CP-201900415, License Amendment Request (LAR) 19-002, Application to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

License Amendment Request (LAR)19-002, Application to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

ML19325C595
Person / Time
Site:	Comanche Peak
Issue date:	11/07/2019
From:	Thomas McCool Luminant, TXU Energy, Vistra Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201900415, TXX-19072
Download: ML19325C595 (14)

Text

m

-~ Lumi_nant Tho-mas P. McCool Site Vice President Lum1nant P.O. Box 1002 6322 North FM 56 Glen R9se, TX 7604;3 o 254.897.6042 CP-201900415 T)()(-19072 U.S. Nuclear Regulatory Commission Ref 10 CFR 50.90 ATIN: Document Control Desk 10 CFR 50.91(b)

Washington, DC 20555-0001 11/07/2019 SUBJECT COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446' LICENSE AMENDMENT REQUEST (LAR)19-002 APPLICATION TO ADOPTTSTF-563, "REVISE INSTRUMENT TESTING DEFINITIONS TO INCORPORATE THE SURVEILLANCE FREQUENCY CONTROL PROGRAM"

Dear Sir or Madam:

Pursuant to 10CFR50.90, V1stra Operations Company LLC (Vistra OpCo) hereby requests an amendment to the Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 Operating License (NPF-87) and CPNPP Unit 2 Operating License (NPF-89) by incorporating the attached change into th~ CPNPP Units 1 and 2 Technical Speclf1cations.

This change request applies to both units.

Vistra OpCo requests adoption of TSTF-563, "Revise l~~tr_ument Test;ng Definitions to Incorporate the Surveillance Frequency Control Program." TSTF-563 revises the Technical Specjf1cation (TS) def1n1t1ons of Channel Calibration, Channel Operational Test, and Trip Actuating Device Operational Test, which currently permit performance by means of 9 ny sen es of s~quential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. _ provides a description and assessment of the proposed changes. Attachment 2 provides the exist_ing TS pages marked to show the proposed changes. Attachment 3 provides revised (clean) TS pages.

Approval of the proposed amendment 1s requested within one year of the NRC acceptance date. Once approved, the amendme*nt shall be implemented within 60 days.

In accordance with 10CFR50.91(bli Vistra OpCo Is providing the State of Texas with a copy of th(s proppsed amendment. -*;i,P !J {

---

:;Jf.-f.-

6555 SIERRA DRIVE IRVING, TEXAS 75039_ 0214-812-4600 VISTRAENERGY.COM

T)()(-19072 Page 2 of 2 This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Garry W Struble at (254) 897-6628 or garry.struble@lumlnant.com.

I state under penalty of perjury that the foregoing 1s true and correct.

Executed on 11/07/2019 Sincerely, Thoma Attachments: 1. DESCRIPTION AND ASSESSMENT

2. PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

3. REVISED TECHNICAL SPECIFICATION CHANGES c-Scott Moms, Region IV Dennis Galvin, NRR Resident Inspectors, Comanche Peak

, Mr. Robert Free Environmental Monitoring & Emergency Response Manager Texas Department of State-Health Services

• Mail Code 1986 P. 0. Box 149347 Austin TX, 78714-9347

/

to TXX-19072 Page 1 of 4 ATTACHMENT 1 to TXX-19072 DESCRIPTION AND ASSESSMENT to TXX-19072 Page 2 of 4

1.0 DESCRIPTION

Vistra Operations Company LLC (Vlstra OpCo) requests adoption oUSTF-563, "Revise Instrument Testing Def1nit1ons to Incorporate the Surveillance Frequency Control Program," into the Technical Specifications (TS) of the Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2 TSTF,563 revises the Technical Spec1f1cation (TS) definitions of Channel Calibration, Channel Operational Test, and Trip Actuating Device Operational Test, which currently permit performance by means of any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined In accordance with the TS Surveillance Frequency Control Program.

