CP-201800659, (Cpnpp), Unit 1 - Response to Request for Additional Information Regarding Exigent License Amendment Request (LAR) 18-001, Revision to Technical Specification 3.8.4, 11DC Sources - Operating, Condition B

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(Cpnpp), Unit 1 - Response to Request for Additional Information Regarding Exigent License Amendment Request (LAR)18-001, Revision to Technical Specification 3.8.4, 11DC Sources - Operating, Condition B
ML18267A059
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 09/20/2018
From: Thomas McCool
Luminant, Vistra Operations Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201800659, EPI D L-2018-LLA-0238, LAR18-001, TXX-18064
Download: ML18267A059 (20)
v • d • e


Text

V!S'!~I\

ENERGY Thomas P. McCool Site Vice President Luminant P.O. Box 1002 .

6322 North FM 56 Glen Rose, TX 76043 o 254.897.6042 CP-201800659 TXX-18064 U.S. Nuclear Regulatory Commission Ref 10 CFR 50.90 ATIN: Document Control Desk 10 CFR 50.91(a)(6)

Washington, DC 20555-0001 10 CFR 50.91(b) 9/20/2018

SUBJECT:

Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 Docket No. 50-445 Response to Request for Additional Information regarding Exigent License Amendment Request (LAR)18-001, 11 Revision to Technical Specification 3.8.4, DC Sources - Operating," Condition B (EPI D L-201S:-LLA-0238)

Reference 1. Letter TXX-18010 from Thomas P. McCool to the NRC "Submittal of Exigent License Amendment 11 Request (LAR)l 18-001, Revision to Technical Specification 3.8.4, DC Sources - Operating,"

Condition. B, dated September 5, 2018 (ML18250A186)

2. NRC Letter from Margaret W. O'Banion to Ken J. Peters, "Comanche Peak Nuclear Power Plant, Unit No. 1- Request For Additional Information Regarding License Amendment Request to Revise Technical Specification 3.8.4, "DC: SOURCES - OPERATING," CONDITION B (EXIGENT CIRCUMSTANCES), dated September 14, 2018 (ML18256A257)

Dear Sir or Madam:

Vistra Operations Company LLC ("Vistra OpCo") hereby submits a response to an NRC request for additional information (RAI) (Reference 2) in connection with LAR 18-001 requested in Reference 1. Reference 2 requested a response by September 18, 2018. On September 18, 2018, as a result of a d[scussion between the,NRC (Margaret O!Banion) and Vistra OpCo (Carl Corbin) it was agreed that a response to the NRC RAls could be provided no later than September 20, 2018.

/ provides Vistra OpCo's response to the NRC Request for Additional Information.

Attachments 1 through 4 were previously provided in Reference 1 and are updated to reflect the responses in .

TXX-18064 Page 2 of 2 contains a list of inspections, compensatory measures, and conditions. Attachment 2 contains a regulatory commitment associated with the requested change. Attachment 3 provides existing TS pages marked to show proposed changes. Attachment 4 provides revised (clean) TS pages. Attachments 1, 2, 3, and 4 of this letter replace Attachments 1, 2, 3, and 5 of Reference 1.

Regulatory Commitment 5644411 has been incorporated into the NOTE in TS 3.8.4, REQUIRED ACTION B.2 (see Attachments 3 and 4).

In accordance with 10CFR50.91(b}, Vistra OpCo is providing the State of Texas with a copy of this response to the request for additional information.

The No Significant Hazards Consideration Determination provided in Enclosure 1 of Reference 1 is not changed by the additional information provided by this letter.

Should you have any questions, please contact Carl B. Corbin at (254)' 897-0121.

I state under penplty of perjury that the foregoing is true and correct.

Executed on September 20, 2018.

Sincerely, CPNPP Response to NRC RAls List of Inspections, Compensatory Measures, and Conditions List of Regulatory Commitments Existing TS Pages Marked to Show the Proposed Changes Revised (Clean) TS Pages c- Kriss Kennedy,_Region IV Mark Haire, Region IV Margaret Watford O'Banion, 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, 78714-934 7

Enclosure to TXX-18064 Page 1 of 8 NRC RAI 1:

Criterion 17 (GDC 17), "Electric power systems," of Appendix A, "General Design Criteria [GDC] for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (10 CFR}, Part 50, requires, in part, that:

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Paragraph 50.63(a), "Loss of ,all alternating current power," to 10 CFR states, in part, that each light-water-cooled nuclear power plant licensed to operate "must be able to withstand for a specified duration and recover from a station blackout [SBO] ... "

Section 88, "Station Blackout," of the CPNPP Final Safety Analysis Report, as updated (FSAR), states, in part, that the licensee complies with SBO requirements by having the batteries as an independent alternating current power source for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by using Class 1E batteries (i.e., both Train A and 8 batteries) based on the loading requirements specified in FSAR Table 8.3-4, "125-Vdc Class 1E Battery Load Requirements."

