume. When necessary, test vents are supplied to ensure that the side of the valve opposite to the test gas is at ambient pressure during the test.

Valves are tested in the direction of leakage from the Containment, i.e., from the center of the Containment outwards, with the following exceptions:

6.2-57 Amendment 97 February 1, 2001

CPSESIFSAR FOR INFORMATION ONLY TABLE 6 2 4-1 (Sheet 4)

CONTAINMENT ISOLATION VALVING APPLICATION Isolation Line NRC General Valving Engineered FSAR Size Design Critenon Arrangement Fluid Safeguard Figure Penetration Number System Line or Service (Inches) or Reg Guide Met (Fig 6 2 4-1) Contained Feature Item Number 12 55 11 Water No 54-6 33 MII-2 RH R H R From Hot Leg Loop #4 RH R H R From Hot Leg Loop #1 12 55 11 Water No 54-6 34 MII-3 35 MIA~ 8 Wdta 55 and #2 36

'and #4 37 MII-6 Spare 12 50 38 MII-7 Spare 24 50 39 MII-8 Spare 24 50 Maintenance Penetration 2 56 31 Air No 94-6 40a MII-9(A) 1 1/2 56 31 Air No 9 4-6 40b MII-9(B) Maintenance Penetration 2 56 31 Air No 94-6 40c MII-9(C) Maintenance Penetration RC Reactor Make Up Water to 3 56 4 Water No 5 1-1 41 MIll-1 Pressurizer Relief Tank &R C Pump Stand Pipe 5.1-1 41a MIll-1 RC Penetration Thermal Relief 3/4 56 4 Water No 3 55 9 Water Yes 6 3-1 42 MIII-2 SI S.I. To Cold Leg Loops #1, #2,

1. 3, &#4 8 Water Yes 6 3-1 43 MIII-3 SI S I to R C System Hot Leg 4 55 Loops #2 &#3 4 55 8 Water Yes 6.3.1 44 MIII-4 SI S I. To R C System Hot Leg (Sh. 3)

Loops #1 &#4 55 33 Water Yes 63-1 45 MIll-5 SI S I To RC. System Cold Leg 4 Loops #1. #2, #3 &#4 CS Charging Line to Regenerative 3 55 25 Water No 9.3-10 46 MIII-6 Heat Exchanger 2 55 15 Water No 9 3-10 47 MIll-7 CS Seal Injection to R C. Pump (Loop #1) 2 55 15 Water No 93-10 48 MIll-8 CS Seal Injection to R C. Pump (Loop #2) 2 55 15 Water No 93-10 49 MIII-9 CS Seal Injection to R C Pump (Loop #3) 2 55 15 Water No 93-10 50 MIll-10 CS Seal Injection to RC. Pump (Loop #4) 2 55 24 Water No 9 3-10 51 MIll-11 CS Seal Water Return And Excess Letdown AMENDMENT 97 February 1,2001

CPSESIFSAR FOR INFORMATION ONLY TABLE 6.2.4-1 (Sheet 5)

CONTAINMENT ISOLATION VALVING APPLICATION Isolation Line NRC General Valving Engineered FSAR Penetration Size Design Criterion Arrangement Fluid Safeguard Figure Item Number System Line or Service (Inches) or Reg Guide Met (Fig 6 2 4-1) Contained Feature Number 52 MII1-12 WP R C D T Heat Exchanger To 3 56 27 Water No 11.2-2 Waste Hold Up Tank 52a MIII-12 WP Penetration Thermal Relief 3/4 56 27 Water No 11 2-2 53 MIII-13 Spare 10 50 CT i-o1mdmeS pray TFS-pray *t 56 25 Header (TR. B) YN CT tCoT6inmeFii~ifpray to-Spray 16 56 25 Header (TR, A)

Refueling Water Purification to 4 14 Air* 91-13 56 MII1-16 SF 56 No Refueling Cavity 57 MII1-17 LT Containment Leak Rate Test 10 56 31 Air No 9 4-6 58 Mill-18 VA Hydrogen Purge Supply 12 56 20 Air No 94-6 59 MII1-19 VA Hydrogen Purge Exhaust 12 56 21 Air No 9.4-6 60 MIII-20 DD Demineralized Water Supply 3 56 5 Water No 92-5 No 60a MIll-20 DD Penetration Thermal Relief 3/4 56 5 Water 9.2-5 No No 9 3-5 61 MIII-21 VD Containment Sump Pump 4 56 22 Water Discharge No 93-5 61a MIII-21 VD Penetration Thermal Relief 3/4 56 22 Water 62 Mlll-22 CI Instrument Air To Containment 3 56 7 Air 9 3-1 63 MVI -23 S1 WRfik ToTI- Lo#o3ps#2& T1 50

