View source for TXX-9810, LAR 98-005 to Licenses NPF-87 & NPF-89,incorporating Encl Change Into Plant,Units 1 & 2 Ts.Change Is Applicable to Unit 2 & Administrative for Unit 1.Affidavit,encl

{{Adams
| number = ML20216E617
| issue date = 04/09/1998
| title = LAR 98-005 to Licenses NPF-87 & NPF-89,incorporating Encl Change Into Plant,Units 1 & 2 Ts.Change Is Applicable to Unit 2 & Administrative for Unit 1.Affidavit,encl
| author name = Terry C, Walker R
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-98107, NUDOCS 9804160257
| package number = ML20216E622
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 19
}}

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                                                                            =.                    .=                        Log # TXX 98107 s                                                                           r                      C                        File # 916 (3/4.8) 7UELECTRIC Ref#NhR50.90 10 CFR 50.36
: c. L. wery s<asor uc, Pre,uf,a,                                                                                         Apri1 9, 1998
             & PrincipalNuclear Olylcer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50 446
"                            SUBMITTAL OF LICENSE AMENDHENT REQUEST (LAR) 98 005 A.C. POWER, OPERATING REF:              1. TV Electric Letter, logged TXX 98100, from C. L. Terry to the NRC dated April 6, 1998
: 2. TU Electric Letter, logged TXX-98116, from C. L. Terry to the NRC dated April 7, 1998 Gentlemen:                                                                                                                                         '
Pursuant to 10CFR50.90, TU Electric hereby requests an amendment to the CPSES                                                                  "
Unit 1 Operating License (NPF 87) and CPSES Unit 2 Operating License (NPF 89) by incorporating the attached change into the CPSES Units 1 and 2 Technical Specifications. This change is only applicable to CPSES Unit 2 and is administrative for Unit 1.
On April 6, 1998. TU Electric submitted a letter (TXX 98100) (reference 1) requesting enforcement discretion. On April 7, 1998, TV Electric submitted a second letter (TXX 98116) (reference 2) which provided some corrections to the April 6'" letter and superseded it in its entirety. A conference call was held on April 8,1998, at 9:30 a.m. CDST between the NRC staff and TV Electric. During that phone call, TU Electric agreed to make several corrections and clarifications to the April 7'" letter as part of this license amendment request. The required changes are provided below:
In reference 5 of TXX 98116, the word is " logged" (not " logger") and the correct date for reference 5 is April 6, 1998 (not April 7, 1998).
9804160257 980409 PDR P
ADOCK 05000445                                                                                                                   \
PDR                                                                                                              f h
COMANCllE PEAK STEAM ELECTRIC S1 ATION P.O. Box 1002 Glen Rose. Texas 76043 1002                                                             y

TVX:98107 Page 2 of 3
        .       " Category 4" is listed in a footnote in attachments 1 through 5 but is not discussed anywhere in the text. Category 4 was originally created as a potential category that some of the untested contacts might be best assigned. Based on the reviews performed and the actions taken by TU Electric, none of the components which were included in the request for enforcement discretion were category 4 components. As a result, none of the items on attachments 1 though 5 were assigned to category 4 and category 4 does not need to be addressed in the text of the letter.
        .       The proposed footnote for the technical specification change reads, in part, that the specified testing "... may be deferred until the startup from 2RF04 or earlier outage of greater than 72 hours duration to at least MODE 3." TU Electric agreed to delete the "of greater than 72 hours duration" and that deletion is reflected in this license amendment request.
At 9:45 a.m. on April 8. 1998, the NRC granted the requested enforcement discretion. This license amendment request satisfies the commitment in that enforcement discretion request to submit a license amendment request for a one time exception to not perform the portions of the surveillances related to the enforcement discretion and to allow crediting performance of other portions of the surveillances during power operation.
This LAR is being submitted as follow up to the request for enforcement discretion (reference 2). The license amendment should be effective upon' issuance to be implemented immediately.
Attachment 1 is the required affidavit. Attachment 2 provides a detailed description of the proposed changes, a safety analysis of the changes, and TV Electric's determination that the proposed changes do not involve a significant hazard consideration. Attachment 3 provides the affected Technical Specification page, marked up to reflect the proposed changes.
