CP-201800115, License Amendment Request 17-001 Revision to Technical Specification 3.3.2. ESFAS Instrumentation

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License Amendment Request 17-001 Revision to Technical Specification 3.3.2. ESFAS Instrumentation
ML18102A516
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/29/2018
From: Thomas McCool
Luminant Generation Co, TXU Energy, Vistra Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201800115, LAR-17-001, TXX-18011
Download: ML18102A516 (27)
v • d • e


Text

ENERGY 0 'f!J! I Luminant Thomas P. M cCool Site Vice President Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 o 254.897.6042 CP-201800115 TXX-18011 U.S. Nuclear Regulatory Commission Ref 10 CFR 50.90 ATIN: Document Contro l Desk 10 CFR 50.91(b)

Washington, DC 20555-0001 3/29/2018

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 LICENSE AMENDMENT REQUEST (LAR)17-001 REVISION TO TECHNICAL SPECIFICATION (TS) 3.3.2 . ESFAS INSTRUMENTATION

Dear Sir or Madam:

Pursuant to 10CFR50.90, Vistra 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 the CPNPP Units 1 and 2 Technical Specifications.

This change request app li es to both un it s.

The proposed change will revise Technical Specification 3.3.2 entitled "ESFAS Instrumentation ." The proposed change will revise the CPNPP Units 1 and 2 Technical Specifications for MODE 2 applicability with a note for function 3.3.2.6.g; Auxiliary Feedwater - Trip of all Main Feedwater Pumps. The note would modify the function applicabi lity as fol lows; "When one or more Main Feedwate r Pump(s) are supp lying feedwater to steam generators."

Enclosure provides the following;

1) A Summary Description of the proposed change .
2) A Detailed Description of the proposed changes, a safety ana lysis of the proposed changes, CPNPP's determination that the proposed changes do not involve a significant hazard considerat ion, a regulatory ana lysis of the proposed changes and an environmental evaluation .
3) A Technical Evaluation to include the affected Techni ca l Specification pages marked-up and retyped to reflect the proposed changes and proposed changes to the Techn ical Specifications Bases for information only.
4) A Regulatory Evaluation of applicable regulatory requirements, precedents, and no significant hazards consideration. These changes will be processed per CPNPP site procedures .
5) Environmental Considerations for the requested change .

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

6) A list of references used for change development. Two attachments are provided with figures and change documents.

Vistra OpCo requests approval of the proposed License Amendment by October 1, 2018 to be implemented within 60 days of the issuance of the license amendment. The requested approval date was administratively selected to allow for NRC review but the plant does not requ ire this amendment to allow continued safe full power operations.

In accordance with 10CFRS0.91(b), Vistra OpCo is providing the State of Texas with a copy of this proposed amendment.

This letter contains no new regu latory comm itments.

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

I state under pena lty of perjury that t he forego ing is true and correct.

Exec uted on March 29, 2018.

Sincerely,

Enclosure:

License Amendment Request (LAR 17-001) Evaluation of Change to Technical Specification 3.3.2, Engineered Safety Features Actuation System Instrumentation : Referenced Figures Attachment 2: Cu rrent, Markup, and Retyped Technical Specification Tabl e 3.3.2-1, Engin eered Safety Features Actuation System Instrumentation and supporting Technical Specification Bases for information only c-Kriss M . Kennedy, Region IV Margaret M. Watford, NRR Ba /want K. Singa l, NRR Resident Inspectors, Comanche Peak Mr. Robert Free Environmental Mon itoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P. 0 . Box 149347 Austin TX, 78714-9347

Enclosure to TXX-18011 Page 1 of 10 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for Proposed Change 2.4 Description of Proposed Change

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

S

6.0 REFERENCES

ATTACHMENTS Attachment 1 Referenced Figures Attachment 2 Technical Specification and Bases Pages

Enclosure to TXX-18011 Page 2 of 10 1.0

SUMMARY

DESCRIPTION Proposed change LAR 17-001 is to revise Technical Specifications 3.3.2, Engineered Safety Function Actuation System (ESFAS) Instrumentation for Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2.

Vistra OpCo is requesting this change to the applicability when the automatic Auxiliary Feedwater actuation due to the trip of all Main Feedwater Pumps is required to be operable in order to minimize the risk of plant transients such as unnecessary ESF actuations at low power. Revising the function applicability will ensure that Auxiliary Feedwater actuation is due to an actual loss of Main Feedwater.

No changes to the Comanche Peak Nuclear Power Plant Final Safety Analysis Report are anticipated as a result of this License Amendment Request.