1. 3 (Shl3) 64 MIII-24 Spare 12 50 65 MiI1-25 Spare 12 50 66 Mi1-26 Spare 12 50 67 MIII-27 SF Refueling Cavity To Refueling 4 56 14 Air* No 9.1-13 Water Purification Pump 68 Mill-28 Spare 12 50 69 MIII-29 Spare 12 56 70 MIII-30 LT Containment Leak Rate Test 12 56 31 Air No 94-6 Pressurization 71 MIII-31 SF Refueling Cavity Skimmer 3 56 14 Air No 91-13 Pump Discharge (System no longer used) 72 Mi1-32 Spare 12 50 73 MIV-1(a) MS Sample From Steam Generator 3/4 57 35 Sat. Water No 10 3-1

1. 1 AMENDMENT 97 February 1,2001

CPSES/FSAR TABLE 6 2.4-2 (Sheet 3)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 8)

Length of Pipe U1/U2 Isolation Location in Type of Direction to Outermost Method of Valve No Relation to Leakage of Test Isolation Valve Actuation Item (Note 6) Containment Rate Test (Note 10) Valve (ft) Type/Operator Primary Secondary HV-2492B Outside Note I N/A 50'/54'-7" Gate/Motor Remote Manual Local Manual 22b FW-104 Outside Note 1 N/A Globe/Manual Local Manual NIA 22c FV-2194 Outside Note 1 N/A 29'-6"/30'-9" Globe/Air Auto close Remote Manual 22d HV-2186 Outside Note 1 N/A 12'-8"/11'-8" Globe/Air Auto close Remote Manual 23 HV-2136 Outside Note 1 N/A 10'/15*-4" Gate/Hydr. Auto close Remote Manual N2 Actuator 50'/50'-5" 24a HV-2493A Outside Note I N/A Gate/Motor Remote Manual Local Manual HV-2493B Outside Note 1 N/A 50'/53'-5" Gate/Motor Remote Manual Local Manual 24b FW-102 Outside Note 1 N/A Globe/Manual Local Manual N/A 24c FV-2195 Outside Note 1 N/A 30'-9"/33'-0" Globe/Air Auto close Remote Manual 24d HV-2187 Outside Note 1 N/A 12'-8"/l1V-9" Globe/Air Auto close Remote Manual 25 HV-2137 Outside Note 1 N/A 10/15'-3" Gate/Hydr. Auto close Remote Manual N2 Actuator 26 26a HV-2494A Outside Note I N/A 507/50'-4" Gate/Motor Remote Manual Local Manual HV-2494B Outside Note 1 N/A 50'/53'8" Gate/Motor Remote Manual Local Manual 26b FW-108 Outside Note 1 N/A Globe/Manual Local Manual N/A 26c FV-2196 Outside Note 1 N/A 31'-10"/33'-1" Globe/Air Auto close Remote Manual 26d HV-2188 Outside Note 1 N/A 12'-8"/11'-9" Globe/Air Auto close Remote Manual 27 HV-2399 Outside Note I N/A 17/16'-6" Globe/Air Auto close Remote Manual 28 HV-2398 Outside Note I N/A 17'/16'-2" Globe/Air Auto close Remote Manual 29 HV-2397 Outside Note 1 NIA 17'116'-0" Globe/Air Auto close Remote Manual 30 HV-2400 Outside Note I N/A 17/16'-8" Globe/Air Auto close Remote Manual 31 A N/A 32 8152 Outside C YES 7'/7'-7" Globe/Air Auto close Remote Manual 8160 Inside C YES Globe/Air Auto close Remote Manual 33 8701B Inside Note 17 NIA N/A Gate/Motor Remote Manual Remote Manual 8708B Inside Note 17 N/A N/A Relief Self-Actuated N/A 34 8701A Inside Note 17 N/A N/A Gate/Motor Remote Manual Local Manual 8708A Inside Note 17 N/A N/A Relief Self-Actuated N/A Note 3 8'/9'-1 1" Gate/Motor Remote Manual Local Manual 35 8809A Outside 8818A Inside Note 11 N/A Check Self-Actuated N/A 8818B Inside Note 11 NIA Check Self-Actuated N/A Amendment 98

CPSESIFSAR TABLE 6 2 4-2 (Sheet 4)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 8)