In accordance with 10CFR50.91(b). TU Electric is providing the State of Texas with a copy of this proposed amendment.
Should you have any questions, please contact Mr. Bob Dacko at                 '
(254) 897 0122.

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TXX 98107                                                                i Page 3 of 3                                                              l This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2.
                                                 . Sincerely, 1
O, N.
C. L. Terry                     1 By:    adJ24 h.
Roger 95. Walker Regulatory Affairs Manager BSD/bd Attachments:
: 1. Affidavit
: 2. Description and Assessment
: 3. Affected Technical Specification page as revised by all approved license amendments c-      E. W. Herschoff, Region IV J. I. Tapia, Region IV T. J. Polich, NRR Resident Inspectors, CPSES Mr. Arthur C. Tate Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78704                                           i I
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Attachment'l to TXX 98107 Page 1 of 1                                                                     ;
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UNITED STATES OF AMERICA                           l i
l NUCLEAR REGULATORY COMMISSION In the Matter of                             )
                                                            )
Texas Utilities Electric Company              )         Docket Nos. 50 445
                                                            )                       50 446   I (Comanche Peak Steam Electric                )         License Nos. NPF 87 Station, Units 1 & 2)                         )                       NPF 89 AFFIDAVIT l
Roger D. Walker, being duly sworn, hereby deposes and says that he is Regulatory Affairs Manager for TU Electric, the licensee herein: that he       i is duly authorized to sign and file with the Nuclear Regulatory Commission     i this License Amendment Request 98 005; that he is familiar with the l
content thereof: and that the matters set forth therein are true and           l correct to the best of his knowledge, information and belief.
yc.. p u._m. m . _ ,
                           ! f 6h  8                   # h, i -
                     .y.s. m m .
                                        ?
                                       -p Roge FD. Walker Regulatory Affairs Manager             i STATE OF TEXAS        )
                                     )                                                       ,
COUNTY OF somervell)                                                          i Subscribed and sworn to before me, on this     9th   day of April, 1998     .
0l f         NC D NgtaryPublic

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ATTACHMENT 2 to TXX 98107   l DESCRIPTION AND ASSESSMENT l
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Attachment 2 to TXX 98107 Page 1 of 14                                                                     l j
DESCRIPTION AND ASSESSMENT I. BACKGROUND During the process of conducting reviews in accordance with U.S. NRC Generic Letter 96 01, CPSES discovered that certain lockouts, various            I seal in contacts and diesel generator trip bypass circuits were not verified to perform their required functions or were not unambiguously verified under the current testing methodology. Therefore, complete           J testing in accordance with Surveillance Requirement (SR) 4.8.1.1.2f has not been performed as identified in Tables 1, 2 and 3. These omissions in the surveillance program at CPSES have been present since the issuance of     j the initial operating license for Unit 2 and were identified on March 24,       i 1998. As the ambiguity constitutes a failure to perform a SR within the surveillance frequency plus allowable extension in accordance with SR 4.0.2 and performance of the SRs within 24 hours was not achievable,            {
enforcement discretion was requested and granted by the NRC. Whereas, the surveillances in question applied to both Units 1 and 2, the Unit 1             I surveillances are scheduled to be performed prior to the startup from the       l current Unit 1 outage. Therefore, this license amendment is requested for       !
Unit 2 only.
This change does not it, .ct the improved Standard Technical Specifications     ,
because it is a temporary change and is plant specific. Neither does this       !
change impact the CPSES improved Technical Specifications submittal           j l       (LAR 97 01). Prior adoption of approved line item improvements to the            '
Technical Specifications or the improved Standard Technical Specifications would not have obviated the need for this license amendment request.
II. DESCRIPTION OF TECHNICAL SPECIFICATIONS CHANGE REQUEST                  j This LAR provides a tempo.ary Technical Specification change for SRs 4.8.1.1.2 f.4)a) , 4.8.1.1.2 f.4)b) , 4.8.1.1.2f 6) a) , 4.8.1.1.2f. 6)b) and 4.8.1.1.2f.6)c) to credit the at power verification of the proper               {
operation of the Unit 2 load shed seal in contacts and the diesel generator trip bypass contacts, and to allow the deferral of verification of the proper operation of the Unit 2 lockout relays and contacts until         !
startup from 2RF04 or earlier outage to at least H0DE 3.                        !
