ML20203J492

Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Attached Change Into TS to Remove Requirement to Demonstrate Load Shedding Feature of MCC XEB4-3 as Part of Surveillance Requirements

ML20203J492
Person / Time
Site:	Comanche Peak
Issue date:	02/25/1998
From:	Kelley J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20203J497	List: ML20203J492 ML20203J521
References
TXX-98050, NUDOCS 9803040166
Download: ML20203J492 (8)

Text

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- O Log # TXX 98050 C C File # 916 (3/4.8) 1RIELECTRIC 10010 Ref. # 10 CFR 50.90 10 CFR 50.36

c. u.c. wrry senior wee rre,u,n, February 25, 1998

& PrincipalNuclear Oficer

-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 98 002 A.C. POWER, OPERATIhG REF: 1) TU Electric Letter, logged TXX-98049, from C. L. Terry to the NRC dated February 20, 1998 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 change into the CPSES Units 1 and 2 Techn u.a1 Specifications. Th' change is applicable to both CPSES Unit 1 and CPSES Unit 2.

On February 20, 1998, at about 2:30 pm central time TU Electric participated in a conference call with the NRC staff. The subject of the call was the request for enforcement discretion submitted to the NRC earlier that day in TU Electric letter TXX 98049 (reference 1). The NRC had six comments. Those comments are paraphrased below along with the responses provided by TU Electric:

1. Section 2 of the letter, " Circumstances," does not discuss the roct cause of the failure to demonstrate the load shedding feature for MCC XEB4 3.

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TU Electric's response: The root cause of this event has not yet been -

determined. The root cause will be determined as required by the CPSES corrective action processes. To the extent required by 10 CFR 50.73, root cause will be discussed in the License Event Report (LER) to be issued for i d

p this event.

2. Section 3 of the letter,

• Safety Significance and Potential Consequences," did not include at least a qualitative risk assessment derived from the licensee's PRA.

TU Electric's response: The deterministic assessment as provided in the letter is that continued operation in the current condition poses rio adverse consequences. The PRA experts at CPSES have evaluated continued operation of the plant without demonstrating the load shedding feature of MCC XEB4 3 cnd

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.TXX 98050 Page 2 of 3 have qualitatively concluded that such continued operation would have no impact of significance on the existing PRA for CPSES.

3. In Section 10 of e letter, TV Electric committed to provide a License Amendment Request (LARf by March 9, 1998. This date.is not soon enough to-meet NRC guidance.

TU Electric's response: TU Electric agrt'd with the NRC staff to a submittal '

date for the LAR of February 25, 1998.

4. The proposed LAR should allow the temporary exclusion > of the subject demonstration until startup subsequent to the next refueling outage for each unit or until the next outage on each unit of sufficient duration to perform the required testing.

TU Electric's response: TV Electric agreed with the comment cnd agreed to change the LAR accordingly. The NRC staff and TU Electric agreed that an outage of sufficient duration included sufficient time to both setup for and perform the required testing. A specific outage length could not be confirmed as it is not clear at this time if the testing should be performed as part of the entire integrated test or_if this feature may be tested i

separately.

5. The NRC's guidance for enforcement discretion requires the licensee to provide marked up pages of the technical specifications if an LAR wi'il be required.

TU Electric's response: The marked up page of the CPSES Technical Specification was provided as committed.

6. The NRC staff asked that TU Electric address the separation between Class 1E and non Class 1E circuits as it relates to this MCC.

-TV Electric's response: As shown on FSAR Figure 8.3 12. Sheet 2. MCC XEB4 3 is non Class 1E. The MCC is powerad from either MCC 1EB4 3 (CPSES Unit 1) or 2EB4 3 (CPSES Unit 2), both 1EB4 3 and 2EB4 3 are Class IE (train B for their respective units). Separation is provide by the feeder breakers on the Class 1E MCCs. These feeder-breakers are tripped by a safety injection

_ signal from their respective units. The operability of this trip feature is demonstrated by the quarterly slave relay-testing of the Automatic Actuation Logic and Actuation Relays for Safety Injection (see Tcble 4.3 2, Channel Functional Unit 1.b. of the CPSES Technical Specifications). The feeder

= cables frca the feeder breakers to MCC XEB4 3 are Associated Class 1E (Train BB). Table 8.310 of the FSAR lists MCC XEB4 3 as a non-safety load fed by associated cables, after isolation, where separation from internal non Class IE circuits within the equipment is not required.

This license amendment request (LAR) propcses a tempor6cy change to the Technical Specifications to remove the requirement to demonstrate the load shedding feature of MCC XEB4 3 as part of Surveillance Requirements (SRs) 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) until the plant startup subsequent to the next refueling outage for each res)ective unit or until an outage of sufficient duration to properly scledule and perform the test. This f

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.TXX 98050 Page 3 of,3 temporary change is requested as a result of the failure to confirm the load-shedding feature of MCC XEB4 3 during the last.performence of these SRs for the Unit 1 and Unit 2 train B diesel generators (DGs).

Attachment-I is the required affidavit. Attachment 2 provides a detailed description-of the proposed changes, a safety analysis of the changes, and TV +

Electric's determination that the proposed changet, do not involve a significant hazard consideration. Attachment 3 provides the affected

' Technical Specification page, marked up to reflect the proposed changes.

This LAR is bein0' submitted as follow up to the request for enforcement discretion'(references 1). The license amendment should be effective upon-

- issuance to be implemented irmediately.

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

, Should you have any questions, please contact Mr. Bob Dacko at L (*54) 897 0122.

- This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2.

4 Sincerely. -

C. L. Terry By:

James J. Kelley, Jr.

