ML16342A532
| ML16342A532 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/07/1998 |
| From: | Steven Bloom NRC (Affiliation Not Assigned) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| TAC-M98984, TAC-M98985, NUDOCS 9810150149 | |
| Download: ML16342A532 (62) | |
Text
Mr. Gregory M. Rueger, ior Vice President and General Manager Pacific Gas and Electric Company Nuclear Power Generation N9B P.O. Box 770000 San Francisco, California 94177 October 7, 199
SUBJECT:
REQUEST FOR ADDITIONALINFORMATIONON THE PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR DIABLOCANYON POWER PLANT, UNIT NOS.
1 AND 2 (TAC NOS. M98984 AND M98985)
Dear Mr. Rueger:
The Nuclear Regulatory Commission staff is reviewing Pacific Gas & Electric Company's proposed license amendment to convert the current technical specifications for the Diablo Canyon Power Plant, Unit Nos.
1 and 2, to the Improved Standard Technical Specifications.
Pacific Gas 8 Electric Company provided their proposed license amendment request by letter dated June 2, 1997.
The staff has reviewed selected portions of the application.
Based on its review, the staff has determined that additional information is needed in Section 3.8, Subsections 3.8.1, 3.8.2, 3.8.3, 3.8.9, and 3.8.10, Electrical Power Systems, as discussed in the enclosure.
The request for additional information was electronically transmitted to your staff on October 5, 1998, to expedite the review process.
Question 3.8.03-03 has been modified by deleting the first sentence because it was not needed.
To assist the staff in maintaining its review schedule, please respond to the questions within 30 days of the date of this letter. Ifyou have any questions regarding the RAI, please contact me at (301) 415-1313.
Ifall four utilities would like to have a common discussion, a single meeting, or phone call, it can be coordinated by contacting the NRR Lead Project Manager, Jack Donohew at (301) 415-1307.
Sincerely, Original Signed By Steven D. Bloom, Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosure:
Request for Additional Information cc w/encl: See next page Document Name:
DCITS.RAI t Docket..'UBLIC PDIV-2 Reading EAdensam (EGA1)
WBateman SBloom JLuehman OGC ACRS PGwynn, RIV GPick, RIV WBeckner EPeyton OFC NAME PD4-2 SBI TSB WBeckner DATE 10/
/98 10/ t/98 OFFICIALRECORD COPY 981015014'7 981007 PDR ADQCK 05000275 P
I'
Mr. Gregory M. Rueger October 7, 1998 cc w/encl:
NRC Resident Inspector
'iablo Canyon Nuclear Power Plant cIo U.S. Nuclear Regulatory Commission P. O. Box 369 Avila Beach,. California 93424 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower 8 Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Dr. Richard Ferguson, Energy Chair Sierra Club California 1100 11th Street, Suite 311 Sacramento, California 95814 Christopher J. Warner, Esq.
Pacific Gas 8 Electric Company Post Office Box 7442 San Francisco, California 94120 Ms. Nancy Culver San Luis Obispo Mothers for Peace P. O. Box 164 Pismo Beach, California 93448 Chairman San Luis Obispo'County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Mr. David H. Oatley, Vice President Diablo Canyon Operations and Plant Manager Diablo Canyon Nuclear Power Plant
'P.O. Box 3 Avila Beach, California 93424 Telegram-Tribune AKIN: Managing Editor 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406 Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, California 94102 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732 Sacramento, California 94232 Diablo Canyon Independent Safety Committee AITN: Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D Monterey, California 93940
'I
~
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.1, AC Sources - Operatin 3.8.1-01 DC ITS 3.8.1 Required Action A.2 STS 3.8.1 Required Action A.2 Bases for ITS 3.8.1 Required Action A.2, STS Bases markup page B 3.8-10 ITS 3.8.1 Note for Required Actions D.1 and D.2 STS 3.8.1 Note for Required Actions D.1 and D.2 Bases for ITS 3.8.1 Required Actions D.1 and D.2, STS Bases markup page B 3.8-25 Required Action A.2 for STS 3.8.1 specifies to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable with a Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s).
This requirement has not been adopted as Required Action A.2 for corresponding ITS 3.8.1.
The Note for Required Actions D.1 and D.2 for STS 3.8.1 states, "Enter applicable Conditions and Required Actions of LCO 3.8.9, Distribution Systems - Operating, when Condition D is entered with no AC power source to any train." This Note has not been adopted as the Note for Required Actions D.1 and D.2 for corresponding ITS 3.8.1
~
JFD 3.8-32 states that a loss of one offsite power circuit willnot result in offsite power to the bus being unavailable.
Comment:
Confirm that there are no potential failures that could occur that would result in offsite power to a bus being unavailable, or conform to the STS.
Licensee Response:
3.8.1-02 DC ITS 3.8.1 Required Action B.2 ITS 3.8.1 Note for Required Action B.2 Bases for ITS 3.8.1 Required Action B.2, STS Bases markup page B 3.8-Bases for STS 3.8.1 Required Actions A.2 and B.2 Reviewer's Notes This comment is applicable only ifRequired Action A.2 for STS 3.8.1 has been adopted by corresponding ITS 3.8.1.
Required Action B.2 for ITS 3.8.1 specifies to declare required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable.
The Bases for STS 3.8.1 Required Actions A.2 and B.2 contain the same Reviewer's Note. The Reviewer's Notes address when the turbine driven auxiliary feedwater pump (TDAFWP) is required to be considered a redundant required feature.
The Note
Diablo Canyon improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 associated with Required Action B.2 states, "In Modes 1, 2, and 3, the TDAFWP is considered a required redundant feature." Required Action A,2 does not have this Note.
Comment:
Not having a Note associated with Required Action A.2 for ITS 3.8.1 that addresses the TDAFWP appears to be inconsistent with Required Action B.2, and not in conformance with the STS Reviewer's Notes.
Revise the submittal to provide the explanation/justification for this apparent inconsistency and nonconformance, or add a Note addressing the TDAWFP to Required Action A.2 Licensee Response:
3.8.1-03 CP(3.8.1-02)
DC DOC 01-03-LS CTS 3/4.8.1.1 Action e Action e for CTS 3/4.8.1
~ 1 requires demonstrating the Operability of three diesel generators by performing the requirements of Specification 4.8.1.1.2a.2 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> unless the DGs are already operating.