2.0 DETAILED DESCRIPTION The Auxiliary Feedwater actuation on Trip of all Main Feedwater Pumps is an anticipatory function in that it provides early actuation of the auxiliary feedwater system to mitigate the consequences of a loss of main feedwater which is a Condition II Fault. The current Technical Specification requires that this function be operable in Mode 1 and in MODE 2 prior to Main Feedwater Pumps feeding steam generators.

The proposed Technical Specification change adds a footnote to modify MODE 2 applicability that states the following , "When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators ." The associated Technical Specification Bases further states that, "Function 6.g must be OPERABLE in MODE 1, and MODE 2 when the MFW pump(s) are feeding the steam generators and the auxiliary feedwater system has been placed in standby for automatic start."

"For information only," this request includes proposed changes to the Technical Specification Bases . ESFAS Instrumentation , Applicable Safety Analysis , LCO ,

and Applicability for function 3.3.2.6.g, Auxiliary Feedwater - Trip of all Main Feedwater Pumps provides the basis for making the function operable after at least one Main Feedwater Pump is feeding the steam generators and auxiliary feedwater is in standby, ready for automatic start.

2.1 System Design and Operation The Feedwater system operates in conjunction with the Condensate and Heater Drain systems to provide feedwater automatically to the steam generators during steady state and transient conditions.

During power operation the main feedwater pumps take suction from the Condensate and Heater Drain systems and discharges through a common header through the high-pressure feedwater heaters to the steam

Enclosure to TXX-18011 Page 3 of 10 generators. One main feedwater pump is required to operate during power operation up to 50% of rated power. From 50% rated power to full power, both main feedwater pumps are required , with each pump providing approximately 50% of the required flow . Prior to aligning main feedwater pumps to the steam generators, water is supplied by the auxiliary feedwater system .

Unit 1 steam generators have separate feed lines for auxiliary feedwater and do not rely on the integrity of the main feedwater piping in order to inject auxiliary feedwater flow into the steam generators . Unit 2 main feedwater system piping is required to admit auxiliary feedwater to each steam generator when a main feedwater supply is unavailable .

Feedwater pump turbine trips include ; safety injection signal , high-high steam generator water level , low feed pump suction pressure, auxiliary condenser low vacuum , and turbine protection trips (i.e. turbine and bearing low oil pressures , thrust bearing wear, and overspeed) , and manual. Trip of both main feedwater pumps starts both motor-driven auxiliary feedwater pumps . Trip of a single main feedwater pump causes a runback of the main turbine .

The main feedwater pump turbine trip pressure switches, which are used to start the auxiliary feedwater pumps, are redundant Class 1E switches.

Each main feedwater pump is equipped with two oil pressure switches located in the turbine's hydraulic control circuit which makes up one channel of the auxiliary feedwater automatic start circuit. A low pressure signal from both main feedwater pumps will automatically start both motor-driven auxiliary feedwater pumps . Currently, LCO 3.3.2 , Function 6.g, requires the automatic start of the auxiliary feedwater pumps to be operable during MODE 2 even when no main feedwater pumps are feeding steam generators . See Attachment 1 to TXX-18011 , Figures 1 through 4 for excerpts from plant drawings of the oil pressure switches and the trip circuit for each Unit's main feedwater pumps.

The auxiliary feedwater automatic start circuit for each main feedwater pump is reset when the main feedwater pump's electrical control circuit is energized and the pressure switches located in the main feedwater pump turbine's hydraulic control circuit senses that the circuit is pressurized. The main feedwater pump is considered to be in service when the pump is providing feed flow to the steam generators. The auxiliary feedwater automatic start circuit is in the trip condition when the main feedwater pump's electrical control circuit is energized and the hydraulic control circuit is depressurized . Main Feedwater pumps are considered to be out of service when not providing feed flow to the steam generators .

When entering MODE 2, the auxiliary feedwater system is in service to control and maintain steam generator level. At approximately 2% RTP , a main feedwater pump is reset and placed into service. During the process of placing one main feedwater pump in service, the non-operating main feedwater pump is tripped and the pressure switches that actuate the

Enclosure to TXX-18011 Page 4 of 10 auxiliary feedwater automatic start are isolated. During this time the main feedwater system is in service and the auxiliary feedwater pumps are in standby. Under these conditions the auxiliary feedwater automatic start circuit will be in a half trip condition (one-out-of-two) . If the operating main feedwater pump were to trip during this period , an auxiliary feedwater automatic start signal would be generated causing both motor-driven auxiliary feedwater pumps to start.

