ML070440346

License Amendment, Issuance of Amendment Nos. 133 & 133 Revision to TS 3.3.1.2 and 3.3.1.3, Reactor Trip System Instrumentation (TAC Nos. MC9492 & MC9493)

ML070440346
Person / Time
Site:	Comanche Peak
Issue date:	02/26/2007
From:	Thadani M NRC/NRR/ADRO/DORL/LPLIV
To:	Blevins M TXU Power
Thadani, M C, NRR/DORL/LP4, 415-1476
Shared Package
ML070440342	List: ML070440346 ML070440371
References
TAC MC9492, TAC MC9493
Download: ML070440346 (4)

Text

February 26, 2007 Mr. M. R. Blevins Senior Vice President

& Chief Nuclear Officer TXU Power ATTN: Regulatory Affairs P. O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 -

ISSUANCE OF AMENDMENTS RE: REVISION TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS 3.3.1.2 AND 3.3.1.3, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION (TAC NOS. MC9492 AND MC9493)

Dear Mr. Blevins:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 133 to Facility Operating License No. NPF-87 and Amendment No. 133 to Facility Operating License No.

NPF-89 for Comanche Peak Steam Electric Station, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated December 12, 2005.

The amendments revise the TS Surveillance Requirements (SRs) 3.3.1.2 and 3.3.1.3, Reactor Trip System (RTS) Instrumentation. The license amendment request is based on Technical Specification Task Force (TSTF) Traveler, TSTF-371-A, Revision 1, NIS [Nuclear Instrumentation System] Power Range Channel Daily SR TS Change to Address Low Power Decalibration. TSTF-371-A, Revision 1, revised the requirements for performing a daily surveillance adjustment of the power range channel(s) to address industry concern that compliance with SR 3.3.1.2 and SR 3.3.1.3 may result in a non-conservative channel calibration during reduced-power operations. The proposed changes resolve this issue.

M. R. Blevins A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosures:

1. Amendment No. 133 to NPF-87

2. Amendment No. 133 to NPF-89

3. Safety Evaluation cc w/encls: See next page

Pkg ML070440342 (Amdt./License ML070440346, TS Pgs ML070440371)

• See SE input.

OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/ITSB/BC NRR/EICB/BC OG - NLOC NRR/LPL4/BC NAME MThadani LFeizollahi TKobetz* AHowe* TCampbell DTerao DATE 2/26/07 2/15/07 10/3/06 10/13/06 2/22/07 2/26/07 Comanche Peak Steam Electric Station cc:

Senior Resident Inspector Mr. Richard A. Ratliff, Chief U.S. Nuclear Regulatory Commission Bureau of Radiation Control P.O. Box 2159 Texas Department of Health Glen Rose, TX 76403-2159 1100 West 49th Street Austin, TX 78756-3189 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Mr. Brian Almon 611 Ryan Plaza Drive, Suite 400 Public Utility Commission Arlington, TX 76011 William B. Travis Building P.O. Box 13326 Mr. Fred W. Madden, Director 1701 North Congress Avenue Regulatory Affairs Austin, TX 78701-3326 TXU Generation Company LP P.O. Box 1002 Ms. Susan M. Jablonski Glen Rose, TX 76043 Office of Permitting, Remediation and Registration George L. Edgar, Esq. Texas Commission on Environmental Morgan Lewis Quality 1111 Pennsylvania Avenue, NW MC-122 Washington, DC 20004 P.O. Box 13087 Austin, TX 78711-3087 County Judge P.O. Box 851 Terry Parks, Chief Inspector Glen Rose, TX 76043 Texas Department of Licensing and Regulation Environmental and Natural Boiler Program Resources Policy Director P.O. Box 12157 Office of the Governor Austin, TX 78711 P.O. Box 12428 Austin, TX 78711-3189 December 2004

TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 1 DOCKET NO. 50-445 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 133 License No. NPF-87

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by TXU Generation Company LP dated December 12, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications and paragraph 2.C.(2) of Facility Operating License No. NPF-87 as indicated in the attachment to this license amendment.

