Text

License Amendment Request 04-011, Revision to Technical Specification (TS 3.3.3) Post Accident Monitoring Instrumentation and 3.6.8 Hydrogen Recombiners
	ML043070519
Person / Time
Site:	Comanche Peak
Issue date:	10/28/2004
From:	Madden F; TXU Power
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	00236, CPSES-200402431, LAR 04-011, TXX-04167
	Download: ML043070519 (111)
	v • d • e

A TXU 4"'

Power TXU Power Comanche Peak Steam Electric Station P.O. Box 1002 (EO1)

Glen Rose, TX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mike.blevinsetxu.com Mike Blevins Senior Vice President &

Chief Nuclear Officer Ref: 1 OCFR5O.90 CPSES-200402431 Log # TXX-04167 File # 00236 October 28, 2004 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)04-011 REVISION TO TECHNICAL SPECIFICATION (TS 3.3.3) POST ACCIDENT MONITORING (PAM) INSTRUMENTATION AND 3.6.8 HYDROGEN RECOMBINERS Gentlemen:

Pursuant to 1 OCFR50.90, TXU Generation Company LP (TXU Power) hereby requests an amendment to the CPSES Unit I 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 change will delete Technical Specification (TS) 3.6.8, "Hydrogen Recombiners," and references to the hydrogen monitors in TS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. (The deletion of the requirements for the hydrogen recombiner and references to hydrogen monitors resulted in numbering and formatting changes to other TS, which were otherwise unaffected by this proposed amendment.)

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

2)\\

Callaway

Comanche Peak

Diablo Canyon

Palo Verde

South Texas Project

Wolf Creek

TXX-04167 Page 2 of 3 provides a detailed description of the proposed changes, a safety analysis of the proposed changes, TXU Generation Company LP'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 changes will be processed per CPSES site procedures. Attachment 4 provides retyped Technical Specification pages that incorporate the requested changes. Attachment 5 provides retyped Technical Specification Bases pages that incorporate the proposed changes. Attachment 6 provides preliminary marked-up pages of the Final Safety Analysis Report (for information only) to reflect the proposed changes to the FSAR.

TXU Generation Company LP requests approval of the proposed License Amendment by November 1, 2005, to be implemented within 120 days of the issuance of the license amendment. The approval date was administratively selected to allow for NRC review but the plant does not require this amendment to allow continued safe full power operations.

In accordance with IOCFR50.91(b), TXU Generation Company LP is providing the State of Texas with a copy of this proposed amendment.

This communication contains the following new commitment which will be completed as noted:

Commitment Number Commitment 27324 TXU Power has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at CPSES and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be retained in the CPSES Final Safety Analysis Report (FSAR). This regulatory commitment will be implemented within 120 days of issuance of the license amendment.

TXX-04167 Page 3 of 3 Should you have any questions, please contact Mr. J. D. Seawright at (254) 897-0140.

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

Executed on October 28, 2004.

Sincerely, TXU Generation Company LP By:

TXU Generation Management Company LLC, Its General Partner Mike Blevins By: ITL L

tr:7, Fred W. Madden Director, Regulatory Affairs jds Attachments 1.

2.

3.

4.

5.

6.

Description and Assessment Markup of Technical Specifications pages Markup of Technical Specifications Bases pages (for information)

Retyped Technical Specification Pages Retyped Technical Specification Bases Pages (for information)

Proposed FSAR changes (for information) 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-04167 DESCRIPTION AND ASSESSMENT to TXX-04167 Page 1 of 4 LICENSEE'S EVALUATION

1.

DESCRIPTION

2.

PROPOSED CHANGE

3.

BACKGROUND

4.

TECHNICAL ANALYSIS

5.

REGULATORY SAFETY ANALYSIS 5.1.

No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/criteria

6.

ENVIRONMENTAL CONSIDERATION

7.

PRECEDENT

8.