In Section 3.1.2, "Battery Cell Replacement Discussion," of the LAR, the licensee states "[t]hat even though the

  • affected battery is inoperable due to the disassembly of seismic bracing, the battery will remain connected and available for approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the requested 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMPLETION TIME. For the planned activity, unavailability is limited to approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and is equivalent to the existing 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> COMPLETION TIME for TS 3.8.4 REQUIRED ACTION 8.1."
  • The LAR does not appear to address how the SBO 4-hour coping time requirements will be met, as specified in the FSAR, during the proposed extended CT for each battery.
  • Address how the SBO 4-hour coping requirements will be met, as specified in CPNPP FSAR Table 8.3-4, during the duration of the requested CT if an SBO event occurs at CPNPP, Unit No. 1. In addition, identify how the structures, systems, and components (SSCs) will meet the associated FSAR battery loading requirements and describe any additional compensatory measures that will be used to ensure the SSCs will meet the associated FSAR battery loading requirements.

CPNPP Response to NRC RAI 1:

The SBO coping assessment for CPNPP was performed assuming the blackout event occurs with both Units at 100% power as per article 3.2.1 of Regulatory Guide 1.155, "Station Blackout," August 1988 (ML003740034). The result of that assess,ment is CPNPP is a 'four hour coping' (duration) plant. Consistent with the Regulatory Guide and NUMARC 87-00, "Guidelines and Technical Bases for NUMARC Initiative Addressing Station Blackout at Light Water Reactors," Revision 1, August 1991 (ML12137A732) CPNPP relies on equipment controlled by plant Technical Specifications for event mitigation. Consistent with NRC Generic Letter No. 80-30, "Clarification of the Term 'Operable' as It Applies to Single Failure Criterion for Safety Systems Required by TS,"

April 10, 1980, during the time the affected battery would be under the extended COMPLETION Tl ME (CT) would constitute a " ... temporary relaxation of the single failure criterion, which, consistent with overall system reliability considerations provides a limited time to fix equipment or otherwise make it OPERABLE." This being the case, entry into the extended CT would not impact SBO compliance and would be fundamentally nb different than the condition wherein any equipment relied upon for SBO compliance was out-of-service in accordance with its respective Technical Specification CT.

Consistent with the guidance of the Regulatory Guide and NUMARC 87-00, the CPNPP coping assessment included a verification of the Class 1E batteries and determined each battery has sufficient capacity to supply SBO loads for the station blackout duration. Since the two trains of Class 1E DC power are independent of each other, this necessarily resulted in separate calculation of the loads and load carrying capability of each battery; for example, the calculation for BT1 ED2 (Train 8) is independent of the analysis of BT1 ED1 {Train A). It is the results of such calculations which are reflected in FSAR Table 8.3-4 and which show that the Class 1E batteries would maintain an adequate 'end-of-duty-cycle' voltage. Statements concerning the ability of both batteries to supply SBO loads for the required duration were first included in TXX-901008 (November 5, 1990), a Unit 1

Enclosure to TXX-18064 Page 2 of 8 specific document, and subsequently updated to reflect the same conclusion for Unit 2 (initially via TXX-92447, dated October, 1 1992). The logic behind analysis of using each train of DC power is simply to maximize the ability to recover AC power, either from an EOG or an offsite power source. The 'last minute load' shown on FSAR Table 8.3~4 for BT1 ED1 (BT2ED1) and BT1 ED2 (BT2ED2) includes consideration of breake(control loads and EOG field flashing. Examples of NRC review of CPNPP coping assessments can be found in the SER for CPNPP License Amendment No. 72 (September 30, 1999 / ML021820306) and section 2.3.2.7 of CPNPP License Amendment No. 146 (June 27, 2008 / ML081510173).

Per FSAR section 8.3.2.1, the CPNPP DC power system is designed in accordance with IEEE-308 and

  • are electrically and physically separate. NRC review of the DC power system is summarized in NUREG-0797, *

"Safety Evaluation Report related to the operation of Comanche Peak Steam Electric Station, Units 1 and 2," Section 8.3.2 which includes the statement: "There are no bus ties or sharing of power supplies betweensedundant trains."

During the time either affected Train B batteries wHI be under the extended CT, there will be no effect on the battery loading or assessment of the redundant Train A battery. Additional compensatory measures related to the SBO four hour coping duration are not required. As.detailed in Attachment 2 of this submittal, preventive measures will be implemented to reduce the potential for events or conditions which would complicate operations while in the extended CT.

Enclosure to TXX-18064 Page 3 of 8 NRC RAI 2: to the LAR contains Commitment 5, which addresses the proposed actions to be taken should severe weather conditions be anticipated prior to the scheduled battery cell replacement or if a severe thunderstorm warning or tornado warning is issued after entering TS 3.8.4 REQUIRED ACTION B.2. The commitment states, in part:

Battery cell replacement will not be scheduled if severe weather conditions are anticipated.

