ML20203K862

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Proposed Tech Specs,Increasing RWST low-low Level Setpoint
ML20203K862
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/27/1998
From:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20203K855 List:
References
NUDOCS 9803050256
Download: ML20203K862 (7)


Text

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L (ACHMENT 3 to TXX 98033 -

AFFECTED TECHNICAL SPECIFICATION PAGES 1

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9903050256 980227 PDR ADOCK 05000445 P PDR

_ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ . to TXX-98033 .. ,

Page 1 cf 1 TABLE 3.3-3 (Continued) -

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS l

FUNCTIONAL UNIT- TRIP SETPOINT ALLOWABLE VALUE i

6. Auxiliary Feedwater
a. Automatic Actuation Logic N.A. N.A and Actuation Relays
b. Steam Generator Water Level--Low-Low
1) ' Unit 1 2 25.0% of 2 23.1% of narrow narrow range range instrument instrument span.

span.

2) Unit 2 2 35.4% of 2 33.4% of narrow

, arrow range range instrument instrument span.

span.

c. Safety Injection-Start See Item 1. cbove for all Safety Injection Trip Setpoints and Motor Driven Puros Allowable Values.
d. Loss-of-Offsite ruwer N.A. N.A
e. Trip of All Main Feedwater N.A. N.A Pumps
7. Automatic Initiation of ECCS Switchaver to Containment Sump
a. Automatic Actuation Logic N.A. N.A and Actuation Relays
b. RWST Level--Low-Low
a. Unit 1 14hM45:0% 2 -3hM43.9%

of span of span

b. Unit 2 2 40-H45 0% 230.1943%

of span of span Coincident With See Item 1. above for all Safety Injection Trip Setpoints and Safety Injection Allowable Value:..

COMANCHE PEAK - UNITS 1 AND 2 3/4 3-29 Unit 1 Amendmelt No. E14.41 Unit 2 Amendment No.27

- Attachment 4 to TXX 98033 ITS Technical Specifications a

' Attachment 4 to TXX 98033

. Page 2 of 4 ESFAS InStru entation 3.3.2 Table 3.3.2 1 (page 6 of 6)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE H00ES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE'"

7. Automatic Switchover to Containment Sump 1.2.3.4 2 trains C 3R 3.3.2.2 NA
a. Automatic SR 3.3.2.4 Actuttion Logic SR 3.3.2.6 and Actuation Relays
b. F.efueling Water 1,2,3,4 4 K SR 3.3.2.1 i Bed 4 Storage Tank SR 3.3 2.5 43.9%

(RWST) Level . SR 3.3.2.12 (Unit 1)

Low Low > 39d4 44.'It (Unit 2)

Coincident with Refer to function 1 (Safety injection) for all initiation Safety injection functions and requirements.

8. ESFAS Interlocks
a. Reactor Trip. 1.2.3 1 per F SR 3.3.2.11 NA P.4 train 2 trains
b. Pressurizer 1.2.3 2 L SR 3.3.2.5 s1975.2 Pressure. P.11 SR 3.3.2.9 psig (Unit 1) s1976.4 psig (Unit 2)

(a) The Allowable Value defines the limiting safety system setting. See the 9ases for the Trip Setpoints.

.. COMANCHE PEAK ITS 3.3 35 May 15, 1997

' Attachment 4 to TXX 98033 Page 3 of 4 ESFAS Instru:entation B 3,32 BASES APPLICABLE g. Auxiliary Feedwater Trio of All Main _Eeedwater SAFETY ANALYSES, Pumps (continued)

LCO, and Function 6.g must be OPERABLE in MODES 1 and 2. This APPLICABILITY ensures that at least one SG is provided with water to serve as the heat sink to remove reactor decay heat and sensible heat in the event of an accident. In MODES 3, 4, and 5 the HFW pumps may be normally shut down, and thus pump trip is not indicative of a condition requiring automatic AFW initiation,

h. Not Used.