After entering MODE 1, the second main feedwater pump is reset and placed into service (approximately 50% RTP) . Then both main feedwater pumps are in service and both auxiliary feedwater automatic start channels are reset, with the auxiliary feedwater automatic start function fully operational.

2.2 Current Technical Specification Requirements The current Technical Specification proposed to be changed is Limiting Condition for Operation (LCO), 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation.

Table 3.3.2-1 Engineered Safety Feature Actuation System Instrumentation , Auxiliary Feedwater, Function 6.g. Trip of all Main Feedwater Pumps is required in MODES 1 and 2. See Attachment 2 to TXX- 18011, item 1, Current Technical Specification.

The current Technical Specification Bases is provided "for information only. " See Attachment 2 to TXX-18011 , item 2, Current Technical Specification Bases.

2.3 Reason for Proposed Change Since the auxiliary feedwater pumps are used as the primary means of removing heat from the reactor core in MODE 2, the anticipatory auxiliary feedwater automatic start function serves no purpose because the auxiliary feedwater system is already in service. If a motor-driven auxiliary feedwater pump were to fail during startup , the turbine-driven auxiliary feedwater pump would start automatically on low-low steam generator level , or would be manually started by the operator.

This proposed technical specification change is acceptable because , as stated , at approximately 2% RTP , a main feedwater pump is reset and placed into service. During the process of placing the first main feedwater pump in service , the anticipatory auxiliary feedwater automatic start function should not be placed in a half trip condition to prevent inadvertent auxiliary feedwater automatic start. Once the operating main feedwater pump has established sufficient feed flow to maintain SG level and the auxiliary feedwater system has been placed in standby ready for automatic start, the anticipatory auxiliary feedwater automatic start function shall be operable. If the operating main feedwater pump were to trip during this period an auxiliary feedwater automatic start signal would

Enclosure to TXX-18011 Page 5 of 10 be generated causing both motor-driven auxiliary feedwater pumps to start.

Modifying the requirement for automatic start of the auxiliary feedwater pumps to be required only when one or more main feedwater pump(s) are feeding steam generators , limits the potential for a low power, overcooling transient due to inadvertent auxiliary feedwater actuation. Inadvertent auxiliary feedwater actuation during startup would start both motor-driven auxiliary feedwater pumps and fully open flow control valves to the steam generators .

2.4 Description of Proposed Change The proposed change will revise MODE 2 applicability for Auxiliary Feedwater, Function 6.g with the following footnote: "When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators."

See Attachment 2 to TXX-18011 , item 3 for Techn ical Specification 3.3.2, Table 3.3.2-1 markup.

The proposed change to Technical Specification Bases for Table 3.3.2-1 ,

Function 6.g is provided "for information only." See Attachment 2 to TXX-18011, item 4 for the associated Technical Specification Bases markup.

The retyped pages for the proposed change to Technical Specification, Table 3.3 .2-1 are provided for review. See Attachment 2 to TXX-18011 ,

item 5 for Technical Specification 3.3.2, Table 3.3.2-1 retyped. The retyped pages for the proposed change to Technical Specification Bases, Table 3.3.2-1 , Function 6.g are provided "for information only." See Attachment 2 to TXX-18011 , item 6 for the associated Technical Specification Bases retyped.

3.0 TECHNICAL EVALUATION

The proposed change provides a more stable auxiliary feedwater to main feedwater transition in MODE 2, by delaying the restoration of LCO 3.3.2 , Table 3.3 .2-1 , Auxiliary Feedwater, Function 6.g , "Trip of all Main Feedwater Pumps" causing an Auxiliary Feedwater actuation . This actuation sends a start signal to both motor-driven auxiliary feedwater pumps and causes the flow control valves to the steam generators to "trip-to-auto" which opens them to 100% demand .

The auxiliary feedwater pumps are already running feeding the steam generators and flow is being controlled by the operator. During the short period of time between entering MODE 2 and the start of the first main feedwater pump and aligning it to feed the steam generators it is not prudent to reinstate LCO 3.3.2 ESFAS Instrumentation, Table 3.3.2-1 , Function 6.g.

The design basis events , which impose auxiliary feedwater safety function requirements are, loss of all AC power to plant auxiliaries, loss of normal feedwater, steam generator fault in either the feedwater or steam lines , and small break loss of coolant accidents. These design basis events assume auxiliary feedwater automatic starts on a low-low steam generator level , station blackout,

Enclosure to TXX-18011 Page 6 of 10 or safety injection. These ESFAS signals are Class 1E, meaning they meet all requirements for reliable power supplies, separation, redundancy, testability, seismic, and environmental qualification as specified in 10 CFR 50.55a(h)(2),

Protection Systems. The ATWS Mitigation System Actuation Circuitry (AMSAC) is a redundant system that will automatically start auxiliary feedwater pumps should the Solid State Protection System fail.