This requirement has not been retained in corresponding ITS 3.8.1 in conformance with the STS.
Comment:
DOC 01-03-LS does not address this proposed change.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
. 3.8.1-04 DC ITS 3.8.1 Condition I and Required Actions I.1 CTS 3/4.8.1.1 Actions Condition I for ITS 3.8.1'addresses two or more DGs inoperable and one or more required offsite circuits inoperable.
Required Action l.1 for ITS 3.8.1 requires to enter LCO 3.0.3 with a Completion Time of immediately. This requirement is a proposed change relative to the Actions for corresponding CTS 3/4.8.1.1.
Comment: The CTS markup does not show this proposed change, and no justification has been provided to support the proposed change.
Revise the submittal to provide the appropriate justification.
Licensee Response:
f
Diablo Canyon improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 DC 3.8.1-05 ITS 3.8.1 Condition J and Required Actions J.1 CTS 3/4.8.1.1 Actions Condition J for ITS 3.8.1 addresses one or more DGs inoperable and two required offsite circuits inoperable.
Required Action J.1 for ITS 3.8.1 requires to enter LCO'3.0.3 with a Completion Time of immediately. This requirement is a proposed change relative to the Actions for corresponding, CTS 3/4.8.1.1.
Comment: The CTS markup does not show this proposed change, and no justification has been provided to support the proposed change.
Revise the submittal to show the proposed change on the CTS markup, and provide the appropriate justification.
Licensee Response:
3.8.1-06 DC DOC 01-1 2-A CTS SR 4.8.1.1.2 DOC 01-12-A references RG 1.9, Rev. 3. Does DCPP endorse Rev. 3?
Comment:
Since RG 1.9, Rev. 3 incorporates RG 1.108 and supersedes all previous RG 1.9 revisions, does the proposed ITS delete all references to RG 1.108 and to previous revisions to RG 1.9? Has the DCPP FSAR been updated to reflect Rev. 3?
Licensee Response:
3.8.1-07 DC DOC 01-18-LS11 CTS SR 4.8.1.1.2.a.3 For DOC 01-18-LS11, the justification for the change in DG loading requirements is not adequate.
Comment: The DOC should specifically support the change, and not just state that the change is consistent with NUREG-1431.
Licensee Response:
Diablo Canyon improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.'I -08 DC DOC 01-20-LG CTS 4.8.1.1.2.b DOC 01-20-LG states that several SRs will be relocated to licensee controlled documents.
Comment: This related SR and other SRs elsewhere should be designated as a relocated item and the DOC should state where the SR willgo and what controls willbe associated with it.
'icensee Response:
3.8.1-09 DC CTS 4.8.1.1.1.b.2, The CTS SR indicates that the load sequence timer is used to sequence loads onto the offsite power circuits.
Is this correct?
Comment:
Ifso, why is the load sequencer not included as part of the LCO?
Licensee Response:
3.8.1-10 DC DOC 01-27-LS9 CTS 4.8.1.1.2.b.4 DOC 01-27-LS9 references RG 1.108.
Mowever, other DOCs reference RG 1.9, Rev. 3 which incorporates RG 1.108.
Comment:
The DOCs can not reference both documents.
The DOCs must be changed to reference only RG 1.9, Rev. 3, or some prior revision to RG 1.9 and RG 1.108.
Licensee Response:
3.8.1-11 DC DOC 01-38-LG DOC 01-39-LG CTS 4.8.1.1.3.e DOC 01-38-OG and DOC 01-39-LG state that the SR would be moved to a licensee-control document.
Comment: This SR should be designated as a relocated item and the DOCs should state we the SR willgo and what controls will be associated with it.
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Licensee Response:
3.8.1-12 DC DOC 01-44-LG CTS 3.8.1.2 Action ITS 3.8.2, ACTIONA DOC 01-44-LG is not acceptable.
The licensee should provide a detailed justification for the relocation of region the crane operations provisions of this CTS.
1 Comment: The justification should include a discussion of where it will be relocated to and what controls willbe applicable.
Licensee Response:
3.8.1-13 DC ITS SR 3.8.1.2 Note 3 STS SR 3.8.1.2 Note 3 Bases for ITS SR 3.8.1.2, STS Bases page 3.8-33 Bases for STS SR 3.8.1.2 Note 3 for STS SR 3.8.1.2 states, "[Amodified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.
When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.]" This has been adopted as Note 3 for corresponding ITS SR 3.8.1.2. The Bases for ITS SR 3.8.1.2 states, "Currently, the DGs are not able to gradually accelerate, and Note 3 does not apply. However, ifthe DG's governor is replaced with a governor with the ability to allow gradual acceleration, Note 3 may be applied."
This is a proposed difference relative to the Bases for STS SR 3.8.1.2.
Comment: The intention of the brackets around Note 3 of STS SR 3.8.1.2 is that the Note is to be utilized by plants for which it is applicable.
The Bases for ITS SR 3.8.1.2 states that Note 3 does not apply. Revise the submittal to delete Note 3 from ITS SR 3.8.1.2, and delete the reference to the Note from the Bases for ITS SR 3.8.1.2.
Licensee Response:
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.1-14 CP(3.8.1-06)
CW(3.8.1-03)
DC WC(3.8.1-03)
ITS SR 3.8.1.3 Note 4 STS SR 3.8.1.3 Note 4 CTS 4.8.1.1.2.a.3 Note 4 for STS SR 3.8.1.3 states, "This SR shall be preceded by and immediately followwithout shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7." This Note has been adopted in corresponding ITS SR 3.8.1.3, and is a proposed change relative to corresponding CTS 4.8.1.1.2.a.3.
Comment: The proposed change is not shown on the CTS markup, and no justification has been provided to support the proposed change.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
3.8.1-15 CP(3.8.1-08)
DC DOC 01-20-LG CTS 4.8.1.1.2.a.4 and 5 ITS 3.8.1 CTS 4.8.1.1.2.a.4 requires verifying that the diesel generator is aligned to provide standby power to the associated emergency buses.
CTS 4.8.1.1.2.a.5 requires verifying that the diesel engine protective relay trip cutout switch is returned to the cutout position following each diesel generator test. These requirements have not been retained in corresponding ITS 3.8.1, in conformance with the STS.