l 7. Semi Automatic Switchover to Containment Suma At the end of the injection phase of a LOCA, the RWST will be nearly empty. Continued cooling must be provided by the ECCS to remove decay heat. The source of water for the RHR pumps is semi automatically switched to the containment recirculation sumps. After switching; the low head residual heat removal (RHR) pumps draw the water from the containment recirculation sump, the RHR ) umps pump the water through the RHR heat exchanger, inject tie water back into the RCS, and supply the cooled water to the suction of the other ECCS pumps. Switchover from the RWST to the containment sump should occur before the RWST empty setpoint. Switchover of the containment spray pumps from the RWST to the containment sump is performed manually after completio,)Lof;ECCS switchoveEbuti.before the empty setpoint is reached. For similar reasons, switchover must not occur before there is sufficient water in the containment sump to support ESF pump suction. Furthermore, early switchover must not occur to ensure that sufficient borated water is injected from the RWST. This ensures the reactor remains shut down in the recirculation mode.

(Continued)

C0HANCHE PEAK ITS B 3.3 87 May 15, 1997 n -

  • Attachment 4 to TXX.98033

. Pa9e 4 of 4 PAN E5FAS Instru:entation B 3.32 BASES Function Trip Setpoint (1) Low a 605 psig ti a 50 seconds-te s 5 second:

(2) Negative Rate High. s 100 psi t r 50 seconds 5 Turbine Trip and Feedwater Isolation a Automatic Actuation Logic and Actuation Relays NA b SG Water Level High High (P.14) s 82.4% NR (Unit 1) s 81.5% NR (Unit 2) c Safety injection See Function 1.

6 Auxiliary feedwater a Automatic Actuation Logic and Actuation Relays ($5PS) NA b Not Used c SG Water tsv91 Low Low a 25% NR (Unit 1)

= 35.4% NR (Unit 2) d Safety injection See Function 1.

e Loss of rower Na f Not Used g Trip of All Main Feedwater Pumps NA h Not Used.

7 Automatic Switchover to Containment Sump a Automatic Actuation Logic and Actuation Relays NA-b Refueling Water Storage Tank (RWST) Level . Low Low a W spen Coincident with Safety injection 45i04; span 8 ESFAS Interlocks a Reactor Trip. P 4 NA b Pressurizer Pressure. P 11 s 1960 paig COMANCHE PEAK ITS B 3.3 109 May 15, 1997 i

y. .

Attachment 5 to TXX 98033 LER 97 002 01 i

s ttachment S to TXX.98033

., Page 1 of 6 I

E' CPSES 9703719 b d LogFileiTXX97173 i 10200 fUELECTR/C*Ref. # 10CFR50.73(a)(2)(11)(B)

August 15,1997

c. ta.= 1wer o.e mer ee U. 5. Nuclear Regulatory Cynission Attn,; Document Control Desk washin, ton. 0.C. 20;55

$UBJECT: COP %NCHE PEAK $ TEAM FLECTRIC $iATION (CPSES)

DOCKET N05. 50 4 5 AND 50 4 6 CONDITION OUTS 10E Or OESIGN BAS!$

LICE.lSEE EVENT REPORT M5/97 002 01 REF.: TV Electric Letter logged Txx 97097 dated April 18. 1997 to the NRC ,

(Licensee Event Report 4 5/97 002 00)

Via the above referenced letter TU Elect'ic reported a condition outside the design basis with r6spect to invalid assunption for containment spray switchover. Enclosed is supplement 1 to the aforementioned le*,ter: Licensee Event Report (LER) 97 002 00 for Comanche Peak $ team 21ectric Station Units 1 and 2. ' Invalid Assumption for containment spray switchover from the Refueling Water Storage Tank,'

Sincerely, "

8. S. %

C, L. Terry

. By: OQG1 .

Roger WWalker Regulatory Affairs Manager OB:ob

  • Enclosure cc: Mr. E. L. Merchoff, Region IV '

Mr. J. 1. Tapia, Region IV Resident inspectors, CPSES

. ++ i P 0. Bos 1002 Cien Pme Team hos)

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Attachment 5 to TXX.98033 Page 2 of 6 ,

Enclosure to TXX. 97173 n amana aamuron, or- . 4.

easm we UCENSEE EVENT REPORT (LER) ases reverse for reavited nurnt,er of

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a-. m ai re o, 01 0F 05 050004a5 COVNCHE PEAK STEAM EttCTaf t Staff 0N UNIT 1

v. m INVALIO AS$UMPTION FUR CONTA!Pt4ENT $ PRAY SWITCHOVER FROM THE REFUELING W n .n o , c . ...

