CP-202400335, License Amendment Request to Adopt TSTF-51, TSTF-471, and TSTF-571-T to Eliminate Use of the Term Core Alterations and Revise Requirements During Handling of Irradiated Fuel

License Amendment Request to Adopt TSTF-51, TSTF-471, and TSTF-571-T to Eliminate Use of the Term Core Alterations and Revise Requirements During Handling of Irradiated Fuel

ML24256A088
Person / Time
Site:	Comanche Peak
Issue date:	09/12/2024
From:	Sewell S Vistra Operations Company
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
CP-202400335, TXX-24065
Download: ML24256A088 (1)

Text

6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214-812-4600 VISTRACORP.COM Comanche Peak Nuclear Power Plant Steven Sewell Site Vice President P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 CP-202400335 TXX-24065 September 12, 2024 ATTN: Document Control Desk Ref 10 CFR 50.90 U. S. Nuclear Regulatory Commission 10 CFR 50.91 Washington, DC 20555-0001 Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445, 50-446 and 72-74

Subject:

License Amendment Request to Adopt TSTF-51, TSTF-471, and TSTF-571-T to Eliminate Use of the Term Core Alterations and Revise Requirements During Handling of Irradiated Fuel.

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Vistra Operations Company LLC (Vistra OpCo) is submitting a request for an amendment to the Technical Specifications (TS) for Comanche Peak Nuclear Power Plant Units 1 and 2 (CPNPP).

The proposed amendment would modify the CPNPP TS to eliminate use of the defined term core alterations and revise requirements during handling of irradiated fuel by adopting TSTF-51, TSTF-471, and TSTF-571-T.

The enclosure to this letter contains an evaluation of the proposed change. Attachment 1 of the enclosure includes a markup of the Proposed Technical Specification Changes. Attachment 2 of the enclosure includes a markup of the Technical Specifications Bases for information only.

Vistra OpCo concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified. The CPNPP Station Operations Review Committee (SORC) has reviewed the proposed license amendment.

Vistra OpCo requests approval of the proposed license amendment within one year of completion of the NRC's acceptance review. The amendment will be implemented within 180 days after approval.

There are no new regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Texas Official.

Should you have any questions, please contact Nic Boehmisch at (254) 897-5064 or nicholas.boehmisch@luminant.com.

TXX-24065 Page 2 of 2 I state under penalty of perjury that the foregoing is true and correct.

Executed on September 12, 2024.

Enclosure:

Evaluation of the Proposed Change cc:

John Monninger, Region IV Uohn.Monninger@mc.gov]

Samson Lee, NRR [Samson.Lee@mc.gov]

John Ellegood, Senior Resident Inspector, CPNPP Uohn.Ellegood@mc.gov]

Hemy Strittmatter, Resident Inspector, CPNPP [Hemy.Strittmatter@mc.gov]

Sincerely, Steven Sewell (Sep 12, 2024 04:02 CDT)

Steven Sewell

Enclosure to TXX-24065 Page 1 of 16 Evaluation of the Proposed Change 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for Proposed Change 2.4 Description of Proposed Change

3.0 TECHNICAL EVALUATION

3.1 Current Licensing Basis and Accident Analysis 3.2 Acceptability of the Proposed Change 3.3 Variations from TSTF-51, TSTF-471, TSTF-571, and STS

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

S

6.0 REFERENCES

ATTACHMENTS Proposed Technical Specification Changes Proposed Technical Specification Bases Changes (information only)

Enclosure to TXX-24065 Page 2 of 16 1.0

SUMMARY

DESCRIPTION Vistra Operations Company LLC (Vistra OpCo) requests partial adoption of TSTF-51, "Revise containment requirements during handling irradiated fuel and core alterations,"

and adoption of TSTF-471, Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes, which are approved changes to the Standard Technical Specifications (STS), and adoption of TSTF-571-T Revise Actions for Inoperable Source Range Neutron Flux Monitor, into the Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2 Technical Specifications (TS). TSTF-51 removes the TS requirements for certain systems to be OPERABLE after sufficient radioactive decay has occurred following a plant shutdown. Following sufficient radioactive decay, these systems are no longer required during a fuel handling accident (FHA) to ensure main control room personnel dose and offsite doses remain below applicable limits. TSTF-471 and TSTF-51 remove the defined term CORE ALTERATIONS from TS and revise certain TS actions that are not needed to mitigate accidents postulated during shutdown. TSTF-571-T Revises the actions for an inoperable source range neutron flux monitor.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation Containment The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100. Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment. The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access. During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary.

The requirements for containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted from escaping to the environment. The closure restrictions are sufficient to restrict fission product radioactivity release from containment due to a fuel handling accident during refueling.

Containment ventilation isolation instrumentation closes the containment isolation valves in the Containment Purge, Hydrogen Purge, and Containment Pressure Relief Systems. This action isolates the containment atmosphere from the environment to minimize releases of radioactivity in the event of an accident. There is no credit taken for containment isolation for a fuel handling accident.

Enclosure to TXX-24065 Page 3 of 16 Boron Concentration The limit on the boron concentrations of filled portions of the Reactor Coolant System (RCS), the refueling canal, and the refueling cavity that have direct access to the reactor vessel during refueling ensures that the reactor remains subcritical during MODE 6. Refueling boron concentration is the soluble boron concentration in the coolant in each of these volumes having direct access to the reactor core during refueling.

The limiting boron dilution accident analyzed occurs in MODE 5. Boron dilution accidents are precluded in MODE 6 by isolating potential dilution flow paths per LCO 3.9.2, Unborated Water Source Isolation Valves.

Nuclear Instrumentation The source range neutron flux monitors are used during refueling operations to monitor the core reactivity condition. These detectors are located external to the reactor vessel and detect neutrons leaking from the core. The installed BF3 source range neutron flux monitors are part of the Nuclear Instrumentation System (NIS) operating in the proportional region of the gas filled detector characteristic curve. The detectors provide continuous visual indication in the control room.

A separate Neutron Flux Monitoring System (NFMS) is installed to satisfy the requirements of Regulatory Guide 1.97, Instrumentation for Light-Watered-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident. The NFMS utilizes fission chamber neutron detectors for all ranges of neutron flux indication.

Control Room Emergency Filtration/Pressurization System (CREFS) and Control Room Air Conditioning System (CRACS)

The CREFS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CREFS consists of two independent, redundant trains that pressurize, recirculate and filter the air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air. The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room and may encompass other non-critical areas. Each CREFS train contains two filtration units.

The CREFS is an emergency system wholly contained within the CRACS, parts of which operate during normal unit operations. Upon receipt of the actuating signal(s),

normal air supply fans to the CRE are isolated, and the stream of ventilation air is provided by the emergency pressurization units and then recirculated through the emergency filtration units. The CREFS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding dose limits.

Enclosure to TXX-24065 Page 4 of 16 The control room is common to both units and the CRACS is a shared system common to both units. The CRACS provides temperature control for the control room during normal and emergency operation. The CRACS consists of two redundant trains that provide cooling and heating of recirculated control room air. CRACS is an emergency system, parts of which may also operate during normal unit operations. The design basis of the CRACS is to maintain the control room temperature for 30 days of continuous occupancy.

AC Sources, DC Sources, Inverters, and Distribution Systems The unit Class 1E AC electrical power distribution system AC sources consist of the offsite power sources (preferred power source, and alternate), and the onsite standby emergency power sources (Train A and Train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17, the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

The 125 VDC electrical power system consists of two independent and redundant safety related Class 1E DC electrical power subsystems (Train A and Train B). Each subsystem consists of two 125 VDC batteries, the associated battery chargers for each battery, and all the associated control equipment and interconnecting cabling.

The station DC electrical power system provides control power to selected equipment. It also provides both motive and control power to selected safety related equipment and preferred AC vital bus power (via inverters).

The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses. The inverters are powered from the 125 V DC system. The station battery provides an uninterruptible power source for the instrumentation and controls for the Reactor Protective System (RPS) and the Engineered Safety Feature Actuation System (ESFAS).

2.2 Current Technical Specification Requirements CORE ALTERATIONS is a defined term in the CPNPP TS. CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

TS 3.3.6 Containment Ventilation Isolation Instrumentation currently includes the Applicability, in part, During CORE ALTERATIONS, and the applicable actions require placing and maintaining containment ventilation valves in a closed position OR entering applicable Conditions and Required Actions of LCO 3.9.4. for the inoperable isolation valve.

TS 3.3.7 Control Room Emergency Filtration System (CREFS) Actuation Instrumentation Required Action D.1 requires the immediate suspension of CORE

Enclosure to TXX-24065 Page 5 of 16 ALTERATIONS when Required Action and associated Completion Time for Condition A or B not met in MODE 5 or 6 or during movement of irradiated fuel assemblies.

TS 3.7.10 Control Room Emergency Filtration/Pressurization System (CREFS)

Required Action D.1 requires the immediate suspension of CORE ALTERATIONS when Required Action and associated Completion Time of Condition A are not met in MODE 5 or 6 or during movement of irradiated fuel assemblies. Required Action E.1 requires the immediate suspension of CORE ALTERATIONS when two CREFS trains are inoperable OR one or more CREFS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of irradiated fuel assemblies.

3.7.11 Control Room Air Conditioning System (CRACS) Required Action C.1 requires the immediate suspension of CORE ALTERATIONS when Required Action and associated Completion Time for Condition A not met in MODE 5 or 6 or during movement of irradiated fuel assemblies. Required Action D.2.1 requires the immediate suspension of CORE ALTERATIONS when two CRACS trains are inoperable in MODE 5 or 6 or during movement of irradiated fuel assemblies.

