ML20151T015

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Proposed Tech Specs Re Response to Request for Addl Info on Conversion to Improved Tech Specs
ML20151T015
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 05/15/1997
From:
WOLF CREEK NUCLEAR OPERATING CORP.
To:
Shared Package
ML20151S998 List:
References
NUDOCS 9809090196
Download: ML20151T015 (150)


Text

_

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1.1-1 APPLICABILITY: DC, CP, WC, CA l

REQUEST:

CTS 1.3, Analog Channel Operations Test i

CTS 1.3, Channel Operational Test [Diablo Canyon) l CTS 1.7, Channel Functional Test (Diablo Canyon)

CTS 1.35, Trip Actuating Device Operational Test (Wolf Creek)

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) l 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 if NRC has not approved TSTF-39 by the time the draft safety evaluation is l

prepared, then these changes should be withdrawn from the conversion submittal at that time.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 i

the Diablo Canyon ITS markup for COT.

FLOG RESPONSE: TSTF-39 Rev.1 has been withdrawn by the TSTF. However, changes addressed in TSTF-39 Rev.1 have been subsumed by TSTF-205.

{

Revision 1 of TSTF-205 is currently undergoing final review by the TSTF l

members. After final wording changes for the COT definition as well as Section 3.3 Bases changes to establish the requirements for relay contact surveillance testing (issue originally raised at Peach Bottom) are agreed upon, Revision 1 will be submitted for NRC review. The attached pages t

represent the definition changes to be included in Revision 1. The l-Section 3.3 Bases changes will be addressed under that Section's review.

ATTACHED PAGES:

Encl. 2 1-1,1-4,1-6 Encl. 3A 6

Encl. 3B 4

Encl. 5A Traveler Status page, 1.1 -2, 1.1 -4, 1.1 -6 Encl.6A 2

1 Encl.6B 2

9809090196 980828 L

PDR ADOCK 05000482:

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PDR l

mm._.._ _. _ _ ____ _ ___-.__..___ _.. _..._ _ _._ _ ___.__....____

1 (1.0 USE AND APPUCATION]

)

1.0@EFINITION i.

i i

The defined terms of this section appear in capitalized type and are applicable I'" 14A '"1 throughout these Technical Specifications [and Bases)

U--" "

l ACTION 4

' 4,4 ACTION shall be that part of a T: 1-- - ' R---T- +:-- which that prescribes

[~TI.01-A'""j j

remedC - ' : :n_- : ?r_"-#, Actions to be taker 9under designated l

conditions [within the specified Completion Times.)

j 9wed fov. Of'EllASILIT1 h-32-A ACTUATION LOGIC TEST elr m. logc. Of'd 1.1 2.)

1 4,2 An ACTUATION LOGIC TEST shall be the application of various simulated

$@#h d l41FD I

Mnput combinations in conjunction with each posasble interlock logic state nd D#

]

vertficehon of the required logic output The ACTUATION LOGIC TEST shall.@

@ include a continuity check, as-a4mmmum, of output devices _

andevicea l'nthe. channel requind ANALOG CHANNEL OPERATIONAL TESh for channel OPEERASILtTY, j

^k"

~_

4,3 ^. ^31*iM C" don:CL CFCF.^7!OSi^1 TEMahall be the injection of a

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BR)M?@

simulatedhractua al into the channel as close to the sensor as practicable to i

verify OPERABILIT"" 7_'aii :' _ " jp4fle;stranselatuen aptlpepsf,1 j-ei elawn.i Je '-

_~.. ame trine. ;". '.C toderfosefi thesseelfiedT F7932!A?3 fangr gy g_.' _;_ _ n-a-- *r" x.JThe COT may be, h-- :I by means of any]u "NM8

,?

e reerles of- _-- ^ _.o.

n

_ or total channel otope so that the entire channo Je testedJ The.^31'i^ C"^?P: L CP5P_^?!OS1'i T55"pil include -

{cptt-t adpustments, as necessary, of larm, interlock and/or Tiip Setpoints,

% t. t -2.

l 8

range and m, uNd h Channt A)dAL FLUX DIFFERENCQ NW 6 AFD shall be the difference in normalized flux signals

(("l4}{AYQ "h

between the top and bottom halves of e4wo eeehen an excore ne_utron_ detector _ __

"" V8 "'S T

ha4 h channst meM {cy11 '2.)

C)*ANNEL CAI tr RATION # --

(c.utpd s _ _

44 A C NNEL CALIBRATION shall be E**14M Eg

, as necessary, of charynet thatit responds within nge and accuracy t The CHANNEL CAllBRATI 11 eewn- _::"t _.._ _. zz.

t munpei_'_ _'r'" ?^t 2- '_i^.. "= WM-%

mia#6eeis anddeGMan$ebsfoslGisedM;;"F.".y.' :^'; -- - JWistford(pr talibration of :. ;. J- : ; channele with resistance temperature detector (RTD) or]

?F324W" thermocouple seneoes may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices _ in the d 78' I O "00f*

n a

n..;.. '.

^ f The CHANNEL

. CALIBRATION 4nd may be performed by anyrenes of sequential, overlapping, or W chew W N

ag 'ggygM m,,,,.2. }

chmnd emgaM for' 1

CHANNEL CHECK chann,.t cPERAlkt. TTY.

44 A CHANNEL CHECK shall be'the qualitative assessment &v -:' ms-: il Fil4A?l 4

of channel behavior during operation 5/ rtr ::. This determination shall include

@er, where possible, comparison of the channelindication andder status with indications anddor status derived from independent instrument channels measunng the same parameter.

WOLF CREEK - UNIT 1 11 Mark-up of CTS 1.0 S/lS/97 s

,,s.

