CPSES-200402477, (CPSES) License Amendment Request (LAR) 04-013 Revision to Technical Specification (TS) 3.7.5 Auxiliary Feedwater (AFW) System

(CPSES) License Amendment Request (LAR)04-013 Revision to Technical Specification (TS) 3.7.5 Auxiliary Feedwater (AFW) System

ML050330389
Person / Time
Site:	Comanche Peak
Issue date:	01/24/2005
From:	Madden F TXU Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
00236, CPSES-200402477, TXX-04195
Download: ML050330389 (23)

Text

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^TXU Power TXU Power MIe Blevins Comanche Peak Steam Senor Vice Preent &Ref:

CFR5.90 Electric Station Chief Nuclear Officer Rf CR09 P. O. Box 1002 (EO1)

Glen Rose, TX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mikeJblevinsbtxu.com CPSES-200402477 Log# TXX-04195 File # 00236 January 24, 2005 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)04-013 REVISION TO TECHNICAL SPECIFICATION (TS) 3.7.5 AUXILIARY FEEDWATER (AFW) SYSTEM Gentlemen:

Pursuant to 1 OCFR50.90, TXU Generation Company LP (TXU Power) 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 will revise the Surveillance Requirements (SRs) for Technical Specification (TS) 3.7.5, "Auxiliary Feedwater (AFW) System." Specifically, a note will be added to SRs 3.7.5.1, 3.7.5.3, and 3.7.5.4 that states "AFW train(s) maybe considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation."

This amendment is based on NRC-approved traveler, TSTF-245-A, Revision 1, "AFW Train Operable When in Service," dated July 31, 2003 (Reference 8.1).

Attachment I provides a detailed description of the proposed changes, a technical analysis of the proposed changes, TXU Power'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.

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

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

TXX-04195 Page 2 of 3 provides proposed changes to the Technical Specification Bases for information only. These changes will be processed per CPSES site procedures. provides retyped Technical Specification pages that incorporate the requested changes. Attachment 5 provides retyped Technical Specification Bases pages that incorporate the proposed changes.

TXU Power requests approval of the proposed License Amendment by September 30, 2005, to be implemented within 90 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 1 OCFR50.91 (b), TXU Power 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 January 24, 2005.

Sincerely, TXU Generation Company LP By:

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

2fY')a a

Fred W. Madden Director, Regulatory Affairs JCH Attachments

1. Description and Assessment

2. Markup of Technical Specifications pages

3. Markup of Technical Specifications Bases pages (for information)

TXX-04195 Page 3 of 3

4. Retyped Technical Specification Pages

5. Retyped Technical Specification Bases Pages (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-04195 DESCRIPTION AND ASSESSMENT to TXX-04195 Page 1 of 7 LICENSEE'S EVALUATION

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Determination 5.2 Applicable Regulatory Requirements/Criteria

6.0 ENVIRONMENTAL CONSIDERATION

7.0 PRECEDENT

8.0 REFERENCES

Attachment I to TXX-04195 Page 2 of 7

1.0 DESCRIPTION

By this letter, TXU Power 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. The proposed License Amendment Request (LAR)04-013 will revise the Surveillance Requirements (SRs) for Technical Specification (TS) 3.7.5, "Auxiliary Feedwater (AFW) System." Specifically, a note will be added to SRs 3.7.5.1, 3.7.5.3, and 3.7.5.4 that states "AFW train(s) maybe considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation."

This amendment is based on NRC-approved traveler, TSTF-245-A, Revision I, "AFW Train Operable When in Service."

2.0 PROPOSED CHANGE

TXU Power is not proposing variations or deviations from the TS changes described in TSTF-245-A, Revision 1. The proposed TS changes add a note to SR 3.7.5.1, SR 3.7.5.3, and SR 3.7.5.4 stating that "AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation." The existing note in SR 3.7.5.1 is being deleted.

As described in NRC-approved Revision 1 of TSTF-245-A, the changes to TS requirements 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 (TS) Bases Control Program."

3.0 BACKGROUND

Prior to conversion to Improved Technical Specifications (ITS), CPSES Technical Specifications (TS) allowed operation of auxiliary feedwater (AFW) isolation valves below 10% rated thermal power for steam generator water level control. This allowance permitted the isolation valves to be closed on leakage by the flow control valve to keep steam generator water level from increasing.

The NRC issued the amendment to convert to ITS on February 26, 1999. ITS went into effect at CPSES on July 27, 1999. Section 3.7.5, AFW System, did not address the AFW isolation valves.

Presently CPSES has to enter and exit a LCO when closing isolation valves for leakage by the flow control valve. This condition existed last year on May 16, 2003, following a Unit 1 reactor trip. CPSES lost some latitude when dealing with AFW alignment during Mode 3 operation which necessitated operation in multiple LCO conditions to maintain steam generator water level control. Operation in LCO 3.7.5 Condition C, Two AFW trains inoperable, requires the Unit to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 in 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

Attachment I to TXX-04195 Page 3 of 7 Final resolution of TSTF-245, Revision 1, with NRC approval was January 13, 1999. This was too late to be included in CPSES ITS. The need for the change in TS was not apparent until CPSES experienced leakage past the flow control valve.