If a severe thunderstorm warning or tornado Warning is issued per ABN 907 ... after entry into TS 3.8.4 proposed REQUIRED ACTION B.2, then exit TS 3.8.4 proposed REQUIRED ACTION B.2 and enter TS 3.8.4 REQUIRED ACTION 0.1 (Be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) and TS 3.8.4 REQUIRED ACTION 0.2 (Be in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />).

  • While the Regulatory Commitment 5 addresses that the battery cell replacement will not be scheduled if severe weather conditions are anticipated, the commitment does not address if the licensee will enter TS 3.8.4, proposed REQUIRED ACTION B.2, if severe weather conditions are anticipated.

Justify why the actions described in Regulatory Commitment 5 do not address when the licensee would not enter TS 3.8.4, proposed REQUIRED ACTION B.2, if severe weather conditions are anticipated.

Also, clarify why the actions described in Regulatory Commitment 5 do not address actions necessary if severe thunderstorms and tornados watches are issued.

CPNPP is sensitive to severe weather anticipated or forecasted during the planned 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMPLETION TIME (CT). The first sentence of Commitment 5644411, item 5 (Attachment 2) is changed to "Battery cell replacement will not begin (i.e., entry into REQUIRED ACTION B.2) if severe weather conditions are anticipated during the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMPLETION TIME." Also, the first bullet under "List of Conditions where* CPNPP would not consider entering the one-time extended COMPLETION TIME" (Attachment 1) is changed to "Severe weather conditions are anticipated during the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> CT (see commitment in Attachment 2)."

Per CPNPP ABN-907, Acts of Nature, Section 5.0, Severe Weather, a "warning" means a severe thunderstorm or tornado has been sighted or detected by radar and may be approaching, a "watch" means meteorological conditions are favorable for the formation of a severe thunderstorm or tornado. If a "watch" were declared for Hood and/or Somervell counties, that condition would be captured by the opening statement of Attachment 2, Regulatory Commitment 5644411, item 5, "Battery cell replacement will not begin (i.e., entry into REQUIRED ACTION B.2) if severe weather conditions are anticipated during the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMPLETION TIME." Based on meteorological conditions, CPNPP ABN-907, Acts of Nature, Section 5.0, Severe Weather is utilized to ensure proper plant risk is considered and mitigated as necessary. The notification of a "watch" initiates a continuous monitor and evaluate posture until the "watch" is cancelled or elevated to a "\/\laming." The primary concern during Severe Weather is loss of offsite AC power. The actions initiated in response to a "watch" provide a framework to more closely monitor changing conditions that may impact offsite AC power. Should conditions deteriorate to a "warning" being issued then REQUIRED ACTION(s) D.1 and D.2 would be entered. Work to restore the battery will continue if REQUIRED ACTION(s) 0.1 and 0.2 are entered. Should the condition requiring entry into REQUIRED ACTION(s) 0.1 and 0.2 clear, REQUIRED ACTION B.2 would be resumed not to exceed a total COMPLETION TIME of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from the original entry time.

Enclosure to TXX-18064 Page 4 of 8 NRC RAI 3: to the LAR contains Regulatory Commitment 5, which addresses the proposed actions to be taken should a Severe Thunderstorm or Tornado Warning be issued after entering TS 3.8.4, proposed REQUIRED ACTION B.2. The commitment states, in part:

  • TS 3.8.4 proposed REQUIRED ACTION B.2 is entered and battery cell replacement begins.
  • One hour after entering TS 3.8.4 proposed REQUIRED ACTION B.2 a Tornado Warning is issued for Somervell County, the county where Comanche Peak is located.
  • At that one-hour point TS 3.8.4 proposed REQUIRED ACTION B.2 is exited and TS 3.8.4 REQUIRED ACTIONs D.1 and D.2 are entered.
  • One hour after exit from TS 3.8.4 proposed REQUIRED ACTION B.2 and entry into TS 3.8.4 REQUIRED ACTIONs D.1 and D.2, the Tornado Warning for Somervell County is cancelled and forecasts predict no further severe weather.
  • TS 3.8.4 REQUIRED ACTIONs D.1 and D.2 are exited and TS 3.8.4 proposed REQUIRED ACTION B.2 is re-entered with 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> remaining to complete battery cell replacement.

In addition, Attachment 2 of the LAR, contains Regulatory Commitment 6, which addresses the proposed actions to be taken to ensure the local grid is stable and no anticipated challenges have been identified. Regulatory Commitment states, in part:

Similar to the example described in severe weather above, if TS 3.8.4 REQUIRED ACTIONS D.1 and D.2 are entered due to an item (6.a, b, c, or d) above not being met and the items are subsequently met, then TS 3.8.4 REQUIRED ACTIONs 'D.1 and D.2 will be exited and TS 3.8.4 proposed REQUIRED ACTION B.2 will be re-entered and battery cell replacement will continue until completed or 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from initial entry into TS 3.8.4 proposed REQUIRED ACTION B.2.

