DCL-98-116, Forwards Response to NRC 980707 & 09 RAIs Re LAR to Convert Current TS Sections 1.0,2.0 & 3.0 to Improved Std TS
| ML17083C711 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/28/1998 |
| From: | Oatley D PACIFIC GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML16342E246 | List: |
| References | |
| DCL-98-116, NUDOCS 9809040350 | |
| Download: ML17083C711 (20) | |
Text
CATEGORY j.
REGULA Y INFORMATION DISTRIBUTI SYSTEM (RIDS)
SUBJECT:
Forwards response to NRC 980707 S
09 RAIs re LAR to convert current TS Secitons 1.0,2.0 6 3.0 to Improved Std TS.
DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: General Distribution ACCESSION NBR:9809040350 DOC.DATE: 98/08/28 NOTARIZED: YES DOCKET I FACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific Ga 05000275 50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga 05000323 AUTH.NAME AUTHOR AFFILIATION OATLEY,D.H.
Pacific Gas
&, Electric Co.
RECIP.NAME RECIPIENT AFFILIATION gg Records Management Branch (Document Control Desk)+~ /<+
/pc up' NOTES:
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LTTR 14 ENCL 13
Pacific Gas a'nd Electric Company August 28, 1998 PG8 E Letter DCL-98-116 David H. Oatley Diablo Canyon Power Plant Vice President-Diablo Canyon PO. Box 56 Operations and Plant Manager Avita Beach, CA 93424 605.545.6000 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 License Amendment Re uest 97-09 "Technical S ecification Conversion" Res onse to Re uest for Additional Information for Sections 1.0 2.0 and 3.0 Reference 1)
NRC letter from Steven D. Bloom to Gregory M. Rueger, dated July 7, 1998 2),
NRC letter from Steven D. Bloom to Gregory M. Rueger, dated July 9, 1998 3)
DCL-97-106, "License Amendment Request 97-09, Technical Specification Conversion License Amendment Request," dated June 2, 1997 4)
DCL-98-003, "License Amendment Request 97-09, Errata," dated January 9, 1998
Dear Commissioners and Staff:
PGRE submitted a license amendment request (Reference 3) for Diablo Canyon Power Plant (DCPP), Units 1 and 2 to convert the current DCPP Technical Specifications (TS) to a set of TS based upon the improved standard TS.
PGB E submitted an errata to Reference 3 as noted in Reference 4. The NRC staff requested additional information regarding Section 1.0, "Use and Application"; Section 2.0, "Safety Limits"; and Section 3.0, "LimitingConditions for Operation Applicability/Surveillance Requirement Applicability" of the proposed TS changes in References 1 and 2. The requested information, other than the response to Comment Number 1.1-4, is provided in the Enclosures to this letter as are any additional changes needed for Sections 1.0, 2.0, and 3.0 as identified by PG8 E. The response to Comment Number 1.1-4 will be provided separately after the August 17, 1998, NRC letter to NEI on TSTF-111 has been fullyevaluated.
9809040350 980828 PDR ADOCK 05000275 P
PDR'
Document Control Desk August 28, 1998 Page 2 PG8 E Letter-DCL-98-116 This letter and the Enclosures are not a supplement to Reference 3, and thus have not been reviewed and approved by DCPP's Plant Staff Review Committee.
A supplement to Reference 3 will be provided at a later date. Any deviations from the responses provided in this letter will be discussed in the supplement.
Sincerely, David H. Oatley cc:
Edgar Bailey, DHS Steven D. Bloom Dennis F. Kirsch Ellis W. Merschoff David L. Proulx Diablo Distribution Enclosures MRZ/
Enclosure 1
PGRE Letter DCL-98-116 UNITED STATES OF AMERICA NUCLEAR REGULATORYCOMMISSION Diablo Canyon Power Plant Units 1 and 2
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In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY )
)
)
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Docket No. 50-275 Facility Operating License No. DPR-80 Docket No. 50-323 Facility Operating License No. DPR-82 AFFIDAVIT David H. Oatley, of lawful age, first being duly sworn upon oath says that he is Vice President - Diablo Canyon Operations and Plant Manager of Pacific Gas and Electric Company; that he has executed the "Response To NRC Request For Additional Information," dated June 7 and 9, 1998, regarding License Amendment Request 97-09, "Technical Specification Conversion," on behalf of said company with full power and authority to do so; that he is familiar with the content thereof: and that the facts stated therein are true and correct to the best of his knowledge, information, and belief.