4.0 TECHNICAL ANALYSIS

Auxiliary Feedwater (AFW) is a dual use system. AFW valves may not be in their AFW required position during Modes l(below 10% Rated Thermal Power), 2, 3, 4, and 5 when used for maintaining steam generator level. Adding the note that an AFW train may be considered OPERABLE during alignment and operation for steam generator level control, if capable of being manually realigned to the AFW mode of operation would clarify the intended flexibility allowed and prevent unnecessary Action entry.

This exception allows the AFW system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an expected function of the AFW system, OPERABILITY (i.e., the intended safety function) should be maintained during these operations. Following a reactor trip, AFW flow provides the source of makeup to the steam generators. If excessive RCS cooldown is experienced and it is caused by a large amount of AFW flow, the Turbine Driven AFW Pump may be stopped in an attempt to limit RCS cooldown. However, the Turbine Driven AFW Pump remains available for steam generator level control and can be restored by the operator should the need arise.

NUREG-1431, Revision 1, Standard Technical Specifications, Westinghouse Plants, addresses dual use components for RHR (Residual Heat Removal). "An RHR train may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned to the ECCS mode of operation." This note is included in CPSES T.S. 3.5.3, ECCS-Shutdown. Using this position, a similar intent can be interpreted for AFW.

NRC Inspection Manual Part 9900: Technical Guidance, "OPERABLE/OPERABILITY:

Ensuring the Functional Capability of a System or Component," Section 6.7, "Use of Manual Action in Place of Automatic Action," states "...the licensee's determination of operability with regard to the use of manual action must focus on the physical differences between automatic and manual action and the ability of the manual action to accomplish the specified function." The physical differences to be considered include "...emergency operation procedures written for the automatic mode of operation." CPSES Emergency Operating Procedures contain the required steps to ensure that the AFW pumps are running and supplying water to all steam generators.

With regards to the AFW system, the NRC staff has already made a determination of when manual versus automatic operation is permissible. The NRC recognizes this system may be used during startup of the plant, normal shutdown, and hot standby conditions and that it is control band operated during these conditions in the manual mode of operation. In such situations, the AFW system is considered OPERABLE with regards to the limiting condition for operation and the TS definitions of OPERABLE/OPERABILITY.

to TXX-04195 Page 4 of 7 5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Determination TXU Generation Company LP has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in I OCFR50.92, 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 The proposed change has no impact on the probability of any accident previously evaluated. The consequences of the limiting transients and accidents (full power operation) are unaffected by the proposed change. At low power sufficient time is available to establish auxiliary feedwater injection if needed.

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 No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of these changes. There will be no adverse effect or challenges imposed on any safety-related system as a result of these changes. There are no changes in the method by which any safety-related plant system performs its safety function. Overall protection system performance will remain within the bounds of the previously performed accident analyses and the protection systems will continue to function in a manner consistent with the plant design basis. The proposed changes do not affect the probability of any event initiators. The proposed changes do not alter any assumptions or change any mitigation actions in the radiological consequence evaluations in the Final Safety Analysis Report (FSAR).

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

to TXX-04195 Page 5 of 7

3.

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

Response: No The proposed changes do not affect the acceptance criteria for any analyzed event nor is there a change to any Safety Analysis Limit (SAL). There will be no effect on the manner in which safety limits, limiting safety system settings, or limiting conditions for operation 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, the Departure from Nucleate Boiling Ratio (DNBR) limits, the Heat Flux Hot Channel Factor (FQ), the Nuclear Enthalpy Rise Hot Channel Factor (Fmg), the Loss of Coolant Accident Peak Centerline 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.

Since the limiting transients and accidents are unaffected, the proposed change does not involve a reduction in a margin of safety.

Based on the above evaluations, TXU Energy concludes that the proposed amendment(s) present no significant hazards consideration under the standards set forth in 1 OCFR50.92(c) and, accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements/Criteria The regulatory bases and guidance documents associated with the auxiliary feedwater system include:

GDC 2 requires that structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.

GDC 4 requires that structures, systems, and components important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.

GDC 5 requires that structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

Attachment I to TXX-04195 Page 6 of 7 GDC 44 requires that a system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions.

GDC 54 requires that piping systems penetrating primary reactor containment shall be provided with leak detection, isolation, and containment capabilities having redundancy, reliability, and performance capabilities which reflect the importance to safety of isolating these piping systems. Such piping systems shall be designed with a capability to test periodically the operability of the isolation valves and associated apparatus and to determine if valve leakage is within acceptable limits.

GDC 57 requires that each line that penetrates primary reactor containment and is neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere shall have at least one containment isolation valve which shall be either automatic, or locked closed, or capable of remote manual operation. This valve shall be outside containment and located as close to the containment as practical. A simple check valve may not be used as the automatic isolation valve.