3.8.2 AC Sources - Shutdown Required Action A.2.1 requires the immediate suspension of CORE ALTERATIONS when one required offsite circuit inoperable.

Required Action B.1 requires the immediate suspension of CORE ALTERATIONS when one required DG inoperable.

3.8.5 DC Sources - Shutdown Required Action A.2.1 requires the immediate suspension of CORE ALTERATIONS when required DC electrical power subsystems inoperable.

3.8.3 Inverters Shutdown Required Action A.2.1 requires the immediate suspension of CORE ALTERATIONS when one or more required inverters inoperable.

3.8.10 Distribution Systems - Shutdown Required Action A.2.1 requires the immediate suspension of CORE ALTERATIONS when one or more required AC, DC, or AC vital bus electrical power distribution subsystems inoperable.

TS 3.9.1 Boron Concentration Required Action A.1 requires the immediate suspension of CORE ALTERATIONS when boron concentrations limits are not met.

TS 3.9.2 Unborated Water Source Isolation Valves Required Action A.1 requires the immediate suspension of CORE ALTERATIONS when one or more valves are not secured in closed position. Required Action A.2 requires the immediate suspension of positive reactivity addition when one or more values are not secured in closed position.

TS 3.9.3 Nuclear Instrumentation Required Action A.1 requires the immediate suspension of CORE ALTERATIONS when one required source range neutron flux monitor is inoperable.

TS 3.9.4 Containment Penetrations currently includes the Applicability, in part, During CORE ALTERATIONS, and During movement of irradiated fuel assemblies within containment, and the applicable actions require immediate suspension of CORE

Enclosure to TXX-24065 Page 6 of 16 ALTERATIONS, and the immediate suspension of movement of irradiated fuel assemblies within containment when one or more containment penetrations not in required status.

2.3 Reason for Proposed Change After sufficient radioactive decay of irradiated fuel following a reactor shutdown, the proposed adoption of TSTF-51 (Reference 1) will allow CPNPP the flexibility to move personnel and equipment and perform work, which would affect containment operability during the handling of irradiated fuel.

Suspending CORE ALTERATIONS has no effect on the initial conditions or mitigation of any Design Basis Accident (DBA) or transient and no corresponding safety benefit, the proposed adoption of TSTF-471 (Reference 2) will remove these requirements and the associated operational burdens.

The proposed amendment would also align the CPNPP TSs more closely, as technically practicable, with the STS described in NUREG-1431 (Reference 4).

2.4 Description of Proposed Change The TS 1.1 Definition for CORE ALTERATIONS will be deleted.

The Applicability for TS 3.3.6, represented in Table 3.3.6-1 will delete note (b) During CORE ALTERATIONS. Note (c) will be renumbered to (b), and the word recently will be added before the word irradiated. The note for Condition C will delete the words CORE ALTERATIONS or, and will insert the word recently before the word irradiated.

Required Action D.1 of TS 3.3.7 will be deleted, and subsequent Required Actions will be renumbered.

Required Action D.2.1 and E.1 of TS 3.7.10 will be deleted, and subsequent Required Actions will be renumbered.

Required Action C.2.1 and D.2.1 of TS 3.7.11 will be deleted, and subsequent Required Actions will be renumbered.

Required Action A.2.1 and B.1 of TS 3.8.2 will be deleted, and subsequent Required Actions will be renumbered.

Required Action A.2.1 of TS 3.8.5 will be deleted, and subsequent Required Actions will be renumbered.

Required Action A.2.1 of TS 3.8.8 will be deleted, and subsequent Required Actions will be renumbered.

Required Action A.2.1 of TS 3.8.10 will be deleted, and subsequent Required Actions will be renumbered.

Enclosure to TXX-24065 Page 7 of 16 Required Action A.1 of TS 3.9.1 will be deleted, and subsequent Required Actions will be renumbered.

Required Action A.1 and A.2 of TS 3.9.2 will be deleted, and subsequent Required Actions and NOTE references will be renumbered.

Required Action A.1 of TS 3.9.3 will replace the term CORE ALTERATIONS with Positive Reactivity Additions. Required Action A.2 will incorporate the changes from TSTF-571-T (Reference 3) which consists of replacing the current Required Action A.2 with a note Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range neutron flux monitor or to complete movement of a component to a safe condition, and action to immediately suspend movement of fuel, sources, and reactivity control components within the reactor vessel.

The Applicability of TS 3.9.4 will delete During CORE ALTERATIONS, and insert the word recently before irradiated. Required Action A.1 will be deleted, and subsequent Required Actions will be renumbered. Required Action A.2 will insert the word recently before irradiated.

A markup of the proposed TS page changes, and a clean copy of the proposed TS pages are provided in Attachment 1.

3.0 TECHNICAL EVALUATION

3.1 Current Licensing Basis and Accident Analysis Fuel Handling Accident As described in the CPNPP FSAR, the fuel handling accident is defined as dropping of a spent fuel assembly in the containment building or spent fuel pool fuel storage area floor resulting in the rupture of the cladding of all the fuel rods in the assembly despite many administrative controls and physical limitations imposed on fuel handling operations. The method of analysis used for evaluating the potential radiological consequences of a fuel handling accident is consistent with applicable regulatory guidance in Regulatory Guide 1.195.

The accident is assumed to occur 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> after plant shutdown. The damaged assembly is the highest-powered assembly in the core region to be discharged. The values for individual fission product inventories in the damaged assembly are calculated assuming full power operation at the end of core life and a 50-hour shutdown. The minimum water depth between the top of the damaged fuel rods and the spent fuel pool surface is 21 ft. All the gap activity in the rods of the damaged assembly is released to the spent fuel pool. All activity released from the spent fuel pool is released at ground level to the environment over a 2-hour period. The overall decontamination factor for the spent fuel pool is 160. No credit is taken for iodine filtration by the primary plant ventilation system.

Enclosure to TXX-24065 Page 8 of 16 The thyroid and whole-body doses at the EAB are conservatively calculated to be 26.0 rem and 0.14 rem, respectively. The corresponding doses at the LPZ are conservatively calculated to be 3.9 rem and 0.021 rem. The corresponding doses in the control room are conservatively calculated to be 4.2 rem and 0.18 rem, respectively and a beta-Skin dose of 5.2 rem. These calculated doses are within the values set forth in 10 CFR 100.

An analysis of the radiological consequences of a fuel handling accident inside the Containment Building would use the same assumptions and yield the same results as those of a fuel handling accident outside the Containment Building. Therefore, no specific analysis of such an accident inside the Containment is provided. Additional details related to the Fuel Handling Accident can be found in the CPNPP FSAR Section 15.7.4.

This submittal does not modify the fuel handling accident analysis as previously approved by the NRC in CPNPP License Amendment 146, Section 2.9.8, (Reference 6).

The term recently as used in this application for recently irradiated fuel will be considered 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />. This length of time is less (approximately half) than the time required to remove the reactor vessel head and internals and expose the irradiated fuel after a shutdown.

The CPNPP Technical Requirements Manual (TRM) Technical Requirement (TR) 13.9.31 Decay Time, prohibits the movement of irradiated fuel in the reactor vessel prior to the reactor being subcritical for 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />.

Boron Dilution During Refueling As described in the CPNPP FSAR one of the two principal means of positive reactivity insertion to the core is the addition of unborated, primary grade water from the Demineralized and Reactor Makeup Water System (RMWS) into the Reactor Coolant System (RCS) through the reactor makeup portion of the Chemical and Volume Control System (CVCS). Boron dilution with these systems is a manually initiated operation under strict administrative controls requiring close operator surveillance with procedures limiting the rate and duration of the dilution.

The principal means of causing an inadvertent boron dilution are the opening of the primary water makeup control valve and failure of the blend system, either by controller or mechanical failure. The CVCS and RMWS are designed to limit, even under various postulated failure modes, the potential rate of dilution to values which, with indication by alarms and instrumentation, will allow sufficient time for automatic or operator response (depending on the mode of operation) to terminate the dilution. An inadvertent dilution from the RMWS may be terminated by closing the primary water makeup control valve.

All expected sources of dilution may be terminated by closing isolation valves in the CVCS. The lost shutdown margin (SDM) may be regained by the opening of isolation valves to the Refueling Water Storage Tank (RWST), thus allowing the addition of borated water to the RCS. The rate at which unborated water can be added to the RCS is limited by the design of the CVCS and RMWS. Alarms in the CVCS are available to alert the reactor operators to high flow rates.

Enclosure to TXX-24065 Page 9 of 16 An uncontrolled boron dilution transient cannot occur during the refueling mode of operation. Inadvertent dilution is prevented by administrative controls that isolate the RCS from the potential source of unborated water. Valves in the CVCS will be locked closed during refueling operations. These valves block all flow paths that could allow significant rates of unborated makeup water to reach the RCS. Any makeup that is required during refueling will be borated water supplied from the RWST.

Dropping a Heavy Load onto Irradiated Fuel The dropping of a heavy load onto irradiated fuel is not an analyzed event in the CPNPP FSAR.

3.2 Acceptability of the Proposed Change Applicability of TS 3.3.6 and TS 3.9.4 Following reactor shutdown, decay of the short-lived fission products greatly reduces the fission product inventory present in irradiated fuel. The proposed changes are based on analyses assuming a longer decay period to take advantage of the reduced radionuclide inventory available for release in the event of a fuel handling accident.