REFERENCES to TXX-04167 Page 2 of 4

1.0 DESCRIPTION

By this letter, TXU Generation Company LP 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. Proposed change LAR 04-011 deletes Technical Specification (TS) 3.6.8, "Hydrogen Recombiners," and references to the hydrogen monitors in TS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. (The deletion of the requirements for the hydrogen recombiner and references to hydrogen monitors resulted in numbering and formatting changes to other TS, which were otherwise unaffected by this proposed amendment.)

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the Consolidated Line Item Improvement Process (CLIIP).

The initial preliminary proposed FSAR changes are also included for information only (See ). These changes reflect that Regulatory Guide 1.7 no longer applies to CPSES, that the hydrogen recombiners no longer have a design function, and that calculations of hydrogen post-LOCA are no longer required. The changes also reflect the reduced requirements for the hydrogen monitors.

2.0 PROPOSED CHANGE

Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

TS 3.3.3, Condition C Note: Reference to Hydrogen Monitors Deleted TS 3.3.3, Condition D Inoperable Hydrogen Monitors Deleted SR 3.3.3.2 Sensor Module Calibration for Hydrogen Monitors Deleted Table 3.3.3-1 Item 11, Hydrogen Monitors Deleted TS 3.6.8 Hydrogen Recombiners Deleted (Other TS changes included in this application are limited to renumbering and formatting changes that resulted directly from the deletion of the above requirements related to hydrogen recombiners and hydrogen monitors.)

to TXX-04167 Page 3 of 4 As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements (and associated renumbering of other TSs) result in changes to various TS Bases sections. Proposed changes to the TS Bases are provided for information only in Attachment 4. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.14, "Technical Specifications Bases Control Program."

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 TECHNICAL ANALYSIS

TXU Power has reviewed the safety evaluation (SE) published on September 25,2003 (68 FR 55416), as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE, as well as the information provided to support TSTF-447, Revision 1. TXU Power has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, and justify this amendment for the incorporation of the changes to the CPSES TS.

4.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416), for this TS improvement, TXU Power is making the following verifications and regulatory commitments:

1. TXU Power has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at CPSES and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be retained in the CPSES Final Safety Analysis Report (FSAR). This regulatory commitment will be implemented within 120 days of issuance of the license amendment.

2.

CPSES does not have an inerted containment.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration TXU Power has reviewed the proposed no significant hazards consideration determination published on September 25,2003 (68 FR 55416), as part of the CLIIP. TXU Power has concluded that the proposed determination presented in the notice is applicable to CPSES

Attachment I to TXX-04167 Page 4 of 4 Units I and 2 and the determination is hereby incorporated by reference to satisfy the requirement of 10 CFR 50.91(a).

5.2 Applicable Regulatory Requirements/Criteria The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.0 ENVIRONMENTAL CONSIDERATION

TXU Power has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416), as part of the CLIIP. TXU Power has concluded that the staff's finding's presented in that evaluation are applicable to CPSES and the evaluation is hereby incorporated by reference for this application.

7.0.

PRECEDENT This application is being made in accordance with the CLIIP. TXU Power is not proposing variations or deviations from the TS changes described in TSTF447, Revision 1, or the NRC staff's model SE published on September 25, 2003 (68 FR 55416).

8.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

ATTACHMENT 2 to TXX-04167 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Pages ii 3.3-36 3.3-37 3.3-38 3.3-39 3.6-22 3.6-23

TABLE OF CONTENTS (continued) 3.4 REACTOR COOLANT SYSTEM (RCS)...............................................

3.4-1 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits...............................................

3.4-1 3.4.2 RCS Minimum Temperature for Criticality...............................................

3.4-4 3.4.3 RCS Pressure and Temperature (PIT) Limits............................................... 3.4-5 3.4.4 RCS Loops - MODES 1 and 2...............................................

3.4-7 3.4.5 RCS Loops - MODE 3...............................................

3.4-8 3.4.6 RCS Loops - MODE 4...............................................

3.4-11 3.4.7 RCS Loops - MODE 5, Loops Filled...............................................

3.4-14 3.4.8 RCS Loops - MODE 5, Loops Not Filled...............................................

3.4-17 3.4.9 Pressurizer...............................................

3.4-19 3.4.10 Pressurizer Safety Valves...............................................