Length of Pipe U1I/U2 Isolation Location in Type of Direction to Outermost Method of Relation to Leakage of Test Isolation Valve Actuation Valve No Primary (Note 6 Containment Rate Test (Note 10) Valve (ft) Type/Operator Secondary Item 8890A Inside C YES Globe/Air Auto close Remote Manual 3'/5'-9" Remote Manual Local Manual 36 8809B Outside Note 3 -YE-SN/A Gate/Motor Inside Note 11 N/A Check Self-Actuated N/A 8818C Inside Note 11 N/A Check Self-Actuated N/A 8818D Inside C YES Globe/Air Auto close Remote Manual 8890B 37 A N/A 38 A N/A 39 A N/A B N/A N/A N/A N/A N/A 40a N/A NIA N/A B N/A N/A N/A N/A N/A 40b N/A N/A B N/A N/A N/A N/A N/A 40c N/A Inside C YES Check Self-Actuated N/A 41 8046 Outside C YES 16'/18'-1" Diaphragm/Air Auto close Remote Manual 8047 Outside C YES Relief Self-Actuated N/A 41a RC-035 Inside Note 2 N/A - Check Self-Actuated N/A 42 8815 Note 7 NIA 13/16-1" Gate/Motor Remote Manual N/A 8801A Outside Outside Note 7 NIA 131/161-1" Gate/Motor Remote Manual N/A 8801B Inside Note 2 N/A - Globe/Air Auto close Remote Manual 8843 Outside Note 12 N/A 11713'-0" Gate/Motor Remote Manual Local Manual 43 8802A Inside Note 12 N/A - Check Self-Actuated N/A SI-8905B Inside Note 12 N/A - Check Self-Actuated N/A SI-8905C Note 12 N/A Globe/Air Auto close Remote Manual 8881 Inside -

Outside Note 12 N/A 127/13'-9" Gate/Motor Remote Manual Local Manual 44 8802B Inside Note 12 N/A Check Self-Actuated N/A SI-8905A Note 12 NIA Check Self-Actuated N/A SI-8905D Inside Inside Note 12 NIA Globe/Air Auto close Remote Manual 8824 Note 13 N/A 16'/19'-1" Gate/Motor Remote Manual Local Manual 45 8835 Outside Inside Note 13 N/A Check Self-Actuated N/A SI-8819A Inside Note 13 N/A - Check Self-Actuated N/A SI-8819B Note 13 N/A - Check Self-Actuated N/A SI-8819C Inside Note 13 N/A - Check Self-Actuated N/A SI-8819D Inside Note 13 N/A - Globe/Air Auto close Remote Manual 8823 Inside C YES 37/1 07" Gate/Motor Auto close Remote Manual 46 8105 Outside Amendment 98

CPSESIFSAR TABLE 6 2 4-2 (Sheet 5)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 8)

Length of Pipe UI/U2 Isolation Location in Type of Direction to Outermost Method of Valve No Relation to Leakage of Test Isolation Valve Actuation (Note 6 Containment Rate Test (Note 10) Valve (ft) Type/Operator Primary Secondary Item 8381 Inside C YES Check Self-Actuated NIA Inside Note 4 N/A Check Self-Actuated N/A 47 CS-8368A Note 4 N/A 67/15'-7" Globe/Motor Remote Manual Local Manual 8351A Outside Inside Note 4 N/A Check Self-Actuated N/A 48 CS-8368B Note 4 N/A Globe/Motor Remote Manual Local Manual 8351B Outside 7/79'-9" Note 4 NIA Check Self-Actuated N/A 49 CS-8368C Inside Outside Note 4 N/A 27/11V-11" Globe/Motor Remote Manual Local Manual 8351C Inside Note 4 N/A Check Self-Actuated N/A 50 CS-8368D Outside Note 4 N/A 10710'-3" Globe/Motor Remote Manual Local Manual 8351D Outside C YES 777'-1" Globe/Motor Auto close Remote Manual 51 8100 C YES Globe/Motor Auto close Remote Manual 8112 Inside C YES Check Self-Actuated N/A CS-8180 Inside Inside C YES Diaph /Air Auto close Remote Manual 52 7136 Outside C YES 30/23-11" Globe/Air Auto close Remote Manual LCV-1003 Outside C YES 30'/24'-2" Diaph /Manual Local Manual N/A 7135 C YES Relief Self-Actuated N/A 52a WP-7176 Outside 53 A N/A Note 3 15716'-7" Gate/Motor Remote Manual N/A 54 HV-4777 Outside YEsN-*

Note 3 Check Self-Actuated N/A CT-145 Inside Note 3 9/16'-9" Gate/Motor Remote Manual NIA 55 HV-4776 Outside Note 3 Check Self-Actuated N/A CT-142 Inside C YES 11718'-6" Diaphragm/Man. Local Manual N/A 56 SF-01I Outside C YES Diaphragm/Man Local Manual N/A SF-012 Inside B N/A N/A N/A N/A N/A 57 N/A NIA 5'-6"/l'-5" Butterfly/Motor Auto close Remote Manual 58 HV-5542 Outside C YES C NO Butterfly/Motor Auto close Remote Manual HV-5543 Inside C NO - Butterly/Motor Auto close Remote Manual HV-5563 Inside C YES 5'-6"/5'-10" Butterfly/Motor Auto close Remote Manual 59 HV-5540 Outside Inside C NO - Butterfly/Motor Auto close Remote Manual HV.5541 C NO - Butterfly/Motor Auto close Remote Manual HV-5562 Inside Outside C YES 12714'-8" Globe/Air Auto close Remote Manual 60 HV-5365 C YES - Globe/Air Auto close Remote Manual HV-5366 Inside Amendment 98 February 1, 2001