-, -. -.,. + +

+

r

(l.0 USE AND APPUCATION) l 1.0 DEFINITION LEAKAGE -(Continued)

I

b. Unidentified LEAKAGE L

All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; l

c. Pmasure Roundary LEAKAGE i

LEAKAGE (except SG LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall.

J l

t MASTER RFI AY TEST

@aquhd (84"I%

-eer.w f MASTER RELAY TEST shall5-M :

1" FOWXE 4,44 N _2 :: :'5-noist of enernizine)

M ej k

each' master relay and r" -

-i..Linethe f OPERABILITY of eactirrossy. i MASTER RELAY TEST shall include a continuity check of estessociated' slave relav.

PThe, Masted. eta LAY TasT may non, jiert.< mea. ba em: ens, at snu serico} ( Q l.1-l l l

m ~ -- - aq ugue,wi.i, ov.,t.p6, orpe,t up.,,

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OPERABLE OPERABILITY 4,40 A system, subsystem, train, component or device shall be OPERABLE or

^ sl41M have OPERABILITY when it is capable of performing its E-+?="Oanction(s),

hMW and when all necessary attendant instrumentabon, controls,[ normal or emergency) electrical power, cooling e@al water, lubncation egg)other auxiliary equipment that are required for the system, subsystem, train, c.wi,,,c,r, erit, or device to perform its

[specified safetyJfunction(s) are also capable of performing their related support function (s).-

QPERAT4QNAL,4AODE-MODE 4,30-As&CRERAT4QNAL A MODE f., "OE) shall correspond to any one inclusive 9Mii1FAF comtunation of core reactivity condition. power level, and average reactor

^nnhd coolant temperatureQand reactor vessel head cloeure bolt tensioning) specified in Table 4,3[1.1 1Twith fuel in the reactor vessel.)

PHYSICS TESTS 44% PHYSICS TESTS S".^' ' Mbe those tests performed to measure the 1y#"%.

141 fundamental nuclear characteristics of the core and related instrumentation. [These)

[ tests are %

du esenbod in Chapter 14.0[lnitial Test Prograndof the hAR, or (44 a.

(34 b.

aA Jthorized under the provisions of 10 CFR 50.59, or (Rc : a g therwise approved by the[ Nuclear Regulatotypommission.

WOLT CREEK - UNIT 1 1-4 Amendment No. 61 Mark-up ofC151.0 5/15/97

~.

[1.0 USE AND APPUCATION) 1.0[1 DEFINITION SHUTDOWN MARGINM 440 SHWTDOWN MARGIN @shall be the instantaneous amount of reactivity by which the reactor is subentical or would be subcritical from its present condition assuming : M rod clustericontroljassemblies (RCCAs) 'thddr"9 : d]2fMM" a.

are fully inserted except for the single r~' &T': : r.-1:;

RCC of highest reactivity worth which is assumed to be fully withdrawn.

any RCCA not capable of being fully inserted, the reactivity the RCCA must be accounted for in the determination of SDM; and

b. In MODES 1 and 2 the fuel and moderator temperatures are changed to the hot zero power temperatures.

ElE AQMNG6BM "IKIOMRI GMwac8 1.20 Th0 S!TE "OUND.A_,V Lg L ggma 1:==

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_":f b; S: ":: :r requthd SLAVE RELAY TEST 444 A SLAVE RELAY TEST shall be-theEonsist ofhnny-t 5nergizing)of each

"{l-Ol;A7]

.-+ slave relay and un'- ^t n!verifyingjef OPERABILITY of eacMslavejrelay. The p~

LI SLAVE RELAY TEST shallincludeQ, Minimum)a continuity check as-e r, of associategtestable actu? - '._ devices./7hc SLAVE: IRELA's TE$T ww)

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STdGGERED TEST BASIS U W 23;A M u%%%n 443 A STAGGERED TEST BASIS shall consist ofi-the testing of one of the systems, subsystemsichanneig) or other deslanated components (during the interval "specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, I

channels or other designated components in the associated function. y

2. ^ t e ! : ' : f-dr ^' - r/d---, -"'-;:':rc, trehr, er :tr dr';; 'ed, 8

z;--- 2 '2'nf 5; IP;'.f. ; 50 ; r*- f t--! 'nt. ; ' -': : -" '

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et 5:i:y" ; ^' ch rd'ntr;:!.

THERMAL POWER 444 THERMAL POWER shalt be the total core heat transfer r to the reactor coolant.

of my devic.es in ibe, chanwed regned nir ivip actua '

TRIP ACTUATING DEVICE OPERATIONAL TESTifTADOTi devic.e.Of%KA6tLtti, 41342 4m h

446 A ADOT '"'

^^T'^ = nem^c^""

^ = ^'

eTs operating t e rip Actuatino Device and verifying OPERABILITh" hall consist of

'Ei EC) d egwnponernts'triafkaffanrW;'sysfi,athioldrlodig.<figpl$yerarmer se7 71;30 A?

Cunr*M-5 _;'SWL, f'tha__ '

'"F" "' ^ 'f" ' 2-7_1The TADOT may be) in gi. 4

'lperformed by means of any seres of secuential, overlappina or total channel 3 3ME':,ahitMantif= **--WalWteabl?[l'he(TADOT"o'o ^CTU.^"'O DEV!CE 1

i g:.[

OPE ^7!OF^'_ TEST :hallinclude adjustment. as necess ry f the Trip Actuating Device

' @ - 2.

such that it actuates at the required Ssetpoint within the

~

ccuracy.

WOLF CREEK UNIT 1 Amendment No. 42,61 Mark-up of CTS 1.0

  • *C"' D S/2S/97 1

..-...r.-.

CHANGE NUMBER H5 tic DESCRIPTION improved TS. The proposed changes are administrative in nature and by themselves ate not tech _nical changes, j I 4-13 incorporating travelers @rn44A,90JP93 sTP 26 r M TSTF 2_lo) 1 27 Not applicable to WCGS. See conversion comparison Table (enclosure 38).