DOC 01-20-LG states that these requirements are being moved to a licensee controlled document.
Comment:
DOC 01-20-LG should be designated as a relocated item. Revise the submittal to identify the licensee controlled documents that willbe receiving this requirements.
Licensee Response:
3.8.1-16 CP(3.8.1-09)
DC DOC 01-20;LG CTS 4.8.1.1.2.b.1 ITS 3.8.1 CTS 4.8.1.1.2.b.1 requires subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service.
This requirement has not been retained in corresponding ITS 3.8.1, in conformance with the STS.
DOC 01-20-LG states that this requirement is being moved to a licensee
Diablo Canyon improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 controlled document.
Comment:
DOC 01-20-LG should be designated as a relocated item. Revise the submittal to identify the licensee controlled document that will be receiving this requirement.
Licensee Response:
3.8.1-17 DC DOC 01-18-LS CTS 4.8.1.1.2.a.3 ITS SR 3.8.1.3 CTS 4.8.1.1.2.a.3 requires verifying that the generator is synchronized and loaded to greater than or equal to 2484 kW. Corresponding ITS SR 3.8.1.3 requires verifying that each DG is synchronized and loaded to a 2370 kW and ~ 2610 kW.
Comment:
DOC 01-18-LS does not explain why the proposed change is acceptable.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
3.8.1-18 CP(3.8.1-10)
DC DOC 01-1 8-LS CTS 4.8.1.1.2.b.4 ITS SR 3.8.1.10 CTS 4.8.1.1.2.b.4 requires verifying the generator capability to reject a load of greater than or equal to 2484 kW without tripping. Corresponding ITS SR 3.8.1.10 requires verifying that each DG does not trip following a load rejection of ~ 2370 kW and s 2610 kW.
Comment:
DOC 01-18-LS does not explain why the proposed change is acceptable.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
3.8.1-19 DC DOC 01-18-LS CTS 4.8.1.1,2.b.8 ITS SR 3.8.1.14.b CTS 4.8.1.1.2.b.8 requires that'the diesel generator shall be loaded to greater than or equal to 2484 kW. Corresponding ITS SR 3.8.1.14.a requires verifying that each DG is loaded to ~
2370 kW and s 2610 kW.
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Comment:
DOC 01-18-LS does not explain why the proposed change is acceptable.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
3.8.1-20 DC ITS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 STS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 CTS 4.8.1.1.2.a.1 CTS 4.8.1 '.3.a.2 CTS 4.8.1.1.2.d ITS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 refer to a "day tank."
Corresponding CTSs 4.8.1.1.2.a.1 and 4.8.1.1.3.a.2 refer to an "engine mounted tank," while CTS 4.8.1.1.2.d refers to a "day tank." STS SRs 3.8.1.4, 3.8.1.5, and 3.8.1.6 refer to day tanks and engine mounted tanks.
Comment:
There is an apparent discrepancy between the CTS markup and the ITS. Revise the submittal to resolve this discrepancy Licensee Response:
3.8.1-21 DC DOC 01-18-LS CTS 4.8.1.1.2.b.8 ITS SR 3.8.1.14.a CTS 4.8.1.1.2.b.8 requires that the diesel generator shall be loaded to greater than or equal to
'2750 kW. Corresponding ITS SR 3.8.1.14.a requires verifying that each DG is loaded to ~
2625 kW and z 2890 kW.
Comment:
DOC 01-18-LS does not explain why the proposed change is acceptable.
Revise the submittal to provide the appropriate justification for the proposed change..
Licensee Response:
3.8.1-22 CP(3.8.1-14)
DC DOC 01-20-LG CTS 4.8.1.1.2.b.9 ITS 3.8.1 CTS 4.8.1.1.2.b.9 requires verifying that the auto connected loads to each diesel generator do not exceed the maximum rating of 2750. This requirement has not been retained in corresponding ITS 3.8.1, in conformance with the STS.
DOC 01-20-LG states that this
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 requirement is being moved to a licensee controlled document.
Comment:
DOC 01-20-LG should be designated as relocated item. Revise the submittal to identify the licensee controlled document that willbe receiving this requirement.
Licensee Response:
3.8.1-23 DC DOC 01-20-LG CTS 4.8.1.1.2.b.2 CTS Table 4.8-2a CTS Table 4.8-2b ITS SR 3.8.1.18 CTS 4.8.1.1.2.b.2 references the load sequence timer limits in CTS Table 4.8-2. CTS Tables 4.8-2a and b provide the specific limits. This material is not being retained in corresponding ITS 3.8.1.
DOC 01-20-LG states that this material willbe moved to licensee controlled documents.
Comment:
DOC 01-20-LG should be designated as relocated item. Revise the submittal to identify the licensee controlled document that will be receiving this material.
Licensee Response:
3.8.1-24 DC DOC 01-18-LS CTS 4.8.1.1.2.e ITS SR 3.8.1.15.b CTS 4.8.1.1.2.e requires that the diesel generator has operated at a load greater than or equal to 2484 kW. Corresponding ITS SR 3.8.1.15.b requires that each DG has operated at a load ~
2370 kW and s 2610 kW.
Comment:
DOC 01-18-LS does not explain why the proposed change is acceptable.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.1-25 DC DOC 01-20-LG CTS 4.8.1.1.2.b.12 ITS 3.8.1 CTS 4.8.1.1.2.b.12 requires verifying that the shutdown relay lockout feature prevents diesel generator starting only when required:
a)
Generator differential current high, or b)
Engine lube oil pressure low, or c)
Emergency stop button actuated, or d)
Overspeed trip actuated.
This requirement has not been retained in corresponding ITS 3.8.1, in conformance with the STS.
DOC 01-20-LG states that this requirement is being moved to a licensee controlled document.
Comment:
DOC 01-20-LG should be designated as relocated item. Revise the submittal to identify the licensee controlled document that willbe receiving this requirement.
Licensee Response:
3.8.1-26 DC Bases for ITS LCO 3.8.1, STS Bases markup page B 3.8-7 Bases for.STS LCO 3.8.1 The Bases for STS LCO 3.8.1 addresses each DG starting, accelerating to rated speed and voltage, and connecting to its respective ESF bus; and states, "This will be accomplished within
[10] seconds."
