CP-202000401, (CPNPP) - Supplement to Exigent License Amendment Request (LAR) 20-002, Revision to Technical Specification (TS) 3.7.19, Safety Chilled Water

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(CPNPP) - Supplement to Exigent License Amendment Request (LAR)20-002, Revision to Technical Specification (TS) 3.7.19, Safety Chilled Water
ML20210M089
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/28/2020
From: Sewell S
Luminant, Vistra Operations Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202000401, LAR 20-002, TXX-20056
Download: ML20210M089 (22)
v • d • e


Text

m Luminant CP-202000401 TXX-20056 July 28, 2020 Steven K. Sewell Senior Director, Engineering & Regulatory Affairs Comanche Peak Nuclear Power Plant (Vistra Operations Company LLC)

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.6113 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Ref 10 CFR 50.90 10 CFR 50.91(a)(6) 10 CFR 50.91(b)(l)

Subject:

Reference:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 SUPPLEMENT TO EXIGENT LICENSE AMENDMENT REQUEST (LAR)20-002, REVISION TO TECHNICAL SPECIFICATION (TS) 3.7.19, "SAFETY CHILLED WATER"

1.

Letter TXX-20039 from Thomas P. McCool to the NRC "Exigent License Amendment Request (LAR)20-002, Revision to Technical Specification (TS) 3.7.19, "Safety Chilled Water," dated June 24, 2020 (ML20176A281)

2.

A public teleconference held on July 7, 2020 identified the need for a supplement to clarify information found in LAR 20-002, Revision to TS 3.7.19, Safety Chilled Water (ML20190A067)

3.

Letter TXX-20052 from Thomas P. McCool to the NRC "Supplement to Exigent License Amendment Request (LAR)20-002, Revision to Technical Specification (TS) 3.7.19, "Safety Chilled Water," dated July 16, 2020 (ML20198M365)

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Vistra Operations Company LLC (Vistra OpCo) hereby submits a supplement to the exigent license amendment request for the Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 and Unit 2 Technical Specifications in connection to LAR 20-002, Revision to TS 3.7.19, Safety Chilled Water requested in Reference 1. Reference 2 information was utilized to supplement the original submittal in Reference 3.

The Enclosure to this letter provides; an executive summary describing changes to Section 2.4 of the original submittal (Reference 1) and clarifying information for Attachments 2 and 3. contains an updated regulatory commitment associated with the requested change., contains updated Technical Specifications and Bases pages associated with the requested change.

In accordance with 10 CFR 50.91(b)(l), a copy of the supplement for the proposed license amendment is being forwarded to the State of Texas.

Vistra OpCo has determined that this supplement does not change the No Significant Hazards Consideration provided in the Enclosure submitted by Reference 1.

TXX-20056 Page 2 of2 Should you have any questions, please contact Garry W Struble at (254) 897-6628 or garry.struble@luminant.com.

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

Executed on July 28, 2020.

Sincerely,

Enclosure:

SUPPLEMENT TO EXIGENT LICENSE AMENDMENT REQUEST (LAR)20-002 REVISION TO TECHNICAL SPECIFICATION (TS) 3.7.19, "SAFETY CHILLED WATER" EXECUTIVE

SUMMARY

Attachments: 1.

[Not Used]

c (email) -

2.

Regulatory Commitment No. 5900444

3.

Technical Specifications and Bases Scott Morris, Region IV [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP [John.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

Mr. Robert Free [robert.free@dshs.state.tx.us]

Environmental Monitoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P.O. Box 149347 Austin, TX 78714-9347

Enclosure to TXX-20056 Page 1 of 1 SUPPLEMENT TO EXIGENT LICENSE AMENDMENT REQUEST (LAR)20-002 REVISION TO TECHNICAL SPECIFICATION (TS) 3.7.19, "SAFETY CHILLED WATER" Executive Summary The following items describe the supplemental changes to the original LAR submittal based on information discussed during a public teleconference on July 7, 2020 between the Licensee (Vistra Operations Company LLC (Vistra Op Co)) and the Nuclear Regulatory Commission, including subsequent clarifying information.