Following sufficient decay occurring, the primary success path for mitigating the fuel handling accident no longer includes the functioning of the Containment Ventilation Isolation Instrumentation and Containment Penetrations. As stated previously, no credit is taken for containment in mitigating the fuel handling accident, as all activity is assumed to be released from the pool at ground level to the environment in the analysis with no credit for filtration, holdup, or dilution of the released activity.

The only other accident postulated to occur during CORE ALTERATIONS, is a boron dilution. This event is not postulated to result in fuel cladding integrity damage. Since the only accident postulated to occur during CORE ALTERATIONS that results in a significant radioactive release is the fuel handling accident, the proposed Technical Specification requirements omitting CORE ALTERATIONS is justified.

Also, the Technical Specifications only allow the handling of irradiated fuel in the reactor vessel when the water level in the reactor cavity is at the high water level. Therefore, the proposed changes only affect containment requirements during periods of relatively low shutdown risk during refueling outages. Therefore, the proposed changes do not significantly increase the shutdown risk.

This portion of the change is consistent with TSTF-51.

Required Actions The term core alteration does not appear in the Standard Review Plan or in Title 10 of the Code of Federal Regulations. Since CORE ALTERATIONS only occur when the reactor vessel head is removed, it only applies in MODE 6. There are only two accidents considered during MODE 6 for PWRs: a fuel handling accident and a boron dilution accident. As previously discussed for the fuel handling accident, there are no mitigation actions, except CPNPP credits the CREFS and CRACS systems to reduce

Enclosure to TXX-24065 Page 10 of 16 the dose consequences for the control room. Suspension of CORE ALTERATIONS, except for suspension of movement of [recently] irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident.

The second analyzed event is a boron dilution accident. A boron dilution accident is initiated by a dilution source that results in the boron concentration dropping below that required to maintain the SHUTDOWN MARGIN. As described in the Bases of Specification 3.9.1, Boron Concentration, (which applies in MODE 6), The refueling boron concentration limit is specified in the COLR. Plant procedures ensure the specified boron concentration in order to maintain an overall core reactivity of keff 0.95 during fuel handling, with control rods and fuel assemblies assumed to be in the most adverse configuration (least negative reactivity) allowed by plant procedures. The accident is mitigated by stopping the dilution. Suspension of CORE ALTERATIONS has no effect on the mitigation of a boron dilution accident. Movement of control rods or fuel do not affect the initial conditions of a boron dilution accident as it is assumed that the control rods and fuel are in the most adverse conditions with a large safety margin (keff 0.95).

In summary, with the exception of suspending movement of [recently] irradiated fuel assemblies, there are no DBAs or transients that are initiated by, or mitigation affected by, suspension of CORE ALTERATIONS. Therefore, if all Required Actions that require suspension of CORE ALTERATIONS also require suspension of movement of [recently]

irradiated fuel, suspension of CORE ALTERATIONS provides no safety benefit.

For TS 3.3.7; 3.7.10; 3.7.11; 3.8.2; 3.8.5; 3.8.8; 3.8.10; 3.9.4; The Required Actions that include suspension of CORE ALTERATIONS also include suspension of movement of

[recently] irradiated fuel assemblies. As discussed above, the suspension of CORE ALTERATIONS in these TS provides no safety benefit.

For TS 3.9.1, The Required Action which includes suspension of CORE ALTERATIONS also includes suspension of positive reactivity additions. This Specification is only concerned with a boron dilution accident, as SDM has no bearing on a fuel handling accident. Note that the Required Action to suspend positive reactivity additions would also prohibit adding fuel assemblies to the reactor, which could reduce the SDM. The requirement to suspend positive reactivity additions is the only action needed to mitigate a boron dilution event. Therefore, the action to suspend CORE ALTERATIONS provides no safety benefit and is not needed.

For TS 3.9.2, The Required Action which includes suspension of CORE ALTERATIONS and suspension of positive reactivity additions also includes initiation of actions to secure valves in closed position. The purpose of this Specification is to prevent a boron dilution accident. CORE ALTERATIONS and positive reactivity additions have no effect on a boron dilution accident, either as an initiator or as mitigation. The only mitigating action is to secure valves in a closed position. Suspending CORE ALTERATIONS and suspending positive reactivity additions when a valve is not secured does not provide compensation or reduce the probability of the event. Therefore, the actions to suspend CORE ALTERATIONS and suspend positive reactivity additions provide no safety benefit and are not needed. This change will increase CPNPP consistency with STS.

Enclosure to TXX-24065 Page 11 of 16 For TS 3.9.3 the Required Action to Suspend CORE ALTERATIONS will effectively be retained and a new requirement to suspend positive reactivity additions will be added.

The defined term CORE ALTERATIONS from Required Action A.1 will be replaced by a substantially similar text definition of core alterations in Required Action A.2. This portion of the change is administrative in nature as it facilitates the deletion of the defined term but maintains the effect of the Required Action the same. Required Action A.2 to immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1 is replaced with a more restrictive requirement to immediately suspend positive reactivity additions. This portion of the change is based on the guidance in TSTF-571-T.

3.3 Variations from TSTF-51, TSTF-471, TSTF-571, and STS TSTF-51 The Applicability of TS 3.3.6 is expressed as a list in the traveler, compared to the CPNPP TS tabular format.

The Applicability change to TS 3.3.7 is already incorporated in CPNPP TS.

The Conditions in TS 3.7.10 are numbered differently than CPNPP TS. The changes to the Applicability and Condition C and D are already incorporated in CPNPP TS.

The change to the TS 3.7.11 Applicability and Condition C and D are already incorporated in CPNPP TS.

The changes to TS 3.3.8 and 3.7.13 are not applicable, CPNPP does not have a similar TS.

The changes to TS 3.9.7 are already incorporated in CPNPP TS.

These variations are administrative in nature and do not affect the applicability of the traveler to CPNPP.

TSTF-471 and TSTF-571-T There are no variations to TSTF-471 and TSTF-571-T.

STS CPNPP TS 3.9.2 has Required Action A.2 to immediately suspend positive reactivity additions. This requirement has existed since the initial issue of CPNPP TS in NUREG-1399 (Reference 5), initially as LCO 3.9.1 Action b. This requirement never existed in STS. The requirement is removed to increase alignment with STS as described previously.

Enclosure to TXX-24065 Page 12 of 16

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements The TSs satisfy 10 CFR 50.36, "Technical specifications." The following systems and parameters meet one or more of the criteria of 10 CFR 50.36(c)(2)(ii): Containment ventilation isolation instrumentation and containment penetrations during movement of recently irradiated fuel assemblies; CREFS and associated actuation instrumentation and CRACS systems during movement of irradiated fuel assemblies; AC sources, DC sources, inverters, and distribution systems in MODES 5 or 6; Boron concentration, Unborated water source isolation valve, and Nuclear Instrumentation requirements in Mode 6.

The proposed amendment continues to provide appropriate remedial actions and shutdown requirements required by 10 CFR 50.36(c)(2)(i) for any system requiring an LCO pursuant the criteria of 10 CFR 50.36(c)(2)(ii).

GDC 13: Instrumentation and control. The proposed amendment does not alter the design of the applicable instrumentation that monitor variables and systems over their anticipated ranges for normal operation for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety.

GDC 16: Containment design. The proposed amendment does not alter the containment design or the associated systems' design. The containment and associated systems, when required, will continue to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment as previously licensed and approved by the NRC. During movement of irradiated fuel assemblies when containment integrity is relaxed, CPNPP, will continue to establish and implement administrative controls that ensure that open penetrations can and will be promptly closed, following containment evacuation, in the event of an FHA inside containment.

GDC 19: Control room. The proposed amendment does not alter the design or operation of the control room envelope or the CREFS or CRACS. The FHA analysis is not changed by this submittal and continues to show the radiological dose to the MCR personnel to be within requirements.

GDC 20: Protection system functions. The proposed amendment does not alter the design of reactivity control protection systems or instrumentation that sense accident conditions to initiate systems or components important to safety. The change relaxes the requirements for instrumentation of systems not assumed in the mitigation of an FHA.

GDC 21: Protection system reliability and testability. The proposed amendment does not alter the design of any protection system, including the containment ventilation instrumentation and the CREFS actuation instrumentation. Therefore, the protection system design continues to provide high functional reliability and inservice testability commensurate with the safety functions to be performed and continues to be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the

Enclosure to TXX-24065 Page 13 of 16 required minimum redundancy. The containment ventilation instrumentation and the CREFS actuation instrumentation designs continue to permit periodic testing of its functioning when the reactor is in operation as previously licensed and approved by the NRC.

GDC 22: Protection system independence. The proposed amendment does not alter the design of any protection system, including the containment ventilation instrumentation and the CREFS actuation instrumentation. Therefore, the protection system design continues to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in loss of the protection function to the extent previously licensed and approved by the NRC.

GDC 23: Protection system failure modes. The proposed amendment does not alter the design of any protection system, including the containment ventilation instrumentation and the CREFS actuation instrumentation. Therefore, the protection system design continues to fail into a safe state or into a state demonstrated to be acceptable as previously licensed and approved by the NRC.

GDC 24: Separation of protection and control systems. The proposed amendment does not alter the design of any protection system, including the containment ventilation instrumentation and the CREFS actuation instrumentation. Therefore, the protection system design continues to be separated from control systems as previously licensed and approved by the NRC.

