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*9 Power TXU Power Comanche Peak Steam Elecric Station P.O. Box 1002 (E01) Glen Rose, TX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mike.blevins txu.com Mike Blevins Senior Vice President & Chief Nuclear Offleer Ref: #IOCFR50.59 CPSES-200501587 Log # TXX-05140 August 2, 2005 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) DOCKET NOS. 50-445 AND 50446 1OCFR50.59 EVALUATION SUMMARY REPORT 0012 AND COMMITMENT MATERIAL CHANGE EVALUATION REPORT 0006 Gentlemen: Please find attached (Attachment 1) the report required by 1 OCFR50.59(b)(2) for those activities which were completed or partially completed at CPSES Units I and 2 between August 3,2003, and February 1, 2005, and which were not reported to the NRC in a previous submittal. This report contains a brief description of the changes, tests and experiments implemented or performed pursuant to 1 OCFR50.59(a), including a summary of the evaluations for each. Items in this report are referenced by their 1 OCFR50.59 Evaluation Numbers. This report also includes certain activities completed or partially completed after February 1,2005. Attachment 2 is the CPSES Units I and 2 report (Commitment Material Change Evaluation Report 0006) per the recommendations of NRC document SECY-95-300, "Guidelines for Managing NRC Commitments." The tracking document for this process at CPSES is the "Commitment Material Change Evaluation (CMCE)" which identifies the affected commitments and origin, original criteria, proposed changes and the justifications for the changes. This report pertains to commitment material changes (in docketed correspondences) which require reporting between August 3, 2003 and February 1, 2005, which were not addressed in the 1 OCFR50.59 evaluations. =E V-t1 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance - -1) (O -a> -( Callaway * Comanche Peak * Diablo Canyon * Palo Verde * South Texas Project * Wolf Creek
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Page 1: Comanche Peak Steam Electric Station, 1OCFR50.59 Evaluation … · 2012-11-20 · compressor 2-02 is controlled by a Elektronikon MKIV-III digital regulator, which starts, stops,

*9 Power

TXU PowerComanche Peak SteamElecric StationP.O. Box 1002 (E01)Glen Rose, TX 76043Tel: 254 897 5209Fax: 254 897 6652mike.blevins txu.com

Mike BlevinsSenior Vice President &Chief Nuclear Offleer

Ref: #IOCFR50.59

CPSES-200501587Log # TXX-05140

August 2, 2005

U. S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)DOCKET NOS. 50-445 AND 504461OCFR50.59 EVALUATION SUMMARY REPORT 0012 ANDCOMMITMENT MATERIAL CHANGE EVALUATIONREPORT 0006

Gentlemen:

Please find attached (Attachment 1) the report required by 1 OCFR50.59(b)(2) for thoseactivities which were completed or partially completed at CPSES Units I and 2between August 3,2003, and February 1, 2005, and which were not reported to theNRC in a previous submittal. This report contains a brief description of the changes,tests and experiments implemented or performed pursuant to 1 OCFR50.59(a),including a summary of the evaluations for each. Items in this report are referenced bytheir 1 OCFR50.59 Evaluation Numbers. This report also includes certain activitiescompleted or partially completed after February 1,2005.

Attachment 2 is the CPSES Units I and 2 report (Commitment Material ChangeEvaluation Report 0006) per the recommendations of NRC document SECY-95-300,"Guidelines for Managing NRC Commitments." The tracking document for thisprocess at CPSES is the "Commitment Material Change Evaluation (CMCE)" whichidentifies the affected commitments and origin, original criteria, proposed changes andthe justifications for the changes. This report pertains to commitment materialchanges (in docketed correspondences) which require reporting between August 3,2003 and February 1, 2005, which were not addressed in the 1 OCFR50.59 evaluations.

=E V-t1A member of the STARS (Strategic Teaming and Resource Sharing) Alliance --1) (O -a> -(�

Callaway * Comanche Peak * Diablo Canyon * Palo Verde * South Texas Project * Wolf Creek

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TXX-05140Page 2 of 2

This communication contains no new licensing basis commitments regarding CPSESUnits 1 and 2. Should you have any questions, please contact Mr. J. D. Seawright at(254) 897-0140.

Sincerely,

TXU Generation Company LP

By: TXU Generation Management Company LLCIts General Partner

Mike Blevins

By: 4if7X/PredW. Madden

Director, Regulatory Affairs

JDSAttachments: 1) IOCFR50.59 Evaluations

2) Commitment Material Change Evaluations

c - B. S. Mallett, Region IVM. C. Thadani, NRRResident Inspectors, CPSES

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ATTACHMENT 1 TO TXX-05140Page 1 of 12

1OCFR50.59 Evaluations

59EV-2001-000158-01-0059EV-2001-000158-02-0059EV-2001-000158-03-0059EV-2001-001255-01-0159EV-2001-001255-02-0059EV-2001-001672-02-0159EV-2002-000100-01-0059EV-2002-001911-01-00

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Attachment 1 to TXX-05140Page2 ofl2

Evaluation Number: 59EV-2001-000158-01-00 Unit: CommonRevision 0

Activity Description:This evaluation covers the analog-to-digital replacement of obsolete Instrument Air Compressor

CPX-CICACO-01 and installation of new Instrument Air Dryer CPX-CIDYIA-01. New aircompressor CPX-CICACO-01 is controlled by a Elektronikon MKIV-III digital regulator, whichstarts, stops, loads, unloads and monitors the compressor, and is used as a diagnostic tool whentroubleshooting. Alarm and shutdown setpoints are programmed using the regulator.