This statement has not been adopted in the Bases for corresponding STS LCO
3.8.1. Comment
No justification has been provided to support this proposed difference.
Revise the submittal to provide the appropriate justification for the proposed difference, or conform to the STS.
Licensee Response:
10
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.1-27 CW(3.8.'1-10)
DC Bases for ITS LCO 3.8.1, STS Bases markup page 8
Bases for STS LCO 3.8.1 The Bases for STS LCO 3.8.1 addresses fast transfer capability and interlock mechanisms with respect to the offsite AC sources.
This material has not been adopted in the Bases for corresponding ITS LCO 3.8.1.
Comment:
No justification has been provided for this proposed difference.
Revise the submittal to provide the appropriate justification for the proposed difference.
Licensee Response:
3.8.1-28 DC Bases for ITS LCO 3.8.1, STS Bases markup page B 3.8-8 Bases for STS LCO 3.8.1 The Bases for STS LCO 3.8.1 states, "Acircuit that is not connected to an ESF bus is required to have Operable fast transfer interlock mechanisms to at least two ESF buses to support Operability of that circuit." This statement has not been adopted in the Bases for corresponding ITS LCO 3.8.1.
Comment:
No justification has been provided to support this proposed difference.
Revise the submittal to provide the appropriate justification for this proposed difference.
Licensee Response:
3.8.1-29 DC Bases for ITS 3.8.1 Required Action A.1, STS Bases markup page B 3.8-9 Bases for STS 3.8.1 Required Action A.1 The Bases for Required Action A.1 for ITS 3.8.1 states, "Ifone required offsite circuit to only one Class 1E 4160 VAC bus is inoperable, SR 3.8.1.1 needs to be performed only for the affected Class 1E 4160 VAC bus.
It is not necessary to perform SR 3.8.1
~ 1 for the other Class 1E 4160 VAC buses."
This is a proposed difference relative to the Bases for Required Action A.1 for corresponding ITS 3.8.1.
Comment:
No justification has been provided to support this proposed difference.
Revise the submittal to provide the appropriate justification for this proposed difference, or conform to the STS.
11
Diablo Canyon improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Licensee Response:
3.8.1-30 DC Bases for ITS 3.8.1 Required Action B.2, STS Bases markup page B 3.8-15 Some of the material in the Bases for Required Action B.2 for ITS 3.8:1 contains both the redline and strikeout features.
Comment: The status of this material needs to be clarified by the licensee, that is, which material is proposed for inclusion in the Bases, and which is not. Revise the submittal to clarify the status of the proposed Bases material.
Licensee Response:
3.8.1-31 DC Bases for ITS 3.8.1 Required Action B.2, STS Bases markup page B 3.8-16 The Bases for Required Action B.2 for ITS 3.8.1 states, "For example, declaring DG 1-1 inoperable would require maintaining the turbine driven AFW pump and motor driven pump 1-2 Operable, while declaring'G 1-2 inoperable would only require any 2 of the 3 AFW pumps Operable."
This is a proposed difference relative to the Bases for Required Action B.2 for corresponding STS 3.8.1.
Comment The Bases does not provide sufficient information for this example.
Revise the Bases to explain why declaring DG 1-1 inoperable would require maintaining the turbine driven AFW pump and motor driven pump 1-2 Operable; and explain why declaring DG 1-2 inoperable would only require any 2 of the 3 AFW pumps Operable.
Licensee Response:
3.8.1-32 DC Bases for ITS SR 3.8.1.6, STS Bases page 3.8-38 Bases for STS SR 3.8.1.6 The Bases for STS SR 3.8.1.6 states', "... and the controls and control systems for automatic fuel transfer systems are Operable." This material has not been adopted in the Bases for corresponding ITS SR 3.8.1.6.
Comment:
No justification has been provided to support the proposed diffe'rence.
Revise the submittal to provide the appropriate justification.
12
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Licensee Response:
3.8.1-33
)
CP(3.8.1-20)
DC WC(3.8.117)
Bases for ITS SR 3.8.1.8, STS Bases page 3.8-40 Bases for STS SR 3.8.1.8 Bases for ITS SR 3.8.1.9, STS Bases page 3.8-42 Bases for STS SR 3.8.1.9 Bases for ITS SR 3.8.1.10, STS Bases page 3.8-45 Bases for STS SR 3.8.1.10 Bases for ITS SR 3.8.1.11, STS Bases page 3.8-49 Bases for STS SR 3.8.1.11 Bases for ITS SR 3.8.1.12, STS Bases page 3.8-51 Bases for STS SR 3.8.1.12 Bases for ITS SR 3.8.1.13, STS Bases page 3.8-52 Bases for STS SR 3.8.1.13 Bases for ITS SR 3.8.1.14, STS Bases page 3.8-55 Bases for STS SR 3.8.1.14 Bases for ITS SR 3.8.1.16, STS Bases page 3.8-57 Bases for STS SR 3.8.1.16 Bases for ITS SR 3.8.1.17, STS Bases page 3.8-59 Bases for STS SR 3.8.1.17 Bases for ITS SR 3.8.1.18, STS Bases page 3.8-60 Bases for STS SR 3.8.1.18 Bases for ITS SR 3.8.1.19, STS Bases page 3.8-63 Bases for STS SR 3.8.1.19 The Bases for ITS SRs 3.8.1.8, 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.12, 3.8.1.13, 3.8.1.14, 3.8.1.16, 3.8.1.17, 3.8.1
~ 18, and 3.8.1.19 state, "This Note does not prohibit the application of LCO 3.0.5." This is a proposed difference relative to the Bases for STS SRs 3.8.1.8, 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.12, 3.8.1.13, 3.8.1.14, 3.8.1.16, 3.8.1.17; 3.8.1.18, and 3.8.1.19.
Comment:
The Notes for ITS SRs 3.8.1.8, 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.12, 3.8.1.13, 3.8.1.14, 3.8.1.16, 3.8.1.17, 3.8.1.18, and 3.8.1
~ 19 do not provide any exceptions.
The proposed differences appear to be in conflict with the Notes.
No justification has been provided to support the proposed differences.
Revise the submittal to provide the appropriate justification, or conform to the STS.