David H. Oatley Vice President - Diablo Canyon Operations and Plant Manager Subscribed and sworn to before me this K 'ay of August 1998.
County of San Luis Obispo State of California Notary ic AMYJ. CALLOWAY COMM. Ap966pg NOTARYPUBUC CAUFORNIA ~
SAN LUIS OBISPO COUNlY MIIComm. Expires April28,2000
0
ACRONYM LIST Enclosure 1
PG8 E Letter DCL-98-116 ADV CFCU CIV CPSES CTS DBA DLAP DOC ECCS ECG EQ FLOG FSAR GDC IEEE IST ITS JFD LCO LER LG LOCA MFIV MFRV MSSV PAMS Atmospheric Dump Valve Containment Fan Cooling Unit Containment isolation Valve Comanche Peak Steam Electric Station Current Tech Spec Design Basis Accident Department Level Administrative Procedure Description of Change Emergency Core Cooling System Equipment Control Guideline Environment QualiTication Four Loop Owner's Group Final Safety Analysis Report Generic Design Criteria Institute of Electrical and Electronic Engineers In-service Test Improved Tech Spec Justification For Differences License Amendment License Amendment Request Limiting Condition of Operation Licensee Event Report Less Restrictive Loss of Coolant Access Main Feedwater Isolation Valve Main Feedwater Regulating Valves Main Steam Safety Valve Post Accident Monitoring System Required Actions Request for additional information RCS RG RHR SER SR STS TRM TSTF USAR WCGS WOG Reactor Coolant System Regulatory Guide Residual Heat Removal Safety Evaluation Report Surveillance Requirement Standard Tech Spec Technical Requirements Manual Tech Spec Task Force Updated Safety Analysis Report WolfCreek Generating Station Westinghouse Owners Group
EncIosure 2 PG8 E Letter DCL-98-116 JLS CONVERSION TO IMPROVED TECHNICALSPECIFICATIONS CTS 1.0 - DEFINITIONS ITS 1.0 - USE AND APPLICATION RESPONSE TO REQUEST FOR ADDITIONALINFORMATIONAND LICENSEE INITIATEDADDITIONALCHANGES
PG8E Letter DCL-98-116 INDEXOF ADDITIONALINFORMATION ADDITIONALINFORMATION NUMBER APPLICABILITY ENCLOSED 1.1-1 1.1-2 1.1-3 1.1-4 1.1-5 1.1-6 1.1-7 1.1-8 1.1-9 1.4-1 TR 1.0-006 DC-ALL-002 (1.0 changes only)
DC-ALL-005 (3.3 Bases changes only for TR 1.0-006)
DC, CP, WC, CA DC, CP, WC, CA CP, WC, CA DC, CP, WC, CA DC, CP, WC, CA DC, CP, WC, CA DC, CP, WC, CA CP, WC, CA DC, CP, WC, CA DC, CP, WC, CA DC, CP, WC, CA DC DC YES YES NA YES YES YES YES NA YES YES YES see DCL-98-003 YES
0 PG8 E Letter DCL-98-116 JOINT LICENSING SUBCOMMITTEE METHODOLOGYFOR PROVIDING ADDITIONALINFORMATION The following methodology is followed for submitting additional information:
1.
Each licensee is submitting a separate response for each section.
2.
Ifan RAI does not apply to a licensee (i.e., does not actually impact the information that defines the technical specification change for that licensee),
"NA"has been entered in the index column labeled "ENCLOSED" and no information is provided in the response for that licensee.
3.
Ifa licensee initiated change does not apply, "NA"has been entered in the index column labeled "ENCLOSED" and no information is provided in the response for that licensee.
4.
The common portions of the "Additional Information Cover Sheets" are identical, except for brackets, where applicable (using the same methodology used in enclosures 3A, 3B, 4, 6A and 6B of the conversion submittals).
