ML20244D805
| ML20244D805 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/14/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20244D809 | List: |
| References | |
| TXX-89169, NUDOCS 8904240122 | |
| Download: ML20244D805 (11) | |
Text
.
4.
t c-C -.
Log # TXX-89169 1
C File # 10014 r
C 916 clo Ref. # 10CFR50.36 7UELECTRlC April 14, 1989 W. J. Cahm Executive s'ke i.siden i
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 TECHNICAL SPECIFICATION CERTIFICATION REF:
1)
Letter dated March 17, 1989, from C. I. Grimes to W. J. Cahill, Jr.
2)
Letter logged TXX-89117, dated April 12, 1989, from W. J. Cahill, Jr. to the NRC Gentlemen:
The above referenced letter (reference 1) transmitted to 1U Electric the Final Draf t Technical Specifications for CPSES Unit 1.
In addition, the referenced letter requested that TV Electric certify by April 14, 1969, that the Final Draft Technical Specifications accurately reflect the as-built plant and the Final Safety Analysis Peport.
The adequacy and accuracy of the CPSES Unit 1 Technical Specifications have been established through the attention, involvement, and interaction of the NRC and TV Electric over the past two years.
Furthermore, TV Electric has conducted an intensive Technical Specification Review Program to confirm the accuracy of the CPSES Unit 1 Technical Specifications.
This program which began in early 1987, involved licensing, operations and engineering participation in a comprehensive review to verify that the Final Draft Technical Specifications are correct and fully applicable to CPSES Unit 1.
During the Technical Specification preparation process, interpretations of specific requirements of certain Technical S)ecifications were provided to 10 Electric by members of the NRC staff.
Attac1 ment 1 describes some of these interpretations.
00$
I 1
8904240122 890414 PDR ADOCK 05000445 A
PDC 400 North Olive Street LB 81 Dallas, Texas 75201
4 TXX-89169 Page 2 of 2 April 14, 1989 Our Technical Specification Review Program has identified changes to the Final Draft Technical Specifications for CPSES Unit 1 that are required to adequately and accurately (as it will be upon completion of the design modifications in progress) reflect the CPSES Unit 1 as-built design.
These changes are generally of the following types:
- Changes resulting from Generic Letter 89-01,
- Changes resulting from the issuance of the final setpoint study, or
- Changes resulting from the revision of the PORV cold overpressure curve.
These Technical Specification changes are listed in Attachment 2.
In addition, editorial corrections were provided to the NRC by reference 2.
Currently, our review has not affirmed that the Technical Specifications for Plant Systems (Auxiliary Feedwater flow requirements / Condensate Storage Tank volume), Accident Monitoring Instrumentation and Area Temperature Monitoring adequately and accurately reflect the CPSES Unit 1 design.
Resolution of the above items may require changes to the Technical Specifications.
TV Electric will work closely with the NRC staff to reach mutual resolution of these and any other changes necessary to the Final Draf t Technical Specifications.
FSAR Amendment 76 is presently scheduled for issuance on May 1,1989.
The FSAR is being revised to provide the consistency needed to support the Technical Specifications.
As requested by your letter of March 17, 1989, this letter affirms and certifies that to the best of my knowledge with exceptions, corrections and interpretations noted above, the draft Technical Specifications transmitted by the referenced letter accurately reflects the as-built plant (as it will be upon completion of design modifications in progress) and the FSAR (as it will be after the changes scheduled to be provided in Amendment 76).
Should you require additional information or desire further discussions on the CPSES Unit 1 Technical Specifications, do not hesitate to contact me.
Sincerely,
/
William J. Cahill, Jr.
JDS/vid Attachments c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l
- 9-
. STATE OF. TEXAS' )-
SS COUNTY-OF DALLAS i-I, W. J. Cahill, Jr. being dely sworn, subscribe to and say that I am the Executive Vice President Nuclear Engineering and Operations of TV Electric o
Company; that I have full authority to execute this oath; that I have read the foregoing Technical Specifications Certification Letter and know the contents thereof; and that to the best of my knowledge, information, and belief the statements made in it are true.
f f
i
/
i W.
abi lT, ~ Jr.ug i
SUBSCRIBED AND SWORN to before me, a Notary publip, in and for the County and State above named, this
/4/W1
' day of.#t1t2E
, 1989.