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On March 19. 1997, at approximately 10:40 a.m. CST. a condition was identified where the time for containment spray switchover frent the Refueling Water Storage Tant (RWST) to the containment sump coulo take longer than the time assumed in the supporting calculation: thus resuiting in Insufficient water to supply containment l I

spray. On March 19,1997, a TV Electric engineer (utility. non.11cesed),

censervattvely concluded that the postulated scenario for the analyzed time for conttinment spray switchover from the RWST to the sumps compared to the available volumes in the RWST was considered outside of the CPSES design basis.

TV Electric believes that the cause of this condition was a failure of contract engineering to verify the assunction of valve stroke times assumed in the design of the facility. Analysis of this condition has determined that the containment spray

. system remained operable, TU Electric is revising calculations, including level setpoints as appropriate, and the FP" reflect the capability to complete containment spray switchover without 1. rruption of flow. Although the current emergency operating procedures should result in switchover without interruption of flow under realistic scenaries, the procedures are being revised to assure the operator can comolete the switchover without interruption of flow under design Oasis accident C0nditions including the worst single active failure.

I

Attachment 5 to TXX 98033 Page 3 of 6 Enclosure to TXX 97173 o auctana aseuta,on, c tons anna LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION e , s. m o ,,, AM' .

0$000443 0 0 2 0 g OF g COMANCHE PEAK ST7AM E1.ECTRIC STA110N UNIT I 9l7 . . 1

....-ee-m j, nreIRfPTI(W OF M REPGtTAllt F MNT A. REPORTA81.E EVENT CLAS$1FICATION Any event or condition *. hat resulted in the nuclear power plant being in a condition that was outside the design basis of the plant, i B. PLANT OPERATING CONDITIONS PRIOR TO THE EVENT On March 19,1997 Comanche Peak Steam Electric Station (CPSES) Unit I was in Mode 1. Power Operation. at approxtmately 100 percent power and Unit 2 was in Mode 1. Power Operation, at approximately 100 percent power.

C. STMUS OF STRUCalRES. SYSTEMS OR COMPONENTS THAT WERE IN0PERA8LE AT THE START OF THE EVENT AND THAT COAIBUTED TO THi. EVENT There were no inoperable structures, systems, or components that contributed to tra event.

D. NARRATIVE SLNWlY OF THE EVENT. INCLUDING DATES Af0 APPROXIMATE TIMES On March 19. 1997 at approximately 10:40 a.m. CST. while reviewing Refueling Water Storage Tank (RWST) (E!!$:(TK)(BE)) level setpoint calculations (see section VII for additional information) to determine if the setpoint could te loweied, an invalid assation that the +

containment spray pg (E!!S:(P)(BE)) switchover from the RWS1 to the sumps would take about one minute was identified. Contrary to this asswiptict.. plant drawings show the stroke time for the sump valves and the tank isolation valves to be 120 seconds. Therefore. considering operator response times, c:mplete isolation of the RWST could take between 4 and 5 minutes.

+

On March 19. 1997 at approximately 1:30 p.m. CST. TV Electric engineering cerservatively deemed that the postulated condition icenttfied earlier represented a reportable condition. Itwas determined that this scensrio represents a condition that is outside o' the design basis of the plant and therefore requires a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> notification pursuant to 10CFRSO.72. At approximately 1:40 p.m. CST. on March 19.1997, the NRC was notified of the event via the Emergency Notification System.

, Nttactment5toTXX98033

, Pa9e 4 of 6 Eeurs to TXX. 97173 me i,m uamanaanas w tonc - -

4 UCENSEE EVENT REPORT (LER)

TEXT CONTINUATION a--

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g 05000445 0F

0MANCHE PEAK STEAM ELECTRIC STA110N UNIT I 9l7 . 0 0 2 . O Ilo3 99

. . . _ - . - um E. THE METH00 0F O!SCOVERY OF EACH COPPONDIT OR SYSTEM FAILURE OR PROCEDURAL ERA R On March 19. 1997. a TU Electri: engineer (utility. non licensed) conservatively concluded that the postulated scenario for the analynd time for containment spray switchover from RWST to the stscs comparec to the available volumes in the RWST was considered outside of the

PSES design basis.

