TXX-9505, LAR 95-001 to Licenses NPF-87 & NPF-89,changing TS to Address Performance Requirements of Containment Spray Pumps

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LAR 95-001 to Licenses NPF-87 & NPF-89,changing TS to Address Performance Requirements of Containment Spray Pumps
ML20080P335
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/28/1995
From: Terry C
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20080P337 List:
References
TXX-95050, NUDOCS 9503070321
Download: ML20080P335 (8)
v • d • e


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========== Log # TXX 95050

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" " " " " " File # 916 (3/4.6) 10010 1 Z Ref. # 10CFR50.90 C C 10CFR50.36 1UELECTRIC

c. w Tmy February 28, 1995 Group Vice President U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50 446 SUBMITTAL OF LICENSE AMENDHENT REQUEST 95 01 CONTAINMENT SPRAY PUMP DIFFERENTIAL PRESSURE Gentlemen:

Pursuant to 10CFR50.90. TV Electric hereby requests an amendment to the CPSES Unit 1 Operating License (NPF-87) and CPSES Unit 2 Operating License (NPF 89) by incorporating the attached change into the CPSES Units 1 and 2 Technical, Specifications. These changes apply equally to CPSES Units 1 and 2.

As part of the first refueling outage on CPSES Unit 2 (2RF01), TU Electric implemented a performance enhancement modification to the Containment Spray pumps. This enhancement replaced the Containment Spray pump impellers with impellers of a new design which significantly reduces pump vibration. This modification is now scheduled to be implemented on the Unit 1 Containment Spray pumps during the upcoming refueling outage in March 1995. One of the

, Unit 1 pumps has historically seen differential pressures very close to the Technical Specification Surveillance Requirement 4.6.2.lb. limit of 245 psid. The impeller change out could potentially result in a differential pressure for this pump below the surveillance requirement limit although it is expected that the pump will still be able to provide the head and flow necessary to perform its safety function and to satisfy the associated safety analyses.

TV Electric proposes to resolve this potential compliance prob}em by replacing the existing surveillance requirement with the corresponding surveillance requirement from NUREG 1431. The NUREG 1431 version stipulates that the pumps meet the " required developed head at the flow test point" but does not specify a minimum head or flow. The required developed head and flow test point will be relc.cated to the CPSES Technical Requirements Manual (TRM) and will be established and maintained to ensure that the appropriate safety analyses are satisfied. The surveillance frequency will not change.

Attachment 2 provides a detailed description of the proposed changes, a safety analysis of the changes, and TU Electric's determination that the proposed changes do not involve a significant hazard consideration.

Attachment 3 provides the affected Technical Specification pages d'

pf 9503070321 950229 i PDR ADOCK 05000445 ) P.O. Box 1002 Glen Rose. Texas 76043 v 1

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i TXX-95050-Page 2 of.2-

(NUREG-1468), marked up to reflect the proposed changes. Enclosed is an
information only copy of the proposed change to the Technical Requirements i Manual to incorporate the_ performance requirements for the-Containment Spray '

pumps.

p While' the new pump differential pressures'will not be known until after pump.

i testing late in the ' outage, expeditious. review' and approval of the proposed

. change is. requested to' ensure that the Unit 1 restart will not- be delayed.

4 The current schedule for Unit .1,. Fuel' Cycle 5 startup. is mid Apr11;1995.

3

The date needed for. the amendment to be effective is April:5,1995'which is

[ .the. scheduled date for. entry into MODE 4.

[ In accor'd ance with 10CFR50.91(b)~, TU Electric is providing the State of -

Texas with a copy of this_ proposed amendment.

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l Should you have any questions.. please. contact- Mr.. Bob Dacko at :

r (214).812 8228. ,

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Sincerely, 7

  • V3 < .,

C.-L.' Terry ~ l

[ .

J. J. Kelley,-Jr. ..

Vice President of Nuclear Engineering'and Support

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BSD/bd Attachments: '

1. Affidavit i
2. Description and Assessment .

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3. Affected Technical Specification page (NUREG 1468) as revised by all approved license amendments *

Enclosures:

1. Proposed revision to TRH . &
2. NUREG 1431 pages associated with license amendment -

cc - Mr. L.'J. Callan, Region IV Mr.' T. J. Polich, NRR

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, Ms. D. D.' Chamberlain, Region IV Resident _ Inspectors, CPSES Mr. Arthur C. Tate  !

Bureau of Radiation Control

  • Texas Department of Public Health 1100 West 49th Street i

.. Austin.. Texas 78/04 ]

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-Attachment 1 to TXX 95050 l3 Page 1.of 1 h

!- UNITED STATES OF AMERICA ~

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NUCLEAR REGULATORY COMMISSION l .

l In the Matter of ) .-

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l Texas Utilities Electric Company ) Docket Nos. 50 445  !

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50 446 l' (Comanche Peak Steam Electric ) License Nos. NPF 87 Station, Units l'& 2) ) . NPF 89 AFFIDAVIT-l James J. Kelley, Jr. being duly sworn, hereby depose.s and says that he is

  • Vice President of Engineering and Support for TV Electric, the licensee herein: that he is duly authorized to sign and file with the~ Nuclear -

l Regulatory Commission this License Amendment Request 95 01:. that he is l familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge. information and belief.  :

i WkV J. J. Kelley, Jr. I L Vice President of Nuclear  !