New dryer CPX-CIDYIA-01 is controlled by the Advanced Dryer Controller (ADC) system,which controls drying and regeneration, and monitors the dryer, and is used as a diagnostic toolwhen troubleshooting.

Summary of Evaluation:Per FSAR Section 9.3.1, the Instrument Air System is designed to provide a reliable supply ofclean, dry, oil-free air of suitable quality and pressure for pneumatic instruments and controlsand pneumatically operated valves for normal plant operation. The Instrument Air System servesno safety function because it is not required to achieve safe shutdown or to mitigate theconsequences of a DBA.

Digital controllers, provided with the new compressor and new dyer, perform the same functionsas the current analog systems on existing equipment. NEI 01-01, Appendix A guidance is usedto determine potential adverse impact of critical aspects of the digital controls. From thisguidance it can be concluded there is no decrease in reliability of design functions; operatorburden is not increased; EMI, seismic, ventilation, and electrical issues associated with overalldesign do not adversely impact existing SSCs; cyber security sabotage is not a credible concern;no fundamental HSI changes result from this design; failure modes, including common modefailures, remain unchanged; and loss or degradation of electrical power does not result in adverseconsequences.

This evaluation concludes there are no new accidents or malfunctions created by thismodification. Prior NRC approval is not required for this proposed plant activity.

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Attachment 1 to TXX-05 140Page 3 of 12

Evaluation Number: 59EV-2001-000158-02-00 Unit: CommonRevision 0

Activity Description:This evaluation covers the analog-to-digital replacement of the common instrument aircompressor X-02, and analog-to-digital replacement of the common X-02 instrument air dryer.New air compressor X-02 is controlled by a Elektronikon MKIV-III digital regulator, whichstarts, stops, loads, unloads and monitors the compressor, and is used as a diagnostic tool whentroubleshooting. Alarm and shutdown setpoints are programmed using the regulator.

New dryer X-02 is controlled by the Advanced Dryer Controller (ADC) system, which controlsdrying and regeneration, and monitors the dryer, and is also used as a diagnostic tool whentroubleshooting.

There are no Main Control Board components impacted by this activity.

Summary of Evaluation:Per FSAR Section 9.3.1, the Instrument Air System is designed to provide a reliable supply ofclean, dry, oil-free air of suitable quality and pressure for pneumatic instruments and controlsand pneumatically operated valves for normal plant operation. The Instrument Air System servesno safety function because it is not required to achieve safe shutdown or to mitigate theconsequences of a DBA.

Digital controllers, provided with the new compressor and new dyer, perform the same functionsas the current analog systems on existing equipment. NEI 01-01, Appendix A guidance is used todetermine potential adverse impact of critical aspects of the digital controls. CPSES hasconcluded that there is no decrease in reliability of design functions. EMI, seismic, ventilation,and electrical issues associated with overall design do not adversely impact existing SSCs.Cyber security sabotage is not a credible concern; no fundamental HSI changes result from thisdesign and operator burden is not increased; failure modes, including common mode failures,remain unchanged; and loss or degradation of electrical power does not result in adverseconsequences.

The Human System Interface (HSI) has been properly addressed through design and testing ofthe compressor controller, procedure development, and Operator training. SystemSoftware/Hardware attributes have been properly addressed through engineering evaluation,design, and testing in accordance with industry guidelines to ensure safe and reliable systemoperation.

This evaluation concludes there are no new accidents, failure modes, or malfunctions created bythis modification. Therefore, prior NRC approval is not required for this modification activity.

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Attachment 1 to TXX-05140Page 4 of 12

Evaluation Number: 59EV-2001-000158-03-00 Unit: 2Revision 0

Activity Description:This evaluation covers the analog-to-digital replacement of the control and monitoring systemfor the Unit 2 instrument air compressor 2-02, and the Unit 2 instrument air dryer 2-02. New aircompressor 2-02 is controlled by a Elektronikon MKIV-III digital regulator, which starts, stops,loads, unloads and monitors the compressor, and is used as a diagnostic tool whentroubleshooting. Alarm and shutdown setpoints are programmed using the regulator.

New dryer 2-02 is controlled by the Advanced Dryer Controller (ADC) system, which controlsdrying and regeneration, and monitors the dryer, and is also used as a diagnostic tool whentroubleshooting.

There are no Main Control Board components impacted by this activity and the compressor anddryer operation from the Control Room remains unchanged.

Summary of Evaluation:Per FSAR Section 9.3.1, the Instrument Air System is designed to provide a reliable supply ofclean, dry, oil-free air of suitable quality and pressure for pneumatic instruments and controlsand pneumatically operated valves for normal plant operation. The Instrument Air System is notrequired to achieve safe shutdown or to mitigate the consequences of a DBA.