3.4-21 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)..................................... 3.4-23 3.4.12 Low Temperature Overpressure Protection (LTOP) System.......................... 3.4-27 3.4.13 RCS Operational LEAKAGE...............................................

3.4-33 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage............................................... 3.4-35 3.4.15 RCS Leakage Detection Instrumentation...............................................

3.4-40 3.4.16 RCS Specific Activity...............................................

3.4-44 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)............................................ 3.5-1 3.5.1 Accumulators...............................................

3.5-1 3.5.2 ECCS - Operating...............................................

3.5-4 3.5.3 ECCS - Shutdown...............................................

3.5-8 3.5.4 Refueling Water Storage Tank (RWST)...............................................

3.5-10 3.5.5 Seal Injection Flow...............................................

3.5-12 3.6 CONTAINMENT SYSTEMS...............................................

3.6-1 3.6.1 Containment...............................................

3.6-1 3.6.2 Containment Air Locks...............................................

3.6-2 3.6.3 Containment Isolation Valves...............................................

3.6-7 3.6.4 Containment Pressure...............................................

3.6-16 3.6.5 Containment Air Temperature...............................................

3.6-17 3.6.6 Containment Spray System...............................................

3.6-18 3.6.7 Spray Additive System...............................................

3.6-20 3.6.8 Hydrogon Rocombinore...............................................

3.6 22 (continued)

COMANCHE PEAK - UNITS 1 AND 2 ii Amendment No. 44

PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

NOTE C.1 Restore one channel to 7 days Not applicable to hydrogon OPERABLE status.

monitor channels.

One or more Functions with two required channels inoperable.

OR One required Thot channel and one required Core Exit Temperature channel inoperable.

OR One required TCOld channel and one required Steam Line Pressure channel for the associated loop inoperable.

D.

T-wo hydrogen monitor D.1 Restore one hydrogen 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months chaRnRls inoperable.

monitor channel to OPERABLE status.

ED. Required Action and ED.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C eo-Table 3.3.3-1 for the not met.

channel.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-36 Amendment No. 464

PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME FE. As required by Required FE.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action ED.1 and referenced in AND Table 3.3.3-1.

FE.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months GF. As required by Required GF.1 Initiate action in Immediately Action ED.1 and accordance with referenced in Specification 5.6.8.

Table 3.3.3-1.

SURVEILLANCE REQUIREMENTS

NOTE----------------------------------------------------------------

SR 3.3.3.1 and SR 3.3.3.3 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 Deleted

NOTE Applicable to hydrogen monitor channels only.

Q2 days Perform a sensor module calibration.

SR 3.3.3.3 Perform CHANNEL CALIBRATION.

18 months COMANCHE PEAK - UNITS 1 AND 2 3.3-37 Amendment No. 64

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 2)

Post Accident Monitoring Instrumentation FUNCTION

1. Refueling Water Storage Tank Level

2.

Subcooling Monitors

3.

Reactor Coolant System (RCS) Hot Leg Temperature (Wide Range) (Tw)

4.

RCS Cold Leg Temperature (Wide Range)

(Tcdd)

5. RCS Pressure (Wide Range)

6. Reactor Vessel Water Level

7. Containment Sump Water Level (Wide Range)

8. Containment Pressure (Intermediate Range)

9. Steam Une Pressure

10. Containment Area Radiation (High Range)

11. Hydrogon MneitorDeleted

12. PressurizerWaterLevel

13. Steam Generator Water Level (Narrow Range)

14. Condensate Storage Tank Level REQUIRED CHANNELS 2

2 1 per loop 1 per loop 2

2(a) 2 2

2 per steam line 2

2(b) 2 2 per steam generator 2

CONDITION REFERENCED FROM REQUIRED ACTION D&.I FE FE FE FE FE GF FE FE GF F

FE FE FE (continued)

(a) A channel is eight sensors In a probe. A channel Is OPERABLE If four or more sensors, one or more in the upper section and three or more In the lower section, are OPERABLE.

