ML20195F175

Proposed Tech Specs,Revising Administrative Controls Section to Include Configuration Risk Mgt Program Into CPSES TS

ML20195F175
Person / Time
Site:	Comanche Peak
Issue date:	11/13/1998
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20195F167	List: ML20195F161 ML20195F175
References
NUDOCS 9811190206
Download: ML20195F175 (9)

Text

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4 ATTACHMENT 3 TO TXX-98241 TECHNICAL SPECIFICATION MARKUP Pages: B 3/4 1-3 B 3/4 5-2 6-7 l

9811190206 981113 PDR ADOCK 05000445 P PDR ,

. TXX-98241 Pago 2 of 6 REACTIVITY CONTROL SYSTEMS BASES BORATION SYSTEMS (Continued)

With the RCS temperature below 200 F, one Boron Injection System is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the sdditional restrictions prohibiting COPE ALTERATIONS and positive reactivity changes in the r, vent the single Boron Injection System becomes inoperable.

The limitation for a maximum of two charging pumps to be OPERABLE and the requirement to verify one charging pump to be inoperable below 350 F provides assurance that a mass addition pressure transient can be relieved by the operation of a single PORV.

With one centrifugal charging pump (CCP) inoperable, the inoperable CCP must be returned to OPERABLE status within 7 days. The 7 day Allowed Outage Time is based on a risk-informed assessment to manage the risk associated with the equipment in accordance with the Configuration Risk Management Program and is a reasonable time for repair of the CCPs.

The limitation for minimum solution temperature of the borated water sources are sufficient to prevent boric acid crystallization with the highest allowable boron concentration.

The boron capability required below 200 F is sufficient to provide the required SHUTDOWN MARGIN after xenon decay and cooldown from 200 F to 140 F. This condition requires either 1,100 gallons of 7000 ppm borated water from the boric acid storage tanks or 7,113 gallons of 2400 ppm borated water from the RWST.

As listed below, the required indicated levels for the boric acid storage tanks and the RWST include allowances for required / analytical volume, unusable volume, measurement uncertainties (which inclLde instrument error and tank tolerances, as applicable), margin, and other required volume.

Tank l MODES lInd. l Unusable l Required l Measurement l Margin l other l lLevell Volume l Volume l Uncertainty l l (gal)

I I I (aal) I (cal) l I (cal)I RWST l5,6 l24% l98,900 l 7,113 l 4% of span l10,293l N/A 11.2.3.4195% I45.494 l 70.702 l 4% of scan i N/A 1357.535*

Boric l5,6 l10% l 3,221 l 1,100 l 6% of span l N/A l N/A Acid l5,6(gral20% l 3,221 l 1,100 l 6% of span l 3,679l N/A Storage l-vity l l l l l l Tank l teed) l l l l l l l1,2,3,4l50% l 3,221 l 15,700 l 6% of span l N/A l N/A I I I I I I I Additional volume required to meet Specification 3.5.4.

COMANCHE PEAK - UNITS 1 AND 2 B 3/4 1-3 Unit 1 - Amendment No. 5,10,25,44 Unit 2 - Amendment No. 562,30

. TXX-98241 i Paga 3 of 6 '

EMERGENCY CORE COOLING SYSTEMS BASES ACCUMULATORS (Continued) retum the inoperable accumulator to OPERABLE status. The completion time minimizes the potential for exposure of the plant to a LOCA under these conditions.

1 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS i The OPERABILITY of two independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the event of a LOCA assuming the loss of one subsystem through any single failure consideration. Either subsystem operating in conjunction with the accumulators is capable of supplying sufficient core cooling to limit the  ;

peak cladding temperatures within acceptable limits for all postulated break sizes ranging l from the double ended break of the largest RCS cold leg pipe downward. In addition, each l ECCS subsystem provides long-term core cooling capability in the recirculation mode during the accident recovery period. With the RCS temperature below 350 F, one OPERABLE .

ECCS subsystem is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

I The limitation for a maximum of two charging pumps to be OPERABLE and the requirement to verify one charging pump and all safety injection pumps to be inoperable below 350 F provides assurance that a mass addition pressure transient can be relieved by the operation of a single PORV.

With one centrifugal charging pump (CCP) inoperable, the inoperable CCP must be retumed to OPERABLE status within 7 daysi. The 7_ day Allowed Outage Time'is based on a risk-informed assessment to manage the risk associated with the equipment in accordance with the Configuration Risk Management Program and is a reasonable time for repair of the CCPs The requirement to remove power from certain valve operators is in accordance with Branch Technical Position ICSB-18 for valves that fail to meet single failure considerations.

Power is removed via key-lock switches on the control board.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensures that at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout conditions when the system is in its minimum resistance configuration, (2) provide the proper flow split between iniection points in accordance with the assumptions COMANCHE PEAK - UNITS 1 AND 2 B 3/4 5-2 Unit 1 - Amendment No. 40 Unit 2 - Amendment No. 26

. TXX-98241 Pags 4 of 6 used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points equal to or above that assumed in the ECCS-LOCA analyses.

