ML20206G705

LAR 99-001 for Amends to Licenses NPF-87 & NPF-89,revising Surveillances Associated with Plant Battery & EDGs & Miscellaneous Editorial Corrections

ML20206G705
Person / Time
Site:	Comanche Peak
Issue date:	05/04/1999
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206G709	List: ML20206G705 ML20206G711
References
TXX-99065, NUDOCS 9905100118
Download: ML20206G705 (7)

Text

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10CFR50.90 1 CFR50.36a 7t# ELECTRIC May 4,1999 C. Immes' merry senior uce rmwns

& Princ4nniNuclear Oficer.

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

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 LICENSE AMENDMENT REQUEST LAR)99-001 REVISIONS TO SURVEILLANCES A(SSOCIATED WITH THE PLA BATTERY AND THE EMERGENCY DIESEL GENERATORS AND MISCELLANEOUS EDITORIAL CORRECTIONS

' REF:

1. ' TU Electric letter logged, TXX-97105 from C. L. Terry to the NRC dated

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May 15,1997 2.

TU Electric letter logged, TXX-99018 from C. L. Terry to the NRC dated February 3,1999 3.

TU Electric letter logged, TXX-99040 from C. L. Terry to the NRC dated February 12,1999 i

4.

TU Electric letter logged, TXX-99051 from C. L. Terry to the NRC dated February 23,1999 5.

NRC letter from Jack N. Donohew to C. L. Terry dated February 26, 1999 Gentlemen:

. Pursuant _to 10CFR50.90, TU Electric requested an amendment to the CPSES Unit 1 facility operating license (NPF-87) and Unit 2 facility operating license (NPF-89) by incorporating changes to the CPSES Units 1 and 2 Technical Specifications (TS) as

provided in reference 1 and as supplemented by references 2,3 and 4. The NRC granted the requested license amendment (Amendment 64)in reference 5. TU Electric hereby proposes a new license amendment request (LAR 99-001 ) to the CPSES Units 1 and 2 Technical Specifications. This request applies equally to both units.

- LAR 99-001 contains 3 changes. The first change revises Surveillance Requirement (SR) 3.8.4.7 to allow the unrestricted substitution of the modified battery performance 3

discharge test in lieu of the service discharge test. The second change involves the adoption of NRC approved traveler, TSTF-163, Rev 2. ' This traveler revises SRs 3.8.1.7, 3.8.1.12,3.8.1.15 and 3.8.1.20 to separate the voltage and frequency acceptance criteria for the Diesel Generator (DG) start surveillances into two sets of criteria; those criteria required to be met within 10 seconds, and those criteria required to be met ~

i following achievement of steady state conditions. The third change corrects miscellaneous editorial errors in the certified specifications (Amendment 64).

j

. 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 c>Q COMANCliE PEAK SiLAM ELECTRIC STATION pp { (

r g gg-m P.o.nox1002 cien Rose. Texas 76043.ioo2 POR ADOCK 05000445 I

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m TXX-99065 Page 2 of 2 a significant hazard consideration. Attachment 3 provides the affected Technical Specification pages as of Amendment 64 (Improved Technical Specification or ITS),

marked-up to reflect the proposed changes. The current TS pages (pre-Amendment 64) have not been marked up as these changes will not be implemented before Amendment

- 64 is implemented. Attachment'4 provides clean copies (except for the amendment number in the footer) of the revised specification pages.

- This LAR requests approval of the specification changes only. Changed Bases pages are provided for information. Bases changes will be made in accordance with TS 5.5.14, Bases Control Program.

TU Electric requests approval of the proposed license amendment by July 30,1999.

These changes are to be implemented simultaneous with Amendment 64 or within 30 days following the issuance of the license amendment but not before implementation of

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Amendment 64.

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l in accordance with 10CFR50.91(b), TU Electric is providing the State of Texas with a

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copy of this proposed amendment.

i This communication contains no new commitments or revised commitments. Should you have'any questions, please contact Mr. B.(Bob) S. Dacko at (254) 897-0122.

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Sincerely, e.s.g C. L. Terry By:

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R6g6f D. Walker Regulatory Affairs Manager BSD/bsd Attachments: 1. Aft! davit

2. Description and Assessment

3. Affected Technical Specification pages (marked-up of pages)

4. Affected Technical Specification pages (clean replacement pages) c- '

E. W. Merschoff, Region IV J. l..Tapia, Region IV

' Resident inspectors, CPSES D. H. Jaffe, NRR J. N. Donohew,- NRR Mr. Authur C.. Tate Bureau of Radiation Control

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Texas Department of Public Health

- 1100 West 49th Street Austin, Texas 78704

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.. to TXX-99065 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the Matter of

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Texas Utilities Electric Company

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Docket Nos.