Digital controllers, provided with the new compressor and new dryer, perform the samefunctions as the current analog systems on existing equipment. NEI 01-01, Appendix A guidanceis used to determine potential adverse impact of critical aspects of the digital controls. From thisguidance it can be concluded there is no decrease in reliability of design functions; EMI, seismic,ventilation, and electrical issues associated with overall design do not adversely impact existingSSCs; cyber security sabotage is not a credible concern; no fundamental Human SystemInterface (HSI) changes result from this design and operator burden is not increased; failuremodes, including common mode failures, remain unchanged; and loss or degradation ofelectrical power does not result in adverse consequences.

This evaluation concludes there are no new accidents, failure modes or malfunctions created bythis modification. Prior NRC approval is not required for this proposed plant activity.

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Attachment 1 to TXX-05 140Page 5 of 12

Evaluation Number: 59EV-2001-001255-01-01 Unit: 1Revision I

Activity Description:This evaluation covers the analog-to-digital upgrade of the replacement of the diesel generatorvoltage regulator/exciter provided by Siemens/Framatome. The new exciter/voltage regulatoruses Siemens' proprietary THYRIPART equipment and software.

The principal digital component is the Automatic Voltage Regulator (AVR), a Masterdrivedigital control system which improves THYRIPART regulation by producing a digitally-controlled single-phase zero frequency (DC) output. This DC output boosts the field current asrequired to provide +0.5 percent Diesel Generator voltage regulation. Components of this digitalcontrol system are:(1) Control Board, the brains of the AVR which contains the parameter set for control functionsand fault diagnostics.(2) Operator control panel displays, parameter numbers and values on a LED screen (able toscroll the screen and change parameters with a keypad).(3) Technology Board which implements the software for open-loop and closed-loop control.(Functional logic can be changed by software, and parameters can be changed from the operatorcontrol panel or software.)(4) Serial communications unit which consists of a Serial Communications Board in the AVRand two remote input/output units (provides interface for digital inputs and outputs fromthroughout the THYRIPART with the AVR.)

A second digital component is the Siprotec multifunctional relay. The function of this relay isnonsafety-related since the relay trip function is disconnected, by a non-digital safety-relateddevice, when a diesel generator emergency start signal is received.

Summary of Evaluation:The new upgraded THYRIPART DG field excitation unit serves the same function as theexisting analog system. During normal operation, the AVR has two independent closed-loopcontrol systems, the automatic channel which contains the automatic voltage control, thePFNAR control and all limiters; and the manual channel which provides manual adjustment offield current directly from the control room if the automatic channel mode experiences trouble.

Only one closed-loop control system is in operation at any one time, usually the automaticchannel.

The failures of the AVR to control the steady state voltage within specification, i.e., design basisrequirements, are sensed by an external non-digital failure monitoring device. If DieselGenerator steady state voltage goes outside the desired limits or other significant faults occurwhich results in the Diesel Generator voltage approaching the Technical Specification limits, anon-digital safety-related voltage monitoring device will disconnect the AVR before the voltagegoes outside the tolerance range. This non-digital safety-related voltage monitoring device islocated within the THYRIPART but external to the AVR and will disconnect the AVR via the

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Attachment 1 to TXX-05140Page 6 of 12

K604 contactor before the voltage goes outside the tolerance range of 6480V to 7150V with atime delay consistent with Technical Specifications requirements to allow for expectedtransients.

The THYRIPART magnetics then maintains the Diesel Generator steady state voltage within theTechnical Specification limits. In this condition, the Diesel Generator continues to meetRegulatory requirements and requirements of the Chapter 15 accident analysis.

Another digital component is a multifunction generator protective relay to provide dieselgenerator non-safety related protection, replacing existing electromechanical relays. This deviceis Class IE because of its association with Class IE wiring/power source. It remains connected topower at all times, but like the existing relays, its diesel generator trip functions are disconnectedby an Emergency Start/Run signal, in accordance with FSAR Section 8.3.1.1.11. Relay function,provided by software/firmware, is non-safety related.

Human-System Interface is through handswitches, meters and indicators, which are similar toexisting components. There are no Video Display Unit screen displays. Both operator controlpanel and the multifunction generator protective relay have LED screens which displayparameters and functions, and are scrolled by a keypad. No fundamental HSI changes resultfrom this design.

There are no new accidents, failure modes, or malfunctions created by this change. Prior NRCapproval is not required for this proposed plant activity.

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Attachment 1 to TXX-05140Page 7 of 12

Evaluation Number: 59EV-2001-001255-02-00 Unit: 2Revision 0

Activity Description:This evaluation covers the analog-to-digital upgrade of the replacement of the diesel generatorvoltage regulator/exciter provided by Siemens/Framatome. The new exciter/voltage regulatoruses Siemens' proprietary THYRIPART equipment and software.

The principal digital component is the Automatic Voltage Regulator (AVR), a Masterdrivedigital control system which improves THYRIPART regulation by producing a digitally-controlled single-phase zero frequency (DC) output. This DC output boosts the field current asrequired to provide +0.5 percent Diesel Generator voltage regulation. Components of this digitalcontrol system are:(I) Control Board, the brains of the AVR which contains the parameter set for control functionsand fault diagnostics. (2) Operator control panel displays, parameter numbers and values on aLED screen (able to scroll the screen and change parameters with a keypad).(3) Technology Board which implements the software for open-loop and closed-loop control.(Functional logic can be changed by software, and parameters can be changed from the operatorcontrol panel or software.)(4) Serial communications unit which consists of a Serial Communications Board in the AVRand two remote input/output units (provides interface for digital inputs and outputs fromthroughout the THYRIPART with the AVR.)