The anticipatory auxiliary feedwater actuation circuits associated with both main feedwater pumps tripping do not meet requirements specified in 10 CFR 50.55(h)(2). These circuits do not interface with ESFAS, which is an integral part of the Solid State Protection System . As such, these circuits are not part of the primary success path for postulated accident mitigation as defined by 10 CFR 50.36(c)(2)(ii), Criterion 3, and therefore are not credited in the accident analysis.

The safety grade auxiliary feedwater actuation signals credited in the accident analysis are low-low steam generator level , station blackout, or safety injection.

The addition of footnote (d) to Technical Specification Table 3.3.2-1 , Auxiliary Feedwater, Function 6.g , "When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators" and the bases explanation that includes having auxiliary feedwater aligned for automatic start to reinstate the "Trip of all Main Feedwater Pumps" input to Auxiliary Feedwater actuation meets the design purpose for the function.

The loss of the anticipatory trip circuit during plant startup is of very low safety significance because the an Auxiliary Feedwater actuation will automatically occur on steam generator low-low level during , loss of all AC power to plant auxiliaries, loss of normal feedwater, steam generator fault in either the feedwater or steam lines , and small break loss of coolant accident, which are all Class 1E circuits. The "Trip of all Main Feedwater Pumps" anticipatory circuits are Class 1E circuits, but do not process through the Solid State Protection System.

For these reasons, Vistra OpCo concludes that the anticipatory AFW automatic start channels need not be reinstated until a main feedwater pump is feeding steam generators and the auxiliary feedwater system is in standby ready for automatic start.

In summary, the proposed technical specification change will eliminate the requirement that LCO 3.3.2 Function 6.g be met in Mode 2 prior to feeding steam generators with main feedwater pump(s) . In the unlikely event that a motor-driven auxiliary feedwater pump trips during plant startup, the turbine-driven auxiliary feedwater pump would start automatically on low-low steam generator level , or would be manually started by the operator.

Enclosure to TXX-18011 Page 7 of 10

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements The regulatory basis for Technical Specifications 3.3.2 , "ESFAS Instrumentation" is to ensure that accident conditions are sensed and operation of systems and components important to safety are initiated in order to protect against violating core design limits , challenging the reactor coolant system pressure boundary, and to mitigate the consequences of accidents.

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include technical specifications as part of the license. The Commission's regulatory requirements related to the content of the technical specifications are contained in Title 10, Code of Federal Regulations (10 CFR), Section 50 .36, "Technical Specifications ,"

of 10 CFR Part 50 "Domestic Licensing of Production and Utilization Facilities ." The technical specification requirements in 10 CFR 50.36 include the following categories: (1) safety limits, limiting safety systems settings and control settings, (2) limiting conditions for operation , (3) surveillance requirements , (4) design features, and (5) administrative controls . The requirements for Auxiliary Feedwater actuation resulting from a trip of all MFW pumps are included in the technical specifications in accordance with 10 CFR 50.36(c)(2) , "Limiting Conditions for Operation ."

As stated in 10 CFR 50.59(c)(1 )(i), a licensee is required to submit a license amendment pursuant to 10 CFR 50 .90 if a change to the technical specifications is required. Furthermore, the requirements of 10 CFR 50.59 necessitate that the NRC approve technical specification changes before the changes are implemented . Vistra OpCo's submittal meets the requirements of 10 CFR 50.59(c)(1)(i) and 10 CFR 50.90.

General Design Criterion (GDC) 13 "Instrumentation and Control," of Appendix A "General Design Criteria for Nuclear Power Plants ," to 10 CFR Part 50 requires , among other things , that instrumentation be provided to monitor variables and systems and that controls be provided to maintain these variables and systems within prescribed operating ranges . The proposed operational change continues to provide system monitoring and proper actuation to satisfy the anticipatory trip function .

No changes are proposed to the safety-related instrumentation (i .e.

ESFAS).

GDC 21 , "Protection system reliability and testability," requires that the protection system shall be designed for high functional reliability and inservice testability commensurate with the safety functions to be performed. The proposed change does not reduce functional reliability or inservice testability.

Enclosure to TXX-18011 Page 8 of 10 GDC 29, "Protection against anticipated operational occurrences ,"

requires that protection systems be designed to assure an extremely high probability of accomplishing their functions in the event of anticipated operational occurrences . The proposed change does not reduce the extremely high probability of accomplishing the auxiliary feedwater system automatic start when needed due to the trip of both main feedwater pumps when they are feeding the steam generators.

