ML16343A596
| ML16343A596 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/21/1998 |
| From: | Steven Bloom NRC (Affiliation Not Assigned) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| TAC-M98984, TAC-M98985, NUDOCS 9807240202 | |
| Download: ML16343A596 (32) | |
Text
'July 21, 1998 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
SUBJECT:
REQUEST FOR ADDITIONALINFORMATIONON THE PROPOSED CONVERSION TO THE IMPROVED STANDARDTECHNICAL
'PECIFICATIONS 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,'o 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 3.4, Reactor Coolant System, 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 l/
Docket Nos. 50-275 and 50-323
Enclosure:
Request for Additional Information cc w/encl: See next page Document Name:
DCITS.RAI DISTRIBUTION:
QD.o'cket
-" g PUBLIC PDIV-2 Reading EAdensam (EGA1)
WBateman SBloom JLuehman OGC ACRS PGwynn, RIV KPerkins, RIV WCFO WBeckner EPeyton.
OFC PD4 NAME SB oom DATE 7/>I/98 PD4-2 EPeytcept 7 RKY98 TSB ti WBeckner 7 kA/98
)~pi pgre g,". r-,-'~ (~~
~<<~~~ I-"~i' OFFICIALRECORD COPY 9807240202 98072i PDR ADOCK 05000275 P
~ ~
Fl
Mr. Gregory M. Rueger July 21, 1998 ccw/encl:
'RC Resident Inspector Diablo Canyon Nuclear Power Plant do 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 ATlN: 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 3.4 - REACTOR COOLANTSYSTEM (By ITS Section) 3.4.1-1 Difference 3.4-38 Comment: TSTF-1 05 has been rejected by the NRC.
FLOG Response:
3.4.1-2 Difference 3.440 Comment: WOG-99 has not yet become a TSTF.
FLOG Response:
3.4.1-3 ITS 3.4.1 Bases Applicable Safety Analyses (Diablo Canyon)
Comment:
It is stated that the DNBR correlation limitof greater than or equal to 1.17 is the "acceptance limitfor RCS DNB parameters."
While that may be the'post-transient limit, as discussed in the CTS Bases, a DNBR of greater than or equal to 1.3 is the assumed normal limit. Is the minimum DNBR of 1.3 what is being restored when the Bases for ITS Required Action A.1 discusses restoring DNB margin or is the margin being restored only enough to ensure the post-transient limitof 1.17 is not violated'?
FLOG Response:
3.4.2-1 Difference 3.4-33 Comment: TSTF-27 Rev. 3 is still pending NRC approval.
FLOG Response:
3.4.3-1 ITS 3.4.3 Bases References Comment: WCAP-14040-NP-A, Rev. 2 January 1996, has replaced WCAP-7924-A, April 1975.
Please summarize the differences/applicability to the FLOG.
FLOG Response:
0
3.4.4-1 ITS 3.4.4 Bases Comment:
The Bases refer to the DNBR limitin the safety limits. Where is it? (this appears to be a problem with the STS, as well as these conversions).
FLOG Response:
3.4.5-1 Change 1-14 LS-22. (Callaway and WolfGreek)
Comment: The change discussion is not adequate.
The NSHC contains the necessary justification.
FLOG Response:
3.4.5-2 ITS SR 3.4.5.2 (also SR 3.4.6.2 and SR 3.4.7.2) (Callaway)
Change 1-15M Comment: The sections of the ITS use the phrase "or equivalent" yet the term is not explained in the change or in the ITS Bases.
According to the information provided narrow range level is used at the higher temperatures (Modes 3 and 4) and wide range level is used at the lower temperatures (Mode 5). If"or equivalent" means using the wide range at higher temperatures and the narrow range at lower temperatures are the levels specified applicable at the different temperatures?
Ifnot, what are the equivalent levels to the values specified in the ITS and how were they determined?
FLOG Response:
3.4.5-3 CTS 4.4.1.2.2, 4.4.1.3.2 and 3.4.1.4.1.b and ITS 3.4.5, 6 and 7 (Callaway and Wolf Creek)
Comment: Ten percent~ range level was specified as the necessary heat sink level. Now in the ITS the level is murgm range.
Was this is a known error in the TS that is now being corrected or was this just discovered as part of the conversion effort? Please provide the technical basis for concluding that 10% (4% for Caliaway) narrow range is adequate.
Additionally explain why different narrow range level values are used at each plant and why wide range level is used in Mode 5 at one and not the other.
FLOG Response:
3.4.5.4 ITS SR 3.4.5.2 (Comanche Peak)
Comment: It should read "SR" rather than "Sr".
FLOG Response 3.4.6-1 Difference 3.442 Comment: The difference states that the STS doesn't cover all possible configurations and the language of the STS is potentially confusing.
Please explain the basis for these comments..