)
h Notary Public i
-_- - - to TXX-89169 April 14, 1989 Page 1 of 1 INTERPRETATIONS TO CPSES UNIT 1 TECHNICAL SPECIFICATIONS Interpretation 1:
Condition - When taking exception to 4.0.4 for entry into an Applicable Mode.
Interpretation - The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period allowed to complete the surveillance (for which exception to 4.0.4 is taken) begins at that point in time when the prerequisite conditions required to perfonn the surveillance have been attained (eg. system temperature > 3000 F, system pressure 2 2235 psig, Power 2 75's RTP, Stable Xenon).
Interpretation 2:
Cort tion - The discussion of shutdown ACTION requirements in the Bases for Specification 3.0.3 states:
"It is not intended to be used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service..."
Interpretation - This allows the use of the allowed out-of-service time within the ACTION statement for routine maintenance and surveillance activities but does not allow the use of the shutdown portion of the ACTION statement for these same activities. An example is that the Train A Auxiliary Feedwater Pump is declared inoperable to perform the monthly surveillance per Specification 4.7.1.2a.1),
ACTION statement a. of Specification 3.7.1.2 allows the pump to be inoperable for "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />...".
Therefore, this monthly surveillance could take up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to complete, but could nct use the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> which is
)
allowed for plant shutdown to Hot Standby.
Although it would be an extreme sit ation that would use the entire allowed out-of-service time to complete the surveillance requirement, it is allowed.
Surveillance or maintenance activities that put the plant into an ACTION statement, such as this one, are expeditiously performed to minimize out-of-service time.
Interpretation 3:
1 Condition - Specifications 3/4.7.7 and 3/4.7.8 provida for a surveillance on the filtration Units "following paintina, fire or chemical release in any ventilation zone communicating with the system."
Interpretation - This surveillance is interpreted to mean: following significant painting, fire, or chemical release in any ventilation zone communicating with the system.
I l
1
l to TXX-89169 April 14, 1989
.Page 1 of 81 l
l TECilNICAL SPECIFICATIONS Correction Descriptions Page Description ii, 1-6 Relocates definition of " SOLIDIFICATION" to the PCP per Generic Letter 89-01.
Definition of " SOURCE CHECK" is no longer used in the Technical Specifications, therefore the definition is not required.
Corrects definition of " SITE B0UNDARY" to agree with the Offsite Dose Calculation Manual".
1-2 Adds appropriate reference to Technical Requirements Manual. This change is consistent with Specification 4.6.1.la.
1-4 Corrects referenced section of the Tecl1ical Specifications.
1-5 Revises PCP definition to exact wording in Generic Letter 89-01, 1-7 Revises the definition of " UNRESTRICTED AREA" to be consistent with the original Standard Technical Specifications as was agreed to with the NRC staff for implementing Generic Letter 89-01.
1-8 Deletes frequency Notation "P" and the corresponding
" Frequency", since the notation is no longer used in the Technical Specifications after the implementation of Generic Letter 89-01.
i 2-2 Corrects the scale provided on Figure 2.1-1, " Reactor Core l
Safety Limit". Revised " Print Ready" to be supplied to the NRC staff by TV Electric.
2-4, 2-5 Revises Table 2.2-1, overpower N-16, pressurizer pressure 2-7, 2-8
- low, pressurizer pressure - high, steam generator water level - Low-Low, Turbine Trip low system pressure, and Table Notations.
These changes are due to a revised statistical setpoint study.
B 2-2 Corrects RCS Hydrotest of 125% of design to 3107 psig.
3/4 0-5 Corrects specification reference.
3/4 0-6 Removes footnote that provides directions for Technical Specification preparation.
