ML20115C927

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LAR 96-003 to Licenses NPF-87 & NPF-89,increasing Allowable Value for Steam Line pressure-low for Cpses,Unit 1
ML20115C927
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/09/1996
From: Terry C, Walker R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115C930 List:
References
TXX-96393, NUDOCS 9607120209
Download: ML20115C927 (14)
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Text

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M Log # TXX 96393 MM File # 916 (2.0)

L 4 10010 C C Ref. # 10CFR50.90 RIELECTR C'

c. iance T"'7 July 9, 1996 Gnwp bke President l

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) UNITS 1 AND 2 DOCKET NOS. 50 445 AND 50 446 SUBMITTAL OF LICENSE AMENDHENT REQUEST 96 003 STEAM LINE PRESSURE LOW ALLOWABLE VALUE 1

Gentlemen: l Pursuant to 10CFR50.90 TV 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 Unit 1 and Unit 2 Technical Specifications. These changes apply to CPSES Unit 1 only. Because the Technical Specifications is a common document for both units, the changes are also being submitted for CPSES Unit 2 for administrative purposes only.

TU Electric proposes to increase the Allowable Value for the Steam Line Pressure Low from "E 593.5 psig" to "E 594.0 psig" for CPSES Unit 1. TV Electric has concluded, during review of the Industry Advisory Letter from ITT Barton concerning the gage pressure electronic transmitters, that the impact on the Allowable Value for the Steam Line Pressure Low ESFAS ,

function necessitates submittal of a License Amendment Request to change 1 the Technical Specifications. Administrative controls are already in place to conservatively calibrate this setpoint.

Attachment 1 is the required affidavit. Attachment 2 provides a detailed description of the proposed changes, a safety analysis of the proposed changes and TV Electric's determination that the proposed changes do not involve a significant hazard consideration. Attachment 3 provides the affected Technical Specifications pages marked up to reflect the proposed changes.

TU. Electric requests approval of this proposed license amendment request by December 18, 1997, with implementation of the Technical Specification changes to occur within 30 days of approval. \ji In accordance with 10CFR50.91(b), TV Electric is providing the State of Texas with a copy of this proposed amendment. JJ

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960712O209 960709 PDR ADOCK 05000445 P PDR Energy Plaza 1601 Bryan Street Dallas, Texas 75101 3411

TXX 96393 Page 2 of 2 Should you have any questions, please contact Mr. Jimmy Seawright at (214) 812 4375 or Mr. Don Woodlan at (214) 812 8225.

Sincerely, b

hty C. L. Terry By: UYA 4 Roger D/ Walker Regulatory Affairs Manager JDS/grp Attachments:

1. Affidavit
2. Description and Assessment
3. Affected Technical Specifications pages as revised by all approved license amendments l c- Mr. L. J. Callan. Region IV Mr. P. M. Ray NRR Ms. L. J. Smith, Region IV Resident Inspectors. CPSES l

Mr. Arthur C. Tate l Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78704 l

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Attachment 1 to TXX 96393 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Hatter of )

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Texas Utilities Electric Company ) Docket Nos. 50 445

) 50 446 (Comanche Peak Steam Electric ) License Nos. NPF 87 Station, Units 1 & 2) ) NPF 89 AFFIDAVIT Roger D. Walker being duly sworn, hereby deposes and says that he is Regulatory Affairs Manager of TV Electric, that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 96 003: that he is familiar with the content thereof: and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

'WN d1 Rog'er'D. Walker Regulatory Affairs Manager STATE OF TEXAS )

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COUNTY OF DALLAS )

Subscribed and sworn to before me, a Notary Public, on this 8th day of Juiv ,1996.

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'r NadL Notary P'dblic cb i/

Gayle R. Peck l Netary Pu%c. State of Tau f h t, \ My Ccmm. Empirn 01/06/98

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ATTACHMENT 2 to TXX-96393 l DESCRIPTION AND ASSESSMENT 1

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i Attachment 2 to TXX 96393 Page 1 of 10 l

4- DESCRIPTION AND ASSESSMENT

I. BACKGROUND 3 ?iES Unit 1 uses Barton model 763 and 763A Gage Pressure Electronic j

rar.smitters to monitor the Steam Line Pressure Low and the Pressurizer

Pressure--Low for the Reactor Trip System (RPS) and the Engineered Safety Features Actuation System (ESFAS). Temperature changes between the calibration and the operating temperatures have been identified by ITT Barton to cause an additional error in the transmitter's signal. These errors impact the related setpoint calculations used to establish Trip Setpoints and j Allowable Values for these parameters.

