ML031360748

Memo, License Amendment Involving Positive Reactivity Additions

ML031360748
Person / Time
Site:	Comanche Peak
Issue date:	05/16/2003
From:	Donohew J NRC/NRR/DLPM/LPD4
To:	Gramm R NRC/NRR/DLPM/LPD4
Jaffe D, NRR/DLPM, 415-1439
References
TAC MB6890, TAC MB6891
Download: ML031360748 (5)

Text

May 16, 2003 MEMORANDUM TO: Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Jack N. Donohew, Senior Project Manager /RA/

Project Directorate IV-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 -

LICENSEES AGREEMENT TO REVISED WORDING IN PROPOSED LICENSE AMENDMENT INVOLVING POSITIVE REACTIVITY ADDITIONS (TAC NOS. MB6890 AND MB6891)

By letter dated December 4, 2002 (TXX-02201), TXU Energy (the licensee) submitted changes to incorporate TSTF-286, Revision 2, into the Technical Specifications (TSs) for Comanche Peak Steam Electric Station (Comanche Peak), Units 1 and 2. The changes would remove restrictions in the TSs on not adding positive reactivity to the core.

In the application, the licensee proposed changes to the Notes to Limiting Conditions for Operation (LCOs) 3.4.5, 3.4.6, 3.4.7, 3.4.8, and 3.9.5, and to Required Actions 3.4.5.D.2, 3.4.6.B.1, 3.4.7.B.1, 3.4.8.B.1, 3.9.3.A.2, 3.9.5.A.1, and 3.9.6.B.1. The licensee had proposed wording in accordance with TSTF-286, Revision 2. In reviewing the proposed changes, the staff has decided that the proposed wording could be made clearer. This is explained below.

In each case, the difference is shown underlined in the application and in bold in the staff-requested wording.

The proposed Notes, except for LCO 3.9.5, state, "No operations are permitted that would cause introduction into the RCS [Reactor Coolant System], coolant with boron concentration less than required to meet the SDM [Shutdown Margin] of LCO 3.1.1." The staff concludes that the Notes should read "No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1."

For LCO 3.9.5, the Note states "...no operations are permitted that would cause introduction into the Reactor Coolant System, coolant with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1." The staff concludes that the Note should read "...no operations are permitted that would cause introduction of coolant into the Reactor Coolant System with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1."

The proposed Required Actions (except 3.9.3.A.2, 3.9.5.A.1, and 3.9.6.B.1 below) state "Suspend operations that would cause introduction into the RCS, coolant with boron concentration less than required to meet SDM of LCO 3.1.1." The staff concludes that the Required Actions should read "Suspend operations that would cause introduction of coolant into the RCS with boron concentrations less than required to meet the SDM of LCO 3.1.1."

Proposed Required Actions 3.9.3.A.2, 3.9.5.A.1, and 3.9.6.B.1 state "Suspend operations that would cause introduction into the RCS, coolant with boron concentrations less than required to meet the boron concentration of LCO 3.9.1." The staff concludes that the Required Action should read "Suspend operations that would cause introduction of coolant into the RCS with boron concentrations less than required to meet the boron concentration of LCO 3.9.1."

The staff believes that the above changes make the statements in the Notes and Required Actions clearer than the words in TXX-02201, which uses wording in accordance with TSTF-286, Revision 2, that the Notes and Required Actions are preventing "introduction of coolant into the RCS" of boron concentration greater than the LCO 3.1.1-required SDM and LCO 3.9.1-required boron concentration. This prevents the core from having an unacceptable reactivity.

The staff requested by e-mail that the licensee agree to having the revised wording added to the TSs as part of its proposed license amendment request. As stated in the attached e-mail, the licensee agrees to the revised wording.

Docket Nos.: 50-445 and 50-446

Attachment:

E-mail Dated May 7, 2003

ML031360748 NRR-106 OFFICE PDIV-2/PM PDIV-1/LA PDIV-1/SC NAME JDonohew DJohnson RGramm DATE 5/15/03 5/14/03 5/15/03 E-MAIL DATED MAY 7, 2003 From: <rwalker5@txu.com>

To: <JND@nrc.gov>

Date: 5/7/03 11:49AM

Subject:

Re: Requested agreement to change in wording for certain proposed Notes- II Jack:

I have reviewed the requested changes and find them acceptable.

Roger D. Walker Regulatory Affairs Manager CPSES, TXU "Jack Donohew"

<JND@nrc.gov> To: <rwalker5@TXU.com>

cc: "David Jaffe" <DHJ.owf4_po.OWFN_DO@nrc.gov>

05/07/2003 09:58

Subject:

Requested agreement to change in wording for certain proposed Notes - II AM In your application dated December 4, 2002, you proposed changes to certain Notes for LCOs and certain Required Actions to allow controlled introduction of positivity reactivity changes to the core. The proposed changes are to the Notes for LCOs 3.4.5, 3.4.6, 3.4.7, 3.4.8, and 3.9.5, and to Required Actions 3.4.5.D.2, 3.4.6.B.1, 3.4.7.B.1, 3.4.8.B.1, 3.9.3.A.2, and 3.9.5.A.1 and B.1.

The proposed Notes except for LCO 3.9.5 state no "operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1". The staff requests that the Notes read that no "operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1". The difference is shown underlined in the application and in bold in the staff-requested wording.

For LCO 3.9.5, the Note states no "operations are permitted that would cause introduction into the Reactor Coolant System, coolant with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1." The staff requests that the Note reads no "operations are permitted that would cause introduction of coolant into the Reactor Coolant System with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1." The difference is underlined and in bold.

The proposed Required Actions (except 3.9.3.A.2, 3.9.5.A.1, and 3.9.5.B.1 below) state "Suspend operations that would cause introduction into the RCS, coolant with boron concentrations less than required to meet SDM of LCO 3.1.1." The staff requests that the required Actions read "Suspend operations that would cause introduction of coolant into the RCS with boron concentrations less than required to meet the SDM of LCO 3.1.1." Again the difference is shown underlined and in bold.

For proposed Required Actions 3.9.3.A.2, 3.9.5.A.1, and 3.9.5.B.1 state "Suspend operations that would cause introduction into the RCS, coolant with boron concentrations less than required to meet the boron concentration of LCO 3.9.1." The staff requests that the Required Action reads "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1." The difference is again underlined and in bold.

The staff believes that the staff requested changes make the statements in the Notes and Required Actions clearer, than the words in the application from TSTF 286, Revision 2, that the Notes and Required Actions are preventing "introduction of coolant into the RCS" of boron concentration greater than the LCO 3.1.1 required SDM and LCO 3.9.1 required boron concentration.

Do you agree to the changes requested by the staff to have clearer TS wording.

<JND>

CC: "David Jaffe" <DHJ.owf4_po.OWFN_DO@nrc.gov>