1.

Section 2.4 of the original Enclosure was revised to reference the correct docketed correspondence tracking number. The original submittal was made under docketed correspondence TXX-20039. The attached Section 2.4 replaces that section in the original submittal in its entirety with the current docketed correspondence tracking number of TXX-20056. This change is made to be consistent with the information found in Attachment 3, Technical Specifications and Bases.

2.

The original Attachment 2, Regulatory Commitment Number 5900444 Implemented during Unit 2 Safety Chilled Water extended COMPLETION TIME was revised to include the following as the eighth committed action; "Loss of both safety chilled water trains probability due to extending the single train inoperable COMPLETION TIME from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3 days) to 7 days is small.

Based on the loss of both safety chilled water trains as a possibility, CPNPP will stage alternate cooling equipment (blowers and ducting) outside of the following rooms; CCW Pump 2-01 room CCP 2-01 room MDAFWP 2-01 room SIP 2-01 room Containment Spray Pumps 2-01 and 2-03 room (both pumps are in the same room and a blower for each pump motor will be staged)

RHR Pump 2-01 room The SFP Cooling Water Pump and Heat Exchanger room coolers will be aligned to Unit 1."

3.

The original Attachment 3, Technical Specifications and Bases was revised to refer to Regulatory Commitment 5900444 (Attachment 2 to TXX-20056) in docketed correspondence TXX-20056 vice the original license amendment request docketed correspondence (TXX-20039).

The attached documents replace Attachment 2 and Attachment 3 in their entirety.

Enclosure to TXX-20056 Page 6 of 29 2.4 Description of Proposed Change The proposed change will add an OR logic connector after REQUIRED ACTION A.1 and the following REQUIRED ACTION A.2 and COMPLETION TIME; OR A. 2

NOTE-----------------------------

Req u ired Action A.2 is applicable on a one time basis to replace Safety Chiller 2-06 (Train B) compressor during Unit 2 Cycle

19. If Train A safety chilled water becomes inoperable, immediately enter LCO 3.0.3. Regulatory Commitment 5900444 (Attachment 2 to TXX-20056) will be implemented during the 7 day COMPLETION TIME.

Restore safety chilled water train to OPERABLE status.

See Attachment 3 for Technical Specification 3. 7.19 markup.

7 days The proposed change to Technical Specification Bases for TS 3.7.19, Safety Chilled Water is provided "for information only." The new REQUIRED ACTION A.2 information is added as follows; A.2 The completion time for restoring the inoperable safety chilled water train to OPERABLE status can be extended to 7 days, on a one-time basis for Safety Chiller 2-06 (Train B) compressor replacement during Unit 2 Cycle 19. This one-time change regains reliability margin for Unit 2, Train B safety chilled water. The 7 day completion time for action A.2 is based on a deterministic evaluation supplemented with risk insights.

See Attachment 3 for Technical Specification Bases markup.

The retyped pages for the proposed change to Technical Specification, 3.7.19, Safety Chilled Water are provided for review.

See Attachment 3 for Technical Specification 3.7.19, Safety Chilled Water retyped.

The retyped pages for the proposed change to Technical Specification Bases, 3. 7.19, Safety Chilled Water are provided "for information only."

See Attachment 3 for the associated Technical Specification Bases retyped.

to TXX-20056 Page 1of4 to TXX-20056 Regulatory Commitment Number 5900444 Implemented during Unit 2 Safety Chilled Water extended COMPLETION TIME to TXX-20056 Page 2 of 4 Regulatory Commitment Number 5900444 Implemented during Unit 2 Safety Chilled Water extended 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 extended CT.

This risk reduction measure was selected based on the reliance on offsite power during the extended CT. The measure is selected 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," (Reference 6.27) has sole authority to grant access to the switchyard. 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 or response to abnormal or emergency conditions.

2.