I

!!. cDNPnMrWT OR SYSTEN FAfttM S A. FAILURE N00E, MECHANISM AND EFFECT OF EACH FAILED COMPONENT Not Applicable . No failed components or systems were identified for this event,

8. FAUSE OF EACH COMPOND R OR SYSTEM FAILURE

- Not Applicable No failed components or systems contributed tc this event.

C. SYSTEMS OR SECONDARY FUNCTIONS THAT WERE AFFECTED BY FAILURE OF COMPONENTS WITH MULTIPLE FUNCTIONS Not Applicable . No failed Components contributed to this event.

D. FAILED COMP 0NDR INFORMATION Not Applicable . No failed components contributed to this event.

!!!, ANALYSf 5 0F THCJD(I A. SAFETY SYSTEM RESPONSES THAT OCCURRED Net Applicable . No safet." system responses occurred as a result of this event.

Attachment 5 to TXX 98033 Page 5 of 6 Enclosure to TXX 97173 _

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n .ucma namwoav c--

W LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION l

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. ,, m 0s00o44s o y OF COMANCHE PEAK STEAM E1.ECT10C STAT 10N tMT I 9l7 0 0l2 . 1 o$

, . . - - . - . -c .- n n B, DURATION OF SAFETY SYSTEM TRAIN INDPERABILITY Not Applicaole No safety system trains were inoperable as a result of this event.

l C. SAFETY CONSEQUENCES Am IMPLICATIONS OF THE EVENT TV Electric has cetermined that the identified secuence of events is a more limiting cc:.dition than the current analysis assumed in the licensing oasis. The FSAR stat *'t that containment spray 5.itchover begins on receipt of the RWST F alarm. Analysis performed by TU Electric Engineering and Westingneuse has shown the actual volse of the RWST to be sufficient to permit full opening of the sump 1 solation valves and full closure of the RWST isolatton valves without stopping the spray pumps, Based on the system hydraulics, the sparger elevation, and the minimum containment water level at the end of injection, and the actual valve stroke times (the sump valves open in less than 20 seconds and the RWST tank valves close in less than 120 seconds) the RWST would be isolated prior to loss of pump suction, Due to the precaution (in accordance with the FSAR) to stop ECCS pumps still taking suction from the RWST on receipt of the empty alarm, the current emergency procedures caution the operator to stop any pump still taking suction fra the RWST on receipt of the empty alarm to assure the pumps are not damaged. The current procedure starts the ,

containment spray switenover on level indication prior to receipt of the empty alarm; however, under worst DBA conditions and assettons, calculations do not assure this transfer can be completed prior to the

-mty alarm. Therefore, containment spray flow might be stopped for 9 al minutes while the ECCS and spray transfer is being completed stopp2d pumps. TU Electric believes that calculations and

. .puints can be revised to demonstrate that switchover can be comaleted without stopping the containment spray pumps in the event of

.- loss of coolant accident. Under worst case design basis accident scenarios, this condition is outside the current licensing basis and has the pctential to increase the radiological consequences as calculated in the FSAR due to the temporary stopoing of the spray pumos. Hc.ever, any potentia 1 increase is cxpected to Jmain below the

    • tance limits of the Standard Review Plan Section 15.6 and 10CFR100 o reflected in the SER and SSER 22 for CPSES. Hence, this event did not impact the health and safety of the public.

, btachment5toTXX98033

,, Page 6 Of 6 i

Erdoeure to Txx. 37173

' nimma. nw-:

geomu u.a LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION 8""' -

'*'"""' y me p 05o0044$ o o 2 o I OF g COMANCHE Pr.AK s17.AM ELECTRIC STATION INT I 9l7 . . of

.. . . - . nn IV. cAust ca w rygg The cause of this euncition was the failure to identify these events as a Credible scenario during the design of the facility by the Contract engineer, V. CORRECTIVE ACTIONS TV Elc;tric is revising calculations. including level setpoints as appropriate, and the FSAR to reflect the capability to complete containment spray switchover without interruption of flow. Althougn the current emergency operating procedures should result in switchover without interruption of flow under realistic scenarios, they are being revised to assure the operator can complete the switchover without interruption of flow under design basis accident conditions.

