ML16342E174
| ML16342E174 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/15/1998 |
| From: | Steven Bloom NRC (Affiliation Not Assigned) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| TAC-M98984, TAC-M98985, NUDOCS 9807200394 | |
| Download: ML16342E174 (16) | |
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 July 15, 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 & 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.
PaciTic 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 5.0, Administrative Controls, 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 identified 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 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
~BU 0
, Docket-PUBLIC PDIV-2 Reading EAdensam (EGA1)
WBateman SBloom JLuehman OGC ACRS PGwynn, RIV WJohnson, RIV WBeckner EPeyton OFC PD4-2 NAME I
DATE 7 $
/98 PD4-2 E~ey o 7 /lq/98 TSB WBeckner 7/6'i98 OFFICIAL RECORD COPY 9807200394 9807%5 POR ADQCK 05000275 P
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Mr. Gregory M. Rueger July 15, 1998 cc w/encl:
NRC Resident Inspector Diablo Canyon Nuclear Power Plant cto U.S. Nuclear Regulatory Commission P. O. Box 369 Avila Beach, California 93424 Dr. Richard Ferguson, Energy Chair Sierra Club California 1100 11th Street, Suite 311 Sacramento, California 95814 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower 8 Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 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 Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, California 94102 Telegram-Tribune ATTN: Managing Editor 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732
'aciamento, 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) IMPROVEDTS REVIEW COMMENTS SECTION 5.0 - ADMINISTRATIVECONTROLS 5.1-1 CTS 6.1.1, ITS 5.1.1, Change 0141-A and Difference 5.1-2 (Callaway)
Comment: Difference 5.1-2 states that the STS is revised to "maintain CTS." However, given that Change 01-01-A Insert 1 includes new language into the CTS it is unclear how the CTS is being maintained.
This addition of new language into the CTS and deviation from the STS is not Justified. Provide justification.
FLOG Response:
5.2-1 STS 5.2.2 b and Difference 5.2-2 Comment: TSTF-121 has been withdrawn for modiTication, combination and resubmission.
Use current ITS.
FLOG Response:
5.3-1 ITS 5.3.1 (WolfCreek, Callaway and Diablo Canyon)
Comment: Part 55 of Title 10 of the Code of Federal Regulations was revised in March 1987 to establish upgraded requirements for licensed reactor operators.
NRC Regulatory Guide (RG) 1.8, Revision 2, April 1987, describes methods acceptable to the staff for complying with the revised rule. The Statements of Consideration for the Part 55 rule change state that, "Those facilitylicensees that have made a commitment that is less than that required by the new rules must conform to the new rules automatically."
The staff is concerned some facilities continue to have technical specifications that reference older Industry standards that may not fullymeet the revised requirements of 10 CFR Part 55.
The staff previously considered that the standards applied through the industry's accreditation process were equivalent to the guidance contained in RG 1,8, Revision 2.
However, the staff has recently found that current INPO guidance in this area is very general; only advising licensees to followregulatory requirements.
In RG 1.8, Revision 2, the NRC staff endorses, with conditions, certain parts of industry standard ANSI/ANS-3.1-1981 as an acceptable approach for complying with the qualification and training requirements of 10 CFR Parts 50 and
- 55. This endorsement applies to the positions identified as shift supervisor, senior operator, licensed operator, shift technical advisor, and radiation protection manager.
For positions other than those identified, the RG finds acceptable the approach provided in ANSI N18.1-1971.
For Callaway, the ITS proposes to adopt the CTS which adopts ANSI/ANS 3.1-1978 for the unit staff (besides SROs, ROs and STAs) and RG 1.8, September 1975 for the radiation protection manager.
For WolfCreek, the ITS proposes to adopt the CTS which adopts ANSI/ANS 3.1-1978 for the unit staff (besides SROs and ROs) and RG 1,8, September 1975 for the radiation
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protection manager.
For Diablo Canyon, the ITS proposes to adopt the CTS which adopts ANSI/ANS 3.1-1978 for the unit staff (besides the radiation protection manager) though it does makes a reference to ROs and SROs having to meet the minimum qualifications of Part 55.
Please describe how your commitment to an ANSI standard other than that endorsed by NRC RG 1.8, Revision 2 currently meets the requirements of 10 CFR Part 55, as discussed in the Statements of Consideration for the rule change and would meet those requirements with the ITS as proposed.
FLOG Response:
5.5-1 Change 2-17 LS1 (Callaway, Diablo Canyon)
Comment: WOG-85 has not yet become a TSTF, Use current ITS.
FLOG Response:
5.5-2 Difference 5.5-14 Comment: WOG-85hasnotyetbecomea TSTF. UsecurrentlTS.
