ML20116E847

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Application for Amends to Licenses NPF-87 & NPF-89,modifying Inverter/Battery Chargers by Incorporating Attached Changes Into CPSES Units 1 & 2 TSs
ML20116E847
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/31/1996
From: Terry C
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20116E850 List:
References
TXX-96432, NUDOCS 9608060142
Download: ML20116E847 (12)


Text

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M Log # TXX-96432 MM

' File # 916 (3/4.8) l

-- 4 Ref. # 10CFR50.90  ;

10CFR50.36  !

1UELECTRIC' C. Lance Terry j Gwp % e Prendent j U. S. Nuclear Regulatory Commission Attn: Document Control Room Washington, DC 20555 i

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) l DOCKET NOS. 50 445 AND 50-446 SUBMITTAL OF LICENSE AMENDMENT REQUEST 96 005 INVERTER / BATTERY CHARGER MODIFICATION Gentlemen:

Pursuant to 10CFR50.90, TU 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 l CPSES Units 1 and 2 Technical Specifications. The purpose of this request is to (1) change the acceptance values for amperes and voltage for the 18 month surveillance test of the battery chargers: (2) clarify the meaning of the term " associated inverter" used in the context of energizing 118-Volt A. C. Instrument Busses during MODES 1 thrcugh 6: and (3) delete the protection channel and the vital bus ratings for the 118 Volt A. C.

Instrument Busses identified for MODES 1 through 4. These changes are associated with a plant modification in which the inverters and battery

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chargers are being replaced and an installed spare inverter is being added j for each safety train. These changes are equally applicable to CPSES l Units 1 ano 2.

Attachment 1 is the required affidavit. Attachment 2 provides a detailed description of the proposed changes, a safety analysis of the changes, and )

TU Electric's determination that the proposed changes do not involve a  !

significant hazard consideration. Attachment 3 provides the proposed changes to the Technical Specifications. j 1

In accordance with 10CFR50.91(b) TU Electric is providing the State of Texas with a copy of this proposed amendment.

TU Electric requests NRC approval of the proposed license amendment by October 1,1996, or earlier so as to allow the implementation of the revised technical specifications during and/or following the next Unit i refueling outage. Unit 2 implementation will occur at the next refueling outage for Unit 2, however Unit 2 can continue to operate with the proposed changes and maintain compliance with the Technical  ;

specifications. Upon approval of the proposed changes, TV Electric  ;

requests implementation within 60 days following the date of license  :

9608060142 960731 PDR ADOCK 05000445 l 'hI P PDR l Energy Plaza 1601 Bryan Sucet Dallas. Texas ~15201-3411

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l TXX 96432 Page 2 of 2 amendment issuance, to allow coordination of the modification installation with the implementation of the license amendment.

Should you have any questions, please contact Mr. Jacob M. Kulangara at (214) 812 8818.

Sincere y, ho C. L. Terry By:

Roger D. Walker Regulatory Affairs Manager JMK/jmk Attachments: 1. Affidavit 4

2. Description and Assessment I
3. Affected Technical Specification pages (NUREG 1468) as l revised by all approved license amendments

Enclosure:

Applicable Pages of NUREG 1431, " Standard Technical Specifications - Westinghouse Plants," Revision 1 c- Mr. L. J. Callan, Region IV Hs, L. J. Smith, Region IV Resident Inspectors, CPSES Mr. T. J. Polich, NRR Hr. Arthur C. Tate l Bureau of Radiation Control l Texas Department of Public Health

! 1100 West 49th Street Austin, Texas 78704 l

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i Attachment 1 to TXX-96432 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

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, In the Matter of ) l l

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! Texas Utilities Electric Company ) Docket Nos. 50 445 I

( ) 50 446 (Comanche Peak Steam Electric ) License Nos.NPF 87 Station, Units 1 & 2) ) NPF 89 AFFIDAVIT C. L. Terry being duly sworn, hereby deposes and says that he is Group I

Vice President, Nuclear Production for TU Electric, the licensee herein:

j that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 96 005; that he is familiar with l the content thereof; and that the matters set forth therein are true and i correct to the best of his knowledge, information and belief.

l Roger D.' Walker l Regulatory Affairs Manager  !

l STATE OF TEXAS )

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COUNTY OF DALLAS )

, Subscribed and sworn to before me, a Notary Public, on this day of l Mu , 1996.