Engineering and Support j l

STATE OF TEXAS )  !

COUNTY OF)nnhnd ) ) -

Subscribed and sworn to before me, on this Of day'of' b 4/u4 .

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%h>&m-Notiry. Public  ;

O JEANAMUNDSON NOTARY PUBUC STATEOF1EXAs

% Commission E@ ires 71 ge

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. Attachment ~2 to TXX 95050' 4

'Page 1 of 4. .!

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DESCRIPTION AND ASSESSMENT i ~

i 'I. BACKGROUND -

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[- Vibration ~ in the~ Unit 21 Containment Spray System piping resulted in the

' initiation-of. fatigue cracks at connections-from various.small bore piping

.to the discharge headers. ~This condition was reported to the NRC.via LER 2-

? ,94 005 transmitted by TU Electrictietter TXX 94166,, dated' June 22,^ 1994 l -[ reference 1]. A numb'r e of approaches were employed as corrective actions ^,

including reinforcement of.the connecting, piping ~ deletion'of unnecessary

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. piping connections, and a performance enhancement that: replaces thel. .

L containment spray pump impe11ers with impe11ers.of a:different design.

Similar modifications to the Unit 1 Containment _ Spray pump impe11ers:are- 1 planned during the March 1995 refueling outage.

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{ .The corrective actions and. performance enhancements significantly reduced l 3 the Unit 2 Containment Sprayisystem _ vibration;.however, the impeller

. replacement resulted in a reduction of 2 to 6 psid in the discharge head of

-each containment spray pump. While all _ the Unit -2 pumps had' sufficient '

i; margin to meet the Surveillance Requirement l4.6.2.lb. minimum of:245 psid..

it was recognized _ that this might- not be' the-case for. Unit ~ 1. _ ' The discharge
head of one of the Unit 1 Containment Spray pumps historically has been only ,

j a few psid above the surveillance limit. The impeller replacement in this .;

pump could potentially reduce its head
below the-surveillance limit. .In  ;

!. addition. the pump head value.provided in the surveillance requirement. is-4 greater than the actual _. developed head necessary to satisfy the.' safety .

j analyses. j i In order to address this potential compliance problem. TU Electric proposes l- to replace the existing surveillance requirement with the corresponding. ,

i. surveillance requirement from NUREG-1431 [ reference ~:2]. The NUREG 1431 l version stipulates'that the pumps meet the " required developed head at the-- l
. flow test point" but does not specify a minimum. head or flow. The required ,

L developed head and flow test point will be relocated to the CPSES Technical  !

r Requirements Manual '(TRM) and will be established and maintained to ensure 3 l that the appropriate safety analyses are satisfiede Changes to the CPSES TRM are~ controlled under 10CFR50.59. Technical Specification'6.5.1.6 (review o by 50RC), and Technical Specification 6.8.1 (procedures ~and programs). The

[ surveillance frequency will not change. i

[ II. -DESCRIPTION OF TECHNICAL SPECIFICATIONS CHANGE REQUEST ~

Technical Specification 3/4.6.2 "DEPRESSURIZATION AND COOLING SYSTEMS -

. CONTAINMENT SPRAY SYSTEM" Surveillance Requirement 4.6.2.lb. is replaced l with NUREG 1431 Surveillance Requirement 3.6.6A.4. This change replaces the L- specific pump flow and head values now contained in'the Surveillance I i Requirement with the general requirement that.the pump ~ develop the required r - head at the flow test point. ,

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Attachment 2 to TXX 95050 Page 2 of 4

, ' Bases 3/4.6.2.1 " CONTAINMENT SPRAY SYSTEM" is revised to expand the detail' consistent with the NUREG-1431 BASES SR 3.6.6A.4. The BASES from'NUREG-1431 has minor modifications to reflect (1) that the' CPSES containment spray pumps are tested via a special test line which allows testing at . flows higher than that allowed'by the miniflow recirculation line: (2)-the'" pump design curve" is termed the " analytical pump curve"; and (3)-the reference'  !

to the TRH where~ the pump head requirements are defined'is' provided' for the

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user's information. .

.In summary, the surveillance requirement. and its associated bases', for.

confirming-the performance of the Containment Spray pumps is changed by replacing the specific pump head and flow values ~ with the general requirement that.the pumps provide the required head at the flow test point while the specific required values are moved to the Technical Requirements Manual.

III. ANALYSIS The containment spray pump surveillance was originally provided to ensure that the pump is capable of performing as necessary,to-satisfy the related safety analyses. Tne design basis accidents which define the performance requirements for these pumps are the Loss of Coolant Accident (LOCA) and the Main Steam Line Break (MSLB) inside containment. The spray provided by the pumps limits the temperature and pressure peak ~1nside containment' and '

reduces the radioactivity of the containment atmosphere. In order to j perform their safety-function and support these safety analyses, the pumps' must meet or exceed the analytical pump curve used in the safety analyses.