                                                                                      }  '
III. ANALYSIS The safety basis for this request is commensurate with the safety                ,
functions and significance of the components that have not been tested per    {
the relevant SR. The safety functions and significance of those components vary as denoted in Tables 1. 2, and 3. As such, the following        l I
discussion is broken down by the classifications and categories depicted within those tables.                                                          -
l The conditions discussed individually below have all existed since initial issuance of the CPSES Unit 2 operating license. When a surveillance is identified which has not been performed within the prescribed time period, the Technical Specifications allow the ACTION requirements to be delayed up to 24 hours (provided the allowed outage time for the ACTION l
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Attachment 2 to TXX 98107                                                        l Page 2 of 14 requirements is less than 24 hours) for the performance of the                   l surveillance in accordance with SR 4.0.3. In NUREG 1431, this allowance          l 1s contained within SR 3.0.3. As stated in the BASES to SR 3.0.3 of             1 NUREG 1431 Rev. 1, "the basis for this delay seriod includes consideration      l of unit conditions, adequate planning, availasility of personnel, the time     {
required to perform the Surveillance, the safety significance of the delay      ;
in completing the required Surveillance, and the recognition that the most       l probable result of any particular Surveillance being performed is the           i verification of conformance with the requirements." Consistent with this position. TU Electric believes that performance of the SR will most probably demonstrate OPERABILITY. In addition to this general position concerning all of the testing omissions, case specific discussions are presented.
a)     Table 1 lists automatic lockouts and some operator lockouts (Items 2, 3, 4, 5 and 6) which block undesired automatic actions, which start and stop equipment, which actuate auxiliary relays, and which     '
require testing. TV Electric's review of these lockouts has not revealed a method of testing these lockouts in totality during MODE
: 1. POWER OPERATION, without exposing Unit 2 to what TV Electric           .
feels it undue risk. TV Electric has demonstrated the functionality of the relays which actuate these contacts. Functional verification   ,
that all relay contacts have repositioned was not demonstrated,          j however each relay was shown to have actuated by a positive verification methodology. While the relays were safely tested at power, due to the setup required to actuate, monitor, and verify the individual contacts, TV Electric is not prepared to say that the contact testing can be done safely at power. In addition, contacts involved with Train A common busses are listed in Table 1 (Item 7).
These busses have loads which are affected by auxiliary lockout relays scoped with Unit 1 Train A. The Unit 2 contacts that affect these busses are category 3 and are included in items 2, 3, 4, and
: 5. The Unit 1 auxiliary relays will be tested during 1RF06 (and are therefore noted as category 5).
The safety functions of the lockouts are listed in Table 1 by groupings. These contacts are relied upon to ensure that perturbations in the diesel generator starting and loading sequence are avoided. Failure of the lockouts which block the auto start of equipment would allow loads to attach inappropriately to the A.C.
bus potentially rendering the bus unavailable as the power source for the necessary equipment to support reaching and/or maintaining       ,
safe shutdown following an event. Failure of the lockouts which start and/or stop equipment could result in equipment not being available as assumed in an accident analysis or could result in excessive load on the DG at some point in its loading sequence.
TV Electric believes that the operability of these lockout contacts       I will be confirmed when the contacts are tested. The bases for this        l belief (in addition to that presented generically in the bases for        I LC0 3.0.3) are as follows:
: 1. The lockout relays are identical to the load block relays which have been routinely tested over the life of CPSES Units 1 and 2.

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                                                                                  '  to TXX 98107 Page 3 of 14 During the course of over 8 years of operation and testing, none of these relays have failed to perform their function.
: 2. The CPSES Unit 1 Train B lockout relays and contacts, which are essentially identical to tl,e lockout relays on Unit 2, have been tested during the current Unit i refueling outage.       As expected, no failures were identified and surveillance testing served as confirmation of OPERABILITY.
Testing of the Unit 1 Train A lockout relays and contacts will be     ;
completed prior to the end of the current Unit 1 outage, IRF06 (the testing is presently scheduled to be completed by April 17).
: 3. Each lockout relay has been demonstrated to actuate by positive         l verification.
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: 4. Pre operational testing in 1992 verified that the relays and contacts of concern operated as designed. Therefore, when the relays actuate, reasonable assurance exists that the contacts will reposition correctly.                                            !