FLOG Response:
3.4.6-2 Change 1-17-LG, ITS 3.4.6, ITS 3.4.7, 3.4.10 and 3.4.12 (Diablo Canyon)
Comment: WOG-67 Rev.
1 has not yet become a TSTF. Additonally, the proposed wording is imprecise and confusing.
IfLTOP is required g or less than 275 degrees F it is inconsistent to then say "the temperature below which LTOP is required" because LTOP is required at that temperature as well as below it.
FLOG Response:
3.4.7-1 ITS 3.4.7.2 (WolfCreek)
Comment: It should read "required SGs" rather than "required Sgs".
FLOG Response:
3.4.7-2 ITS LCO Bases 3.4.7 and 3.4.8 (WolfCreek)
Comment: The TS condition "Loops Not Filled" should be defined in the TS Bases subject to the Bases Control Program and not in an unnamed plant procedure for which the control mechanism is not specified.
FLOG Response:
3.4.7Q lTS Bases 3.4.7 Background (Callaway)
Comment: The last paragraph on smooth Bases Page B 3A-32 incorrectly states "... above 7%." This error does not appear in the highlight/strikeout version of the Bases.
FLOG Response:
0 v
3.4.8-1 Difference 3.448 Comment:
It is unclear why TS 3.0.4 would not apply, Ifthis change is to be considered it should be done on a generic basis.
FLOG Response:
3.4.8-2 Change 01-20 LS-27, ITS 3.4.8 (Diablo Canyon)
Comment: The justification in the change is inadequate.
The NSHC contains appropriate justification.
FLOG Response:
3.4.9-1 ITS 3.4.9 Comment:
Does 92% (90% for Diablo Canyon) in the pressurizer ensure that upon an inadvertent Sl that the pressurizer willnot overfill before the operator is assumed to take action? Other plants have lowered this limit(Robinson) or qualified the PORVs for water (Millstone 3).
FLOG Response:
3.4.9-2 ITS LCO 3.4.9.b (Callaway)
Comment: The ITS should read "... 150 gw."
FLOG Response:
3.4.9-3 Difference 3.4.17 (WolfGreek, Diablo Canyon and Comanche Peak)
Comment: TSTF-93 Rev. 3 was approved with a reviewer's note which says that for non-dedicated safety-related heaters which normally operate the frequency is 18 months and for dedicated safety-related heaters which normally don't operate the frequency is 92 days.
Each of the plants is asking for the 18 month frequency but it is unclear from the submittals ifthey meet the criterion. Please provide information demonstrating consistency with the TSTF.
FLOG Response:
0 C ~
3.4.94 CTS 4.4.3.3 and ITS 3.4.9.3 (Diablo Canyon)
Comment: There is no justification for this less restrictive change (the CTS require the heaters be energized and the ITS which require the heaters be verified as being capable).
FLOG Response:
3.4.10-1 ITS 3.4.10 Bases Applicable Safety Analyses Comment: What justifies the differences between the ITS Bases and the STS Bases and between the plant Bases (especially Callaway and WolfCreek) of the lists of possible over pressurization events?
FLOG Response:
3.4.11-1 Change 4-04 LG Comment: The requirement is in the CTS and the STS. The justification for not putting it in the ITS is that automatic actuation to open is not required.
However, proper calibration also ensures that the PORV does not prematurely open creating as stated in the Bases "in effect a small break LOCA."
FLOG Response:
3.4.11-2 Change 4-08 LS 34 and Difference 3.4-35 Comment: WOG40 has not yet become a TSTF.
FLOG Response:
3.4.11-3 Change 4-05 LS 31 and Difference 3.4-39 Comment: TSTF-113 (presently Rev. 4) has not yet been approved by the NRC staff.
FLOG Response:
3.4.11M Change 4%9 LS-36, Difference 3.4Q?, Change 344 and Difference 3.4-31 Comment: WOG-87 has not yet become a TSTF.
0 FLOG Response:
3.4.11-5 ITS Bases 3.4.11 Background (WolfCreek)
Comment:
On the top of smooth Bases Page 3,4-55 the sentence beginning "The functional design..." should not end with "... Pressurizer."
It should include the phrase that comprises the next paragraph.
FLOG Response:
3.4.114 Difference 3.449 (WolfCreek, Comanche Peak and Callaway)
Comment: This difference does not address the addition of the "Immediately" in Required Actions D.1, E.1, and G.1 of ITS 3.4.11 FLOG Response:
3.4.1 2-1 Difference 3.449 Comment: WOG-100 has not yet become a TSTF.
FLOG Response:
3.4.12-2 Differences 3.4-23 and 3.445 Comment:
WOG-51 Rev.
1 has not yet become a TSTF.