GDC 64: Monitoring radioactivity releases. The proposed amendment does not alter the design of any radioactivity monitoring instrumentation, including the containment ventilation instrumentation and the CREFS actuation instrumentation. Means continue to be provided for monitoring the reactor containment atmosphere, spaces containing components for recirculation of loss-of-coolant accident fluids, effluent discharge paths, and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents (e.g.,

FHA).

4.2 Precedent A recent submittal of TSTF-51 and TSTF-471 was approved by the NRC for Vogtle Units 1 and 2. Reference ML23158A018 A recent submittal of TSTF-471 and TSTF-571-T was approved by the NRC for Prairie Island Units 1 and 2. Reference ML22061A206.

4.3 No Significant Hazards Consideration Determination Analysis The proposed amendment to Technical Specification (TS) removes the requirements for certain systems to be OPERABLE after sufficient radioactive decay has occurred following a plant shutdown. Following sufficient radioactive decay, these systems are no longer required during a fuel handling accident (FHA) to ensure main control room personnel dose and offsite doses remain below applicable limits.

Enclosure to TXX-24065 Page 14 of 16 The proposed amendment also removes the defined term CORE ALTERATIONS from TS and revises certain TS actions that are not needed to mitigate accidents postulated during shutdown. The action for an inoperable source range neutron flux monitor is revised.

Vistra OpCo has evaluated whether a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment neither alters plant equipment nor the manner in which equipment is operated and maintained, and thereby cannot increase the probability of an accident. The proposed amendment cannot adversely affect the type or amount of effluent that may be released off-site or increase individual or cumulative occupational exposures resulting from any design basis accident, and thereby cannot increase the consequences of any accident.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendment neither installs new nor modifies existing plant equipment and thereby cannot introduce new equipment failure modes. The proposed amendment does not alter safety analysis assumptions, or create new accident initiators or precursors, and thereby cannot introduce a new or different type of accident.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed amendment does not involve a physical change to the containment, nor does it change the safety function of the containment or associated instrumentation. The subject ESF systems are not assumed in the mitigation of an FHA after sufficient radioactive decay of irradiated fuel has occurred.

Enclosure to TXX-24065 Page 15 of 16 Elimination of the action to suspend CORE ALTERATIONS does not reduce the margin of safety in the event boron concentration is not within the required limit in refueling condition because the remaining required actions continue to prohibit positive reactivity additions until reactor core shutdown margin can be restored to within the required limit.

Permitting fuel assemblies, sources, and reactivity control components to be moved to restore an inoperable source range neutron flux monitor to operable status when one or more required source range neutron flux monitors are inoperable does not significantly reduce the margin of safety. The required actions continue to minimize actions that could result in reactivity changes within the core, while providing the ability to safely restore source range neutron monitoring capability.

The proposed amendment does not modify any, limiting safety system settings, or safety analysis assumptions. The proposed amendment does not modify equipment credited in safety analyses, and thereby cannot affect the integrity of any radiological barrier.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above evaluations, Vistra OpCo concludes that the propose amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

S Vistra OpCo 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 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

Enclosure to TXX-24065 Page 16 of 16

6.0 REFERENCES

1 STS Change Traveler TSTF-51-A, "Revise containment requirements during handling irradiated fuel and core alterations," Revision 2, dated November 1, 1999, (ML040400343) 2 STS Change Traveler TSTF-471-A, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes" Revision 1, dated December 18, 2006, (ML19101A215) 3 STS Change Traveler TSTF-571-T, Revise Actions for Inoperable Source Range Neutron Flux Monitor, Revision 0, dated August 28, 2020 4

NRC NUREG-1431, "Standard Technical Specifications Westinghouse Plants Revision 5.0 Volume 1, Specifications," (ML21259A155) 5 NUREG 1399, Technical Specifications, Comanche Peak Steam Electric Station Unit 1, Docket No. 50-445, Appendix 'A' to License No. NPF-87, (ML20043D512) 6 Comanche Peak, Units 1 and 2 - Issuance of Amendment Nos. 146 and 146, Stretch Power Uprate, Revision to TS 1.0, "Use and Application," to Revise Rated Thermal Power from 3458 to 3612 MWt (TAC Nos. MD6615 and MD6616), (ML081510173)

Enclosure to TXX-240065 Proposed Technical Specification Changes

Definitions 1.1 1.1 Definitions (continued)

COMANCHE PEAK - UNITS 1 AND 2 1.1-2 CHANNEL OPERATIONAL TEST (COT)

A COT shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY so that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS REPORT (COLR)

The COLR is the unit specific document that provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes I-131, I-132, I-133, I-134, and I-135 actually present. The determination of DOSE EQUIVALENT I-131 shall be performed using thyroid dose conversion factors from Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites," or from Table E-7 of Regulatory Guide 1.109, Revision 1, NRC, 1977, or from ICRP-30, 1979, Supplement to Part 1, page 192-212, Table titled Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity, or from Table 2.1 of EPA Federal Guidance Report No. 11, 1988, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion.

Amendment No. 150, 174

Containment Ventilation Isolation Instrumentation 3.3.6 3.3 INSTRUMENTATION COMANCHE PEAK - UNITS 1 AND 2 3.3-51 3.3.6 Containment Ventilation Isolation Instrumentation LCO 3.3.6 The Containment Ventilation Isolation instrumentation for each Function in Table 3.3.6-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6-1 ACTIONS

---

NOTE-------------------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One radiation monitoring channel inoperable.

A.1 Restore the affected channel to OPERABLE status.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Amendment No. 156, 183 no change this page

Containment Ventilation Isolation Instrumentation 3.3.6 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-53 SURVEILLANCE REQUIREMENTS

---

NOTE--------------------------------------------------------------

Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Ventilation Isolation Function.

CONDITION REQUIRED ACTION COMPLETION TIME C. --------------NOTE-------------

Only applicable during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment.

Required Action and associated Completion Time for Condition A not met.

---

NOTE------------------------

The containment pressure relief valves may be opened in compliance with the gaseous effluent monitoring instrumentation requirements in Part I of the ODCM.

C.1 Place and maintain containment ventilation valves in closed position.

OR C.2 Enter applicable Conditions and Required Actions of LCO 3.9.4, "Containment Penetrations," for containment ventilation isolation valves made inoperable by isolation instrumentation.

Immediately Immediately SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 156, 183 recently

Containment Ventilation Isolation Instrumentation 3.3.6 COMANCHE PEAK - UNITS 1 AND 2 3.3-55 Table 3.3.6-1 (page 1 of 1)

Containment Ventilation Isolation Instrumentation (a) Must satisfy Gaseous Effluent Dose Rate Requirements in Part I of the ODCM.

(b) During CORE ALTERATIONS.

(c) During movement of irradiated fuel assemblies within containment.

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT

1. Manual Initiation 1, 2, 3, 4 Refer to LCO 3.3.2 ESFAS Instrumentation, Functions 2.a and 3.a.1, respectively for all initiation functions and requirements.

2. Automatic Actuation Logic and Actuation Relays 1, 2, 3, 4 2 trains SR 3.3.6.2 SR 3.3.6.3 SR 3.3.6.5 NA

3. Containment Radiation

a. Gaseous 1, 2, 3, 4, (b), (c) 1 SR 3.3.6.1 SR 3.3.6.4 SR 3.3.6.7 (a)

4. Containment Isolation -

Phase A Refer to LCO 3.3.2, ESFAS Instrumentation, Function 3.a, for all initiation functions and requirements.

Amendment No. 156, 183 recently (b)

CREFS Actuation Instrumentation 3.3.7 3.3 INSTRUMENTATION COMANCHE PEAK - UNITS 1 AND 2 3.3-56 3.3.7 Control Room Emergency Filtration System (CREFS) Actuation Instrumentation LCO 3.3.7 The CREFS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.7-1 ACTIONS

---

NOTE-------------------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one channel or train inoperable.

A.1 Place the affected CREFS train(s) in emergency recirculation mode.

OR A.2 --------------------NOTE---------------------

Applicable only to Functions 3a and 3b.

Secure the Control Room makeup air supply fan from the affected air intake.

7 days 7 days Amendment No. 183 no change this page

CREFS Actuation Instrumentation 3.3.7 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-57 CONDITION REQUIRED ACTION COMPLETION TIME B. One or more Functions with two channels or two trains inoperable.

B.1.1 Place one CREFS train in emergency recirculation mode.

AND B.1.2 Enter applicable Conditions and Required Actions for one CREFS train made inoperable by inoperable CREFS actuation instrumentation OR B.2 -----------------NOTE------------------

Applicable only to Functions 3a and 3b.

Secure the Control Room makeup air supply fan from the affected air intake.

Immediately Immediately Immediately C. Required Action and associated Completion Time for Condition A or B not met in MODE 1, 2, 3, or 4.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours D. Required Action and associated Completion Time for Condition A or B not met in MODE 5 or 6, or during movement of irradiated fuel assemblies.

D.1 Suspend CORE ALTERATIONS.

AND D.2 Suspend movement of irradiated fuel assemblies.

Immediately Immediately Amendment No. 183 1

CREFS Actuation Instrumentation 3.3.7 COMANCHE PEAK - UNITS 1 AND 2 3.3-59 Table 3.3.7-1 (page 1 of 1)

CREFS Actuation Instrumentation (a) During movement of irradiated fuel assemblies.