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! These changes to the plant Technical Specifications are specific to CPSES Unit 1 and are needed to ensure that the instrumentation error is properly i accounted for in the Technical Specifications. The proposed changes are i changes to plant specific values, justified by plant specific ca'yses and, as j such, do not represent changes in the improved Standard Technica.

j Specifications for Westinghouse Plants, NUREG 1431.

t II. DESCRIPTION OF TECHNICAL SPECIFICATIONS CHANGE REQUEST

! The following specific Technical Specifications (TS) changes are proposed:

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! The minimum allowable value in Table 3.3 3, " Engineered Safety Featu; as 1 Actuation System Instrumentation Trip 2tpoints" for the " Steam Line

~ Pressure Low" for the Functional Unit "1. Safety Injection" is increased from "a 593.5 psig" to "a 594.0 psig" for CPSES Unit 1.

The minimum allowable value in Table 3.3 3, " Engineered Safety Features Actuation System Instrumentation Trip Setpoints" for the " Steam Line Pressure Low" for the Functional Unit "4. Steam Line Isolation" is increased from "2 593.5 psig" to "2 594.0 psig" for CPSES Unit 1.

In summary, the license amendment request includes uianges proposed to CPSES Unit 1. These changes will increase the minimum allowable value of the Unit 1 Steam L1oe Pressure Low from "593.5" to "594.0",

III. ANALYSIS TU Electric uses Barton model 763 and 763A Gage Pressure Electronic Transmitters in CPSES Unit 1 to monitor the pressurizer pressure and steam line prestere for input into the Reactor Protection System (RPS) and Engineered Safety FNtures Actuation System (ESFAS). During factory production, all transmitters manufactured by ITT Barton were compensated and tested for temperature effects to ensure compliance with the required specifications. The ITT Barton specification for temperature effect during normal operating conditions (40 to 150 'F) is ilt of full span per 100 F

Attachment 2 to TXX 96393 Page 2 of 10 change between the calibration and normal operating conditior. These tests were performed without the transmitter cover installed to facilitate adjustments.

The reference pressure for the bourdon tube sensing element is the inside of the transmitter case, which, under factory testing conditions, was vented to the local atmosphere. When the transmitter is installed and operated in the field, the cover is installed. The transmitter case is hermetically sealed, and under these conditions, the reference pressure for the bourdon tube will fluctuate with changes in the temperature of the transmitter case. The temperature compensation procedure used during factory temperature compensation did not correct for these fluctuations in the sensor's reference pressure and potentially resulted in additional error to that specified by ITT Barton for temperature effect.

The additional error caused by the case Wassure fluctuations is no greater than 3 psi per 100 F, regardless of the n:nsmitter's full span. The change in the transmitter's temperature specification depends on the full span of the transmitter (e.g., for a 5000 psi span transmitter, the additional error is approximately 0.06% of full span per 100 F, while the additional error for a 100 psi transmitter span is approximately 3.0% of full span per 100 F).

Safety analysis limits are used for the RPS and ESFAS parameter setpoints in the accident analyses. Instrumentation uncertainty calculations are then performed, and the Technical Specifications Trip Setpoints are selected such that, even if all uncertainties are considered, the required (RPS and/or ESFAS) actuation will occur at or prior to the point where such actuation is required to occur. The Allowable Value is calculated based primarily on the amount of instrument drift expected to occur between surveillance intervals.

If, during the surveillance, a channel is found to be less conservative than the Allowable Value, the channel is declared inoperable, the required actions for an inoperable channel are performed and an evaluation is performed to ensure that the allowances provided in the setpoint uncertainty calculation remain valid. A channel is restored to operable status by performing a full channel calibration thereby removing the as found deviations in the channel.

At CPSES, if a channel is found to be outside of a calibration tolerance on either side of the Trip Setpoint, the channel is returned to within the calibration tolerance prior to returning the channel to weration. Thoc, in practice, more restrictive criteria (the calibration tolerances) are used at CPSES to determine when to reset a channel's setpoint.

TV Electric has evaluated the safety implications for each case where Barton )

, model 763 and 763A Pressure Electronic Transmitters are used in safety related l applications. The ESFAS actuations (Functional Units) which are potentially l affected are Safdcy Injection and Steam Line Isolation. The logics for each  !

of these Functional Units receive inputs from the Steam Line Pressure Low i channels and the Safety Injection Functional Unit also receives inputs from the Pressurizer Pressure--Low channels. RPS actuation also receives inputs from the Pressurizer Pressure- Low channels. As noted above these are the channels which use the Bsrton model 763 and 763A transmitters. Setpoint  !