1 28 LG The current TS definition of CONTROLLED LEAKAGE is deleted to be consistent with NUREG 1431. Rev.1. The RCP seal water return flow limit is moved to a licensee controlled document.

{Msaa.T 34 -4g. o a. s.s - 2 J 1 29 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

(~rm-2dp Consistent with(TMN the definitions of ChannelkQll"I k 1 30 A

Operational Test (C0T).,[ ] and Trip Actuating Device rmehr.e bh'ie**,

Operational Test (TADOT) is expanded to include the 51w e. A l$

  • 5+.

details of acceptable performance methodology.

T Performance of these te in a series of sequential, overlapping, or total steps provid the necessary

(*

assurance of appropriate operation of the channelC)

This change also makes the COT,*[ ] and TAD 0T definitions consistent with the current TS and the NUREG 1431 definition of channel calibration which already contains_

similar wording.

(, rel>3, q davice, yhg

,_See EonveMon[/moa[r>'s'on T$rie) h 1 31 Not nel re 3B. lW 5EE.T.3A -@ T

Q.i-q {

1 32 A

The definition of channel calibratio

. and TADOT is jo 1. t -2.]

reworded to be consistent with TSTFyto clarify the phrase

" entire channel" thus reducing the potential for inconsistent interpretation nf the ohrase as exoerienced by_r. number of P M N kiLfeY.

  • P" D o t.t-3 \\

1 33 Thi an evi s th S de initio of Co e Alt ati s to ete " r man' ulati ~ and conser ative" consi ten with NUREg 431.

e wo s as ed in e de nitio wer redu ant aryVdelet the rds d s not er t e mea ng f the i

definiti n.

I e4of, gli c=Ra 4o WUrs. See. Coenm Co9me TMa (Encl s,wu.3B').

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l WCGS-Description of Changes to CTS 1.0 6

5/15/97 I

CONVERSION COMPARISONTABLE - CURRENT TS 1.0 Page 4 er 4 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 1-28 The definition of CONTROLLED LEAKAGE is deleted. The RCP No - Se'e change No - See Change Yes. Hoved to USAR Yes. Hoved to FSAR LG seal water return flow limit is moved to a licensee nunter 1-05-A.

Number 1-05 A.

Section 16.

Section 16.4.

controlled document.

1-29 Allows measuring of QPTR when one or more excore detectors No Yes, Portion of No No definition being LS-3 channels are inoperable with moveable incore detectors.

changed only in CPSES CTS Yes Yes Yes The definition of Channel Operational Test (C0T).F[ ] and h la3_ 9,

{gg,gl) 1-30 mager Re A

TADOT is expanded to include the details of acceptable performance methodology. Performance of this test in a sg,,,, g,g g d.

series of sequential, overlapping, or total channel steps provides the necessary assurance of appropriate operation of the @channefe123.or devna. re*%vt.y

- Jhd d[twDS

'~

1-31 Definitions of specific plant systems which are defined by Yes Yes Ye5 Yes A

the plant design are deleted.

1 32 The definitions of CHANNEL CALIBRATION, COT, [ ] and TADOT Yes Yes Yes Yes WoD

[Q f. t - 2. ]

A are reworded to be consistent with the TSTF-g The revised idhin of AcMb I.chc. Ted _4_ SN' clar[seM wording clarifies what is meant by " entire channel.* Ql_se'def 1-33 This change revised the CTS definition of CORE ALTERATION to Yes Yes fhe,140. Amendm yes A

delete delete "or manipulation" and " conservative".

[ 109 Acoqerated.

4 3 I-b 1

t tuMJt.T 38-4 g.g_ci g 1-3 Aru l-4

& dim 34 EA~E i

5/15M7 renvmion rmnnarision Table - Current TS 1.fl

INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 TRAVELER #

STATUS DIFFERENCE #

COMMENTS TSTF-19, Rev.1

@ incorporated g

/7u.o.og j TSTF W Incorporated 1.1-9 h

@ ' ' l (TSTr g / Indrporsed - /

M i G i.i-M QIINffl / ' jcorporiftedj f M-

. lb t.t cl I TSTF-111, Rev.1 Incorporated 1.1-5

@JJCMgev/D Incorporated 1.1-6 (Napp,,4]IQI'l~6l NG4 M.1]

Incorporated 1.1-3

{o I.4-1 l b NMy2)

Incorporated 1.1-11 la t.4-I \\

iner pre [A d<4+ Rs.v.t rsn:-s2.

Inwqua teJ i.i-is pan. 4 J.4.1-(,

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5/15/97

Definitions 1.1 1.1 Definitions (continued)

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of i

the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

)

CHANNEL OPERATIONAL A COT shall be the injection of a simulated or i

TEST (C0T) actual signal into the channel as close to the __

sensor as practicable to verify the OPERABILIT4Y hall d,5cas m. nc-Ing 1

sa

~

nnel s;~ a

@MillINR

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chmnel requnA &-

erl n

1 a ( ct i '

ir -

Ichel. OPERASILtTY, rf t

ed -

y i W f_; d r M ql q; ;.

NEI5139%

int;rixk. di:;;ln. ;ad trief.actix;A:COTliny 4 g,j 1 Tperformed by;means of artyisecies of sequential, overlappjng N u.1 or total:charinel: steps.so-ttat.the entire channeri Jested l]he COT shall incluce adjustments, as necessary, of reqd M e g the required alarm. interlock, and trip setpoints@)that the setpo1nts are within the required range and accuracy. M oPERABlMW J CORE ALTERATION, CORE ALTERATION shall be the movement of any fuel, sources..

or reactivity control components,'within the reactor vessel with the vessel head removed and fuel in the vessel.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5.

Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT I 131 DOSE EQUIVALENT I 131 shall be that concentration of I 131 (microcuries/ gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I 131.

I 132,1 133, I 134, and I 135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III'of MB (81 TID 14844,_ AEC 1962. " Calculation of' Distance-Factors for Power and. Test Reactor-Sites." x t'.. x ,t-d in

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(continued)

WCGS-Mark-up ofNUREG-lUl-ITS 1.0 1.1 2 5/1587

__ _.__ _._.__ _._._._ _ _.~. _

Definitions 1.1 1.1 Definitions (continued)

System:

b.

Unidentified LEAKAGE j

All LEAKAGE (except RCP seal water injection or -

leakoff) that is not identified LEAKAGE:

f c.

Pressure Boundary LEAKAGE LEAKAGE-(except SG LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall.

j MASTER RELAY TEST A MASTER RELAY TEST shall consist of energizing each i.t q master relay and verifying the OPERABILITY of each m

agwe m,.wJrelay. The MASTER RELAY TEST shall include a

@ i.i-i {

continu1ty check of each associated, slave relay.4 Gepivv4j f

MODE A MODE shall correspond to any one inclusive f ths.tssnm RELAY WAT im3 8-Combination of Core reactivity Condition, power level, b

Amed. by msene d m average reactor coolant temperature, and reactor 4

L 3en'es, of seque<64evalqq,,

vessel head closure bolt tensioning specified in Table 1.1 1 with fuel in the reactor vessel.

j Mg.3t93, OPERABLE-0PERABILITY A system, subsystem, train, component, or device'shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function (s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety l

function (s) are also capable of performing their related support function (s).

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a.

Described in Chapter 14. Ir.itid Tat NF; of eps; t the FSAR USAR:

(continued) i i

j WCGS-Mark-up ofNUREG-1431 -ITS 1.0 1.1 4 5/15M l.

l

-,.. -. ~,.

\\

Definitions 1.1 1.1 Definitions (continued) d SHUTDOWN MARGIN (SDH) fully withdrawn With any RCCA not capable of being (continued) fully insertet., the reactivity worth of the RCCA must be accounted for in the determination of SDH: and b.

In H0 DES 1 and 2 the fuel and moderator temperatures are changed to the ca ta;l ;;re ggggg*,

p ;r d;; iga 1; ni hot zero power;temperaturesf SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing each i.1-q Ngg 7 slave relay and verifying the OPERABILITY of each rslave relay. The SLAVE RELAY TEST shall include, as a g9 i 1

minimum, a continuity check of associated,t_estable actuation devices.j (regyny STAGGERED TEST BASIS

[ A STAGGERED TEST BASIS shall consist of the testing of

)

IThe. St.ME REtkrDiis,T one of the systems, subsystems, channels, or other.

f,g P' p g b m )

designated components during the interval.specified by

  1. "O " P 4 the Surveillance Frequency, so that all systems, l

FI*T"$ 8 "%"9'gl,,pb are tested during n Surveillance Frequency intervals, subsystems, channels, or other designated components 7

where n is the total nimber of systems, subsystems, channels, or other designated components in the associated function.

THERHAL POWER THERHAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TRIP ACTUATING DEVICE A TADOT shall consist of operating the trip OPERATIONAL TEST (TADOT) actuating device and verifyinglthe OPERABILITY gygg blde4:c.::.in &c.

fi, _

l a

Mr 4 rip acka?sd.g devia.

9 W Naction;.]TheJADOT may be performed.br g~ r gL i

'd M n"*l f*4 j (,)g 7; 47;g3;;j;;,$3;7;;g,gg;;;;j, i

Fasans of'any series:oE3equential, overllipping or l

(O___ #f total" channel steos,so that1Wentt'es thannsMW klendf/The TADOT shall inc' ude adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the required accuracy.j 2

WCGS-Mark-up ofNUREG-H31 -ITS 1.0 1.1 6 S/lSM w.

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inaddMn,&z PTIA defiViWon AshAse ks. PbRV I "D*N **"*'itent A h tra Mev'.5 chmy.

CHANGE

*" 8 ' ' ' -

NUMBEP.

JUSTIFICATION gi.i g]

l The [LTOP] arming temperature was added to the PTLR. since changes in the heatup/cooldown figures could change the arming temperature. This change corrects the PTLR definition to be consistent with all of the requirements contained in the PTLR. Referenced methodologies for the lPTLR would contain the methodology used to develop the heatup and cooldown figures, as well as the methodology for developing the_(LTOP] )

setpoints. This change is consistent with traveler (gF6)(' pava #

bCtsrsr-zas>lopi.is-T 1.1 7 Not applicable to WCGS. See Conversion Comparison Table anciosure 68).

m,,,,q r MODE i 5 a 6)

I he r 'ctor ssel ad os e bol rQuT ts l

1.1 8 T

a lari p pos cha revis s foot ebf MODES and I

to r to equ ed r ctor ssel d clo re bol fully j

ten ned" no ef MODE is re sed to ead "

uired eacto

(

sel clo re ts le than 11y t ioned." The ansit n-l

) point ES and 6 1d a so be c rifi as occ ring I

j-t equir rea r vess head osure its ar less an fu y t sio T

requir number closu bolt. which y

ess tha he tot number is esta ished anal is tha demon rat i

i te ing ession prev leak and sure hat l

LSpction I stres inits f aff ed c s

exc (This nge is sist ith 88.

tM Applic3 Lads tuts 5. Saa

_ A (ea eta u.rw 6 aid.

tc a g r._, B c w p

..'. m e.