2.0 ASSESSMENT 2.1 Applicab1l1ty of Safety Evaluation Vistra QpCo has reviewed the,safety evaluation for TSTF-563 provided to the Technical Specifications Task Force in a letter dated December 4, 2018. This review included a review of the NRC staff's evaluation, as well as the Information provided in TSTF-563. As descnbed herein, Vlstra OpCo has concluded that the Justrflcations presented In TSTF-563 and the safety evaluation prepared by the NRC staff are applicable to CPNPP Units 1 and 2, and Justify this amendment for the incorporation of the changes to the CPNPP Units 1 and 2 Technical Specifications.

A Surveillance Frequency Control Program was incorporated into the CPNPP Units 1 and 2 Technical Speclf1cat1ons in.a license amendment dated June 29, 2012 (NRC Agency Documents Access and Management System (ADAMS}

Accession No. ML12067A244}.

2.2 Optional Changes and Variations V1stra OpCo is not proposing any variations from the Technical Specification changes described in the TSTF-563 or the 9ppl1cable parts of the NRC staff's safety evaluation dated December 4, 2018.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Vistra OpCo requests adoption ofTSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program," into the Technical Speclflcat1ons (TS) of Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2. TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration, Ch_annel Operational Test (COT), and Trip Actuating Device Operational Test (TADOT), which currently permit performance by means of any series of sequential, overlapping, or total channet steps, to allow the ,required frequency for testing the components or devices in each step to be determined In acrnrdance with the TS Surveillance Frequency Control Program.

V1stra OpCo has evaluated whether /

or not a significant hazards consideration 1s 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 s1gnif1cant Increase In the probability or consequences of an accident previously evaluated?

Resp~inse: No to TXX-19072 Page 3 of 4 The proposed change revises the TS definitions of Channel Calibration, COT, and TADOT to allow the frequency for testing the components or devices In each step to be determined in accordance with the TS Surveillance Frequency Control Program. All components In the channel continue to be tested. The frequency at which a channel test Is performed is not an initiator of any accident previously evaluated, so the probability of an accident Is not affected by the proposed change. The channels surveilled In accordance with the affected definitions continue to be required to be operable and the acceptance criteria of the surveillances are unchanged. As a result, any mitigating functions assumed In the accident analysis will continue to be performed.

Therefore, the proposed change does not involve a significant Increase in the probab1l1ty or consequences of an accident previously evaluated.

2. Does the proposed amendment create the poss1bll1ty of a new or different kind of accident from any previously evaluated?

Response: No The proposed change revises th'e TS definitions of Channel Calibration, COT, and TADOT to allow the frequency for testing the components or: devices In each step to be determined In accordance with the TS Surveillance Frequency Control Program. The design function or operation of the components involved*

are not affected and there Is no physical alteration of the plant (i.e., no new or different type of equipmen,t will be Installed). No credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are introduced. The changes do not alter assumptions made 1n the safety analysis. The proposed changes are consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction ma margin of safety?

Response: No The proposed change revises the TS definitions of Channel Calibration, COT, and TADOT to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. The Surveillance Frequency Control Program assures suff1c1ent safety margins are maintained, and that that design, operation, surveillance methods, and acceptaAce cntena specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described m the plants' licensing basis. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate 1n the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

Margins of safety are unaffected by method of determining surveillance test mtei:vals under an NRC-approved licensee-controlled program.

Therefore, the proposed change* does not involve a s1gnrflcant reduction ma margin of safety Basecj on the above, V1stra OpCo concludes that the proposed change presents no significant hazards cons1derat1on under the standards set forth 1n 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is Just1fl~d to TXX-19072 Page 4-of 4 3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation In the proposed manner, (2) such activities will be conducted in compliance with the Comm1ss1on's regulatlons, and (3) the issuance of the amendment will not be m1mlcal to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to mstallatfon-or use of a facility component located within the restricted area, as defined In 10 CFR 20, or would cliange an inspection or surveillance requirement. However, the proposed change does not involve (1) a significant hazards consideration, (ii) a significant change in the types or significant Increase in the amounts of any effluents that may be released offs_ite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change 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 envlronmentai"impact statement or environmental assessment need be prepared In connection with the proposed change to TXX-19072 Page 1 of 4 AlTACHMENT 2 to TXX-19072 PROPOSED TECHNICAL SPEOFICATION CHANGES (MARK-UP).