The following applies to Unit 2. The EDGs, APGs, TDAFWP, inservice startup transformers, CCWPs, and SSWPs will have ALL testing and maintenance activities suspended (except for those required to restore equipment from any ongoing maintenance activity) for the duration of the safety chilled water extended 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 on Train A equipment in service or in standby; safety chiller and recirculation pump, CCW pump, CCP, SIP, RHR pump, Containment Spray pumps (two per train), and both trains of Spent Fuel Pool Cooling pumps, 6.9kV Safeguards electrical switchgear and UPS HVAC, noting the restriction of testing and maintenance.

These risk reduction measures ensure continued availability of these components for the entire duration of the extended CT.

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 as a Risk Management Action (RMA). The Fire Areas of Concern are the areas that credit the affected safety chiller for achieving FSS.

4.

For Risk Mitigation Both Unit 1 and 2 Transient Combustible safe zones identified in the fire assessment, in the Main Control Room (MGR) and the Cable Spread Room (CSR) and the cable routing paths for the inservice startup transformers will have additional restrictions relating to combustible storage during the extended CT.

Implementing this RMA will reduce the fire risks that were identified for the transient combustible scenarios in the fire analysis.

to TXX-20056 Page 3 of 4 All hot work activities along the routing associated with power and control cabling for inservice startup transformers, in the MCR and the CSR will be suspended during the extended CT. This RMA reduces the risks associated with fires that could damage and thus disable the station transformer cabling.

An hourly roving fire watch will be in effect to protect areas credited by the fire assessment, specifically, the MCR and CSR (to minimize the exposure time for detection and suppression of potential fires) and areas containing power and control cabling of the inservice startup transformers (to minimize loss of offsite power).

5.

Safety Chiller compressor replacement will not be started if severe weather conditions are anticipated.

6.

Safety Chiller compressor replacement will not be started if grid instability conditions are anticipated.

If the grid becomes unstable in accordance with ABN-601, Response to a 138/345 KV System Malfunction" (Reference 6.24) after entry into TS 3.7.19 proposed REQUIRED ACTION A.2, and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> have elapsed then exit TS 3.7.19 proposed REQUIRED ACTION A.2 and enter TS 3.7.19 REQUIRED ACTION B.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 3.7.19 REQUIRED ACTION B.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 />).

Once grid stability is restored and plant system statuses are verified, TS 3.7.19 REQUIRED ACTIONs B.1 and B.2 will be exited and TS 3.7.19 proposed REQUIRED ACTION A.2 will be re-entered and Safety Chiller 2-06 compressor replacement will continue until completed or 7 days from initial entry into TS 3.7.19 proposed REQUIRED ACTION A.2.

For example:

TS 3.7.19 proposed REQUIRED ACTION A.2 is entered and Safety Chiller 2-06 compressor replacement begins.

73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> after entering TS 3.7.19 proposed REQUIRED ACTION A.2 the ERGOT grid becomes unstable due to degraded voltage or fluctuating frequency.

At that 73 hour8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> point TS 3. 7.19 proposed REQUIRED ACTION A.2 is exited and TS 3.7.19 REQUIRED ACTIONs B.1 and B.2 are entered.

One hour after exit from TS 3. 7.19 proposed REQUIRED ACTION A.2 and entry into TS 3.7.19 REQUIRED ACTIONs B.1 and B.2, the ERGOT grid voltage and frequency are restored with no anticipated instabilities.

TS 3.7.19 REQUIRED ACTIONs B.1 and B.2 are exited and TS 3.7.19 proposed REQUIRED ACTION A.2 is re-entered and safety chiller compressor to TXX-20056 Page 4 of 4 replacement will continue until completed or 7 days from initial entry into TS 3.7.19 proposed REQUIRED ACTION A.2.

7.

