ML20087J930

Requests Amend to Licenses NPF-87 & NPF-89,consisting of Change Request 95-06,moving RCS Flow Limits from TS to COLR & Providing Guidelines for Removal of cycle-specific Parameter Limits from TS

ML20087J930
Person / Time
Site:	Comanche Peak
Issue date:	08/15/1995
From:	Kelley J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20087J931	List: ML20087J930 ML20087J953
References
TXX-95216, NUDOCS 9508220243
Download: ML20087J930 (9)

Text

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s Log # TXX-95216' ll== 5 File # 916 (2.2)

_ .- 916 (3/4.2) clo'

=_ = 916 (6.0) clo 10010 7UELECTRIC Ref. # 10CFR50.90 10CFR50.36 c.t c. y.,,y August 15, 1995 Groep Yke PresMent.Narleer 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 SUBMITTAL OF LICENSE AMENDMENT REQUEST 95 06 CYCLE-SPECIFIC PARAMETER LIMITS RCS FLOW REF: 1) TV Electric letter logged, TXX-95076 from C. L. Terry to the NRC dated May 12, 1995 Gentlemen:

, Pursuant to 10CFR50.90, TU Electric 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 changes into the CPSES Units 1 and 2 Technical Specifications. These changes apply equally to CPSES Units 1 and 2.

The proposed changes in this license amendment request (LAR) were originally submitted in LAR 95 03 on May 12,1995 (reference 1). Based on subsequent discussions with the NRC, LAR 95 03 is being divided into four separate LARs for ease in processing by the NRC and to allow review of the four basic changes separately. The changes which move the Reactor Coolant System (RCS) Flow limits from the Technical Specifications to the Core Operating Limits Report are resubmitted herein. The proposed changes will result in resource savings for TU Electric and the NRC by eliminating license amendment requests now required to change the values of these- I parameters. The proposed changes are consistent with the intent of Generic Letter (GL) 8816 which provides guidelines for the removal of cycle specific parameter limits from the Technical Specifications.

Attachment 2 provides a detailed description of the proposed changes, a

! safety analysis of the changes, and TV Electric's determination that the

! proposed changes do not involve a significant hazard consideration.

I Atta63et 3 provides the affected Technical Specification pages (NUREG-l M@?, erked up to reflect the proposed changes.

TU Electric requests approval of this proposed license amendment by i February 29. 1996, with implementation of the technical specification j changes to occur within 30 days of approval. i 1

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TXX 95216  :

-Page 2 of 2  ;

i E :In accordance with 10CFR50.91(b).-TU Electric is providing the State.of l

~ Texas with a copy of this proposed amendment.  ;

Should you have any questions', please contact Mr.' Bob Dacko at i

'(214) 812 8228. l i

f Sincerely. l I

i C. L. Terry' By:

JY J. Kelley, Jr.  !

Vice President of Nuclear  !

Engineering and Support  ;

i BSD/bd l Attachments:  !

1. Affidavit

2. Description and Assessment  ;

3. Affected Technical Specification page (NUREG 1468) as revised by.all approved license amendments

Enclosure:

1. Generic Letter 88 16 ,

c- Mr. L. J. Callan, Region IV j Mr. T. J. Polich, NRR  !

Mr. D. F. Kirsch, Region IV  ;

Resident Inspectors, CPSES l t

Mr. Arthur C. Tate  ;

Bureau of Radiation Control i Texas Department of Public Health i 1100 West 49th Street '

Austin. Texas 78704 l

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Attachment 1 to TXX-95216 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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Texas Utilities Electric Company ) Docket Nos. 50 445

) 50 446 (Comanche Peak Steam Electric ) License Nos. NPF-87 l- Station Units 1 & 2) ) NPF 89 l-l AFFIDAVIT l

J. J. Kelley, Jr. being d:ly sworn, hereby deposes and says that he is Vice President of Nuclear Engineering and Support for TV Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 95 06: that he is familiar with the content thereof: and that the matters set forth therein are true and correct to the best of his kno- 1e, information and belief.

X J. Kelley, Jr.

Vice President of Nuclear Engineering and Support STATE OF TEXAS )

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COUNTY OF )

Subscribed and sworn to before me, on this I day of b40ST o

Notary Public DONALD R. WOOOLAN Notory Public GCommamon Expees 4-9-96 State of Tens

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/4ttachment 2 to TXX 95216 Page 1 of 5  :

i DESCRIPTION AND ASSESSMENT-  ;

I. BACKGROUND ,

TV Electric proposes to remove several cycle specific-parameter limits  :

from the Technical Specification (TS) and to add these limits to the Core i Operating Limits Report (COLR).-The addition of these limits to the COLR is a result of the evolution from contractor performed reload analyses  :

(Westinghouse) to TU Electric performed reload analyses. The content of ,

the current COLR was primarily based on the Westinghouse determination of i what plant specific parameter limits .should be in the COLR to support  ;

reload analyses using their methodologies. TU Electric has largely replaced the need for Westinghouse reload methodologies through the l development and subsequent NRC approval of TU Electric reload l methodologies. Part of the desirability of performing in house reload analyses is the ability to perform trade offs between operating margins  :'

and analytical design margins, whenever appropriate, to optimize the economic performance of the plant while maintaining the required margin of  ;

safety. The removal of these parameter limits from the TS and their  ;

addition to the COLR improves the efficiency of this process. ,

The removal of these limits from the TS is consistent with the guidance  !

provided in Generic Letter (GL) 85-16. " Guidance for Technical  !