The proposed language in the commitments above appear to conflict with the wording in the NOTE in TS 3.8:4, proposed REQUIRED ACTION B.2, as stated below: .

Required Action B.2 is applicable for a one-time basis to replace cell 27 in battery BT1 ED2 and cell 41 in battery BT1 ED4 during Unit 1 Cycle 20 (not at the same time). If the second battery on the same train becomes inoperable, immediately initiate Required Actions D.1 and D.2.

The proposed language in the NOTE indicates a one-time usage of TS 3.8.4, proposed REQUIRED ACTION B.2 to replace each cell in batteries BT1 ED2 and BT1 ED4. Commitments 5 and 6 indicate that TS 3.8.4, proposed REQUIRED ACTION B.2, can be entered, exited, and re-entered based on severe weather and grid instability.

Clarify why the Regulatory Commitments 5 and 6 are inconsistent with the proposed TS 3.8.4 REQUIRED ACTION B.2 NOTE. In addition, explain why the proposed NOTE allows re-entry into TS 3.8.4, REQUIRED ACTION B.2 and revise the NOTE, if necessary.

CPNPP Response to NRC RAI 3:

The following addresses the application of Technical Specification Limiting Condition for Operation (LCO) 3.8.4, DC Sources - Operating and LCO 3.0.2, LCO Applicability while in LCO 3.8.4 REQUIRED ACTION B.2.

REQUIRED ACTION(s) D.1 (Be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) and D.2 (Be in MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />) will be entered if any the following conditions occur while in REQUIRED ACTION B.2;

1. Notification* of a Severe Thunderstorm Warning or a Tornado Warning in Hood and/or Somervell counties per ABN-907, Acts of Nature, Section 5.0, Severe Weather
2. Notification from the Qualified Scheduling Entity (QSE) per ABN-601, Response to a 138/345 KV System Malfunction, Section 9.0, of Grid Frequency fluctuations/Loss of QSE Generation Controller Communications or Notification from TGM Transmission Grid Controller or QSE Generation Controller per ABN-601, Response to a 138/345 KV System Malfunction, Section 10.0, of Potentially Degraded Off-Site Power System Voltage

Enclosure to TXX-18064 Page 5 of 8

3. The battery in LCO 3.8.4 REQUIRED ACTION B.2 is disconnected from its DC bus for greater than two hours While in LCO 3.8.4 REQUIRED ACTION(s) D.1 *and D.2, if the condition requiring entry clears;
1. Severe Thunderstorm Warning or Tornado Warning for Hood and/or Somervell counties is cancelled
2. Notification from TGM Transmission G~id Controller or QSE Generation Controller that grid frequency and/or grid voltage is stable in the normal range
3. The battery in LCO 3.8.4 REQUIRED ACTION B.2 is connected to its DC bus Per LCO 3.0.2, LCO Appliyability; LCO 3.8.4 REQUIRED ACTION(s) D.1 and D.2 will be exited and REQUIRED ACTION B.2 will be resumed not to exceed a total COMPLETION TIME of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from the original entry time.

The above conditions are captured in Attachments 1 and 2 and in the revised NOTE of REQUIRED ACTION B.2 (See Attachments 3 and 4).

-Enclosure to TXX-18064 Page 6 of 8 NRC RAl4:.

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TS as part of the license. The regulations in 10 CFR Part 50.36, "Technical specifications," require, in part, that the operating license of a nuclear production facility include TSs. The regulations in 10 CFR 50.36(c)(2) require that the TSs include limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by tile TSs until the condition can be met.

In Section 3.1.2, "Battery Gell Replacement Discussion," of the LAR, the licensee states the following, in part:

That even though the affected battery is inoperable du.e to the disassembly of seismic bracing,, the battery will remain connected and available for approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the requested 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMPLETION TIME. For the planned activity, unavailability is limited to approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and is equivalent to the existing 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> COMPLETION TIME for TS 3.8.4 REQUIRED ACTION 8.1. .

The proposed language in TS 3.8.4 REQUIRED ACTION B.2 NOTE does not discuss the need to enter TS 3.8.4, REQUIRED ACTIONS D.1 and D.2 if batteries BT1 ED2 and BT1 ED4 are unavailable for greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> each. Explain why the proposed NOTE does not have this provision and revise the NOTE, if necessary.

CPNPP Response to NRC RAI 4:

The following addresses the application of Technical Specification Limiting Condition for Operation (LCO) 3.8.4,

If the battery in LCO 3.8.4 REQUIRED'ACTION B.2 is disconnected from its DC bus for greater than two hours, REQUIRED ACTION(s) D.1 (Be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) and D.2 (Be in MODE 5 in *35 hours) will be entered.

