ML20210N170
| ML20210N170 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/03/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210N161 | List: |
| References | |
| NUDOCS 9908110038 | |
| Download: ML20210N170 (4) | |
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UNITED STATES s
,j NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20eeH001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 66 AND 66 TO 1
FACILITY Of.ERATING LICENSE NOS. NPF-87 AND NPF-89
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TEXAS UTILITIES ELECTRIC COMPANY l
COMANCHE PEAK STEAM ELECTRIC STATION. UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 s
1.0 INTRODUCTION
By application dated May 4,1999, as supplemented by letter dated June 4,1999, Texas Utilities Electric Company (TU Electric /the licensee) requested changes to the Technical Specifications (TSs) for the Comanche Peak Steam Electric Station, Units 1 and 2. The proposed changes would revise the TSs to correct a number of editorial errors that occurred with issuance of License Amendment No. 64 dated February 26,1999, which issued the improved TS (ITS). In addition, Surveillance Requirement (SR) 3.8.4.7 would be changed to I
allow the substitution of a modified performance discharge test, for a service test, for the 125 VDC batteries and SRs 3.8.1.7,3.8.1.12,3 S.1.15, and 3.8.1.20 would be revised to separate the voltage and frequency acceptance criteria for the diesel generator (DG) start surveillance into two sets of criteria; those criteria required to be met within 10 seconds, and
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those criteria required to be met following achievement of steady state conditions.
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2.0 DISCUSS!ON AND EVALUATION The licensee has identified the following editorial errors, which should be corrected:
j (1)
ITS 3.0 SR 3.0.3, third paragraph, would be revised to delete one occurrence of the phrase " Conditions (s) rr,ust be entered," which was inadvertently included twice.
(2)
ITS 3.1.8 Limiting Condition for Operation (LCO) its n b wouH be revised to delete an extraneous ">" symbol.
Required Action A.5, Note 2, would be revised to restore the word (3) ITS 3.2.4 "shall," which was inadvertently deleted.
(4)
ITS 3.3.1 SR 3.3.1.7, Note 2, would be revised to delete an extraneous
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comma after the word " instrumentation."
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r o (5) ITS 3.3.5 Condition F would be revised to delete the word " Logic" from
" Actuation Logic Relays" consistent with the terminology used in other areas of the ITS.
(6)
ITS 3.4.14 SR 3.4.14.1 would be revised to delete the "HV' prefix for the specified residual heat removal (RHR) valves consistent with plant practice.
-(7)
ITS 3.7.11.
Required Action E.1.2 would be revised to change " trains" to 7tain" for grammatical consistency.
(0)
ITS 3.8.3 Condition A would be revised to change " Modes" to " MODES" in two locations consistent with use of TS definitions.
(9)
ITS 3.8.7 LCO Note itern b would be revised to restore the word " associated" in front of " OPERABLE inverters" consistent with the standard TS wording.
(10) TS 5.5.16 The second item "d" would be revised to be item "e."
Double commas would be revised to be a single comma in two (11) ITS 5.6.1 locations.
(12). LCO 3.2.2 The Completion Times for Required Actions A.1.2.2 and A.2 would be moved to align them with the location of their corresponding Required Actions, consistent with NUREG-1431 format.
(13) LCO 3.4.11 The Note for Required Actions in Conditions C and F would be revised to reference " Actions B.2 or E.2" instead of " Actions B.2 or E.3." The Condition "E" Actions had been tsnumbered but the i
changes to the note were inadvertently omitted.
SR 3.7.12.4 would be revised to add a negative sign to the "0.05
- (14) SR 3.7.12.4 inches water gauge," which had been inadvertently deleted.
(15) LCO 3.7.10 '
The Applicability would be revised to add the word "and" after Mode 5, to be consistent with the NUREG-1431 format.
i (16) SR 3.8.4.5 The units of " ohm" would be added to two resistance values in SR 3.8.4.5, which had been inadvertently omitted.
(17) LCO 3.9.5 Consistent with the title of the LCO, the page heading would be corrected to be "RHR and Coolant Circulation - High Water Level" instead of "RHR and Coolant Recirculation - High Water."