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS SURVEILLANCE REQUIREMENTS TRIP SETPOINT

1. Manual Initiation 1, 2, 3, 4, 5, and 6, (a) 2 trains SR 3.3.7.6 NA

2. Automatic Actuation Logic and Actuation Relays 1, 2, 3, 4, 5, and 6, (a) 2 trains SR 3.3.7.2 NA

3. Control Room Radiation

a. Control Room Air North Intake 1, 2, 3, 4, 5, and 6, (a) 2 SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.7 1.4 x 10-4 Ci/ml

b. Control Room Air South Intake 1, 2, 3, 4, 5, and 6, (a) 2 SR 3.3.7.1 SR 3.3.7.2 SR 3.3.7.7 1.4 x 10-4 Ci/ml

4. Safety Injection Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 1, for all initiation functions and requirements.

Amendment No. 183 no change this page

CREFS 3.7.10 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-25 3.7.10 Control Room Emergency Filtration/Pressurization System (CREFS)

LCO 3.7.10 Two CREFS trains shall be OPERABLE

---

NOTE-----------------------------------------------

The Control Room envelope (CRE) boundary may be opened intermittently under administrative controls.

APPLICABILITY:

MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREFS train inoperable for reasons other than Condition B.

A.1 Restore CREFS train to OPERABLE status.

7 days B. One or more CREFS Trains inoperable due to inoperable CRE boundary in MODES 1, 2, 3, and 4.

B.1 Initiate action to implement mitigating actions.

AND B.2 Verify mitigating actions to ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND B.3 Restore CRE boundary to OPERABLE status.

Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days Amendment No. 150, 156 no change this page

CREFS 3.7.10 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.7-26 CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or 4.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours D. Required Action and associated Completion Time of Condition A not met in MODE 5 or 6, or during movement of irradiated fuel assemblies.

D.1 Place OPERABLE CREFS train in emergency recirculation mode.

OR D.2.1 Suspend CORE ALTERATIONS.

AND D.2.2 Suspend movement of irradiated fuel assemblies.

Immediately Immediately Immediately E. Two CREFS trains inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies.

OR One or more CREFS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.

E.1 Suspend CORE ALTERATIONS.

AND E.2 Suspend movement of irradiated fuel assemblies.

Immediately Immediately F. Two CREFS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

F.1 Enter LCO 3.0.3.

Immediately Amendment No. 150, 156 1

CRACS 3.7.11 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-28 3.7.11 Control Room Air Conditioning System (CRACS)

LCO 3.7.11 Two CRACS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CRACS train inoperable.

A.1 Restore CRACS train to OPERABLE status.

30 days B. Required Action and associated Completion Time of Condition A not met in MODE 1, 2, 3, or 4.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours C. Required Action and associated Completion Time of Condition A not met in MODE 5, or 6, or during movement of irradiated fuel assemblies.

C.1 Place OPERABLE CRACS train in operation.

OR C.2.1 Suspend CORE ALTERATIONS.

AND C.2.2 Suspend movement of irradiated fuel assemblies.

Immediately Immediately Immediately Amendment No. 150, 156

CRACS 3.7.11 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.7-29 CONDITION REQUIRED ACTION COMPLETION TIME D. Two CRACS trains inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies.

D.1.1 Verify at least 100% of the required heat removal capability equivalent to a single OPERABLE train available.

AND D.1.2 Restore the CRACS trains to OPERABLE status.

OR D.2.1 Suspend CORE ALTERATIONS.

AND D.2.2 Suspend movement of irradiated fuel assemblies.

Immediately 30 days Immediately Immediately E. Two CRACS trains inoperable in MODE 1, 2, 3, or 4.

E.1.1 Verify at least 100% of the required heat removal capability equivalent to a single OPERABLE train available.

AND E.1.2 Restore one CRACS train to OPERABLE status.

OR E.2 Enter LCO 3.0.3.

Immediately 30 days Immediately Amendment No. 150, 156

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.8-18 3.8.2 AC Sources -- Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a.

One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem required by LCO 3.8.10, "Distribution Systems -- Shutdown"; and b.

One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystems required by LCO 3.8.10.

APPLICABILITY:

MODES 5 and 6 Amendment No. 150, 183 no change this page

AC Sources - Shutdown 3.8.2 COMANCHE PEAK - UNITS 1 AND 2 3.8-19 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit inoperable.

---

NOTE-----------------------

Enter applicable Conditions and Required Actions of LCO 3.8.10, with the required train de-energized as a result of Condition A.

A.1 Declare affected required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.4 Initiate action to restore required offsite power circuit to OPERABLE status.

Immediately Immediately Immediately Immediately Immediately Amendment No. 150, 183 1

2 3

AC Sources - Shutdown 3.8.2 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-20 SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG inoperable.

B.1 Suspend CORE ALTERATIONS.

AND B.2 Suspend movement of irradiated fuel assemblies.

AND B.3 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.4 Initiate action to restore required DG to OPERABLE status.

Immediately Immediately Immediately Immediately SURVEILLANCE FREQUENCY

---

NOTE-----------------------------------------------

The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.14, SR 3.8.1.15, and SR 3.8.1.16.

SR 3.8.2.1 For AC sources required to be OPERABLE, the following SRs are applicable:

SR 3.8.1.1 SR 3.8.1.5 SR 3.8.1.10 SR 3.8.1.2 SR 3.8.1.6 SR 3.8.1.11 (except c.2)

SR 3.8.1.3 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.4 SR 3.8.1.9 SR 3.8.1.15 SR 3.8.1.16 In accordance with applicable SRs Amendment No. 153, 183 1

2 3

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.8-27 3.8.5 DC Sources -- Shutdown LCO 3.8.5 The Train A or Train B DC electrical power subsystem shall be OPERABLE to support one train of the DC electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems -- Shutdown."

APPLICABILITY:

MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required DC electrical power subsystems inoperable.

A.1 Declare affected required feature(s) inoperable.

OR A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.4 Initiate action to restore required DC electrical power subsystem to OPERABLE status.

Immediately Immediately Immediately Immediately Immediately Amendment No. 150, 183 1

2 3

Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.8-36 3.8.8 Inverters Shutdown LCO 3.8.8 The Train A or Train B inverters shall be OPERABLE to support one train of the onsite Class 1E AC vital bus electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems -- Shutdown."

APPLICABILITY:

MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required inverters inoperable.

A.1 Declare affected required feature(s) inoperable.

OR A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.4 Initiate action to restore required inverters to OPERABLE status.

Immediately Immediately Immediately Immediately Immediately Amendment No. 156, 183 1

2 3

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.8-40 3.8.10 Distribution Systems -- Shutdown LCO 3.8.10 The necessary portion of the Train A or Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support one train of equipment required to be OPERABLE.

APPLICABILITY:

MODES 5 and 6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC, DC, or AC vital bus electrical power distribution subsystems inoperable.

A.1 Declare associated supported required feature(s) inoperable.

OR A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

AND A.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND Immediately Immediately Immediately Immediately Amendment No. 156, 183 1

2

Distribution Systems - Shutdown 3.8.10 ACTIONS COMANCHE PEAK - UNITS 1 AND 2 3.8-41 SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2.4 Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

AND A.2.5 Declare associated required residual heat removal subsystem(s) inoperable and not in operation.

Immediately Immediately SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 183 3

4

Boron Concentration 3.9.1 COMANCHE PEAK - UNITS 1 AND 2 3.9-1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of all filled portions of the Reactor Coolant System, the refueling canal, and the refueling cavity, that have direct access to the reactor vessel, shall be maintained within the limit specified in the COLR.

---

NOTE----------------------------------------------

While this LCO is not met, entry into MODE 6 from MODE 5 is not permitted.

APPLICABILITY:

MODE 6.

ACTIONS SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME A. Boron concentration not within limit.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend positive reactivity additions.

AND A.3 Initiate action to restore boron concentration to within limit.

Immediately Immediately Immediately SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the limit specified in the COLR.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 150, 156 1

2

Unborated Water Source Isolation Valves 3.9.2 3.9 REFUELING OPERATIONS COMANCHE PEAK - UNITS 1 AND 2 3.9-2 3.9.2 Unborated Water Source Isolation Valves LCO 3.9.2 Each valve used to isolate unborated water sources shall be secured in the closed position.

APPLICABILITY:

MODE 6.

ACTIONS

---

NOTE---------------------------------------------------------------

Separate Condition entry is allowed for each unborated water source isolation valve.

CONDITION REQUIRED ACTION COMPLETION TIME A. --------------NOTE--------------

Required Action A.4 must be completed whenever Condition A is entered.

One or more valves not secured in closed position.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend positive reactivity addition.

AND A.3 Initiate actions to secure valve in closed position.

AND A.4 Perform SR 3.9.1.1.

Immediately Immediately Immediately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Amendment No. 150 1

2 2

Nuclear Instrumentation 3.9.3 3.9 REFUELING OPERATIONS COMANCHE PEAK - UNITS 1 AND 2 3.9-4 3.9.3 Nuclear Instrumentation LCO 3.9.3 Two source range neutron flux monitors shall be OPERABLE.

APPLICABILITY:

MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required source range neutron flux monitor inoperable.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

Immediately Immediately B. Two required source range neutron flux monitors inoperable.

B.1 Initiate action to restore one source range neutron flux monitor to OPERABLE status.

AND B.2 Perform SR 3.9.1.1.

Immediately Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Amendment No. 150 Positive Reactivty Additions

---

NOTE -------------

Fuel assemblies, sources, and reactivity control components may be moved if necessary to restore an inoperable source range neutron flux monitor or to complete movement of a component to a safe condition.

Suspend movement of fuel, sources, and reactivity control components within the reactor vessel.