50-445

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50-446 (Comanche Peak Steam Electric Station,

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License Nos.

NPF-87 Units 1 & 2)

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NPF-89 AFFIDAVIT Roger D. Walker being duly sworn, hereby deposes and says that he is Regulatory Affairs Manager of TU Electric, the licensee herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 99-001; 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.

@ Of RogerW. Walker Regulatory Affairs Manager STATE OF TEXAS

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COUNTY OF Somervell

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Subscribed and sworn to before me, on this J day of

/W7v 1999.

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'%1 LOO Notary Public w.c ~ ~ -

Gayu R Pec't Jespeaen '

Nobry PWfic

c jp;..,,..p IA) Comm.ra.S: ate of Texas

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. to TXX-99065

.Page 1 ^of 4.

DESCRIPTION AND ASSESSMENT

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BACKGROUND ~

.1) The first change revises ITS Surveillance Requirement (SR) 3.8.4.7 to allow the J

unrestricted substitution of the modified performance discharge test in lieu of the service discharge test.' The Standard Technical Specifications, NUREG-1431, revision 1 (STS) had previously allowed this substitution only once per 60 months. The markups associated with this change were originally provided in reference 1 as part of a larger change incorporating traveler TSTF-115. However, based on the NRC rejection of 4

-TSTF-115, and in response to NRC Comment Number Q 3.8.4-08, this change was j

withdrawn. Subsequently, the NRC accepted the portion of TSTF-115 allowing the

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unrestricted substitution of the modified performance discharge test in lieu of the j

service discharge test. This is a less restrictive change which is described in DOC j

J2-25-LS-23, NSHC LS-23 and JFD 3.8-38 (provided in reference 1).

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.2) The second change involves the adoption of NRC approved traveler, TSTF-163, Rev 2. This traveler applies to the STS for Westinghouse plants (NUREG 1431) and is l

. fully applicable to CPSES.EThis traveler revises SRs 3.8.1.7, 3.8.1.12, 3.8.1.15 and 3.8.1.20 to separate the voltage and frequency acceptance criteria for the Diesel I

- Generator.(DG) start surveillances into two sets of criteria; those criteria required to be met within:10 seconds, and those criteria required to be met following achievement of.

steady state conditions. _ Previously all the acceptance criteria were required to be met

-within 10 seconds.

3) The third change coirects miscellaneous editorial errors in the certified specifications.

' DESCRIPTION OF TECHN' CAL SPECIFICATIONS CHANGE REQUEST

,,. II.

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1) LThe words "once per 60 months" in Note 1 of SR 3.8.4.7 are deleted. This results in j

aliowing unrestricted substitution of the modified performance discharge test in lieu of the service test. The corresponding change is also made in the SR 3.8.4.7 Bases.

2). SRs 3.8.1.7,3.8.1.12,3.8.1.15 and 3.8.1.20 are revised to separate the voltage and frequency acceptance criteria for the Diesel Generator (DG) start surveillances into two sets of criteria; those criteria required to be met within 10 seconds, and those criteria f required to be met following achievement of steady state conditions.

4) Editorial corrections are made as follows:

q

1) "

..lTS 3.0

~ " Conditions (s) must be entered" which was inadvertently included SR 3.0.3 is revised to delete one occurrence of the phrase twice.

2).

ITS 3.1.8 - LCO ltem b is revised to delete an extraneous ">" symbol.

3)'

ITS 3.2.4 - Required Action A.5 Note 2 is revised to restore the word "shall"

- wnich was inadvertently deleted.

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q LAttachment 2 to TXX-99065 Page 2 of 4 -

4)

. lTS '3.3.1

- SR 3'3.1.7,' Note 2 is revised to delete an extraneous comma after the word " instrumentation."

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.5).

ITS 3.3.5 - Condition F is revised _to dc'c.e the word " Logic" from " Actuation Logic Relays" consistent with the terminology used in other areas of the ITS.

I 6):

'lTS 3.4.14 SR 3.4.14.1 is revised to delete the "HV" prefix for the specified RHR valves' consistent with plant practice, i

7)

ITS 3.7,11 - Required Action E.2 is revised to change " trains" to " train" for i

grammatical consistency.

. 8),

. ITS 3.8.3 = - Condition A is revised to change " Modes" to " MODES" in two I

f locations consistent with use of TS definitions.

