Text

Application to Revise Technical Specifications to Adopt TSTF-432, Change in Technical Specifications End States (WCAP-16294)
	ML25209A150
Person / Time
Site:	Comanche Peak
Issue date:	07/24/2025
From:	Christopher Jackson; Luminant Generation Co, Vistra Corp
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	CP-202500207, TXX-25040, WCAP-16294
	Download: ML25209A150 (1)
	v • d • e

6555 SIERRA DRIVE IRVING, TEXAS 75039 o 214-812-4600 VISTRACORP.COM Comanche Peak Nuclear Power Plant Christopher Jackson Site Vice President P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 CP-202500207 TXX-25040 July 24, 2025 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:

Application to Revise Technical Specifications to Adopt TSTF-432, "Change in Technical Specifications End States (WCAP-16294)"

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 (CPNPP), Units 1 and 2.

The proposed amendment would modify TS requirements to incorporate risk-informed requirements for selected Required Action end states. Specifically, the proposed change would permit a Required Action end state of Mode 4 rather than an end state of Mode 5. These changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-432, "Change in Technical Specifications End States (WCAP-16294).

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides the revised (clean) TS pages. provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

Vistra OpCo requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.

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-25040 Page 2 of 2 I state under penalty of perjury that the foregoing is true and correct.

Executed on July 24, 2025.

Sincerely,

~~-

Christopher Jackson

Enclosure:

Evaluation of the Proposed Change : Proposed Technical Specification Markup : Proposed Technical Specification Clean : Proposed Technical Specification Bases Change (information only) cc:

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

William Orders, NRR [William.Orders@nrc.gov]

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

Mr. Robert Free [robert.free@dshs.state.tx.us]

Environmental Monitoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P. 0. Box 149347 Austin TX, 78714-9347

Enclosure to TXX-25040 Page 1 of 5 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

Vistra Operations Company LLC. (Vistra OpCo) requests adoption of TSTF-432, Change in Technical Specifications End States (WCAP-16294), which is an approved change to the Standard Technical Specifications (STS), into the Commanche Peak Nuclear Power Plant, Units 1 and 2, Technical Specifications. TSTF-432 incorporates risk-informed requirements for selected Required Action end states.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Vistra OpCo has reviewed Westinghouse Topical Report (TR) WCAP-16294 (Reference 1), the Nuclear Regulatory Commission (NRC) safety evaluation for WCAP-16294 (Reference 2), TSTF-432-A, Revision 1 (Reference 3), and the associated NRC model safety evaluation (Reference 4).

Vistra OpCo has concluded that the justifications presented in the Westinghouse Topical Report, TSTF-432, and the associated safety evaluations prepared by the NRC staff are applicable to Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2, and justify this amendment for the incorporation of the changes to the CPNPP Technical Specifications (TS)

On November 27, 2012, the NRC published a Federal Register Notice stating that RG 1.182 has been withdrawn and the subject matter has been incorporated into RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." RG 1.160 endorses NUMARC 93-01, Revision 4A, dated April 2011. The NRC model safety evaluation reference Regulatory Guide (RG) 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," which endorses the February 2000 version of NUMARC 93-01, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." References and commitments to RG 1.182 in these documents are assumed to refer to RG 1.160 and Revision 4A of NUMARC 93-01 instead of RG 1.182.

2.2 Variations Vistra OpCo is proposing the following variations from the TS changes described in TSTF-432 or the applicable parts of the NRC staffs safety evaluation. The proposed changes of TSTF-432 were based on STS rev 3.0 and 3.1.

The following STS LCOs are not applicable to CPNPP; STS LCO 3.3.8 FBACS Actuation Instrumentation, STS LCO 3.6.11 Iodine Cleanup System (ICS) (Atmospheric and Subatmospheric),

STS LCO 3.6.12 Vacuum Relief Valves (Atmospheric and Ice Condenser),

STS LCO 3.6.13 Shield Building Air Cleanup System (SBACS) (Dual and Ice Condenser),

STS LCO 3.6.14 Air Return System (ARS) (Ice Condenser),

STS LCO 3.6.18 Containment Recirculation Drains (Ice Condenser).

CPNPP TS LCO 3.3.2 Conditions B, C and K were modified by CPNPPs adoption of TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, which consolidated

Enclosure to TXX-25040 Page 2 of 5 the Mode change Required Actions of these conditions into a new Condition M. Changing the Condition M from a Mode 5 completion time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to a Mode 4 completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is consistent with the application of TSTF-432 and STS Rev 5. This change does not affect the applicability of this traveler.

CPNPP TS LCO 3.4.15 Conditions C, D and E were modified by CPNPPs adoption of TSTF-513 PWR Operability Requirements and Actions for RCS Leakage Instrumentation, which added a new condition to this LCO. Changing the Condition F from a Mode 5 completion time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to a Mode 4 completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is consistent with the application of TSTF-432 and STS Rev 5. This change does not affect the applicability of this traveler.

CPNPP TS LCO 3.6.6 is similar to STS Rev 3.1 LCO 3.6.6A. However, the CPNPP LCO does not address cooling. Therefore, the cooling related change in this LCO is not applicable to CPNPP.

CPNPP TS LCO 3.7.8 has an additional requirement for an SSW pump on the opposite unit and its associated cross connect to be operable that is not specifically discussed in TSTF-432 or WCAP-16294. The CPNPP Station Service Water System (SSWS) is designed as two separate 100 percent capacity trains, each with a single 100 percent capacity pump. Additionally cross-connections are provided between units such that any pump can supply any other pumps required flow. The WCAP model plant includes two independent trains with one pump in each train, and a third pump that can be aligned to either train. This is effectively the same as the CPNPP configuration with the opposite unit pump in the place of the backup pump. Therefore, this variation is bounded by the WCAP analysis and does not affect the applicability of the traveler.

CPNPP TS LCO 3.7.9 has different conditions based on Safe Shutdown Impoundment (SSI) level instead of temperature. The WCAP acknowledges the variety of water sources used to meet the requirements of the ultimate heat sink. The WCAP uses a qualitative approach for the Ultimate Heat Sink (UHS) endstate change and describes the most likely scenario for entering condition C is that the cooling capability of the ultimate heat sink is only partially degraded. This is consistent with the CPNPP Condition A for SSI level less than required. Therefore, this variation is bounded by the WCAP analysis and does not affect the applicability of the traveler.

CPNPP TS LCO 3.7.11 Control Room Air Conditioning System (CRACS) uses different system terminology than STS LCO 3.7.11 Control Room Emergency Air Temperature Control System (CREATCS), this variation and does not affect the applicability of the traveler.

CPNPP TS LCO 3.7.12 Primary Plant Ventilation System (PPVS) - ESF Filtration Trains terminology and structure is different than the STS LCO 3.7.12 Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS), STS LCO 3.7.13 Fuel Building Air Cleanup System (FBACS), and STS LCO 3.7.14 Penetration Room Exhaust Air Cleanup System (PREACS). CPNPP PPVS encompasses the STS ECCS PREACS, FBACS, and PREACS systems. CPNPP LCO 3.7.12 Condition A and B are equivalent to the STS LCOs Condition B.

CPNPP LCO 3.7.12 Condition C is the equivalent of STS LCOs Condition A. CPNPP LCO 3.7.12 Condition D is the equivalent of STS LCOs Condition C. The WCAP uses a qualitative approach to analyze the ventilation systems endstate change. The combined analysis of STS ventilation systems is applicable to the CPNPP PPVS. Therefore, this variation is bounded by the WCAP analysis and does not affect the applicability of the traveler.