Containment Penetrations 3.9.4 3.9 REFUELING OPERATIONS COMANCHE PEAK - UNITS 1 AND 2 3.9-6 3.9.4 Containment Penetrations LCO 3.9.4 The containment penetrations shall be in the following status:

a.

The equipment hatch closed and held in place by four bolts, or if open, capable of being closed; b.

One door in the emergency air lock closed and one door in the personnel airlock capable of being closed; and c.

Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:

1.

closed by a manual or automatic isolation valve, blind flange, or equivalent, or 2.

capable of being closed by an OPERABLE containment ventilation isolation valve.

---

NOTE---------------------------------------------

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.

APPLICABILITY:

During CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more containment penetrations not in required status.

A.1 Suspend CORE ALTERATIONS.

AND A.2 Suspend movement of irradiated fuel assemblies within containment.

Immediately Immediately Amendment No. 150 1

recently recently

Enclosure to TXX-240065 Proposed Technical Specification Bases Changes (information only)

Containment Ventilation Isolation Instrumentation B 3.3.6 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-140 Revision 88 APPLICABLE SAFETY ANALYSES The safety analyses for LOCA assume that the containment remains intact with penetrations unnecessary for core cooling isolated early in the event.

Containment pressure relief is assumed to be isolated within 5 seconds of Pressurizer Pressure Low for LOCA. Containment isolation in turn ensures meeting the containment leakage rate assumptions of the safety analyses, and ensures that the calculated accidental offsite radiological doses are below 10 CFR 100 (Ref. 1) limits.

There is no credit taken for containment isolation by the radiation monitor in the accident analyses. There is no credit taken for containment isolation for a fuel handling accident.

The containment ventilation isolation instrumentation satisfies Criterion 3 of 10CFR50.36(c)(2)(ii).

LCO The LCO requirements ensure that the instrumentation necessary to initiate Containment Ventilation Isolation, listed in Table 3.3.6-1, is OPERABLE.

1.

Manual Initiation Containment Ventilation Isolation is manually initiated when the Phase A isolation function or the containment spray function is manually initiated. Refer to the Bases for LCO 3.3.2, ESFAS Instrumentation, Function 3.a.1 and 2.a, respectively, for applicability, required channels and surveillance requirements.

2.

Automatic Actuation Logic and Actuation Relays The LCO requires two trains of Automatic Actuation Logic and Actuation Relays OPERABLE to ensure that no single random failure can prevent automatic actuation.

Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b, SI, and ESFAS Function 3.a.(2), Containment Phase A Isolation. The applicable MODES and specified conditions for the containment ventilation isolation portion of these Functions are different and less restrictive than those for their Phase A isolation and SI roles. If one or more of the SI or Phase A isolation Functions becomes inoperable in such a manner that only the Containment Ventilation Isolation Function is affected, the Conditions applicable to their SI and Phase A isolation Functions need not be entered. The less restrictive Actions specified for inoperability of the Containment Ventilation Isolation Functions specify sufficient compensatory measures for this case.

(continued)

Due to radioactive decay, containment is only required to isolate during fuel handling accidents involving handling recently irradiated fuel (i.e.,

fuel that has occupied part of a critical reactor core within the previous 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />).

Containment Ventilation Isolation Instrumentation B 3.3.6 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-141 Revision 88 LCO (continued) 3.

Containment Radiation The LCO specifies one required radiation monitoring channel to ensure that the radiation monitoring instrumentation necessary to initiate Containment Ventilation Isolation remains OPERABLE.

For sampling systems, channel OPERABILITY involves more than OPERABILITY of the channel electronics. OPERABILITY may also require correct valve lineups, and sample pump operation, as well as detector OPERABILITY. These supporting features are necessary for a containment radiation trip to occur under the conditions assumed by the safety analyses. The Trip Setpoint for this Function is selected to satisfy the Gaseous Effluent Dose Rate requirements in Part I of the Offsite Dose Calculation Manual (ODCM).

4.

Containment Isolation-Phase A Refer to LCO 3.3.2, Function 3.a., for all initiating Functions and requirements. The operator can initiate Containment Ventilation Isolation at any time by using either of two Containment Isolation Phase A manual switches in the control room. Either switch actuates both trains. This action will cause actuation of all components in the same manner as any of the automatic actuation signals.

This functions requirements encompass the requirement to test the manual initiation which ensures the proper amount of redundancy is maintained in the manual actuation circuitry to ensure the operator has manual initiation capability.

APPLICABILITY The Manual Initiation, Automatic Actuation Logic and Actuation Relays, Containment Isolation - Phase A, and Containment Radiation Functions are required OPERABLE in MODES 1, 2, 3, and 4, and, for the radiation function, during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment. Under these conditions, the potential exists for an accident that could release fission product radioactivity into containment. Therefore, the containment ventilation isolation instrumentation must be OPERABLE in these MODES.

While in MODES 5 and 6 without fuel handling in progress, the containment ventilation isolation instrumentation need not be OPERABLE since the (continued) recently significant (i.e., fuel that has occupied part of a critical reactor core within the previous 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />)

Containment Ventilation Isolation Instrumentation B 3.3.6 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-142 Revision 88 APPLICABILITY (continued) potential for radioactive releases is minimized and operator action is sufficient to ensure post accident offsite doses are maintained within the limits of Reference 1.

The Applicability for the containment ventilation isolation on the ESFAS Containment Isolation - Phase A Function is specified in LCO 3.3.2. Refer to the Bases for LCO 3.3.2 for a discussion of the Containment Isolation -

Phase A Function Applicability.

ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification.

A Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.6-1. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to failure of the radiation monitor channel. Since the containment radiation monitor measures the containment atmosphere and provides an actuation signal, failure of the channel results in the loss of the radiation monitoring Function. Consequently, the channel must be restored to OPERABLE status. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed to restore the affected channel is justified by the low likelihood of events occurring during this interval.

B.1 Condition B applies to all Containment Ventilation Isolation Automatic Actuation Logic and Actuation relays and addresses the train orientation of the Solid State Protection System (SSPS) and the master and slave relays for this Function. Condition B also applies to the radiation monitoring channel if the required action and completion times of Condition A are not met.

(continued)

No Change this page

Containment Ventilation Isolation Instrumentation B 3.3.6 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-143 Revision 88 ACTIONS B.1 (continued)

If a train is inoperable, or the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action for the applicable Conditions of LCO 3.6.3 is met for each valve made inoperable by failure of isolation instrumentation.

A Note is added to allow the containment pressure relief valves to be opened in compliance with the gaseous effluent monitoring instrumentation requirements in Part I of the ODCM, for Required Action and associated Completion Time of Condition A not met.

A Note is added stating that Condition B is only applicable in MODE 1, 2, 3, or 4.

C.1 and C.2 Condition C applies to the inability to restore the radiation monitoring channel to OPERABLE status in the time allowed for Required Action A.1. If the Required Action and associated Completion Time of Condition A are not met, operation may continue as long as the Required Action to place and maintain containment ventilation isolation valves in their closed position is met or the applicable Conditions of LCO 3.9.4, "Containment Penetrations,"

are met for each valve made inoperable by failure of isolation instrumentation. A note allows the containment pressure relief valves to be opened in compliance with gaseous effluent monitoring instrumentation requirements in Part I of the ODCM. The Completion Time for these Required Actions is Immediately.

A Note states that Condition C is applicable during CORE ALTERATIONS and during movement of irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS A Note has been added to the SR Table to clarify that Table 3.3.6-1 determines which SRs apply to which Containment Ventilation Isolation Functions.

SR 3.3.6.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

(continued) recently

CREFS Actuation Instrumentation B 3.3.7 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-150 Revision 88 ACTIONS (continued)

D.1 and D.2 Condition D applies when the Required Action and associated Completion Time for Condition A or B have not been met during MODE 5 or 6 or when irradiated fuel assemblies are being moved. Movement of irradiated fuel assemblies and CORE ALTERATIONS must be suspended immediately to reduce the risk of accidents that would require CREFS actuation SURVEILLANCE REQUIREMENTS A Note has been added to the SR Table to clarify that Table 3.3.7-1 determines which SRs apply to which CREFS Actuation Functions.

SR 3.3.7.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability.

If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.7.2 A COT is performed on each required channel to ensure the entire channel will perform the intended function. This test verifies the capability of the instrumentation to provide the CREFS actuation. The setpoints shall be left consistent with the unit specific calibration procedure tolerance. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The COT surveillance of the control room air intake monitors verifies the contacts and circuitry between the monitors and the CREFS actuation circuits, and thereby satisfies the COT for Automatic Actuation Logic and Actuation Relays.

(continued)

CREFS B 3.7.10 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-52 Revision 88 ACTIONS B.1, B.2, and B.3 (continued)

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protection measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CREFS train or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1, D.2.1, and D.2.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, if the inoperable CREFS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREFS train in the emergency mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the (continued) and

CREFS B 3.7.10 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-53 Revision 88 ACTIONS D.1, D.2.1, and D.2.2 (continued)

CRE. This places the unit in a condition that minimizes the accident risk.

This does not preclude the movement of fuel to a safe position.

E.1 and E.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, with two CREFS trains inoperable or with one or more CREFS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

F.1 If both CREFS trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than an inoperable CRE boundary (i.e., Condition B), the CREFS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE REQUIREMENTS SR 3.7.10.1 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train periodically provides an adequate check of this system. Periodic heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air.