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6 Attachment 2 to TXX 96393 Page 3 of 10 calculations have been revised for these actuation channels.

Sufficient margin existed within the Pressurizer Pressure -Low setpoint calculations that the current Trip Setpoints and Allowable Values in the Technical Specifications are acceptable. However, an increase of 0.5 psig (from "1593.5 psig" to "t 594.0 psig") is necessary for the Allowable Value for the Steam Line Pressure Low Safety Injection and Steam Line Isolation Functional Units to assure that the additional error caused by the case pressure fiuttuations are accounted for.

Currently, TV Electric is using the proposed revised value for the Allowable

, Value for the Steam Line Pressure Low Safety Injection and Steam Line Isolation functions which is more conservative than the current-Technical Specifications. As such TV Electric is operating CPSES Unit 1 in compliance with the current Technical Specifications and within the bounds of the supporting accident analyses and setpoint calculations. The proposed changes are more conservative in that the Allowable Value is more restrictive but in practice has no impact in that TU Electric has been implementing the more restrictive criteria.

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 as discussed below:

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

The changes in the License Amendment Request proposes more restrictive setpoint Allowable Values for the Steam Lina pressure- Low channels of the Engineered Safety Features Actuation System (ESFAS). These more restrictive values assure that all applicable safety analysis limits are being met. Changing an Allowable Value in the Technical Specifications has no impact on the probability of occurrence of any accident previously evaluated. None of the accident analyses were affected, therefore, the consequences of all previously evaluated accidents remain unchanged.

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

i The proposed changes involve the use of a more conserv6tive value for the Allowable Value for the Steam Line Pressure--Low Safety Injection and Steam Line Isolation functions. As such none of the changes effect plant hardware or the operation of plant systems in a way that could initiate an accident. Therefore, the troposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Attachment 2 to TXX-96393 Page 4 of 10

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

There were no changes made to any of the accident analyses or safety analysis limits as a result of this proposed change. Further, the proposed change does not affect the acceptance criteria for any analyzed event. ESFAS will remain capable of performing its safety function, and the new requirement will continue to provide adequate assurance of that capability. Making the Allowable Value more restrictive provides increased assurance that the channels will function within the safety analysis limits assumed in the safety analyses. The margin of safety established by the Limiting Conditions for Operation also remains unchanged. Thus there is no effect on the margin of safety.

Based on the above evaluations, TV Electric concludes that the activities associated with the above described changes present no significant hazards consideration under the standards set forth in 10CFR50.92 and accordingly, a finding by the NRC of no significant hazards consideration is justified.

V. ENVIRONMENTAL EVALUATION TU Electric has determined that the proposed amendment would change requirements with respect to the installation er use of a facility component l located within the restricted area, as defined in 10CFR20, or would change an -

inspection or surveillance requirement. TU Electric has evaluated the l 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).

l Therefore, pursuant to 10CFR51.22(b), an environmental assessment of the l proposed changes is not required.

VI. REFERENCES

1. NUREG 1431 Rev.1. " Improved Standard Technical Specifications for l Westinghouse Plants," April 7, 1995, Pages 3.3-32 and 3.3-35.

l 2. ITT Barton letter dated September 14, 1995 from Jerald Anderson to D. W.

Leigh (TV Electric) - Enclosed.

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Attachment 2 to CXX 96393 Page 5 of 10 l

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REFERENCE 1 l 1

NUREG 1431. Rev. 1.

"Imoroved Standard Technical Soecifications for Westinahouse Plants."

Aoril 7. 1995.

Paaes 3.3 32 and 3.3 35 l

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i Attachm:nt 2 to TXX 96393 ESFAS Instrumentation l Page 6 of 10 3.3.2 r

Table 3.3.2 1 (pege 1 of 8)

Engineered Safety Feature Actuation System Instrumentation D

APPt.lCABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTICN CON 0lfl0NS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT(a)

1. Safety Injection
a. Manual Initiation 1,2,3,4 2 8 SR 3.3.2.8 NA NA
b. Automatic 1,2,3,4 2 traies C SR 3.3.2.2 NA NA~

Actuation Logic SR 3.1.2.4 l and Actuation SR 3.g3.2.6 Relays

c. Containment 1,2,3 3 0 SR 3.3.2.1 5 (3.861 s (3.61 psig Pressure - Hign 1 SR 3.3.2.5 psig SR 3.3.2.9 SR 3.3.2.10
d. Pressuriter 1,2,3(b) (31 0 SR 3.3.2.1 a (1839] = (18501 Pressure - Low SR 3.3.2.5 peig psig SR 3.3.2.9 SR 3.3.2.10
e. Steam Line Pressure j (1) Low 1,2, 3 per D SR 3.3.2.1 a (6351(C) = [675)(c)