Licensee Response:
13
1
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.1-34 DC Bases for ITS SR 3.8.1.15, STS Bases markup page B 3.8-56 Bases for STS SR 3.8.1.15 The Bases for ITS SR 3.8.1.15 states, ".;. test data and manufacturer recommendations, which
'ndicate 45 minutes is sufficient..." This is a proposed difference relative to the Bases for STS SR 3.8.1.15.
Comment:
No justification has been provided for this proposed difference. Revise the submittal to provide the appropriate justification, or conform to the STS.
Licensee Response:
3.8.1-35 DC Bases for ITS SR 3.8.1.18, STS Bases markup page B 3.8-59 Bases for STS SR 3.8.1.18 The Bases for ITS SR 3.8.1.18 states, "With an ESF timer found to be outside the range of acceptable settings, the corresponding DG shall be declared inoperable in Modes 1, 2, 3, and 4, and the corresponding Condition followed. With an Auto Transfer timer found to be outside the range of acceptable settings, the corresponding DG shall be declared inoperable in all Modes." This is a proposed difference relative to the Bases for STS SR 3.8.1.18.
Comment: The proposed difference appears to contain requirements that would more appropriately appear'directly in ITS 3.8.1 as two Conditions and their associated required Actions rather than the Bases.
Revise the submittal to provide these requirements as Conditions and Required Actions in ITS 3.8.1, and provide the appropriate justification.
Licensee Response:
14
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.1 Beyond Scope Item DC DOC 01-27-LS ITS SR 3.8.1.10 CTS 4.8.1.1.2.b.4 CTS 4.8.1.1.2.b.4 states, "The generator voltage shall not exceed 4580 volts during and following the load rejection." Corresponding ITS SR 3.8.1.10 requires maintaining voltage
~ 6200 volts during and following a load rejection. This proposed change is beyond the conversion review scope and has not been identified as such by the licensee.
Licensee Response:
15
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.2, AC Sources - Shutdown 3.8.2-01 CP(3.8.2-05)
CW(3.8.2-02)
DC WC(3.8.2-02)
DOC 01-44-LG CTS 3/4.8.1.2 Action ITS 3.8.2 The Action for CTS 3/4.8.1.2 states, "... or crane operation with loads over the fuel storage pool." This material is not being retained in corresponding ITS 3.8.2 in accordance with the STS: DOC 01<4-LG states that this material is being moved to licensee controlled documents Comment:
DOC 01-44-LG does not provide an adequate justification for relocating the CTS requirements regarding crane operation with heavy load over the spent fuel pool. Revise the submittal to specify which licensee controlled documents will be receiving this material.
Licensee Response:
3.8,2-02 DC JFD 3.8-35 ITS 3.8.2 Actions Note STS 3.8.2 Actions Bases for ITS 3.8.2 Actions, STS Bases markup page B 3.8-75 The Actions Note for ITS 3.8.2 states, "LCO 3.0.3 is not applicable." This is a proposed difference relative to the Actions for corresponding STS 3.8.2, and is a proposed change relative to the CTS. JFD 3.8-35 references TSTF-36.
Comment: TSTF-36 has been rejected.
Revise the submittal to conform to the STS.
Licensee Response:
3.8.2-03 CP(3.8.2-07)
CW(3.8.2-03)
DC WC(3.8.2-03)
DOC 01<7-LS CTSs 4.8.1.2, 4.8.1.1.1.b.1 and 4.8.1.1.2.c ITS SRs 3.8.2.1, 3.8.1.8 and 3.8.1.20 Bases for ITS SR 3.8.2.1, STS Bases markup page B 3.8-78 CTS 4.8.1.2 states that CTSs 4.8.1.1.1.b.1 and 4.8.1.1.2.c are applicable in Modes 5 and 6.
ITS SR 3.8.2.1 states that corresponding ITS SRs 3.8.1.8 and 3.8.1.20 are not applicable in Modes 5 and 6, in conformance with the STS.
16
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Comment:
DOC 01-47-LS does not explain why the proposed changes are acceptable.
Revise the submittal to provide the appropriate justification for the proposed changes.
Licensee Response:
3.8.2-04 DC(See 3.8.2-03)
JFD 3.8-17 DOC 01-47-LS CTS 4.8.1.2 CTS 4.8.1.1.2.b.7.c ITS SRs 3.8.2.1 and 3.8.1.13 Bases for ITS SR 3.8.2.1, STS Bases markup page B 3.8-78 STS SR 3.8.2.1 states that STS SR 3.8.1.13 is applicable in Modes 5 and 6. This requirement has not been adopted in corresponding ITS SR 3.8.2.1.
This is also a proposed change relative to corresponding CTS 4.8.1.2 which states that corresponding CTS 4.8.1.1.2.b.7.c is applicable in Modes 5 and 6.
Comment:
JFD 3.8-17 does not explain why the proposed difference with the STS is acceptable.
Revise the submittal to explain why the proposed difference is acceptable, or conform to the STS.
DOC 01-47-LS does not explain why the proposed change is acceptable.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
3.8.2-05 DC(See 3.8.2-03/04)
JFD 3.8-17
'ITS SR 3.8.2.1 Note STS SR 3.8.2.1 Note STS SR 3.8.1
~ 13 Bases for ITS SR 3.8.2.1, STS Bases markup page B 3.8-78 This comment is applicable only if ITS SR 3.8.1.13 is applicable in Modes 5 and 6.
The Note for STS SR 3.8.2.1 states that SR 3.8.1.13 is not required to be performed.
This allowance has not been adopted in the Note for corresponding ITS SR 3.8.2.1.
Comment:
JFD 3.8-17 does not explain why the proposed difference is acceptable.
Revise the submittal to explain why the proposed difference is acceptable.
Licensee Response:
17
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.2-06 DC Bases for ITS LCO 3.8.2.1, STS Bases markup page B 3.8-73 Bases for STS LCO 3.8.2.1 The Bases for STS LCO 3.8.2.1 states, "This sequence must be accomplished within [10]
seconds."
This requirement has not been adopted in the Bases for corresponding ITS LCO 3.8.2.1.
Comment:
No justification has been provided to support this proposed difference.
Revise the submittal to provide the appropriate justification for the proposed difference.
