ML20216D584

Revised LAR 98-002 for Licenses NPF-87 & NPF-89,temporarily Removing Requirement to Demonstrate Load Shedding Feature of MCC XEB4-3 as Part of SRs 4.8.1.1.2f.4)a) & 4.8.1.1.2f.6)a), for Unit 2 Only

ML20216D584
Person / Time
Site:	Comanche Peak
Issue date:	03/09/1998
From:	Terry C, Walker R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216D590	List: ML20216D584 ML20216D602
References
TXX-98066, NUDOCS 9803170145
Download: ML20216D584 (7)

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Log # TXX 98066 y

File # 916 (3/4.8) g Ref. #

R 50.90 10 CFR 50.36 c.x nery s,,ae, vie, r,,,m,,,

March 9, 1998

& PrincipalNancieer 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 REVISION TO LICENSE AMENDMENT REQUEST 98 002 A.C. POWER, OPERATING REF: 1) TU Electric Letter, logged TXX 98049, from C. L. Terry to the NRC dated February 20. 1998 i

2) TU Electric Letter, logged TXX 98050, from C. L. Terry 1

to the NRC dated February 25. 1998 Gentlemen:

In references 1 and 2 TU Electric requested a temporary change to the CPSES Units 1 and 2 Technical Specifications. The proposed temporary change to the Technical Specifications removed the requirement to demonstrate the load shedding feature of MCC XEB4 3 as part of Surveillance Requirements (SRs)

'4.81.1.2f.4)a) and 4.8.1.1.2f.6)a) until the plant startup subsequent to the next refueling outage for each respective unit or until an outage of sufficient duration to properly schedule and perform the test. This temporary change was requested as a result of the failure to confirm the load shedding feature of MCC XEB4 3 during the last performance of these SRs for the Unit 1 and Unit 2 train B diesel generators'(DGs).

Subsequently, it was determined that the surveillances had been satisfactorily performed for Unit 1.

The requested change to the Technical specifications submitted in License Amendment Request (LAR) >8 002 (reference

2) and the Enforcement Discretion-(reference 1) is thereforr. revised such that it applies to Unit 2 only.

1 In addition, based on discussions with the NRC staff, the footnote added to i

the affected technical specification page is revised.

The footnote phrase, "or earlier outage of sufficient duration to properly schedule and perform the test" is revised to indicate a specific outage duration. The revised wording states "or the next Unit 2 outage greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in duration."

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' is the required affidavit. Attachment 2 to LAR 98 002 as

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revised, provides a detailed description of the proposed change, a safety

' analysis of the change, and TU Electric's determination that the proposed change does not involve a significant hazard consideration. Attachment 3 to COMANCHE rEAK STEAM ELECTRIC STATION 9903170145 9

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TXX 98066 Page 2 of 2

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LAR 98-002 as revised, provides the affected Technical Specification page, marked up to reflect the proposed change.

The license amendment request (LAR 98 002 as revised) should be effective up1n issuance to be implemented immediately.

In accordance 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 (254) 897 0122.

This communication contains no new licensing basis commitments regarding j

CPSES Units 1 and 2.

Sincerely, j

C. L. Terry By:

N Roger %. Walker Regulatory Affairs Manager BSD/bd Attachments-1 1.

Affidavit 2.

Description and 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 Mr. Arthur C. Tate Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 4

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Attachient l'to TXX 98066 Page 1 of 1 i

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

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License Nos. NPF 87

-Station. Units 1 & 2)

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NPF-89 AEf.1DAYII Roger D. Walker. _being ' duly sworn, hereby deposes and says that he is Manager of Regulatory Affairs for TU Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 98 002 (as_ revised); 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.

Of4P.4 2:

Togef D. Walker Regulatory Affairs Manager STATE OF TEXAS

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COUNTY OF h ))

Subscribed and sworn to before me, on this T

dayofMaRek[TN.

bout)[d Notary Public 9commwon axons DONALD R. WOOOLAN Notory Public state of Tm 494s l

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ATTACHMENT 2 to TXX 98066 DESCRIPTION AND ASSESSMENT 1

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0- to TXX 98066 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 I

procedures for 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 Unit 2 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 procedure for the train B diesel generator (DG) for Unit 2 does not require confirmation that bus XEB4 3 load sheds.

TV Electric confirmed that failure to load shed this bus would not result in the diesel generator being inoperable. The diesel has sufficient reserve capacity to emergency start and perform its safety functions with this bus loaded at time zero in the diesel generator loading sequence. TU Electric believes that this specification only requires testing of the

- loads which are required to be load shed to allow the DG to perform its specified safety functions. Because the diesel generator remains capable of performing its specified safety functions without the load shed of this bus. TU 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. CPSES 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 change does not impact the improved Technical Specifications because it is a temporary change and it is plant specific.

II.

DESCRIPTION OF TECHNICAL SPECIFICATIONS CHANGE REQUEST This LAR requests a temporary Technical Specification change which removes the requirement to demonstrate the load shedding feature of MCC XEB4 3 as part of 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 Unit 2 or the next Unit 2 outage greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in duration.

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) the safe shutdown of the facility, and (2) the mitigation and control of j

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 allow the diesel generator to start. connect to the emergency

, to TXX-98066 Page,2 of 3 i

be shed to allow the diesel generator to start, connect to the emergency busses and load. Because the bus 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 generator's safety function is not adversely affected.

Failure to test the load shed feature with respect to this single load has no impact on safety. TU Electric concludes that this change is safe and acceptable.

IV SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS TU 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:

1.

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

The 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 CPSES 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 DG if this bus does not shed and has concluded that the DG remains fully capable of performing its 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 differant

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kind of accident from any accident previously evaluated?

Operation without havi..; tested the load shedding feature of bus XEB4 3 does not effect the operation or design of the plant 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 margin of safety?

Because the diesel generator remains fully capable of performing its 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, accordingly, a finding by the NRC of no significant hazards consideration is justified.

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V.

ENVIRONMENTAL EVALUATION TU Electric has determined that the proposed amendment would change requirements with res act to the installation or use of a facility i

component located wit 11n the restricted area, as defined in 10CFR20, or J

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 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 proposed change is not required.

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