ML20067C849
| ML20067C849 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/23/1994 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20067C853 | List: |
| References | |
| TXX-94034, NUDOCS 9403040296 | |
| Download: ML20067C849 (11) | |
Text
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l EE231:225 Log # TXX-94034 l
CC File # 916 (3/4.5) 0 Ref. # 10CFR50.90
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1UELECTRIC February 23, 1994 wimam J. c hm,Jr.
Gwup Vwe hendent U. S. Nuclear Regulatory Commission Attn:
Document Control Room Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 t
l SUBMITTAL OF LICENSE AMENDMENT REQUEST 94-005 EMERGENCY CORE COOLING SYSTEM (ECCS) LINE ITEM TECHNICAL SPECIFICATION (TS) IMPROVEMENTS l
l Gentlemen:
Pursuant to 10CFR50.90, TV Electric hereby requests an amendment to the CPSES Unit 1 Facility Operating License (NPF-87) and CPSES Unit 2 Facility Operating License (NPF 89) by incorporating the attached changes into the CPSES Units 1 and 2 Technical Specifications.
The requested changes modify the CPSES Technical Specifications to:
1) allow a one hour allowed outage time (A0T) following discovery of a closed cold leg injection accumulator discharge isolation valve in Modes 1, 2, or 3:
- 2) eliminate the redundant requirement to reverify accumulator boron concentration following fill from the Refueling Water Storage Tank (RWST):
- 3) relocate the accumulator water level and pressure channel Analog Channel Operational Test (ACOT) and Channel Calibration from the CPSES Technical Specifications to an administrative 1y controlled program:
- 4) change the accumulator limits to analysis values rather than indicated values and 5) reduce the inspection frequency following containment entries.
l TV Electric has prepared the requested changes to be consistent with 10CFR50,36a and requests that these changes be incorporated into the Technical Specifications as described in the attachments to this submittal. is an affidavit: provides a detailed description and assessment of the proposed changes: provides the proposed changes to the Technical Specifications.
Also enclosed are copies of Generic Letter (GL) 93-05, "Line Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation," and applicable portions of NUREG-1431, " Standard Technical Speci ficat ions,
Westinghouse Plants,"
In accordance with 10CFR50.91(b), TV Electric is providing the State of Texas with a copy of this requested amendment.
230085 Oh1 9403040296 940223 PDR ADOCK 05000445
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TXX-94034 Page 2 of 2 l
Upon NRC approval of the requested changes TV Electric requests a 30 day implementation period following the date of license amendment issuance, i
j Should you have any questions regarding the requested amendment, please contact Mr. Tom Light at (214) 812 8879.
1 Sincerely Williamd.EaTIill,Jr.
l l
TBL/vid l
Attachments:
1.
Affidavit 2.
Description and Assessment l
3.
Affected Technical Specification pages (NUREG-1468) as revised
Enclosures:
1.
Applicable portions of NUREG-1431 c-Mr.
L. J. Callan, Region IV Mr.
T.
A.
Bergman, NRR Hr.
L.
A.
Yandell, Region IV Resident Inspectors, CPSES (2)
Mr.
D.
K.
Lacker Bureau of Radiation Control Texas Department of Public Health 1110 West 49th Street Austin, Texas 78704
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. to TXX-94034 Page 1 of 1 UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION In the Matter of Texas Utilities Electric Company
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Docket Nos.
50-445
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50-446 (Comanche Peak Steam Electric
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License Nos, NPF-87 Station, Units 1 & 2)
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NPF-89 AFFIDAVJ.T William J. Cahill, Jr. being duly sworn, hereby deposes and says that he 4 Group Vice President, Nuclear for TV Electric, the licensee herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 94-005; that he is familiar with the conteat thereof; and that the matters set forth therein are true and correct to t1e best of his knowledge, information and belief, l
i L
VTT11am J. CDfill, Jr.
Group Vice President, Nuclear l
STATE OF TEXAS
)
l
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COUNTY OF SOMERVELl) l
(
Subscribed and sworn to before me, on this 23rd day of February 1994.
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PATNCM WLSON Notary Public W MSSOi EXMES March 16,1997 1
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ATTACilHENT 2 to TXX-94034 DESCRIPTION AND ASSESSMENT l
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. to TXX-94034 Page 1 of 7 DESCRIPTION AND ASSESSNENT I.
BACKGROUND 1
The Nuclear Regulatory Commission (NRC) issued NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements," in December 1992 to provide the results of a comprehensive examination of surveillance testing required by plant technical specifications.
This document found that while some testing at power is essential to verify equipment and system operability, safety can be improved, equipment degradation decreased, and unnecessary personnel burden relaxed by reducing the amount of testing performed while the plant is operating.
In September 1992, the NRC issued NUREG-1431, " Standard Technical Specifications, Westinghouse Plants," that incorporated the recommendations of NUREG-1366.