I steam SR 3.3.2.5 psig psig i 3(ID)I line SR 3.3.2.9 SR 3.3.2.10 (2) Migh 1,2,3 3 per 0 (SR 3.3.2.11 s (1061 psig s (971 psig Differential steam SR 3.3.2.5 Pressure line SR 3.3.2.9 Between Steam SR 3.3.2.10 Lines

f. Migh Steam Flow in 1,2,3(d3 2 per D SR 3.3.2.1 (e) (f)

Two Steam Lines steen SR 3.3.2.5 line SR 3.3.2.9 SR 3.3.2.10 coincident with 1,2,3(d) 1 per D SR 3.3.2.1 m (550.61'F = [5531*F T,., - Low Low loop SR 3.3.2.5 SR 3.3.2.9 SR 3.3.2.10 (continued) l l (a) Reviewer's Note: Unit specific implementations may contain only AlloweDle Value depending on Setpoint Study

' methodology used by the is11t.

(b) Above the P-11 (Pressuriter Pressure) Interlock.

(c) Time constants used in the lead /les controller are t ai (501 seconds and t, s (5) seconds.

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(d) Above the P 12 (T,,,- Low Low) Interlock.

(e) Less than or emat to a function defined as & corresponding to (4411 full steam flow below (201% toad, and

& increasing linearly from (4411 full steem flow at (2011 load to (1141% full steam flow at (1001% toed, and & corresponding to (11411 full steen flow above 1005 loed.

(f) Less than or egal to a fisiction defined as & corresponding to (401% full steen flow between (01% and (201%

load and then a & increasing lineerly from (4011 steem flow at (2011 load to (11011 full steen flow at

{ (1001x loed.

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s WOG STS 3.3-32 Rev 1. 04/07/95 i

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E5FAS Instrumentatice l 3.3.2  ;

Attachment 2 to TXX 9.6393 i Page 7'of 10 .

vaele 3.3.2 1 (pege 4 of a) l Engineered Safety Feature Actuation System Instrtmentation l t

o APPLICA8LE j MODES OR OTHER SPECIFIED REQUIRED SURVE!LLANCE ALLOWASLE TRIP FUNCTION CON 0lfl0NS CHANNELS CON 0!TIONS REQUIREMENTS VALUE SETPOINy(a)

) 4. Steam Line Isolation (continued)

c. Contairment 1,2(I) , (41 0 SR 3.3.2.1 5 (6.611 Pressure - Mign 2 s (6.351
d. Steam Line Pressure (1) Low 1,2(I) 3 per D SR 3.3.2.1 = (635)(C)

= (6751(c) ,

steam SR 3.3.2.5 pois psig 3(b)(f) line SR 3.3.2.9 '

SR 3.3.2.10 (2) Negative 3(8)(I) 3 per o SR 3.3.2.1 s (121.6)(h) 5 (1101(h)

Rate - M ign steam SR 3.3.2.5 psi /see psi /see line SR 3.3.2.9 SR 3.3.2.10 )i

e. High Steam Flow in 1,2(I) , 2 per D SR 3.3.2.1 (e) (f)

Two Steam Lines steam SR 3.3.2.5 3ci3 Line SR 3.3.2.9 SR 3.3.2.10 Coincident with 1,2(I) , 1 per D SR 3.3.2.1 = (550.61*F = (5531*F T,y - Low tow loco SR 3.3.2.5 3(d)(1)

SR 3.3.2.9 SR 3.3.2.10 (continued) l (a) Reviewer's Note: Unit specific ist;.ementations may contain only Attoweble Value cepending on Setpoint Study I methodology used by the unit, i

(b) Above the P-11 (Pressurizer Pressure) interlock.  !

(c) Time constants used in the lead /las controller are t a (501 seconds and t, s ($1 seconds.

g (d) Above the P 12 (T,,- Low Low) Interlock.

(e) Less than or ocp. int to a ftriction defined as & corresponding to (4411 full steam flow below (201% toad, &

increasing lineerly from (441% full steam flow at (201X load to (1141% full steem flow at (1001% loed, and

& corresponding to (11411 full steem flow above 1001 toed.

(f) Less than or equel to a function defined as & corresponding to (4011 fut t steen flow between (01X and (201%

toed and then e & increasing lineerly from (401% steam flow at (201% toad to (11011 full steem flow at (10011 load.