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l ATTACHMENT 2 TO TXX-96432 1

DESCRIPTION AND ASSESSMENT \

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Attachmsnt 2 to TXX 96432 Page 1 of 8 DESCRIPTION AND ASSESSMENT I. BACKGROUND At Comanche Peak Steam Electric Station (CPSES) for Units 1 and 2,118 volts A. C. Single phase 60 Hz uninterruptible power is supplied to critical instrumentation and control circuits. For each unit, there are four Class 1E uninterruptible power supplies for balance of plant (B0P) instrumentation and four uninterruptible power supplies for the reactor protection system. Each uninterruptible power supply consists of an inverter and static (automatic) and bypass (manual) switches. A modification will be performed to enhance the reliability of these inverters and the overall system design. As part of the modification, the associated inverters and battery chargers are being replaced and an installed spare inverter is being added for each train. For ,

standardization - all the new replacement inverters including installed spare will be 10 KVA inverters.  ;

The CPSES Units 1 and 2 Technical Specification Surveillance Requirement 4.8.2.1, in part, requires performing a surveillance test once in 18 months which verifies, "The battery charger will supply at least 225 '

amperes at 130 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />." These numerical values are i respectively based on the design capacity of the battery charger and battery float voltage. The surveillance is being changed to 300 amperes at greater than or equal to 130 volts.

The CPSES Units 1 and 2 Technical Specifications 3.8.3.1 and 3.8.3.2 refer to " associated inverter" for the 118 volts A. C. Instrument busses. The

" associated inverter" may be either the dedicated inverter for the instrument bus or the installed spare inverter which is being added for l that train. The proposed change clarifies how credit is taken for the new design configuration with an installed spare inverter for each train.

Also the CPSES Units 1 and 2 Technical Specification 3.8.3.1 actions b and c refer to ~7.5 KVA protection channel" and "10 KVA vital bus" for the 118 volts A. C. instrument busses. The described ratings 7.5 KVA and 10 KVA, do not need to be identified in the Technical Specifications since the ratings are identified in other Licensing Basis Documents (LBDs) or Design Basis Documents (DBDs) which are subject to 10 CFR 50.59 regulation for any changes. This proposed change does not alter the applicability of these actions.

1 II. DESCRIPTION OF TECHNICAL SPECIFICATION CHANGE REQUEST (1) The following change is proposed for Technical Specification 3/4.8.2, "D.C. Sources":

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Attachm6nt 2 to TXX 96432 Page 2 of 8 l

CHANGE TO IDENTIFY BATTERY CHARGER RATINGS The SURVEILLANCE REQUIREMENT (SR) 4.8.2.1c.4) states that at least once per 18 months battery charger shall be demonstrated OPERABLE by verifying "[t]he battery charger will supply at least 225 amperes at l 130 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />." l The proposed change replaces,

".. 225 amperes at 130 volts for

... , with, ".. 300 amperes at greater than or equal to 130 volts for ...." A footnote is added to specify that the Unit 2 battery chargers will continue to be tested to 225 amperes until the battery chargers are replaced during the third refueling outage for Unit 2.

(2) The following change is proposed for Technical Specifications 3/4.8.3, "0NSITE POWER DISTRIBUTION":

CLARIFICATION TO DEFINE ASSOCIATED INVERTER In technical specifications 3.8.3.1c, Id, le and if (including the associated note) and 3.8.3.2b and 2c, pertaining to the 118 volt A. C. Instrument Bus, refer to being energized from the " associated inverter." The proposed change clarifies " associated inverter" by adding the foot note, " Associated inverter is the dedicated inverter or installed spare inverter." The BASES for Specifications 3/4.8.3 are also revised to reflect this change including the basis for the proposed change.

(3) The following additional change is proposed for technical specification 3,8.3.1, "0NSITE POWER DISTRIBUTION OPERATING":

DELETION OF THE PROTECTION CHANNEL AND VITAL BUS RATINGS FOR INSTRUMENT BUS

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Actions b and c in part show the protection channel and the vital bus ratings respectively as "7.5 KVA" and "10 KVA." The proposed change deletes the rating description.

In summary, this license amendment request proposes to (1) change the ampere rating for the 18 month surveillance test of the battery chargers:

(2) clarify the meaning of the term " associated inverter" used in the context of energizing 118 Volt A. C. Instrument Busses during MODES 1 through 6: and (3) delete the protection channel and the vital bus ratings for the 118 Volt A. C. Instrument Busses identified for MODES 1 through 4.

These changes are associated with a plant modification in which the inverters and battery chargers are being replaced and an installed spare

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h, l Attachment 2 to TXX 96432 t

Page 3 of 8 j inverter is being added for each safety train, i
III. ANALYSIS

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The three basic changes in this license amendment request are discussed separately below.