(b) A channel consistr of two onomrs ner train. A channol is considorod OPERABLE if one Aron or In OPEPRABLE. Deleted COMANCHE PEAK - UNITS 1 AND 2 3.3-38 Amendment No. 64

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 2 of 2)

Post Accident Monitoring Instrumentation 15.

16.

17.

18.

19.

FUNCTION Core Exit Temperature - Quadrant 1 Core Exit Temperature - Quadrant 2 Core Exit Temperature - Quadrant 3 Core Exit Temperature - Quadrant 4 Auxiliary Feedwater Flow

a.

AFW Flow OR

b.

AFW Flow and Steam Generator Water Level (Wide Range)

REQUIRED CHANNELS 2(c) 2(c) 2(c) 2(c) 2 per steam generator 1 each per steam generator CONDITION REFERENCED FROM REQUIRED ACTION D&1 FE FE FE FE FE FE (c) A channel consists of two core exit thermocouples (CETs).

COMANCHE PEAK - UNITS 1 AND 2 3.3-39 Amendment No. r64

Hyd~e~eR ReGembinw&

U R^r 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Rccombincrs a '% %

^

t^ n T. A A.

.I

..._..L

_A

.I__I Lf

_1_

-1 I-, I 1-L':.J v.b.v I WO nyaUrogn roFEiddfiUnHrE bsnad UD Il-I-tI.

ADDI Ir'A RllITV-

^R~nf'NM 1

-^. f3

.. I I.

AGT4QNS GONDITION REQUIRED ACTION COMPLETION TIME A. Ono hydrogon roombino A.1 RoStoro hydrogon 30 days 4^r~phl^

t^FeGembinRe t9 OPERABLE statu6.

B. Two hydrogon rocombinors B.1-Vorify by administmtivo 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months iRperabe moanS that the hydrogen control function iS AN Dn Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months theFeafteo AND

_.2 Rto one hyde R

7 days reGOmbiRne to OPERABLE 6tatus.

(3ontiNued)

COACEPEAK U

-NITS 1 AND 2 3.2 S2 A mnndmnet Ncl. 109 1109

HydFrgon RocombinorF 2.6.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. RoquFrod Action and C.1 Be in MODE 3.

aSociatod Complption Time nret met SURVEILLANCE REQUIREMENTS SURVEILLANCE FRSQUENCY SP 3.6.8.1 Perform a system functional test for each hydrogon 48 months reGmbinor.

SR 3.6.8.2 Visual!lex n each hydFrogon ecomFbinr encRoSUre9 1 8 months and verify thee ie. noRe evidence f nrml conditions.

SR 3.6.8.3 Perform a resistance to ground test for each heator phase.

COMANCHE PE-AK U NITS; 1,AND 2 3.6232 Amendment No. 10-9

ATTACHMENT 3 to TXX-04167 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)

(For Information Only)

Pages B 3.3-124 B 3.3-131 B 3.3-138 B 3.3-139 B 3.3-141 B 3.6-52 B 3.6-53 B 3.6-54 B 3.6-55 B 3.6-56 B 3.6-57 B 3.6-58

PAM Instrumentation B 3.3.3 BASES (continued)

BACKGROUND Determine whether other systems important to safety are (continued) performing their intended functions; Provide information to the operators that will enable them to determine the likelihood of a gross breach of the barriers to radioactivity release; and Provide information regarding the potential release of radioactive materials to allow for early indication of the need to initiate action necessary to protect the public, and to estimate the magnitude of any impending threat.

These variables are identified by the unit specific Regulatory Guide 1.97 analyses (Ref. 1). These analyses identify the unit specific Type A and non-Type A Category 1 variables and provide justification for deviating from the NRC proposed list of Category 1 variables.