1.1 9 Consistent with TSTJJ;Mr)teVD, the definition of Channel Operational ms and Trip Actuating Device Operational Test (TADOT) is Test (C0T)3[ ]lude the details of acceptable performance methodology. 4,g expanded to inc

\\

t

)

% g,gg Performance of this test in a series of sequential, overlapping, or I

!*Y*d'b total @ steps rovides the necessary assurance of appropriate operation of the channelhThis change also makes the COTS definition consistent with the def\\inition of channel calibration which already contains similar wording. {re133 ordam.a. req =ctiveg 1.1 10.

Not applicable to WCGS. See Conversion Comparison Table (Enclosure L

68).

1 1.1 11 Adds new example to ITS Section 1.4 to clarify surveillance frequencies that are contingent on both a specified frequency and plant conditions.

-The ITS contains many Surveillance Frequencies that are contingent on l.

both a "specified Frequency" and plant conditions. For example.

"Within 7 days prior to the initiation of Physics Tests." and " Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 l

days." These Frequencies do not fall clearly under any of the existing l

Section 1.4 examples. The proposed example is needed to make clear l

L WCGS-Differencesfrom NUREG-1431 - 1151.0 2

5/15/97

CONVERSION COMPARISON T4BLE FOR DIFFERENCES FROM NUREG-1431 Page 2 of 2 SECTION 1.0 -

L APPLICABILITY DIFFERENCES FRON NUREG-1431 REV. 1 NUPEER DESCRIPTION DIABLO, CANYON COMANCHE PEAK WOLF CREEK CALLAWAY

^

CalbwEg spedfd cb@

1.1-7 The definition of Channel Functional Test in the Yes No - Not part No - Not part No - Not part current T5 will be retained in the improved TS. This of current TS.

of current TS.

of current TS.

definition is not in NLREG-1431 Rev 1.

1.18 -dote b is revised to refer to the " Required reactor

  1. ee ble 4es Eo

~4es M o )

Yes 1 Q t.t-9j

~

vessel head closure bolts fully tensioned" and note c is revised to read " Required reactor vessel head closure bolts less than fully tensioned."

L 1-1-9 The definition of Channel Operational Test (C0T). [ ]

Ye Yes Yes Yes and TADOT are expanded to include the details of (fEvnentse Rah te g,g_,

acceptable performance methodology. Performance o St Rat $ Test, this test a series of sequential, overlapping. or total steps provides the necessary assurance of appropriate operation of the@channe(veh,or dedcA-,resfeebv clij]

3 1.1-10 This change is based on the current TS definition of No - Not part No - Not part No -

Yes CONTROLLED LEAKAGE. This change is a clarification of current TS.

of current TS.

Maintaining ISTS wording.

only and does not affect the way RCS water inventory balances are performed.

f 1.1-11 Adds new example to ITS Section 1.4 to clarify Yes Yes Yes Yes surveillance frequencies that are contingent on both a L

specified frequency and plant conditions.

(l. t - 1[ tdsEATf,6-@ Tn 1.o. cord ihisE2.T 6

- - fQ3,6.t-(,]

5/IS/97 WCGS-Conversion Comparision Tame - ITS 1.0 I

I l

ADDITIONAL INFORMATION COVER SHEET l

ADDITIONAL INFORMATION NO: Q 1.1-2 APPLICABILITY: DC, CP, WC, CA l

REQUEST:

CTS 1.3, Analog Channel Operations Test l

CTS 1.5, Channel Calibration CTS 1.35, Trip Actuating Device Operational Test (Wolf Creek]

CTS 1.36, Trip Actuating Device Operational Test (Callaway]

j 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 l-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.

Comment: If NRC 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.

l FLOG RESPONSE: TSTF-64 has been withdrawn by the TSTF. However, changes addressed in TSTF-64 have been subsumed by TSTF-205. Revision 1 of TSTF-205 is currently undergoing final review by the TSTF members.

After final wording changes for the COT definition as well as Section 3.3 L

Bases changes to establish the requirements for relay contact surveillance testing (issue originally raised at Peach Bottom) are agreed upon, Revision 1 will be submitted for NRC review. The attached pages represent the definition changes to be included in Revision 1. The l

Section 3.3 Bases changes will be addressea under that Section's review ATTACHED PAGES:

Encl. 2 1-1,1-6 Encl.3A 6

Encl. 3B 4

Encl.5A Traveler Status page, 1.1 -1, 1.1 -2, 1.1-6 Encl.6A 1

Enci. 6B 1

l L

__~______-.-.m (1.0 USE AND APPLICATION]

j 1.0@EFINITION I

I.

i i

The defined terms of this section appear in capitalized type and are applicable PM141;^]**

throughout these Technical Specificationstand Bases.)

E*k**

ACTION M ACTION shall be that part of a T: '- "' R ---P-d-n which that prescribes

{l g "t A M J

.:--- ':' ~ ~- : : _i :Suired Actions to be taken)under designated conditions [within the specified Completion Times.)

9ad for OrEllA86LLT1 1 -37. -A ACTUATION LOGIC TEST 4m.Lejc, circ.utt g,,g,,)

M An ACTUATION LOGIC TEST shall be the application of various simulated Cl41 A1""]

2

' put combinations in conjunction with each possible interlock logic state nd

"""'"~d tion of the required logic output The ACTUATION LOGIC TEST shall,@

j

@ include a continuity check, as sanmunum, of output devices.__

of all daite26 l'n the, channel requtmA i

^M^' OO CHANNEL OPERATIONAL TEST %'.for charmal CPERASit.tTV.

s

'. OP P_^7!C"^1"S7 hall be theinjection of a E((l "@"P M ^.