4.2 Precedent Several operating facilities have been identified with similar operational technical specification 3.3.2, ESFAS Instrumentation allowances as proposed herein. These facilities include D.C. Cook, Sequoyah, and Vogtle . See reference 6. 7 through 6.11 .

4.3 No Significant Hazards Consideration Determination Vistra OpCo has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92 , "Issuance of amendment,"

as discussed below:

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The design basis events which impose auxiliary feedwater safety function requirements are loss of all AC power to plant auxiliaries, loss of normal feedwater, steam generator fault in either the feedwater or steam lines, and small break loss of coolant accidents.

These design basis event evaluations assume actuation of auxiliary feedwater due to station blackout, low-low steam generator level or a safety injection signal. The anticipatory auxiliary feedwater automatic start signals from the main feedwater pumps are not credited in any design basis accidents and are, therefore, not part of the primary success path for postulated accident mitigation as defined by 10 CFR 50.36(c)(2)(ii) , Criterion 3. Modifying MODE 2 Applicability for this function will not impact any previously evaluated design basis accidents.

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

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

Enclosure to TXX-18011 Page 9 of 10 This technical specification change allows for an operational allowance during MODE 2 while placing main feedwater pumps in service . This change involves an anticipatory auxiliary feedwater automatic start function that is not credited in the accident analysis.

Since this change only affects the conditions at which this automatic start function needs to be operable and does not affect the function that actuates auxiliary feedwater due to loss of offsite power, low-low steam generator level or a safety injection signal, it will not be an initiator to a new or different kind of accident from any accident previously evaluated.

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

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response : No This technical Specification change involves the automatic start of the auxiliary feedwater pumps due to trip of both main feedwater pumps, which is not an assumed start signal for design basis events. This change does not modify any values or limits involved in a safety related function or accident analysis .

Therefore , the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluations , Vistra OpCo concludes that the propose amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50 .92(c) and , accordingly, a finding of "no significant hazards consideration " is justified .

4.4 Conclusions The requirements of GDC 13, 21 , and 29 continue to be met since no changes are being proposed which would affect the design capability, function , operation , or method of testing the Solid State Protection System or associated relays. Therefore the applicable guidance of RG 1.22 and 1.118 continue to be met. RG 1.22 . 10 CFR 50.55a(h) will continue to be satisfied since the Solid State Protection System will continue to meet the requirements of IEEE 279.

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 Commission's regulations , and (3) the issuance of the amendment will not be adverse to the common defense and security or to the health and safety of the public.

Enclosure to TXX-18011 Page10of10

5.0 ENVIRONMENTAL CONSIDERATION

S Vistra OpCo 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 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration , (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the 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), an environmental assessment of the proposed change is not required .

6.0 REFERENCES

6.1 CPNPP FSAR Section 10.4.7, "Condensate and Feedwater System" 6.2 CPNPP FSAR Section 15.2.7,"Loss of Normal Feedwater" 6.3 General Design Criteria (GDC) of 10 CFR 50 Appendix A , GDC 13 "Instrumentation and control" 6.4 General Design Criteria (GDC) of 10 CFR 50 Appendix A, GDC 21 "Protection system reliability and testability" 6.5 General Design Criteria (GDC) of 10 CFR 50 Appendix A, GDC 29 "Protection against anticipated operational occurrences" 6.6 Code of Federal Regulations 10 CFR 50.55a(h)(2) , Protection systems 6.7 DC Cook 1 Technical Specifications (ML053050305) 6.8 DC Cook 2 Technical Specifications (ML053050307) 6.9 Sequoyah 1 Technical Specifications (ML052930183) 6.10 Sequoyah 2 Technical Specifications (ML052930262) 6.11 Vogtle 1 and 2 Technical Specifications (ML052840233) to TXX-18011 Page 1 of 5 Attachment 1 to TXX-18011 Referenced Figures

1. Unit 1 Main Feedwater Pump - Anticipatory Trip Circuit
2. Unit 2 Main Feedwater Pump - Anticipatory Trip Circuit
3. Unit 1 Motor-driven Auxiliary Feedwater Pump Start Circuit
4. Unit 2 Motor-driven Auxiliary Feedwater Pump Start Circuit to TXX-1 8011 Page 2 of 5 Figure 1 Unit 1 Main Feedwater Pump - Anticipatory Trip Circuit*