The selected non-Type A Category 1 variables are Reactor Vessel Water Level, and Containment Area Radiation (High Range), aRd HydrogeR Monitors. These selected variables are considered essential to the operator for LOCA management. Non-Type A Category 1 variables that are not included are Neutron Flux, Containment Pressure (Wide Range),

Steam Generator Water Level (Wide Range), and Containment Isolation Valve Status. Although they are important variables, effectiveness of the operator response to a DBA would not be reduced because other variables provide sufficient in formation for operator response. Neutron Flux is not required since reactor coolant temperatures provide sufficient confirmation of subcriticality. Containment Pressure (WR) is not required since the Containment Pressure intermediate range exceeds the containment design pressure and would provide sufficient confirmation of peak containment pressure. Steam Generator Water Level (WR) is not required since the Steam Generator water level narrow range would provide sufficient confirmation of level. The Wide range level is included as an alternative to auxiliary feedwater flow. Containment Isolation Valve Status is not a CPSES Category 1 variable.

The specific instrument Functions listed in Table 3.3.3-1 are discussed in the LCO section.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-1 24 Amendment Pie. 64 Revision

PAM Instrumentation B 3.3.3 BASES (continued)

LCO (continued)

9.

Main Steam Line Pressure (Steam Generator Pressure)

Main Steam Line Pressure (Steam Generator Pressure) is a Type A Category 1 variable for event diagnosis, natural circulation, and RCP trip criteria. It is also a Type B Category 1 variable for monitoring heat sink status tree. It is a variable for determining if a secondary pipe rupture has occurred. This indication is provided to aid the operator in the identification of the faulted steam generator and to verify natural circulation.

10.

Containment Area Radiation (Hiah Ranae)

Containment Area Radiation Level (High Range) is a Type E Category 1 variable used to determine if an adverse containment environment exists due to a high containment radiation level.

Containment Area Radiation is provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans.

11.

NV-IFUpgO.'P.URRE:FoSelee~ie Hydrogne Monitoer-e ro Typoe 1 Catoor; 1 Yasiablos for hydrogon rocombinor oporatin. It is also a TPeo G Catog; 1 Yariablo fo detectiOn of potential broah Of Gcntainmont boendaSy. Hydo9gen onitors aro aprovided to detect high hydrgern conRontration conditionR that reprosont a potential for cOntainment broach from a hydrogeon oxploieR.

This Yariable is also important in Vorifying the adeauacy of mitigating actions.

12.

Pressurizer Water Level Pressurizer Water Level is Type A Category 1 variable for Si termination/reinitiation. It is also Type B Category 1 for monitoring RCS inventory status tree. Pressurizer Level is used to determine (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-131

.Arnnndmwit bin 64 Re - -

vision

PAM Instrumentation B 3.3.3 BASES (continued)

ACTIONS C.1 (continued)

Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur. Condition C is modified by a Note that eXGludec hydrogen monitoFr channele.

P4 Condition D applie6 whonetwo hydrogen monitor channels are inoporablo.

Required Action D.1 requires rFetoring one hydrogen monitor channol to OPERABLE statur vithin 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Complotion Time is reasonable based on the backup capability of the contingency sampling plan to monitor the hydrogon concentration for evaluation of core damage or other coro damago aecssesmnt capabilities available (e.g. core exit thormocouple6, containment radiation monitore) and to proFide information for operator decisions. Also, it is unlikely that a LOCA (which would cause co r

damage) would occur during this time.

26 ED.1 Condition ED applies when the Required Action and associated Completion Time of Condition C oF D-ae is not met. Required Action 9D.1 requires entering the appropriate Condition referenced in Table 3.3.3-1 for the channel immediately. The applicable Condition referenced in the Table is Function dependent. Each time an inoperable channel has not met any Required Action of Condition C e-Q, and the associated Completion Time has expired, Condition ED is entered for that channel and provides for transfer to the appropriate subsequent Condition.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-1 38 Revision 26

PAM Instrumentation B 3.3.3 BASES (continued)

ACTIONS PE.1 and FE.2 (continued)

If the Required Action and associated Completion Time of Conditions C er-D ae is not met and Table 3.3.3-1 directs entry into Condition FE, the unit must be brought to a MODE where the requirements of this LCO do not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

GF.1 Alternate means of monitoring Reactor Vessel Water Level and Containment Area Radiation have been developed. These alternate means may be temporarily used if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. If these alternate means are used, the Required Action is not to shut down the unit but rather to follow the directions of Specification 5.6.8, in the Administrative Controls section of the TS. The report provided to the NRC should discuss the alternate means used, describe the degree to which the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels.