Licensee Response:
3.8.2-07 DC Bases for ITS LCO 3.8.2.1, STS Bases markup page B 3.8-73 Bases for STS LCO 3.8.2.1 The Bases for STS LCO 3.8.2.1 states, "These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby at ambient conditions." This has not been adopted in the Bases for corresponding ITS LCO 3.8.2.1.
Comment:
No justification has been provided to support this proposed difference.
Revise the submittal to provide the appropriate justification for the proposed difference.
Licensee Response:
3.8.2-08 DC Bases for ITS LCO 3.8.2.1, STS Bases markup page B 3.8-74, third paragraph Bases for STS LCO 3.8.2.1 The Bases for ITS LCO 3.8.2.1 states that with administrative controls in place, it is acceptable for Class 1E AC electrical power distribution subsystems to be cross tied during shutdown allowing a single DG to supply the required Class 1E AC electrical power distribution subsystems.
This is a proposed difference relative to the Bases for corresponding ITS LCO 3.8.2.1.
Comment:
No justification has been provided to support this proposed difference.
Revise the submittal to provide the appropriate justification for the proposed difference.
18
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Licensee Response:
3.8.2 No Beyond Scope items 19
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.3, Diesel Fuel Oil, Lube Oil, and Startin Air 3.8.03-01 CW(3.8.03-01)
DC WC(3.8.03-01)
DOC 0149-LS ITS 3.8.3'Condition A and Required Action A.2 Condition A for ITS 3.8.3 addresses the storage tank fuel level for one or more DGs.
Associated Required Action A.2 requires to restore the fuel oil level to within limits with a Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. These are proposed changes relative to the CTS.
Comment:
DOC 01-49-LS does not explain why these proposed changes are acceptable.
Revise the submittal to provide the appropriate justification for the proposed changes.
Licensee Response:
3.8.03-02 DC DOC 01<9-LS ITS 3.8.3 Required Actions A.1.1 and A.1.2 Required Action A.1.1 for ITS 3.8.3 requires verifying the combined fuel oil level ~ 29,000 gallons for each unit operating in Modes 1, 2, 3, or 4. Required Action A.1.2 for ITS 3.8.3 requires verifying the combined fuel oil level ~ 23,000 gallons for each unit operating in Modes 5 or 6.- These are proposed changes relative to the CTS.
Comment:
DOC 01%9-LS does not provide specific technical justification for these values.
Revise the submittal to provide the appropriate justification for these values.
Licensee Response:
3.8.03-03 CW(3.8.03-03)
DC WC(3.8.03-03)
DOC 01<8-M ITS SR 3.8.3.2 Bases for ITS SR 3.8.3.2, STS Bases markup page B 3.8-89 STS SR 3.8.3.2 ITS 3.8.3 Condition B Bases for ITS 3.8.3 Required Action B.1, STS Bases markup page B 3.8-85 STS SR 3.8.3.2 requires verifying the lubricating oil inventory. This requirement has been adopted as corresponding ITS SR 3.8;3.2 which requires verifying lubricating oil inventory is ~
650 gal. Condition B for corresponding ITS 3.8.3 addresses both units in Mode 1, 2, 3, or 4 with lube oil inventory(650 gal and > 610 gal, or one unit in Mode 1, 2, 3, or 4 and one unit in 20
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Mode 5 or 6 with lube oil inventory < 590 gal and > 520 gal. These are proposed changes relative to the CTS.
Comment:
DOC 01-48-M does not provide specific technical justification for these values.
Revise the submittal to provide the appropriate justiTication for these values.
Licensee Response:
3.8.03-04 DC DOC 01-49-LS ITS 3.8.3 Condition D and Required Action D.1 STS 3.8.3 Condition D and Required Action D.1 Condition D for STS 3.8.3 addresses new fuel oil properties not within limits. Required Action D.1 for STS 3.8.3 requires restoring the stored fuel oil properties to within limits with a Completion Time of 30 days. This requirement has been adopted as Condition D and Required Action D.1 for corresponding ITS 3.8.3, and is a proposed change relative to the CTS.
Comment:
DOC 01-49-LS does not explain why this proposed change is acceptable.
Revise the submittal to provide the appropriate justification for the proposed change.
Licensee Response:
3.8.03-05 CP(3.8.03-01)
CW(3.8.03-04)
DC WC(3.8.03-05)
DOC 01-48-M ITS SR 3.8.3;4 STS SR 3.8.3.4 ITS 3.8.3 Condition E Bases for ITS 3.8.3 Required Action E.1, STS Bases markup page B 3.8-87 STS SR 3.8.3.4 requires verifying the DGs air start receiver pressure.
This requirement has been adopted as corresponding ITS SR 3.8.3.4 which requires verifying that each DG has at least one air start receiver with a pressure
~ 180 psig. Condition E for ITS 3.8.3 addresses one or more DGs with both starting air receiver pressures
< 180 psig and ~ 150 psig. These are proposed changes relative to the CTS.
Comment:
DOC 01-48-M does not provide specific justification for these values.
Revise the submittal to provide the appropriate justiTication for these values.
Licensee Response:
21
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.03-06, DC JFD 3.8-18 DOC 01-64-M ITS SR 3.8.3.6 ITS 3.8.3 Condition F Bases for ITS 3.8.3 Required Action F.1, STS Bases markup page B 3.8-87 I
ITS SR 3.8.3.6 requires verifying that each DG turbocharger air assist air receiver pressure is
~ 180 psig. Condition F for ITS 3.8.3 addresses one or more DGs with turbocharger air assist air receiver pressures
< 180 psig and ~ 150 psig. These are proposed differences relative to the STS and proposed changes relative to the CTS.
Comment:
JFD 3.8-18 and DOC 01-64-M do not provide specific justification for these values.
Revise the submittal to provide the appropriate justification for these values.
Licensee Response:
3.8.03-07 DC DOC 01-48-M DOC 01-49-LS JFD 3.8-10 ITS 3.8.3 Condition G ITS 3.8.3 Condition H Condition G for ITS 3.8.3 states, "Required Action and associated Completion Time not met."
Condition H for ITS 3.8.3 states, "Required Action and associated Completion Time of Condition A, B, C, or D not met."