Filtration units with heaters must be operated for > 10 continuous hours with the heaters energized. Filtration units without heaters need only be operated for > 15 minutes to demonstrate the function of the system. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.10.2 This SR verifies that the required CREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREFS filter tests are in accordance with Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, (continued) and

CRACS B 3.7.11 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-58 Revision 88 ACTIONS (continued)

B.1 and B.2 In MODE 1, 2, 3, or 4, if the inoperable CRACS train cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.1, C.2.1, and C.2.2 In MODE 5 or 6, and during movement of irradiated fuel, if the inoperable CRACS train cannot be restored to OPERABLE status within the required Completion Time, the OPERABLE CRACS train must be placed in operation immediately. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that active failures will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that present a potential for releasing radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

D.1 and D.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, with two CRACS trains inoperable and at least 100% of the required heat removal capability equivalent to a single OPERABLE train available, action must be taken to restore OPERABLE status in 30 days. In this condition, the remaining OPERABLE air conditioning units in both trains are adequate to maintain the control room temperature within limits. However, the overall reliability is reduced because a single failure in the OPERABLE CRACS air conditioning units could result in loss of CRACS function. The 30 day Completion Time is based on the low probability of an event challenging the remaining units and the consideration that the remaining train can provide the required protection.

An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

(continued) and

AC Sources - Shutdown B 3.8.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-33 Revision 88 LCO (continued)

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 provide assurance that:

a.

Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core; b.

Systems needed to mitigate a fuel handling accident are available; c.

Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and d.

Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. The one train with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron (continued) irradiated and

AC Sources - Shutdown B 3.8.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-34 Revision 88 ACTIONS A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 (continued) concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to the required ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized.

LCO 3.8.10 would provide the appropriate restrictions for the situation involving a de-energized train.

SURVEILLANCE REQUIREMENTS SR 3.8.2.1 SR 3.8.2.1 requires the SR from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4.

Table B 3.8.2-1 discusses the applicability of the 3.8.1 surveillances.

(continued) and

DC Sources - Shutdown B 3.8.5 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-57 Revision 88 APPLICABILITY (continued) b.

Required features needed to mitigate a fuel handling accident are available; c.

Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and d.

Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the unit safety systems.

(continued) and

DC Sources - Shutdown B 3.8.5 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-58 Revision 88 ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

SURVEILLANCE REQUIREMENTS SR 3.8.5.1 SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.3. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SR 3.8.4.2 and SR 3.8.4.3. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

REFERENCES 1.

FSAR, Chapter 6.

2.

FSAR, Chapter 15.

and

Inverters - Shutdown B 3.8.8 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-74 Revision 88 APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6 provide assurance that:

a.

Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core; b.

Systems needed to mitigate a fuel handling accident are available; c.

Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and d.

Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory may allow dilution of the RCS but the source of makeup water is required to contain sufficient boron concentration such that when mixed with the RCS inventory the resulting boron concentration in the RCS meets the minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to (continued) and

Inverters - Shutdown B 3.8.8 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-75 Revision 88 ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 (continued) immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE REQUIREMENTS SR 3.8.8.1 This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage output ensures that the required power is available for the instrumentation connected to the AC vital buses.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Chapter 6.

2.

FSAR, Chapter 15.

and

Distribution Systems - Shutdown B 3.8.10 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-85 Revision 88 LCO (continued)

OPERABILITY). Otherwise, the supported components must be declared inoperable and the appropriate conditions of the LCOs for the redundant components must be entered.

The required AC vital bus electrical power distribution subsystem is supported by one train of inverters as required LCO 3.8.8, Inverters -

Shutdown. When the second (subsystem) of AC vital bus electrical power distribution is needed to support redundant required systems, equipment and components, the second train may be energized from any available source. The available source must be Class 1E or another reliable source.

The available source must be capable of supplying sufficient AC electrical power such that the redundant components are capable of performing their specified safety function(s) (implicitly required by the definition of OPERABILITY). Otherwise, the supported components must be declared inoperable and the appropriate conditions of the LCOs for the redundant components must be entered.

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6, provide assurance that:

a.

Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core; b.

Systems needed to mitigate a fuel handling accident are available; c.

Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and d.

Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, DC, and AC vital bus electrical power distribution subsystems requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired (continued) and

Distribution Systems - Shutdown B 3.8.10 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-86 Revision 88 ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 (continued) administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions.

As AC Vital Bus 1EC5 or 2EC5 power common panel XEC1-1 and AC Vital Bus 1EC6 or 2EC6 power common panel XEC2-1, and evaluations have called into question the ability for Unit 2 to fully power all Unit 1 loads, XEC1-1 and XEC2-1 cannot be powered by Unit 2 when Unit 1 is in any mode applicable to TS 3.8.10 (i.e., MODES 5-6). When Unit 2 is powering XEC1-1 or XEC2-1 in MODES 5 or 6, the requirements of TS 3.8.10, Condition A, are applicable for the associated vital bus (Ref. 3).

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

and

Boron Concentration B 3.9.1 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-3 Revision 86 ACTIONS A.1 and A.2 Continuation of CORE ALTERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO. If the boron concentration of any coolant volume in the filled portions of the RCS, the refueling canal or the refueling cavity, that have direct access to the reactor vessel is less than its limit, all operations involving CORE ALTERATIONS or positive reactivity additions must be suspended immediately.

Suspension of CORE ALTERATIONS and positive reactivity additions shall not preclude moving a component to a safe position. Operations that individually add limited positive reactivity (e.g., temperature fluctuations, inventory addition, or temperature control fluctuations), but when combined with all other operations affecting core reactivity (e.g., intentional boration) result in overall net negative reactivity addition, are not precluded by this action.

When determining compliance with actions, addition of borated water with a concentration greater than or equal to the minimum required RWST concentration shall not be considered a positive reactivity change (Ref.3).

A.3 In addition to immediately suspending CORE ALTERATIONS and positive reactivity additions, boration to restore the concentration must be initiated immediately.

In determining the required combination of boration flow rate and concentration, no unique Design Basis Event must be satisfied. The only requirement is to restore the boron concentration to its required value as soon as possible. In order to raise the boron concentration as soon as possible, the operator should begin boration with the best source available for unit conditions.

Once actions have been initiated, they must be continued until the boron concentration is restored. The restoration time depends on the amount of boron that must be injected to reach the required concentration.

SURVEILLANCE REQUIREMENTS SR 3.9.1.1 This SR ensures that the coolant boron concentration in the filled portions of the RCS, and all the filled portions of the refueling canal and the refueling cavity, that have direct access to the reactor vessel is within the COLR limits.

(continued) 2

Unborated Water Source Isolation Valves B 3.9.2 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-6 Revision 86 ACTIONS The ACTIONS table has been modified by a Note that allows separate Condition entry for each unborated water source isolation valve.

A.1 and A.2 Continuation of CORE ALTERATIONS or positive reactivity additions is contingent upon maintaining the unit in compliance with this LCO. With any valve used to isolate unborated water sources not secured in the closed position, all operations involving CORE ALTERATIONS or positive reactivity additions must be suspended immediately. The Completion Time of "immediately" for performance of Required Action A.1 shall not preclude completion of movement of a component to a safe position.

Condition A has been modified by a Note to require that Required Action A.4 be completed whenever Condition A is entered.

A.3 Preventing inadvertent dilution of the reactor coolant boron concentration is dependent on maintaining the unborated water isolation valves secured closed. Securing the valves in the closed position, under administrative controls, ensures that the valves are not inadvertently opened. The Completion Time of "immediately" requires an operator to initiate actions to close an open valve and secure the isolation valve in the closed position immediately. Once actions are initiated, they must be continued until the valves are secured in the closed position.

A.4 Due to the potential of having diluted the boron concentration of the reactor coolant, SR 3.9.1.1 (verification of boron concentration) must be performed whenever Condition A is entered to demonstrate that the required boron concentration exists. The Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is sufficient to obtain and analyze a reactor coolant sample for boron concentration.

SURVEILLANCE REQUIREMENTS SR 3.9.2.1 These valves are to be secured closed to isolate possible dilution paths.

Secured closed includes a mechanical stop for the manual isolation valve CS-8455 or mechanical stops for the manual isolation valves CS-8439, CS-8441, CS-8560, and CS-8453 and removal of air or electrical power from the fail-closed, air operated valve FCV-111B. The likelihood of a significant reduction in the boron concentration during MODE 6 operations is remote due to the large mass of borated water in the refueling cavity and the fact (continued) 1 2

Nuclear Instrumentation B 3.9.3 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-9 Revision 86 LCO This LCO requires that two source range neutron flux monitors be OPERABLE to ensure that redundant monitoring capability is available to detect changes in core reactivity. To be OPERABLE, each monitor must provide visual indication in the control room.

APPLICABILITY In MODE 6, the source range neutron flux monitors must be OPERABLE to determine changes in core reactivity. There are no other direct means available to check core reactivity levels. In other MODES, the NIS source range monitors are governed by LCO 3.3.1.

ACTIONS A.1 and A.2 With only one required source range neutron flux monitor OPERABLE, redundancy has been lost. Since these instruments are the only direct means of monitoring core reactivity conditions, CORE ALTERATIONS and introduction of coolant into the RCS with boron concentration less than required to meet the minimum boron concentration of LCO 3.9.1 must be suspended immediately. Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Performance of Required Action A.1 shall not preclude completion of movement of a component to a safe position. Addition to the RCS of borated water with a concentration greater than or equal to the minimum required RWST concentration shall not be considered to be a positive reactivity change (Ref 3).