'i 9).

ITS 3.8.7 - LCO Note item b is revised to restore the word " associated"in front 1

of " OPERABLE inverters" consistent with the STS wording.

10)

ITS 5.5.16 - The second item "d"is revised to be item "e."

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ITS 5.6.1 - Double commas are revised to be single commas in two locations.

Ill.

ANALYSIS j

1) The "once per 60 months" limitation on use of a modified performance discharge test In lieu of a service test is removed.~ IEEE-450-1995, Section 5.4 places no such limitation on the use of a modified performance discharge test in lieu of a service test 1

since the modified performance discharge rate is required to envelope the duty cycle of lI the service test. A modified performance discharge test is a test of the battery's ability

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- to provide a high-rate, short-duration load. This will confirm the battery's ability to meet

'the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test will be

. identical to those specified for a service test.

2) TSTF-263, Rev 2 clarifies that the intent of the 10 second start test is to confirm the

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ability of the DG to reach minimum conditions to accept load. As such, the capability to stay below the maximum voltage and frequency is not required to be demonstrated within'10 seconds. The ability of the'DG to reach and maintain steady state operation is used to identify degradation of governor and voltage regulator performance.

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3) The editorial changes do not involve any technical changes.

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, to TXX-99065 Page 3 of 4 IV.

SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS TU Electdc has evaluated whether the proposed changes involve a significant hazards consideration. The evaluation addresses the three standards set forth in 10CFR50.92(c) and is discussed below.

1.

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

1) Batteries are used to support mitigation of the consequences of an accident, and are not considered to be an initiator of any previously analyzed accident. The proposed change would not effect the design or performance of the batteries. The allowance to perform the modified performance discharge test in lieu cf the service test at any time is permissible since the test's discharge rate envelopes the duty cycle of the service test. Therefore, the allowance for unrestricted substitution of the modified performance discharge test in lieu of the service discharge test does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) The diesel generators are used to support mitigation of the consequences of an accident, and are not considered to be an initiator of any previously analyzed accident. The proposed change does not affect the accident analysis assumption that the DG reaches minimum conditions to accept load within 10 seconds. The ability of the DG to maintain steady state operation within 10 seconds is not an accident analysis assumption and is primarily used to identify degradation of governor and voltage regulator performance. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

3) The editorial changes are non-technical and therefore do not involve a 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?

1) The allowance for unrestricted substitution of the modified performance discharge test in lieu of the service discharge test does not involve any physical alteration to the plant. No new failure mechanisms will be introduced and the change does not affect the ability of the batteries to fulfill their safety-related function. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

2) The separation of the DG start surveillance criteria into those criteria required to be met within 10 seconds, and those criteria required to be

- met following achievement of steady state conditions, does not involve any physical alteration to the plant. No new failure mechanisms will be introduced and the change does not affect the ability of the DGs to fulfill their safety-related function. Therefore, this change does not create the 1

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o 1

' Attachment 2 to TXX-99065 Page 4 of 4 possibility of a new or different kind of accident from any accident

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previously evaluated.

3) The editorial changes are non-technical and therefore do not create the possibility of a new or different kind of accident from any accident-previously evaluated.

j 3.

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

.1) The allowance for unrestricted substitution of the modified i

performance discharge test in lieu of the service discharge test will not alter any accident analysis assumptions, initial conditions, or results.

Consequently, it does not have any effect on the margin of safety.

. Therefore, this change does not involve'a significant reduction in a margin i

of safety.

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2) The proposed change to delete the requirement to demonstrate that the DG can achieve and maintain steady state operation within 10

. seconds is not an accident analysis assumption. The accident analysis i

I assumption that the DG reaches minimum conditions to accept load within 10 seconds is preserved. Consequently, it does not have any effect on the margin of safety. Therefore, this change does not involve a'significant reduction in a margin of safety.

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3) The editorial changes are non-technical and therefore do not involve a significant reduction in a margin of safety.

Based on the evaluations above, TU Electric has determined that the activities associated with this change satisfy the no significant hazards consideration I

standards of 10CFR50.92 (c) and, accordingly, a no significant hazards i

consideration finding is justified.

' V.

ENVIRONMENTAL EVALUATION TU Electric has determined that the proposed amendment would change requirements with respect to the installation or 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 proposed changes and has determined that the changes do not involve (1) a significant hazards consideration, (2) a significant change in the types or significant Increase in the amounts of any effluent that may be released offsite, or (3) 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 required.

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VI.

REFERENCES Change 1 - Wolf Creek, Callaway and Diablo Canyon t

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