The list of attached pages willvary to match the licensee specific conversion submittals. A licensee's FLOG response may not address all applicable plants ifthere is insufficient similarity in the plant specific responses to justify their inclusion in each submittal.
In those cases, the response willbe prefaced with a heading such as "PLANTSPECIFIC DISCUSSION."
5.
Changes are indicated using the redline/strikeout tool of WordPerfect or by using a hand markup that indicates insertions and deletions.
Ifthe area being revised is not clear, the affected portion of the page is circled. The markup techniques vary as necessary, based on the specifics of the area being changed and the complexity of the changes, to provide the clearest possible indication of the changes.
- 6. A marginal note (the Additional Information Number from the index) is added in the right margin of each page being changed, adjacent to the area being changed, to identify the source of each change.
7.
Some changes are not applicable to one licensee but still require changes to the Tables provided in Enclosures 3A, 3B, 4, 6A, and 6B of the original license amendment request to reflect the changes being made by one or more of the other licensees.
These changes are not included in the additional information for the licensee to which the change does not apply, as the changes are only for consistency, do not technically affect the request for that licensee, and are being provided in the additional information being provided by the licensees for which the change is applicable.
The complete set of changes for the license amendment request will be provided in a licensing amendment request supplement to be provided later.
PG8E Letter DCL-98-116 8.
The item numbers are formatted as follows:
[Source] [ITS Section]-[nnn]
Source =
Q - NRC Question CA - AmerenUE DC - PG8E WC - WCNOC CP - TU Electric TR - Traveler ITS Section = The ITS section associated with the item (e.g., 3.3). Ifall sections are potentially impacted by a broad change or set of changes, "ALL" is used for the section number.
nnn = a three digit sequential number
PG&E Letter DCL-98-116 ADDITIONALINFORMATIONCOVER SHEET ADDITIONALINFORMATIONNO: Q 1.1-1 REQUEST:
APPLICABILITY: DC, CP, WC, CA CTS 1.3, Analog Channel Operations Test CTS 1.3, Channel Operational Test [Diablo Canyon]
CTS 1.7, Channel Functional Test [Diablo Canyon]
CTS 1.35, Trip Actuating Device Operational Test [WolfCreek]
CTS 1.36, Trip Actuating Device Operational Test [Callaway]
CTS 1.37, Trip Actuating Device Operational Test [Comanche Peak]
CTS 1.38, Trip Actuating Device Operational Test [Diablo Canyon]
DOC 1-30-A ITS 1.1, Channel Operational Test (COT)
ITS 1.1, Channel Functional Test (CFT) [Diablo Canyon]
ITS 1.1, Trip Actuating Device Operational Test (TADOT)
JFD 1.1-9 These are changes to both the CTS and the STS and are considered generic.
Therefore, they are beyond the scope of the conversion review.
The DOC states that these changes are consistent with TSTF-39, Rev. 1.
Also, Diablo Canyon's ITS markup appears to be in error as shown by "Channel Operational" versus "Channel Operational Test (COT)."
Comment:
If NRC has not approved TSTF-39 by the time the draft safety evaluation is prepared, then these changes should be withdrawn from the conversion submittal at that time. These changes willnot be reviewed on a plant-specific basis.
In addition, correct the Diablo Canyon ITS markup for COT.
FLOG RESPONSE:
TSTF-39 Rev.
1 has been withdrawn by the TSTF. However, changes addressed in TSTF-39 Rev.
1 have been subsumed by TSTF-205. Rev.
1 of TSTF-205 is currently undergoing final review by the TSTF members.
Afterfinal wording changes for the COT definition as well as Section 3.3 Bases changes to establish the requirements for relay contact surveillance testing (issue originally raised at Peach Bottom) are agreed upon, Rev.
1 willbe submitted for NRC review. The attached pages represent the definition changes to be included in Rev. 1. The Section 3.3 Bases changes willbe addressed under that Section's review.
ATTACHED PAGES'ncl.
2 Encl. 3A Encl. 3B Encl. 5A Encl. 5A Encl. 6A Encl. 6B 1-1, 1-1a, 1-4, 1-6, and 1-7 5
4 Traveler Status Sheet 1.1-2, 1.1-4, and 1.1-6 2
2