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1. Current Technical Specification Page 3.3-33
2. Current Technical Specification Bases Pages B 3.3-83 & B 3.3-84 (For Information Only)
3. Markup of Technical Specification Page 3.3-33
4. Markup of Technical Specification Bases Pages B 3.3-83 & B 3.3-84 (For Information Only)
5. Retyped Technical Specification Page 3.3-33
6. Retyped Technical Specification Bases Pages B 3.3-83 & B 3.3-84 (For Information Only)

Attachment 2 to TXX-18011 Page 2 of 10 ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 5 of 6)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPEC IFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

6. Auxiliary Feedwater
a. Automatic Actuation 1, 2, 3 2 trains G SR 3.3.2.2 NA Logic and Actuation SR 3.3.2.4 Relays (Solid State SR 3.3.2.6 Protection System)
b. Not Used .
c. SG Water Level 1, 2, 3 4 per SG D SR 3.3.2.1 2:37.5% of narrow Low-Low SR 3.3.2.5 range span SR 3.3.2.9 (Unit 1) (q)(r)

SR 3.3.2.10 2:34.9% of narrow range span (Unit2) (q)(r)

d. Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements .
e. Loss of Offsite 1, 2, 3 1 per train F SR 3.3.2.7 NA Power SR 3.3.2.9 SR 3.3.2.10
f. Not Used.
g. Trip of all Main 1, 2 2 perAFW J SR 3.3.2.8 NA Feedwater Pumps pump
h. Not Used .

(a) The Allowable Value defines the limiting safety system except for functions 5b and 6c (the Nominal Trip Setpoint defines the limiting safety system setting for these Trip Functions) . See the Bases for the Nominal Trip Setpoints.

(q) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(r) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a va lue that is more conservative than the Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint, the methodology used to determine the as-found tolerance and the methodology used to determine the as-left tolerance sha ll be specified in the Technical Specification Bases.

COMANCHE PEAK - UNITS 1 AND 2 3.3-33 Amendment No. 4-eG, 156

Attachment 2 to TXX-18011 Page3of10 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES , LCO, and APPLICABILITY (continued) decay heat removal. During a loss of offsite power, to both safety related busses feeding the motor driven AFW pumps, the loss of power to the bus feeding the turbine driven AFW pump valve control motor will start the turbine driven AFW pump to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip. In addition , once the diesel generators are started and up to speed , the motor driven AFW pumps will be sequentially loaded onto the diesel generator busses .

Functions 6.a through 6.e must be OPERABLE in MODES 1, 2, and 3 to ensure that the SGs remain the heat sink for the reactor. SG Water Level-Low Low in any operating SG will cause the motor driven AFW pumps to start. The system is aligned so that upon a start of the pump, water immediately begins to flow to the SGs. SG Water Level-Low Low in any two operating SGs will cause the turbine driven pumps to start. These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RHR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation .

f. Not Used
g. Auxiliary Feedwater - Trip of All Main Feedwater Pumps A Trip of all MFW pumps is an indication of a loss of MFW and the subsequent need for some method of decay heat and sensible heat removal to bring the reactor back to no load temperature and pressure . Each turbine driven MFW pump is equipped with two pressure switches on the oil line for the speed control system . A Train "A" and a Train "B" sensor is on each MFW pump . The Train "A(B)" trip signals from both MFW pumps are required to actuate the Train "A(B)" motor-driven auxiliary feedwater pump . A trip of all MFW pumps starts the motor driven AFW pumps to ensure that at least one SG is available with water to act as the heat sink for the reactor.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-83 Revision73

Attachment 2 to TXX-18011 Page 4 of 10 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO , and APPLICABILITY (continued)

Function 6.g must be OPERABLE in MODES 1 and 2. This 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 MFW pumps may be normally shut down , and thus pump trip is not indicative of a condition requ iring automatic AFW initiation.

h. Not Used .
7. Automatic Switchover to Containment Sump 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 pumps pump the water through the RHR heat exchanger, inject the 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 must occur before the RWST Empty setpoint. Switchover of the containment spray pumps from the RWST to the containment sump is performed manually after completion of ECCS switchover, but 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. Raising the nominal RWST level at which Operations starts switchover (33%) would require prior NRC approval. This ensures the reactor remains shut down in the reci rculation mode.

a. Automatic Switchover to Containment Sump - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-84 Revision73

Attachment 2 to TXX-18011 Page 5 of 10 ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 5 of 6)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a) 6 . Auxiliary Feedwater

a. Automatic Actuation 1, 2, 3 2 trains G SR 3.3.2 .2 NA Logic and Actuation SR 3.3.2.4 Relays (Solid State SR 3.3.2 .6 Protection System)
b. Not Used.
c. SG Water Level 1, 2, 3 4 per SG D SR 3.3.2.1 ~37 .5% of narrow Low-Low SR 3.3.2.5 range span SR 3.3.2.9 (Unit 1) (q)(r)

SR 3.3.2.10 ~34.9% of narrow range span (Unit2) (q)(r)

d. Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements .
e. Loss of Offsite 1, 2 , 3 1 per train F SR 3.3.2.7 NA Power SR 3.3.2.9 SR 3.3.2.10
f. Not Used .
g. Trip of all Main 1, 2(d) 2 perAFW J SR 3.3.2.8 NA Feedwater Pumps pump
h. Not Used .