CPSESIFSAR TABLE 6 2 4-2 (Sheet 6)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 8)

Length of Pipe U1/1U2 Isolation Location in Type of Direction to Outermost Method of Valve No Relation to Leakage of Test Isolation Valve Actuation Containment Rate Test (Note 10) Valve (ft) Type/Operator Primary Secondary Item (Note 6) 60a DD-430 Outside C YES Relief Self-Actuated N/A Outside C YES 14'/16'-2" Diaphragm/Air Auto close Remote Manual 61 HV-5157 Inside C NO Diaphragm/Air Auto close Remote Manual HV-5158 YES Relief Self-Actuated NIA 61a 1VD-907 Outside C (2VD-0896)

Outside C YES 14717'-3" Globe/Air Auto close Remote Manual 62 HV-3487 C YES Check Self-Actuated N/A CI-030 Inside Note 3 Y-ESNA 26'/27'-8" Gate/Motor Remote Manual Local Manual 63 8840 Outside Inside C YES Globe/Air Auto close Remote Manual 8825 Note 14 N/A Check Self-Actuated NIA 8841A Inside Note 14 N/A Check Self-Actuated N/A 8841B Inside 64 A N/A 65 A N/A 66 A N/A Inside C YES Diaphragm/Man, Local Manual N/A 67 SF-021 C YES 11/8'-2" Diaphragm/Man Local Manual N/A SF-022 Outside 68 A 69 A N/A B N/A N/A N/A N/A 70 N/A N/A C YES Diaphragm/Man Local Manual N/A 71 ISF-053 Inside (2SF-055)

YES 7'/4'-10" Diaphragm/Man Local Manual N/A 1SF-054 Outside C (2SF-056) 72 A N/A Outside Note 1 N/A 51-3"/1 1'-8" Globe/Air Auto close Remote Manual 73 HV-2405 Outside C YES Angle/Air Auto close Remote Manual 74 HV-4170 6'-0"/8W-0" Inside C YES Angle/Air Auto close Remote Manual HV-4168 Inside C YES Angle/Air Auto close Remote Manual HV-4169 C YES Relief Self-Actuated N/A 74a PS-503 Outside 75 A N/A Note I N/A Globe/Air Auto close Remote Manual 76 HV-2406 Outside C YES Angle/Air Auto close Remote Manual 77 HV-4167 Outside Inside C YES Angle/Air Auto close Remote Manual HV-4166 Amendment 98

CPSESIFSAR TABLE 6 2 4-2 (Sheet 10)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 8)

Length of Pipe U1/U2 Isolation Location in Type of Direction to Outermost Method of Valve No Relation to Leakage of Test Isolation Valve Actuation Item (Note 6) Containment Rate Test (Note 10) Valve (ft) Type/Operator Primary Secondary 129 Bellows N/A B N/A N/A N/A N/A N/A Flange N/A B NIA N/A N/A N/A N/A 130 1BS-0016 Outside Note 1 N/A Globe/Manual Local Manual N/A 1BS-0017 Outside Note 1 NIA Globe/Manual Local Manual N/A 131 1BS-0030 Inside C No Ball/Hydraulic Local Hydraulic NIA 1BS-0025 Inside C Yes Ball/Hydraulic Local Hydraulic N/A 131a 1BS-0056 Inside C No Ball/Manual Local Manual N/A 1BS-0044 Inside C No Ball/Manual Local Manual N/A 1BS-0029 Inside C Yes Ball/Manual Local Manual NIA IBS-0015 Outside C Yes 1 Ball/Manual Local Manual N/A 132 BS-0202 Inside C No 1 Ball/Manual Local Manual N/A BS-0203 Inside C Yes 1 Ball/Manual Local Manual N/A 133 2BS-0016 Inside C No 1 Globe/Manual Local Manual N/A 2BS-0017 Inside C No Globe/Manual Local Manual NIA 2BS-0039 Inside C Yes Globe/Manual Local Manual N/A 2BS-0040 Inside C Yes Globe/Manual Local Manual N/A 134 2BS-0030 Inside C No Ball/Hydraulic Local Hydraulic N/A 2BS-0025 Outside C Yes Ball/Hydraulic Local Hydraulic N/A 134a 2BS-0056 Inside C No Relief/Spring Closed Local Manual NIA 2BS-0044 Inside C No Relief/Spring Closed Local Manual N/A 2BS-0029 Inside C Yes Relief/Spring Closed Local Manual N/A 2BS-0015 Outside C Yes Relief/Spring Closed Local Manual NIA NOTES

1. These are closed systems which meet the requirements of NUREG-0800, Section 6 2 4,11 6, paragraph o. These valves are therefore not required to be tested.