                                                                                 )
: 5. The sequencer relay coils are continuously monitored on line for         '
continuity. If continuity were lost, the sequencer trouble alarm would alert the operators to take action.                             j
: 6. The diesel generator has repeatedly demonstrated the capability to start and load satisfactorily without problems introduced by       !
malfunctions of either the relays or their associated contacts.
These previous tests add additional evidence that the confirmation of OPERABILITY is highly probable. Although this          ,
testing has not provided unambiguous confirmation that the            {
contacts currently perform their required functions, it is most       i likely that the circuits have responded appropriately during the      j previous integrated tests.
l TU Electric requests a one time deferral of the performance of the         j above SRs until the startup from 2RF04 or earlier outage to at least       j H0DE 3. The potential safety consequences resulting from a shutdown        l of Unit 2 (as would be required if the requested license amendment         '
is not granted) are clearly higher than allowing Unit 2 to continue to operate without these lockout contacts (for which there is a high level of confidence that they will function as designed) being unambiguously tested.        Because the Unit I lockout contacts on the Train A common busses will be tested as part of 1RF06, the technical specification change will not need to include these Unit 1 contacts.
b)    Table 1 lists lockouts (Items 1. 3 and 5) which block undesired manual actions and which require testing. TV Electric's review of these lockouts has not revealed a method of testing these lockouts in totality during MODE 1, POWER OPERATION, without exposing Unit 2        .
to what TV Electric feels is undue risk. TU Electric has                   I demonstrated the functionality of the relays which actuate these contacts. Functional verification that all relay contacts have repositioned was not demonstrated, however each relay was shown to have actuated by a positive verification methodology. While the

l Attachment 2 to TXX 98107                                                        I l
Page 4 of 14                                                                    )
;       relays were safely tested at power, due to the setup required to actuate, monitor, and verify the individual contacts. TU Electric is not prepared to say that the contact testing can be done safely at power. In addition, some Train A common busses are listed in Table 1 (Item 7). These busses have loads which are affected by lockout        ,
relays from Unit 1 Train A.       The Unit 2 contacts that affect these busses are category 3 and are included in items 1, 3 and 5. The Unit 1 relays will be tested during 1RF06 (and are therefore noted as category 5).
The safety functions of the lockouts are listed in Table 1 by groupings. These contacts are relied upon to ensure that aerturbations in the diesel generator starting and loading sequence
         )y operator action are avoided. Failure of the lockouts would allow loads to be attached inappropriately to the A.C. bus potentially rendering the bus unavailable as the power source for the necessary l       equipment to support reaching and/or maintaining safe shutdown following an event.
TU Electric believes that the operability of these lockout contacts      i will be confirmed when the contacts are tested. The bases for this belief (in addition to that presented generically in the bases for         )
LC0 3.0.3) are as follows:
: 1. The lockout relays are identical to the load block relays which have been routinely tested over the life of CPSES Units 1 and 2.
During the course of over 8 years of operation and testing, none of these relays have failed to perform their function.
: 2. The CPSES Unit 1 Train B lockout relays and contacts, which are essentially identical to the lockout relays on Unit 2, have been tested during the current Unit I refueling outage. As expected,       J l           no failures were identified and surveillance testing served as         j confirmation of OPERABILITY.                                           l Testing of the Unit 1 Train A lockout relays and contacts will be completed prior to the end of the current Unit 1 cutage, 1RF06 (the testing is presently scheduled to be completed by April 17).
: 3. Each lockout relay has been demonstrated to actuate by positive verification.
: 4. Pre-operational testing in 1992 verified that the relays and contacts of concern operated as designed. Therefore, when the relays actuate, reasonable assurance exists that the contacts will reposition correctly.
: 5. The sequencer relay coils are continuously monitored on line for continuity. If continuity were lost, the sequencer trouble alarm   j would alert the operators.
: 6. The diesel generator has repeatedly demonstrated the capability to start and load satisfactorily without problems introduced by malfunctions of either the relays or their associated contacts.
These previous tests add additional evidence that the

Attachment 2 to TXX 98107 Page 5 of 14 confirmation of OPERABILITY is highly probable. Although this testing has not provided unambiguous confirmation that the contacts currently perform their required functions, it is most likely that the circuits have responded appropriately during the previous integrated tests.