B.1 With no required source range neutron flux monitor OPERABLE, action to restore a monitor to OPERABLE status shall be initiated immediately. Once initiated, action shall be continued until a source range neutron flux monitor is restored to OPERABLE status.

(continued) positive reactivity additions Suspending the movement of fuel, sources, and reactivity control components ensures that positive reactivity is not inadvertently added to the reactor core while the source range neutron flux monitor is inoperable. Required Action A.2 is modified by a Note that states that fuel assemblies, sources, and reactivity control components may be moved if necessary to facilitate repair or replacement of the inoperable source range neutron flux monitor. It may be necessary to move these items away from the locations in the core close to the source range neutron flux monitor to minimize personnel radiation dose during troubleshooting or repair. The Note also permits completion of movement of a component to a safe position, should the source range neutron flux monitor be discovered inoperable during component movement.

movement of fuel, sources, and reactivity control components within the reactor vessel

Nuclear Instrumentation B 3.9.3 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.9-10 Revision 86 ACTIONS (continued)

B.2 With no required source range neutron flux monitor OPERABLE, there are no direct means of detecting changes in core reactivity. However, since CORE ALTERATIONS and boron concentration changes inconsistent with Required Action A.2 are not to be made, the core reactivity condition is stabilized until the source range neutron flux monitors are OPERABLE. This stabilized condition is determined by performing SR 3.9.1.1 to ensure that the required boron concentration exists.

The Completion Time of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is sufficient to obtain and analyze a reactor coolant sample for boron concentration and ensures that unplanned changes in boron concentration would be identified. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is reasonable, considering the low probability of a change in core reactivity during this time period.

SURVEILLANCE REQUIREMENTS SR 3.9.3.1 SR 3.9.3.1 is the performance of a CHANNEL CHECK of required channels, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels, but each channel should be consistent with its local conditions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.3.2 SR 3.9.3.2 is the performance of a CHANNEL CALIBRATION. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. For the source range neutron detectors, performance data is obtained and evaluated. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued) positive reactivity additions

Containment Penetrations B 3.9.4 COMANCHE PEAK - UNITS 1 AND 2 B 3.9-12 Revision 86 B 3.9 REFUELING OPERATIONS B 3.9.4 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, a release of fission product radioactivity within containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY." Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the 10CFR50, Appendix J leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100. Additionally, the containment provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment. If closed, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced. Alternatively, the equipment hatch can be open provided it can be installed with a minimum of four bolts holding it in place.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 unit operation in accordance with LCO 3.6.2, "Containment Air Locks."

Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required.

During periods of unit shutdown when containment closure is not required, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; however both personnel air lock doors may be open provided that one personnel air (continued) recently recently (i.e., fuel that has occupied part of a critical reactor core within the previous 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />).

Containment Penetrations B 3.9.4 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.9-13 Revision 86 BACKGROUND (continued) lock door is capable of being closed, and one emergency air lock door is closed.

The requirements for containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted from escaping to the environment. The closure restrictions are sufficient to restrict fission product radioactivity release from containment due to a fuel handling accident during refueling.

The containment ventilation isolation system includes three subsystems.

The Containment Purge System includes a 48 inch supply penetration and a 48 inch exhaust penetration. The Containment Pressure Relief System includes an 18 inch exhaust penetration. The Hydrogen Purge System includes a 12 inch supply penetration and a 12 inch exhaust penetration.

During MODES 1, 2, 3, and 4, the two valves in each of the Containment Purge System and Hydrogen Purge System supply and exhaust penetrations are secured in the closed position. The two valves in the Containment Pressure Relief System penetration can be opened continuously, but are closed automatically by the Engineered Safety Features Actuation System (ESFAS). None of the subsystems are subject to a Specification in MODE 5.

In MODE 6, large air exchangers are necessary to conduct refueling operations. The normal 48 inch Containment Purge System is used for this purpose, and all four valves are closed by the Containment Radiation Monitor in accordance with LCO 3.3.6, Containment Ventilation Isolation Instrumentation."

The Containment Pressure Relief System remain operational in MODE 6, and both valves are also closed by the Containment Ventilation Isolation Instrumentation.

The Hydrogen Purge System is not normally used in MODE 6. However, all six of the twelve inch valves are also closed by the Containment Ventilation Isolation Instrumentation.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side. Isolation may be achieved by a closed automatic isolation valve or manual isolation valve, or by a blind flange or equivalent. Equivalent isolation methods must be approved and may include use of a material that can provide a temporary, atmospheric pressure, ventilation barrier for the other containment penetrations during fuel movements.

(continued) recently irradiated Involving recently irradiated fuel

Containment Penetrations B 3.9.4 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-14 Revision 86 APPLICABLE SAFETY ANALYSES During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents, analyzed in Reference 2, include dropping a single irradiated fuel assembly in either the containment or fuel building with no credit for isolation or filtration. The requirements of LCO 3.9.7, "Refueling Cavity Water Level,"

and the minimum decay time of the Technical Requirements Manual (Ref. 4) prior to CORE ALTERATIONS ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 10 CFR 100. Standard Review Plan, Section 15.7.4, Rev. 1 (Ref. 2), defines "well within" 10 CFR 100 to be 25% or less of the 10 CFR 100 values. Containment penetration closure is not required to meet the acceptance limits for offsite radiation exposure of 25% of 10 CFR 100 values (Ref 3).

Containment penetrations satisfy Criterion 4 of 10CFR50.36(c)(2)(ii).

LCO This LCO limits the consequences of a fuel handling accident in containment by limiting the potential escape paths for fission product radioactivity released within containment. The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment ventilation penetrations, the personnel air locks, and the equipment hatch, which must be capable of being closed. For the OPERABLE containment ventilation penetrations, this LCO ensures that these penetrations are isolable by the Containment Ventilation Isolation System. The OPERABILITY requirements for this LCO ensure that the automatic ventilation isolation valve closure function specified in the FSAR can be achieved and, therefore, meet the assumptions used in the safety analysis to ensure that releases through the valves are terminated, such that radiological doses are within the acceptance limit.

Both containment personnel air lock doors may be open during movement of irradiated fuel or CORE ALTERATION, provided an air lock door is capable of being closed and the water level in the refueling pool is maintained as required. Administrative controls ensure that: 1) appropriate personnel are aware of the open status of the containment during movement of irradiated fuel or CORE ALTERATIONS, 2) specified individuals are designated and readily available to close the air lock following an evacuation that would occur in the event of a fuel handling accident, and 3) any obstructions (e.g.,

cables and hoses) that would prevent rapid closure of an open air lock can be quickly removed.

(continued) irradiated fuel movement with containment closure capability or a minimum decay time of 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> without containment closure capability, recently recently involving recently irradiated fuel in conjunction with involving recently irradiated fuel

Containment Penetrations B 3.9.4 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.9-15 Revision 86 LCO (continued)

The LCO is modified by a NOTE allowing penetration flow paths with direct access from the containment atmosphere to the outside atmosphere to be unisolated under administrative controls. Administrative controls ensure that

1) appropriate personnel are aware of the open status of the penetration flow path during CORE ALTERNATIONS or movement of irradiated fuel assemblies within containment, and 2) specified individuals are designated and readily available to isolate the flow path in the event of a fuel handling accident.

The equipment hatch may be open during movement of irradiated fuel or CORE ALTERNATIONS provided the hatch is capable of being closed and the water level in the refueling pool is maintained as required. Administrative controls ensure that 1) appropriate personnel are aware of the open status of the containment during movement of irradiated fuel or CORE ALTERNATIONS, 2) specified individuals are designated and readily available to close the equipment hatch following an evacuation that would occur in the event of a fuel handling accident, and 3) any obstructions (e.g.,

cables and hoses) that would prevent rapid closure of the equipment hatch can be quickly removed.

APPLICABILITY The containment penetration requirements are applicable during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment because this is when there is a potential for a fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1. In MODES 5 and 6, when CORE ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for a fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status.

ACTIONS A.1 and A.2 If the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere is not in the required status, including the containment ventilation isolation system not capable of automatic actuation when the isolation valves are open, the unit must be placed in a condition where the isolation function is not needed. This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position.

(continued) recently recently recently recently recently is the limiting

Containment Penetrations B 3.9.4 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.9-16 Revision 86 SURVEILLANCE REQUIREMENTS SR 3.9.4.1 This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open isolation valves will demonstrate that the required valves are not blocked from closing. Also the Surveillance will demonstrate that each valve operator has motive power, which will ensure that each required valve is capable of being closed by an OPERABLE automatic containment ventilation isolation signal.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.9.2 This Surveillance demonstrates that the necessary hardware, tools, and equipment are available to install the equipment hatch. The equipment hatch is provided with a set of hardware, tools, and equipment for moving the hatch from its storage location and installing it in the opening. The required set of hardware, tools, and equipment shall be inspected to ensure that they can perform the required functions.

The Surveillance is performed during CORE ALTERATIONS or movement of irradiated fuel assemblies within the containment. The Surveillance is modified by a Note which only requires that the Surveillance be met for an open equipment hatch. If the equipment hatch is installed in its opening, the availability of the means to install the hatch is not required. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.4.3 This Surveillance demonstrates that each required containment ventilation valve actuates to its isolation position on manual initiation or on an actual or simulated high radiation signal from a containment atmosphere gaseous monitoring instrumentation channel. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Section 15.7.4.

2.

NUREG-0800, Section 15.7.4, Rev. 1, July 1981.

3.

NUREG-0797, Section 15.4.8, Supplement 22, January 1990.

4.

Technical Requirements Manual recently