2 These valves Inside containment are part of closed systems outside containment which are In service post-accident at a pressure in excess of containment design pressure and satisfy single active failure criteria These valves are therefore not required to be tested 3 These are closed systems outside containment which are in service post-accident and have a water filled loop seal on the containment side of the valves, for-a Fcricd greater than 30 dac flb,.owg-the-acidenb These alves ir itf6.p'eh~o~a6 clos*dpro~ldlng'thrrd baririt ont.ainment le'akaeAtwir-el i maintained bo~th nsrdend outsdte c6ntalnmentl These valves are therefore not required to be leakrate tested, with water at a p..o..u.r. of not less than..4-

.- 1 or air at a prossuro of PG

4. These ESF valves are normally open and remain open during post-accident conditions Post-accident they are continually pressurized in excess of containment pressure from an ESF source which meets the single active failure criteria These valves are therefore not to be tested Amendment 98 February 1, 2001

CPSESIFSAR TABLE 6 2 4-2 (Sheet 11)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 8)

5. This valve is not required to be leakage tested per 10 CFR 50 Appendix J since the downstream pressure indicator sensing element is dead-ended, and is hydrostatically tested to 1 5 times the design pressure of the pipe, thus providing a leaktight bamer similar to vent and drain connections having capped ends and under administrative controls.

6 Unit 1 and Unit 2 Tag Numbers are generally the same except for the prefix or as otherwise noted.

7. These are parallel ESF valves that are normally closed, but are designed to open during post-accident conditions. Failure of one valve to open will not prevent system pressurization on both sides of both valves In excess of containment pressure. These valves are therefore not required to be tested 8 Table does not list local vent, drain and test connections as they are a special class of containment Isolation valve per FSAR Section 6 2 4 1 3 These valves are locked closed and capped to meet containment Isolation cntena if located within the pressure boundary These valves do not require Type C testing

9. These penetrations are normally closed and upon Initial ESF actuation remain closed with a water seal from the RWST. During the ESF recirculation phases, the RHR and Containment Spray suction side isolation valves are open and supplying water to their respective ESF pumps Water in the containment sump provides a seal between the containment atmosphere (post-accident) and these valves

10. "YES" signifies that the isolation valve test pressure is applied In the same direction as the pressure existing when the valve Is required to perform its containment isolation function "NO" signifies that the Isolation valve test pressure is not applied in the same direction as the pressure existing when the valve is required to perform its safety function.

11. This penetration is an engineered safety feature system supplying RHR pump flow (valves opened) to the cold legs of the RCS during cold leg injection and cold leg recirculation modes of operation During hot leg recirculation this penetration Is not In service (valves closed) but is pressurized by the residual heat removal pumps to a pressure in excess of 1.1 times the containment design pressure. in addition, the out I erated valves a e Gtested, thus*any I-eakage-at-the-penetrat n-wond he-motor-operated-vatves- The"outSde cfiotai'rirent mot6*ýoperatidl°V1,*l*,nd the*l6sed sStes ousiade contaInnimentprovid6etw b6und.riesln'additionit6thzsalv? These valves are therefore not required to be Type C tested.

12. This penetration is an Engineered Safety Feature System supplying SI pump flow (valves opened) to the hot legs of the RCS dunng hot leg recirculation mode of operation During cold leg injection and cold leg recirculation this penetration is not in service (valves closed) but Is pressurized by the safety injection pumps to a pressure in excess of 1.1 times the containment design pressure This ensures that leakage path for containment atmosphere does not exist during a LOCA Therefore, these valves are not required to be Type C tested

13. This penetration is an Engineered Safety Feature System supplying SI pump flow (valves opened) to the cold legs of the RCS during cold leg Injection and cold leg recirculation modes of operation. During hot leg recirculation this penetration is not in service (valves closed) but is pressurized by the safety injection pumps to a pressure In excess of containment design pressure This ensures that a leakage path for containment atmosphere does not exist dunng a LOCA. Therefore, these valves are not required to be Type C tested.