A second digital component is the Siprotec multifunctional relay. The function of this relay isnonsafety-related since the relay trip function is disconnected, by a non-digital safety-relateddevice, when a diesel generator emergency start signal is received.

Summary of Evaluation:The new upgraded THYRIPART DG field excitation unit serves the same function as theexisting analog system. During normal operation, the AVR has two independent closed-loopcontrol systems, the automatic channel which contains the automatic voltage control, thePF/VAR control and all limiters; and the manual channel which provides manual adjustment offield current directly from the control room if the automatic channel mode experiences trouble.

Only one closed-loop control system is in operation at any one time, usually the automaticchannel.

The failures of the AVR to control the steady state voltage within specification, i.e., design basisrequirements, are sensed by an external non-digital failure monitoring device. If DieselGenerator steady state voltage goes outside the desired limits or other significant faults occurwhich results in the Diesel Generator voltage approaching the Technical Specification limits, anon-digital safety-related voltage monitoring device will disconnect the AVR before the voltagegoes outside the tolerance range. This non-digital safety-related voltage monitoring device islocated within the THYRIPART but external to the AVR and will disconnect the AVR via the

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Attachment I to TXX-05 140Page 8 ofl2

K604 contactor before the voltage goes outside the tolerance range of 6480V to 7150V with atime delay consistent with Technical Specifications requirements to allow for expectedtransients.

The THYRIPART magnetics then maintains the Diesel Generator steady state voltage within theTechnical Specification limits. In this condition, the Diesel Generator continues to meetRegulatory requirements and requirements of the Chapter 15 accident analysis.

Another digital component is a multifunction generator protective relay which provides dieselgenerator non-safety related protection, replacing existing electromechanical relays. This deviceis Class 1 E because of its association with Class 1 E wiring/power source. It remains connected topower at all times, but like the existing relays, its diesel generator trip functions are disconnectedby an Emergency Start/Run signal, in accordance with FSAR Section 8.3.1.1.11. Relay function,provided by software/firmware, is non-safety related.

Human-System Interface (HSI) is through handswitches, meters and indicators, which are similarto existing components. There are no Video Display Unit screen displays. Both operator controlpanel and the multifunction generator protective relay have LED screens which displayparameters and functions, and are scrolled by a keypad. No fundamental HSI changes resultfrom this design.

There are no new accidents, failure modes, or malfunctions created by this change. Prior NRCapproval is not required for this proposed plant activity.

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Attachment 1 to TXX-05140Page 9 of 12

Evaluation Number: 59EV-2001-001672-02-01 Unit: 1Revision 1

Activity Description:This activity comprises the first phase replacement of the selected Turbine-Generator (TG) andTVR analog control systems with a new digital control system supplied by Siemens PowerCorporation/Framatome ANP. This upgrade is required to improve long term TG reliability andto eliminate the obsolescence issues associated with the control systems.

The following Turbine-Generator systems as described in Section 10.2 of the UFSAR will bemigrated to the new digital control system via plant design change activities:

Electro Hydraulic Turbine Controller (EHC)Turbine Stress Evaluator (TSE)Speed Target Unit (STU)Seal Steam Controller (SSC)Generator Temperature Control (GTC)Leakage Water Return Control (LRC)Moisture Separator Reheater (MSR)Thyristor Voltage Regulator (TVR)

The operator interface to the new digital system is via operating and monitoring process controland information system and consists of two redundant computer-based workstations with twoVideo Display Units (VDU) each (total four) in the Control Room. This allows the plant to beoperated, visualized, and monitored centrally. The digital controls consist of dual redundantprocess computers. These computers handle both system control and system monitoring. Allmigrated Turbine-Generator control systems are operated using screen-based soft controls.

All main control board equipment associated with the replaced Turbine-Generator Controlsystems and Generator Exciter Voltage Regulator system (TVR) are removed from the maincontrol board with their functions migrated to the new Operating Monitoring (OM) system. Thisincludes system controls, monitoring of process parameters, and alarm functions. The turbinetrip logic and the control interfaces with the Reactor Protection System (RPS) are not affected bythese design changes.

Summary of Evaluation:The operator impact of operating the Turbine Controls and Generator Thyristor VoltageRegulator from the re-designed control workstation is significant. By definition, digital upgradesare considered adverse by their nature. Its adverse impact is less than minimal. All ControlRoom operator interface devices formerly located on control boards as control switches, analogindicators, alarms, etc., have been replaced with video display terminals, keyboards, and mousedevices located on two consoles in the Control Room. Engineering Evaluations have beenperformed to document acceptability of those critical aspects of these activities as required byindustry regulations and by industry technical guidelines. The Human System Interface (HSI)

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Attachment 1 to TXX-05 140Page 10 of 12

has been properly addressed through design and testing of the Operating Monitoring (OM)Screens, procedure development, and simulator operator training. Access to the control systemthrough the OM station is limited to authorized personnel by the use of access passwords.System Software/Hardware attributes have been properly addressed through engineeringevaluation, design and testing in accordance with industry guidelines to ensure safe and reliablesystem operation.