: 7. The manual actions which these-lockout contacts are designed to block are very unlikely to occur. The p3riod of time in which the blocks are needed is very short (110 seconds or less). Both the operating proceduret, and operator training include aspects which decrease the chances that the undesirable manual actions would ever occur.
TU Electric requests a one time deferral of the performance of the above SRs until the startup from 2RF04 or earlier outage to at least MODE 3. The potential safety consequences resulting from a shutdown of Unit 2 (as would be required if the requested license amendment is not granted) are clearly higher than allowing Unit 2 to continue to operate without these lockout contacts (for which there is a high level of confidence that they will function as designed) being tested. In addition, the operating procedures and operator training decrease the likelihood that undesirable manual actions would occur and can mitigate the potential impact of other failures that might occur. Because the Unit 1 lockout contacts on the Train A common busses will be tested as part of 1RF06, the technical specification change will not need to include these Unit 1 contacts.
c)    Table 2 (Items 1 and 2) lists those seal in contacts on CPSES Unit 2 that perform a load shed function as described within the FSAR which have not previously been unambiguously tested. Those contacts listed in Table 2, may be tested during H0DE 1 POWER OPERATION, and are noted as Category 2. For this category, the purpose of the license amendment is to allow the crediting of at power testing for the "during shutdown" SRs. The at power testing is scheduled to be completed by April 16, 1998. Also included in Table 2 are the seal.
in contacts for the Train A common busses. These contacts are category 5 for these common busses may be transferred to Unit 1 and tested shutdown as part of the ongoing refueling outage for Unit 1 (1RF06).
The safety function of the seal in contacts is to ensure that the indicated equipment does not inappropriately load onto the A.C. bus powered by an operating diesel generator. These contacts are relied upon to ensure that the unnecessary equipment loads do not cause perturbations in the diesel generator starting and loading sequence.
Failure of the seal in contacts in such a manner as to allow the loads to attach inappropriately to the bus could render the A.C. bus unavailable as the power source for the necessary equipment to support reaching and/or maintaining safe shutdown following an event. However, these loads are relatively small in comparison to the allowable diesel generator loading. Therefore, based on a qualitative assessment, a combination of failures would be necessary to render the diesel generator incapable of performing its function. l l

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Attachment 2 to TXX 98107 Page 6 of 14 The diesel generator has repeatedly demonstrated the capability to start and load satisfactorily. These previous tests add additional       j evidence that confirmation of OPERABILITY is probable. Although          i this testing has not provided unambiguous confirmation that the         l contacts currently perform their required functions, it is most likely that the contacts have res)onded appropriately during the previous integrated tests. For tie seal in contacts, the relays are      j operated periodically in normal operation and/or surveillance             I testing and the functionality of only one or more contacts may not       !
have been verified. As such, the current plant configuration is acceptable for continued operation until such time as the SR can be completed for these contacts.                                           i TV Electric believes that the crediting of these segments of the integrative tests are both acceptable and appropriate during POWER      i OPERATIONS.
                                                                                      )
TV Electric requests a one time allowance to credit at power testing that demonstrates the functionality of the associated contacts to         l satisfy the during shutdown surveillance requirements. The potential safety consequences resulting from a shutdown of Unit 2 (as would be required if the license amendment is not granted) are clearly higher than allowing Unit 2 to continue to operate with crediting at power tests to demonstrate operability for these seal-in contacts. Because the seal in contacts on the Train A common busses will be tested as part of 1RF06, the technical specification change will not need to include these contacts, d)    Table 2 (Item 3) lists the contacts on CPSES Unit 2 that perform a load shed function for the instrument air compressors.         These contacts may be tested during H0DE 1. POWER OPERATION, and are noted as Category 2.        For this category, the purpose of the license amendment is to allow the crediting of at power testing for the "during shutdown" SRs. The at power testing is scheduled to be           I completed by April 16, 1998.
