ML032721646

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9/25/03 Stars RAI TSs 3.8.1 and 3.8.4 for Callaway, Diablo Canyon, Palo Verde and Wolf Creek Plants. (Tacs. MB9664, MB9476, MB9477, MB9150, MB9151, MB9152 and MB8763 Respectively)
ML032721646
Person / Time
Site: Palo Verde, Wolf Creek, Diablo Canyon, Callaway  Pacific Gas & Electric icon.png
Issue date: 09/25/2003
From: Donohew J
NRC/NRR/DLPM/LPD4
To: Muench R, Overbeck G, Randolph G, Rueger G
Arizona Public Service Co, Pacific Gas & Electric Co, Union Electric Co, Wolf Creek
Donohew J N, NRR/DLPM,415-1307
References
TAC MB8763, TAC MB9150, TAC MB9151, TAC MB9152, TAC MB9476, TAC MB9477, TAC MB9664
Download: ML032721646 (11)


Text

September 25, 2003 Mr. Garry L. Randolph Mr. Gregg R. Overbeck Vice President and Chief Nuclear Officer Senior Vice President, Nuclear Union Electric Company Arizona Public Service Company Post Office Box 620 P.O. Box 52034 Fulton, MO 65251 Phoeniz, AZ 85072-2034 Mr. Gregory M. Rueger Mr. Rick A. Muench Senior Vice President, Generation and President and Chief Executive Officer Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation Pacific Gas and Electric Company Post Office Box 411 Diablo Canyon Power Plant Burlington, KS 66839 P. O. Box 3 Avila Beach, CA 93424

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RE: TECHNICAL SPECIFICATIONS 3.8.1 AND 3.8.4 FOR CALLAWAY, DIABLO CANYON, PALO VERDE, AND WOLF CREEK PLANTS (TAC NOS. MB9664, MB9476, MB9477, MB9150, MB9151, MB9152, AND MB8763, RESPECTIVELY)

Dear Messrs. Randolph,

Rueger, Overbeck and Muench:

By letters dated June 6 (Callaway, ULNRC-04837), May 29 (Diablo Canyon, DCL-03-061),

May 28 (Palo Verde, 102-04946), and April 30 (Wolf Creek, WO 03-0009), 2003, you submitted applications for license amendments to modify several surveillance requirements (SRs) in Technical Specifications (TSs) 3.8.1 and 3.8.4 on alternating current and direct current sources - operating, respectively, for plant operation. The revised SRs would have notes deleted or modified to allow the SRs to be performed, or partially performed, in reactor modes that are currently not allowed by the TSs. The current SRs are not allowed to be performed in Modes 1 and 2, and several of the current SRs also cannot be performed in Modes 3 and 4.

You jointly submitted your applications as members of the Strategic Teaming and Resource Sharing (STARS), an industry consortium of six nuclear power plant licensees. The applications are similar, but there are some differences. The staff is reviewing the applications jointly.

The enclosed information is needed for the staff to complete its review of the applications. To expedite the staffs review to meet the agreed-upon schedule, the request for additional information was provided to your staff by e-mail on September 3, 2003. Any differences between the enclosed questions and the e-mail is editorial. In a call on the questions with your staff, they agreed to submit the responses to the questions by October 30, 2003. If the

Multiple Addressees responses are submitted by that date, the staff expects to issue its evaluation on schedule. If you have any questions, contact me, the lead project manager, at 301-415-1307, or at jnd@nrc.gov through the internet.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-275, 50-323, 50-482, 50-483, 50-528, 50-529, and 50-530

Enclosure:

Request for Additional Information cc w/encl: See next page

Multiple Addressees responses are submitted by that date, the staff expects to issue its evaluation on schedule. If you have any questions, contact me, lead project manager, at 301-415-1307, or at jnd@nrc.gov through the internet.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-275, 50-323, 50-482, 50-483, DISTRIBUTION:

50-528, 50-529, and 50-530 PUBLIC PDIV-2 Reading

Enclosure:

Request for Additional Information RidsNrrDlpmPdiv(HBerkow)

RidsNrrPMJDonohew cc w/encl: See next page RidsNrrLAEPeyton RidsOGCRp RidsACRSACNWMailCenter DGraves, RIV OChopra MConnell MFields GShukla LSmith, RIV APal

  • Three EEIB RAI memos dated 08/29/2003 ACCESSION NO.: ML032721646 NRR-088 OFFICE PDIV-2/PM PDIV-2/LA EEIB/SC PDIV-2/SC NAME JDonohew EPeyton RJenkins*

SDembek DATE 9/24/03 9/23/03 08/29/2003 9/24/03 DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML032721646.wpd OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION CHANGES TO SECTIONS 3.8.1 AND 3.8.4 AC AND DC SOURCES - OPERATING CALLAWAY, DIABLO CANYON, PALO VERDE, AND WOLF CREEK PLANTS DOCKET NOS. 50-483, 50-275, 50-323, 50-528, 50-529, 50-530, AND 50-482 The required onsite emergency backup power supply to offsite power is referred to in the licensees' applications, as either the emergency diesel generators (EDGs) or the diesel generators (DGs). Both acronyms are used in the staff's questions.