14. This penetration is an Engineered Safety Feature System supplying RHR pump flow (valves opened) to the hot legs of the RCS during hot leg recirculation mode of operation. Dunng cold leg injection and cold leg rocirculation this penetration is not in service (valve closed) but is pressunzed by the residual heat removal pumps to a pressure In excess of containment design pressure -n-addtlon-the-outside-conta imntmotcr valve-ls-Tye--Csted*,-thusanu,.eakage-t-the peeetrato* woeuld be enta'ied at t-he Mte- operated ,v*,ve Durffig c61d leg recirculatio*,l thi* pen'tra2on is"otTns6rilcWb-it isolatd by aminimum of two idditf6hal alvesut$Ide" 6htahi~iiht* These valves are therefore not required to be Type C tested

15. Due to the piping arrangement, these valves cannot be tested individually; as such the leak test will result in a combined leak rate for both isolation valves under test conditions.

16. These valves function as local manual Isolation for penetrations MI-1, MI-4 following exhaustion of air accumulators for HV-2452-1, -2 (see FSAR Section 9.3.1.2 discussion regarding accumulators for main steam supply to AFW pump turbine)

17. These valves do not require Appendix J Type C leak rate testing. An effective fluid seal on these penetrations Is provided by the suction sources to the residual heat removal pumps during and following an accident In addition, these containment isolation valves are non-automatic, are not required to operate post-accident and are located inside containment. See Section 6.2.4.1.3, items 3 and 5 for details Amendment 98

CPSES/FSAR FOR INFORMATION ONLY TABLE 6 2 4-3 (Sheet 4 of 13)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 1)

Valve Position Containment Valve Power Valve Closure Item Isolation Signal Normal Shutdown Post-Accident Failure Time (Sec) Power Source Remarks Closed Closed Closed 5 A/B Remote Manual Isolation 28 Phase A Opened Satisfies CDC-57 29 Phase A Opened Closed Closed Closed 5 A/B Remote Manual Isolation Satisfies CDC-57 Closed Closed Closed 5 A/B Remote Manual Isolation 30 Phase A Opened Satisfies CDC-57 31 32 Phase A Opened Closed Closed Closed 10 B Phase A Opened Closed Closed Closed 10 A Closed/Opened Opened Closed FAI NIA B Relief valve Is 33 Closed Closed Closed N/A NIA closed In backfiow direction at all times Opened Closed FAI N/A A Relief valve is 34 Closed/Opened Closed Closed Closed N/A N/A closed in backflow direction at all times fR/A Up-ened/06ls' NA ff/s 35 Op*ened bOpened A-r -operate-d -valve-00 Closed test line 36

• poened Open*eCd FA B bpenediClos-ed P ha-seA CIose d 0s6-e Is B Aro-p-e d -valv'e o

test line 37 38 39 N/A N/A N/A N/A N/A Flanged 40(a) N/A N/A N/A N/A N/A N/A NIA Flanged 40(b) N/A N/A N/A NIA N/A N/A N/A N/A Flanged 40(c) N/A N/A Closed Closed Check Valve 41 Closed Closed Closed Closed Closed 10 B Phase A Amendment 97 February 1, 2001

CPSESIFSAR FOR INFORMATION ONLY TABLE 6 2 4-3 (Sheet 6 of 13)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 1)

Valve Position Containment Valve Power Valve Closure Isolation Signal Post-Accident Failure Time (Sec) Power Source Remarks Item Normal Shutdown 49 Opened Opened/Closed Opened Check Valve Opened Opened/Closed Open FAI N/A B Opened/Closed Opened Check Valve 50 Opened Opened Opened/Closed Open FAI N/A B 51 Phase A Opened Opened/Closed Closed FAI 10 B (8100)

Phase A Opened Opened/Closed Closed FAI 10 A (8112)

Closed Closed Open/Closed Thermal Relief Check Valve Opened Opened Closed Closed 10 B 52 Phase A Opened Opened Closed Closed 10 A Phase A Closed N/A N/A Manual Valve Closed Closed Open/Closed NIA N/A Thermal Relief Valve 52a Closed Closed 53 54 CIose WJA B C-h-WVale Closed 'it oe i16_sd/bOpen-ed FA'I Closed Closed Closed/ONA Closed N/A N/A 56 Closed Closed Opened/Closed Closed N/A NIA Closed N/A N/A N/A N/A N/A 57 N/A N/A Closed/Open FAI N/A B (HV-5542) (Note 3) 58 Containment Closed Closed Vent. Isolation Containment Closed Closed Closed/Open FAI NIA A (HV-5543) (Note 3)

Vent Isolation Closed Closed/Open FAI N/A B (HV-5563) (Note 3)

Containment Closed Vent. Isolation Amendment 97 February 1,2001

CPSESIFSAR FOR INFORMATION ONLY TABLE 6 2 4-3 (Sheet 7 of 13)

CONTAINMENT ISOLATION VALVING APPLICATION (Note 1)

Valve Position Containment Valve Power Valve Closure Item Isolation Signal Normal Shutdown Post-Accident Failure Time (Sec) Power Source Remarks 59 Containment Closed Closed Closed/Open FAI NIA B (HV-5540) (Note 3)