VI. Pn:v10us sfMI ua tytMTs There have been other previous events which resulted in conditions outside of design basis. However, the causes of tuse events are sufficiently different than the subject event. Corrective actions taken for the previous events would not have P-avwited this event.

. VII. ADDITIONAL INFORMATIM RWST level setpoint calculations were being reviewed as result of inconsistencies regarding steps in FSAR tables and the CPSES Er gency Response Guidelines associated with the switchover of the ECCS from the RWST -

ii the containment simp. Refer to NRC Inspection Report 50 MS/(M6) 9716.

~

s Attachment 6 to TXX 98033 Federal Register Vol. 51, No.-44 Rules and Regulations.--

March 6, 1986, page 7751 l

b Att achment 6 to TXX 98033 .

'. Page 1 of 1 '

Federel Regleter / Vol.' 81. No. 44 / Thurs. lay.hrch e. togs / Rules dnd Regulet. tone ~F731

$ to.21(b) or i 30.22 at for a testing Ill Ter a nucleet power enctor, e elsewhere in the nuclear industry or in facihty will hkely be found to involve ch(ang)e resulting from a nuclest, other reactor industrhe. and does not involve a significant baserde sens*rouona,if core reloading. If no fuel assembbee significant increase in the prtMility or operetion of the facility in accordance significantly e6fferent from those found consequenose of en ace 6 dent previously with the proposed amendment involves prevloesly acceptable to the NRC for e evelected or create the possibihty of a one or more of the foDowing- previous core et the facility in question new or different kind of accident from ti) A e6sninoant relemation of the are involved. This soeumes that no any accident previously evolueted; and enter 6e used to estabheh sefety hmite. , signtAcont changes are made to the 18)The repaired or replaesswat 111 A eienineent relemation of h acceptance critw6e for the technical component or system does not roeult in base)s forluniting selet eyetem setunge specaheatione, that the analytical e significar:t che in its esfety or limiting conditions opwation. methods used to demonstrate function er a cent et testion in any-

- till) A significant relemation in limiting confermance with the technical sollty han (or ting condition of conditions fw opwetion riot specificatione end tiene are not operation) assedsted with the eccompanied by compensatory changes. significantly . and that NRC has com t er system.

condMons or actions that maintain a previous found such methods (a An expansies of the storego corrmensurele level of safety such as acco tab e. capacity of a apent fuel liv ^ IA'Igr*RI'd #P" I when all of allowing a plant te operate at vil power the following are se during a period in which one or more demonstrebon of seceptable operation froen an opweting restriction that wee (g) agg, go,,,, g7m-_ nghg sefety eyelesne are not operable).

consists of either repla sais*. lag (iv) Renewal of an operating license, imposed because s t eeptable operation was not yM demonMrewd.This apuan spacing between stored rocks with a design wh6 eBowe closer (v) For a nuclear power plant en that the opere restr6ction and the tfuel increase in authorleed maximum core assemblies or placing a 5 alracks power level. criterte to be e led to a request for (vil A chage k kchalca relief have been estabhehod la e prior d he wis, mal dniga om h pool Boor

,,,,,,,gg if specificeuone or otherNRC approval m.w sad est H le lueuna in a (t) The storage ==pa==w method involving a signifloant unreviewed aanslactory way est he arHwie ha" safety queouon, ben mL does not le volve rod coneohdaties or

    • "* double

.. vii) A chance la plant operation de(signed to improve oefety but which* g 3) m rduf granud from les(s than er equal to 0.gs; andof thepoollemalata ,

due to e.17 factors,in fact allows plant opwoung fWh

-au- -* -3 "' "egme

m e=,e, ,,a g s on w ,,

osas,, (4)naog,isenhead No new technolo.gy ei or .e o.r unproves 22?ha ,"bes?,re"s**" n.e ,,e,,,

ea ;s".',7,u'"sellll"er',':,').'ent*d

-sei- - d e geg,r;;f,ue,,.yv,,ue,'~~gr wi, ore it ie .at oonotrec.on e,anei-c,,;,h w,eo m.s.W [ ,-,, See been compimed As- sati.sfactorily R.Beepeness to Commente se latens rmaRas eu re.o m et.nongf nne m *:::i ,en,e,ge ~ ~ e s - ~m *:;,=,*

os - a,e d eve;6 g ,

,o -.i ei gre r d.os.rea m e-o .e unow rgbe-m,i.e had mteria.ffma r e es,.,d., e me,, e, m,aJe a, , ,ed e,se.,, ,es some eo,we, a,otta m ta cr dina. .m