SSER #4, Section H documents that 40% is more conservative than Regulatory Guide 1.121.
3/4 1-10 Clarifies " APPLICABILITY" to properly reference footnote.
' to TXX-89169 April 14, 1989 l
Page 2 of 81 3/4 3-11 Adds a 4.0.4 exception to notation 9 of Table 4.3-1.
This change was previously discussed with the NRC during noticed meeting.
This exception is required because CPSES's plant specific design does not allow testing while above P-6.
As reactor power is increased above P-6 the high voltage to the source range detectors is automatically removed and the flux doubling bistable is reset and held in the reset condition.
Therefore, with the flux doubling bistable held in reset an ACOT cannot be performed during power operations (without the use of jumpers) because a reactor trip would immediately put the operator in an ACTION statement.
The operability of the Source Range Nuclear Instrumentation is required in MODES l
2 (below P-6), 3, 4 and 5 by Table 3.3-1, item #6.
Table 4.3-1 requires a quarterly Analog Channel Operational Test (in addition to 18 month surveillance) which includes checks of the Boron Dilution Alarm.
During normal MODE 1 Power Operation there are no operability requirements; therefore, pursuant to Specification 4.0.3 surveillance is not required and the instrument can be considered l
technically inoperable when the surveillance intervals of Specification 4.0.2 are exceeded.
Subsequently, for a normal plant shutdown, the lapsed surveillance would be performed prior to power decrease below P-6 pursuant to Specification 4.0.4 and the Source Range instruments declared OPERABLE.
In the event of a Reactor Trip, however, the MODE changes from MODE 1 to 3 are not under the control of the operator but occur automatically.
Thus, an OPERATIONAL MODE could be entered without the Limiting Condition for Operation being met - a possible. violation of Specification 3.0.4.
Specification 3.0.4 implies that its purpose applies only when going to higher MODES; however, this is not explicitly stated in 3.0.4 itself.
Furthermore, 3.0.4 would not apply if a shutdown is required to comply with an ACTION requirement.
Adding an exception to 4.0.4 will correct the requirement.
This change is necessary to support normal plant operation.
3/4 3-19 Adds "AFW" in Table 3.3-2, Functional Unit 6e, to the description of " pump" in the columns to clarify that there are a total of 2 cctuation channels per AFW Pump, that 2 of 2 channels are r.: quired for actuation of the AFW Pump, and that the minimum channels operable is one channel per AFW Pump, provided the Inoperable Channel is placed in the tripped condition.
The ACTION required was appropriately
{
modified.
i
)
l
- _ _ _ _ _ - _ _ _. :to TXX.o9169
' April: 14,1989 c
Page 3 of 81
.a 1
l '
3/4 3-20,21,29,36 Deletes functional Unit 9b from Table 3.3-2, 3.3-3 and.
l 4.3-2.
The oniy logic and relay functions associated with i
the Control Room Emergency Recirc Actuation this applies j
to is the Safety injection Actuation which is covered by-l' Functional Unit 9c.
High air intake radiation, which initiates control room emergency recirculation, is covered by Specification 3.3.3.1.
3/4 3-19,22 Adds Notation g: The actuation signal should not be required if the Auxiliary Feedwater Pum) is~ inoperable.
The allowed out-of-service time should ye the same as Specification 3.7.1.2.
3/4 3-25, 26, Changes Table 3.3-3 to include new values provided by the 27, 28, 29 revised statistical setpoint study.
Changes the maximum allowable value for Functional Unit 8.a and 8.b from 5933 volts to 5900 volts. Analysis shows that the Bus Voltage could drop to as low as 5909 volts during the worst case motor start with the lowest allowable grid voltage.
3/4 3-39, 40 Adds to Table 3.3-4 a "<" sign, which must have been inadvertently deleted ~between Standard Technical Specifications, Rev 4 and Rev. 4a.
This setpoint is not a nominal setpoint. Corrects Table Notations to reflect changes resulting from Generic Letter 89-01.
