ML20248L316
| ML20248L316 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/12/1998 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20248L317 | List: |
| References | |
| TXX-98076, NUDOCS 9803190311 | |
| Download: ML20248L316 (7) | |
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=. = Log # TXX-98076 r C File # 916 (3/4.8)
TUELECTRIC Ref.#NhR50.90 10 CFR 50.36 c.I m ce wrry senior we,rentsen, March 12, 1998
& PrincipalNuclear Officer 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 SUBMITTAL OF LICENSE AMENDHENT REQUEST 98-003 A.C. POWER, OPERATING REF: 1) TU Electric Letter, logged TXX 98074, from C. L. Terry to the NRC dated March 10. 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 11. 1998, at about 8:00 am central time TU Electric participated in a conference call with the NRC staff to discuss the request for enforcement discretion submitted to the NRC in TV Electric letter TXX 98074 (reference 1). At the conclusion of the conference call the NRC exercised enforcement discretion to allow CPSES Units 1 and 2 to perform portions of shutdown Surveillance Requirements 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) at power. Without the 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 Safety Injection (SI) and Blackout (BO) Sequencer block contacts. This LAR is being submitted as follow up to the request for enforcement discretion (reference 1). The license amendment should be effective upon issuance to be implemented immediately. Attachment 1 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 significant hazard consideration. Attachment 3 provides the affected Technical Specification page, marked up to reflect the proposed changes. , 9803190311 980312 ~ PDR ADOCK 05000445 I / P PDR
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COMANCHE PEAK STEAM El ECTRIC STATION lllh!i! P.O. Box 1002 Glen Rose, Texas 76043-1002
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TXX 98076 Page 2 of 2 In accordance with 10CFR50.91(b). TV Electric is providing the State of Texas I with a copy of this proposed amendment. Should you have any questions, please contact Mr. Bob Dacko at ! l (254) 897 0122. ' i This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2. Sincerely,
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Co f C. L. Terry By: @ b. Roger 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 3
Resident Inspectors, CPSES I Mr. Arthur C. Tate Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78704 i i i 1 l j
Attachment 1 to TXX-98076 Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j I 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 TU Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 98 003: 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.
09 ret b. ' RogeM). Walker Regulatory Affairs Manager l STATE OF TEXAS ) , COUNTY OF l-{ ood) Subscribed and sworn to before me, on this $ day of orCb
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4 f 1 ATTACHMENT 2 to TXX 98076 DESCRIPTION AND ASSESSHENT f i i
Attachment 2 to TXX-98076 Page 1 of 3 DESCRIPTION AND ASSESSMENT l I. BACKGROUND During the process of conducting reviews in accordance with U.S. NRC l Generic Letter 96-01. CPSES discovered that some of the Safety Injection (SI) and Blackout (BO) Sequencer block contacts had not been tested in accordance with Surveillance Requirements 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b). These surveillance were performed during the last refueling outage for each unit as part of the integrative tests. However, it was subsequently discovered that some of the sequencer loads had parallel starting paths such that it could not be determined, based only on the observation that the equipment had successfully started, that the specific contacts required to be tested had in fact operated. In addition, verification of testing of certain contacts was missing. Specifically, verification of testing of the sequencer load group contacts (B0S or SIS) to the following equipment is missing or cannot be , distinguished from other possible circuit actuations: BOS Contacts-Safety Chill Water (SCW) Pump U1 both trains, U2 both trains Safety Chiller U1 both trains, U2 both trains l Control Room Air Conditioner (CRAC) unit U1 both trains Battery. Exhaust Fans 7, 8, 9. 10 V1 both trains Battery Exhaust Fans 10, 11 U1 both trains Instument air compressors U2 both trains I SIS Contacts: Safety Chill Water Pump U1 both trains, U2 both trains Safety Chiller U1 both trains, U2 both trains Control Room Air Conditioner (CRAC) unit U1 both trains Emergency fill Fire Pump U1 train A i 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 18 month frequency plus l allowances allowed per Surveillance Requirement 4.0.2, would result in failure to perform a Surveillance Requirement. In accordance with l Surveillance Requirement 4.0.3, this failure to perform the Surveillance l Requirement would constitute a noncompliance with the OPERABILITY I requirements for the LCO. Also in accordance with Surveillance Requirement 4.0.3. the ACTION requirements may be delayed for up to 24 hours to permit completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours. With respect to Surveillance Requirements 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b). TU Electric requested and the NRC granted enforcement discretion to not enforce compliance with the requirement to perform the surveillance "during shutdown". in order to demonstrate the OPERABILITY of the SI and B0 Sequencer block contacts. On a one time basis, crediting I performance of those portions of Surveillance Requirements 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b), during POWER OPERATIONS as opposed to "during shutdown" is acceptable.
Attachment 2 to TXX 98076 Page 2 of 3 l 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 i 4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) to allow the verification of the auto connected shut down loads through the load sequencer 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 SI and B0 Sequencer block contacts is to sequence necessary equipment loads onto an operating diesel generator connected to the A.C. bus. These contacts are relied upon to ensure that the necessary equipment is loaded onto the bus at the appropriate time. Failure of the affected equipment to properly load would place the operators in a situation where manual operatcr actions would be necessary to restore all attendant equipment to the A.C. bus. TU Electric has reviewed the required testing and has determined that acce) table tests for demonstrating OPERABILITY of the SI and B0 Sequencer blocc contacts, can be parformed during POWER OPERATIONS with no adverse effect to the A.C. electrical distribution system. TU Electric is aware i 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. The tests to demonstrate the SI and B0 Sequencer block contacts, are small segments of the integrative tests. These segments demonstrate that the contacts close and that the equipment properly loads as necessary. Performance of this testing will not create the potential i for any 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 l order to demonstrate the OPERABILITY of the SI and B0 Sequer,cer block contacts 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: L__. _ _
1 Attachment 2 to TXX 98076 I Page 3 of 3 1 Do the proposed changes involve a significant increase in the probability l or consequences of an accident previously evaluated? ! Crediting the at power performance of the portions of surveillance testing necessary to demonstrate the OPERABILITY of the SI and B0 Sequencer block contacts, will not increase the probability or consequences of an accident previously evaluated. The conclusion has been reached that the probability of initiating a perturbation in the A.C. electrical distribution system is not created via the crediting of the tests. As the testing is conducted on only one i train per unit at a given time, no increase in consequences, other than those previously postulated, are considered credible.
- 1. Do the proposed changes create the possibility of a new or different j kind of accident from any accident previously evaluated? 1 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 i crediting the performance of the testing.
- 2. 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 A.C. electrical distribution perturbations, no associated margin is expected to be reduced. 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. 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 (lii) 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. L-__________-__- - _ _}}