Enclosure to TXX-25040 Page 3 of 5

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Vistra Operations Company LLC. (Vistra OpCo) requests adoption of TSTF-432, Change in Technical Specifications End States (WCAP-16294), which is an approved change to the Standard Technical Specifications (STS), into the Commanche Peak Nuclear Power Plant, Units 1 and 2, Technical Specifications. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Tech Spec Required Action Endstates for Westinghouse NSSS PWRs," evaluates and identifies the appropriate endstate for a number of Technical Specification Required Actions based on the risk of transitioning the unit from Mode 1 to the lower Modes. TSTF-432 incorporates risk-informed requirements for selected Required Action end states as justified in WCAP-16294.

Vistra OpCo has evaluated if a significant hazards consideration is involved with the proposed amendment(s) 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 change modifies the end state (e.g., mode or other specified condition) which the Required Actions specify must be entered if compliance with the LCO is not restored.

The requested technical specifications (TS) permit an end state of Mode 4 rather than an end state of Mode 5 contained in the current TS. In some cases, other Conditions and Required Actions are revised to implement the proposed change. Required Actions are not an initiator of any accident previously evaluated. Therefore, the proposed change does not affect the probability of any accident previously evaluated. The affected systems continued to be required to be operable by the Technical Specifications and the Completion Times specified in the Technical Specifications to restore equipment to operable status or take other remedial Actions remain unchanged. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Tech Spec Required Action Endstates for Westinghouse NSSS PWRs," demonstrates that the proposed change does not significantly increase the consequences of any accident previously evaluated.

Therefore, it is concluded that this change 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 change modifies the end state (e.g., mode or other specified condition) which the Required Actions specify must be entered if compliance with the LCO is not restored.

In some cases, other Conditions and Required Actions are revised to implement the proposed change. The change does not involve a physical alteration of the plant (i.e., no

Enclosure to TXX-25040 Page 4 of 5 new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new requirements. The change does not alter assumptions made in the safety analysis.

Therefore, it is concluded that this change 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 change modifies the end state (e.g., mode or other specified condition) which the Required Actions specify must be entered if compliance with the LCO is not restored.

In some cases, other Conditions and Required. Actions are revised to implement the proposed change. Remaining within the Applicability of the LCO is acceptable because WCAP-16294-NP-A demonstrates that the plant risk in MODE 4 is similar to or lower than MODE 5. As a result, no margin of safety is significantly affected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, Vistra OpCo concludes that the proposed change 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.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to 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 a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

5.0 REFERENCES

1.

WCAP-16294-NP-A, Revision 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010 (NRC ADAMS Accession Number ML052620374)

2.

Final Safety Evaluation for Nuclear Energy Institute Topical Report WCAP-16294-NP, Revision 0, "Risk-Informed Evaluation of Changes to Technical Specification Required Endstates for Westinghouse NSSS [Nuclear Steam Supply System] PWRs [Pressurized Water Reactors]," March 29, 2010 (NRC ADAMS Accession Number ML100820533)

Enclosure to TXX-25040 Page 5 of 5

3.

TSTF-432, Revision 1, "Change in Technical Specifications End States WCAP-16294," dated November 29, 2010 (NRC ADAMS Accession number ML103360003

4.

Federal Register, (77 FR 27814), "Model Safety Evaluation for Plant Specific Adoption of Technical Specifications Task Force Traveler TSTF-432, Revision 1, 'Change in Technical Specifications End States (WCAP-16294)' Using the Consolidated Line Item Improvement Process," May 11, 2012

Enclosure to TXX-25040 Proposed Technical Specification Markup

INSERT 1

NOTE ----------

LCO 3.0.4.a is not applicable when entering MODE 4.

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-26 SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

M. Required Action and associated Completion Time of Conditions B, C, or K not met.

M.1 Be in MODE 3.

AND M.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours N. Required Action and associated Completion Time of Conditions D, E, F, G, or L not met.

N.1 Be in MODE 3.

AND N.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours O. Required Action and associated Completion Time of Conditions H, I, or J not met.

O.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program.

CONDITION REQUIRED ACTION COMPLETION TIME Amendment No. 156, 183 4

12 INSERT 1

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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 INSERT 1 4

12

RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS)

COMANCHE PEAK - UNITS 1 AND 2 3.4-31 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE; b.

1 gpm unidentified LEAKAGE; c.

10 gpm identified LEAKAGE; and d.

150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RCS operational LEAKAGE not within limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

A.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. Required Action and associated Completion Time of Condition A not met.

OR Pressure boundary LEAKAGE exists.

OR Primary to secondary LEAKAGE not within limits B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No. 150, 156 INSERT 1 4

12

RCS PIV Leakage 3.4.14 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-34 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more flow paths with leakage from one or more RCS PIVs not within limit.

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

Each valve used to satisfy Required Action A.1 and Required Action A.2 must have been verified to meet SR 3.4.14.1 and be in the reactor coolant pressure boundary or the high pressure portion of the system.

A.1 Isolate the high pressure portion of the affected system from the low pressure portion by use of one closed manual, deactivated automatic, or check valve.

AND A.2.1 Isolate the high pressure portion of the affected system from the low pressure portion by use of a second closed manual, deactivated automatic, or check valve.

OR A.2.2 Restore RCS PIV to within limits.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Required Action and associated Completion Time for Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours C. RHR System interlock function inoperable.

C.1 Isolate the affected penetration by use of one closed manual or deactivated automatic valve.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Amendment No. 150, 156 4

INSERT 1 12

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-39 CONDITION REQUIRED ACTION COMPLETION TIME

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

Only applicable when the containment atmosphere gaseous radiation monitor is the only OPERABLE monitor.

D. Required containment sump monitor inoperable.

AND Containment air cooler condensate flow rate monitor inoperable.

D.1 Analyze grab samples of the containment atmosphere.

AND D.2.1 Restore required containment sump monitor to OPERABLE status.

OR D.2.2 Restore containment air cooler condensate flow rate monitor to OPERABLE status.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7 days 7 days E. Required containment atmosphere radioactivity monitor inoperable.

AND Containment air cooler condensate flow rate monitor inoperable.

E.1 Restore required containment atmosphere radioactivity monitor to OPERABLE status.

OR E.2 Restore containment air cooler condensate flow rate monitor to OPERABLE status.

30 days 30 days F. Required Action and associated Completion Time not met.

F.1 Be in MODE 3.

AND F.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours G. All required monitors inoperable.

G.1 Enter LCO 3.0.3.

Immediately Amendment No. 150, 156, 176 4

INSERT 1 12

ECCS -- Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

COMANCHE PEAK - UNITS 1 AND 2 3.5-7 3.5.3 ECCS -- Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

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

An RHR train may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned to the ECCS mode of operation.

APPLICABILITY:

MODE 4 ACTIONS

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

LCO 3.0.4.b is not applicable to ECCS Centrifugal Pump subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS residual heat removal (RHR) subsystem inoperable.

A.1 Initiate action to restore required ECCS RHR subsystem to OPERABLE status.

Immediately B. Required ECCS Centrifugal Charging Pump subsystem inoperable.

B.1 Restore required ECCS Centrifugal Charging Pump subsystem to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time of Condition B not met.

C.1 Be in MODE 5.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Amendment No. 150, 156 train train INSERT 1

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

COMANCHE PEAK - UNITS 1 AND 2 3.5-9 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RWST boron concentration not within limits.

OR RWST borated water temperature not within limits.

A.1 Restore RWST to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months B. RWST inoperable for reasons other than Condition A.

B.1 Restore RWST to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No. 150, 156 4

INSERT 1 12

Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.6-16 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray train inoperable.

A.1 Restore containment spray train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 84 hours C. Two containment spray trains inoperable.

C.1 Enter LCO 3.0.3.

Immediately Amendment No. 156, 183 4

INSERT 1 54

Spray Additive System 3.6.7 3.6 CONTAINMENT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.6-18 3.6.7 Spray Additive System LCO 3.6.7 The Spray Additive System shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME A. Spray Additive System inoperable.