The new upgraded digital control system for the Turbine-Generator controls and GeneratorExciter Voltage control systems serve the same function as the existing analog systems. Theconsequences of an equipment malfunction are the same as those of the equipment beingreplaced. The reliability of the controls for the affected systems will be increased because of theredundancy in the software, enhancement of the automatic control functions and addedredundant instrumentation. There are no new accidents, failure modes, or malfunctions createdby this change

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Attachment 1 to TXX-05140Page 11 of 12

Evaluation Number: 59EV-2002-000100-01-00 Unit: 1 and 2Revision 0

Activity Description:CPSES was originally licensed based upon a probabilistic missile analysis to demonstrate thatsafety related SSCs are sufficiently protected from postulated turbine generated missiles. Themethodology considered three probabilistic components; namely, PI (probability of occurrenceof ejected turbine missiles per turbine year), P2 (missile strike probability) and P3 (probability ofbarrier penetration and SSC damage due to the strike). The product of these three components,P4, was compared to the NRC limit of 1 E-07 per year to establish the risk of damage to safetyrelated SSCs for a postulated turbine generated missile event. Regulatory Guide 1.115, Revision1 identifies this threshold probability as "... an acceptable risk rate for the loss of an essentialsystem from a single event." A component of these probabilities is the assessment of crackdevelopment and crack propagation in the LP turbine rotor and disks.

A replacement of the methodology used in determining the risk rate of damage to safety relatedSSCs for a postulated turbine generated missile event will be evaluated under this 1 OCFR50.59Evaluation. Although the basic methodology of using P4 = PI*P2*P3 has not changed, thedetermination of these three values has changed as a result of changes within the regulatoryenvironment on the development of the P1 value and the establishment of the P2 and P3 values.In addition, the calculational method for assessing crack development and propagation haschanged. This evaluation will evaluate the adoption of this new methodology for incorporationinto the FSAR. This change in methodology will support a replacement of the LP turbines with anew design of Siemens-Westinghouse LP turbines.

Summary of Evaluation:This I OCFR50.59 Evaluation reviewed the proposed changes in the methodology used for thecalculation of the risk rate for damage to safety related SSCs for a postulated turbine generatedmissile. This methodology is based upon previously accepted probabilistic and engineeringprinciples and founded on sound engineering practice. The methodology used is directlyapplicable to the intended application documented in the previously accepted NRC safetyevaluation and conforms to the requirements and stipulations of the associated NRC safetyevaluation. Since this methodology has been previously reviewed and accepted by the NRC,these methodology changes to the FSAR do not constitute a departure from a method ofevaluation described in the UFSAR. Therefore, prior NRC approval of these FSARmethodology changes is not required.

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Attachment 1 to TXX-05140Page 12 ofl2

Evaluation Number: 59EV-2002-00191 1-01-00 Unit: CommonRevision 0

Activity Description:This evaluation addresses Activities implementing digital modifications installing a newMeteorological Monitoring System (MMS) data transmission system and recorder, which thuschanges the plant as described in the FSAR.

The new data transmission system consists of two dataloggers. One datalogger collects data fromsix meteorological parameter analog loop signals from the primary meteorological tower; theother datalogger collects data from four meteorological parameter analog loop signals from thebackup meteorological tower. The dataloggers store parameter data locally, and convert analogparameters to digital RS-232 serial which are transmitted via short-haul modem to threeindependent digital-analog conversion modules installed in Unit 1 Plant Computer cabinet. Thesemodules replicate the original 4 - 20 mA signals for each meteorological parameter, which aretransmitted to the meteorological computer, the Unit 1 and Unit 2 plant computers, and recorderequipment in the Main Control Room (MCR) meteorological panel.

The three existing obsolete pen-type analog recorders on the MCR meteorological are replacedwith a single digital paperless recorder.

Summary of Evaluation:FSAR Sections 2.3.3.1.1 and 2.3.3.2 state that the MMS design function, in accordance with RG1.23, is to monitor and record information on six principal meteorological parameters. Theseparameters are used, and stored, to calculate dispersion of dose releases for normal and for post-accident conditions. No control function is provided by MMS. The MMS is designed to measurethe parameters needed to evaluate the dispersive characteristics of the site for both the routineoperational and the hypothetical accidental releases of radionuclides to the atmosphere. TheMMS is not required to achieve safe shutdown or to mitigate the consequences of a DBA, but isrequired for post-accident dose assessment.

Digital data transmission equipment and recorder perform the same functions as the existingequipment. EPRI guidelines are used to determine potential adverse impact of critical aspects ofthe digital controls. From this guidance it can be concluded there is no decrease in reliability ofdesign functions; operator burden is not increased; EMI, seismic, ventilation, and electricalissues associated with overall design do not adversely impact existing SSCs; cyber securitysabotage is not a credible concern; no fundamental HSI changes result from this design; new oradditional failure modes are not an issue; and loss or degradation of electrical power does notresult in adverse consequences.

This evaluation concludes there are no new accidents, failure modes, or malfunctions created bythis modification.