The following questions are separated into (1) those questions which are the same for the four plants, and (2) those questions which are different:

1.

Callaway, Diablo Canyon Units 1/2, Palo Verde Units 1/2/3, and Wolf Creek a.

Surveillance Requirement (SR) 3.8.4.7 and SR 3.8.4.8 contain a Note that has been modified to add "However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced." Provide the intent of this note in detail (what exactly will be done at power, the duration of these surveillances and its impact on the limiting condition of operation, details regarding assessment, etc.)

b.

Does the work control programs, risk management programs, and/or procedures cover a comprehensive walk-down just prior to entering the period of reduced equipment availability during EDG testing? Provide details about the walk-down or justify why such a walk-down is not required.

c.

Indicate where the loss-of-offsite power signal comes from when the EDG is powering, or is paralleled to, the safety bus.

d.

Discuss administrative controls to preclude performing these surveillances during other maintenance and test conditions that could have adverse effects on the offsite power system or plans for restricting additional maintenance or testing of required safety systems that depend on the remaining EDG as a source.

Additionally, discuss if the remaining EDG were to become inoperable while the other EDG is being tested, would the test be aborted.

e.

Discuss whether procedures are in place to alert operators when to perform either portions or full SRs/testing. Will the operators receive training on the procedures related to the proposed technical specification changes prior to implementation?

f.

Discuss the compensatory measures that will be implementing during performance of SRs 3.8.1.10, 3.8.1.13, and 3.8.1.14.

g.

For SR 3.8.1.13, discuss (1) how the SR is performed, and (2) how the safety injection (SI) signal is generated without disturbing power operation.

1.

Callaway and Wolf Creek Only a.

SR 3.8.1.10 - In Section 4.1.1 of the application, it is stated that "experience with this test has shown that the voltage 'perturbation' seen on the bus during and just after the load rejection is not significant, i.e., within 5 percent step change.

Data recorded from past performances of this test show that bus voltage during the transient remains well above the minimum required voltage for bus loads and typically recovers within one second." Discuss the impact of this voltage transient on degraded voltage relays. Also, during power operation the voltages at the safety buses are relatively lower than during shutdown. What will be the voltage transient due to a full load rejection test at the lower voltages and its impact on degraded voltage relays?

b SR 3.8.1.10 - In Section 4.1.4 of the application, it is stated that "In the event of a LOOP [loss-of-offsite power] occurring while a DG is running and paralleled to offsite power for testing... At some point, however, because loading would exceed the DGs capability, the DG would be unable to match load and either the bus undervoltage relays would trip (after timing out) or the DG overcurrent or underfrequency relays would trip." Discuss the time associated with manually resetting the involved relays and components.

c.

Questions a. and b. above are also applicable to SR 3.8.1.14.

3.

Diablo Canyon Units 1/2 Only a.

SR 3.8.1.10 - In Section 4.1 of the application, it is stated that "during the last refueling outage at DCPP [Diablo Canyon Power Plant] when the DG full load reject SRs were performed on each diesel, the voltage transients experienced by the loads on the associated buses were minor (the worst case was an approximate 1.29 percent change of 54 volts in the bus voltage at the 4.16 kV level, in approximately 0.09 seconds)." Discuss the impact of this voltage transient on degraded voltage relays. Also, during power operation the voltages at the safety buses are relatively lower than during shutdown. What will be the voltage transient due to a full load rejection test at the lower voltages and its impact on degraded voltage relays?

b.

Question a. above is also applicable to SR 3.8.1.14.

4.

Palo Verde Units 1/2/3 Only a.

SR 3.8.4.6 contains a Note that has been modified to add "However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced."

Discuss the intent of this note in detail (e.g., what exactly will be done at power, the duration of these surveillances and its impact on the limiting condition of operation, details regarding assessment, etc.).

b.

SR 3.8.1.10 - In Section 4.1 of the application, it is stated that "at PVNGS when the DG full load reject SR is performed at shutdown, the voltage transients experienced by the loads on the associated bus are considered minimal [at approximate 10 percent step change (400Vac)] in the bus voltage at the 4.16 kV level, with voltage recovery within 1 second." Discuss the impact of this voltage transient on degraded voltage relay. Also, since the voltages at the safety buses during power operation are relatively lower than during shutdown, what will be the voltage transient due to full load rejection test during power operation?

c.