^"^1M C" don:alinto the channel as close o t simulatedtLr actua sensor as practicable to verify OPERABILITYT"" _-111 :' 1 %1p4ReMaorhtuen ge1mjanger,1 ei-alami. ' T' "-

.. ane trin4Gne"-MC 'd toderfenh tlWImpos1ftedl

{'{ggf"d73#

" series of==a_n f__l, overlapsena or total channel steps so that the entire chann]el)

(asfeWW't:27_.c".'::" ^. r:n.JThe COT may be performed by means of any l

Je testedJThe ^."^1M C"*?:': ' CP P_^7!C"^i T5PEQT/shallinclude

{ cpi.1-1 l adjustments, as necessary, of

,r., interlock and/or Trip Setpoints,

% t. 4 -2.

l

sucMat me am ange and accuracy.

,,,j 4,, eg,,,

j l

r A)dAL FLUX DIFFERENCI:IU"dh O

NW 6 AFD shall be the difference in normalized flux signals

{E$gA]"

between the top and bottom halves of e4wo-seehen an excore neutron detector. ___ __

CHANNEL CAI1RRATION f

""V8 "88 (cutpd suc h+h@__% Ch*"*I "

(Cp l.1-2.]

=

~ M AC NNEL CAllBRATION shall be ustmenTas necessary, of Ff 143-M

"~'*#

(

charjnel thatit responds within nge and acceracy j'

"-5 _ - The CHANNEL CAllBRATI 11 er.ce,W :9 : _ _ ' nn;:

1 amtpe 'z'_ '_ ^' M-:t '_^ M f.; S: @_-f_"'M"W meesteek anddemiHbat5sehsfogGisedh"Jv#c"" ' 3)ihetfors(pr talibration of instrument channels with resistance temperature detector (RTD) or]

""%?

%.32 j_

thermocouple sensors may consist of an inplace qualitative assessment of eensor behaylor arid normal calibration of the remaining adjue+able devices in the C

i

.09 "ATIOfWnemay be performed by anylenes of sequential, overlapping, or ~ _

total channel stepe$pPr]haf})p4myedjperI51M;-g agg 'ggA3 gn chama\\ r@K 'N ggj WA 1

CHANNEL CHECK c__har_ met OPERA 6tt. TTY.

M A CHANNEL CHECK shall be the qualitative assessmentby observation)

% % 010A P of channel behavior during operation byebsewetion This determination shall

""~^

%, where possible, comparison of the channel indication andler status with include indications and/or status derived from independent instrumerit channels measunng the same parameter, WOLF CREEK UNIT 1 11 Mark-up of CTS 1.0

$/15/97

h.0 USE AND APPUCATION) _

1.0[1pEFINITION SHUTDOWN MARGINEDE 4.30 SH4JTDOWN44ARGINMahall be the instantaneous amount of reactivity by which the reactor is suberitical or would be suberitical from its present condition assuming : h! 6" in;. rod cluster l control) assemblies (RCCAs) (thr'd^' M :nd "G"Q20-Mi '

a.

are fully inserted except for the single r-J

^r'r- - - Tf; RCC of highest reactivity worth which is assumed to be fully withdrawn.

any RCCA not capable of being fully inserted, the reactivity wo the RCCA must be accounted for in the determination of SDM; and

{b. In MODE 81 and 2, the fuel and moderator temperatures are changed L to the hot zero power temperatures.

SITESQlJNQARV "MMFM GWhunna i N D 8 "E "O' 'I'9.'"V -Ed '" O' 'I"" '^;T"d 'J '2 ^' *" '""d k "I^r r xt, ner 'rr" ner c* crc:_:: en'c:":d by Se Wrr SLAVE RELAY TEST t'equ trt d 4,34 A SLAVE REl.AY TEST shall' :Q=ssist of]energiaasonEnergizing)of each 71-01247[

-+ slave relay and ". ::'- '"'verifyingjef OPERABILITY of eact islavejrelay. The y *M j

d SLAVE RELAY TEST shall includefas a minimum) a continuity check, as a

-' 'cr, of associate $ testable actuation devices.f The. SLAVE: RELAY'IETwg W'{Ql.1-I{

e m,m - Q* *

  • s*'"' % **" N N P E* P*rf*"'"*d re cuer><

fnXFi@

%[N3MS

?." ^. ?^"".CE C""C 22:: '- Se :-

x
r: :_ ^ d fann::::;:x:

on the e2nn:: :: :q-te :g:::d te'e ee" - ef inr:: ed efer-'aj.

N STAGGERED TEST BASIS NM3W 5 tshd M 4,33 A STAGGERED TEST BASIS shall consist of;- the testing of one of the systems, subsystems,[channeis] or other desionated componentefduring the interval "specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance j

Frequency intervals, where n is the total number of systems, subsystems,

< channels or other designated components in the associated function.

J

2. ^ teet :2:dM 8 r :;:tm:. erbeyr:::, t- :x, er :":: drt ted.
n;:xnt :t' icd by 2;: din; te :;::*:d te! Mur;:' -te r --" '

ri! tc;i.Ord

5. The t--'M; d ere :ytt -- ubry:ter, tr !r, er emer dert 'rd 20m cr r' e'Seb:; "n; M e-'tutM' r;!.

THERMAL POWER 4,34 THERMAL POWER shall be the total core heat transfer r to the raum coolant.

att devic.c.s. M Me, chamwe.\\

requked for it ip actua '

TRIP ACTUATING DEVICE OPERATIONAL TESTfTADOT) cievh.e. OPERAIMLtif "aA,n-01W 9 4,36 A ADOT. or arma-neuire noemimia EeT s ___

a operating t e rip Actuatino Device and verifying OPERABILITD" hall consist of

^ # efiO topspontents'irul%.stianrWeysftskhotelpeltidispinymaraer ne7

?t40;A 3 _

p y g-p g,g e_1_y --~f"a2+: 1The TADOT may be (1-33.- A)

Performed by means of any sortes of secuential, overlaccina or total channel g.h I LeteMla ehdDhsentif= =5--+=lMee6Cfl'he(TADOT"o'

^CTU.^

G DEY!CE 0"E"^7!OS'^.L TEST -hall include adjustment, as necess ry f the Trip Actuating Device

' Q t.t-2.

such that it actuates at the required Saetpoint within the ccuracy.