Prior to entry into TS 3.7.19 REQUIRED ACTION A.2, CPNPP will contact the Transmission Grid Controller (TGM) to ensure:

the local grid is stable and no anticipated challenges have been identified Prior to entry into TS 3.7.19 REQUIRED ACTION A.2, CPNPP will verify the following items and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. If any of the following items are not met, and after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> have elapsed CPNPP will exit TS 3.7.19 REQUIRED ACTIONS A.2 and enter TS 3.7.19 REQUIRED ACTIONS B.1 and B.2:

a. Both offsite sources available as determined by performance of OPT-215-1, "Offsite Transmission Network Operability Data Sheet"
b. Affected 6.9kV bus steady state frequency is 59.5 - 60.5 Hz in accordance with ABN-602, Response to a 6900/480V System Malfunction (Reference 6.25)
c. The 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 (Train A) Emergency Diesel Generator For example:

Similar to the example described in grid instability above, if TS 3. 7.19 REQUIRED ACTIONS B.1 and B.2 are entered due to an item (a, b, c, or d) above not being met and the items are subsequently met, then TS 3.7.19 REQUIRED ACTIONs B.1 and B.2 will be exited and TS 3.7.19 proposed REQUIRED ACTION A.2 will be re-entered and safety chiller compressor replacement will continue until completed or 7 days from initial entry into TS 3.7.19 proposed REQUIRED ACTION A.2.

8.

Loss of both safety chilled water trains probability due to extending the single train inoperable COMPLETION TIME from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3 days) to 7 days is small.

Based on the loss of both safety chilled water trains as a possibility CPNPP will stage alternate cooling equipment (blowers and ducting) outside of the following rooms; CCW Pump 2-01 room CCP 2-01 room MDAFWP 2-01 room SIP 2-01 room Containment Spray Pumps 2-01 and 2-03 room (both pumps are in the same room and a blower for each pump motor will be staged)

RHR Pump 2-01 room The SFP Cooling Water Pump and Heat Exchanger room coolers will be aligned to Unit 1.

to TXX-20056 Page 1 of 14 to TXX-20056 Technical Specifications Technical Specification 3. 7.19, Safety Chilled Water - Markup Technical Specification 3.7.19, Safety Chilled Water - Retype Technical Specifications Bases (For Information Only)

Technical Specification Bases 3.7.19, Safety Chilled Water - Markup Technical Specification Bases 3.7.19, Safety Chilled Water - Retype

INSE to TXX-20056 Page 2of14 3.7 PLANT SYSTEMS 3.7.19 Safety Chilled Water LCO 3.7.19 Two safety chilled water trains shall be OPERABLE APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A. One safety chilled water A.1 Restore safety chilled water train to train inoperable.

OPERABLE status.

RTA B. Required Action and B.1 Be in MODE 3.

associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5.

Safety Chilled Water 3.7.19 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 6 hours 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 3.7-45 Amendment No. +w, 4-a.e, 162 to TXX-20056 Page 3of14 SURVEILLANCE REQUIREMENTS SR 3.7.19.1 SR 3.7.19.2 SURVEILLANCE

N 0 TE-----------------------------------

1 so I ati on of safety chilled water flow to individual components does not render the safety chilled water system inoperable.

Verify each safety chilled water manual, power operated, and automatic valve servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Verify each safety chilled water pump and chiller starts on an actual or simulated actuation signal.

Safety Chilled Water 3.7.19 FREQUENCY In accordance with the Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

COMANCHE PEAK - UNITS 1 AND 2 3.7-46 Amendment No. 4-aQ.; 4ee, 162 to TXX-20056 Page 4 of 14 INSERT A OR A. 2

N 0 TE--------------------------

Req u ired Action A.2 is applicable on a one time basis to replace Safety Chiller 2-06 (Train B) compressor during Unit 2 Cycle 19. If Train A safety chilled water becomes inoperable, immediately enter LCO 3.0.3. Regulatory Commitment 5900444 (Attachment 2 to TXX-20056) will be implemented during the 7 day COMPLETION TIME.

Restore safety chilled water train to OPERABLE status.

7 days to TXX-20056 Page 5of14 3.7 PLANT SYSTEMS

3. 7.19 Safety Chilled Water LCO 3.7.19 Two safety chilled water trains shall be OPERABLE APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A. One safety chilled water A.1 Restore safety chilled water train to train inoperable.

OPERABLE status.

OR A. 2 -----------------NOTE---------------------

Required Action A.2 is applicable on a one time basis to replace Safety Chiller 2-06 (Train B) compressor during Unit 2 Cycle 19.