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,e, sieruficant hasarde considerations. 44 syme w componem M Commando-A groep of FR teses, it explained that unless the la h Standard Review plan.et e abange sem-aten stak hat de era ePecific cwcumstances of a hcense reesittag from to appl 6estion of a small Mandanie in 4 30Aa(c) an unclear and amendment roguest lead to a contrerY argue that the examples in the statement refinement of a prev 6eenly see.1 concloe6on when seasured against the colouisdeaal moda ur design sembod. of considersticas-which they belieu standarde is 5 30.0L then, pursuant to em sluter thee the standarde-obould

.the procedures in 130.g1. a ch(anges in the regulaeone, wherebethevtil A ofchange rude part the tele; to conforse otherwies, theya bosase to ninendment to en operstmg icones for a boense te la very minor argue to examples have ne legal facility licensed under i 30.21(b) or -

changes to ty opereuene clearly in ^7"^^^~~

l 30.22 or for a testing facility will hkely keeping with b regulatione. "--- r The Cosenloeloei disagrwe be found to involve no ificant (vtit) A chansa to a heense to reflect a withM request. As explained in hacerde considerations, operation of minor adjustment in ownership obares response to the seassents on the the feckhty in accordance alth the proposed rule lase es FR teges), the as,ong oo-owners already shown in the

, proposed aseendscat tavolves only one beenee. ld. commenters are serrect that es or more of b fouowtag As discussed below. the r %==i==w s===plaa have no blading 1 (i) A purely adadaistrative change to ha(s added rummples (in) and (m)in eiptincance. However, ter provide technical =paehations: for example, e reopense to commente en the lateria guidance to the staff, liconesee and to change to achieve consistency the general public about the way the final rules.)

throughout the technical specifications. (in) A repair or replacement of a standards mal be laterpreted the oortection af an error, or eJ hange in maior seaposent er erstem important to t'a==la=len. Tuo Commission aslety. if she folloertag condinome are seasider een the standards and nomencl.ature.

(ii) A aage that esastitutes an met: exemples se a est elsetteria in the

_ edditionallimitetase,sostriction or =

=

' (1) The repair er replacement process laterta Anal rules, but deelded against

_ control not pressadyincluded in the deve6vve pressoas whid have been thle beesuse I the standards and technical 7" O, a pi---wat least emos as, a more  : esemples proved sesfulover time, stragem survauseos seguirement. en mader sempensou erayetene tu) se eies had need all three standards

Attachment 7 to TXX 98033 Cover Letter for TXX 97105, dated May 15, 1997 l

ll--

Log # TXX 97105 File # 10010

- - 916 Ref. # 10CFR50.90 it ELECTPYC' Hay 15, 1997 C. L.anc

  • 1ern cm ,ike rms,w U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50 445 AND 50 446 LICENSE AMENDMENT REQUEST 97 001 TECHNICAL SPECIFICATION CONVERSION APPLICATION REF: 1) TV Electric letter logged, TXX 95292 from C. L. Terry to the NRC dated March 4,1994

2) NUREG 1431, " Standard Technical Specifications Westinghouse Plants," Revision 1 April 1995 Gentlemen:

Pursuant to 10CFR50.90 TV Electric hereby requests an amendment to the CPSES Unit 1 facility operating license (NPF 87) and Unit 2 facility operating license (NPF 89) by incorporating changes to the CPSES Units 1 and 2 Technical Specifications (TS) as provided in this license amendment request and by adding license conditions to address Surveillance Requirements not previously performed by existing requirements or tests.

The purpose of this request is to provide a submittal pursuant to Reference 1 which dockets TU Electric's request for NRC approval of the full conversion of the CPSES Unit 1 and Unit 2 Technical Specifications from the current Technical Specifications to a set of Technical Specifications based upon the improved Standard Technical Specifications (ISTS) [ Reference 2].