A.1 Restore Spray Additive System to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 84 hours SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify the spray additive system ensures an equilibrium sump pH 7.1 using NaOH.

In accordance with the Technical Requirements Manual Amendment No. 150 4

INSERT 1 54

CCW System 3.7.7 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-18 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCW train inoperable. -----------------------NOTE------------------------

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE 4," for residual heat removal loops made inoperable by CCW.

A.1 Restore CCW train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No. 156, 183 4

INSERT 1 12

SSWS 3.7.8 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.7-21 CONDITION REQUIRED ACTION COMPLETION TIME B. One SSWS train inoperable.

B.1

NOTES-------------------

1.

Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources -- Operating," for emergency diesel generator made inoperable by SSWS.

2.

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -- MODE 4," for residual heat removal loops made inoperable by SSWS.

Restore SSWS train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program C. Required Action and associated Completion Time of Condition A or B not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No. 178, 183 4

INSERT 1 12

UHS 3.7.9 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-23 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The Safe Shutdown Impoundment (SSI) shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME A. SSI level less than required.

A.1 Restore SSI level to within limits.

7 days B. Required Action and associated Completion Time of Condition A not met.

OR SSI inoperable for reasons other than Condition A.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of SSI is 770 ft mean sea level.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 150, 156 4

INSERT 1 12

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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 4

INSERT 1 12

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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 4

INSERT 1 12

PPVS - ESF Filtration Trains 3.7.12 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-31 3.7.12 Primary Plant Ventilation System (PPVS) - ESF Filtration Trains LCO 3.7.12 Two PPVS trains shall be OPERABLE APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. With one or more PPVS trains unable to maintain a negative pressure envelope in the Auxiliary, Safeguards, and Fuel Buildings 0.05 inch water gauge.

A.1 Restore PPVS trains to OPERABLE status.

30 days B. With one or more PPVS trains unable to maintain a negative pressure envelope in the Auxiliary, Safeguards, and Fuel Buildings 0.01 inch water gauge.

B.1 Restore ability of PPVS trains to maintain a negative pressure envelope of 0.01 inch water gauge pressure.

7 days C. One PPVS train inoperable for any reason except Conditions A or B.

C.1 Restore PPVS train to OPERABLE status.

7 days D. Required Actions and associated Completion Times not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No. 150, 156 4

INSERT 1 12

AC Sources -- Operating 3.8.1 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-6 CONDITION REQUIRED ACTION COMPLETION TIME F. One SI sequencer inoperable.

F.1 --------------------NOTE---------------------

One required SI sequencer channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other channel is operable.

Restore SI sequencer to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program G. Required Action and associated Completion Time of Condition A, B, C, D, E, or F not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours H. Three or more required AC sources inoperable.

H.1 Enter LCO 3.0.3.

Immediately I.

One Blackout Sequencer inoperable I.1 Declare associated DG inoperable Immediately Amendment No. 177, 183 4

INSERT 1 12

DC Sources - Operating 3.8.4 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-25 CONDITION REQUIRED ACTION COMPLETION TIME B. One or two batteries on one train inoperable.

B.1 Restore affected battery(ies) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program C. One DC electrical power subsystem inoperable for reasons other than Condition A or B.

C.1 Restore DC electrical power subsystem to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program D. Required Action and Associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No. 170, 183 4

INSERT 1 12

Inverters - Operating 3.8.7 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-35 SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, and alignment to required AC vital buses.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 156, 183 4

INSERT 1 12

Distribution Systems - Operating 3.8.9 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-39 SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical power distribution subsystem inoperable.

C.1 Restore DC electrical power distribution subsystem to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours E. Two trains with inoperable distribution subsystems that result in a loss of safety function.

E.1 Enter LCO 3.0.3.

Immediately SURVEILLANCE FREQUENCY SR 3.8.9.1 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. 156, 183 4

INSERT 1 12

Enclosure to TXX-25040 Proposed Technical Specifications Clean

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.3-26 SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

M. Required Action and associated Completion Time of Conditions B, C, or K not met.

M.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours N. Required Action and associated Completion Time of Conditions D, E, F, G, or L not met.

N.1 Be in MODE 3.

AND N.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours O. Required Action and associated Completion Time of Conditions H, I, or J not met.

O.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program.

CONDITION REQUIRED ACTION COMPLETION TIME Amendment No. 156, 183, TBD M.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

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 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 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, TBD C.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

RCS Operational LEAKAGE 3.4.13 3.4 REACTOR COOLANT SYSTEM (RCS)

COMANCHE PEAK - UNITS 1 AND 2 3.4-31 3.4.13 RCS Operational LEAKAGE LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a.

No pressure boundary LEAKAGE; b.

1 gpm unidentified LEAKAGE; c.

10 gpm identified LEAKAGE; and d.

150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RCS operational LEAKAGE not within limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

A.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. Required Action and associated Completion Time of Condition A not met.

OR Pressure boundary LEAKAGE exists.

OR Primary to secondary LEAKAGE not within limits B.1 Be in MODE 3.

AND.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No. 150, 156, TBD B.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

RCS PIV Leakage 3.4.14 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-34 CONDITION REQUIRED ACTION COMPLETION TIME A. One or more flow paths with leakage from one or more RCS PIVs not within limit.

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

Each valve used to satisfy Required Action A.1 and Required Action A.2 must have been verified to meet SR 3.4.14.1 and be in the reactor coolant pressure boundary or the high pressure portion of the system.

A.1 Isolate the high pressure portion of the affected system from the low pressure portion by use of one closed manual, deactivated automatic, or check valve.

AND A.2.1 Isolate the high pressure portion of the affected system from the low pressure portion by use of a second closed manual, deactivated automatic, or check valve.

OR A.2.2 Restore RCS PIV to within limits.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Required Action and associated Completion Time for Condition A not met.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours C. RHR System interlock function inoperable.

C.1 Isolate the affected penetration by use of one closed manual or deactivated automatic valve.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Amendment No. 150, 156, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

B.2

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.4-39 CONDITION REQUIRED ACTION COMPLETION TIME

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

Only applicable when the containment atmosphere gaseous radiation monitor is the only OPERABLE monitor.

D. Required containment sump monitor inoperable.

AND Containment air cooler condensate flow rate monitor inoperable.

D.1 Analyze grab samples of the containment atmosphere.

AND D.2.1 Restore required containment sump monitor to OPERABLE status.

OR D.2.2 Restore containment air cooler condensate flow rate monitor to OPERABLE status.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7 days 7 days E. Required containment atmosphere radioactivity monitor inoperable.

AND Containment air cooler condensate flow rate monitor inoperable.

E.1 Restore required containment atmosphere radioactivity monitor to OPERABLE status.

OR E.2 Restore containment air cooler condensate flow rate monitor to OPERABLE status.

30 days 30 days F. Required Action and associated Completion Time not met.

F.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours G. All required monitors inoperable.

G.1 Enter LCO 3.0.3.

Immediately Amendment No. 156, 176, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

F.2

ECCS -- Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

COMANCHE PEAK - UNITS 1 AND 2 3.5-7 3.5.3 ECCS -- Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

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

An RHR train may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned to the ECCS mode of operation.

APPLICABILITY:

MODE 4 ACTIONS

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

LCO 3.0.4.b is not applicable to ECCS Centrifugal Pump subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS train inoperable.

A.1 Immediately Amendment No. 150, 156, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Initiate action to restore required ECCS train to OPERABLE status.

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

COMANCHE PEAK - UNITS 1 AND 2 3.5-9 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RWST boron concentration not within limits.

OR RWST borated water temperature not within limits.

A.1 Restore RWST to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months B. RWST inoperable for reasons other than Condition A.

B.1 Restore RWST to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No. 150, 156, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

C.2

Containment Spray System 3.6.6 3.6 CONTAINMENT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.6-16 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray train inoperable.