3/4 3-46,49, Corrects Specification 3.3.3.4, Explosive Gas Monitoring 50 Instrumentation, reference to the Table from 3.3-8 to 3.3-7, makes several minor editorial changes, and combines the surveillance requirements previously_ contained in Table 4.3-3 with the introductory statement of Specification 4.3.3.4 for simplification.
The latter change also allows for the incorporation of the old " Table Notations" into the basic. surveillance requirements.
3/4 4-29, Changes Figure 3.4-4 to agree with revisions provided by B 3/4 4-14 Westinghouse. Revised " print ready" to be supplied to the NRC staff by 10 Electric.
Corrects the EFPY for CPSES Appendix G limits.
3/4 4-32 Modifies Specification 3.4.10, Reactor Coolant System Vents, ACTION statements to clearly refiect that required shutdown to HOT STANDBY is to occur within the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period immediately following the allowed outage times.
These changes make the language consistent with other ACTION statements which require a shutdown (e.g., 3.5.1, ACTION a., b. or c.).
j'
-Attachment 2 to TXX-89169 L."
-4 D
April 14, 1989 Page 4 of 81 L
-3/4-5-4 Corrects typographical on Specification 3/4.5.2.
Value t
for automatic isolation and interlock action of the RHR l
system is "442" as provided' in the January 24, 1988 submittal logged TXX-89035.
3/4 5-8 Corrects Specification 3/4 5-3 reference to-a
. specification.
"8.4.8.3" should be "3.4.8'.3" 3/4 6 3 Modifies Specification 4.6.1.2. Surveillance required to 9
not prohibit air testing in accordance with Appendix J as an acceptable alternative to' testing with water.
3/4 6-11 Modifies Specification 4.6.2.lc. 2) surveillance requirement to ensure that both test signals are.verfied.
3/4 7-3,4 Changes Specification 4.7.1.2a.1) " discharge" to
" differential" to eliminate any possible confusion on what is to be measured.
This also makes the surveillance objective agree with the acceptance criteria.
' Changes Specification 4.7.1.2a.4) with the insertion of the words " auxiliary feedwater' flow control and isolation" in lieu of " automatic" for valves in the auxiliary feedwater flow path.
This is required to be consistent with the CPSES design since the abject valves are not automatic.s 3/4 7-14 Modifies Specification 3.7.4 and 4.7.4 surveillance requirements by deleting 4.7.4b.1), since the CPSES design is being modified and will no longer'have any " automatic valves supplying safety-related equipment" which actuate on a Safety injection signal.
3/4 7-18, 21 Corrects Specifications 3/4.7.7 and 3/4.7.8 to reflect B 3/4 7-5 results of February 28, 1989 meeting.
3/4 7-24 Deletes " Motor-Driven" from Table 3.7-3 to indicate that area temperature monitoring normal limit of 1220F applies to all auxiliary feedwater pump rooms.
3/4 8-7 Corrects Specification 3/4.8.1 diesel generator loading to "6900 - 7700kW" as provided in letter logged TXX-89035, dated January 24, 1989.
3/4 8-9 Modifies Table 4.8-1, " Diesel Generator Test Schedule",
surveillance test requirements to match the surveillance test philosophy guidance provided by the staff during technical meetings with TUE.
U to TXX-89169 April 14, 1989
'Page 5 of 81 1
3/4 8-12 Changes Specification 3/4.8.2 continuous output rating of 1
the Class 1E Battery Chargers at CPSES from 300 amperes to 225 amperes.
The vendor has performed testing to demonstrate that 225 amperes is the correct rating.
3/4 8-14 Corrects typographical error on Specification 3/4.8.2.
Adds words "at least" which were inadvertently dropped.
Standard Technical Specifications includes these words.
1 3/4 8-15, 16 Corrects bus loading for Specification 3/4.8.3.
This
{
correction reflects the results of a design modification.
Adds the words " inverter connected to its associated" which were inadvertently dropped.
Corrects text to Standard Technical Specification wording.