Vent Isolation Containment Closed Closed Closed/Open FAI N/A A (HV-5541) (Note 3)

Vent Isolation Containment Closed Closed Closed/Open FAI N/A B (HV-5562) (Note 3)

Vent Isolation 60 Phase A Closed Opened Closed Closed 5 B Provides automatic fire protection water Phase A Closed Opened Closed Closed 5 A Closed Closed Open/Closed N/A N/A Thermal Relief Valve 60a 61 Phase A Open Closed Closed Closed 5 B Phase A Open Closed Closed Closed 5 A Closed Closed Open/Closed N/A N/A Thermal Relief Valve 61a Open Open Closed/Open Closed 5 B 62 Phase A Open Open Closed/Open Check Valve 63 d Closed dlo-sed/1p FAI iRN PaKlA Ci-sed Wr opeated -valve'on Mest line

'cf*d Closed I C*heck Val cosigd Clo-sediOpenedM 64 65 66 67 Closed Closed Closed N/A NIA Closed Closed Closed N/A N/A 68 69 70 N/A N/A N/A N/A N/A NIA N/A 71 Closed Closed Closed N/A N/A Closed Closed Closed N/A N/A Amendment 97 February 1, 2001

FOR INFORMATION ONLY CPSES/FSAR TABLE 6.2.4-4 PENETRATIONS THAT ARE NOT DRAINED AND VENTED DURING CONTAINMENT INTEGRATED LEAKAGE RATE (TYPE A) TEST **

Item Penetration No. System 33 MII-2 RHR 34 MII-3 RHR 13 II-5 s 42 MIII-2 SI 43 MII-3 SI 44 MIII-4 SI 45 MIlI-5 SI 47* MHI-7 CS 48* MIII-8 CS 49* MII-9 CS 50* Mill-10 CS 92 MIV-7 (b) VA 95 MIV-8 (b) VA 98 MIV-9 (b) VA 101 MIV-10 (b) VA 120* MV-12 CH 120a* MV-13 CH 121* MV-13 CH 121a MV-13 CH 125 MS-1 SI 126 MS-2 SI 127 MS-3 CT 128 MS-4 CT

• Items maybe water filled during Type A testing but are not necessarily water filled post-accident.

• • Type C penetrations, conforming to GDC-57, are not necessarily drained or vented during the Type A test. See Table 6.2.4-1, Items 1 to 30, 73, 76, 79, 82, 111,112, 130 In addition other penetrations not shown on this table may not be vented and drained as discussed in section 6.2.6.1.

Amendment 97 February 1, 2001

CPSES/FSAR FOR INFORMATION ONLY TABLE 6.2.4-6 (Sheet 7)

CLASSIFICATION OF SYSTEMS PATHS PENETRATION CONTAINMENT WALL Penetration Post-Accident Item Number System Normal Operating Function Classification Function 32 MII-1 CS Letdown Line to Letdown Heat non-essential None Exchanger 33 MII-2 RH R.H.R. From Hot Leg Loop #4 non-essential None 34 MII-3 RH R.H.R. From Hot Leg Loop #1 non-essential None T5 TI None essýent ial rejection of cTOnTiwater mito the cold leg loops #l and #2 MII-5 None essent-ial necton of COOling water into

,the cold legjoops #3 and #4 37 MII-6 Spare 38 MII-7 Spare 39 MU-8 Spare 40a MII-9A Maintenance Penetration non-essential None 40b MII-9B Maintenance Penetration non-essential None 40c MII-9C Maintenance Penetration non-essential None Amendment 97 February 1, 2001

CPSES/FSAR FOR INFORMATION ONI y TABLE 6.2.4-6 (Sheet 9)

CLASSIFICATION OF SYSTEMS PATHS PENETRATION CONTAINMENT WALL Penetration Post-Accident Itern Number System Normal Operating Function Classification Function 48 Mill-8 CS Seal Injection to R.C. Pump Essential Seal Water Injection (Loop #2) (Note 2) 49 MIII-9 CS Seal Injection to R.C. Pump Essential Seal Water Injection (Loop #3) (Note 2)

Seal Injection to R.C. Pump Essential Seal Water Injection 50 MIII-10 CS (Loop #4) (Note 2) 51 Mill-1I CS Seal Water Return to R.C. Excess non-essential none Letdown 52 MIII-12 WP R.C.D.T. Heat Exchanger To non-essential Waste Hold Up Tank 52z MIII-12 WP None non-essential none 53 MIII-13 Spare 54 No~ne essential Containment Spray To Spray Header (Train B)

MIII1-14 CT 755 None Containment Spray To Spray Header_(Train A)