A.1 Restore containment spray train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 54 hours C. Two containment spray trains inoperable.

C.1 Enter LCO 3.0.3.

Immediately Amendment No. 156, 183, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

B.2

Spray Additive System 3.6.7 3.6 CONTAINMENT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.6-18 3.6.7 Spray Additive System LCO 3.6.7 The Spray Additive System shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME A. Spray Additive System inoperable.

A.1 Restore Spray Additive System to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 54 hours SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify the spray additive system ensures an equilibrium sump pH 7.1 using NaOH.

In accordance with the Technical Requirements Manual Amendment No. 150, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

B.2

CCW System 3.7.7 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-18 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCW train inoperable. -----------------------NOTE------------------------

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -

MODE 4," for residual heat removal loops made inoperable by CCW.

A.1 Restore CCW train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No. 156, 183, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

B.2

SSWS 3.7.8 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.7-21 CONDITION REQUIRED ACTION COMPLETION TIME B. One SSWS train inoperable.

B.1

NOTES-------------------

1.

Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources -- Operating," for emergency diesel generator made inoperable by SSWS.

2.

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops -- MODE 4," for residual heat removal loops made inoperable by SSWS.

Restore SSWS train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program C. Required Action and associated Completion Time of Condition A or B not met.

C.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No. 178, 183, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

C.2

UHS 3.7.9 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-23 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The Safe Shutdown Impoundment (SSI) shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME A. SSI level less than required.

A.1 Restore SSI level to within limits.

7 days B. Required Action and associated Completion Time of Condition A not met.

OR SSI inoperable for reasons other than Condition A.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of SSI is 770 ft mean sea level.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 150, 156, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

B.2

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 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 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, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

C.2

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 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 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, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

B.2

PPVS - ESF Filtration Trains 3.7.12 3.7 PLANT SYSTEMS COMANCHE PEAK - UNITS 1 AND 2 3.7-31 3.7.12 Primary Plant Ventilation System (PPVS) - ESF Filtration Trains LCO 3.7.12 Two PPVS trains shall be OPERABLE APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. With one or more PPVS trains unable to maintain a negative pressure envelope in the Auxiliary, Safeguards, and Fuel Buildings 0.05 inch water gauge.

A.1 Restore PPVS trains to OPERABLE status.

30 days B. With one or more PPVS trains unable to maintain a negative pressure envelope in the Auxiliary, Safeguards, and Fuel Buildings 0.01 inch water gauge.

B.1 Restore ability of PPVS trains to maintain a negative pressure envelope of 0.01 inch water gauge pressure.

7 days C. One PPVS train inoperable for any reason except Conditions A or B.

C.1 Restore PPVS train to OPERABLE status.

7 days Amendment No. 150, 156, TBD

PPVS - ESF Filtration Trains 3.7.12 COMANCHE PEAK - UNITS 1 AND 2 3.7-31a ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Actions and associated Completion Times not met.

D.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No. TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

D.2

AC Sources -- Operating 3.8.1 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-6 CONDITION REQUIRED ACTION COMPLETION TIME F. One SI sequencer inoperable.

F.1 --------------------NOTE---------------------

One required SI sequencer channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other channel is operable.

Restore SI sequencer to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program G. Required Action and associated Completion Time of Condition A, B, C, D, E, or F not met.

G.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours H. Three or more required AC sources inoperable.

H.1 Enter LCO 3.0.3.

Immediately I.

One Blackout Sequencer inoperable I.1 Declare associated DG inoperable Immediately Amendment No. 177, 183, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

G.2

DC Sources - Operating 3.8.4 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-25 CONDITION REQUIRED ACTION COMPLETION TIME B. One or two batteries on one train inoperable.

B.1 Restore affected battery(ies) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program C. One DC electrical power subsystem inoperable for reasons other than Condition A or B.

C.1 Restore DC electrical power subsystem to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program D. Required Action and Associated Completion Time not met.

D.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No. 170, 183, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

D.2

Inverters - Operating 3.8.7 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-35 SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, and alignment to required AC vital buses.

In accordance with the Surveillance Frequency Control Program.

Amendment No. 156, 183, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

B.2

Distribution Systems - Operating 3.8.9 ACTIONS (continued)

COMANCHE PEAK - UNITS 1 AND 2 3.8-39 SURVEILLANCE REQUIREMENTS CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical power distribution subsystem inoperable.

C.1 Restore DC electrical power distribution subsystem to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two trains with inoperable distribution subsystems that result in a loss of safety function.

E.1 Enter LCO 3.0.3.

Immediately SURVEILLANCE FREQUENCY SR 3.8.9.1 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. 156, 183, TBD

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

D.2

Enclosure to TXX-25040 Proposed Technical Specification Bases Change (information only)

ESFAS Instrumentation B 3.3.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-90 Revision 89 ACTIONS A.1 (continued)

Condition A addresses the situation where one or more channels or trains for one or more Functions are inoperable at the same time. The Required Action is to refer to Table 3.3.2-1 and to take the Required Actions for the protection functions affected. The Completion Times are those from the referenced Conditions and Required Actions.

B.1 Condition B applies to manual initiation of:

SI; Containment Spray; Phase A Isolation; and Phase B Isolation.

This action addresses the train orientation of the SSPS for the functions listed above. If a channel or train is inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to return it to an OPERABLE status. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

Note that for containment spray and Phase B isolation, failure of one or both channels in one train renders the train inoperable. Condition B, therefore, encompasses both situations. The specified Completion Time is reasonable considering that there are two automatic actuation trains and another manual initiation train OPERABLE for each Function, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months total time) and in MODE 5 within an additional 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months in accordance with Condition M.

C.1 Condition C applies to the automatic actuation logic and actuation relays for the following functions:

SI; Containment Spray; Phase A Isolation; (continued) overall plant risk is reduced 4

6

( 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months total time)

ESFAS Instrumentation B 3.3.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-91 Revision 89 ACTIONS C.1 (continued)

Phase B Isolation; and Semi-Automatic Switchover to Containment Sump.

This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to restore the train to OPERABLE status. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed for restoring the inoperable train to OPERABLE status is justified in Reference 12. The specified Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months total time) and in MODE 5 within an additional 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months total time) in accordance with Condition M.

The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing, provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption of WCAP-10271-P-A (Ref. 6) that 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the average time required to perform train surveillance.

Consistent with the requirement in Reference 12 to include Tier 2 insights into the decision-making process before taking equipment out of service, restrictions on concurrent removal of certain equipment when a logic train is inoperable for maintenance are included (note that these restrictions do not apply when a logic train is being tested under the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months bypass Note of Condition C). Entry into Condition C is not a typical, pre-planned evolution during power operation, other than for surveillance testing. Since Condition C is typically entered due to equipment failure, it follows that some of the following restrictions may not be met at the time of Condition C entry. If this situation were to occur during the 24-hour Completion Time of Required Action C.1, the Configuration Risk Management Program will assess the emergent condition and direct activities to restore the inoperable logic train and exit Condition C or fully implement these restriction or perform a plant shutdown, as appropriate from a risk management perspective. The following restrictions will be observed:

To preserve ATWS mitigation capability, activities that degrade the availability of the auxiliary feedwater system, RCS pressure relief system (pressurizer PORVs and safety valves), AMSAC, or turbine (continued) overall plant risk is reduced 6

4 36

ESFAS Instrumentation B 3.3.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-98 Revision 89 ACTIONS K.1 (continued)

Function requires the bistables to energize to perform their required action.