The safety function of the contacts is to ensure the instrument air compressors are load shed from the A.C. bus prior to being powered        ,
by an operating diesel generator. These contacts are relied upon to       l ensure that the instrument air compressor loads do not cause              !
perturbations in the diesel generator starting and loading sequences. Failure of a contact in such a manner as to allow the load to attach inappropriately to the bus could render the A.C. bus unavailable as the power source for the necessary equipment to support reaching and/or maintaining safe shutdown following an event. However, this single load is relatively small in comparison       l to the allowable diesel generator loading.       Therefore, based on a   l qualitative assessment, a combination of failures would be necessary to render the diesel generator incapable of performing its function.
The diesel generator has repeatedly demonstrated the capability to start and load satisfactorily. These previous tests add additional evidence that confirmation of OPERABILITY is probable. Although this testing has not provided unambiguous confirmation that the contacts currently perform their required functions, it is most

Attachment 2 to TXX 98107 Page 7 of 14 likely that the contacts have responded appropriately during the previous integrated tests. As such, the current plant configuration is acceptable for continued operation until such time as the SR can be completed for this contact.
TV Electric believes that the crediting of these segments of the      i integrative tests are both acceptable and appropriate during POWER OPERATIONS.
TU Electric requests a one time allowance to credit at power testing    ,
that demonstrates the functionality of the associated contacts to       j satisfy the during shutdown surveillance requirements. The potential  i safety consequences resulting from a shutdown of Unit 2 (as would be required if the requested license amendment is not granted) are         J clearly higher than allowing Unit 2 to continue to o)erate with         j crediting the at power test to demonstrate the opera)111ty of these   -
l seal in contacts.
I           e)    Table 3 lists contacts on CPSES Unit 2 that perform the function of ensuring that non emergency diesel generator trips do not result in      .
the trip of a diesel generator operating in the emergency mode.          l These contacts may be tested during MODE 1 POWER OPERATION, and are      l
!                 noted as Category 2. For this category. the purpose of the license i
amendment is to allow the crediting of at power testing for the         t "during shutdown" SRs. The at power testing is scheduled to be completed by April 16, 1998.
The safety function of the contacts is to ensure that the engine overspeed and generator differential are the only diesel generator faults that would actually result in the tripping of a diesel generator during an emergency start. Failure of these contacts could result in the diesel generator tripping on a non emergency trip signal when the diesel generator is operating in the emergency mode.
!                 Under the worst case failure scenario for these contacts, the diesel  !
I generator would trip from a valid non emergency trip signal. The        l Emergency Response Guidelines currently provide operator recovery instructions for this scenario.
TU Electric believes that the crediting of these segments of the integrative tests are both acceptable and appropriate during POWER OPERATIONS.
TV Electric requests a one time allowance to credit at power testing l                 that demonstrates the functionality of the associated contacts to satisfy the during shutdown surveillance requirements. The potential safety consequences resulting from a shutdown of Unit 2 (as would be required if the requested license amendment is not granted) are clearly higher than allowing Unit 2 to continue to         l operate with crediting at power tests to demonstrate the operability    j of these seal in contacts.                                              i l
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Attachment 2 to TXX 98107 Page 8 of 14 A plant specific evaluation was performed to estimate the potential impact of the deferral of Unit 2 TS requirement testing on overall plant risk.
This evaluation was done using the CPSES IPE model. The result of this evaluation demonstrates that the total core damage frequency (CDF) could increase by less than 2 percentage should these tests be deferred to the next Unit 2 refueling outage. This increase is considered to be insignificant. In addition, the industry guidelines consider an increase in CDF up to 13% to be quite acceptable for a temporary plant change / plant alteration.
The PRA evaluation takes credit for the operator action to manually remove non essential loads from the diesel generators following a loss of off-site power initiating event should any of the relay contacts fail to load shed as required. A list of loads that can be shed has been provided to the operator by a shift order. Furthermore, this evaluation conservatively assumes that any failure of any single relay contact to function will result in the failure of the associated diesel generator to start and run due to potential overloading of diesels.      In reality, single failures that result in a 480 volt load inappropriately loaded on the DG are not expected to have any adverse impact.
Although not part of the license amendment request, the course of action planned by TU Electric includes some at power testing to verify the functionality of some of the relays and contacts listed and discussed above. The operating and testing procedures that will be used to perform this at power testing are designed to minimize any adverse impact on safety. As part of the procedure development, the procedure writers and reviewers consider the conditions required to perform the test, the actions that will occur when the test is run and the potential adverse events that could occur. For this testing, where a defined set of relays and contacts are being operated, the pretest conditions are essentially normal operating conditions. If a relay or contact fails to operate, there is no adverse impact as the plant remains in the normal lineup.