SURVEILLANCE A Note has been added to the SR Table to clarify that REQUIREMENTS SR 3.3.3.1 and SR 3.3.3.3 apply to each PAM instrumentation Function in Table 3.3.3-1. SR 3.3.3.2 applieo only to the hydrogen Mcntnu6d (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-1 39 Amendment No. 64 Revision

PAM Instrumentation B 3.3.3 BASES (continued)

SURVEILLANCE SR 3.3.3.2 Deleted REQUIREMENTS (continued)

For the hydgen monitors, a senorr module calibmrtioR is perfotrmed overy 92 days. Tho calibration seoqueRn user, sample gas in acrGGdaneo Yith the manufacturer' recommendatiens and eorifies that the current calibration constants are contained in the iropro orr database. This SR is modified by a Neto indicating that this SR is nly applicable to tho hyrgon monritors. The Frequency is based on manufacturers recommendationes.

SR 3.3.3.3 A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, Reactor Trip System (RTS) Instrumentation." Whenever an RTD is replaced in Function 3 or 4, the next required CHANNEL CALIBRATION of the 19 RTDs is accomplished by an inplace cross calibration that compares other sensing elements with the recently installed element. Whenever a core exit thermocouple replaced in Functions 15 thru 18, the next required CHANNEL CALIBRATION of the core exit thermocouples is 9

accomplished by an in-place cross calibration that compares the other sensing elements with the recently installed sensing element.

The Frequency is based on operating experience and consistency with the typical industry refueling cycle. Containment Radiation Level (High Range) CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for range decades above 1 OR/hr and a one point calibration check of the detector below 1 OR/hr with an installed or portable gamma source.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-141 Revision,-

HydFegen -GeGembieF&

B 3.6 CONTAINMENT SYSTEMS 1B 3.6.8 HydFOgen ReOcombinors BACKGROUND The function of the hydrogen rocombiners is to oliminate the potontial breach of containmont duo to a hydrogen oxygen roaction.

Per 10 CFR 60.14, "Standards for Combustiblo Gas Control Systoms in Light Water Coolod RoactorvF (Rof. 1), and GDC 1t, GContainmont Atmosphoro Cleanup (Ref. 2), hydrogon rocombinors are required to reduce the hydFG*eron coRert{ation in the ontainRmnt follow*nga loss of coolant accident (LOCA). Tho recombinors accomplivh thi_

by roFemFbining hydrgeR and oxygen to form wate or.h var remains in containmont, thus oliminating any discharge to tho enVironment. The hydrogen rocombinors are menaually initiatedi soG flammable limits would not bo roachod until 6everal days aftor a Design Bjasis Accident (DBA.

Two, 1 00% Gapaci' indopenondet hydrogeln rormbinor systems ar provided. Each consistS of controls, lecatod in accGesible aroas outside con~taiRnment (Rof. 6), a poWer supply and a recombioRef.

Recombination is accomplished by hoating a hydrogen air mixture above 11 I90F. The rmsulting watFor vaporand discharge gases are cooled prior to discharge from the recombiner. A single recombinor is capable of nain;taiRRnn the hydrogen conr ntrRatioR in onRtaiRmenR below the 1.0 volume percent (vo) flammability limit. TP.o recombinors are provided to meet the requirement for redundancy ard indepe nn.

E-ch recmhbinor is poWered from a separate Engineered Safety Featuroe bus, and is provided with a separate powerFpainl and control panel.

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H4ydrogen ReGcombinors B 3.6.8 BASES (continuod)

APPDDICABLEC The hyderogon roemhbinere provide for tho capabilit' Of controlling the SAFEY bulk hydrogon concentration in containmont to less than the lower ANALIYSES fla mmale cenconratioR of 4.0 W folloying a DBA. This control would provent a containment wido hydrogon burn, thus ensuring the pressure and temnporatur assumod i;n the aralyeo aro not exceodod. Tho limiting DB3A Felative to hydrogon genreation is a LOCA.

Hydrogen may accumulate in containment following a LOCA as a Fesult of:

a.