~ I While .in LCO 3.8.4 REQUIRED ACTION(s) D.1 and D.2, when the new battery cell is installed and the disconnect to its DC bus is closed, per LCO 3.0.2, LCO Applicability; LCO 3.8.4 REQUIRED ACTION(s) D.1 and D.2 will be exited and REQUIRED ACTION B.2 will be resumed not to exceed a total COMPLETION TIME of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from the original entry time.

The above conditions are captured in Attachments 1 and 2 and in the revised NOTE of REQUIRED ACTION B.2 (See Attachments 3 and 4).

Enclosure to TXX-18064 Page 7 of 8 NRC RAI 5:

GDC 17, "Electric power systems," of Appendix A to 10 CFR, *Part 50, requires, in part, that:

An onsite electric power system and an offsit~ electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

\

As quoted above in RAI 4, the licensee describes in Section 3.1.2 of the LAR that the affected battery will be inoperable due to the disassembly of seismic bracing during the extended CT, but the battery will be available for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.of the requested 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> CT. The licensee further states that unavailability of the batteries will be limited to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, which is equivalent to the existing 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> CT for TS 3.8.4 REQUIRED ACTION 8.1.

In addition, in Section 3.1.4, "Defense in Depth Considerations," of the LAR, the licensee states that "[t]he extension of the CT has no impact on the current safety analysis *because the remaining OPERABLE batteries are still available to perform their safety functions while in this TS action."

Please provide a discussion explaining: (1) what scenarios and failures the licensee has evaluated and (2) whether th~ licensee has established plant procedures, or will develop temporary plant procedures to address potential consequences to the plant in the event of a design basis event or an anticipated operational occurrence.

CPNPP Response to N.RC RAI 5:

(1) What Scenarios and failures the licensee has evaluated All scenarios and failures contained* with the FSAR are responded to per CPNPP Normal, Abnormal, and Emergency procedures. An evaluation of the changes for this license amendment request has determined no new scenarios or failures have been created or changed.

(2) whether the licensee has established plant procedures, or will develop temporary plant procedures to address potential consequences to the plant in the event of a design basis event or an anticipated operational occurrence.

Only existing procedure form ODA-308-3.8.4, Standard LCOAR for 3.8.4 DC Sources - Operating will have a supplement added to capture Regulatory Commitment 5644411 actions and measures.

Defense in Depth actions are listed in Regulatory Commitment 5644411. CPNPP procedure STl-600.01, "Protecting Plant Equipment and Sensitive Equipment Controls," establishes controls.

  • Level 1 Controls, Administrative (Work Schedule & Notifications of Personnel) - protection includes, but is not limited to, work planning, informational signs, floor tape, and notification of personnel through site work schedules.

This control level will establish a "protected train" (Train A for work on Train B batteries) concept. Work on the opposite train is planned (limited) to ensure the protected train safety functions are maintained. CPNPP personnel are made aware of the protected train through the use of "Protected Train Signs" and the Plan of the Day (POD) work schedule. The two Train B batteries BT1 ED2 and BT1 ED4 will have their cells replaced during Train B work weeks.

Level 2 Controls, Use of Physical Barriers - plant equipment is normally protected by the use of physical barriers and/or signs using the Guarded Equipment Management (GEM) Program. GEM postings provide plant equipment protection when an impairment of the equipment could result in;

('

Enclosure to TXX-18064 Page 8 of 8

  • loss of the equipment's safety function
  • reduced operating margin, or
  • inadvertent entry into a Technical Specification 3.0.3 plant shutdown Personnel are directed to NOT enter a GEM posted area without Shift Manager authorization.

During each battery cell replacement, the following equipment will be pQsted per the GEM program, Unit 1 and Unit 2;

1. Emergency Diesel Generators (both trains)
2. Alternate Power Generators (three per unit)
3. Turbine Driven Auxiliary Feedwater Pumps
4. lnservice Startup Transformers (XST1 orXST1A and XST2 of XST2A)
5. Component Cooling Water Pumps (both trains)
6.
7. Switchyard Relay House(s) entrances (138kV and 345kV)

Per CPNPP procedure STl-429.04, "Pre-Job and Post Job Briefs and Take Two" a Formal Pre-Job Brief structured to focus on complex, risk-significant, and/or infrequently performed tasks, will be held prior to each battery cell replacement. Each pre-job brief will include as a minimum; safety critical steps, prior performance (including OE), error likely steps, anticipated worst case outcome, and kinds of defenses. These defenses include the GEM postings, work scheduling, and contingency actions. The pre-job brief will also cover roles and responsibilities for all participants.

to TXX-18064 Page 1 of 2 List of Inspections, Compensatory Measures, and Conditions Summary of Current Routine Inspections (see Section 3.1.4)

