ML20217A384

LAR 98-004 to Licenses NPF-87 & NPF-89,requesting Enforcement Discretion to Allow Units 1 & 2 to Perform Shutdown Surveillance Requirements 4.8.1.1.2f.4)a) & 4.8.1.1.2f.6)a) at Power

ML20217A384
Person / Time
Site:	Comanche Peak
Issue date:	03/18/1998
From:	Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217A387	List: ML20217A384 ML20217A390
References
TXX-98079, NUDOCS 9803250025
Download: ML20217A384 (7)

Text

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.5 Log # TXX-98079

. r C File # 916-(3/4.8) 7t/ ELECTRIC Ref. # ! R 50.90 10 CFR 50.36

c. ime. Thrry i s ,.ior we ,r m u ,.,

March 18, 1998 j

& Pri.cipalNancl,ar Officer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 l

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50 445 AND 50 446 SUBMITTAL OF LICENSE AMENDMENT REQUEST (LAR) 98 004 A.C. POWER, OPERATING REF: 1) TV Electric Letter, logged TXX 98078, from C. L. Terry to the NRC dated March 13, 1998

2) TU Electric Letter, logged TXX 98049, from C. L. Terry to the NRC dated February 20, 1998

3) TU Electric Letter, logged TXX-98066, from C. L. Terry to the NRC dated March 9, 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 Technical Specifications. This change is applicable to both CPSES Unit 1 and CPSES Unit 2.

On March 13, 1998, at about 1:00 pm central time. TV Electric participated in a conference call with the NRC staff to discuss the request for enforcement discretion submitted to the NRC in TU Electric letter TXX 98078 (reference 1). At the conclusion of the conference call the NRC exercised enforcement discretion to allow CPSES Units 1 and 2 to perform shutdown Surveillance Requirements 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) at power. Without the /

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requested enforcement discretion, compliance with CPSES Technical Specification 4.8.1.1.2f would have required both CPSES Units 1 and 2 to shutdown in order to demonstrate the OPERABILITY of the 480 volt motor

' control center ~(HCC) undervoltage load shed relay contacts. [

This LAR is being submitted as follow up to the-request for enforcement discretion (reference 1). The license amendment should be effective upon zissuance to be implemented immediately.

Attachment'l-is the required affidavit. 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 a c " ^ "'" ' "'^

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TXX 98079 Page 2 of 2 significant hazard. consideration. Attachment 3 provides the affected Technical Specification page, marked up to reflect the proposed changes.

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 CPSES Units 1 and 2.

Sincerely,

<db y C. L. Terry By: 0GGr $-

RogeY D. Walker Regulatory Affairs Manager BSD/bd Attachments:

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 78704

Attachment 1 to TXX 98079 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 Roger D. Walker, being duly sworn, hereby deposes and says that he is Regulatory Affairs Manager for TV Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 98 004: 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.

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Roge H . Walker Regulatory Affairs Manager STATE OF TEXAS )

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COUNTY OF N\oks )

Subscribed and sworn to before me, on this 13 day of O arch R M .

Notary Public j f l.. oONALD R. WOODLAN j Notory Put:ilic

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ATTACHMENT 2 to TXX-98079 DESCRIPTION AND ASSESSMENT

Attachment 2 to TXX 98079 Page 1 of 3 DESCRIPTION AND ASSESSMENT I. BACKGROUND During the process of conducting reviews in accordance with U.S. NRC Generic Letter 96 01, CPSES discovered that it had not positively verified that certain contacts from the undervoltage relays cause load shedding at the 480 volt MCCs. Therefore complete testing in accordance with Surveillance Requirements (SRs) 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) has not been performed. A parallel circuit path containing a contact from the Diesel Generator output breaker exists and could not be conclusively eliminated as causing the observed load shed during performance of previous integrated tests.

