ML20211G344

Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2

ML20211G344
Person / Time
Site:	Comanche Peak
Issue date:	08/25/1999
From:	Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-MA4436, TAC-MA4437, TXX-99203, NUDOCS 9908310232
Download: ML20211G344 (5)

Text

h

(

. .~ ' w TXU

/ .

TXU Electric . C. Lance Terry . .

Comanche Peek seniorVice President & Principal Nuclear Officer .

Steam Electric Station P. o.8ox 1002 -

! Glen %TX 76043 T.i 254 897 8920 ~

l Fax:254 8976652 Iterryletxu.com Log # TXX-99203 File # 10010 i

Ref.# 10CFR50.36 August 25,1999 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 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON LICENSE AMENDMENT REQUEST 98-010 (TAC Nos. MA4436 and MA4437)

REF: TXU Electric iletter, logged TXX-98265, from C. L. Terry to the NRC dated December 21,1998 Gentle. men:

In the referenced letter, TXU Electric submitted a request to incorporate changes into the CPSES Units 1 and 2 Technical Specifications and the CPSES Unit 2 Operating License to increase the licensed power for operation of CPSES Unit 2 to 3445 MWth; an increase of approximately 1%. Per telephone conversation with the NRC, TXU Electric received a request to provide the attached additional information regarding l

License Amendment Request 98-010. Attachment 1 is the affidavit for the  ;

information supporting License Amendment Request 98-010. Attachment 2 provides

~

)

our response to the infonnation requested.

310009 L

t 8

I_ TXU Electric _was formerly TU Electric. A license amendment request (LAR 99-003) was

?

submitted per TXX-99122, dated May 14,1999, to revise the company name contained in the f_ CPSES operating licenses.

g

-9908310232 990825 I \ $

l

-PDR ADOCK 05000445 [k I h 'P_ PDR n j

hTXU l I

TXX-99203 Page 2 of 2 If you have any questions regarding the attached information, please contact Mr. J. D. Seawright at (254) 897-0140.

i

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

Sincerely, l hr -

C. L. Terry By: 04Jh b. &

RogeM. Walker Regulatory Affairs Managet 1

L JDS/jds Attachments c- E. W. Merschoff, Region IV J. I. Tapia, Region IV D. H. Jaffe, NRR Resident Inspectors, CPSES Mr. Arthur C. Tate Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78704 l

l L_

' Attachment 1 to TXX-99203 Page1 of1 - l l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

TXU Electric ) Docket Nos. 50-445

) 50-446 (Comanche Peak Steam Electric ) License Nos. NPF-87 Station, ~ :ts 1 & 2) ) NPF-89 AFFIDAVIT Roger D. Walker, Jr. being duly sworn, hereby deposes and says that he is the Regulatory Affairs Manager of TXU Electric, the licensee herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this Request for Additional Information regarding License Amendment Request 98-010; 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.

\ Ves,PA I l ,

Roger (d. Walker Regulatory Affairs Manager STATE OF TEXAS . )

)

COUNTYOF 8ommQ )

i Subscribed and swom to before me, on this 7_1 N day ofducgtrII- ,1999. l l

L, C hkN'l/V Gafe R Fed A4m Dotary Public f l

4 i  ; ,. t&t N11r/ Pett,Cb.e Comm.Expiru 03MWof kxas jff ,, . . . = .

I J

1 l

l Attachment I to TXX-99203 Page1 of2 -

RESPONSE TO NRC REQUEST FOR INFORMATION Question 1:

In section 6 of the Caldon Topical, reference is made to use of the LEFM to calibrate the Nis. Ilow does CPSES plan to use the LEFM and explain the relation of the LEFM as M&TE with regards to Appendix B.

Response

The requirement in Technical Specification Surveillance 3.3.1.2 is to " adjust" the NIS ,

and N-16 Power Monitor channels if the absolute difference between the calorimetric heat balance calculation and the NIS or N-16 Power Monitor channel output is greater than 2%. This requirement is further clarified in the associated Bases with the words

" adjusted consistent with the calorimetric power." Using these guidelines, it is more correct to state that the NIS and N-16 indications of reactor power are normalized, rather than calibrated, ugainst the reactor power calculated with the LEFM-based secondary plant calorimetric measurement. As such, the application of M&TE is not strictly appropriate.

The improved LEFM is included in the non-Appendix B Quality Assurance program as described in FSAR Section 17A.

Question 2:

Page 5.5 of the Caldon Topical discusses the use of the LEFM to correct the Venturi measurement. Page 8 of the TXU license amendment request also discusses the use of the LEFM for providing correction for venturi. What are CPSES plans when the LEFM is unavailable and the venturis are used for normalizing the NIs?

Response

The current practice at CPSES is to use the LEFM measured feedwater flow as a basis for correcting the venturi-based feedwater flow indication for effects such as fouling. This correction is used for the power calorimetric measurements only.

The purpose of the discussion that begins on the bottom of Page 5-5 of the Caldon Topical Report (ER-80P) is essentially a disclaimer. Through the use of the improved LEFM, the power calorimetric uncertainty is shown to be less than 1% RTP. However, this uncertainty calculation is not applicable to the case where the power calorimetric is

V l

Attachment I to TXX-99203 Page 2 of 2 -

based on venturi based feedwater flow indications, even if the improved LEFM is used to correct the venturi-based feedwater flow indications for effects such as fouling.

CPSES will be operated in accordance with the safety analyses and the applicable power calorimetric uncertainty analysis. When the improved LEFM-based calorimetric measurement is available, the plant will be operated at a nominal core power of 3445 MWth; however, the reactor operators will be provided procedural guidance for

. those occasions when the improved LEFM is not available.

As described in the proposed procedural guidance, if the LEFM becomes unavailable during the intervals between performance of Technical Specification Surveillance SR 3.3.1.2, plant operation at a thermal power of 3445 MWth may continue using the power indications from the NIS and N-16 systems. However, in order to remain in compliance with the bases for operation at a RATED THERMAL POWER of 3445 MWth, the LEFM must be returned to service prior to performance of SR 3.3.1.2. If the LEFM has not been retumed to service prior to the performance of SR 3.3.1.2, the procedural guidance would require that the reactor power be reduced to, or maintained at, a power level -less than or equal to 99% of RTP (3445 Mwth), which is the pre-uprated thermal power,3411 MWth. This power reduction is intended to be performed prior to SR 3.3.1.2 being performed. The surveillance would then be performed using the feedwater venturi indications of feedwater flow. Once SR 3.3.1.2 is performed using the feedwater venturi indications of feedwater flow, the required power uncertainty is 2%

RTP. In order to maintain compliance with the safety analyses, it is necessary to operate the plant at a maximum core thermal power of 3411 MWth.

Per the proposed procedural guidance, the core power would be maintained at a value less than or equal to 3411 MWth until the LEFM was returned to service and SR 3.3.1.2 had  ;

been performed using the LEFM indication of feedwater flow. Once SR 3.3.1.2 had been l performed, then the plant could again be operated at 3445 MWth. j l

l l

i l