Vice President of.

Nuclear Engineering and Support

'B50/bd-Attachments:

-1. Affidavit'

2. Description andl Assessment

3. Affected Technical Specification page as revised by all approved

-license amendments c--

E.-W. Herschoff, Region IV J. I. Tapia. Region IV T. J. Polich, NRR Resident Inspectors :CPSES l

Mr. Arthur C. Tate  !

Bureau.of Radiation Control Texas Department of- Public' Health 1100 West 49th Street-Austin, Texas 78704 Attachment 1 to TXX 96007 s

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. Attachment ilto TXX 98050 Page 1 of 1 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COH11SSION 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 Station. Units 1 & 2) ) NPF 89 AFFIDAVIT James.J. Kelley, Jr., being duly sworn. hereby deposes and says that he is Vice President of Nuclear Engineering and Support for TU Electric, the -

licensee herein: that he 1: duly authorized to sign and file with:the Nuclear Regulatory Commission this License Amendment Request 98 002: that he is familiar with the con:ent thereof: and that the matters set forth therein are true and correct to the best of his_ knowledge, information and belief.

W)

James J. Kelley, Jr.

Vice President of (*

Nuclear Engineering and Support STATE OF TEXAS -)

COUNTY OF 8 W Subscribed and sworn to before me, on this 05 day of db.

OuAaaI (Notary _Public JEAN AMUN05GN ~

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2 ATTACHMENT ?. to TXX 98050 t

DESCRIPTION AND ASSESSHENT 4

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Attachment 2 to TXX 98050 Page 1 of 3 DESCRIPTION AND ASSESSMENT -

I. BACKGROUND While performing a review of surveillance procedures in accordance with U.S. NRC Generic Letter 96 01, it was determined that the surveillance procedures fer Surveillance Requirements 4,8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) were deficient in that the load shedding of one electrical bus on each unit had not previously been demonstrated. The surveillances required that upon a loss of offsite power, the emergency busses de energize and load shedding occurs. The current procedures for the train B diesel generator (DG) for botn CPSES Units 1 and 2 do not require confirmat1on that bus XEB4 3 load sheds for Units 1 and 2 respectively.

This is a common bus that can be supplied from either Unit 1 or Unit 2.

TU Electric confirmed thic failure to load shed this but would not result in the diesel generators oeing inoperable as both die: sis have sufficient reserve capacity to emergency start and perform their safety functions with these busses loaded at time zero in the diesel gr.ierator loading

sequen

e. TV Electric believes that this s)ecification only requires i testing of the loads which are required to )e load shed to allow the DG to perform its specified safety functions. Because the diesel generators remain capable of performing their specified safety functions without the

' load shed of this aur TV Electric concluded that the surveillance had been met.

In subsequent discussions with NRR, the NRC staff expressed the opinion that, even though the staff did not see a safety problem or issue, C'SES was not in literal compliance with these Surveillance Requirements. Based on the feedback received from the NRC staff. TU Electric chose the conservative action of declaring the Surveillance Requirements as missed and invoking the requirements of Technical Specification 4.0.3 for a missed surveillance.

This charge does not impact the improved Technical Specifications because it is temporary change and is plant specific.

II. DESCRIPTION OF TECHNICAL. SPECIFICATIONS CHANGE REQUEST This LAR will request a temporary Technical Specification changt which removes the requirement to demonstrate the load shedding feature of MCC XEB4 3 as part rf SRs 4.8.1.1.2f. A)a) and 4.8.1.1.2f.6)a) until plant startup subsequent to the next refueling outaje for each rc pective unit or earlier outage of sufficient duration to properly schedule and perform the test.

III. ANALYSIS The safety function of the A.C. Sources is to ensure that sufficient power will be available to supply the safety related equipment required for: (1)

Attachment 2 to TXX 98050 Page 2 of 3 the safe shutdown of the facility, and (2) the mitigation and ccntrol of accident conditions within the facility. The function of the Surveillance Requirement of concern is to demonstrate that for a start of the diesel generators, the emergency busses will de energize and sufficient load will be shed, to al?9w the diesel generator to start, connect to the emergency busses and load. Because the busses in question can be loaded on the diesel generator at time zero of the loading sequence without affecting the ability of the diesel generator to properly start, connect to the emergency bus and load, the diesel generators' safety function is not adversely affected. Failure to test the load shed feature with respect to this single load has no impact on safety. TV Electric concludes that this change is safe and acceptable.

IV SIGNIFICANT HAZARDS CONSIDERATIONS ANALYS!3 TV 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: (

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

1he only potential impact of operating without having demonstrated the load shedding feature of MCC XEB4 3 is the potential that the train B DG for either CPSES Unit 1 or Unit 2 will not- be able to perform its safety function following a postulated accident or event. TU Electric has evaluated the potential load added to the DGs if this bus does not shed and has concluded that the DGs remain fully capable of performing their-safety function. As a result, there is no significant increase in 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?

Operation without having tested the load shedding feature of bus XEB4 3 does not effect the operation or design of the Units and therefore cannot create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Because the diesel generators remain fully capable of performing their safety functions without having demonstrated the load shedding feature of MCC XEB4 3, there is no significant reduction in a 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(c) and, t accordingly, a finding by the NRC of no significant hazards consideration is justified.

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Attachment 2 to TXX 98050 Page 3 of 3 V. ENVIRONMENTAL EVALUATION TV Electric has determined that the proposed amendment would change requirements with res)ect to the installation or use of a facility component located wit 11n the restricted area, as defined in 10CFR20. or-would change an inspection or surveillance requirement. 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 cumclative 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 proposed change is not required.

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