A metal 6team reaction between the zirconium fuel rod cladding and the reactor coola-nt;

b.

RadiGo4ic decomposGition Of Water iFn the Reactor Coolant SyStem (RCS) and the containment sump;

c.

Hydrogen in the RCS at the time of the LOCA (i.e., hydrogen dissolved in the reactor coolant and hydrogen ga, in the pressurizer vapor space); or

d.

Corrosion of metals exposed to containment Spray and Emergency Core Cooling System 6outiORs.

To evaluate the potential for hydFrogen acumulation in containment following a LOCA, the hydrogen generation as a function of time following the initiation of the accident is calrulated. Conserwative asumnptions recommended by Reference 3 are used to maximize the amount of hydGroen caIculated.

Based On the conserwative assumptions used to calculate the hydrenR concentration versus time after a LOCA, the hydrogen conc;e-ntration in the primary containment would reach 3.6 v/o about 3 days after the LOCA and 1.0 n ' about 3 days later if no rFecmbinrer Was functi;n;ng (Ref. 5).

Initiating the hydrogen rocembinoRe when the primary containmont hydrogeRn concen;traton reaches 3.6 v'o YAill maintain the hydrogern concentration in the primary containment below flammability limits.

(continued)

COMANCHE PEAK UNITS 1 AND 2-B 3.6 63 Amendment No. 61

Hy-dF9neRReGembiners B-3.6.8 APPLIGABIES The hydrogen roFmGbiners a-r designed 6uch that, vith the SAFETY consorvativoly calculated hydrogen gonoration rates discussod above, a ANALYSES

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Onbi~eF iS Gapable Of ijmitiRg the peak hy gR GGnoentoati (continued) in containment to loss than 1.0 v/o (Ref. 1). Tho Hydrogon Purgo System

s similarly designed ruch that one Of tMG edunrdant tranrs is an adoquato backup to the redundant hydrogen recombiners.

The hydrogen recombinores satisfy Criterion 3 of 1 OCFR60.36(c)(2)(ii).

LCO Tweo hydrogen recombinerS must be OPERABLE. This ensures operation of at least one hydrogen roombiinor in the event of a Worst Gaso sr ein atiefai!Ue-.

Operation with at least one hydrogen rocombinor ensures that the post ILOCA hydrogeRn concentration can be prseVented from exNeedin; the flammability-limit.

AD IGABILII In Mnd" 1 and

'W hdFroren rFecmbinereF6 are ire to oRntl the hydrogen concentration within containment bolow its flammabilit' limit of 1.0 We folloAing a LOCA, assuming a worst case single failur-.

In MODE 3 and 4, both the hydrogen production rate and the total hydrogen produced after a LOCA would be less than that calculated for the DnRA IOCA. Also, because of the limited time in there MODES, the probability of an accident requiring the hydrogen rocombiners is loGW.

Therefore, the hydrogen reoGmbinors are not required in MODE 3 or 4.

In MODES 6 and 6, the probability and conSequences of a LOCA are low, due to the pressure and temperature limitations in these MODES.

Therefore, hydrogen recombiners are not required in those MODES.

(continued)

COMANCHE PEAK UNITS 1 AND 2 B 3.6 61 Amendment No. 61

Hydrogen Recombinor^S B 3.6.8 BASES (continued)

ACTIONS With ono containment hydrogon rocombinre inop!rable,tho innop o rcmhbinr must be roStr4ed to OPERABLE ^tatur within 30 dayr. In this condition, the remaining OPERABLE hydrogon recO.mbiner is adequato to poor fRthe hydrogen conrol functon.-

Howevor, tho ovarall reliability i6 reducod because a single failure in tho OPERABLE roc^mhbinr could resUlt in roedueod hydFrogn cntrol capability. Tho 30 day Completion Time is based on tho availability of the other hydsrgen recombiner, tho small pbabili' of a LOCA ourri (that would generate an amount of hydrogen that exceeds tho flaFmmability limit), and the amount of time available aft.r a IOCA (should onGe occur for operator action to provent hydrogen accumulation from exceeding the liammabilit4 !i~mt 34 (cntinued)

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Hydrogen Rocombinorv B3 3.6.8 ACTIONS 8.1 and 8.2

-(GORtifiued)

With two hydrogon rocombiners inoperablo, tho ability to porform tho hydFrogon controlI functi-on via altornato capabilities must bo vYreified b adminiStrativo moans within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The alternate hydrogen control capabilities aro providod by the containmnnt HydrogoR Purge System.