When the contacts do operate, there will be cases that equipment will operate which either do not need to be operating or should not be operating. If the equipment does not need to operate, the procedure will have the operator shut the equipment down. If the equipment should not operate, the procedure will include actions to inhibit that operation (e.g., racking out the breaker or using pull to lock).      In some cases, such action may require the unit to enter an action statement as equipment     I required to be operable by a technical specification LC0 must be taken out     '
of service. The potential impact is also minimized by testing only one train at a time. When the testing is complete, equipment is returned to its normal operating condition. As can be seen, this at power testing is performed in a such manner that there is no significant impact on safety, even if the: equipment fails to function as designed.
In summary, TU Electric concludes that these Technical Specifications changes are safe and should be determined to be acceptable.
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Attachment 2 to TXX 98107 Page 9 of 14 IV. SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS TV Electric has evaluated whether or not a significant hazards               ,
consideration is involved with the proposed changes by focusing on the       i three standards set forth in 10CFR50.92(c) as discussed below:
: 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change is to delay performance of certain portions of the surveillance testing of specific devices and for the crediting of the at power testing of certain portions of shutdown surveillance requirements as previously described and listed in Tables 1, 2 and
: 3. Delaying performance of these tests until such time as appropriate or crediting of at power testing of shutdown surveillance requirements does not increase the probability of an accident. The failure of any of these devices would not create an accident: therefore the probability of an accident previously evaluated is not increased.
No plant equipment is adversely affected by not performing these surveillance tests. The consequences of an accident, as analyzed in the FSAR, does not increase from not having performed the testing.
Based on the statements above and the expectation that the deferred testing and the at power testing will confirm OPERABILITY, this change poses no increase in the consequences of a previously evaluated accident.
: 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Delaying the performance of tests and the crediting of at power testing of shutdown surveillance requirements are administrative actions and do not have the potential to create a new or different kind of accident from any previously evaluated. The systems will continue to respond in the same manner as they currently do.
: 3. Do the proposed changes involve a significant reduction in a margin of safety?
Delaying the performance of, or crediting the at power testing of shutdown surveillance requirements for those portions of the surveillance testing necessary to demonstrate the lockouts and seal-in circuitry, does not significantly reduce a margin of safety. The circuitry is expected to perform its design functions.
Based on the above evaluations, TU Electric concludes that the activities associated with the above described changes present no significant hazards consideration under the standards set forth in 10CFR50.92(c) and, accordingly, a finding by the NRC of no significant hazards consideration is justified.

I Attachment 2 to TXX 98107 Page 10 of 14 V. ENVIRONMENTAL EVALUATION TV Electric has determined that the proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in 10CFR20, or would change an inspection or surveillance requirement. TV Electric has
  ,          evaluated the proposed changes and has determined that the changes do not involve (1) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for cate90rical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), an environmental assessment of proposed changes is not required.
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I Attachment 2 to TXX 98107 Page 11 of 14 TABLE.1 LOCK 0UT CONTACTS REQUIRING TESTING l
Iten       Classification          Train     I      Cat  Test in   Affected Equipment p                                            ,      ,
1 B cks        A and B  61      3     No      See Table 4 o{t ou      Blocks 2                                 A and B  23      a     No      See Table 4 l                                                                                                     i l                    Lockout      Blocks                                                               )
3       manual and auto           A and B  24      3     No      See Table 4 starts l                    Lockout      Starts l-           4       and/or stops              A and B   17     3     No      See Table 4 equipment
!            5 Lockout      Actuates     A and B   12**   3     No See items 1, 2, 3 and
!                    an auxiliary relay                                       4 Automatic Lockout -
[            6       Bypass / block DG         A and B  4       3     No      DG Output Breaker interlock / trip Lockout      Functions                                                            l 7         d        b     e        A        27*     5     NA Unit 1 Train A lockout by Unit 1 testing relays only during 1RF06
* 27 of 54 contacts have been tested in Unit 1 Train B
                        ** Most of the lockout relay contacts which actuate auxiliary relays were confirmed to function as designed during the at power testing which provided positive verification that the lockout relays and auxiliary relays function as designed.
