ML16342E164
| ML16342E164 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/09/1998 |
| From: | Steven Bloom NRC (Affiliation Not Assigned) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| TAC-M98984, TAC-M98985, NUDOCS 9807160234 | |
| Download: ML16342E164 (16) | |
Text
Mr, Gregory M. Rueger, or Vice President and'General Manager Pacific Gas and Electric Company Nuclear Power Generation N9B P.O. Box 770000 San Francisco, California 94177 July 9, 1998
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 8 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 1.0, Use and Application, as discussed in the enclosure.
Since you worked with three other utilities in preparing your submittal, the enclosure contains the request for additional information (RAI) questions for all four utilities. However, you need only reply to the RAI questions associated with Diablo Canyon Power Plant, Unit Nos.
1 and 2, as identiTied in the table within the enclosure.
To assist the staff in maintaining its review schedule, please respond to the questions pertaining to Diablo Canyon Power Plant, Unit Nos.
1 and 2 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, Timothy J. Polich at (301) 415-1038.
Sincerely, Original Signed by William Bateman for 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 DISTRIBUTION:
~
D'ocket PUBLIC PDIV-2 Reading EAdensam (EGA1)
WBateman S Bloom JLuehman OGC ACRS PGwynn, RIV WJohnson, RIV WBeckner EPeyton OFC D
2 NAME I
DATE 7/
/98 PD4-2 eyo 7/
/98 TSB WBeckner 7/ 1/98 OFFICIAL RECORD COPY 9807ih0234 980709 PDR ADQCK 05000275 P
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Mr. Gregory M. Rueger July 9, 1998 cc w/encl:
NRC Resident Inspector Diablo Canyon Nuclear Power Plant c/o 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 Mr. Robert P. Powers Vice President and Plant Manager Diablo Canyon Nuclear Power Plant P. O. Box 56 Avila Beach, California 93424 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Telegram-Tribune ATTN: 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 ATTN: Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D Monterey, California 93940
FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS SECTION 1.0 - USE AND APPLICATION 1.1 Definitions 1.1-1 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:
IfNRC 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 will not be reviewed on a plant-specific basis.
In addition, correct the Diablo Canyon ITS markup for COT.
FLOG Response:
1.1-2 CTS 1.3, Analog Channel Operations Test CTS 1.5, Channel Calibration 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 1-32-A ITS 1.1, Channel Calibration ITS 1.1, Channel Operational Test (COT)
ITS 1.1, Trip Actuating Device Operational Test (TADOT)
JFD 1.1-1 These are changes to both the CTS and the STS and are considered generic changes.
Therefore, they are beyond the scope of the conversion review. The DOC states that these changes are consistent with TSTF-64.
0 t
Comment:
IfNRC has not approved TSTF-64 by the time the draft safety evaluation is prepared, then these changes should be withdrawn from the conversion submittal at that time.
These changes will not be reviewed on a plant-specific basis.
FLOG Response:
1.1-3 CTS 1.9, Core Alteration DOC 1-06-LS The DOC does not provide adequate technical justification to support this change.
Comment:
The associated NSHC for this change appears to provide the necessary justification. Revise the DOC by incorporating the information contained in the associated NSHC.
FLOG Response:
1.1Q CTS 1.13, Engineered Safety Features Response Time [Diablo Canyon, WolfCreek, and Callaway]
CTS 1.14, Engineered Safety Features Response Time [Comanche Peak]
CTS 1.27, Reactor Trip System Response Time [WolfCreek and Callaway]
CTS 1.29, Reactor Trip System Response Time [Diablo Canyon and Comanche Peak]
DOC 1-08-A ITS 1.1, Engineered Safety Feature (ESF) Response Time ITS 1.1, Reactor Trip System (RTS) Response Time JFD 1.1-5 The definitions for ESF Response Time and RTS Response Time are proposed to be revised to substitute the word "verified" in lieu of "measured."
The JFD states that this change is made to be consistent with STS SR 3.3.1.6, SR 3.3.2.10, and TSTF-111, Rev.1.
However, the DOC does not refer to TSTF-111 applicability for this change.
Comment:
IfNRC has not approved TSTF-111 by the time the draft safety evaluation is prepared, then this change should be withdrawn from the conversion submittal at that time.
This change willnot be reviewed on a plant-specific basis.
Also, revise the DOC to include TSTF-111 applicability.