Specification Changes for Cycle Specific Parameter Limits" (reference 1).  ;

The limits presented in the COLR may be modified, provided the  !

requirements of Specification 6.9.1.6 are met (i.e., the modifications are  !

determined using NRC approved methodologies and meet all applicable limits  !

of the plant safety analysis). The proposed changes result in resource i savings for TV Electric and the NRC by eliminating the periodic license i amendment requests that would be required for changes to the values of these cycle specific parameters. ,

The changes contained in this request are plant specific and did not i result from changes recommended in the improved Standard Technical 4 Specifications for Westinghouse Plants, NUREG 1431. The CPSES Technical Specifications remain consistent with NUREG 1431. t i

II. DESCRIPTION OF TECHNICAL SPECIFICATIONS CHANGE REQUEST  ;

The affected Technical Specifications are:

1) Table 2.2.1, " Reactor Trip System Instrumentation Set points" The value of the Loop design flow, denoted by "**" and the Loop 3 minimum measured flow, denoted by "***" (Functional Unit 12), are removed and a referral to the COLR is added.

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P Attachment 2 to TXX 95216 Page 2 of 5

2) 3/4.2.5 "DNB Parameters" The proposed changes remove the indicated Reactor Coolant System flow limits specified in section (c) and insert an appropriate reference to the COLR.

3) 6.9.1.6. " Core Operating Limits Report" The proposed changes modify Specification 6.9.1.6a by adding the >

removed parameter limits to the list of' items contained in the COLR.

including a reference to the implementing Technical Specifications.

In addition, Specification 6.9.1.6b items 1), 9), and 13) are revised to specify the removed parameter limits and their implementing specifications.

l In summary, TU Electric proposes to revise the CPSES Technical Specifications by removing the cycle specific parameter limits for RCS Flow from the Technical Specifications, adding this parameter to the list of parameter limits in the COLR, and adding the appropriate references to Administrative Controls section of the Technical Specifications. The parameter limits are:

. the design and minimum measured loop flow for the Reactor Coolant Flow trip function, and

- the minimum indicated Reactor Coolant System (RCS) flow.

III. ANALYSIS Recognizing that the accident analyses may change from cycle to cycle, the  !

NRC issued Generic Letter (GL) 8816 which provides guidelines for the removal of cycle specific limits of selected parameters from the Technical Specifications. In order to remove cycle specific limits, the Generic Letter requires: (1) the addition of the definition of a named formal report that includes the cycle specific parameter limits that have been established using NRC-approved methodology and consistent with all applicable limits of the safety analysis, (2) the addition of an administrative reporting requirement to submit the formal report on cycle-specific parameter limits to the Commission for information, and (3) the modification of individual technical specification sections to note that the cycle specific parameters shall be maintained within the limits provided in the defined formal report.

TU Electric has previously defined the Core Operating Limits Report (COLR), in Specification 1.10, as the appropriate formal report for cycle-specific parameter limits. Appropriate administrat1ve controls requiring the use of NRC approved methodology and providing the reporting requirements for the COLR have also been previously defined in i Specification 6.9.1.6.Section II above and Attachment 3 describe the modifications to the specific affected Technical Specification sections including appropriate references to the COLR.

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' Attachment 2 to TXX 95216' Page 3 of.5

'The cycle specific nature of the parameter limits for RCS Flow to be. [

removed is discussed below: f The actual RCS flow rate must meet or exceed the Thermal Design Flow (TDF) rate (i.e., the analytical flow rate used in accident analyses). If supported by the actual RCS flow, the TDF for a specific cycle may be increased in the accident analyses to maintain ,

the required margin of safety while supporting the use of more cost- .

effective reload core designs. In addition, if it becomes necessary '

to plug a significant number of steam generator tubes, a reduction in the TDF may be required. Typically, the need for a TDF reduction would be identified as a result of testing performed during a refueling outage: hence, the need for a " rapid turn around" technical specification change may be reduced by the removal of the Thermal Design Flow parameter limit from the Technical '

Specifications. ,

c Values of the RCS flow rate are presented in two places in the CPSES l Technical Specifications. The value of the loop TDF is specified in Table 2.2-1 in association with the low RCS flow reactor trip set