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ATTACHMENT 2 to TXX-05140

Page 1 of 10

Commitment Material Change Evaluations (CMCE)

04-00104-00204-00304-00404-00504-006

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Attachment 2 to TXX-05 140Page 2 of 10

CMCE: 04-001Commitment Number: 25536Change Type: Revision

Source Document:

TXX-89780TXX-9 1119

Original Commitment Description:

TXX-89780:

A maintenance activity is currently being developed which requires that maintenance be performed ongravity dampers every 18 months to ensure operability.

TXX-911 19:

A maintenance activity has been implemented for Unit I safety related gravity dampers which requiresthat maintenance be performed on safety related gravity dampers every 12 months to provide theadditional assurance of the gravity dampers operability. Maintenance activity for the Unit 2 safety relatedgravity dampers will be implemented by Unit 2 fuel load.

Revised Commitment Description:

A maintenance activity has been developed for Unit 1, Unit 2, and Unit common safety related gravitydampers which requires that maintenance be performed every 36 months. This will provide additionalassurance of the gravity damper operability.

Justification for Change:

Based on review of historical Preventive Maintenance records (PMs) and nine years of experience ofperforming maintenance at a frequency of every 12 months, there have been very few problems identifiedwith these safety related dampers and no corrective instances where the damper could not open orperform as intended. Therefore, considering the historical performance and the most effective use ofavailable resources, it is acceptable to change the preventive maintenance frequency from 12 to 36months.

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Attachment 2 to TXX-05140Page 3 of 10

CMCE: 04-002Commitment Number: 24791Change Type: Revision

Source Document:

TXX-90031TXX-92268GL-89-13SSER-24, Appendix C.4

Original Commitment Description:

TXX-90031:

The diesel generator jacket water heat exchanger will be tested in accordance with, 'Heat ExchangerPerformance Monitoring Guidelines for Service Water Systems' (EPRI, July 1989).

TXX-92238:

Supporting documentation for this commitment shall be available in your file for NRC review.

Revised Commitment Description:

The diesel generator jacket water heat exchanger will be monitored in accordance with, 'Heat ExchangerPerformance Monitoring Guidelines for Service Water Systems' (EPRI, July 1989). Supportingdocumentation for this commitment shall be available in your file for NRC review.

The word 'tested' was changed to 'monitored' in the description based on the following:

Justification for Change:

The Emergency Diesel Generator (DG) Jacket Water (3W) Heat Exchanger (HX) fouling monitoring isperformed in accordance with NRC Generic Letter GL-89-13. The GL and EPRI guidance describeseveral methods to evaluate and monitor the performance of heat exchangers. The simplest and mostdirect method is visual inspections. Visual inspections are not considered the best method of monitoringbecause it is some what subjective. However, with the proper considerations, it is an acceptable methodto evaluate HX performance. The GL-89-13 monitoring requirements for DG JW HX's are satisfied bythe existing Preventive Maintenance (PM) inspection and cleaning program. Improvements in cleaningmethods and equipment used for cleaning the DG JWHX's and Component Cooling Water (CCW) HX'sis already in process. The new cleaning equipment will help ensure that the HX's fouling factors aremaintained with in acceptable levels.

Investigation into the erratic fouling data, collected for the DG JWHX's, identified that the temperaturesbeing recorded for HX Jacket Water OUT Temperature were not valid. The temperature being recordedfor HX Jacket Water. OUT was not a true average reading of the jacket water leaving the heat exchanger.The jacket water temperature stratifies as it passes through the heat exchanger and then begins to mix

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Attachment 2 to TXX-05140Page 4 of 10

CMCE: 04-002Commitment Number: 24791Change Type: Revision[cont:]

when it reaches the end bell. The mixing jacket water then swirls up the outlet piping where thetemperature indicator is located. This causes the temperature indicator to fluctuate depending on thelocation of the swirling water.

During DG performance testing the jacket water system maintains the jacket water temperature to theinter-cooler at approximately 149 degrees F. This is accomplished by the use of a temperature controlvalve that bypasses the jacket water HX. The temperature control valve compensates for any degradationof the system. When the JWHX has reached its fouling limit, the jacket water temperature at the inter-cooler begins rising above the normal 149 degrees F, and thus, is a precursor indication of JWHX fouling.Preventive maintenance and inspection activities have validated the design margin of the JWHX to'allow' as much as a 50% degradation in thermal performance. Further, the inter-cooler watertemperature is monitored every time the DG is surveillance tested. This temperature readingdemonstrates the overall performance of the jacket water system and provides the ability to detectdegraded thermal performance.

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Attachment 2 to TXX-05140Page 5 of 10

CMCE: 04-003Commitment Number: 22344Change Type: Revision

Source Document:

TXX-3539CMCE-95-019SSER-20, Section 4

Original Commitment Description:

CMCE-95-019:

The Commitment Management System at CPSES is a comprehensive system governed by administrativecontrol utilized to insure that commitments/requirements are tracked, included, and maintained inappropriate implementing documents. Correspondence to and from regulatory agencies is reviewed forcommitments for inclusion into the Commitment Tracking (CT) database. Any change to source criteriais updated and evaluated against the implementing documents. The need for change or revision is thendetermined and, if applicable, accomplished by the appropriate department/group.