  • Maintenance Surveillances o Weekly Inspection o Monthly Inspection o Quarterly Inspection o IEEE 450-1995 Quarterly Inspections
  • Operations Surveillance/ Inspections (See Section 3.1.4) o Shiftly Surveillance (area temperature) o Shiftly Tours/ Inspection of batteries
  • Engineering enhanced monitoring / inspections due to cracking (See Section 3.1.4) o Weekly walkdowns of all Class 1E batteries that have a condition adverse to quality Summary of New Compensatory Measures to be implemented in addition to the Current Routine Inspections described above
  • Fire Protection Administrative Controls I Protective Measures for the fire areas I fire zones of the affected Unit 1 Train (See commitment in Attachment 2) o Hourly roving fire wa.tch in the Fire Areas of Concern  ;

o Suspend ongoing "Hot Work" and prohibit start of any new "Hot Work" in the Fire Areas of Concern o Do not introduce any new transient combustibles, or add to any transient combustibles already authorized in the Fire Areas of Concern

  • Grid Stability (see Section 3.1. 7 and commitment in Attachment 2) o Prior to entry into TS 3.8.4 REQUIRED ACTION 8.2, contact Transmission Grid Controller (TGM) to assure local grid is stable and no anticipated challenges have been identified
  • Prior to entry into TS 3.8.4 REQUIRED ACTION 8.2 (see commitment in Attachment 2) o Access to both switchyards and relay houses will be controlled and posted, and all planned maintenance will be suspended for the duration of the CT.

o The following applies to Unit 1 and Unit 2. The Emergency Diesel Generators, Alternate Power Generators, Turbine Driven Auxiliary Feedwater Pumps, inservice Startup Transformers, Component Cooling Water Pumps, and Station Service Water Pumpts will have ALL testing and maintenance activities suspended o Both Unit 1 and 2 Transient Combustible safe zones identified in the fire assessment, in the unaffected battery / inverter areas, the Main Control Room (MCR) and the Cable Spreading Room (CSR) and the cable routing paths for the inservice Startup Transformers will have additional restrictions relating to combustible storage during the extended CT durations.

o All hot work activities along the routing associated with power and control cabling for inservice

,Startup Transformers, in the unaffected battery / inverter areas, the MCR, and the CSR will be suspended during the CT.

  • Severe Weather (see commitment in Attachment 2) o If a Severe Thunderstorm Warning or Tornado Warning is issued per CPNPP procedure ABN 907 after entry into TS 3.8.4 REQUIRED ACTION 8.2, then TS 3.8.4 REQUIRED ACTION D.1 (Be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) and TS 3.8.4 REQUIRED ACTION D.2 (Be in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />) will be entered.

o Once the applicable severe weather warning is cancelled and plant system statuses are verified, TS 3.8.4 REQUIRED ACTIONs D.1 and D.2 will be exited and TS 3.8.4 REQUIRED ACTION 8.2 will be resumed and battery cell replacement will continue until completed or 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from initial entry into TS 3.8.4 REQUIRED ACTION 8.2.

to TXX-18064 Page 2 of 2 List of conditions where CPNPP would not enter the one-time extended COMPLETION TIME

  • Severe weather conditions are anticipated during the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> CT (see commitment in Attachment 2)
  • Transmission Grid Controller (TGM) has been contacted and the local grid is not stable or anticipated challenges have been identified during the, 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> CT (see commitment in Attachment 2)

List of conditions where CPNPP would exit the one-time extended COMPLETION TIME (see commitment in Attachment 2)

  • Prior to entry into TS 3.8.4 REQUIRED ACTION B.2, CPNPP will verify the following items and every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> thereafter. If any item is not met after entry into TS 3.8.4 REQUIRED ACTION B.2, then TS 3.8.4 REQUIRED ACTIONS D.1 and D.2 will be entered:
a. Both offsite sources available as determined by performance ofCPNPP procedure OPT-215-1, "Offsite Transmission Network Operability Data Sheet"
b. Affected 6.9kV bus steady state frequency is 59.5 - 60.5 Hz (Reference 6.32)
c. 1"he Turbine Driven Auxiliary Feedwater Pump (TDAFW) is OPERABLE per TS 3.7.5, "Auxiliary Feedwater (AFW) System"
d. The plant is not operating under an ACTION statement for an inoperable offsite AC power source or the opposite train Emergency Diesel Generator

) .

)

to TXX-18064 Page 1 of 2 Regulatory Commitment (Number 5644411)

Will be implemented During the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMPLETION TIME

1. Access to both switchyards and relay houses will be controlled and posted, and all planned maintenance will be suspended for the duration of the CT. This risk reduction measure was selected due to the reliance on offsite power during the CT extension. The measure is selecteq to deter any potential transmission grid perturbations or trip issues to the 6.9 kV power supplies from either the 345kV or 138kV switchyard. Work in the switchyard is administratively controlled by the Operations Shift Manager (SM) who by plant procedure, STA-629 "Switchyard Control and Transmission Grid Interface," has sole authority to grant access to the switchyards. By SM authority, any testing or maintenance activities or access to either switchyard will not be .

permitted, with the exception of normal operator visual inspection rounds.