FLOG Response:
3.4.12-3 Difference 3.449 Comment: The difference does not adequately justify not adopting STS SR 3.4.12.7. The SR is intended to apply to valves besides manual valves. Performing SR 3.4.12.4 does not verify the same status as that verified by SR 3.4.12.7.
FLOG Response:
~
~
~ '
3.4.124 ITS Bases 3A.12 Applicability (Comanche Peak, WolfCreek, and Callaway)
Comment: The intent of the addition to the end of the first paragraph of the ApplicabilityBases is unclear.
The LCO applies ifthe head is on. The added discussion essentially states LTOP (COMS) protection ls not needed with the head on and the bolts fullydetensioned.
Ifthat is the argument then rather than adding it to the Bases discussion, the case should be made for modifying the LCO Applicability.
FLOG Response:
3.4.12-5 Differences 3.4-18 and 3.445 (WolfCreek and Callaway)
Comment: The justification for the 4-hour pump swap is inadequate.
The STS allows 15 minutes. The CTS is used as justification however, finding a pump inoperable and then restoring it (which is the case covered by the CTS) is very different than simply switching from one operable pump to another.-
FLOG Response:
3.4.12-6 ITS Bases Pages B 3.4-56, 59, 60, 62 and 63 (Diablo Canyon)
Comment: These pages in the smooth copy of the Bases contain formatting errors which have created gaps in the text.
FLOG Response:
3.4.12-7 ITS 3.4.12 Required Action D.1 (Comanche Peak)
Comment: Is there an approved analysis that demonstrates that this new action is sufficient protection from an accumulator discharge?
FLOG Response:
3.4.12-8 ITS 3.4.12 Required Action D.2 (Comanche Peak)
Comment: What RCS temperature has to be greater than 350 degrees F? Tave (enter Mode 3)? One or more cold leg temperature(s)?
FLOG Response:
3.4.13-1 Change 6-25 LS-26 (Diablo Canyon and WolfCreek)
Comment:
The change discussion is not adequate.
The NSHC contains the necessary justification.
FLOG Response:
3.4.13-2 Change 6-26 LS 30 and Difference 3.4-36 (Diablo Canyon, Callaway and Wolf Creek)
Comment: TSTF-116 has not yet been approved by the NRC.
FLOG Response:
3.4.13-3 ITS 3.4.13 Bases LCO c. (WolfCreek, Callaway, and Comanche Peak)
Comment:
How is the addition ofwhat does not constitute identified leakage consistent with the definition in ITS Section 1.1'?
FLOG Response:
3.4.13M ITS 3.4.13 Bases SR 3.4.13.1 (Comanche Peak and Diablo Canyon)
Comment:
The Bases for SR 3.4.13.1 define steady state as Tavg changing by less than 5 degrees F/hr (Comanche Peak) and Tavg changing by less than 5 degrees/hr and stable RCS pressure etc. (Diablo Canyon). The'text for Diablo Canyon then goes on to define steady state as changing less than 5 degrees/hr and for Comanche Peak ITS Bases 3.4.15 Required Action B.1.1 and B.1.2 and B.2 defines steady state in terms of stable RCS pressure and then refers back to SR 3.4.13.1.
Which statement or statements define steady state?
FLOG Response:
3.4.13-5 ITS Bases 3.4.13 LCO and Bases SR 3.4.13.1 (Diablo Canyon)
Comment: The discussions include CRDM canopy welds as exceptions to the definition. That exception is not included in the Bases discussion for ITS 3.4.13 Actions B.1 and B.2 and the exception is not justiTied.
FLOG Response:
O.
3.4.13-5 ITS 3.4.13 Bases LGO a. (Callaway)
Comment: The intent of the addition that leakage past instrumentation. lines not being pressure boundary leakage is unclear.
Is that leakage upstream of isolation valves?
Ifit is, is there a line size limitand is this consistent with the description of pressure boundary in the FSAR and the definition in ITS Section 1.1?
FLOG Response:
3.4.14-1 Difference 3.4-13 (Callaway, WolfCreek and Comanche Peak)
Comment: What is the justification for restricting the testing to check valves with the addition of the term "check" in three places in SR 3.14-1 and its Bases?
AllPIVs at a plant may be check valves however, the addition is not consistent with the "or isolation valve" part of the first sentence of the SR Bases or with the words of required Action A of ITS 3.4.14.
For Callaway and WolfCreek simple deletion of "check" causes a problem with CTS 4..4.6.2,2.d and 4.4.5.2.2.d for Comanche Peak.
FLOG Response:
3.4.14-2 Change 6-11 LS-11 (WolfGreek, Diablo Canyon and Comanche Peak)
Comment: The change justifies isolation by a single valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and the use of check valves as isolations.
However, the change does not justify the practice of using a second isolation valve.