If Train A safety chilled water becomes inoperable, immediately enter LCO 3.0.3. Regulatory Commitment 5900444 (Attachment 2 to TXX-20056) will be implemented during the 7 day COMPLETION TIME.

Restore safety chilled water train to OPERABLE status.

B. Required Action and B.1 Be in MODE 3.

associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5.

Safety Chilled Water 3.7.19 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 7 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours COMANCHE PEAK - UNITS 1 AND 2 3.7-45 Amendment No. 156, 162 to TXX-20056 Page 6of14 SURVEILLANCE REQUIREMENTS SR 3.7.19.1 SR 3.7.19.2 SURVEILLANCE

NOTE-----------------------------------

lsolation of safety chilled water flow to individual components does not render the safety chilled water system inoperable.

Verify each safety chilled water manual, power operated, and automatic valve servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Verify each safety chilled water pump and chiller starts on an actual or simulated actuation signal.

Safety Chilled Water 3.7.19 FREQUENCY In accordance with the Surveillance Frequency Control Program.

In accordance with the Surveillance Frequency Control Program.

COMANCHE PEAK - UNITS 1 AND 2 3.7-46 Amendment No. 156, 162 to TXX-20056 Page 7of14 Safety Chilled Water System B3.7.19 B 3. 7 PLANT SYSTEMS B 3.7.19 Safety Chilled Water System BASES BACKGROUND APPLICABLE SAFETY ANALYSES The Safety Chilled Water System provides essential chilled water to the emergency fan coil units (EFCUs) during normal and accident conditions.

EFCUs are provided in motor-driven ESF pump rooms (i.e., Centrifugal Charging Pump rooms, Safety Injection Pump rooms, Residual Heat Removal (RHR) Pump rooms, Containment Spray Pump rooms, and the motor-driven Auxiliary Feedwater (AFW) Pump rooms), in the Spent Fuel Pool Cooling Pump rooms, in the Component Cooling Water (CCW) Pump rooms, in the UPS Rooms, and in the Class 1 E electrical switchgear rooms.

The system is designed to provide chilled water to maintain the ambient air temperature within the design limits of the essential equipment served by the system.

The safety related equipment and respective EFCUs are of the same safety train as the associated chilled water train. Thus, a power failure or other single failure to one cooling system train will not prevent the cooling of redundant equipment in the other train.

The Safety Chilled Water System for each unit consists of two separate and completely redundant safety trains. Each train consists of one packaged centrifugal chiller, one centrifugal chilled water recirculation pump, interconnecting piping, valves, controls and instrumentation. There are no automatic valves in the system. Additionally, the two trains share a common chilled water surge (expansion) tank, partitioned in the middle into two separate compartments to provide complete separation of the two trains, that function to ensure sufficient net positive suction head is available.

In addition to manual start capability, automatic start of the Safety Chill Water System is provided on a Safety Injection (SI) signal or a station blackout.

The Safety Chilled Water System is seismic Category I and remains operational during and after a safe shutdown earthquake. The associated instrumentation is described in greater detail in FSAR Sections, 7.3 and 9.4, References 1 and 2 respectively.

The design basis of the Safety Chilled Water System is to support EFCUs that maintain air temperatures as required in selected rooms containing safety-related equipment during normal operation and during and after a design basis accident (with or without a loss of offsite power) or a blackout (loss of offsite power, LOOP).

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-83 Revision73 to TXX-20056 Page 8of14 Safety Chilled Water System B3.7.19 BASES APPLICABLE SAFETY ANALYSES (continued)

LCO APPLICABILITY ACTIONS The Safety Chilled Water System is designed to perform its function in response to an SI signal with a single failure of any active component, assuming the loss of offsite power. One train of the Safety Chilled Water System provides 100% of the required cooling for the associated train of EFCUs.

The Safety Chilled Water System satisfies criterion 4 of 1 OCFR50.36(c)(2)(ii).