On September 27, 1993, the NRC issued Generic Letter (GL) 93-05, "Line-Item Technical Specification Improvements to Reduce Surveillance Testing During Power Operation." Using this Generic Letter, licensees were encouraged to propose technical specification changes that are consistent with the guidance provided.
Texas Utilities (TV) Electric is requesting changes to the Comanche Peak Steam Electric Station (CPSES) Technical Specifications (TS), incorporating the guidance of GL 93-05.
In addition, additional line-item changes which are consistent with the applicable sections of NUREG-1431, are being requested.
Implementation of the requested changes will avoid potentially unnecessary power reductions and reduce the performance of unnecessary surveillance testing.
II.
DESCRIPTION OF TECHNICAL SPECIFICATION CHANGE RE0 VEST The following specific changes are proposed for TS 3/4.5.1, " Emergency Core Cooling Systems, Accumulators, Cold Leg injection":
1.
Upon discovery of a closed cold leg injection accumulator discharge isolation valve in Modes 1,2, or 3. CPSES Technical Specification 3.5.1 Action "b" currently requires immediate action to reopen the valve or take the plant to Mode 3, Hot Standby, within six hours and reduce pressurizer pressure to less than 1000 psig within the following six hours.
In this condition, the required contents of three accumulators cannot be assumed to reach the core during a loss of coolant accident (LOCA).
Due to the severity of the consequences should a LOCA occur in this condition, it is desired to minimize the potential for exposure of the plant to a LOCA under this condition.
The requested change removes Action "b",
thus, if a cold leg injection accumulator discharge isolation valve is discovered closed as described above, Action "a" will apply, requiring the accumulator to be restored to an operable condition within one hour, or place the plant in Mode 3
. to TXX-94034 Page 2 of 7 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce pressurizer pressure within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. An associated wording change to Action "a" is also required, eliminating the exception specified for a closed isolation valve.
The requested change is consistent with NUREG-1431.
2.
Surveillance Requirement (SR) 4.5.1.lb states the following regarding demonstrating operability of each cold leg injection accumulator,
"...and within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each indicated solution volume increase of greater than or equal to 101 gallons (12% of span) by verifying the boron concentration of the solution....".
The purpose of this requirement is to ensure that operability of the accumulator is maintained, verifying the accumulator boron concentration following volume changes. However, this specification requires the reverification of accumulator boron concentration following a fluid addition to the accumulator greater than 101 gallons, regardless of the source of the addition.
The requested change would require the reverification of the accumulator boron concentration only for additions that do not emanate from the refuelingwaterstoragetank(RWST).
This change is in accordance with GL 93-05.
3.
A change is requested to relocate SR 4.5.1.2, the accumulator water level and pressure channel Analog Channel Operational Test (ACOT) and Channel Calibration, from CPSES Technical Specifications to an administratively controlled program.
These changes are consistent with industry recognition that accumulator instrumentation operability is not directly related to the capability of the accumulators to perform their safety function. This' change is in accordance with the guidance provided by GL 93-05.
Associated changes to Limiting Condition for Operation.(LCO) 3.5.1 and SR 4.5.1.1 are also requested, removing reference to " indicated" values and providing the analytical limits rather than indicated limits.
Verification of the critical parameters will be required, independent of the instrumentation used.
4.
BASES Section 3/4.5.1, " Accumulators", has been expanded and revised to discuss the bases for the limits provided in the LC0 and the required actions in the specification and does not introduce any additional changes.
The following specific change is requested for TS 3/4.5.2, "ECCS Subsystems -
Tavg > 350*F":
SR 4.5.2c for the Emergency Core Cooling Systems requires that a visual inspection be performed that verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of.the pump suctions during a loss of coolant accident (LOCA).
This visual inspection is
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. to TXX-94034 Page 3 of 7 required to be performed prior to establishing containment integrity and of affected areas within containment at the completion of each containment entry when containment integrity is established.
A change is requested to require the referenced inspection to be performed at least once daily of the areas affected within containment by containment entry and during the final entry when containment integrity is established.
This change is in accordance with the guidance provided in GL 93-05 and NUREG-1366.
In summary, the requested changes modify the CPSES Technical Specifications to:
1)allowaonehourallowedoutagetime(A0T)followingdiscoveryofa closed cold leg injection accumulator discharge isolation valve in Modes 1, 2, or 3;
- 2) eliminate the redundant requirement to reverify accumulator boron concentration following fill from the RWST;
- 3) relocate the accumulator water level and pressure channel Analog Channel Operational Test (ACOT) and Channel Calibration from the CPSES Technical Specifications to an administrative 1y j
controlled program;
- 4) change the accumulator limits to analysis values l
rather than indicated values and 5) reduce the inspection frequency following I
containment entries.
l The requested change to TS 3/4.5.2, "ECCS Subsystems - Tavg > 350*F", is based directly on GL 93-05.