(a) The Allowable Value defines the limiting safety system except for functions 5b and 6c (the Nominal Trip Setpoint defines the limiting safety system setting for these Trip Functions). See the Bases for the Nominal Trip Setpoints.

(q) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band , then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(r) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint, the methodology used to determine the as-found tolerance and the methodology used to determine the as-left tolerance shall be specified in the Technical Specification Bases .

(d) When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators.

COMANCHE PEAK - UNITS 1 AND 2 3.3-33 Amendment No. 4-eG, 156

Attachment 2 to TXX-18011 Page6of10 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES , LCO , and APPLICABILITY (continued) decay heat removal. During a loss of offsite power, to both safety related busses feeding the motor driven AFW pumps, the loss of power to the bus feeding the turbine driven AFW pump valve control motor will start the turbine driven AFW pump to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip . In addition, once the diesel generators are started and up to speed, the motor driven AFW pumps will be sequentially loaded onto the diesel generator busses.

Functions 6.a through 6.e must be OPERABLE in MODES 1, 2, and 3 to ensure that the SGs remain the heat sink for the reactor. SG Water Level-Low Low in any operating SG will cause the motor driven AFW pumps to start. The system is aligned so that upon a start of the pump, water immediately begins to flow to the SGs. SG Water Level-Low Low in any two operating SGs will cause the turbine driven pumps to start. These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RHR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation .

f. Not Used
g. Auxiliary Feedwater - Trip of All Main Feedwater Pumps A Trip of all MFW pumps is an indication of a loss of MFW and the subsequent need for some ip of all MFW pumps is an indication of a loss of method of decay heat and sensible heat removal and t ubsequent need for some method of de to bring the reactor back to no load temperature ~ ensible he emoval to bring the re~ctor ~ to no load .

and pressure. Each MFW pump is equipped wit~ emperature an ssure. Each turbtn riven MFW pump 1s two pressure switches on the oil line for the speed equipped with two pre re switc on the oil line for the speed control system. A

  • A" and a Train "B" sensor is control system. Train 'A' and Train 'B' sensors are on each MFW pump. T rain B)" trip signals from both on each MFW pump. Trip signals from both MFW MFW pumps are r ired to actuate Train "A(B)" motor-pumps are required to actuate the motor driven driven auxiliar eedwater pump. A trip of a FW pumps AFW pump auto-start. A trip of both MFW pumps starts th otor driven AFW pumps to ensure th t least starts the motor driven AFW pumps to ensure that is available with water to act as the heat sink the at least one SG is available with water to act as the heat sink for the reactor.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-83 Revision 73- 75

Attachment 2 to TXX-18011 Page 7 of 10 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO , and APPLICABILITY (continued)

Function 6.g must be OPERABLE in MODES ensures 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 MODE 2, when the MFW pump(s) are not feeding the steam generators, this h. Not Used .

function is not required as the AFW system is A t

. 7.

t* S *t h t C t

  • u oma 1c w1 c over o on ainmen t s ump operating to feed the steam generators and does not require the auto-start from this functi 0 Jl.t the end of the injection phase of a LOCA, the RWST will be nearly In MODES 3, 4, and 5, the MFW pumps are empty. Continued cooling must be provided by the ECCS to remove normally shutdown, and thus neither pump decay heat. The source of water for the RHR pumps is semi-trip is indicative of a condition requ iring automatically switched to the containment recirculation sumps . After automatic AFW initiation. switching the low head residual heat removal (RHR) pumps draw the water from the containment recirculation sump, the RHR pumps pump the water through the RHR heat exchanger, inject the 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 must occur before the RWST Empty setpoint. Switchover of the containment spray pumps from the RWST to the containment sump is performed manually after completion of ECCS switchover, but 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. Raising the nominal RWST level at which Operations starts switchover (33%) would require prior NRC approval. This ensures the reactor remains shut down in the recirculation mode.

a. Automatic Switchover to Containment Sump - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-84 Revision Tfr 75

Attachment 2 to TXX-18011 Page8of10 ESFAS Instrumentation 3.3.2 Tab le 3.3.2-1 (page 5 of 6)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

6. Auxiliary Feedwater
a. Automatic Actuation 1, 2, 3 2 trains G SR 3.3.2.2 NA Logic and Actuation SR 3.3.2.4 Relays (Solid State SR 3.3.2.6 Protection System)
b. Not Used.