Two Safety Chilled Water System trains are required OPERABLE to provide the required redundancy to ensure that the system functions to remove heat from the EFCUs during and after an accident assuming the worst case single failure occurs coincident with the loss of offsite power.

A Safety Chilled Water System train is considered OPERABLE when the associated chiller, chilled water pump, surge tank, piping, valves, and instrumentation required to perform the safety-related function are OPERABLE.

The isolation of Safety Chilled Water from the EFCUs may render those units inoperable but does not affect the OPERABILITY of the Safety Chilled Water System.

In MODES 1, 2, 3, and 4 the Safety Chilled Water System is a normally operating system, which must be prepared to provide a safety-related cooling function consistent with the OPERABILITY requirements of the essential equipment it supports.

In MODE 5 or 6, the OPERABILITY requirements of the Safety Chilled Water System are determined by the systems it supports.

A. 1 If one Safety Chilled Water System train is inoperable, action must be taken to restore the train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining OPERABLE Safety Chilled Water System train is adequate to perform the heat removal function for its associated essential equipment.

However, the overall reliability is reduced because a single failure in the (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-84 Revision73 to TXX-20056 Page 9of14 Safety Chilled Water System B 3.7.19 BASES ACTIONS INSERT B

)

SURVEILLANCE REQUIREMENTS A. 1 (continued)

OPERABLE Safety Chilled Water System train could result in loss of the Safety Chilled Water System function. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a OBA occurring during this time.

B.1 and B.2 If the Safety Chilled Water System train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SR 3.7.19.1 This SR is modified by a Note indicating that the isolation of safety chilled water flow to individual components may render these components inoperable but does not affect the OPERABILITY of safety chilled water system.

Verifying the correct alignment for manual valves servicing safety-related equipment provides assurance that the proper flow paths exist for Safety Chilled Water System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to being locked, sealed, or secured. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.19.2 This SR verifies proper operation of the Safety Chilled Water System fans and pumps on an actual or simulated Safety Injection actuation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-85 Revision73 to TXX-20056 Page 10of14 BASES (continued)

REFERENCES

1.

FSAR, Section 7.3.

2.

FSAR, Section 9.4.

INSERT B A.2 Safety Chilled Water System B3.7.19 The COMPLETION TIME for restoring the inoperable safety chilled water train to OPERABLE status can be extended to 7 days, on a one time basis for Safety Chiller 2-06 (Train B) compressor replacement during Unit 2 Cycle 19. This one time change regains reliability margin for Unit 2, Train B safety chilled water. The 7 day completion time for action A.2 is based on a deterministic evaluation supplemented with risk insights.

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-86 Revision73 to TXX-20056 Page 11of14 Safety Chilled Water System B 3.7.19 B 3.7 PLANT SYSTEMS B 3.7.19 Safety Chilled Water System BASES BACKGROUND APPLICABLE SAFETY ANALYSES The Safety Chilled Water System provides essential chilled water to the emergency fan coil units (EFCUs) during normal and accident conditions.

EFCUs are provided in motor-driven ESF pump rooms (i.e., Centrifugal Charging Pump rooms, Safety Injection Pump rooms, Residual Heat Removal (RHR) Pump rooms, Containment Spray Pump rooms, and the motor-driven Auxiliary Feedwater (AFW) Pump rooms), in the Spent Fuel Pool Cooling Pump rooms, in the Component Cooling Water (CCW) Pump rooms, in the UPS Rooms, and in the Class 1 E electrical switchgear rooms.

The system is designed to provide chilled water to maintain the ambient air temperature within the design limits of the essential equipment served by the system.

The safety related equipment and respective EFCUs are of the same safety train as the associated chilled water train. Thus, a power failure or other single failure to one cooling system train will not prevent the cooling of redundant equipment in the other train.

The Safety Chilled Water System for each unit consists of two separate and completely redundant safety trains. Each train consists of one packaged centrifugal chiller, one centrifugal chilled water recirculation pump, interconnecting piping, valves, controls and instrumentation. There are no automatic valves in the system. Additionally, the two trains share a common chilled water surge (expansion) tank, partitioned in the middle into two separate compartments to provide complete separation of the two trains, that function to ensure sufficient net positive suction head is available.