There will be no changes to the auxiliary feedwater system design such that compliance with any of the regulatory requirements and guidance documents above would come into question. The auxiliary feedwater system will continue to comply with all applicable regulatory requirements.

In conclusion, 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) the 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 Power 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 1 OCFR20, 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 1 OCFR51.22 (c)(9). Therefore, pursuant to 1 OCFR5 1.22 (b), an environmental assessment of the proposed change is not required.

Attachment I to TXX-04195 Page 7 of 7 7.0.

PRECEDENT 7.1 Indian Point Nuclear Generating Unit No. 2, TAC No. M98056.

8.0 REFERENCES

8.1 TSTF-245-A, Revision 1, "AFW Train Operable When in Service", dated July 31, 2003.

ATTACHMENT 2 to TXX-04195 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Pages 3.7-14 3.7-15

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY t

SR 3.7.5.1

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31 days SR 3.7.5.2

---

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

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after 2 532 psig in the steam generator.

Verify the developed head of each AFW pump at the flow In accordance test point is greater than or equal to the required with the Inservice developed head.

testing Program SR 3.7.5.3

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a tFW traini(s) may b sdeed OPERABLE duririg Alignment and nopeam generator level ControI, lil~t iscp~e -t 532 psig in the steam generator.

Verify the developed head of each AFW pump at the flow In accordance with test point is greater than or equal to the required the Inservice developed head.

testing Program SR 3.7.5.3

---

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

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW automatic valve that is not locked, 18 months sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 3.7-14 Amendment No.

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

I.

SURVEILLANCE FREQUENCY I.

SR 3.7.5.4

---

NOTES------------------------------------

1. Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after 2 532 psig in the steam generator.

2. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

I Verify each AFW pump starts automatically on an actual or simulated actuation signal.

18 months COMANCHE PEAK - UNITS 1 AND 2 3.7-15 Amendment No.

ATTACHMENT 5 to TXX-04195 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (RETYPED)

(FOR INFORMATION ONLY)

Pages B 3.7-32 B 3.7-34

i.

AFW System B 3.7.5 BASES (continued)

ACTIONS D.1 (continued)

If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.

Required Action D.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

This SR is modified by a note stating that one or more AFW trains may be considered OPERABLE during alignment and operation for steam generator water level control, if it is capable of being manually realigned to the AFW mode of operation and provided it is not otherwise inoperable.

This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable and applies only when the unit is below 10% RATED THERMAL POWER. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW system, OPERABILITY is maintained. The ability to realign the affected AFW train(s) to a standby condition or to an in-service condition supplying feedwater to the steam generator(s) assures the intended safety function is available. Realignment of the AFW train(s) is normally performed from the Control Room. However, when explicitly allowed by Operations' procedure, this provision may also be applied to local manual operation of AFW valves.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-32 Revision

AFW System B 3.7.5 BASES (continued)

SURVEILLANCE REQUIREMENTS SR 3.7.5.3 (continued) the turbine driven auxiliary feedwater pump. This Surveillance is not required for valves that are locked sealed or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply durin a unit outage and the potential for an unplanned transient if the surveillance were performed with the reactor at power.

The 18 month Frequency is acceptable based on operating experience and the design reliability of the equipment.

This SR is modified by a note stating that one or more AFW trains may be considered OPERABLE during alignment and operation for steam generator water level control, if it is capable of being manually realigned to the AFW mode of operation and provided it is not otherwise inoperable.

This exception allows the system to be out of its normal standby ali nment and temporarily incapable of automatic initiation without declaring tie train(s) inoperable and applies only when the unit is below 10% RATED THERMAL POWER. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam aenerator level control, and these manual operations are an accepted function of the AFW system, OPERABILITY is maintained. The ability to realign the affected AFW train(s) to a standby condition or to an in-service condition supplying feedwater to the steam aenerator(s) assures the intended safety function is available. Reali nmenfof the AFW train(s) is normally performed from the Control Room. However, when explicitly allowed by Operations' procedure, this provision may also be applied to local manual operation of AFW valves.

SR 3.7.5.4 This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an ESFAS by demonstrating that each AFW pump starts automatically on an actual or simulated actuation generated v an auxiliary feedwater actuation signal in MODES 1 2, and a. In MODE 4, the required pump is already operating and the autostart function Is not required. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

This SR is modified by two notes. Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.

Note 2 states that one or more AFW trains may be considered OPERABLE during alignment and operation for steam a enerator water level control, if it is capable of being manually realignecdto the AFW mode of operation and provided it is not otherwise inoperable. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable and applies only when the unit is below 10% RATED THERMAL POWER. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW system, OPERABILITY is maintained. The ability to realign the affected AFW train(s) to a standby condition or to an in-service condition supplying feedwater to the steam generator(s) assures the intended safety function is available. Realia nmenf of the AFW train(s) is normally performed from the ControrRoom. However, when explicitly allowed by Operations' procedure, this provision may also be appried to local manual operation of AFW valves.

REFERENCES

1.

FSAR, Sections 7.3 and 10.4.9.

2.

ASME, Boiler and Pressure Vessel Code, Section Xl.

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-34 Revision