(See Enclosure 1, Item 7.5.)
The other changes contained in the improved Standard Technical Specifications (STS)
(NUREG-1431), Specification 3.5.2 have not been included in this license amendment request.
The requested changes to TS 3/4.5.1, "ECCS, Accumulators,"
are also based directly on GL 93-05.
(See Enclosure 1, Items 7.1 and 7.4.)
Additional changes to TS 3/4.5.1 have been proposed to incorporate the technical content (not the format) of the improved STS TS 3.5.1.
III. ANALYSIS The changes described above continue to provide an adequate level of safety as described below:
1.
Without the requested change to CPSES Technical Specification 3.5.1 Action "b" for a closed accumulator discharge isolation valve, compliance with this action statement could potentially require an unnecessary plant transient without a corresponding safety benefit.
The risk associated with exposing the plant to transients during an unnecessary power reduction and restoration is believed to be greater than the risk associated with the additional unavailability associated with the requested one hour of A0T, and represents the safest course of action for CPSES.
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! to TXX-94034 Page 4 of 7 l
2.
The change to SR 4.5.1.lb is being requested to eliminate a redundant i
requirement that reverifies the accumulator boron concentration following a volume increase that comes from the RWST.
Elimination of i
this unnecessary surveillance requirement will have both an economic benefit for TU Electric and may also help reduce unnecessary radiation exposure to plant personnel performing the surveillance activity.
2 3.
The relocation of the accumulator water level and pressure channel ACOT and Channel Calibration from the CPSES Technical Specifications to an administratively controlled program is recognition that accumulator instrumentation operability is not directly related to the capability of the accumulators to perform their safety function.
This relocation represents a more appropriate location for these requirements while the technical specifications retain only the surveillance requirements required to confirm that the parameters defining accumulator operability are within limits assumed by the accident analyses.
4.
The requested change to the visual debris inspection requirement.s found in SR 4.5.2c reduces the required inspection of containment to at least once daily if containment has been entered that day, and during the final entry to ensure that there is no loose debris that would clog the ECCS sump. The elimination of the current requirement to perform a containment inspection for each containment entry on occasions in which multiple containment entries are performed on a single day has an ecenomic benefit for TV Electric and may reduce the personnel radiation exposure associated with these inspections.
IV.
SIGNIFICANT HAZARilS CONSIDERATIONS DETERMINAT10H As required by 10 CFR 50.91(a)(1), an analysis is provided below to demonstrate that the requested license amendment involves no significant hazards considerations.
1)
Operation of the Comanche Peak Steam Electric Station in accordance with the requested license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
l The current requirement to immediately open & cold leg accumulator discharge isolation valve (or shut down the unit) upon discovery that the valve is closed is modified by the requested change to provide a one hour allowed outage time (A0T) prior to requiring a unit shutdown.
This change is consistent with NUREG-1431.
The currently required action is more restrictive than that required by CPSES Technical Specification 3.0.3, that specifies the action required if an LC0 and its associated action requirements are not met and which provides a one hour A0T prior to taking steps to place the plant in Mode 3 within the following 6 i
hours. 'Following this requested change, the required actions for an accumulator declared inoperable due to a closed discharge isolation
- to TXX-94034 Page 5 of 7 valve will be identical to those actions required for inoperability for other reasons, with the exception of the accumulator boron concentration being out of specification that has an A0T of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Changing the A0T from "immediate" to one hour does not affect the probability of an accident.
The only previously evaluated accident that is potentially impacted is the Loss of Coolant Accident (LOCA). With all valves open and thus all accumulators available, a potential LOCA is bounded by the existing accident analyses. With one accumulator discharge isolation valve closed and thus one accumulator not available, the consequences of a LOCA could be more severe; however, this requested amendment does not create this scenario.
In other words, although the change in A0T may slightly increase the probability that, were a LOCA to occur, an accumulator would not be available (see the response to Question 3 below), it does not involve a significant increase in the consequences of an accident previously evaluated.
The requirement to test the accumulator boron concentration following a 101 gallon or greater solution volume increase is modified by the requested change to exclude volume additions from the Refueling Water Storage Tank (RWST).
Since the RWST boron concentration must be confirmed to satisfy the limits for the accumulators, there is no impact on the probability or consequences of any accident.
The relocation of the accumulator water level and pressure channel ACOT and Channel Calibration from CPSES Technical Specifications to an 1
administrative 1y controlled program is essentially an administrative change.
Because proper tests will still be performed, there is no impact on the probability or consequences of any accident.
The requested change to reduce the containment debris inspections from "at the completion of every entry" to "[a]t least once daily" will require fewer inspections and is consistent with SR 4.6.1.3 for the containment air locks.