C. SG Water Level 1, 2, 3 4 per SG D SR 3.3.2.1 :2:37 .5% of narrow Low-Low SR 3.3.2.5 range span SR 3.3.2.9 (Unit 1) (q)(r)

SR 3.3.2.10 :2:34 .9% of narrow range span (Unit 2) (q)(r)

d. Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements .
e. Loss of Offsite 1, 2, 3 1 per train F SR 3.3.2.7 NA Power SR 3.3.2.9 SR 3.3.2.10
f. Not Used .
g. Trip of all Main 1, 2(d) 2 perAFW J SR 3.3.2.8 NA Feedwater Pumps pump
h. Not Used.

(a) The Allowable Value defines the limiting safety system except for functions Sb and 6c (the Nominal Trip Setpoint defines the limiting safety system setting for these Trip Functions). See the Bases for the Nominal Trip Setpoints .

(d) When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators.

(q) If the as-found channel setpoint is conservative with respect to the Allowable Value but outside its predefined as-found acceptance criteria band , then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(r) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance of the Nominal Trip Setpoint, or a value that is more conservative than the Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoint, the methodology used to determine the as-found tolerance and the methodology used to determine the as-left tolerance shall be specified in the Technical Specification Bases.

COMANCHE PEAK - UNITS 1 AND 2 3.3-33 Amendment No. 150, 156,

Attachment 2 to TXX-18011 Page 9 of 10 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES, LCO , and APPLICABILITY (continued) decay heat removal. During a loss of offsite power, to both safety related busses feeding the motor driven AFW pumps ,

the loss of power to the bus feeding the turbine driven AFW pump valve control motor will start the turbine driven AFW pump to ensure that at least one SG contains enough water to serve as the heat sink for reactor decay heat and sensible heat removal following the reactor trip. In addition , once the diesel generators are started and up to speed , the motor driven AFW pumps will be sequentially loaded onto the diesel generator busses.

Functions 6.a through 6.e must be OPERABLE in MODES 1, 2, and 3 to ensure that the SGs remain the heat sink for the reactor. SG Water Level-Low Low in any operating SG will cause the motor driven AFW pumps to start. The system is aligned so that upon a start of the pump , water immediately begins to flow to the SGs. SG Water Level-Low Low in any two operating SGs will cause the turbine driven pumps to start. These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPERABLE because either AFW or residual heat removal (RHR) will already be in operation to remove decay heat or sufficient time is available to manually place either system in operation.

f. Not Used
g. Auxiliary Feedwater - Trip of All Main Feedwater Pumps A Trip of all MFW pumps is an indication of a loss of MFW and the subsequent need for some method of decay heat and sensible heat removal to bring the reactor back to no load temperature and pressure. Each MFW pump is equipped with two pressure switches on the oil line for the speed control system. Train 'A' and Train 'B' sensors are on each MFW pump. Trip signals from both MFW pumps are required to actuate the motor driven AFW pump auto-start. A trip of both MFW pumps starts the motor driven AFW pumps to ensure that at least one SG is available with water to act as the heat sink for the reactor.

( continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-83 Revision 75

Attachment 2 to TXX-18011 Page10of10 ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES , LCO, and APPLICABILITY (continued)

Function 6.g must be OPERABLE in MODES 1 and 2 when the MFW pump(s) are feeding the steam generators and the AFW system has been placed in standby for auto-start. This ensures 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 MODE 2, when the MFW pump(s) are not feeding the steam generators, this function is not required as the AFW system is operating to feed the steam generators and does not require the auto-start from this function . In MODES 3, 4, and 5, the MFW pumps are normally shutdown , and thus neither pump trip is indicative of a condition requiring automatic AFW initiation.

h. Not Used .
7. Automatic Switchover to Containment Sump 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 pumps pump the water through the RHR heat exchanger, inject the 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 must occur before the RWST Empty setpoint. Switchover of the containment spray pumps from the RWST to the containment sump is performed manually after completion of ECCS switchover, but 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. Raising the nominal RWST level at which Operations starts switchover (33%) would require prior NRC approval. This ensures the reactor remains shut down in the recirculation mode.
a. Automatic Switchover to Containment Sump - Automatic Actuation Logic and Actuation Relays Automatic actuation logic and actuation relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.3-84 Revision75

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