The failure of up to two channels will not prevent the operation of this Function. However, placing a failed channel in the tripped condition could result in a premature switchover to the sump, prior to the injection of the minimum volume from the RWST. Placing the inoperable channel in bypass results in a two-out-of-three logic configuration, which satisfies the requirement to allow another failure without disabling actuation of the switchover when required. Restoring the channel to OPERABLE status or placing the inoperable channel in the bypass condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient to ensure that the Function remains OPERABLE, and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is justified in References 8 and 12. If the channel cannot be returned to OPERABLE status or placed in the bypass condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the unit must be brought to MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months in accordance with Condition M. In MODE 5, the unit does not have any analyzed transients or conditions that require the explicit use of the protection functions noted above.

The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing routine surveillance testing. The channel to be tested can be tested in bypass with the inoperable channel also in bypass. The total of 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months to reach MODE 3 and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for a second channel to be bypassed is acceptable based on the results of References 8 and 12.

L.1 Condition L applies to the P-11 interlock.

With one or more required channel(s) inoperable, the operator must verify that the interlock is in the required state for the existing unit condition by observation of the permissive annunciator windows. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is equal to the time allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the interlock is not in the required state (or placed in the required state) for the existing unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in accordance with Condition N. Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.

(continued) placed in a MODE in which overall plant risk is reduced.

This is done by placing the unit in at least 4

6

ESFAS Instrumentation B 3.3.2 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-99 Revision 89 ACTIONS (continued)

M.1 and M.2 If the Required Action and associated Completion Time of Condition B, C or K is not met, the unit must be placed in a MODE in which the LCO does not apply. This is accomplished by placing the unit in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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. In MODE 4, these Functions are no longer required OPERABLE.

N.1 and N.2 If the Required Action and associated Completion Time of Condition D, E, F, G or L is not met, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . 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.

In MODE 4, these Functions are no longer required OPERABLE.

O.1 If the Required Action and associated Completion Time of Condition H, I, or J is not met, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, these Functions are no longer required OPERABLE.

SURVEILLANCE REQUIREMENTS The SRs for each ESFAS Function are identified by the SRs column of Table 3.3.2-1.

A Note has been added to the SR Table to clarify that Table 3.3.2-1 determines which SRs apply to which ESFAS Functions.

Note that each channel of process protection supplies both trains of the ESFAS. When testing channel I, train A and train B must be examined.

Similarly, train A and train B must be examined when testing channel II, channel III, and channel IV. The CHANNEL CALIBRATION and COTs are performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies.

(continued) overall plant risk is reduced 4

an additional Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 16). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action M.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

ESFAS Instrumentation B 3.3.2 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-106 Revision 89 REFERENCES 1.

FSAR, Chapter 6.

2.

FSAR, Chapter 7.

3.

FSAR, Chapter 15.

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

7.

Technical Requirements Manual.

8.

WCAP-10271-P-A, Supplement 3, September 1990.

9.

"Westinghouse Setpoint Methodology for Protection Systems Comanche Peak Unit 1, Revision 1," WCAP-12123, Revision 2, April, 1989.

10.

WCAP-13877-P-A, Revision 2, August 2000.

11.

Elimination of Periodic Protection Channel Response Time Tests, WCAP-14036-P-A, Revision 1, October 6, 1998.

12.

Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, WCAP-14333-P-A, Revision 1, October 1998.

13.

Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, WCAP-15376-P-A, Revision 1, March 2003.

14. to TSTF-569, "Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only Response Time Testing.

15.

10 CFR 50.46.

16. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

CREFS Actuation Instrumentation B 3.3.7 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-149 Revision 89 ACTIONS A.1 and A.2 (continued)

If one train is inoperable, or one radiation monitor channel is inoperable in one or more Functions, 7 days are permitted to restore it to OPERABLE status. The 7 day Completion Time is the same as is allowed if one train of the mechanical portion of the system is inoperable. The basis for this Completion Time is the same as provided in LCO 3.7.10. If the channel/train cannot be restored to OPERABLE status, the affected CREFS train must be placed in the emergency recirculation mode of operation. This accomplishes the actuation instrumentation Function and places the unit in a conservative mode of operation.

Alternatively, the makeup air supply fan from the affected air intake may be secured. This action is modified by a note that states it is applicable only to the control room radiation monitors. This action ensures that in the event of a radiological accident, the control room will not be supplied air through an unmonitored air intake.

B.1.1, B.1.2, and B.2 Condition B applies to the failure of two CREFS actuation trains, two radiation monitor channels, or two manual channels. The first Required Action is to place one CREFS train in the emergency recirculation mode of operation immediately. This accomplishes the actuation instrumentation Function that may have been lost and places the unit in a conservative mode of operation. The applicable Conditions and Required Actions of LCO 3.7.10 must also be entered for one CREFS train made inoperable by inoperable actuation instrumentation. This ensures appropriate limits are placed upon train inoperability as discussed in the Bases for LCO 3.7.10.

Alternatively, as described in the Note, if the affected channels are both of the north air intake radiation monitors or both of the south air intake radiation monitors, the control room makeup supply fan from the affected air intake is required to be immediately secured.

C.1 and C.2 Condition C applies when the Required Action and associated Completion Time for Condition A or B have not been met and the unit is in MODE 1, 2, 3, or 4. The unit must be brought to a MODE in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

(continued)

paragraph break*

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

paragraph break*

overall plant risk is reduced 4

12

CREFS Actuation Instrumentation B 3.3.7 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.3-151 Revision 89 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.7.3 Not Used.

SR 3.3.7.4 Not Used.

SR 3.3.7.5 Not Used.

SR 3.3.7.6 SR 3.3.7.6 is the performance of a TADOT. This test is a check of the Manual Actuation Functions. Each Manual Actuation Function is tested up to, and including, the master relay coils. In some instances, the test includes actuation of the end device.

The test also includes trip devices that provide actuation signals directly to the Solid State Protection System, bypassing the analog process control equipment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Functions tested have no setpoints associated with them.

SR 3.3.7.7 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

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

REFERENCES 1.

FSAR Section 6.4.

2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

RCS Operational LEAKAGE B 3.4.13 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-66 Revision 85 APPLICABILITY In MODES 1, 2, 3, and 4, the potential for RCPB LEAKAGE is greatest when the RCS is pressurized.

In MODES 5 and 6, LEAKAGE limits are not required because the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.

LCO 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage," measures leakage through each individual PIV and can impact this LCO. Of the two PIVs in series in each isolated line, leakage measured through one PIV does not result in RCS LEAKAGE when the other is leak tight. If both valves leak and result in a loss of mass from the RCS, the loss must be included in the allowable identified LEAKAGE.

ACTIONS A.1 Unidentified LEAKAGE or identified LEAKAGE in excess of the LCO limits must be reduced to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This Completion Time allows time to verify leakage rates and either identify unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further deterioration of the RCPB.

B.1 and B.2 If any pressure boundary LEAKAGE exists or primary to secondary LEAKAGE is not within limit, or if any unidentified or identified LEAKAGE, cannot be reduced to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the reactor must be brought to lower pressure conditions to reduce the severity of the LEAKAGE and its potential consequences. It should be noted that LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE. The reactor must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This action reduces the LEAKAGE and also reduces the factors that tend to degrade the pressure boundary.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 5, the pressure stresses acting on the RCPB are much lower, and further deterioration is much less likely.

SURVEILLANCE REQUIREMENTS SR 3.4.13.1 Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of (continued) 4 12 4

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 9). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 9, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

RCS Operational LEAKAGE B 3.4.13 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.4-68 Revision 85 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.13.2 This SR verifies that primary to secondary LEAKAGE is less than orequal to 150 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this SR is not met, the performance criterion is not met and LCO 3.4.17, Steam Generator Tube Integrity, should be entered. The 150 gallons per day limit is measured at room temperature as described in Reference 8. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the primary to secondary LEAKAGE should be conservatively assumed to be from one SG.

The Surveillance is modified by a Note which states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation. For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program and recognizes the importance of early leakage detection in the prevention of accidents. The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Ref. 8).