Surveillance Requirement 4.8.1.1.2f requires, in part. that certain A.C.

electrical sources be demonstrated OPERABLE by performing the Surveillance Requirement at least once per 18 months. "during shutdown." Failure to perform the Surveillance Requirement within the la month frequency plus allowances allowed per Surveillance Requirerent 4.0.2. would result in failure to perform a Surveillance Requireme'nt. In accordance with Surveillance Requirement 4.0.3, this failure to perform the Surveillance Requirement would constitute a noncompliance with the OPERABILITY requirements for the LCO. Also in accordance with Surveillance Requirement 4.0.3, the ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

With respect to SRs 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a). TU Electric requested and the NRC exercised discretion to not enforce the requirement to perform the surveillance "during shutdown". in order to demonstrate the OPERABILITY by verifying load shedding occurs due to a loss-of-offsite power. On a one time basis, crediting performance of SRs 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a), during POWER OPERATIONS as opposed to "during shutdown" is acceptable.

This change 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 provides a temporary Technical Specification change for SRs 4.8.1.1.2f 4)a) and 4.8.1.1.2f.6)a) to allow the verification that load shedding occurs as a result of the deenergization of the emergency busses to be performed at power for fuel cycle 6 on Unit 1 and fuel cycle 4 on Unit 2.

III. ANALYSIS The safety function of the undervoltage relays is to shed unnecessary equipment loads on the A.C. bus and allow an operating diesel generator to be connected to the A.C. bus and power emergency equipment. These relays are relied upon to ensure that the necessary equipment is shed from the bus at the appropriate time. Failure of the affected equipment to

Attachment 2 to TXX 98079 Page 2 of 3

' loads would place the operators in a situation where manual operator actions would be necessary to remove the unnecessary equipment from the A.C. bus.

TU Electric has reviewed the required testing and has determined that acceptable tests for demonstrating OPERABILITY of the undervoltage relay contacts can be performed during POWER OPERATIONS with no adverse effect to the A.C. electrical distribution system. TU Electric is aware that the preclusion from performing these surveillance tests at conditions other than shutdown is to avoid the potential for perturbations to the A.C.

electrical distribution system and thereby result in a challenge to safety systems. These tests demonstrate that the contacts from the undervoltage relays close upon actuation of the associated relay, thus completing the confirmation of the circuit by overlapping tests. Downstream actuation of the relays and breaker trips was confirmed during the normal integrated surveillance test. Note that the bus tie breaker for MCC XEB4 3 for Unit 2 was not tested during the last surveillance test and was the subject of previous enforcement discretion (Reference 2) and License Amendment Request (Reference 3). Performance of this testing does not create the potential for an abnormal perturbation to the A.C. electrical distribution system while the reactor is critical.

TV Electric believes that the crediting of these segments of the integrative tests are both acceptable and appropriate during POWER OPERATIONS. The potential consequences resulting from a coincident shutdown of both units of CPSES and the possible perturbations induced into the A.C. grid are clearly higher than those of crediting these testing segments during POWER OPERATIONS. A qualitative risk assessment based on the CPSES PRA concluded that performance of this testing will not have an adverse impact on risk for either CPSES Unit 1 or Unit 2.

Therefore, the possible consequences of conducting a dual unit shutdown in order to demonstrate the OPERABILITY of the undervoltage relays far exceeds the potential consequences of crediting the testing segments in order to satisfy the Surveillance Requirements.

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?

Crediting the at power performance of the portions of surveillance te sting necessary to demonstrate the OPERABILITY of the undervoltage i relays, will not increase the probability or consequences of an accident previously evaluated. The conclusion has been reached that l the probability of initiating an abnormal perturbation in the A.C.

electrical distribution system is not created via the crediting of the tests. As the testing was conducted on only one train per unit at a given time, no increase in consequences, other than those previously postulated, are considered credible.

Attachment 2 to TXX-98079 Page 3 of 3

'2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Perturbations in the A.C. electrical distribution system have been fully considered within the Final Safety Analysis Report. No new or different kind of perturbation or accident is deemed credible from crediting the performance of the testing.

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

Crediting the required testing at power does not create any new failure scenarios or abnormal A.C. electrical distribution perturbations. As such, there is no reduction in any 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.

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 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, (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.