(18) LCO 4.3.1.1 The word "in" would be deleted from 4.3.1.1.f. because it was duplicative.
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,. The NRC staff has reviewed the lie,enaae's proposed editorial corrections and concludes that the errors occurred with the issuarme of Amendmnnt No. 64 to Facility Operating License Nos. NPF-87 and NPF-89, dated February 28,1999, regarding the conversion to the fS. The proposed editorial changes correct these inadvertent errors and therefore, are acceptable.
- With regard to the TS associated with the SR for the125 VDC batteries, at the present time SR 3.8.4.7 allows the licensee to perform a modified performance discharge test, instead of the L service test, only once in any 60-month period. The requirement for SR 3.8.4.7 states
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- The modified performance discharge test in SR 3.8.4.8 may be performed in lieu of the service test in SR 3.8.4.7 once per 60 months.
The licensee has proposed to' delete the phrase'"once per 60 months" in SR 3.8.4.7. The
- proposed change to SR 3.8.4.7 would allow the performance of a modified performance discharge test in lieu of a service test at any time.
i With regard to battery test recommendations, IEEE-450-1995, "lEEE Recommended Practice for Maintenance Testing, and Replacement of Vented Lead-Acid Batteries for Stationary
. Applications," Section 5.4, places no limitation on the use of a modified discharge test in lieu of a service test since the discharge rate is required to envelope the duty cycle of the service test.
- A modified performance discharge test is a test of the battery's ability to provide a high-rate, short-duration load. This test will often confirm that the battery meets 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 should be identical to those specifed for a service test.' A battery service test is a test of battery capability, as found, to satisfy the design requirernents (battery outy cycle) of the dc electrical power system. IEEE-450-1995, Section 5.4 states that "{a) modifed performance discharge test can be used in lieu of a service test at any time."
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- The basis for acceptability of allowing the substitution of a modified performance discharge test, for a service test, is that the modified performance discharge test will envelope the service test load demand profile. The proposed Bases for ITS SR 3.8.4.7 adequately describes the modified performance discharge test. The proposed change to SR 3.8.4.7.would pmvide addrtional flexibility in allowing the performance of a modified performance discharge test in lieu of a serdce test at any time. Based on the above considerations, the proposed change to SR 3.8.4.7 is acceptable.
- With regard to the emergency DG (EDG) SRs, these SRs address testing that requires the EDGs to start and reach a voltage and frequency within a specified band in a specified period of time (10 seconds). The EDGs actually start and accelerate on full fuel until the govemor responds and reduces the fuel amount. On startup, the governor will lag the engine speed by
= some amount because there is a delay in building up govemor oil pressure. As a consequence of this, the EDG may accelerate beyond synchronous speed before the govemor responds fully.
- At this point, the govemor may call for "0" fuel and the engine. speed will decrease, and may go lower than synchronous speed.~ There may be several cycles like this before the EDG approaches stesdy state operation, and the time to reach steady state (within the specified 1
band) may exceed 10 seconds. In such a case, based on literalinterpretation of the TSs, the SR would be failed. However,' there is nothing wrong with the EDG. Therefore, the licensee
- has proposed to change the SR requirements to only require EDGs to reach a minimum voltage x
. ta i and frequency within 10 seconds, and to subsequently achieve steady state operation. The minimum voltage and frequency are those necessary for the EDG to accept load and are established by the licensee /EDG vendor. The time to reach steady state operation, while not i
part of the T8, is monitored and trended as a means of evaluating continued governor and voltage regulator OPERABILITY.
In summary, the TS should be changed in order to recognize a normal evolution following the start of an EDG (i.e., oscillations in voltage and freauency that may be outside the specified band for greater than 10 seconds ) As stated, this is a normal evolution and is not cause to declare the EDG inoperable. Therefore, the proposed changes to 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 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, are acceptable.
3.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previcusly issued proposed findings that the amendments involve no significant hazards consideration, and there has been no public comment on such findings (64 FR 29715 dated June 2,1999; and 64 FR 35212 dated June 30,1999). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: D. H. Jaffe Date: August 3, 1999 a