SR 3.8.1.10 - In Section 4.1 of the application, it is stated that "If a LOP occurs during testing, the diesel generator either trips on overcurrent or continues to run, depending upon if the resulting load is in excess of the diesel generator's load rating. If the load is excessive, the diesel generator will trip on overcurrent and the diesel generator breaker will trip automatically on a DG shutdown signal." Discuss how will the DG be started and DG breaker be closed once overcurrent relay tripped the DG? Will it involve manual resetting of the relays?

If so, discuss the time associated with the manual resetting of the relay.

d.

Questions b. and c. above are also applicable to SR 3.8.1.14.

e.

Discuss the compensatory measures that will be implemented during performance of SR 3.8.1.20.

f.

On page 12 of the application, it is stated that "only one DG per unit is paralleled to offsite power at any one time and any offsite grid disturbances would only affect one operable DG." Discuss the possibility of testing an EDG of each unit being simultaneously paralleled to offsite power, such that an offsite disturbance could affect all three units. Discuss the testing practice for SRs 3.8.1.10, 3.8.1.13, 3.8.1.14, and 3.8.1.20 in terms of such a situation.

Callaway Plant, Unit 1 cc:

Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855 John ONeill, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C. 20037 Mr. Mark A. Reidmeyer, Regional Regulatory Affairs Supervisor Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 U.S. Nuclear Regulatory Commission Resident Inspector Office 8201 NRC Road Steedman, MO 65077-1302 Mr. Chris Younie Manager, Quality Assurance AmerenUE P.O. Box 620 Fulton, MO 65251 Manager - Electric Department Missouri Public Service Commission 301 W. High P.O. Box 360 Jefferson City, MO 65102 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Mr. Ronald A. Kucera Deputy Director for Public Policy Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KA 66839 Mr. Dan I. Bolef, President Kay Drey, Representative Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, MO 63130 Mr. Lee Fritz, Presiding Commissioner Callaway County Court House 10 East Fifth Street Fulton, MO 65151 Mr. David E. Shafer Superintendent, Licensing Regulatory Affairs AmerenUE P.O. Box 66149, MC 470 St. Louis, MO 63166-6149 Mr. Keith D. Young Manager, Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Scott Clardy, Director Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102-0570

Diablo Canyon Power Plant, Units 1 and 2 cc:

NRC Resident Inspector Diablo Canyon Power Plant c/o U.S. Nuclear Regulatory Commission P.O. Box 369 Avila Beach, CA 93424 Mr. Pete Wagner Sierra Club California 2650 Maple Avenue Morro Bay, California 93442 Ms. Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, CA 93448 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, CA 93408 Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, CA 94102 Diablo Canyon Independent Safety Committee ATTN: Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Richard F. Locke, Esq.

Pacific Gas & Electric Company P.O. Box 7442 San Francisco, CA 94120 Mr. David H. Oatley, Vice President and General Manager Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 City Editor The Tribune 3825 South Higuera Street P.O. Box 112 San Luis Obispo, CA 93406-0112 Mr. Ed Bailey, Radiation Program Director Radiologic Health Branch State Department of Health Services P.O. Box 942732 (MS 178)

Sacramento, CA 94234-7320 Mr. James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 31)

Sacramento, CA 95814 Mr. James R. Becker, Vice President Diablo Canyon Operations and Station Director Diablo Canyon Power Plant P.O. Box 3 Avila Beach, CA 93424

Wolf Creek Generating Station cc:

Jay Silberg, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, D.C. 20037 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-7005 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 311 Burlington, KS 66839 Chief Engineer, Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027 Office of the Governor State of Kansas Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839 Vick L. Cooper, Chief Air Operating Permit and Compliance Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Site Vice President Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Superintendent Licensing Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 U.S. Nuclear Regulatory Commission Resident Inspectors Office 8201 NRC Road Steedman, MO 65077-1032

July 2003 Palo Verde Generating Station, Units 1, 2, and 3 cc:

Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 40 Buckeye, AZ 85326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Mr. Craig K. Seaman, Director Regulatory Affairs/Nuclear Assurance Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. Hector R. Puente Vice President, Power Generation El Paso Electric Company 2702 N. Third Street, Suite 3040 Phoenix, AZ 85004 Mr. John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Ms. Cheryl Adams Southern California Edison Company 5000 Pacific Coast Hwy Bldg DIN San Clemente, CA 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251 Terry Bassham, Esq.

General Counsel El Paso Electric Company 123 W. Mills El Paso, TX 79901 Mr. John Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326