Attac hment 2 to TXX-19072 Defin itions Page 2 of 4 1.1 1.1 USE AND APPLICATION 1.2 Definitions NOTE The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals between the (AFD) top and bottom halves of an excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps , and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation , of channel behavior during operation . This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

COMANCHE PEAK UNITS 1 AND 2 1.1-1 Amendment No. 4-aQ

Attachment 2 to TXX-19072 Definitions Page 3 of 4 1.1 1.1 Definitions (continued)

CHANNEL OPERATIONAL A COT shall be the injection of a simulated or actual signal into TEST(COT) the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments , as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY so that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential , overlapping or total channel steps , and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CORE AL TERA TION CORE ALTERA Tl ON shall be the movement of any fuel , sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERA TIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that provides cycle REPORT (COLR) specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1131 DOSE EQUIVALENT 1131 shall be that concentration of 1131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes I 131 ,

1132, 1133, 1134, and I 135 actually present. The determination of DOSE EQUIVALE NT I 131 shall be performed using thyroid dose conversion factors from Table Ill of TIO 14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites," or from Table E 7 of Regulatory Guide 1.109, Revision 1, NRC, 1977, or from ICRP 30, 1979, Supplement to Part 1, page 192 212, Table titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity," or from Table 2.1 of EPA Federal Guidance Report No. 11 , 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation , Submersion , and Ingestion."

COMANCHE PEAK UNITS 1 AND 2 1.1-2 Amendment No. 4-aO

Attachment 2 to TXX-19072 Definitions Page 4 of 4 1.1 1.1 Definitions (continued)

TRIP ACTUATING DEVICE A TADOT shall consist of operating the trip actuating device and OPERATIONAL TEST (TADOT) verifying the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy. The TADOT may be performed by means of any series of sequential , overlapping or total channel steps , and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

COMANCHE PEAK UNITS 1 AND 2 1.1-7 Amendment No. 4aG to TXX-19072 Page 1 of 4 ATIACHMENT 3 to TXX-19072 REVISED TECHNICAL SPEOFICATlON CHANGES

Attachment 3 to TXX-19072 ~finitions Page 2 of 4 1.1 1.1 USE AND APPLICATION 1 2 Definitions

. NOTE The defined terms of this section appear in capitalized type *and are applicable throughout these Technical Specifications and Bases. . .

Ifilm* Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes -

Required Actions to be takeh under designated.Conditions within specified Completion Times.

ACTUATION LOGIC TEST }\n ACTUAJION LOGIC TESi shall be the application of various simu!ated*or aGtual input cpmbinatio_ns iri conjunction with each po*ssible interlock logic state requ.ired for OPERABILITY of a logic circuit and the vefffication of the requi_red logic output: The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices. -

AXIAL*FLUX DIFFERENCE AFD shall be the difference i!l normalized flux signals between the (AFD)' top and bottom halves of an excore n_eutron de~ector.

CHANNEL CALIBRATION A CHANNEL Cf.LIBRATION shall be the adjustment, as necessary; of the channel output such that it responds "'(jthin the necessary rang~* and accuracy to known values of the parameter that the channel monitors: The CHANNEL CALIBRATION shall

.ericompa~ all devi<?95 in the channel required for channel OPERABILITY. Calibration of instrumerit'channels ~ith.

• resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of.sensor *_

behavior and normal calibration of the remaining adjustable devices in the channel.. The CHANNEL CALIBRATION may be performed by means of ariy series of sequential, overlapping or total chann~I steps, ~rid each step must be performed withirrthe Frequency in the Surveillance Frequency Control Program for the devices included in the step. - .