Comment:
Since the Required Actions and associated Completion Times of Conditions A, B, C, and D are specifically addressed by Condition H, it appears that Condition G is intended to address only the Required Action and associated Completion Time of Conditions E or F not met.
Revise the submittal to have Condition G specifically refer to the Required Action and associated Completion Time of Conditions E or F not met.
Licensee Response:
22
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8;1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.03-08 'C DOC 01-48-M DOC 0149-LS DOC 01-64-M JFD 3.8-10 ITS 3.8.3 Condition G and Required Action G.1 ITS 3.8.3 Condition H ITS 3.8.3 Condition G states, "One or more DG's diesel fuel oil, lube oil, turbocharger air assist or starting air subsystem not within limits for reasons other than Condition A, B, C, D, E, or F."
ITS 3.8.3 Condition H states, "Fuel oil storage tanks or lube oil not within limits for reasons other than Conditions A, B, C, or D." These are proposed changes relative to the CTS.
Comment: These proposed changes are not shown 'on the CTS markup.
Revise the submittal to show these proposed changes on the CTS markup.
Conditions G and H appear to be partially duplicative in that both of the Conditions address Conditions A, B, C, and D. It appears that Condition G should only refer to Conditions E and F, and not to Conditions A, B, C, and D. Revise the submittal to eliminate this duplication.
DOC 01-48-M, DOC 01-49-LS, and DOC 01-64-M do not explain why these proposed changes are acceptable.
Revise the submittal to provide the appropriate justification for the proposed changes.
Licensee Response:
3.8.03-09 DC ITS 3.8.3 Condition G ITS 3.8.3 Condition H Bases for ITS 3.8.3 Required Action G.1, STS Bases markup page B 3.8-87 The Bases for Required Action G.1 for ITS 3.8.3 refers to Conditions B, E, and F. Condition H for ITS 3.8.3 refers to Condition B.
Comment:
It appears that the reference to Condition B that appears in the Bases for Required Action G.1 should be deleted.
Revise the Bases for Required Action G.1 to delete the reference to Condition B.
Licensee Response:
23
U 1
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.03-10 DC JFD 3.8-10 DOC 01-48-M DOC 0149-LS JFD 3.8-10 ITS 3.8.3 Required Actions H.1, H.2, and H.3 ITS 3.8.3 Required Actions H.1, H.2, and H.3 require declaring all DGs on associated unit(s) inoperable with a Completion Time of immediately, and ifthe associated unit is in Modes 1, 2, 3, or.4, be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and be in Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This is a proposed difference relative to corresponding STS 3.8.3 and a proposed change relative to the CTS.
Comment: JFD 3.8-10, DOC 0148-M, and DOC 0149-LS do not explain why the proposed difference and change are acceptable.
Revise the submittal to provide the appropriate'ustifications.
Licensee Response:
3.8.03-11 DC ITS 3.8.3 Condition H Bases for ITS 3.8.3 Required Actions H.1, H.2, and H.3, STS Bases markup page B 3.8-88 Condition H for ITS 3.8.3 refers to Conditions A, B, C, or D. The Bases for Required Actions H.1, H.2, and H.3 for ITS 3.8.3 refers to Conditions A, C, and D and describes the events associated with those Conditions.
However, the Bases does not refer to Condition B nor does the Bases describe it.
Comment:
It appears that the Bases for Required Actions H.1, H.2, and H.3 should also refer to Condition B. Revise the Bases for Condition H to also refer to Condition B.
Licensee Response:
3.8.03-12
'W(3.8.03-05)
DC WC(3.8.03-07)
DOC 01-01-A ITS SR 3.8.3.1 CTS 4.8.1.1.3.a.1 CTS 4.8.1.1.3.a.1 requires verifying the fuel level in the fuel storage tank. Corresponding ITS SR 3.8.3.1 requires verifying that the fuel oil storage tanks contain combined storage within limits.
Commen't:
The format for this SR appears to be reversed from NUREG-1431 and is 24
n
Diablo Canyon Improved TS RevIew Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 inconsistent with SR 3.8.3.2 and SR 3.8.3.4.
DOC 01-01-A does not address the proposed change.
Revise the submittal to provide the appropriate justification for the proposed change and revise SR to incorporate the limitrequirements to e consistent with the presentation in NUREG-1431.
Licensee Response:
3.8.03-13 CW(3.8.03-09)
Bases for ITS SR 3.8.3.4, STS Bases markup page DC B 3.8-93 WC(3.8.03-10)
Bases for STS SR 3.8.3.4 The Bases for STS SR 3.8.3.4 states, "[Astart cycle is defined by the DG vendor, but usually is measured in terms of time (seconds of cranking) or engine cranking speed.]
The Bases for corresponding ITS SR 3.8.3.4 states, "Each start cycle is 15 seconds of cranking."
Comment:
No justification has been provided to support this proposed value.
Revise the submittal to provide the appropriate justification for this value.
Licensee Response:
3.8.3 No Beyond Scope items 25
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.9, Distribution Systems - Operating 3.8.9-01 DC Bases for ITS 3.8.9 Required Action A.1, STS Bases markup page B 3.8-155 Bases for STS 3.8.9 Required Action A.1 ITS 3.8.9 Condition A CTS 3/4.8.2.1 Action a The Bases for STS 3.8.9 Required Action A.1 refers to "With one or more required AC buses...
in one train inoperable..." 'The Bases for Required Action A.1 for corresponding ITS 3.8.9 refers to one or more required Class 1E AC electrical power subsystems inoperable and a loss of function has not yet occurred.
Condition A for corresponding ITS 3.8.9 addresses "One AC electrical power distribution subsystem inoperable," and Action a for corresponding CTS 3/4.8.2.1 addresses "With one of the required 4160 volt and/or associated 480 volt vital buses not energized..."
Comment:
No justification has been provided to support the proposed Bases difference. The ITS Bases discussion appears to be discrepant relative to Condition A for ITS 3.8.9, and appears to be a proposed change relative to the CTS. Revise the submittal to provide the appropriate justification for the proposed difference, and clarify the intent of the Bases discussion.
Licensee Response:
3.8.9-02 DC Bases for ITS 3.8.9 Required Action B.1, STS Bases markup page B 3.8-157 Bases for STS 3.8.9 Required Action B.1 ITS 3.8.9 Condition B CTS 3/4.8.2.1 Action b The Bases for STS 3.8.9 Required Action B.1 refers to "With one AC vital bus inoperable..."