(1)     Number reflects the number of contacts (2)     Category 1     Testing is not required Category 2 - Testing may be performed at power                                     j Category 3     Testing not to be performed at power, however relay functionality either has been demon =u aced or will be demonstrated prior to the end of the current enforcement discretion.                         "
Category 4     Not used Category 5     Testing to be performed durir.g 1RF06 l
l

Attach ent 2 to TXX 98107
    .        Page 12 of 14 TABLE 2 SEAL IN CONTACTS REQUIRING TESTING Item g       Classification         Train     f     Cat  Test in    Affected Equipment DG Lube Oil Heater l                                                                       DG Jacket Water Heater RHR Room Fan Cooler Containment Spray Pump Room Fan Coolers SI Pump Room Fan Load Shed    NOT                                        Cooler 1       Verified during            A       10     2     Yes    Motor Drive AFW Pump Normal Operations                                       Room Fan Cooler       1 CCW Pump Room Fan       !
Cooler                j Positive Displacement Charging Pump Room Fan Cooler             .
DG Generator Space Htr DG Lube Oil Heater DG Jacket Water Heater RHR Room Fan Cooler Containment Spray Pump Load Shed - NOT                                         Room Fan Coolers SI Pump Room Fan 2       Verified during            B       9      2     Yes Normal Operations                                       Cooler Motor Drive AFW Pump      i Room Fan Cooler          l CCW Pump Room Fan Cooler DG Generator Space Htr Load Shed    NOT 3       Verified during         A and B     2     2     Yes Instrument Air Compressors Normal Operations Load Shed    NOT Control Room AC Units 4       Verified during            A        9     5      NA Vent Filter Heaters Normal Operations                                      Ventilation Fans Spent Fuel Pool Pumps (1)     Number reflects the number of contacts (2)     Category 1   Testing is not required Category 2   Testing may be performed at power l               Category 3   Testing not to be performed at power, however relay functionality l                            either has been demonstrated or will be demonstrated prior to the I
end of the current enforcement discretion.
Category 4   Not used l               Category 5   Testing to be performed during 1RF06

Attachment 2 to TXX 98107
)               Page 13 of 14 l
l l                                                    TABLE 3 l                                     VARIOUS CONTACTS REQUIRING TESTING l
Item                                             C    Te     "
y       Classification         Train
((      (    H0DE 1 Affected Equipment cy trips 1       DG Trip Bypass          A and B   6*        2    Yes
                                                                             ]er 9
* The Unit 2 Train B contacts (3) have already been tested at power.
I l                                                                                                  1 l
i l-                                                                                                i i                                                                                                  l l
l l
I l
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l t                                                                                                 1 (1)      Number reflects the number of ccntacts (2)      Category 1   Testing is not required                                           j Category 2   Testing may be performed at power Category 3 - Testing not to be performed at power, however relay functionality either has been demonstrated or will be demonstrated prior to the end of the current enforcement discretion.
Category 4   Not used Category 5   Testing to be performed during 1RF06 i

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Attachment 2 to TXX 98107                              i Page 14 of 14                                         j TABLE 4 Lockout Relay Functions l
Loads with a block of automatic or manual start:
Chilled Watar Recirc Pumps CCW Pumps                                     i AFW Pumps                                     I SSW Pumps Pressurizer Heaters Vent Chiller Water Recirculation Pump Spent Fuel Pool Cooling Pumps Control Room AC Units Reactor Makeup Water Pumps DG Air Compressors                            ,
UPS HVAC Unit Fans                           4 Safety Chillers DG Jacket Water Pumps DG Aux Lube Oil Pumps DG Prelube Pumps Instrument Air Compressors Containment Spray Pumps                       ,
SI Pumps                                      )
4 RHR Pumps CCP Pumps Containment Recirc Fans Chilled Water Recirc Pumps                   '
PD Pump Aux Bldg Equip Rm Exh Fans Plant Vent Exh Fans loads with an automatic start and/or stoo:
,                TDAFW Pump Vent Chilled Water Pumps Rad Monitors DG Emergency Start Spent Fuel Pool Pumps Safety Chillers Reactor Makeup Water Pumps}}