The Commitment Data Form (CDF) contains space for approximately 40 elements of information aboutthe commitment. These elements are necessary to ensure adequate tracking. In addition to the CDFs, theCommitment Management System will maintain files on each commitment as a permanent source ofdetailed supportive information. These files will be maintained in a suitable medium for long termstorage and retrieval. The managing CDF procedure will delineate the storage medium file processinginstructions and required time frame for storage.

Commitment management processes assure that an overview of the supporting documentation and/orinformation identified on the CDF is complete and that compliance criteria/methods have been identified.The information will be entered in the Commitment Tracking database as permanent storage and forfuture reference.

Revised Commitment Description:

Paragraph 1 Revision

The Commitment Management Program at CPSES is a comprehensive system governed byadministrative controls utilized to insure that commitments are tracked, included, and maintained inappropriate implementing documents. Correspondence to and from regulatory agencies is reviewed forcommitments for inclusion into the Commitment Tracking (CT) database. Any change to source criteriaor maintenance documents is evaluated. The need for change or revision is then determined and, ifapplicable, accomplished by the appropriate department/group.

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Attachment 2 to TXX-05 140Page 6 of 10

CMCE: 04-003Commitment Number: 22344Change Type: Revision[cont:]

Paragraph 2 Revision

The CT database can maintain approximately 40 elements (data fields) of information about eachcommitment. Specific required elements are necessary to ensure adequate identification and tracking of acommitment while other optional elements can be used to augment the required element set. Acommitment data form (CDF) is electronically generated to view/modify electronically. In addition to theelectronic CDFs, the Commitment Management Program maintains files on each open or incorporatedstatused commitment as a permanent source of detailed supportive information. These supportive fileswill be maintained in a suitable medium for long term storage and retrieval and may be either electronicor hardcopy in format. The managing commitment procedures delineate the storage medium, fileprocessing instructions and required time frame for storage of either hardcopy and/or electronically storedcommitment data. The Commitment Management Program meets the intent and practices of NEI-99-04,"Guidelines for Managing NRC Commitment Changes" for identification and maintenance of regulatorycommitments.

Paragraph 3 Revision:

Commitment management processes assure that an overview of the supporting documentation and/orinformation identified on the CDF is complete and that compliance criteria/methods have been identified.

Justification for Change:

Paragraph I changes include a change from 'system' to 'program' to properly identify the process andprocedures used at CPSES. The term 'requirements' was removed to eliminate possible misinterpretationof how the commitment database is used. 'Commitment Tracking' was added for clarification of theacronym "CT'. Clarification was added that any potential or needed change regardless of whether it wasa source change or maintenance change was evaluated prior to implementing any change to thecommitment and associated database. These are administrative clarification changes only.

Paragraph 2 changes overall describe the ability to identify a commitment using a subgroup of all datafields available for capturing commitment information. It allows a commitment to be electronicallyidentified using only required data fields with the ability to use other/all data fields to augment theinformation package as necessary for a given commitment. Changes identify that the commitment itselfis electronically represented and hardcopy printouts are the output from the database. The hardcopy maybe used to modify (via markup) a commitment and that the hardcopy may be used (as directed byprocedure) as a method of storage of a commitment information package (i.e. commitment data form).The reduction in the actual number of data field elements used to identify and track a commitment is notcontrary to assuring continuing compliance with the commitment source criteria.

The paragraph 3 change eliminates the redundant statement of maintaining permanent records of changesto commitments.

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Attachment 2 to TXX-05140Page 7 of 10

CMCE: 04-004Commitment Number: 24796Change Type: Revision

Source Document(s):CMCE-96-08GL-88-13TXX-90031TXX-92268NRC IN-2004-00007

Original Commitment Description:

The CCP, CT and SI pump lube oil coolers will not be tested. However, lube oil temperature will berecorded during quarterly surveillance runs of the associated pumps and the trends will be analyzedquarterly. In addition, these heat exchangers will be visually inspected at least once every threeyears. Service water flowrates to these components will be monitored on a weekly basis to verify that theflow rates meet design requirements.

Revised Commitment Description:

The CCP, CT and SI pump lube oil coolers will not be tested. However, the heat exchangers will bevisually inspected at least once every three years. Service water flowrates to these components will bemonitored on a weekly basis to verify that the flow rates meet design requirements.

Justification for Change:

During equipment impact assessment for the 1.4% power uprate, concerns were found in the previoustemperature limits used in STA-734 and other operation's procedures. The concern is that there is noconsideration of the post-accident SSI temperature transient. Operability could be affected if this was notconsidered and the pump coolers were not cleaned when overly fouled. Currently the pumps are operablebased on recent plant data provided by the System Engineer.

IN-2004-00007 was issued by the NRC to notify Licensees of industry problems with degraded lube oilcooler performance for SI Pumps. Monitoring of SSW flow through the coolers by it's self has not beenan adequate indicator of overall cooler performance. Monitoring flow has not detected adverse lube oilcooler fouling conditions. See SMF-2004-001704 for review of IN-2004-00007.