CHANGE TO IDENTIFY BATTERY CHARGER RATINGS l CPSES Technical Specification surveillance requirement 4.8.2.1 currently requires performing a test once per 18 months to verify that the battery j charger will supply at least 225 amperes at 130 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. These ratings are based upon the design capacity of the battery charger and the battery float voltage. The installed battery chargers are being replaced with new battery chargers to increase the design capacity ,

from 225 to 300 amperes. The larger battery charger capacity is needed to  :

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account- for the increased load that is drawn by the replacement inverters  !

which are being installed by the same plant modification.

The test voltage is being changed to " greater than or equal to 130 volts."

The battery charger's largest combined demand of DC loads and the charging

capacity to restore the battery from the design minimum charge state to t
the fully charged state is less than 275 amperes. Surveillances for'the l l new chargers at the rated amperes is sufficient to assure that the l l chargers can perform their intended function. The present voltage of 130 i i volts is adequate to test the chargers. By adding " greater than or equal {

to 130 volts." a higher voltage may be used, which is acceptable, because  !

a higher voltage results_ in a more severe test. Additionally, this change  !

is consistent with NUREG 1431, " Standard Technical Specifications for
Westinghouse Plants."

Implementation of the technical specification change on Unit I will be i coordinated with the effective date of the license amendment. The change will be effective on Unit 2 when the battery chargers are replaced during i the third refueling outage for Unit 2.

CLARIFICATION TO DEFINE ASSOCIATED INVERTER J

CPSES Technical Specification Limiting Conditions for Operation (LCO) ,

3.8.3.1 and 3.8.3.2 in part make reference to energizing the Instrument Bus from its associated inverter.  ;

! CPSES Units 1 and 2.'each have two protection channel and two vital bus inverters for the instrument busses for each safety train. The design

modification will install a spare inverter for each safety train of l adequate capacity to support the maximum load of any protection channel or

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. Attachment 2 to TXX 96432 ,

Page 4 of 8  !

vital bus. The' proposed design allows each spare inverter to be aligned l manually to substitute for any of the other four inverters in that train.  ;

Interlocks and procedural controls ensure that the spare inverter feeds  :

the loads of only one inverter at a time and that the power source for the ,

spare inverter is same as the inverter whose loads are being fed by the spare inverter. In summary this design modification provides additional capability to energize the Instrument Bus for the protection channel and vital busses for each safety train from the installed spare inverter for {

that train. When the installed spare is manually aligned to feed a ~

specific bus (interlocks and procedural controls only allow the spare to j be aligned to one bus at a time), the spare now replaces the dedicated  !

inverter as the associated inverter for that bus. Implementation of. this  ;

change will potentially minimize plant shutdowns due to the unavailability l of a dedicated inverter.

The proposed change to the Technical Specification is to add a foot note .

defining the term " associated inverter" as, " Associated inverter is the I dedicated inverter or-the installed spare inverter." It is also proposed l to revise the Bases section for the specification 3/4.8.3 to reflect this l change and the underlying basis. <

DELETION OF THE PROTECTION CHANNEL AND VITAL BUS RATINGS FOR INSTRUMENT BUS l l

CPSES. Technical Specification Limiting Condition for Operations (LCO) 3.8.3.1 actions in part identify the protection channel and vital bus ratings for the Instrument Bus as "7.5 KVA" and "10 KVA" respectively.

Use of the bus rating in the identification could incorrectly be interpreted as a Technical Specification limitation.

The proposed change is to delete the reference to KVA rating from the Technical Specification LC0 action statements pertaining to the Instrument Bus protection channel and vital bus. By this change, the applicability l or the original intent of the action statements are not altered. This

change is considered to be administrative. The bus ratings are design l descriptions which are provided in other Licensing Basis Documents or Deign Basis Documents and which do not need to be included in the Technical Specifications. 1

SUMMARY

In summary, the changes proposed by this plant modification and the i associated technical specifications are expected to enhance safety. The i replacement inverters have been chosen because they are expected to have

, increased reliability and availability over the inverters presently

!. installed. The addition of an installed spare inverter is expected to increase the availability of the required 118 Volt A. C. Instrument Busses y, y ~. . ~ . -__m., _.__.% .p w , _ _ - _ -

~ - - . - . - .- -- - - . . - - - =.. - - . - - - ..-. .- - ..

i Attachesnt 2 to TXX 96432 '

Page 5 of 8 should an inverter problem occur. The new battery chargers have  !

sLfficient capacity to handle the increased load demand of the new  !

inverters.

IV. SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The following is an evaluation of whether or not a significant hazards consideration is involved with the proposed changes by focusing on the  :

three standards set forth in 10 CFR 50.92(c) as discussed below: '

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

CHANGE TO IDENTIFY BATTERY CHARGER RATINGS

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The first proposed change replaces the test amperes with the design  !

value for the replacement battery charger and allows a voltage range  ;

(greater than or equal to 130 volts) instead of a single value. The intent of the surveillance requirement or the surveillance frequency is not changed. The replacement inverters and battery chargers will continue to provide the capacity needad to perform the required I

safety functions. The revised surveillance will continue to assure that the battery chargers are capable of performing as designed.