REFERENCES 1.

10 CFR 50, Appendix A, GDC 4 and 30.

2.

Regulatory Guide 1.45, May 1973.

3.

FSAR, Section 15.

4.

FSAR, Section 3.6B.

5.

NUREG-1061, Volume 3, November 1984.

6.

10 CFR 100.

7.

NEI 97-06, Steam Generator Program Guidelines.

8.

EPRI, Pressurized Water Reactor Primary-to-Secondary Leak Guidelines.

9. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

RCS PIV Leakage B 3.4.14 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-71 Revision 85 APPLICABILITY In MODES 1, 2, 3, and 4, this LCO applies because the PIV leakage potential is greatest when the RCS is pressurized. In MODE 4, valves in the RHR flow path are not required to meet the requirements of this LCO when in, or during the transition to or from, the RHR mode of operation.

In MODES 5 and 6, leakage limits are not provided because the lower reactor coolant pressure results in a reduced potential for leakage and for a LOCA outside the containment.

ACTIONS The Actions are modified by two Notes. Note 1 provides clarification that each flow path allows separate entry into a Condition. This is allowed based upon the functional independence of the flow path. Note 2 requires an evaluation of affected systems if a PIV is inoperable. The leakage may have affected system operability, or isolation of a leaking flow path with an alternate valve may have degraded the ability of the interconnected system to perform its safety function.

A.1 and A.2 The flow path must be isolated by two valves. Required Actions A.1 and A.2 are modified by a Note that the valves used for isolation must meet the same leakage requirements as the PIVs and must be within the RCPB or the high pressure portion of the system.

Required Action A.1 requires that the isolation with one valve must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Four hours provides time to reduce leakage in excess of the allowable limit and to isolate the affected system if leakage cannot be reduced. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time allows the actions and restricts the operation with leaking isolation valves.

Required Action A.2 specifies that the double isolation barrier of two valves be restored by closing some other valve qualified for isolation or restoring the RCS PIV to within limits. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time after exceeding the limit allows for the restoration of the leaking PIV to OPERABLE status. This time frame considers the time required to complete the Action and the low probability of a second valve failing during this time period.

B.1 and B.2 If leakage cannot be reduced, the system isolated, or the other Required Actions accomplished, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This Action may reduce the leakage and also reduces the potential for a LOCA outside (continued) overall plant risk is redcued 12 4

RCS PIV Leakage B 3.4.14 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.4-72 Revision 85 ACTIONS B.1 and B.2 (continued) the containment. The allowed Completion Times are reasonable based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

C.1 The inoperability of the RHR System interlock renders the RHR suction isolation valves capable of inadvertent opening at RCS pressures in excess of the RHR systems design pressure. If the RHR System interlock is inoperable, operation may continue as long as the affected RHR suction penetration is closed by at least one closed manual or deactivated automatic valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This Action accomplishes the purpose of the function.

SURVEILLANCE REQUIREMENTS SR 3.4.14.1 Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition greater than 150 psig.

For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.

Testing may be extended if the plant does not go into MODE 5 for at least 7 days. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

In addition, testing must be performed once after the check valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the check valve has been reseated (except as provided by Note 1). Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable and practical time limit for performing this test after opening or reseating a check valve.

(continued)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 9). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 9, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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RCS PIV Leakage B 3.4.14 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-74 Revision 85 REFERENCES 1.

10 CFR 50.2.

2.

10 CFR 50.55a(c).

3.

10 CFR 50, Appendix A, Section V, GDC 55.

4.

WASH-1400 (NUREG-75/014), Appendix V, October 1975.

5.

NUREG-0677, May 1980.

6.

Technical Requirements Manual.

7.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

8.

10 CFR 50.55a(g).

9. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

RCS Leakage Detection Instrumentation B 3.4.15 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.4-80 Revision 85 ACTIONS (continued)

E.1 and E.2 With the required containment atmosphere radioactivity monitor and the containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the containment sump monitor. This Condition does not provide the required diverse means of leakage detection.

The Required Action is to restore either of the inoperable required monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a lengthy time period.

F.1 and F.2 If a Required Action of Condition A, B, C, D or E cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

G.1 With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE REQUIREMENTS SR 3.4.15.1 SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action F.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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overall plant risk is reduced 4

12

RCS Leakage Detection Instrumentation B 3.4.15 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.4-81 Revision 85 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.3, SR 3.4.15.4, and SR 3.4.15.5 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50, Appendix A, Section IV, GDC 30.

2.

Regulatory Guide 1.45, Revision 0, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973.

3.

FSAR, Section 5.2.

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

ECCS - Shutdown B 3.5.3 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.5-21 Revision 89 ACTIONS A.1 (continued) inoperable RHR loop components can be restored to operation so that decay heat removal is continuous.

With the required RHR pump and heat exchanger inoperable, it would be unwise to require the plant to go to MODE 5, where the only available heat removal system is the RHR. Therefore, the appropriate action is to initiate measures to restore one ECCS RHR subsystem and to continue the actions until the subsystem is restored to OPERABLE status.

B.1 With no ECCS high head subsystem OPERABLE, due to the inoperability of the centrifugal charging pump or flow path from the RWST, the plant is not prepared to provide high pressure response, if needed. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time to restore at least one ECCS high head subsystem to OPERABLE status ensures that prompt action is taken to provide the cooling capacity or to initiate actions to place the plant in MODE 5, where an ECCS train is not required.

C.1 When the Required Actions of Condition B cannot be completed within the required Completion Time, a controlled shutdown should be initiated.

Twenty-four hours is a reasonable time, based on operating experience, to reach MODE 5 in an orderly manner and without challenging plant systems or operators.

SURVEILLANCE REQUIREMENTS SR 3.5.3.1 The applicable Surveillance descriptions from Bases 3.5.2 apply.

REFERENCES None.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 1). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 1, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action A.1 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

of immediately initiate actions that would required

RWST B 3.5.4 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.5-26 Revision 89 ACTIONS (continued)

B.1 With the RWST inoperable for reasons other than Condition A (e.g., water volume), it must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

In this Condition, neither the ECCS nor the Containment Spray System can perform its design function. Therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the plant in a MODE in which the RWST is not required. The short time limit of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore the RWST to OPERABLE status is based on this condition simultaneously affecting redundant trains.

C.1 and C.2 If the RWST cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE REQUIREMENTS SR 3.5.4.1 The RWST borated water temperature should be verified to be within the limits assumed in the accident analyses band. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The SR is modified by a Note that eliminates the requirement to perform this Surveillance when ambient air temperatures are within the operating limits of the RWST. With ambient air temperatures within the band, the RWST temperature should not exceed the limits.

SR 3.5.4.2 The RWST water volume should be verified to be above the required minimum level in order to ensure that a sufficient initial supply is available for injection and to support continued ECCS and Containment Spray System pump operation on recirculation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Control Board indication may be used in the surveillances of the required indicated RWST water volume. The indicated level of 95%, which includes (continued)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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overall plant risk is reduced 12 4

RWST B 3.5.4 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.5-27 Revision 89 SURVEILLANCE REQUIREMENTS SR 3.5.4.2 (continued) 5% measurement uncertainty, is a conservative verification of contained volume. Other means of surveillance which consider measurement uncertainty may also be used.

SR 3.5.4.3 The boron concentration of the RWST should be verified to be within the required limits. This SR ensures that the reactor will remain subcritical following a LOCA. Further, it assures that the resulting sump pH will be maintained in an acceptable range so that boron precipitation in the core will not occur and the effect of chloride and caustic stress corrosion on mechanical systems and components will be minimized. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Chapter 6 and Chapter 15.

2.

WCAP-16996-P-A, Rev. 1, November 2016.