)oint. The current accident analyses for the two CPSES units are

)ased on two different methodologies for including the uncertainty in the RCS flow measurement. As a result, the CPSES Unit I low RCS flow reactor trip set point is based on the Thermal Design Flow while the CPSES Unit 2 low RCS flow reactor trip set point is based on the " minimum measured flow." The proposed change would generalize the trip set point presented in Table 2.2 1 to read "90% 'i of loop flow." The correct flow, minimum measured or thermal design, would be specified in the COLR for each unit consistent with ,

the accident analyses supporting that unit. '

In addition the minimum acceptable value of total indicated RCS flow is specified in Technical Specification 3.2.5.. This value is based on the total RCS flow (i.e., the sum of all'.four loop flows)  ;

and includes an allowance of 1.8% for the uncertainty associated '

with the measurement of the RCS flow. The 1.8% allowance is also specified in TS 3.2.5.

Administrative Controls Consistent with the requirements of GL 88-16. the Administrative Controls section of the Technical Specifications has been revised to ensure that  ;

the removed parameter limits are contained in the COLR. and that those limits are established using NRC approved methodology and are consistent with all applicable limits of the safety analysis.

l Summary The limits on the parameters which are removed from the Technical Specifications and added to the COLR must be developed or justified using NRC approved methodologies. All accident analyses, performed in l

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Attachment 2 to TXX-95216 Page 4 of 5 accordance with these methodologies, must meet the applicable, NRC-approved limits of the safety analysis. The removal of parameter limits from the Technical Specification and their addition to the COLR does not obviate the requirement to operate within those limits. Furthermore, any changes to these limits must be performed in accordance with Specification '

6.9.1.6c. If any of the applicable limits of the safety analyses are not met, prior NRC approval of the change is required, just as is the case for a license amendment request. For the more routine modifications, where NRC approved methodologies and limits of the safety analysis remain applicable, the potentially burdensome and lengthy process of amending the Technical Specifications may be avoided. These changes are essentially administrative and the required level of safety is maintained.

IV. SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS TU Electric has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10CFR50.92(c) as discussed below:

1. Do the proposed changes involve a significant increase in the probability or consequences of an sccident previously evaluated?

The proposed changes remove cycle-specific parameter limits from the Technical Specifications, add them to the list of limits contained in the Core Operating Limits Report (COLR), and revise the Administrative Controls section of the Technical Specifications.

The changes do not, by themselves, alter any of the parameter limits. The changes are administrative in nature and have no adverse effect on the probability of an accident or on the consequences of an accident previously evaluated. The removal of parameter limits from the Technical Specifications does not eliminate the requirement to comply with the parameter limits.

The parameter limits in the COLR may be revised without prior NRC l approval. However, Specification 6.9.1.6c continues to ensure that the parameter limits are developed using NRC approved methodologies and that applicable limits of the safety analyses are met. While future changes to the COLR parameter limits could result in event consequences which are either slightly less or slightly more severe than the consequences for the same event using the present parameter limits, the differences would not be significant and would be i bounded by the requirement of specification 6.9.1.6c to meet the j applicable limits in the safety analysis.  !

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Based on the above, removal of the parameter limits from the  !

Technical Specifications and the addition of these limits the list of limits in the COLR. thus allowing revision of the parameter i limits without prior NRC approval, has no significant effect on the probability or consequences of an accident previously evaluated.

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Attachment 2'to TXX 95216 Page 5 of 5

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed changes remove certain parameter limits from the Technical Specifications and add these limits to the list of limits in the COLR, removing the requirement for prior NRC approval of revisions to those parameters. The changes do not add new hardware or change. plant operations and therefore cannot initiate an event nor cause an analyzed event to progress differently. Thus, the possibility of a new or different kind of accident is not created. l

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

The margin of safety, as it relates to a parameter limit, is the difference between the acceptance criterion for that parameter and (

its failure value. The proposed changes do not affect the failure  ;

values for any system. Through the accident analyses, all relevant  ;

event acceptance criteria (as described in the NRC approved analysis methodologies) are shown to be satisfied; therefore, there is no-impact on an event acceptance criteria. Because neither the failure values nor the acceptance criteria are affected, the proposed change has no effect on the margin of safety.

Based on the above evaluations. TV Electric concludes that the activities associated with the proposed 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 proposed changes and has determined that the changes do not involve (1) a significant hazards consideration. (ii) a ,

significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), an environmental assessment of the proposed change is not i required.

VI. REFERENCES l

1. Generic Letter 8816 " Guidance for Technical Specification Changes i for Cycle-Specific Parameter Limits " October 4, 1988  !

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ATTACHMENT 3 AFFECTED TECHNICAL SPECIFICATION PAGES (NUREG 1468)

(Pages 2-6, 3/4 2 12, 6 20, 6 21)

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