FLOG Response:
3.4.14-3 ITS 3.4.14 Actions Notes 1 and 2 Comment: The adoption of the STS notes (especially ¹1 which is a less restrictive change) is not discussedfjustified.
FLOG Response:
3.4.144 Change 6-24 M (Callaway and WolfCreek)
Comment:
Cold shutdown rather than hot shutdown is more restrictive however, the discussion does not address the extension of the time from 12 to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
FLOG Response:
3.4.14-5 Change 6-25 LS-26 (Diablo Canyon and WolfGreek)
I Comment: The justification of the change is inadequate.
The NSHC contains the proper justification.
FLOG Response:
3.4.15-1 ITS 3.4.15 and Bases ITS 3.4.15 Required Action E.1 (Callaway, Diablo Canyon and WolfCreek)
Comment:
Callaway and WolfCreek: As written ITS 3.4.15 does not implement CTS 3.4.6.1 as marked up (allowing up to two methods to be inoperable).
Specifically, in the ITS as written, with two monitoring methods inoperable TS 3.0.3 would have to be entered as there is no Condition for two methods inoperable.
Diablo Canyon:
ITS 3.4.15 and Bases ITS 3.4.15 Required Action E.1.
E.1 Bases state that "With two of the three groups of leak detection monitoring not operable, the two groups willenter their respective ACTION and Completion statements."
What in the construction of the ITS supports that statement and more importantly what is the justification for this as the CTS requires 2 of 3 groups of equipment to be operable?
FLOG Response:
3.4.15-2 CTS 3.4.6.1 b&c and CTS 4.4.6.1 b&c markups (Callaway and WolfCreek)
Comment:
Have the systems been renamed, were the names in the CTS incorrect, or are different systems being relied on in the ITS?
FLOG Response:
3.4.15-3 ITS Bases Page B 3.4-9? (WolfCreek)
Comment:
In the smooth Bases discussion ofA.1 and A.2 it should be "and makeup" not "an dmakeup" FLOG Response:
3.4.154 ITS 3A.15.3 (Comanche Peak and Diablo Canyon)
Comment: The SR requires a Channel Calibration of the sump monitom. However, ITS LCO 3.4.15.a only requires one monitor (level and discharge flow) [Comanche Peak] or one monitor system [Diablo Canyon] to be operable.
What other monitor(s) is the SR referencing?
FLOG Response:
3.4.15-5 ITS SR 3.4.15-5 (Diablo Canyon)
Comment:
Only one CFCU condensate collection monitor is required by ITS LCO 3.4.15.
However, the SR specifies that required monitog, be calibrated.
FLOG Response:
3.4.16-1 Difference 3.4-39 Comment: TSTF-113 has not yet been approved by the NRC staff.
FLOG Response:
3.4.16-2 ITS Figure 3.4.16.1 (WolfCreek)
Comment:
In order to be consistent with the ITS LCO and CTS Figure 3.4-1 the units should be micro (p) Curies/gm and not milli(m) Curies/gm as indicated.
FLOG Response:
3.4.16-3 ITS Bases 3.4.16 Applicability(WolfCreek)
Comment:
Page B 3.4-103 of the smooth Bases should read "the reactor" not "thereactor" FLOG Response:
3.4.G-1 CTS 3.4.8.2 and Change 9-05-R (Comanche Peak)
Comment: The CTS Cross Reference Table shows this specification is relocated to the FSAR.
Since this is an operational requirement shouldn't it be in the PTLR or a plant procedure' FLOG Response:
"FLOG RAI APPLICABILITYTABLE FOR ITS SECTION 3A Comment Callaway Comanche Peak Diablo Canyon WolfCreek 3.4.1-2 3.4.1-2 3.4.1-3 3.4.2-1 3.4.3-1 3.4.4-1 3.4.5-1 3.4.5-2 3.4.5-3 3.4.5-4 3.4.6-1 3.4.6-2 3.4.7-1 3.4.7-2 3.4.7-3 3.4.8-1 3.4.8-2 3.4.9-1 3.4.9-2 3.4.9-3 3.4.&4 3.4.10-1 3.4.11-1 3.4.11-2 3.4.11-3 3.4.11M 3.4.11-5 X
X X
X X
X X
X X
X X
X X
X X
X X
X X
X X
X X
X X
X X
3.4.11-6 3.4.12-1 3.4.12-2 3.4.12-3 3.4.124 3.4.12-5 3.4.12W 3.4.12-7 3.4.12-8 3.4.13-1 3.4.13-2 3.4.13-3 3.4.134 3.4.13-5 3.4.13-6 3.4.14-1 3.4.14-2 3.4.14-3 3.4.14-4 3.4.14-5 3.4.15-1 3.4.15-2 3.4,15-3 3.4.154 3.4.15-5 3.4.16-1 3.4.16-2 3.4.16-3
~ r
~
I
~
3A.G-1 X
4