STA-734 "Service Water System Fouling Monitoring Program" requires that SSW flow and oiltemperatures be monitored for the SIP, CCP and CSP lube oil coolers and bearing coolers (commitment24796). These oil temperature trends are compared to maximum allowed design oil temperatures.Trending of the lube oil temperatures from past OPT data for the SIP, CCP and CSP has shown that OPTpump performance runs are not long enough to equalize the oil sump temperature. The short test runtimes and slow rising oil temperatures does not challenge the pump lube oil coolers. Additionally, the

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Attachment 2 to TXX-05140Page 8 of 10

CMCE: 04-004Commitment Number: 24796Change Type: Revision[cont:]

flow and temperature conditions during the OPT pump performance tests do not reflect accident heat loadconditions. This causes oil temperatures to rise very slowly during the OPT tests and prevents oiltemperatures from challenging design limits. The OPT tests were recently revised to increase test runtimes to 20 minutes. The increased run time did not improve the oil temperature readings.

Data for the SIP and CCP showed that pump oil sump temperatures were normally colder than SSW inlettemperatures. Therefore, during the OPT pump runs, the oil was actually cooling the SSW. Data for theCSP showed that the SSW outlet temperature delta from the beginning to the end of the OPT wasundetectable. This indicates that the bearing coolers are not affecting bearing oil temperature under thesetest conditions. Trending of the SIP, CCP and CSP pump lube oil temperatures during OPT pumpperformance tests provides no useful data for the SW System fouling monitoring program. Continuedtrending of this temperature data for lube oil cooler performance is not necessary.

The pump lube oil coolers and bearing coolers are required to be visually inspected and cleaned at leastonce every three years (commitment 24796). The visual inspection process is approved by the EPRIService Water Heat Exchanger Testing Guidelines for monitoring heat exchangers. The as-foundinspection results will be used to adjust the cleaning frequency in order to maintain acceptable coolerperformance. SSW flows will continue to be monitored during each shift by Operations personnel toensure that minimum flow requirements are maintained. The current inspection, monitoring and cleaningprogram will ensure proper lube oil cooler performance with out trending OPT lube oil temperatures.

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Attachment 2 to TXX-05140Page 9 of 10

CMCE: 04-005Commitment Number: 03620Change Type: Revision

Source Document(s):TXX-0040551TXX-4373TXX-90060NEO Policy 55EA-83-64

Original Commitment Description:

The SAFETEAM Program will provide an opportunity for each exiting employee to have a confidentialinterview to express any concern regarding CPSES. Continuing employees will have similaropportunities. Each concern will be investigated, a report will be prepared and the concerned individualwill receive a written reply.

Revised Commitment Description:

There is no change to the description. The Revision is to capture the intent as annotated in sourcedocument TXX-90060, attachment 1, page 2 of using the "Hotline Program" for making QualityAssurance concerns. This program will no longer exist in parallel to the SAFETEAM program. Thededicated SAFETEAM telephones will remain in place and function as a single point for expressing allconcerns.

Justification for Change:

This commitment change is being made in conjunction with CMCE-04-06 where the commitmentdescription associated with SAFETEAM / Hotline Program will be revised.

The Hotline Program mentioned in the source document, and later taken over by Corporate Security (wasknown as either the 'QA Hotline', 'Hotline' or 'Security Hotline'), has not been used in several years. Itwas a Near Term Operating License (NTOL) program/process and as such did not see much if any useafter both Units attained a commercial license. Further, Corporate Security (who currently maintains the'Hotline' telephone lines) at CPSES is downsizing and will not maintain the program since there arededicated telephones for SAFETEAM which duplicates efforts. The non-utilized Hotline telephone lineshave been terminated and the SAFETEAM functionality meets the intent of the previous process.

These actions and process changes are captured by corrective action document SMF-04-02776.

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Attachment 2 to TXX-05140Page 10 of 10

CMCE: 04-006Commitment Number: 02979Change Type: Revision

Source Document(s):TXX-4374TXX-4055TXX-90060EA-83-64CMCE-04-05

Original Commitment Description:

To reaffirm total commitment to an effective and independent QA/QC program, TUGCO will initiate aprogram to encourage immediate reporting of quality concerns via a 24 hour a day telephone contact.Appropriate records of the concerns and dispositions will be maintained.

Revised Commitment Description:

To reaffirm total commitment to an effective and independent QA/QC program, TXU will initiate aprogram to encourage immediate reporting of quality concerns via a 24 hour a day telephone contact.This is accomplished using dedicated SAFETEAM telephones. Appropriate records of the concerns anddispositions will be maintained.

Justification for Change:

This commitment change is being made in conjunction with CMCE-04-05 to identify the current methodand organization which is responsible for capturing, evaluating and reporting concerns brought to theattention of TXU Power at Comanche Peak Steam Electric Station (CPSES).

During the construction and Near Term Operating License (NTOL) phase at CPSES, two different butsimilar methods of assuring QA/QC and any other type of concern associated with the construction andoperation of CPSES were provided to contractor and employees alike. As indicated in CMCE-04-05, theHotline Program is antiquate, has not been used in several years and all provisions of that program arenow exclusively maintained by the SAFETEAM organization. The non-utilized Hotline telephone lineshave been terminated and the SAFETEAM functionality meets the intent of the previous process.

Further, the company name and acronym indicated by TUGCO, has been changed to TXU Power. Thischange is also captured by this CMCE.


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