2. The following applies to Unit 1 and Unit 2. The Emergency Diesel Generators, Alternate Power Generators, Turbine Driven Auxiliary Feedwater Pumps, lnservice Startup Transformers, Component Cooling Water Pumps, and Station Service Water Pumps will have ALL testing and maintenance activities suspended for the duration of the extended battery CT. Additionally, during the extended CT, signs will be placed on the doorways to the equipment, or in the case of the inservice Startup Transformers, boundary signs, and barrier tape, rope, or chains will be installed around the equipment and in-service batteries, chargers, and inverters, noting the restriction of testing and maintenance. These risk reduction measures ensure continued availability of these components for the entire duration of the CT. 1
3. For Fire Safety Shutdown Analysis (FSSA) - Fire Areas of Concern will have additional restrictions on combustible storage during the extended CT. All "Hot Work" in the Fire Areas of Concern will be suspended. An hourly roving fire watch will be in effect to protect the Fire Areas of Concern. The Fire Areas of Concern are the areas that credit the affected battery in the FSSA.
4. For Risk Mitigation -
a. Both Unit 1 and 2 Transient Combustible safe zones identified in the fire assessment, in the unaffected battery room, charger room, inverter rooms, the Main Control Room (MCR), the Cable Spreading Room (CSR) and the cable muting paths for the inservice Startup Transformers will have additional restrictions relating to combustible storage during the extended CT. Implementing this risk reduction measure will reduce the fire risks that were identified for the transient combustible scenarios in the fire analysis.
b. All hot work activities along the routing associated with power and control cabling for inservice Startup Transformers, in the unaffected battery room, charger room, and inverter room, MCR, and CSR will be suspended during the CT. This is to reduce the risks associated with fires that could damage and thus disable the Startup Transformer cabling.
c. An hourly roving fire watch will be in effect to protect areas
i. credited by the fire assessment, specifically, the unaffected battery room, charger room, inverter room, MCR, and CSR (to minimize the exposure time for detection and suppression of potential fires) and ii. areas containing power and control cabling of the inservice Startup Transformers (to minimize loss of offsite power).

to TXX-18064 Page 2 of 2

5. Conditions related to REQUIRED ACTION 8.2 (to address LCO 3 ..0.2 applicability, severe weather, grid stability, and battery unavailability)
a. Prior to entry into REQUIRED ACTION 8.2 CPNPP will:
i. Verify severe weather conditions are not anticipated during the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMPLETION TIME (CT) .

ii. Contact the Transmission Grid Controller (TGM) to ensure the local grid is stable and no anticipated challenges have been identified during the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> CT .

b. REQUIRED ACTION(s) D.1 and D.2 will be entered if any the following conditio~s occur while in REQUIRED ACTION 8.2;
i. Notification of a Severe Thunderstorm Warning or a Tornado Warning in Hood and/or Somervell counties per ABN-907, Acts of Nature, Section 5.0, Severe Weather ii. Notification from the Qualified Scheduling Entity (QSE) per ABN-601, Response to a 138/345 KV System Malfunction, Section 9.0, of Grid Frequency fluctuations/Loss of QSE Generation Controller Communications or Notification from TGM Transmission Grid Controller or QSE Generation Controller per ABN-601, Response to a 138/345 KV System Malfunction, Section 10.0, of Potentially Degraded Off-Site Power System Voltage iii. The battery in REQUIRED ACTION 8.2 is disconnected from its DC bus for greater than two hours
c. While in REQUIRED ACTION(s) D.1 and D.2 (due to item 5.b above),

lE the condition requiring entry clears due to;

i. Severe Thunderstorm Warning or Tornado Warning is cancelled for Hood and/or Somervell counties is cancelled ii. Notification from TGM Transmission Grid Controller or QSE Generation Controller that grid frequency and/or grid voltage is stable in the normal range iii. The battery in REQUIRED ACTION 8.2 is connected to its DC bus THEN per LCO 3.0.2, LCO Applicability; REQUIRED ACTION(s) D.1 and D.2 will be exited and REQUIRED ACTION 8.2 will be resumed not to exceed a total COMPLETION TIME of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from the original entry time.
d. Prior to entry into REQUIRED ACTION 8.2, CPNPP will verify the following items and every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> thereafter. If any item is not met after entry into REQUIRED ACTION 8.2, then REQUIRED ACTION(s) D.1 and D.2 will be entered:
i. Both offsite sources available as determined by performance of OPT-215-1, "Offsite Transmission Network Operability Data Sheet" ii. Unit 1 6.9kV bus steady state frequency is 59.5 - 60.5 Hz (ABN-602) iii. The Turbine Driven Auxiliary Feedwater Pumps (TDAFW) are OPERABLE per TS 3.7.5, "Auxiliary Feedwater (AFVfJ System" iv. Unit 1 is not operating under an ACTION statement for an inoperable offsite AC power source or the opposite train Emergency Diesel Generator
e. While in REQUIRED ACTION(s) D.1 and D.2 (due to item 5.d above),