3. The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: February 26, 2007

TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 133 License No. NPF-89

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by TXU Generation Company LP dated December 12, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications and paragraph 2.C.(2) of Facility Operating License No. NPF-89 as indicated in the attachment to this license amendment.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: February 26, 2007

ATTACHMENT TO LICENSE AMENDMENT NO. 133 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 133 TO FACILITY OPERATING LICENSE NO. NPF-89 DOCKET NOS. 50-445 AND 50-446 Replace the following pages of the Facility Operating Licenses, Nos. NPF-87 and NPF-89, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License No. NPF-87 REMOVE INSERT Facility Operating License No. NPF-89 REMOVE INSERT Technical Specifications REMOVE INSERT 3.3-10 3.3-10

(3) TXU Generation Company LP, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time, special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, and described in the Final Safety Analysis Report, as supplemented and amended; (4) TXU Generation Company LP, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use, at any time, any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) TXU Generation Company LP, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) TXU Generation Company LP, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level TXU Generation Company LP is authorized to operate the facility at reactor core power levels not in excess of 3458 megawatts thermal in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 133 and the Environmental Protection Plan contained l in Appendix B, are hereby incorporated into this license. TXU Generation Company LP shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Amendment No. 133

(3) TXU Generation Company LP, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time, special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, and described in the Final Safety Analysis Report, as supplemented and amended; (4) TXU Generation Company LP, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use, at any time, any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) TXU Generation Company LP, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) TXU Generation Company LP, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level TXU Generation Company LP is authorized to operate the facility at reactor core power levels not in excess of 3458 megawatts thermal in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 133 and the Environmental Protection Plan contained l in Appendix B, are hereby incorporated into this license. TXU Generation Company LP shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions DELETED Amendment No. 133

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 133 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 133 TO FACILITY OPERATING LICENSE NO. NPF-89 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446

1.0 INTRODUCTION

By letter dated December 12, 2005 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML053570277), TXU Generation Company LP (the licensee) submitted a license amendment request for Comanche Peak Steam Electric Station, Units 1 and 2, based on Technical Specification Task Force (TSTF) Traveler, TSTF-371-A, Revision 1, NIS [Nuclear Instrumentation System] Power Range Channel Daily SR [Surveillance Requirement] TS [Technical Specification] Change to Address Low Power Decalibration.

TSTF-371-A, Revision 1, revised the requirements for performing a daily surveillance adjustment of the power range channel(s) to address industry concern that compliance with SR 3.3.1.2 and SR 3.3.1.3 may result in a non-conservative channel calibration during reduced-power operations. The proposed changes resolve the this issue.

The licensee has proposed changes to the TS bases in support of the proposed changes to TS SR 3.3.1.2 and SR 3.3.1.3. The proposed changes are similar to the standard technical specifications (STS), and account for plant-specific differences.

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act (the Act) requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The Commissions regulatory requirements related to the content of the TSs are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36. That regulation requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings (10 CFR 50.36(c)(1));

(2) limiting conditions for operation (10 CFR 50.36(c)(2)); (3) SRs (10 CFR 50.36(c)(3));

(4) design features (10 CFR 50.34(c)(4)); and (5) administrative controls (10 CFR 50.36(c))(5)).

In general, there are two classes of changes to TSs: (1) changes needed to reflect modifications to the design basis (TSs are derived from the design basis), and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TS over time. This amendment deals with the second class of changes. In determining the acceptability of revising STSs 3.7.2 and 3.7.3, the Nuclear Regulatory Commission (NRC) staff used the accumulation of generically-approved guidance in NUREG-1430, Standard Technical Specifications Babcock and Wilcox Plants, Revision 3, dated June 2004; NUREG-1431, Revision 3, Standard Technical Specifications Westinghouse Plants, dated June 2004; and NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 3, dated June 2004.

Licensees may revise the TSs to adopt current improved STS format and content provided that plant-specific review supports a finding of continued adequate safety. Such a finding will be made if: (1) the change is editorial, administrative, or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensees current requirement, or (3) the change is less restrictive than the licensees current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance for the specified plants, are discussed in Section 3.0 of this SE, in the context of specific proposed changes.

3.0 TECHNICAL EVALUATION

The proposed changes adopt NRC-approved generic changes in the industry TSTF-371-A, Revision 1, wich was approved by the NRC staff in a letter dated April 2, 2002. As stated by the NRC staff in its discussion of TSTF-371-A, the TSTF revises SR 3.3.1.2 to resolve the undesirable condition that compliance with the current SR 3.3.1.2 may result in a non-conservative channel calibration during reduced-power operations. The proposed SR 3.3.1.2 would only require adjustment of the NIS power range channels and the N-16 Power Monitor channels when the calorimetric heat-balance calculated power is greater than the power range indicated power by 2 percent. Additionally, conforming editorial changes would be made to SR 3.3.1.3 because of the changes to SR 3.3.1.2.