3/4 8-19 Corrects typographical error on Specification 3/4.8.4.
Adds words "with tolerances" which were inadvertently deleted between Rev. 4 and Rev. 4a of the Standard Technical Specifications.
3/4 10-5 Modifies Specification 3.10.5, Special Test Exception Position Indication System - Shutdown as follows:
The LC0 and APPLICABILITY for this special test exception has been modified to make it clear that the exception can be used for Rod Drop Time measurement testing AND for OPERABILITY testing (CHANNEL CALIBRATION) of the digital rod position indi:ation system.
This change is "equired in order to eliminate legal ambiguity for compliance after initial fuel loading or refueling, especially if Cold Rod Drop Time measurements are not performed.
Remove the word " initial" since conditions (1) and (2) assure that calibration of the Digital Rod Position Indication System is not a safety concern.
3/4 11-3 Corrects Specification 3/4.11.2 referenced specification from "6.9.1.7" to "6.9.1.4".
Corrects surveillance from "92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br />" to "92 days" as agreed to with the NRC staff.
B 3/4 1-3 Provides basis for gravity feed from the Boric Acid Storage tanks.
B 3/4 2-6 Corrects title of report. Correct title is " Improved Thermal Design Procedure Report for CPSES".
B 3/4 4-8 Corrects typographical errors on Table B 3/4.4-1.
l l
'. to TXX-89169 April 14,1989 Page 6 of 81-B 3/4 5-1 Revises Bases 3/4.5.1 to provide the equivalent gallons for accumulator volumes in percent.
B 3/4 6-1 Clarifies Bases 3/4.6.1.2 in that the water test is an acceptable alternate to air testing to meet 10CFR50 Appendix J.
Corrects valves that are in parallel to reflect a conbined leakage limit. Also, corrects maximum allowed leakage limits for 4 valves.
B 3/4 6-2 Revises Bases 3/4.6.1.4 to provide the analytical bases for the indicated values.
B 3/4 6-3 Clarifies Bases 3/4.6.3.
Technical Specification 3/4.6.3 of Standard Technical Specifications is written for GDC-55 and 56 penetrations (which have two containment isolation valves in series) as opposed to GDC-57 penetrations (which have a single remote manual valve).
-Technical Specification 3/4.6.3 cannot be applied, as written, to GDC-57 valves since the ACTION cannot be satisfied with only one valve.
B 3/4 7-5 Changes referenced ANSI standards to agree with Specifications 3/4.7.7 and 3/4.7.8.
B 3/4 11-1 Changes Bases 3/4.11.2.2 to be consistent with other changes made under the guidance of Generic Letter 89-01.
5-4 Revises Figure 5.1.3 to be consistent with that as accepted in the Offsite Dose Calculation Manual.
6-2 Adds to Specification 6.2.2c an asterisk to the Radiation Protection Technician to make it clear that the footnote applies to that position.
6-4 Changes Specification 6.2.3, Independent Safety Engineering Group, reporting relationship for ISEG from the Vice President, Nuclear Operations to the Director l
Technical Interface to reflect current organization.
6-7 Procedure development and review is defined by l
Specification 6.5.3.
It is noted that burdening SORC members with administrative duties reduces the time and attention they can devote to plant operational concerns and the assurance of plant safety.
l 6-12 Revises Specification 6.5.3.lc, Technical Reviews / Design, with the deletion of the exact title and the insertion of a functional title for the V.P. designating individuals who can perform independent reviews of design related activities.
This better accommodates the current organization.
1
' Attachment 2 to TXX-89169 April 14, 1989 J
Page 7 of 81 6-14 Corrects Specification 6.8.1 by providing the correct title of the document containing relocated specifications.
3 The correct title is " Technical Requirements Manual".
I 6-23, 24 Modifies Specification 6.13, 6.14 and 6.15 to meet the implementation of Generic Letter 89-01 for moving the Radiological Effluent Technical Specifications from the Technical Specifications to the Offsite Dose Calculation Manual.
I 1
i i
____--~.-_---______--_a