Therefore this change does not impact the probability or the consequences of an accident previously evaluated.

CLARIFICATION TO DEFINE ASSOCIATED INVERTER The second proposed change adds a foot note to clarify the term

" associated inverter" by describing it as, "... the dedicated inverter or installed spare inverter." Also the Bases for this specification is revised to reflect the basis for this change. l This change allows use of an installed spare inverter (for each train) having the capability to energize the Instrument Bus for the l protection channel or the vital bus. Procedural controls and interlocks ensure that the spare is available to feed only one of '

l the protection channel or vital bus Instrument Bus at a time, in the event the dedicated inverter is not available. Procedural controls and interlocks also ensure that the installed spare inverter is fed from the same power source as that of the dedicated inverter not in service and 9 hose loads are being fed by the spare inverter. This proposed design only allows the spare inverter for a safety train to l be manually aligned to replace only one of the four inverters in i i that train at a time. i

Attachment 2 to TXX 96432 Page 6 of 8 The installation of a spare inverter for each train and the associated design configuration increases the availability of energized Instrument Bus for the protection channel and vital bus.

These changes do not involve an increase in the probability or l

consequences of-an accident previously evaluated. l DELETION OF THE PROTECTION CHANNEL AND VITAL BUS RATINGS l FOR INSTRUMENT BUS l

The third proposed change deletes specifying of the protection l l channel and vital bus KVA ratings for the Instrument Bus. The j ratings of inverter that feeds these instrument buses are being described in other Licensing Bases Documents or Design Basis

! Documents. There is no change proposed to the intent of the action statements. This is considered an administrative change and does not impact the probability or consequences of an accident previously evaluated.

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

CHANGE TO IDENTIFY BATTERY CHARGER RATINGS Replacing the inverters and battery chargers and changing the ,

parameters of the battery charger surveillance test to match the replacement chargers does not alter the functional modes of this portion of the design and does not result in any new failure modes.

As such, it does not create the possibility of a new or different accident from any previously evaluated.

CLARIFICATION TO DEFINE ASSOCIATED INVERTER  ;

The second proposed change allows use of an installed spare inverter l for each train to energize the one of the Instrument Bus for the protection channel and vital bus at a time for the respective safety train while its dedicated inverter is not available. The spare inverter is such that it has the capability to support the maximum load for the protection channel or vital bus. Manually aligning the installed inverter to replace on of the dedicated inverters is l essentially equivalent to a repair activity which replaces a faulted inverter with a new inverter. In addition, procedural controls and

, interlocks are provided to ensure the proper alicament of the j installed spare when it is used. The proposed cl:anges do not create i the possibility of a new or different accident fem anv previously l evaluated.

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l Attachment 2 to TXX 96432 Page 7 of 8 )

i DELETION OF THE PROTECTION CHANNEL AND VITAL BUS RATINGS FOR INSTRUMENT BUS l l

The third proposed change as discussed earlier does not change l l intent of the Technical Specifications action statements. This is '

an administrative change which does not introduce new failure modes l and has no new or different accidents from any previously evaluated ,

l are created. '

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

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The relevant Technical Specification sections proposed for changes:

(1) ensure that the battery charger is capable of charging the battery by performing the surveillance at 18 month frequency: (2) establish operability requirements of the Instrument Bus for the protection channel and vital bus in MODES 1 through 6: and (3) i identify the actions required for not meeting item 2.

l These proposed changes do not alter the intent of the above

! requirements; however replacement of the currently installed

! inverters with inverters which are expected to be more reliable and available and the addition of a spare inverter per safety train to energize Instrument Bus for protection channel and vital bus does increase the reliability of the instrument busses for the train.

Allowing credit for this spare inverter in meeting the operability l requirements of Instrument Bus for the protection channel and vital bus, minimze potential plant shutdowns due to non energized instrument from its dedicated inverter. These changes do not involve a significant reduction in margin of safety.

l On the basis of the above evaluations, TU Electric concludes that the proposed changes satisfy the no significant hazards consideration l

standards and do not involve a significant hazards consideration. I V. ENVIRONMENTAL EVALUATION l

TU Electric has evaluated the requested changes and has determined that j 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 requested changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the requested changes is not required.

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l Attachnent 2 to TXX 96432 i Page 8 of 8-VI. REFERENCE l l

1 NUREG 1431, " Standard Technical Specifications Westinghouse l Plants", Revision 1 <

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