The NIS power range channels and N-16 Power Monitor channels provide indications of reactor power. These are included in TS Table 3.3.1-1, for the Reactor Trip System (RTS) trip functions for power range neutron flux high (function 2.a), overtemperature N-16 (function 6),

and overpower N-16 (function 7). SR 3.3.1.2 requires daily surveillance of the NIS power range channels and the N-16 Power Monitor channels to ensure the channels accurately reflect the reactor power based on the calorimetric heat-balance calculation. A low-power indication in the NIS power range channels and N-16 Power Monitor channels would non-conservatively affect the RTS, and thus, the protection of the reactor.

The proposed amendment removes the requirement to adjust the NIS power range channels and N-16 Power Monitor channels in the decreasing power direction when the indicated power is greater than the calorimetric heat-balance calculation by more than 2-percent rated thermal power (RTP). The licensee stated that compliance with existing SR 3.3.1.2 may result in a non-conservative channel calibration during reduced-power operation. The licensee's

presentation of the changes to TS Bases for SR 3.3.1.2 provides a description of the potential decalibration of the NIS power range channels at reduced-power operation.

The current SR 3.3.1.2 Note 1 requires the power range channel and N-16 Power Monitor channel outputs to be adjusted when the absolute difference between the channel output and the calorimetric heat-balance calculation is greater than 2-percent RTP. With the content of Note 1 moved into the SR and by removing the reference to the absolute difference, the revised SR 3.3.1.2 is unchanged except that the revised SR would require the power range channel and N-16 Power Monitor channel to be adjusted only when the calorimetric heat-balance calculation results exceed the power range channel output by 2-percent RTP. Therefore, if the power range channels and N-16 Power Monitor channels are underestimating reactor power by more than 2-percent RTP, the channels are required to be adjusted to indicate power more accurately. The 2-percent RTP limit and the daily surveillance frequency are sufficient to ensure that the power range high-neutron flux high, overtemperature N-16, and overpower N-16 setpoint reactor trip signals will be generated prior to the safety analysis limit. The calorimetric heat-balance calculation is considered the more accurate determination of reactor power. This change does not affect the design of any NIS channel or N-16 Power monitor channel.

For SR 3.3.1.3, the licensee has proposed to revise the format of Note 1 to be consistent with the format of SR 3.3.1.3. The proposed change moves the requirement in Note 1 of SR 3.3.1.3 into the body of the SR and the acronym NIS is spelled out because it no longer appears in SR 3.3.1.2. The requirements in SR 3.3.1.3 remain unchanged; excore NIS channels are adjusted every 31 effective full power days if the absolute difference between the incore and excore axial flux difference is greater than or equal to 3-percent RTP. This proposed change to SR 3.3.1.3 is editorial in nature because the requirements of SR 3.3.1.3 are not being changed.

Based on the above evaluation, the NRC staff concludes the proposed change to SR 3.3.1.2 accounts for potential effects of decalibrating the NIS power range channels and N-16 Power Monitor channels during reduced-power operation; will ensure that the power range high-neutron flux high, overtemperature N-16, and overpower N-16 setpoint reactor trip signals will be generated prior to the safety analysis limit; and does not change the design of any NIS channel or N-16 Power Monitor channel or alter conformance with the regulatory requirements stated in Section 2.0 of this Safety Evaluation. The NRC staff finds that the NIS power range channels and N-16 Power Monitor channels continue to meet General Design Criterion 13 because appropriate controls are provided to maintain reactor power within prescribed operating ranges for normal operation, anticipated operational occurrences, and accidents to ensure adequate safety. For the proposed change to SR 3.3.1.3, the NRC staff concludes that the change is editorial in nature and does not change the requirement of SR 3.3.1.3. Based on these conclusions, the NRC staff further concludes that the proposed amendments are acceptable.

In its application, the licensee presented the changes to be made to the TS Bases that address the potential decalibration of the NIS power range channels and N-16 Power Monitor channels at reduced-power operation. Since the Bases are not part of the TSs, the NRC staff reviewed the Bases only to assure consistency with the proposed changes. The NRC staff is not approving the Bases changes, but is including the revised bases pages for completeness.

The NRC staff finds the proposed change to revise SR 3.3.1.2 for performing a daily surveillance adjustment of the power range channel(s) and N-16 Power Monitor channel(s) above 15-percent RTP to include only changes in the increasing direction and the revised formats of SR 3.3.1.2 and SR 3.3.1.3 to establish a consistent presentation of notations for SRs will allow safe operation. The NRC staff, therefore, concludes that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change an SR.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published March 28, 2006 (71 FR 15490). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Trent Wertz Date: February 26, 2007