FLOG Response:
1.1-5 DOC 1-17-A ITS 1.1, Pressure and Temperature Limits Report (PTLR)
JFD 1.1-6 The definition of Pressure and Temperature Limits Report (PTLR) is added to be consistent with STS. While this is acceptable, the changes to both CTS and ITS to include the maximum allowable PORV liftsettings, arming temperature associated with the cold overpressure mitigation system (COMS) [for Callaway only], and arming temperature associated with low temperature overpressurization protection (LTOP) [for Comanche Peak and WolfCreek] are generic and are beyond the scope of the conversion review. JFD 1.1-6 states that these changes are consistent with traveler WOG-67, Rev.1.
Comment:
Provide the current status of WOG-67.
IfWOG-67 is not approved by the TSTF, then this change should be withdrawn from the conversion submittal at the time of the TSTF rejection.
IfWOG-67 has not been acted upon by TSTF, or has been approved by the TSTF, but not been approved by the NRC at the time the draft safety evaluation is prepared, then this change should be withdrawn from the conversion submittal. This change will not be reviewed on a plant-specific basis.
FLOG Response:
1.1-6 CTS 1.24, Purge - Purging [Callaway and WolfCreek]
CTS 1.26, Purge - Purging [Diablo Canyon and Comanche Peak]
CTS 1.38, Ventilation Exhaust Treatment System
[WolfCreek]
CTS 1.39, Ventilation Exhaust Treatment System
[Callaway]
~
CTS 1.39, Venting [WolfCreek]
CTS 1.40, Venting CTS 1.40, Waste Gas Holdup System
[WolfCreek]
CTS 1.41, Waste Gas Holdup System
[Callaway]
CTS 1.41, Ventilation Exhaust Treatment System
[Diablo Canyon]
CTS 1.42, Venting [Diablo Canyon]
DOC 1-15-A The DOC states that the definitions of HVAC systems and functions are deleted to be consistent with STS. While this is acceptable, the DOC does not provide sufficient justifications as to why this change is considered to be administrative.
Comment:
Revise DOC by providing. additional justification for this administrative change.
'LOG Response:
E I
J
-4 1.1-7 CTS 1.40, Waste Gas Holdup System
[WolfCreek]
CTS 1.41, Waste Gas Holdup System
[Callaway and Comanche Peak]
DOC 1-15-A DOC 1-31-A For Callaway and WolfCreek, th'e DOC in reference to the subject CTS is DOC 1-15-A.
However, the subject CTS refers to DOC 1-31-A for Comanche Peak.
Comment: Clarify this deviation and, ifappropriate, revise the CTS markup with the correct DOC for the particular plant.
FLOG Response:
1
~ 1-8 CTS 1.25, Quadrant Power Tilt Ratio [WolfCreek and Callaway]
CTS 1.27, Quadrant Power Tilt Ratio [Comanche Peak]
DOC 1-18-A ITS 1.1, Quadrant Power Tilt Ratio (QPTR)
The DOC states that the portion of the QPTR definition dealing with an inoperable excore detector is addressed in the Conditions and Surveillance Requirements of ITS 3.2.4. The CTS markup does not reflect this statement since it still contains the definition portion dealing with an inoperable excore detector.
Comment:
Revise CTS markup to reflect associated DOC and ITS.
FLOG Response:
1.1-9 CTS Table 1.2, Operational Modes, added footnotes (b) and (c)
DOC 1-25-LS ITS Table 1.1-1, Modes, footnotes (b) and (c)
JFD 1.1-8 New footnotes (b) and (c) are proposed to be added per traveler TSTF-88. This is a change to both the CTS and the STS and is considered a generic change.
Therefore, it is beyond the scope of the conversion review.
Comment:
IfNRC has not approved TSTF-88 by the time the draft safety evaluation is prepared, then this change should be withdrawn from the conversion submittal at that time.
This change will not be reviewed on a plant-specific basis.
FLOG Response:
e 1.4 Frequency 1.4-1 DOC 1-26-A ITS Example 1.4-4 ITS Example 1.4-5 JFD 1.1-3 JFD 1.1-11 Additional examples, Example 1.4-4 and 1.4-5, are proposed to be included in ITS. The DOC and the JFDs state that these ITS changes are to incorporate travelers WOG-74 and WOG-90.
Comment:
Provide the current status of WOG-74 and WOG-90.
IfWOG-74 and WOG-90 are not approved by the TSTF, then these changes should be withdrawn from the conversion submittal at the time of the TSTF rejection.
IfWOG-74 and WOG-90 have not been acted upon by TSTF, or have been approved by the TSTF, but not approved by the NRC at the time the draft safety evaluation is prepared, then these changes should be withdrawn from the conversion submittal. These changes willnot be reviewed on a plant-specific basis.
FLOG Response:
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V 1.0 RAI APPLICABILITY 0
RAI NO.
1.1-1 1.1-2 1.1-3 1.1-4.
DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY X
X X
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