lE the condition requiring entry clears due to;

i. Both offsite sources become available as determined by performance of OPT-215-1, "Offsite Transmission Network Operability Data Sheet" ii. Unit 1 6.9kV bus steady state frequency returns to 59.5 - 60.5 Hz (ABN-602) iii. The Turbine Driven Auxiliary Feedwater Pumps (TDAFW) return to OPERABLE per TS 3.7.5, "Auxiliary Feedwater (AFW) System" iv. Unit 1 is not operating .under an ACTION statement for an inoperable offsite AC power source or the opposite train Emergency Diesel Generator THEN per LCO 3.0.2, LCO Applicability; REQUIRED ACTION(s) D.1 and D.2 will be exited and REQUIRED ACTION 8.2 will be resumed not to exceed a total COMPLETION TIME of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> from the original entry time.

Attachment 3 to TXX-18064 Page 1 of 2 DC Sources -- Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources -- Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required battery A.1 Restore affected battery(ies) terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> chargers on one train voltage to greater than or equal to the inoperable. minimum established float voltage.

AND A.2 Verify affected battery(ies) float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current :.: : 2 amps .

AND Insert A Restore required battery charger(s) 7 days OPERABLE status.

B. One or two batteries on one 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> train inoperable.

C . One DC electrical power C.1 Restore DC electrical power 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> subsystem inoperable for subsystem to OPERABLE status.

reasons other than Condition A or B.

COMANCHE PEAK - UNITS 1 AND 2 3.8-23 Amendment No. 150 to TXX- 18064 Page 2 of 2 Insert A (Note : Proposed changes are clouded)

ACTIONS COND ITI ON REQU IRED ACTION COMPLETION TIME B. One or two batterie s on one B.1 Restore affected battery(ies) to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> train inoperable . OPERABLE status.

OR B. 2 ------------NOTE------------------

Req u ired Action B.2 is applicable for a one-time basis .

to replace cell 27 in battery BT1ED2 and cell 41 in battery -

BT1ED4 during Unit 1 Cycle 20 (not at the same time) . If the second battery on the same train becomes inoperable, -

immediately initiate Required -

Actions D.1 and D.2. Regulatory Commitment 5644411 .

(Attachment 2 to TXX-18064) will be implemented during the -

18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> Completion Time. -

Restore affected battery to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> -

OPERABLE status .

to TXX-18064 Page 1 of 4 Revised (Clean) TS Pages (4 total pages)

Attachment 4 List of Pages TS Page 3.8-23 TS Page 3.8-24 TS Page 3.8-25

DC Sources -- Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources -- Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or two required battery A.1 Restore affected battery(ies) terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> chargers on one train voltage to greater than or equal to the inoperable. minimum established float voltage.

AND A.2 Verify affected battery(ies) float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current ::;; 2 amps.

AND A.3 Restore required battery charger(s) 7 days to OPERABLE status. .

COMANCHE PEAK - UNITS 1 AND 2 3.8-23 Amendment No. 4§.0;--

DC Sources -- Operating 3.8.4 ACTIONS (continued)

8. One or two batteries on one 8.1 Restore affected battery(ies) to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> train inoperable. OPERABLE status.

-OR B.2 --------------------NOTE---------------------

Required Action B.2 is applicable for a one-time basis to replace cell 27 in battery BT1 ED2 and cell 41 in battery BT1 ED4 during Unit 1 Cycle 20 (not at the same time). If the second battery on the same train becomes inoperable, immediately initiate

( Required Actions D.1 and D.2.

Regulatory Commitment 5644411 (Attachment 2 to TXX-18064) will be implemented during the 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> Completion Time.

. Restore affected battery to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> OPERABLE status.

C. One DC electrical power C. 1 Restore DC electrical power 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> subsystem inoperable for subsystem to OPERABLE status.

reasons other than

  • Condition A or B. .

D. Required Action and I D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> COMANCHE PEAK - UNITS 1 AND 2 3.8-24 Amendment No. 4-eG, .

DC Sources -- Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to In accordance with

. the minimum established float voltage. the Surveillance Frequency Control program.

I SR 3.8.4.2 Verify each battery charger supplies~ 300 amps at greater In accordance with

- than or equal to the minimum established chargertest the Surveillance voltage for ~ 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Frequency Control

. / Program .

OR Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous 1

steady state loads, after a battery discharge to the bounding_ design basis event discharge state .

SR 3.8.4.3 .----------------------------------NOTES---------------------------- '----

1. The modified performance discharge test in SR 3.8.6.6 -

may be performed in lieu of SR 3.8.4.3.

2. Verify requirement during MODES 3, 4, 5, 6 or with core off-loaded.

Verify battery capacity is adequate to supply, and maintain In accordance with in OPERABLE status, the required emergency loads for the the Surveillance design duty cycle when subjected to a battery service test. Frequency Control program.

COMANCHE PEAK - UNITS 1 AND 2 3.8-25 Amendment No. 150, 156, l

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