CHANNEL CHECK A CHANNE;L CHECK shall be the qualitative assessment,* by observation, of channel behavior during operation*. This detel'}Tlination shall include, where possible, comparison of the channel indication. and status to other indications or status derived fr(?m independent-instrument channels measuring the same '.

parameter.

COMANCHE PEAK UNITS 1 AND 2 1.1-1 Amendment No." 480

Attachment 3 to,TXX-19072 Definitions Page 3 of 4 1.1 1.1 Definitions (continued)

CHANNELOPERA "r!ONAL A COT shall be the injectjon of a simulated or, actual signal into TEST(COT) the channel as close to the sensor as practicable to_vemy OPERABILITY of all devices in the chan!lel req~ired for channel OPERABILITY. The COT-shall ir:iclude adjustments, as necessary, of ttie required *alarm, interlock, and trip setpoints required for channel OPERABILITY so that the setl)9ints are within the necessary' range and accuracy. The_COT may be*

~rformed by means of any series of sequential, overlapping or total channel steps, ar:id each step must be perform~ withi!l.

the Frequency in the Surveillance Frequency Control Program for the devices-included in the*step ..

CORE ALTERATION CORE ALTERATION shall qe tile movem~nt of any fuel, sources, or reactivity control components, within the reactor vessel with the vess~I head removed and fuel in the vessel. Suspension of CORE ALTERI\TIONS shall not"preclude completion of

_movement of a c6mponent to a safe position.

CORE OPERATING LIMITS The CQLR is thE;i unit spe~ific document that p*rovides cy9le REPORT (CO~R) specific parameter limits for the c*urrent reload cycle. These cycle specific parameter limits sh~II be determined for eaqh reload cycle in ac~rdance with Specification 5.6,5. Plant operation within th~e Jim its is addressed- in individual Specifications.-

DOSE EQUIVALENT 1131 DOSE EQUIVALENT. 1131.shall be that concentration of 1131 (microcuries per-gram) that alone wQuld p~oduce the same dose when inhaled as the combined actiyities ofiodine iso!opes I 131, I 132, I 133, I 134, and I 135 actually present. T_he_ determin?tion of DOSE EQUIVALENT 1131 'shall be_ per:formed using thyroid dose conversion factors from Table Ill of TIO 14844, AEC, 1962,*

"Calcuiation ofDistance Factors for: Power and Test Reactor Sltes," or from Ta.bis E 7 of Regulatory Guide 1.1 o~; Revision 1, NRC, 1977, or from ICRP 30, 1979, $upplement to Part 1-, page

.192 212, Table ~itled "Committed'Dose Equivalent in Target

_Organs orllssues per Intake of Unit Activity," or from Table 2.1 of EPA Feaeral Guidance Report *No .. 11, 1988, "Limiting Values of Radionuclfde Intake and Air Cimcentration and Dose Conve.rsion Factors for Inhalation, Submersion, and Ingestion."

COMANCHE P.EAK UNITS 1 AND 2 1.1-2 Amendment No. 4§0

Attachment 3 to TXX-19072 Definitions Page 4 of 4 1.1 1.1 Definitions (continued)

TRIP ACTUATING DEVICE A TADOT shall consist.of operatihg the trip actuating device and OPERATIONAL TEST (TADOT) verifying the OPERABILITY of all devi~ in the channel required for trip actuating device OPERABILITY. The TADOT shall include adjustment, as necessary, of the.trip actuating device so that it actuates at the required setpoint within the necessary aecuracy. The TADOT may be performed by means of any series of sequential, overlapping or total channel. steps, and each step must be performed within the Frequency in the* Surveillance .

Fr.equency Control Program for the devices included in the step.

COMANCHE P~K UNITS 1 AND 2 1.1-7 Amendment No-. 4W