3/4.5.4 REFUELING WATER STORAGE TANK The OPERABILITY of the refueling water storage tank (RWST) as part of the ECCS ensures that a sufficient supply of borated water is available for injection by the ECCS in the event of a LOCA. The limits on RWST minimum volume and boron concentration ensure that: (1) sufficient water is available within l

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COMANCHE PEAK - UNITS 1 AND 2 B 3/4 S-2 (continued) Unit 1 - Amendment No. 40 Unit 2 - Amendment No. 26 i

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. TXX-98241 l P:g35of6 I

l' ADMINISTRATIVE CONTROLS l

PROCEDURES AND PROGRAMS (Continued)

9) Limitations on the annual and quarterly doses to a MEMBER OF THE PUBLIC from lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents i released from each unit to areas beyond the SITE BOUNDARY l conforming to Appendix l to 10CFR50, and l

10) Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40CFR190.

f. Not used l Configuration Risk Management Program (CRMP)

The Configuration. Risk Management Program (CRMP) provides a l proceduralized risk-informed assessment to manage the risk associated with j equipment inoperability. -The program applies to technical specification structures, systems, or components for_which a risk-informed Allowed Outage Tinie has been granted. The program _ shallinclude the following elements:

1). Provisions.for the control an.d implementation of a Level 1, at-power, interpal events PRA-informed roethodology.) The assessment shall be l capable of evaluating the applicable plant configuration, i 2) Provisions for performing an assessment prior to entering the LCO Action for preplanned activities.

3) Provisions for performing an. assessment after._ entering the LCO Action for unplanned entry into the LCO Action;

4) Provisions for assessing the need.for additional actions after the discovery of additional equipment out of service conditions while in the

. LCO Action; 5)- Provisions for considering other. applicable risk significant contributors such as Level 2 issues,' and external events, qualitatively or quantitatively.

COMANCHE PEAK - UNITS 1 AND 2 6-7 Unit 1 - Amendment No. 44,42,50,51 Unit 2 - Amendment No. 28-36,37

. TXX-98241

. Page 6 of 6

g. Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10CFR50.54(o) and 10CFR50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program, dated September 1995".

l The peak calculated containment intemal pressure for the design basis loss of coolant accident, P., is 48.3 psig.

1 The maximum allowable containment leakage rate, L, at P., shall be 0.10% of containment air weight per day.

l Leakage rate acceptance criteria are:

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1. Containment leakage rate acceptance criterion is s 1.0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L, for the Type B and Type C tests and s 0.75 L, for Type A tests;

2. Air lock testing acceptance criteria are:

a) Overail air lock leakage rate is s0.05 L, when tested at 2 P,.

b) For each door, leakage rate is s 0.01 L, when pressurized to 2 P,.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program, with the exception of the containment ventilation isolation valves, which is specified in Specifications 4.6.1.7.2 and 4.6.1.7.3.

The provisions of Specification 4.0.3 are applicable to the Containment Leakage Fele Testing Program.

COMANCHE PEAK - UNITS 1 AND 2 6-7 (continued) Unit 1 - Amendment No. 14,42,50,51 Unit 2 - Amendment No. 28S6,37

ATTACHMENT 4 TO TXX-98241 IMPROVED TECHNICAL SPECIFICATION MARKUP (Section B 3.5.2 Action A.1 and Section 5.5.6) e

. 1 ECCS -Operating B 3.5,2 BASES 1

ACTIONS 6.J With one or more trains inoperable for. reasons other than an inoperable centrifugal charging pump and at least 100% of the ECCS flow equivalent to a l single OPERABLE ECCS train available. the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an NRC reliability waluation (Ref. 5) and is a reasonable time for repair of many ECCS compon e -

With one centrifugalJcharging pump 1(CCP): inoperable and at:least 100% of the i flow equivalent.to.a. single OPERABLE!ECCS train ~ava11able,7the! inoperable CCP l

must be returned .to OPERABLE ~ status.withi_n:7 days;L The__7: day Completion Time is based on a risk _-informed assessment to manage the risk associated with equipmenttin accordance with the Configuration Risk Management. Program and is a reasonable time.for_ repair of the'.CCPs; s _

An ECCS train is inoperable if it is not capable of delivering design flow to the RCS. Individual components are inoperable if they are not capable of I performing their design function or supporting systems are not available. )

The LC0 requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components. j each in a different train, necessarily result in a loss of function for the 1 ECCS. The intent of this Condition is to maintain a combination of equipment such that 100% of the ECCS flow equivalent to a single OPERABLE ECCS train '

, remains available. This allows increased flexibility in plant operations under circumstances when components in opposite trains are inoperable.

An event accompanied by a loss of offsite power and the failure of an EDG can disable one ECCS train until power is restored. A reliability analysis (Ref. 5) has shown that the impact of having one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Reference 6 describes situations in which one component such as an RHR crossover valve can disable both ECCS trains. With one or more component (s) l inoperable such that 100% of the flow equivalent to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident l analysis. Therefore, LC0 3.0.3 must be immediately entered.

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Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS 5.'5 Programs and Manuals

, 5.5.6 Not used Confiauration Risk Man == ant' Proaram (CRMP)

r, ' , ,1The Configuration Risk Management Program (CRMP)

provides.a procedura11 zed risk informed assessmentito manage the risk: associated with equipment inoperability, iThe program: applies to technical:; specification structures, .

systems; Lor components.for which a risk . informed Completion < Time lhas.been granted .2 The program lshall : 1 ncl ude Lthe ' fol l owi ng elements ;

E:m _m ;a. . Provisions;for;the control:and.; implementation of, a, Level?l,; at power; i nternal events ; PRAs i nformed . methodol ogy.3The . assessment , shall . be capable:of evaluating the applicable planticonfiguration't c"  ; b.' ' Provisions;;for performing an assessment prior to; entering the LCO Condition for; preplanned ~ activities;

' c. Provisions;for performing.an assessment after entering the LCO Condition forJ unplanned ~ entry into_ the.LCO. Condition.

'i", ' T d. Provisions for assessing;the need.for; additional; actions'after the m

discoveryf ofiadditional: equipment out'of, service conditions whileiin the LC0 Condition;

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.e/ . Provisions for consideringLother. applicable risk!significant contributors such as._ Level 2 issues,Jand external: events.: qualitatively or. quantitatively!

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