Amendment 97 February 1, 2001

CPSES/FSAR FOR INFORMATION ONLY TABLE 6.2.4-6 (Sheet 10)

CLASSIFICATION OF SYSTEMS PATHS PENETRATION CONTAINMENT WALL Penetration Post-Accident Item Number System Normal Operating Function Classification Function 56 MIII-16 SF Refueling Water Purification to non-essential none Refueling Cavity 57 MIII-17 LT None non-essential none 58 MIII- 18 VA None non-essential none 59 MIII-19 VA None non-essential none 60 MIII-20 DD Demineralized Water Supply non-essential none 60a MIII-20 DD None non-essential none 61 MIII-21 VD Containment Sump Pump non-essential none Discharge 61a MIII-21 VD None non-essential none 62 MIII-22 CI Instrument Air to Containment non-essential Post-Accident Sampling 673 MIII-23' TI R.H.R. To Hot Leg Loops ýtse ai

1. 2 & #3 64 MIII-24 Spare Amendment 97 February 1, 2001

I COMANCHE PEAK S E S FOR INFORMATION ONLY FINAL SAFETY ANALYSIS REPORT UNITS 1 and 2 Safety Injection/Residual AMEND)MENT16 Heat Removal System MARCH 31, 1981 Process Flow Diagram FaUnm 6.3-2, Sheet 2

FOR INFORMATION ONLY NOTES TO FIGURE 6.3-2 (Sheet 1 of 16)

MODES OF OPERATION Mode A - Injection This mode presents the process conditions for the case of maximum safeguards, i.e., all pumps operating, following accumulator delivery. Two residual heat removal (RHR) pumps, two safety injection (SI) pumps, and two centrifugal charging (CC) pumps operate, taking suction from the refueling water storage tank and delivering to the reactor through the cold leg connections. Note that the flow from each pump is less than its maximum runout since the pump discharge piping is shared by the two pumps of each subsystem. Note also that the SI pump branch connections to the residual lines are assumed very close to their discharge into the accumulator lines, thereby eliminating any increase in RHR branch line head loss due to the combined flows of the RHR and SI pumps. The RHR line resistance was assumed to be the minimum of the allowable band presented in the limiting pressure drop and elevation head design requirements, allowing maximum RHR injection flow.

Mode B - Cold Leg Recirculation This mode presents the process conditions for the case of cold leg recirculation assuming RHR pump number 2 operating, SI pumps numbers 1 and 2 operating, and CC pumps numbers 1 and 2 operating.

In this mode the safeguards pumps operate in series, with only the RHR pump capable of taking suction from the containment sump. Thye recirculation coolant is then delivered by the RHR pump to both of the SI pumps

FOR INFORMATION ONLY NOTES TO FIGURE 6.3-2 (Sheet 2 of 16)

Which deliver to the reactor through their cold leg connections and to both of the CC pumps which deliver to the reactor through their cold leg connections. The RHR pump also delivers flow directly to the reactor through two cold legs since the RHR discharge cross connect valves are closed when making the transfer from injection to recirculation.

Mode C - Hot Leg Recirculation This mode presents the process conditions for the case of hot leg recirculation, assuming RHR pump number 1 operating, CC pumps numbers 1 and 2 operating, and SI pumps numbers 1 and 2 operating.

In this mode, the safeguards pumps again operate in series with only the RHR pump taking suction from the containment sump. The recirculated coolant is then delivered by the RHR pump to both of the CC pumps which continue to deliver to the reactor through their cold leg connections and to both of the SI pumps which deliver to the reactor through their hot leg connections. The RHR pump also delivers directly to the reactor through two hot leg connections.

NOTES TO FIGURE 6.3-2 (Sheet 3 of 16)

VALVE ALIGNMENT CHART Operational Modes Valve No. A B C 1 0 C C 2 0 C C 3 0 C C 4 0 C C 5 0 C C 6 0 0 0*

0 0 C*

7 8 C C 0 9 C C 0 10 C C C 11 C C C 12 C 0 0 13 C 0 0 14 C C C 15 C C C 16 C C C 17 C C C 18 0 0 0 19 0 0 0 20 C 0 0 21 C 0 0CLO 22 23 0

0 C

C 0 I

24 0 0 C 25 C C 0 0 = OPEN C = CLOSED

• During Mode C one valve to remain open - one closed, no preference, between valves 6 & 7.

Amendment 78 January 15, 1990

FOR INFORMATION ONLY NOTES TO FIGURE 6.3-2 (Sheet 4 of 16)

VALVE ALIGNMENT CHART (Cont' d)

Operational Modes Valve No. A B c V

27 C c C 28 0 C 29 C c 0 30 C C c

31 C C 0o 35 0 0 0

36 0 C Amendment 78 January 15, 1990