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Containment Spray System B 3.6.6 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.6-35 Revision 89 LCO (continued)

OPERABLE flow path capable of taking suction from the RWST upon an ESF actuation signal. Upon indication of the RWST level required for switchover, the suction flowpath must be capable of being manually transferred to the containment sump.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the containment spray trains.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Thus, the Containment Spray System is not required to be OPERABLE in MODES 5 and 6.

ACTIONS A.1 With one containment spray train inoperable, the inoperable containment spray train must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program. In this Condition, the remaining OPERABLE spray train is adequate to perform the iodine removal and containment cooling functions. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the redundant heat removal capability afforded by the Containment Spray System, reasonable time for repairs, and low probability of a DBA occurring during this period.

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time for attempting restoration of the containment spray train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

(continued)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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overall plant risk is reduced 4

54 4

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore to OPERABLE status in MODE 3. This

Containment Spray System B 3.6.6 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.6-38 Revision 89 REFERENCES 1.

10 CFR 50, Appendix A, GDC 38, GDC 39, GDC 40, GDC 41, GDC 42, and GDC 43.

2.

WCAP-16996-P-A, Revision 1.

3.

FSAR, Section 6.2.1.

4.

FSAR, Section 6.2.2.

5.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

6.

Technical Requirements Manual.

7.

FSAR, Section 6.3.

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Spray Additive System B 3.6.7 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.6-41 Revision 89 ACTIONS A.1 If the Spray Additive System is inoperable, it must be restored to OPERABLE within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The pH adjustment of the Containment Spray System flow for corrosion protection and iodine removal enhancement is reduced in this condition. The Containment Spray System would still be available and would remove some iodine from the containment atmosphere in the event of a DBA. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the redundant flow path capabilities and the low probability of the worst case DBA occurring during this period.

B.1 and B.2 If the Spray Additive System cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months .

The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for restoration of the Spray Additive System in MODE 3 and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach MODE 5. This is reasonable when considering the reduced pressure and temperature conditions in MODE 3 for the release of radioactive material from the Reactor Coolant System.

SURVEILLANCE REQUIREMENTS SR 3.6.7.1 This surveillance verifies that the available buffering agent is sufficient to ensure that the equilibrium containment sump pH is greater than or equal to 7.1. Details of the bases for performance test requirements that ensure sump pH requirements are met are included in the bases of the Technical Requirements Manual.

REFERENCES 1.

FSAR, Chapter 6.5.

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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overall plant risk is reduced 4

54 to restore to OPERABLE status 4

2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

CCW System B 3.7.7 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-37 Revision 88 APPLICABILITY In MODES 1, 2, 3, and 4, the CCW System is a normally operating system, which must be prepared to perform its post accident safety functions, primarily RCS heat removal, which is achieved by cooling the RHR heat exchanger.

In MODE 5 or 6, the OPERABILITY requirements of the CCW System are determined by the systems it supports.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," be entered if an inoperable CCW train results in an inoperable RHR loop. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

If one CCW train is inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program. In this Condition, the remaining OPERABLE CCW train is adequate to perform the heat removal function. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this period.

B.1 and B.2 If the CCW train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

SURVEILLANCE REQUIREMENTS SR 3.7.7.1 This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System.

Verifying the correct alignment for manual, power operated, and automatic valves in the CCW flow path provides assurance that the proper flow paths exist for CCW operation. This SR does not apply to valves that are locked, (continued)

paragraph break*

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

paragraph break*

overall plant risk is reduced 4

12

CCW System B 3.7.7 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-38 Revision 88 SURVEILLANCE REQUIREMENTS SR 3.7.7.1 (continued) sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

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

SR 3.7.7.2 This SR verifies proper automatic operation of each automatic CCW valve on its associated actual or simulated ESF actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.7.3 This SR verifies proper automatic operation of the CCW pumps on an actual or simulated Safety Injection actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Sections 3.9B, 7.3, and 9.2.2.

2.

FSAR, Section 6.2.

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

SSWS B 3.7.8 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-42 Revision 88 ACTIONS B.1 (continued) inoperable decay heat removal train. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components.

If one SSWS train is inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time Program. In this Condition, the remaining OPERABLE SSWS train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE SSWS train could result in loss of SSWS function. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period.

C.1 and C.2 If the SSWS train or an SSW Pump on the opposite unit and its associated cross-connects cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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.

SURVEILLANCE REQUIREMENTS SR 3.7.8.1 This SR is modified by a Note indicating that the isolation of the SSWS components or systems may render those components inoperable, but does not affect the OPERABILITY of the SSWS.

Verifying the correct alignment for manual, power operated, and automatic valves in the SSWS flow path provides assurance that the proper flow paths exist for SSWS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to being locked, sealed, or secured. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

(continued)

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

overall plant risk is reduced 4

12

SSWS B 3.7.8 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-43 Revision 88 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.8.2 This SR verifies proper position or manual operation of the cross-connect valves between units. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.8.3 This SR verifies proper automatic operation of the SSWS pumps on an actual or simulated Safety Injection actuation signal. The SSWS is a normally operating system that cannot be fully actuated as part of normal testing during normal operation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Section 9.2.1.

2.

FSAR, Section 6.2.

3.

FSAR, Section 5.4.7.

4.

Generic Letter 91-13, "Request for Information related to the Resolution of Generic Issue 130, Essential Service Water System Failures at Multi-unit Sites, Pursuant to 10 CFR 50.54(f)."

5.

General Design Criteria 5 and 44.

6.

TXX-92410, "License Amendment Request 92-002, Combined Unit 1 and 2 Technical Specifications" dated August 31, 1992.

7.

ASME XI.

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

UHS B 3.7.9 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-46 Revision 88 ACTIONS (continued)

B.1 and B.2 If the level cannot be restored to OPERABLE status within the associated Completion Time, or if the SSI is inoperable for reasons other than Condition A, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

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.

SURVEILLANCE REQUIREMENTS SR 3.7.9.1 This SR verifies that adequate long term (30 day) cooling can be maintained.

The specified level also ensures that sufficient NPSH is available to operate the SSWS pumps. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.9.2 This SR verifies that the SSWS is available to cool the CCW System to at least its maximum design temperature with the maximum accident or normal design heat loads for 30 days following a Design Basis Accident. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Sections 2.3, 2.4 and 9.2.5.

2.

Regulatory Guide 1.27.

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

overall plant risk is reduced 4

12

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 7). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 7, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action C.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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in which the overall plant risk is reduced 12 4

CREFS B 3.7.10 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-55 Revision 88 SURVEILLANCE REQUIREMENTS SR 3.7.10.4 (continued) exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 5). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 6). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES 1.

FSAR, Sections 2.2, 6.4, 6.5, 7.3, 9.4, and 9.5.

2.

FSAR, Chapter 15.

3.

Regulatory Guide 1.52.

4.

Regulatory Guide 1.196.

5.

NEI 99-03, Control Room Habitability Assessment, June 2001.

6.

Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability. (ADAMS Accession No. ML040300694).

7. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 3). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 3, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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in which the overall plant risk is reduced 4

12

CRACS B 3.7.11 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-59 Revision 88 ACTIONS (continued)

E.1 and E.2 If both CRACS trains are inoperable in MODE 1, 2, 3, or 4, with 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.

If both CRACS trains are inoperable in MODE 1, 2, 3, or 4, the control room CRACS may not be capable of performing its intended function. Therefore, as an alternative to Required Action E.1, LCO 3.0.3 may be entered immediately.

SURVEILLANCE REQUIREMENTS SR 3.7.11.1 This SR verifies that the heat removal capability of the system is sufficient to remove the heat load assumed in the safety analyses in the control room.

This SR consists of a combination of testing and calculations. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The CRACS heating coils are not required to be included in this SR.

REFERENCES 1.

FSAR, Section 6.4.

2.

FSAR, Section 9.4.1.

3. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

PPVS B 3.7.12 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.7-64 Revision 88 ACTIONS C.1 (continued)

The 7 day Completion Time is appropriate because the risk contribution is less than that for the ECCS (72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time), and this system is not a direct support system for the ECCS. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

Concurrent failure of two PPVS trains would result in the loss of functional capability; therefore, LCO 3.0.3 must be entered immediately.

D.1 and D.2 If the PPVS train or negative pressure envelope cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

SURVEILLANCE REQUIREMENTS SR 3.7.12.1 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train periodically provides an adequate check on this system. Periodic heater operations dry out any moisture that may have accumulated in the charcoal from humidity in the ambient air.

Systems with heaters must be operated 10 continuous hours with the heaters energized with flow through the HEPA filters and charcoal adsorbers. Operation is to be initiated from the Control Room. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.12.2 This SR verifies that the required PPVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The ECCS PREACS filter tests are in accordance with Reference 4. The VFTP includes testing HEPA filter performance, charcoal adsorbers efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

(continued)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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overall plant risk is reduced 4

12

PPVS B 3.7.12 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-66 Revision 88 REFERENCES 1.

FSAR, Section 6.5.1.

2.

FSAR, Section 9.4.3 and 9.4.5.

3.

FSAR, Chapter 15.

4.

Regulatory Guide 1.52 (Rev. 2).

5.

10 CFR 100.11.

6.

NUREG-0800, Section 6.5.1, Rev. 2, July 1981.

7.

10 CFR 50, Appendix A, GDC-19.

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

AC Sources - Operating B 3.8.1 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-16 Revision 91 ACTIONS F.1 (continued) commensurate with the importance of maintaining sequencer OPERABILITY. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

This Required Action is modified by a note. The note allows one sequencer channel to be bypassed for surveillance testing provided the other channel is operable. The 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allows sufficient time to perform the required testing.

Based on the low probability of an event requiring the sequencer in combination with a failure to the operable sequencer channel during the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , this period of inoperability for testing is acceptable.

G.1 and G.2 If the inoperable AC electric power sources cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems.

H.1 Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation.

The unit is required by LCO 3.0.3 to commence a controlled shutdown.

I.1 A Blackout sequencer is an essential support system to the DG associated with a given ESF bus. The sequencer is required to provide the system response to a loss of or degraded ESF bus voltage signal. Therefore, the loss of the Blackout sequencer causes the associated DG to become inoperable immediately.

(continued)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 16). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 16, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action G.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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overall plant risk is reduced 4

12

AC Sources - Operating B 3.8.1 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-31 Revision 91 REFERENCES 1.

10 CFR 50, Appendix A, GDC 17.

2.

FSAR, Chapter 8.

3.

Regulatory Guide 1.9 Rev 3, July 1993.

4.

FSAR, Chapter 6.

5.

FSAR, Chapter 15.

6.

Regulatory Guide 1.93, Rev. 0, December 1974.

7.

Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.

8.

10 CFR 50, Appendix A, GDC 18.

9.

Regulatory Guide 1.108, Rev. 1, August 1977.

10.

Regulatory Guide 1.137, January 1978.

11.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

12.

IEEE Standard 308-1974.

13.

IEEE Standard 387-1977 14.

Generic Letter 94-01, Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators, May 31, 1994.

15.

ANSI C84.1

16. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

DC Sources - Operating B 3.8.4 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-53 Revision 91 ACTIONS C.1 (continued)

If one of the required DC electrical power subsystems is inoperable, the other DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of the minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

D.1 and D.2 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems. The Completion Time to bring the unit to MODE 5 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

SURVEILLANCE REQUIREMENTS SR 3.8.4.1 Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger supplies a continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer. The minimum established float voltage is 2.13 Vpc or 128 V at the battery terminals. This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued) overall plant risk is reduced 4

12

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 11). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 11, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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DC Sources - Operating B 3.8.4 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-55 Revision 91 SURVEILLANCE REQUIREMENTS SR 3.8.4.3 (continued)

Note 2 says to verify the requirement during MODES 3, 4, 5, 6 or with the core off-loaded. This note does not prohibit the application of LCO 3.0.5 or the performance of this SR to restore equipment operability. Note 2 neither approves nor prohibits testing in MODES 1 and 2; however, for testing that is performed in MODES 1 and 2 (e.g., for post work testing) the testing may not be credited to satisfy the SR. Only the testing performed in MODES 3, 4, 5, 6 or with core off-loaded can be credited to satisfy the SR.

REFERENCES 1.

10 CFR 50, Appendix A, GDC 17.

2.

Regulatory Guide 1.6, March 10, 1971.

3.

IEEE-308-1974.

4.

FSAR, Chapter 8.

5.

FSAR, Chapter 6.

6.

FSAR, Chapter 15.

7.

Regulatory Guide 1.93, December 1974.

8.

IEEE-450-1995.

9.

Regulatory Guide 1.32, February 1977.

10.

Regulatory Guide 1.129, February 1978.

11. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Inverters - Operating B 3.8.7 BASES (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.8-71 Revision 91 ACTIONS A.1 With a required inverter inoperable, its associated AC vital bus becomes inoperable until it is re-energized by an operable inverter or the alternate bypass power supply from the Class 1E transformers.

For this reason a Note has been included in Condition A requiring the entry into the Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating." This ensures that the vital bus is re-energized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Required Action A.1 allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to fix the inoperable inverter and return it to service. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit is based upon engineering judgment, taking into consideration the time required to repair an inverter and the additional risk to which the unit is exposed because of the inverter inoperability. This has to be balanced against the risk of an immediate shutdown, along with the potential challenges to safety systems such a shutdown might entail. When the AC vital bus is powered from its Class 1E transformer, it is relying upon non-regulating interruptible AC electrical power sources (offsite and onsite).

Because of the potential impact of interrupted power on the Emergency Diesel Generator and the Solid State Safeguards Blackout Sequencer during a postulated Loss of Offsite Power event, these components are considered inoperable when operating on inverter bypass power, and evaluated under the SFDP of Specification 5.5.15. The uninterruptible inverter source to the AC vital buses is the preferred source for powering instrumentation trip setpoint devices.

B.1 and B.2 If the inoperable devices or components cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems.

SURVEILLANCE REQUIREMENTS SR 3.8.7.1 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 (continued)

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Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

paragraph break*

4 overall plant risk is reduced 12

Inverters - Operating B 3.8.7 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-72 Revision 91 SURVEILLANCE REQUIREMENTS SR 3.8.7.1 (continued) power is available for the instrumentation of the RPS and ESFAS connected to the AC vital buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Chapter 8.

2.

FSAR, Chapter 6.

3.

FSAR, Chapter 15.

4. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Distribution Systems - Operating B 3.8.9 BASES COMANCHE PEAK - UNITS 1 AND 2 B 3.8-83 Revision 91 ACTIONS C.1 (continued)

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 4).

D.1 and D.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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 plant systems.

E.1 Condition E corresponds to inoperable distribution subsystems that result in a loss of safety function, adequate core cooling, containment OPERABILITY and other vital functions for DBA mitigation would be compromised, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE REQUIREMENTS SR 3.8.9.1 This Surveillance verifies that the required AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus.

The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

FSAR, Chapter 6.

2.

FSAR, Chapter 15.

3.

FSAR, Chapter 8.3.

4.

Regulatory Guide 1.93, December 1974.

12 overall plant risk is reduced 4

paragraph break*

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 5, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action D.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

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5. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

CP-202500207, Application to Revise Technical Specifications to Adopt TSTF-432, Change in Technical Specifications End States (WCAP-16294)

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Subject:

Dear Sir or Madam:

Enclosure:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

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CP-202500207, Application to Revise Technical Specifications to Adopt TSTF-432, Change in Technical Specifications End States (WCAP-16294)

Text

Subject:

Dear Sir or Madam:

Enclosure:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

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