(g) gelow the P 11 (Pressurizer Pressure) interlock.

(h) Time constant utilized in the rate /tes controller is s (501 seconds.

(i) Except idien all MSIVs are closed and (de activated). l i

I WOG STS 3.3-35 Rev 1. 04/07/95

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t Attachment 2 to TXX 96393 Page 8 of 10

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l REFERENCE 2 l ITT Barton letter dated Seotember 14. 1995 I from Jerald Anderson to D. W.' Leiah (TU Electric) l I

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Attachiment2toTXX96393 Page 9 of 10 f77 5erten

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ITT Muhl Toohmelegy  ;

- Corporation Eg i

j YEARS i

i September 14, 1995 1

.' l TU Electric P.O. Box 102

Glen Rose, TX 76043 4

ATTENTION: D. W. Leigh

SUBJECT:

Industry Notificatica of Teeperature Errors in Model 763 and 763A Gage Pressure Transmitters i i

The attached Industry Advisory letter is being provided for your information. Our records indicate that your company may have purchased the Model 763 and/or Model 763A within the past 10 years.

If there are any questions regarding this notification, please contact the undersigned at (818) 951-2347, i

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Jerald M erson i Director of Quality Assurance Attachment 900 South Turnbu!! Canyon Road, P.O. Box 1882, City of Induury, C.A USA 91749-1862 Telephone (818) 961 2547 Fax (818) 333-D.41

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Attachment 2 to TXX 96393 Page 10 of 10 ITT Barton Industry Advisory Letter cespammer 14, IM8) i Tennerneste L.;... In Madel to and im came n_.m r TIT Barton asppEas Model 70 and 70A Gage Pressure Esctmaic Tremainars to tbs a maleer power industry fbr use h sehty related applicanoes. These insenaments are suppliedio perfonnmace g "- H= that any, a censin appications, be used ha set point r=hh The temperunire eSect g - "--t tr these transminars an the subjess of this advisory haar.

During &ceery pr"+. at transmittars ==*wed are  ; ;

  • and tasted fbr tamparamre ashce to esses compBaace with the speedScadoes. Thus mas bsve been The mhrence perfbrmed without the transminar cover 'anaBed, to eclReste =t=====

presure 1br the bourdon tube sanang alenas is the kaids of the assedner cua, wisch under these test conddons is vased to the local annosphere. When the tramunittar is '===Reni and operused in the field, the cover is instaned. The tr====irw case is haamusicaDy sealed, and under these condhians thi nerence passa er the hourden tube we >=. wkh changes in de temperates of the tranamme casa. The tempersare co"T'""" procedure that has been used during &ctory temperstm congensatica does not conect br these fkactuations in the sensor's rearencepremure.

The temperature sSect W during aannel openting * (40 to !$0'F)ls 21% of j lhR span par 1007. The adadonal error caused by the cess presure Aacenation is no yestar l

! then 3 PE per 1007, regardless of the trumminer's M span. The change la the transminer's

' temperanus spedflesden depamis on the M spun of the transmitter (e.g., er a 5000 PSI span

- transminar, the addsional error is appresimses50.06% of M spas par 100T, while the addhinest error in a 100 PE span transminar is approskassely 3.0% c(M spea per 1007).

Users of these 'asmansats should evehiste tbs 'ampaat etthis ad(sional 3 PE per 100T enwr om edsting set point *=hh to d====ime ific adversely sEsces pissa mety.

There h so choses 'a tbs DRE peribunence speciScations tr traunisters with a caEbneed span of183.5 PEG or greater. Dur'ag Barton's quaidicalon tasu, a tr====le*= widt a russa of 123.5 PSIG pettooed accepubly eming LOCNEILS =h=h This h is appscubis cah to the model 163 and 7CA tnesminars; ao other IIT Bartna tranmudtter unodsis are adEsoted.

ITT Bance is changing the manuteturbg procedures fbr these insenansats to require the i.d.

temperana, =ansion and veriscaio he paan=4 whh 6. wassedn.c e e Instrumsma dipped near the date of tbis advisory wE not abbit this : - -;_ ^f tempenem aror. Ties < sums in samacants proceduns we cornet som arms tempennn enor caused by fluctuations in the case pneum. The residusi arar seer the accrection of the counpanasion procedure depends on altitude where the transminar is instaBed, and local -

==a ph-6 condhions at en time the transminar case is sesimi. In most ==s, tie nsiemi nrar is apocad to be neg5sible.

Questions regartEng this issue should be addnesed to Mr. Jeny Anderson, Director of Quality Assunnen, as(318) 961-2547.

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