ML040090172

License Amendment Request (LAR) 03-09 Regarding Correction to Completion Times for Technical Specification (TS) 3.9.6, Residual Heat Removal (RHR) and Coolant Circulation Low Water Level

ML040090172
Person / Time
Site:	Comanche Peak
Issue date:	12/18/2003
From:	Blevins M TXU Electric
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CPSES-20030270, TXX-03192
Download: ML040090172 (8)

Text

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,W4,04w TXU TXU Energy Mike Blevins Comanche Peak Steam Senior Vice President & Principal Nuclear Officer Ref: 10CFR50.90 Electric Station RO. Box 1002 (EO1)

Glen RoseTX 76043 Tel: 254 897 5209 Fax:254 897 6652 mike.blevins@txu.com CPSES-200302700 Log # TXX-03192 File # 00236 December 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) 03-09 CORRECTION TO COMPLETION TIMES FOR TECHNICAL SPECIFICATION (TS) 3.9.6, RESIDUAL HEAT REMOVAL (RHR) AND COOLANT CIRCULATION LOW WATER LEVEL REF: I) TXU Energy Letter logged TXX-02201 dated December 4, 2002 from C. Lance Terry to the NRC

2) NRC Letter dated June 24,2003 from Jack Donohew to C. Lance Terry

3) NRC Letter dated August 13, 2003 from Jack Donohew to C. Lance Terry 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 I and 2 Technical Specifications. This change request applies to both units.

The proposed change for each unit will revise TS 3.9.6 entitled "Residual Heat Removal (RHR) and Coolant Circulation Low Water Level" to correct the completion times for ACTION B.2 and B.3. ACTION B.2 should have a completion time of "Immediately" and ACTION B.3 should have a completion time of "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />".

Reference 1 was a requested revision to technical specifications regarding suspension of positive reactivity additions. The completion times for ACTION B.2 and B.3 of TS 3.9.6 were incorrect due to an editorial error which was made when formatting the revised page. This error went undetected thru review and approval of Amendment 105 to the CPSES Technical Specifications by the NRC per references 2 and 3.

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

-3)uzl Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

4 6 TXU TXX-03192 Page 2 of 3 provides a detailed description of the proposed change, a safety analysis of the proposed change, TXU Energy's determination that the proposed change does not involve a significant hazard consideration, a regulatory analysis of the proposed change and an environmental evaluation. Attachment 2 provides the affected Technical Specification page marked-up to reflect the proposed changes. Attachment 3 provides the retyped Technical Specification page which incorporate the requested changes.

TXU Energy requests approval of the proposed License Amendment by March 26, 2004 to be implemented within 30 days of the issuance of the license amendment. The approval date was selected to support implementation during RF10, which is scheduled for Spring, 2004.

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 licensing basis commitments regarding CPSES Units 1 and 2.

Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725 or e-mail at jhicksl @txu.com.

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

Executed on Decmeber 18, 2003.

Sincerely, TXU Generation Company LP By: TXU Generation Management Company LLC Its General Partner M. R. Blevins Senior Vice President and Principal Nuclear Officer By: W v-4A Roge. Walker Regulatory Affairs Manager JCH/jch

TXU TXX-03 192 Page 3 of 3 Attachments 1. Description and Assessment

2. Markup of Technical Specification Page

3. Retyped Technical Specification Page c - B. S. Mallett, Region IV W. D. Johnson, Region IV M. C. Thadani, NRR Resident Inspectors, CPSES Ms. Alice Rogers Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78756-3189

ATTACHMENT 1 to TXX-03096 DESCRIPTION AND ASSESSMENT to TXX-03096 Page 1 of 2

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 for each unit into the CPSES Unit 1 and 2 Technical Specifications (TS). Proposed change License Amendment Request (LAR) 03-09 is a request to revise Technical Specification (TS) 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation Low Water Level" for Comanche Peak Steam Electric Station (CPSES) Units 1 and 2.

This is a correction of an editorial error which was made when formatting the revised technical specification page in TXU Energy's previous LAR. This error went undetected during TXU Energy's review of the LAR and the NRC review and approval of Amendment 105 to the CPSES Technical Specifications.

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

2.0 PROPOSED CHANGE

The proposed change revises the Completion Times for ACTION B.2 and B.3 of TS 3.9.6.

Specifically, this change corrects the Completion Time for Action B.2 to "Immediately" and adds the Completion Time for Action B.3 to be "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />".

3.0 TECHNICAL ANALYSIS

The proposed change will return the Completion Times for Actions B.2 and B.3 of TS 3.9.6 to the previous correct values prior to the implementation of Amendment 105 to the Technical Specifications on August 21, 2003.

TS 3.9.6 is only applicable when the plant is in MODE 6 with the water level <23 ft above the top of the reactor vessel flange. Unit 2 entered its seventh refueling outage (2RF07) on October 4, 2003. ACTION B is the condition when "No RHR loop is in operation." There was never a time period during 2RF07 when RHR loops were inoperable in MODE 6 with the water <23 f above the top of the reactor vessel flange. In addition, a tracking LCOAR (Limiting Condition for Operation Action Requirement) has been initiated which will ensure that the correct completion times will be used if TS 3.9.6 is entered prior to implementation of this LAR.

4.0 SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION 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 I OCFR50.92, "Issuance of amendment," as discussed below:

to TXX-03096 Page 2 of 2

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

Response: No The proposed change is considered to be a correction of an editorial error. The proposed revision to TS 3.9.6 is consistent with the current CPSES licensing basis.

Therefore the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed change is considered to be an editorial correction and does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No The proposed change is considered to be an editorial correction and does not involve a reduction in a margin of safety.

Based on the above evaluations, TXU Energy has determined that the requested Technical Specification changes do not involve a significant increase in the probability or consequences of an accident or other adverse condition. It does not create the possibility of a new or different kind of accident or condition previously evaluated. It does not involve a reduction in the margin of safety. Therefore, the requested license amendment request does not involve a significant hazards consideration.

5.0 ENVIRONMENTAL CONSIDERATION

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 I OCFR51.22 (c)(9). Therefore, pursuant to OCFR51.22 (b), an environmental assessment of the proposed change is not required.

6.0. REFERENCES None.

to TXX-03192 RHR and Coolant Circulation -Low Water Level 3.9.6 ACTIONS (continued).

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

AND B.2 Initiate action to restore mneiae one RHR loop to operation.

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

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

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

COMANCHE PEAK - UNITS 1 AND 2 3.9-1 2 Amendment No. 05 to TXX-03192 RHR and Coolant Circulation - Low Water Level 3.9.6 ACTIONS (continued)

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

AND B.2 Initiate action to restore Immediately I one RHR loop to operation.

AND B.3 Close all containment 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> I penetrations providing direct access from containment atmosphere to outside atmosphere.

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

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

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