The accident of concern is a LOCA and these inspections have no impact on the probability of a LOCA.
Performing fewer inspections would slightly increase the possibility that, should a LOCA occur, there could be debris in containment which could be transported to and partially clog the containment sump.
- However, inspecting at least daily if containment entries have been made is adequate and is justified by the reduced total radiation exposure for plant personnel.
The inspections conducted at least daily assures that there is not a significant increase in the consequence of any accident.
The requested changes do not modify the existing LCOs for Technical Specifications 3.5.1 and 3.5.2 with the exception of the replacement of
" indicated" values with analysis values in LCO 3.5.1, consistent with the relocation of the SRs for accumulator instrumentation.
The requested changes are consistent with NUREG-1431 and GL 93-05, and, as such, have already been generically assessed by the NRC.
It is concluded that the requested changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
. -. - _ _ - - - - - - - - - - - = -
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. to TXX-94034 Page 6 of 7 2)
The requested license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The only requested change that modifies current operation of the plant is the requested one hour allowed outage time for action following discovery of a closed cold leg accumulator discharge isolation valve.
The requested one hour completion time to open the valve continues to ensure that prompt action will be taken to return the inoperable accumulator to an operable status, minimizing the potential for exposure of the plant to a LOCA under this condition.
In addition, as LC0 3.5.la will continue to require that the accumulator discharge isolation valve be open with power removed from the valve operator, the probability of the discharge isolation valve being closed in Modes 1,2, or 3 will remain low.
This change in current operation does not create the possibility of a new or different kind of accident.
The requested slight reduction in the containment inspection frequencies specified in SR 4.5.2 only serves to reduce the number of unnecessary inspections.
It does not make substantial changes to the inspection requirements, nor does it change the method of performing these requirements.
Thus, the requested change does not create the possibility of a new or different kind of accident.
No significant changes to the limiting conditions for operation of the accumulators or the emergency core cooling system are requested as part of this amendment request. The requested changes do not involve any physical changes to the plant.
The requested changes are consistent with NUREG-1431 and GL 93-05, and, as such, have already been generically assessed by the NRC.
Thus, the requested changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
4 3)
The requested license amendment does not involve a significant reduction in a margin of safety.
The only requested change that modifies current operation of the plant is the requested one hour allowed outage time for action following discovery of a closed cold leg accumulator discharge isolation valve.
As noted in the response to Question 1 above, this requested change in A0T does not significantly affect the probability or consequences of an accident, but does increase the possibility that, should a LOCA occur, one of the accumulators may not be available to help mitigate the~
consequences of the accident.
However, the requested one hour completion time to open the valve continues to ensure that prompt action will be taken to return the inoperable accumulator to an operable status, minimizing the potential for exposure of the plant to a LOCA l
under this condition.
In addition, as LCO 3.5.la will continue to 4
require that the accumulator discharge. isolation valve be open with power removed from the valve operator,'the. probability of the discharge isolation valve being closed in Modes 1,2, or 3 will remain low.
Considering the controls above and the fact that the requested action statement is consistent with TS 3.0.3, it is concluded that the I
, to TXX-94034 Page 7 of 7 requested change does not involve a significant reduction in the margin of safety.
The requested slight reduction in the containment inspection frequencies specified in SR 4.5.2 only serves to reduce the number of unnecessary inspections conducted and reduce the personnel exposure associated with the inspections. As adequate inspections will continue to be conducted, this requested change does not involve a significant reduction in a margin of safety.
No significant changes to the limiting conditions for operation of the accumulators or the emergency core cooling systems are requested as part of.this amendment request.
The requested changes do not involve any physical changes to the plant.
The requested changes are consistent with NUREG-1366, NUREG-1431 and GL 93-05, and, as such, have already been generically assessed by the NRC.
Thus, it is concluded that the requested changes do not involve a significant reduction in a margin of safety.
==
Conclusion:==
On the basis of the above evaluations, TU Electric concludes that the activities associated with the requested changes satisfy the no significant hazards consideration standards of 10CFR50.92(c) and, accordingly, a no significant hazards consideration finding is justified.
V.
ENVIRONMENTAL EVALUATION TV Electric has evaluated the requested changes and has determined that the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts ofanyeffluentthatmaybereleaseduffsite,or(iii)asignificant increase in individual or cumulative occupational *adiation exposure.
3 Accordingly, the requested changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Therefore, pursuantto10CFR51.22(b),anenvironmentalassessmentofthe requested changes is not required.
VI.
REFERENCES NUREG-1366, " Improvements to Technical Specification Surveillance I
Requirements," December 1992 NUREG-1431, " Standard Technical Specifications, Westinghouse Plants,"-
September 1992 Generic Letter 93-05, "Line-Item Technical Specification Improvements to Reduce Surveillance Testing During Power Operation," September 1993.
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