ML050390544
| ML050390544 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/16/2005 |
| From: | Thadani M NRC/NRR/DLPM/LPD4 |
| To: | Blevins M TXU Energy |
| Thadani M, NRR/DLPM, 415-1476 | |
| References | |
| TAC MC2620, TAC MC2621 | |
| Download: ML050390544 (5) | |
Text
February 16, 2005 Mr. Michael R. Blevins Senior Vice President &
Principal Nuclear Officer TXU Energy Attn: Regulatory Affairs Department P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 -
REQUEST FOR ADDITIONAL INFORMATION RE: THE REVIEW OF REQUEST FOR REVISION OF TECHNICAL SPECIFICATION 3.3.2 (TAC NOS. MC2620 AND MC2621)
Dear Mr. Blevins:
By letter dated April 13, 2004, TXU Generation Company LP (the licensee) requested amendments to the operating licenses for Comanche Peak Steam Electric Station, Units 1 and 2 respectively. The amendments requested revision to the Technical Specification 3.3.2, Engineered Safety Features Actuation System (ESFAS).
The Nuclear Regulatory Commission staff has reviewed your requests and finds that, in order to complete its reviews, we need additional information. We request that you review the enclosed request for additional information and provide responses to the stated questions.
These questions were discussed with your staff during our telephone conference call on February 3, 2005. It was subsequently agreed that TXU Generation Company, LP will provide responses by March 11, 2005, to facilitate the timely completion of our review.
If there are any questions regarding this request, please contact me at (301) 415-1476.
Sincerely,
/RA/
Mohan C. Thadani, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosure:
Request for Additional Information cc w/encl: See next page
ML050390544 OFFICE PDIV-1/PM PDIV-1/LA EEIB/SC PDIV-1/SC NAME MThadani DBaxley EMarinos AHowe DATE 2/16/05 2/16/05 2/15/05 2/16/05
1 To access the document, go to www.nrc.gov, click on Electronic Reading Room, then Documents in ADAMS, then Web-Based Access, then "Begin ADAMS Search," then Advanced Search, and enter the Accession number into the Accession Number box near the top of the page. Click on the Search button near the bottom of the page. You will need to select Image File on the search results page to view the document. NOTE: You will need Adobe Acrobat Reader to open this file.
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES), UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION (TS) 3.3.2, ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (TAC NOS. MC2620 AND MC2621) 1.
Please provide setpoint calculation document of the refueling water storage tank (RWST) level low-low (TS 3.3.2, Function 7b) protection function which has allowable value revised for this license amendment request.
2.
The CPSES, Units 1 and 2, Technical Specifications (TSs) define Limiting Safety System Settings (LSSS) as an allowable value (AV). During reviews of proposed license amendments that contain changes to LSSS setpoints, the NRC staff identified concerns regarding the method used by some licensees to determine the AVs identified in the TSs. AVs are identified in the TS as LSSS to provide acceptance criteria for determination of instrument channel operability during periodic surveillance testing. The NRC staffs concerns relate to one of the three methods for determining the AV as described in the Instrument Society of America (ISA) recommended practice ISA-RP67.04-1994, Part II, Methodologies for Determination of Setpoints for Nuclear Safety-Related Instrumentation.
The staff has determined that, absent additional requirements related to determining the operability of the instrument channel, AVs associated with LSSS established by means of ISA-RP67.04, Part II, Method 3, will not provide reasonable assurance that a plant will operate in accordance with the assumptions upon which the plant safety analyses have been based. Details about the NRC staff's concerns are available on the NRC's public website under ADAMS Accession Numbers ML041690604 and ML0418103461.
In order for the NRC staff to assess the acceptability of your license amendment request related to this issue, the NRC staff requests the following additional information:
1.
Discuss the setpoint methodology used at CPSES, Units 1 and 2, to establish AVs associated with LSSS setpoints.
2.
Regardless of the methodology used, the NRC staff has the following questions regarding the use of the methodology at CPSES, Units 1 and 2:
a.
Discuss how the methodology and controls you have in place ensure that the analytical limit associated with an LSSS trip setpoint will not be exceeded (that safety limits will not be exceeded). Include in your discussion information on the controls you employ to ensure the trip
2 setpoint established after completing periodic surveillances satisfies your methodology. If the controls are located in a document other than the CPSES, Units 1 and 2 TS, discuss how those controls satisfy the requirements of 10 CFR 50.36.
b.
Discuss how the TS surveillances ensure the operability of the instrument channel. Specifically, relate the surveillance test results to the TS AV and describe how these are used to determine the operability of the instrument channel. If the requirements for determining operability of the LSSS instrument being tested are in a document other than the TS (e.g., plant test procedure), discuss how this meets the requirements of 10 CFR 50.36.
3.
The licensees submittal indicated that Veritrack transmitters were replaced by Rosemount transmitters for the RWST level measurement. Are there any other Veritrack transmittals still serving safety-related function?
December 2004 Comanche Peak Steam Electric Station cc:
Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 2159 Glen Rose, TX 76403-2159 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. Fred W. Madden, Director Regulatory Affairs TXU Generation Company LP P. O. Box 1002 Glen Rose, TX 76043 George L. Edgar, Esq.
Morgan Lewis 1111 Pennsylvania Avenue, NW Washington, DC 20004 County Judge P. O. Box 851 Glen Rose, TX 76043 Environmental and Natural Resources Policy Director Office of the Governor P. O. Box 12428 Austin, TX 78711-3189 Mr. Richard A. Ratliff, Chief Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189 Mr. Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Ms. Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122 P. O. Box 13087 Austin, TX 78711-3087 Terry Parks, Chief Inspector Texas Department of Licensing and Regulation Boiler Program P. O. Box 12157 Austin, TX 78711