FLOG Response:
5.5-3 ITS 5.5.4 b&g and Difference 5.5-1 Comment:
Changes are based on a yet unnumbered traveler.
Use current ITS.
FLOG Response:
5.5P ITS 5.5.4 e and Difference 5.5-13 Comment: WOG-72 has not yet become a TSTF. Use current ITS.
FLOG Response:
5.5-5 ITS 5.5.12 c, CTS 6.8.5 a.3 and Difference 5.5<<7 (Callaway)
Comment: The CTS just refers to 10 CFR Part 20 Appendix B. More information is needed to determine which table governs the current requirements,
FLOG Response:
5.5-6 CTS 3.7.6 and Changes 10-15-LG and 10-17-A (Callaway)
Comment; Please provide a better explanation of the deletion of Pressurization System 2200 CFM +800, -200.
FLOG Response:
5.5-7 CTS 3.7.6 and Changes 10-15-LG and 10-17-A (WolfCreek)
Comment: The CTS markup is inconsistent with the comments as nothing is lined out.
Further, the detetions (at least as they are reflected in ITS 5.5."11) need a better explanation.
Provide explanation.
FLOG Response:
5.5-8 CTS 3.7.6 (3.7.5.1 and 3.7.6.1 - DCPP and 3.7.7.1 and 3.7.8 -CPSES) and Change 10-08-A Comment:
It should be specifically noted as to which CTS requirements were carried over to
.the VFTP and which were deleted (as well as which section of what standard justified the duplication deletions).
Provide explanation and justification.
FLOG Response:
5.5-9 CTS 3.9.13 (3.9.12 - DCPP) and Change 12-04-A (WolfCreek, Callaway and Diablo Canyon)
Comment:
It appears that some of the CTS requirements covered by this change were deleted rather than transferred to ITS 5.5.11 as stated.
Justify the individual deletions.
FLOG Response:
5.5-10 ITS 5.5.11.b (Callaway and WolfCreek)
Comment: The smooth copy of the ITS still has the f] around the plant specific bypass value FLOG Response:
5.5-11 ITS 5.5.9 d, ITS 5.5.11 b, and 5.5.13 (Diablo Canyon)
Comment: The smooth copy of the ITS contains a number of administrative errors.
Page 5.0-19 of the smooth copy of the ITS has two errors.
First, the VFTP section title and the (continued) appear before ITS 5.5.11.b when they should appear at the top of Page 5.0-20.
Second, in 5.5.11 b it should not be "10%at". To be consistent with the rest of the section,.
Page 5.0-1 5 should have SG Tube (continued) at the top of the page.
Similarly, Page 5.0-23 should have a Diesel Fuel (continued) at the top of the page.
FLOG Response:
5.5-12 ITS 5.5.11 and CTS 4.7.6.c.2 (WolfCreek)
Comment: The value of relative humidity is 70% in the ITS, 78% in the CTS markup, and 70%
in the CTS.
Is it corr'ect to assume the CTS markup value is wrong' FLOG Response:
5.5-13 Difference 5.5-9 (Diablo Canyon)
Comment:
Unlike Comanche Peak, the ITS/CTS cross reference table does not include any reference to CTS 3/4.11. Therefore, the difference as written is not detailed enough.
Either make the tie in the difference discussion or update the cross reference.
FLOG Response:
5.5-14 ITS 5.5.11.e.and CTS 4.7.8.d.3 (Comanche Peak)
Comment: The value for the ESF filtration unit is 100 plus or minus 5 kW in the CTS and 100 plus 5 kW in the ITS. Provide correction or justify change.
FLOG Response:
5.6-1 ITS 5.6.5 a.?&8, Changes 03-14&15 M Comment:
It is true that the additions would make the COLR more restrictive however, the removal of the specific values from the TS is a less restrictive change that needs to be justified.
Provide justification.
I E
FLOG Response:
5.6-2 Differenc 5.6-2 (Diablo Canyon)
Comment: TSTF-37 has not yet been approved by the NRC. Use current ITS.
FLOG Response:
5.?-1 ITS 5.7.2 and Difference 5.?-2 Comment: TSTF-167 has been rejected by the NRC. Use current ITS.
FLOG Response:
)
FLOG RAI APPLICABILITYTABLE FOR ITS SECTION 5.0 RAI Number 5.1-1 5.2-1 5.3-1 5.5-1 5.5-2 5.5-3 5.54 5.5-5 5.5-6.
5.5-7 5.5-8 5.5-9 5.5-10 5.5-11 5.5-12 5.5-13 5.5-14 5.6-1 5.6-2 Callaway X
X X
X X
Comanche Peak X
X X
Diablo Canyon WolfCreek X'
X
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