TXX-9822, Submits follow-up Items Re Proposed Conversion to Improved Tech Specs Sections 3.1,3.2,3.4,3.5 & 5.0

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Submits follow-up Items Re Proposed Conversion to Improved Tech Specs Sections 3.1,3.2,3.4,3.5 & 5.0
ML20154S256
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/23/1998
From: Terry C, Woodlan D
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20154S259 List:
References
TXX-98229, NUDOCS 9810270359
Download: ML20154S256 (4)
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Log # TXX-98229 File # 10010

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916 7UELECTRIC Ref. # 10 CFR 50.90 10 CFR 50.36 c.Im e. n rry s,ador vice prea,.s October 23,1998

& PrincipalNuclear Officer U. S. Nuclear Regulatory Commission  !

Attn: Document Control Desk Washington, DC 20555 I I

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446  ;

TECHNICAL SPECIFICATION CONVERSION FOLLOW-UP ITEMS RELATED TO THE PROPOSED CONVERSION TO THE IMPROVED TECHNICAL SPECIFICATION SECTIONS 3.1,3.2,3.4,3.5, AND 5.0 REF: 1) TU Electric letter, logged TXX-97105, from C. L. Terry to the NRC dated May 15,1997

2) TU Electric letter, logged TXX-98182, from C. L. Terry to the NRC dated August 5,1998
3) TU Electric letter, logged TXX-98195, from C. L. Terry to the NRC dated August 28,1998 Gentlemen:

C TU Electric requested an amendment to the Comanche Peak Facility Operating Licenses

- (NPF-87 for Unit 1 and NFP-89 for Unit 2) by incorporating changes to the Technical Specifications (TS) as provided in Reference 1. The NRC staff requested additional information regarding Section 3.1, " Reactivity Control Systems," Section 3.2, " Power Distribution Systems," Section 3.5, " Emergency Core Cooling Systems," Section 3.9,

" Refueling Operations," and Section 4.0, " Design Features," which was provided in Reference

2. In addition, the NRC staff requested additionalInformation regarding Section 3.4," Reactor Coolant System," and Section 5.0, " Administrative Controls," which was provided in Reference

' 3. The Attachments to this letter provide (1) additional information or supporting documentation not provided in the original RAI response, (2) answers to follow-up questions, or (3) additional changes identified by the licensee.

This letter and its attachments are not a supplement to Reference 1. A supplement to Reference 1 will be provided at a later date.

The only commitment contained in this letter is to provide a supplement to Reference 1 at a

- later date. tl

.J ' \ '

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COMANCllE PEAK STEAM ELECTRIC STATION m " W2 Gen Rme, Tem NW2 l 9810270359 981023 PDR ADOCK 05000445 i P PDR ,

TXX-98229 Page 2 of 2 4

If you have any questions concerning the content of this letter, please contact Mr. Bob Dacko (254-897-0122).

l Sincerely, l

i C. L. Terry l 1

By:

D. R. Woodlan Docket licensing Manager BSD/bd i Attachments c- E. W. Merschoff, Region IV J. I. Tapia, Region IV Resident inspectors, CPSES i T. J. Polich, NRR J. N. Donohew, NRR Mr. Arthur C. Tate Bureau of Radiation Control l Texas Department of Public Health 1100 West 49* Street i Austin, Texas 78704 1

The item numbers are formatted as follows: [ Source] [lTS Section]-[nnn]

4 Source = Q - NRC Question NR - NRC Follow-upOuestion

, CA- AmerenUE

' DC-PG&E WC-WCNOC 1 CP - TU Electric TR - Traveler 1

ITS ltem Number Applicability Enclosed 3.1 Q 3.1-19 CA, WC NA l 3.1 Q 3.1-20 CP,DC YES 3.1 CA 3.1-005 (new) CA NA

3.2 O 3.2-3 CA, CP, DC, WC YES 3.4 Q 3.4.13-5 DC NA I 3.4 Q 3.4.13-6 CA NA 4

3.5 O 3.5.5-1 CP, DC YES 3.5 CA-3.5-001 CP (new) YES 3.5 CA-3.5-002 CA, CP, DC, WC YES 3.5 CA-3.5-004 (new) CA NA j 3.5 CP-3.5-003 (new) CP YES

3.5 DC-3.5-002 DC NA 3.5 DC-3.5-006 DC NA i

CA, CP, DC, WC 5.0 NR-5.0-001 (new) YES l 2

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ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q3.1-20 APPLICABILITY: CP, DC REQUEST: ITS 3.1.7 Rod Position Indication CTS 3.1.3.2 Position Indication Systems - Operating (Comanche Peak & Diablo

Canyon)

DOC 13-08-LS-20 & 13-09-LS-23 & 13-06-A JFD 3.1-7 & 3.1-12 Comment: The ITS adopts Conditions and associated Required Actions from the Callaway's

, CTS, addressing more than one inoperable digital rod position indicator (DRPI) per group, which is not addressed in either the STS or the CTS. Furthermore, not all associated CTS Required Actions have been retained in the ITS; the Required Actions to take manual control of the rods and to record reactor coolant temperature every hour have not been retained. These i

actions, in one case affect rod movement and in the other case provide an indication that the rod (s) position may have changed, and therefore have a bearing on SDM and therefore should

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not be deleted if the Callaway condition of more than DRPI per group inoperable is retained.

Either retain the CTS requirements and adopt the STS requirements, or provide a better justification for the ITS proposals of adopting the Callaway CTS requirements. This change is 1

based upon proposed change WOG-73, Rev 1; which eventually may become a TSTF change j request. What is the status of WOG-73, Rev 17 The STS wording of the note permitting

separate condition entry should be retained with the STS Conditions and Required Actions.

FLOG Response (original) : No change. DCPP and CPSES wish to continue pursuing this change pending NRC review of WOG-73, Rev.1, which has been submitted to the NRC as TSTF-234. This proposed change provides a specific set of compensatory actions and a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT for a situation previously unaddressed. Thus, the requirements of LCO 3.0.3 would be applicable and a plant shutdown would be required within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

However, the partial loss of RCCA position indication is not an assumed initiating event, nor does it effect the outcome of any analyzed accident. Therefore, an one hour shutdown

, response is considered unnecessary when compared to other situations of similar severity where guidance was provided.

The contribution to plant safety of a well-balanced approach in avoiding unnecessary shutdowns is sufficient to warrant prompt NRC review and approval of TSTF-234. It would also be sufficient to warrant a separate License Amendment Request were the TSTF to be withdrawn from this submittal.

FLOG Response (revised): Per discussions with the NRC, since TSTF-234 has not yet been approved, the changes associated with the TSTF will be withdrawn. However, similar changes

, were accepted by the NRC for the Callaway and Wolf Creek CTS. Diablo Canyon and Comanche Peak will revise their request to be identical to that approved for Callaway and Wolf Creek. These changes are considered to be "beyond scope".

J ATTACHED PAGES:

i Enci 2 3/4 1-17 Enci 38 7 EnclSA Traveler Status sheet (page 2),3.1-18 and 3.1-19 EncISB B 3.1-47 Encl 6A 2 Encl 68 1 l

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