Tho 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Complotion Time allows a roasonablo poriod of timo to vorify that a lossr of hydrogon control functin doos not exist. In addition, tho altornato hydrogeAn control systom capability must bo vorifiod once por l hnurrs threaeForto ensre ;tS contiRued aailabil;ty. Both the initial vorification and all subsequent verifications may bo porformed as an ad9ninintotiye~ Ghe~lk by nexamnin~ 19-r 9F etheF intfrrnation to denteFRine tho availability of tho altomato hydrogon control systom. It doos not moan to porform tho SurFeillanres Rneedd to demonstr-ate OPERABIl IT of the alternate hydrogen control system. If the ability to perform the hydrogen control function is maintained, continued operation is permitted with two hydrogen recombinors inoperable for up to 7 days. Seven days is a reasonable time to allow tvw hydrogen recomnbiners to be inoperable because the hydrogen control function is maintained and because of the low probability of the occurrence of a LOCA that would generate hydrogen in the amounts capable of exceeding the flammability limit.

C.1 If the inoperable hydrogen recombiner(s) cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant mrust be brought to at least MODE 3 Within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating exriFene, to reach MODE 3 frm full poWer conditions iRn an orderly manner and without challenging plant systems.

(continued)

A COMAPIGHE PEAK UNITS 1 AND 2 13 M rb~

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Hydogeon ReoambinorS B 3.6.8 BASES (continued)

SURVEILLANCE SR 3.6.8.1 Performance of a systom functional tost for each hydrogon rocombiner ensuros tho recombiners aro operational and can attain and sustain the temperature necessary for hydrogen rocembination. In particulr, this SR verifios that tho minimum heator sheath tomporaturo increaces to 2 700°F in e D0 minutes. Aftor reaching 700°F, the power is incroased to maximusm pwoSr for approximately 2 minutes and power iS verified to be Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month requency. Therefore, the FRequeRcy WaE concludod to be accoptablo !from a roliability Gtandpeint.

SR. 3.6.8.2 This SR eInsures there are no physical problems that ceuld affect recombiner operation. Since the recombinerS are mechanically passive, they are Rnt subject to mechanical failure. The only credible failure nvolves lOss EOf power, blockage of the internal flow, missile impact, etc.

A visual inspection is Sufficiont to deteFrmine abnormal conditions that could cause such faIlures (i.e., loose wigng or srtreur-al eonnec;tiRs, deposits of foreign materials, etc.). The 18 month Frequency for this SR was developed considering the incidence of hydrogen recombiners failing the SR in the past is low.

SRE 3.6.8.3 This SR., which is performed following the functional test of SR 3.6.8.1, require performrance9 of a rFesitance to grund test for each heater phase to ensure that there are no detectable grounds in any heater phase. This is accomplished by verifying that the resistance to ground for any heater phase is 2 10,000 ohms.

The 18 month FrequeAncy for this Surveillance was developed considering tho incidence of hydrogen recombiners failing the SR in the past is low.

(continued)

COMANNCHE PEAK UNITS 1 AND 2 B 3.6 57 Rvision 31

Hydrogen Recombinore 13 Q._

BASES (continued)

REFERENCES

1.

10 CFR 60.11.

2.

10 CER 60, Appendix A, GDC 11.

3.

Regulatory Guide 1.7, Revision 2.

1.

FSAR Section 6.2.5.

5.

FSAR Section 6.2.6A

6.

FSAR, Section !I.B.2

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ATTACHMENT 4 to TXX-04167 RETYPED TECHNICAL SPECIFICATION PAGES Pages ii 3.3-36 3.3-37 3.3-38 3.3-39