In addition to manual start capability, automatic start of the Safety Chill Water System is provided on a Safety Injection (SI) signal or a station blackout.

The Safety Chilled Water System is seismic Category I and remains operational during and after a safe shutdown earthquake. The associated instrumentation is described in greater detail in FSAR Sections, 7.3 and 9.4, References 1 and 2 respectively.

The design basis of the Safety Chilled Water System is to support EFCUs that maintain air temperatures as required in selected rooms containing safety-related equipment during normal operation and during and after a design basis accident (with or without a loss of offsite power) or a blackout (loss of offsite power, LOOP).

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-83 Revision73 to TXX-20056 Page 12of14 Safety Chilled Water System B3.7.19 BASES APPLICABLE SAFETY ANALYSES (continued)

LCO APPLICABILITY ACTIONS The Safety Chilled Water System is designed to perform its function in response to an SI signal with a single failure of any active component, assuming the loss of offsite power. One train of the Safety Chilled Water System provides 100% of the required cooling for the associated train of EFCUs.

The Safety Chilled Water System satisfies criterion 4 of 1 OCFR50.36(c)(2)(ii).

Two Safety Chilled Water System trains are required OPERABLE to provide the required redundancy to ensure that the system functions to remove heat from the EFCUs during and after an accident assuming the worst case single failure occurs coincident with the loss of offsite power.

A Safety Chilled Water System train is considered OPERABLE when the associated chiller, chilled water pump, surge tank, piping, valves, and instrumentation required to perform the safety-related function are OPERABLE.

The isolation of Safety Chilled Water from the EFCUs may render those units inoperable but does not affect the OPERABILITY of the Safety Chilled Water System.

In MODES 1, 2, 3, and 4 the Safety Chilled Water System is a normally operating system, which must be prepared to provide a safety-related cooling function consistent with the OPERABILITY requirements of the essential equipment it supports.

In MODE 5 or6, the OPERABILITY requirements of the Safety Chilled Water System are determined by the systems it supports.

If one Safety Chilled Water System train is inoperable, action must be taken to restore the train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining OPERABLE Safety Chilled Water System train is adequate to perform the heat removal function for its associated essential equipment.

However, the overall reliability is reduced because a single failure in the (continued)

COMANCHE PEAK-UNITS 1 AND 2 B 3.7-84 Revision73 to TXX-20056 Page 13of14 Safety Chilled Water System B 3.7.19 BASES ACTIONS SURVEILLANCE REQUIREMENTS

&.1_( continued)

OPERABLE Safety Chilled Water System train could result in loss of the Safety Chilled Water System function. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a OBA occurring during this time.

A.2 The COMPLETION TIME for restoring the inoperable safety chilled water train to OPERABLE status can be extended to 7 days, on a one time basis for Safety Chiller 2-06 (Train B) compressor replacement during Unit 2 Cycle 19. This one time change regains reliability margin for Unit 2, Train B safety chilled water. The 7 day completion time for action A.2 is based on a deterministic evaluation supplemented with risk insights.

B.1 and B.2 If the Safety Chilled Water System train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SR 3.7.19.1 This SR is modified by a Note indicating that the isolation of safety chilled water flow to individual components may render these components inoperable but does not affect the OPERABILITY of safety chilled water system.

Verifying the correct alignment for manual valves servicing safety-related equipment provides assurance that the proper flow paths exist for Safety Chilled Water System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to being locked, sealed, or secured. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

COMANCHE PEAK-UNITS 1 AND 2 B 3.7-85 Revision73 to TXX-20056 Page 14 of 14 Safety Chilled Water System 83.7.19 BASES (continued)

REFERENCES SR 3.7.19.2 This SR verifies proper operation of the Safety Chilled Water System fans and pumps on an actual or simulated Safety Injection actuation signal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

FSAR, Section 7.3.

2.

FSAR, Section 9.4.

COMANCHE PEAK - UNITS 1 AND 2 B 3.7-86 Revision73

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