WOLF CREEK-UNIT 1 Amendment No. 42,61 Mark-up of CTS 1.0

  • *C **l S/lSA7

m.__

CHANGE BRSfA EitC DESCRIPTION l

improved TS, The proposed changes are administrative in nature and by themselves are not technical changes.

b l 4-l1 l

incorporating travelers @rn44A)defA3 I

h sM-2.67_ M T5TFT107 i

1 27 Not applicable to WCGS. see convers1ori comparison Table l

l (enclosure 38)..

l 1 28.

LG The current TS definition of CONTROLLED LEAKAGE is deleted 6

l to be consistent with NUREG 1431. Rev. 1.

The RCP seal water return flow limit is moved to a licensee controlled document.

{dses.T 24 -

cp 3 s.s. z j l

1 29 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38).

l rJaTS-2aC Consistent with Wed the definitions of Channe1NI'l-l k 1 30-A

'g Operational Test (C0T).,[ ] and Trip Actuating Device l

e **. -

Operational Test (TADOT) is expanded to include the L rrwe h R* YT l Q%QlM es+.

details of acceptable performance methodology.

Performance of these te in a series of sequential, overlapping, or total steps provi he necessary i

L' assurance of appropriate operation of the channelq

- This change also makes the COT,'[ ] and TADOT definitions consistent with the current TS and the NUREG 1431

^

definition of channel calibration which already contains -

similar wording.

(j 'rsisy, a <savyn,m9schg Not le t

__S_ ee)6nvepdon C(moarfson TgMe) h 1 31 1

re 38. tW 5eeft sA-wH c;p i. i _, g The definition of channel calibratio

, and TADOT is h

reworded to be consistent with idirQto clarify the phrase [c;p i.i 2 1 32.

A

" entire channel" thus reducing the potential for inconsistent interpretatinn af

  • nhrau as arnarienced by a number of P

Y Te.M.

O l.1-3 \\

-1 33 Thi an y devi st TS de initio of Co e Alt ati s to ete " f man ulati ~ and conser tive" consi ten with NURE 431.

wo s as ed in de nitio wer redu ant I

delet the rds s not er t mea ng f the a

definiti n.

NA ap(pu c=Rs_4o LMCrs. See. Comumiaw Cgera i aV4.4. bdemuu 3b).

M E

h.34 p 4a p~licaW.4 it 14.U,r5 see Genve5E C*E

  • 4:4 t

15 2.

(

l' koca;f-35hughl-41 _

lbsEkT 3 see.f,.4 g,4 jt47,,

r VCGS-Description of Changes to CTS 1.0 6

5/158 7 o

CONVERSION COMPARISON' FABLE - CURRENTTS 1.0 rage 4 ora TECH SPEC CHANGE APPLICABILITY NUEER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY S

1-28 The definition of CONTROLLED LEAKAGE is deleted. The RCP No - Se'e change No - See Change Yes. Moved to USAR Yes. Moved to FSAR LG seal water return finw limit is moved to a licensee rumber 1-05 A.

Number 1-05-A.

Section 16.

Section 16.4.

controlled document.

1-29 Allows measuring of QPTR when one or more excore detectors No Yes, Portion of No No LS-3 channels are inoperable with moveable incore detectors.

definition being changed only in CPSES CTS The definition of Channel Operational Test (C0T) f[ ] and Yes

~ - _

Yes Yes Yes 1-30 A

TADOT is expanded to include the details of acceptable Nk, RekM, p g,g l }

performance methodology. Performance of this test in a 3g,,, g,g 94' series of sequential, overlapping or total channel steps

=

provides the necessary assurance of appropriate operation of the @channefe133.ordevR4. respective.g

- Jieb N[twDM 1-31 Definitions of specific plant systems which are defined by Yes Yes A

the plant design are deleted.

yes Yes 1-32 The definitions of CHANNEL CALIBRATION COT. [ ] and TADOT Yes Yes Yes Yes Qo9

[Q t. t - 2 j A

are reworded to be consistent with the TSTFS* The revised _ iniham et Actush11.tvjc Ted 7s same Iwg cl>

wording clarifies what is meant by " entire channel."(The def s

1-33 This change revised the CTS definition of CORE ALTERATION to Yes Yes J #e+ No. Amendme yes r

' O I'I~

A delete delete "or manipulation" and " conservative'

[ 109 Acorporded.

s eid Q j 15J5ERT 3B

}on.tegg hocs 1-3 Wen I-4 Sechb 3A litA E S/15N7 O nrminor Gmunarision Tame - Carrrent TS 1.0

INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 TRAVELER #

STATUS DIFFERENCE #

COMMENTS TSTF-19, Rev.1

@ incorporated w f,o. m 7 TSTF W Incorporated 1.1-9 h

@ 8 i-3.I CT W R _ f lecerrporm v M

Eca i i - 2. \\

Q}SJJ48/Cdcorperlitedj_ f M-

.- { W t.t on i TSTF-111, Rev.1 Incorporated 1.1-5

@.9CA1, Key /TJ Incorporated 1.1-6 (papp;Q W u-q NMW1]

Incorporated 1.1-3

[4 t.4-1 I IMM Incorporated 1.1-11 la 14-1 I rsts:-52.

loco <FfMed t 1 - l'b incor prateA. dr4+ Rd.1 W 4 3 2 ' ~G"

-_n

_^

Q3,4,t.6,)

e l

e S/15/97 l

l l

Definitions l

1.1 1.0 USE AND APPLICATION 1.1 Definitions

.....................................N0TE The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Igrm Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various q

simulated er actual inout ceinations in conjunction with I.1 -1 L[g44@j L

b'.