The Bases for Required Action B.1 for corresponding ITS 3.8.9 refers to one or more required 120 VACvital bus subsystems inoperable and a loss of function has not yet occurred.
Condition B for corresponding ITS 3.8.9 addresses "One 120 VACvital bus subsystem inoperable," and Action b for corresponding CTS 3/4.8.2.1 addresses "With one vital instrument AC bus not energized..."
Comment:
No justification has been provided to support the proposed Bases difference. The ITS Bases discussion appears to be discrepant relative to Condition B for ITS 3.8.9, and appears to be a proposed change relative to the CTS. Revise the submittal to provide the appropriate justification for the proposed difference, and clarify the intent of the Bases discussion.
26
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 Licensee Response:
3.8.9-03 DC Bases for ITS 3.8.9 Required Action C.1, STS Bases markup page B 3.8-161 Bases for STS 3.8.9 Required Action C.1 ITS 3.8.9 Condition C CTS 3/4.8.2.1 Action d The Bases for STS 3.8.9 Required Action C.1 refers to "With DC bus(es) in one train inoperable
..." The Bases for Required Action C.1 for corresponding ITS 3.8.9 refers to one or more DC electrical power distribution subsystems inoperable and a loss of function has not yet occurred.
Condition C for corresponding ITS 3.8.9 addresses "One DC electrical power distribution subsystem inoperable," and Action d for corresponding CTS 3/4.8.2.1 addresses "With one DC bus not energized..."
I Comment:
No justification has been provided to support the proposed Bases difference. 'The ITS Bases discussion appears to be discrepant relative to Condition C for ITS 3.8.9, and appears to be a proposed change relative to the CTS. Under Action C.1, the proposed addition to the Bases regarding a loss of function not yet occurring is not acceptable and should be deleted from the Bases.
Condition C and Action C.1 address gran, DC power distribution subsystem inoperable, not multiple inoperabilities. Also, addition of "or more" to the first sentence is not acceptable for the same reason.
Revise the submittal to provide the appropriate justification for the proposed difference.
Licensee Response:
3.8.9 No Beyond Scope items 27
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.10, Distribution S stems - Shutdown DOC 03-06-LS ITS LCO 3.8.10 STS LCO 3.8.10 CTS 3.8.2.2 3.8.10-01 CP(3.8.10-01)
CW(3.8.10-01)
DC WC(3.8.10-01) r STS LCO 3.8.10 specifies, "The necessary portion of the AC, DC, and AC vital bus electrical power distribution subsystems
..." This requirement has been adopted as corresponding ITS LCO 3.8.10 which specifies, "The necessary portion of the Class 1E AC, DC, and 120 VACvital bus electrical power distribution subsystems
.. ~" Corresponding CTS 3.8.2.2 states, "As a minimum, the following electrical buses shall be energized in the specified manner:..." DOC 03-06-LS merely restates the proposed change.
Comment:
DOC 03-06-LS does not explain why the proposed change is acceptable.
Revise the submittal to confirm that the "minimum electrical buses" required in the CTS LCO 3.8.10 and the "necessary portion of the AC, DC, and AC vital bus..." in the ITS LCO 3.8.10 is the same.
Licensee Response:
3.8.10-02 CP(3.8.10-03)
CW(3.8.10-03)
DC WC(3.8.10-03)
DOC 03-03-LS CTS 3/4.8.2.2 Action ITS 3.8.10 Condition A and Required Action A.2.4 STS 3.8.10 Condition A and Required Action A.2.4 Condition A for STS 3.8.10 addresses, "One or more required AC, DC, or AC vital bus electrical power distribution subsystems inoperable." This has been adopted as Condition A for corresponding ITS 3.8.10, and is a proposed change relative to the Action for corresponding CTS 3/4.8.2.2 which states, "With any of the above required electrical buses inoperable..."
Required Action A.2.4 for STS 3.8.10 states, "Initiate actions to restore required AC, DC, and AC vital bus electrical power distribution subsystems to Operable status." This requirement has been adopted as Required Action A.2.4 for corresponding ITS 3.8.10, and is a proposed change relative to the Action for corresponding CTS,3/4.8.2.2 which states, ".
~. initiate corrective action to energize the required electrical buses in the specified manner..."
Comment:
DOC 03-03-LS does not address these proposed changes.
Revise the submittal to provide the appropriate justification for these proposed changes.
Licensee Response:
28
Diablo Canyon Improved TS Review Comments ITS Section 3.8, Electrical Power Systems 3.8.1, 3.8.2, 3.8.3, 3.8.9, 3.8.10 3.8.10-03 DC
, JFD 3.8-35 ITS 3.8.10 Actions Note STS 3.8.10 Actions Bases for ITS 3.8.10 Actions, STS Bases markup page B 3.8-172 The Actions Note for ITS 3.8.10 states, "LCO 3.0.3 is not applicable." This Note is a proposed difference with corresponding STS 3.8.10. JFD 03-08-35 states that this proposed difference is consistent with TSTF-36.
Comment: TSTF-36 has not been approved yet. Revise the submittal to conform to the STS.
Licensee Response:
3.8.10-04 DC Bases for ITS LCO 3.8.10, STS Bases markup page B 3.8-170 Bases for STS LCO 3.8.10 The Bases for ITS LCO 3.8.10 describes distribution and source arrangements for the AC, DC, and 120 VACvital bus electrical power subsystems.
This is a proposed difference relative to the Bases for corresponding STS 3.8.10.
Comment:
No justification has been provided to support this proposed difference. Revise the submittal to provide the appropriate justification, or conform to the STS. The justification shall include an evaluation of all of the events identified in the USAR that are postulated to occur during the Applicability, with a determination of the acceptability of the distribution and source arrangements described by the proposed Bases.
The evaluation should confirm that all of the equipment that is assumed to operate to mitigate the various postulated events can still be relied on to operate.
Also explain the use of the startup cross-tie feeder breaker to cross-tie an.
D/G to another bus.
Has this administration control been a part of the CTS?
Is "another bus" part of the required OPERABLE AC subsystem?
Licensee Response:
3.8.10 No Beyond Scope items 29
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