TV Electric has pre)ared this submittal to be consistert with 10CFR50.36a and requests that t1e proposed changes be incorporated into the Technical Specifications. Attachment 1 is an affidavit. Atta:hment 2 is a general description and assessment c? the proposed full conversion (including proposed license condition). Attachment 3 contains a list of the enanges within the submittal which are not directly related to the conversion process and a list of other pending or prejected License Amendments Requests (LARs) which could potentially impact the review of this convere'on application. Attachments 4 through 18 provide the specific changes and the justifications that support the acceptability of the changes and the evaluations that support the conclusion that these changes do not involve a significant hazard consideration. Attachments 19 and 20 provided the Improved Technical Specifications (the ISTS with the proposed changes incorporated) for CPSES. Attachment 19 is the ITS for the specifications and attachment 70 is the ITS Bases.

P O Bm 1002 Glen Rme Texas 7600

" Attachment 7 to TXX 98033

_ 's Page 2 of 3 TXX 97105 e Page 2 of 3 TV Electric developed this conversion application in concert with three other utilities: Union riectric Company (UE). Wolf Creek Nuclear 0;,eration Corporation (WCNOC), ano Pacific Gas & Electric Company (PG&t' Two

- enclosures (enclosures 3B and 6B) in Attachments 4 through 18 to this submittal contain conversion comparison tables. These comparison tables t

reflect how the prooosed changes are treated by each of the four Stilities.

  • The tables are p: svided to assist the NRC in performing reviews o' the individual sube .tals of each of these utilities. Only the inforpetion related to CPSES and TU E'ectric on these tables is considered to 'ue part of this license amencment request. The information related to the other utilitie: is being provided for information only, t UE. WCNOC and PG&E are submitting parallel license amendmer n 'r 3 their respective plants (Callaway. Wolf Creek Generating ? '

tbio C;nyon). Because of tne similarities in the attached liet ' a nt requert and the submittals of these other three licensees. .s requested that, to the extent possible, the NRC review these four submittals together in order to minimize the required NRC resources, redace licensee costs and reduce overal' review tira, bon Woodlan of TU Electric is the chairman of 1 the Joint Licensing Subcommittee, which incli 'n members, from each of the four utilities and which coordinated the F

  • ue.;'cpment of '.he four full

( conversion applications. Mr. Woodlan (817 3 < 6887) is the lead utility contact to resolve matters which relate to the NRC's review of these four packages.

In accordance with 10CFR50.91(b). TU Electric is providing the State of Texas with a copy of this proposed amendmert.

Because implementation of the L. proved Technical Specifications involves significant training and revisions to implementing procedures. TV Electric will interfate with the ivRC during the review process to establish an cppropriate implementation date or period.

Should you have any questions, please contact Mr. B.(Gob) S. Dacko at (817) 897 0122 S N y.

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a SC.vu C. L. Terry DkW grp L

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'c Page 3 of 3 TXX 97105 page 3 of 3 Attachments: 1. Affidavit

2. General Description and Assessment
3. Lists of additional changes and related LARs
4. CTS Section 1.0 / ITS Section 1.0
5. CTS Section 2.0 / ITS Section 2.0
6. CTS Section 3/4.0 / ITS Section 3.0
7. CTS Section 3/4.1 / ITS Section 3.1
8. CTS Section 3/4.2 / ITS Section 3.2
9. CTS Section 3/4.3 / ITS Section 3.3
10. CTS Sectin 3/4.4 / ITS Section 3.4
11. CTS Section 3/4.5 / ITS Section 3.5
12. CTS Section 3/4.6 / ITS Section 3.6
13. CTS Section 3/4.7 / ITS Section 3.7
14. CTS Section 3/4.8 / ITS Section 3.P
15. CTS Section 3/4.9 / ITS Section 3.9
16. CTS Section 3/4.10 / CTS Section 3/4.11 17 . CTS Section 5.0 / ITS Section 4.0 18 . CTS Section 6.0 / ITS Section E.0 19 . ITS Specifi stions with propos 1 changes incorporated 20 . ITS 8ases with proposed changes incorporated
  • c Hr. E. W. Herschoff Region IV "r. J. I. Tapia, Region IV Resident Inspectors. CPSES Mr. T. J. Polich NRR (4 copies)

Mr. Arthur C. Tate Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin. Texas 78704

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