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The present surveillance requirement confirms this performance criterion by verifying that the pumps provide a flow greater than or equal- to a specified value (6600 gpm) at a specific head (245 psid) using a specific flow path.

While this test does ensure that the pump will perform as required, it is restrictive in that it can only be revised via a license amendment. By revising the surveillance requirement to provide the general requirement and relocating the specific requirements to a TU Electric controlled document, the Technical Requirements Manual (TRM), the specific recuirements can be revised to ensure compliance and to ensure that the accicent analyses are.

met without requirir.g a license amendment. The basis for this surveillance is not changed by'the proposed change to relocate the quantitative flow and. l head requirements to the TRM. The frequency of the surveillance will  !

continue to be in accordance with the Inservice Testing' Program. The surveillance.Will continue to test each pump separately as described in

. Reference 3. The surveillance will also continue to ensure the pumps satisfy the " analytical pump curve" used in the containment analyses. Based on the discussions above, this change will have no impact on plant safety in that the accident analyses will continue to be satisfied.

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i Attachment 2-to TXX 95050

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! -IV. 'SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS i

TU Electric has evaluated.whether. or not a significant hazards consideration +

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is' involved with the proposed changes by focusing on the three' standards set'  ;

i- forth in 10CFR50.92(c).as discussed below-  ;

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'l. 'Do' the- proposed. changes involve a significant increase in the '  ;

probability or consequences of an accident previously- evaluated? ..
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i. The relocation of the specific values for flow and ' developed head at  ;

the flow test point to the Technical Requirements Manual -(TRM) is '

I essentially.an administrative change. The change'does not change the

. plant' hardware or operating procedures. As such, the change has no l .

l impact on.the. probability of an accident. ,

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. The consequences of. an accident previously evaluated, as-it relates to- 1

, ' the_ performance characteristics of the containment; spray pumps.L l lL Ldepends on the pumps meeting.the performance characteristics in the t

' analytical pump curve used by the containment analyses.' Since thel .

' limitations established in the TRM will. continue to'ensurt that this.

i analytical pump curve is met. there~ 1s..no impact on thel accident. 1

i. analyses. The initial TRM will. duplicate the existing surveillancei ,

val ues.- In the future, the TRM values may be slightly more or i .. . -!

.slightly less restrictive based on changes to the containment analyses. '

l or their design inputs. The result of this ' variation could be a minor '

' variation in'the consequences of an actual event were one to' occur
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howe;er, the consequences would be bounded by the' existing safety:

3 analyses. and therefore, the change does not involve'a significant

.increaseDinlthe consequences of an accident previously evaluated. .

[ , 2. Do the proposed changes create the. possibility of a' new or different '

L kind lof accident fros' any~ accident: previously evaluated? ,

y I

The' proposed change does not add 'new hardware to the' units or' change.

plant operations. Relocation of the surveillance acceptance criteria  ;

j- to the TRM cannot initiate an event nor cause an analyzed event to-

[ progress differently. Thus, the possibility of a new or.different j kind of accident is not created.

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

[ safety?

i The margin of safety is not affected since the surveillance will  ;

i continue to be required by Technical Specifications at the same i frequency and that surveillance will continue to ensure the i- containment spray pump performance is bounded by the analytical pump

curve used in the containment analyses.

i-Based on the above evaluations. TV Electric concludes that the activities-D associated with the proposed changes' satisfy the no significant: hazards:

consideration standards.of- 10CFR50.92(c) and accordingly. .a no significant.

hazards consideration finding is justified.

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1 i Attachment 2 to'TXX 95050

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.V. ENVIRCN"EN1AL EVAL.UATION

- TU Electric has evaluated the proposed changes and has determined that the ,

changes do not. involve (1) a significant hazards consideration. -(11) a  ;

significant change in tne types or significant increase in the amounts of- ,

any effluent that may be released offsite, or-(iii) a significant' increase  ;

in individual or cumulative occupational. radiation, exposure. Accordingly,- )

~ the proposed changes meet the eligibility criterion for categorical exclusion set forth .in 10CFR51.22(c)(9). Therefore, pursuant to.. -

10CFR51.22(b). an environmental assessment .of'the proposed change is not-required.

P VI. PRECEDENCE-Crystal River 3 Technical Specification Amendment'149 ,

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VII. REFERENCES  !

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1. TU. Electric letter logged'TXX 94166 from William J. -Cahill:Jr. to the. I Nuclear Regulatory Commission, dated June 22, 1994-
2. NUREG 1431. Standard Technical Specifications, Westinghouse Plants, September 1992.
3. TV Electric letter logged TXX 89035 from W.J. Cahill to the Nuclear ,

Regulatory Commission, dated January 24, 1989, " Proposed Changes to I the NRC Proof & Review Technical Specifications Docket No. 50 445, l Attachment 9, pages 1 and 12.

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. ENCLOSURE 1 T0 TXX 95050'-

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, PROPOSED. CHANGE TO THE.! TECHNICAL REQUIREMENTS MANUAL ,

,TO ADDRESS PERFORMANCE ~ REQUIREMENTS OF-' CONTAINMENT SPRAY PUNPS l'

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