  • p each possible interlock logic state'and the verification of Ol'I' I the required logic output. The ACTUATION LOGIC TEST. as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux e -

signals between the top,and bottoqi halves of e (AFD) two-section an excore neutron _d_etector._

pd such)

CHANNEL CALIBRATION-A CHANNEL CALIBRATION s 1 be Ine aa,1ustment, as necessary, of the channel hat it res s within the e t.t-2.

range ay accuracy 3 % __ _ _ _

.g

..,,~ _...,

valires oOhe parameter

r,; 7;p7= ;;,;;.7, ;;;7;;;, ;7,;;7;;;;; d;;;;;3, ;7,d trip

+ hat-N. chann A.

funet4ent-The CHANNEL. CALIBRATION shall encompass

'~

ip1f 1

t f

heI s

pit cievica A the channel on(.fcalibration of instrument ciannels with requded Er channal-resTstance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of L# " M **'"-

sensor behavior and normal calibrati f the remaining h-adjust _able devices in the channel.

er a ris t rel t

r ced, he r

1 red CALI TI i

1 nelu an 1 lac ross alib ion at c ar Tg i.e.om) t othe sensi el ts ht rece y in all L-t ens el

.f The CHANNEL CALIBRATIOt may be performed by means or any series of sequential, overlapping i

calibrations or total channel steps so that the entire i

channel is calibrated.

l (continued)

WCGS-Mark-up ofNUREG-1431 - ITS 1.0 1.1 1 S/2S/97

k Definitions 4

ii 1.1 1

l 1.1 Definitions (continued) i j

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This l

-detemination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

4 J

CHANNEL OPERATIONAL A COT shall be the injection of a simulated or j

TEST (C0T) actual signal into the channel as close to the --

sensor as oracticable to verify the OPERABILITM

$all dedic85 lA $t-1 t-

.s g7w

&1 --

a_

!MM t h [ m [ed? b.i 1 f-"m

.. '. redr.sr chmnel requir.A.&

1 i

i g~ My,M i

S dem; : r;.

(chamal oPERASILtW,"l a-i 1;trlect. 01 1;;. ;r.: tr;; f..;;ia.; A :Cutney.

g,,.i i

i rperformed:by;meens.of anyiseries'of.sequentialioverlapping 8 g,g.z

' or totalvh==o17 steps so-ttat the entire channel'1 4

destadi]Tu CF snall incluce adjustments, as necessary, of f8 9 the required alare. interlock, and trip setpointsMthat j

oPERABitl_3 J the setpo1nts are within the required range and accuracy. M 4

)

~ CORE ALTERATION.

CORE ALTERATION shall be the movement of any fuel, sources..

or reactivity control components,'within the reactor vessel with the vessel head removed and fuel in the vessel.

I-Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

l CORE OPERATING LIMITS The COLR is the unit specific document that i

REPORT (COLR) provides cycle specific parameter limits for the current

-reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5.

Plant operation within these limits is addressed in individual Specifications.

1 DOSE EQUIVALENT I 131 DOSE EQUIVALENT I 131 shall be that concentration of I 131 (microcuries/ gram) that alone would produce the same j

thyroid dose as the quantity and isotopic mixture of I 131, I-132. I 133.1-134, and I 135 actually present. The j

thyroid dose conversion factors used for this calculation shall be those listed in Table.III!of

$$tBF

[j TID 14844JAEC,,1962, "C4)culation of' Distance Factors for Power andTest Reactor-Sites,"

tLx.;W d in T;th T;ff".;put;ry 0:.1d; ;~.10^ ";;.1;;;;0'11014

!0"" 3^. ii.;;1a r.t t; "r.G IM:;; 1"2 212,_Tr.tk titi;d, j

i "0

ttd Os; q;ist...". jr. J;.,.; 0,.r.; r E
-:r:W i

k u k ;f W t ".;tivity"~.

f-(continued) i

- WCGS-Mark-up ofNUREG-1431 -ITS 1.0 1.1 2 S/15/97 4

,.y-. _,

-,.s-g

-,r--

Definitions 1.1 l

1.1 Definitions (continued)

SHUTDOWN MARGIN (SDM) fully withdrawn. With any RCCA not capable of being (continued) fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM: and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the 7.7 17.;l use mpg' 8

i.; ;r d;;;;;; 1;;;l hot zero power temperaturesf S MVE RELAY TE A SLAVE RELAY TEST shall consist of energizing each i.t-q 7 slave relay and verifying the OPERABILITt' of each 1gg1 rslave relay. The SLAVE RELAY TEST shall 'nclude, as a gg.

1 minimum, a continuity check of associated, testable actuation devices.j Qegdup STAGGERED TEST BASIS

[ A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other'

/~The. SLMs RELM liiiiT) designated components during the interval specified by_

gP4.,,q m the Surveillance Frequency, so that all systems, i

i

  1. "'$ "'M g subsystems, channels, or other designated components WDf"$' "%g'gl,

'i are tested during n Surveillance Frequency intervals.

where n is the total mmber of systems, subsystems, channels, or other designated components in the associated function. _

i THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TRIP ACTUATING DEVICE A TADOT shall consist of operating the trip OPERATIONAL TEST (TADOT) actuatingdeviceandverifying?theOPERABILITY~

gppy hl Mic.ms, in &e.

i.'s.

' cM h"'I f*9"i t

regired hl; ;. ir.terir.d. di;;l;;,

i LGrMpo.cAahdeva..

- i tr ; fg.;ti;n;.]Tha. TAD 0T may be-performed.
ggitngs, (O__D$f (means ofIapy. seriesiof5 sequential,' over14pping-@or l

'~

f totnF channel:s+=asa se4at't deSdf /The TADOT shall inc1ude adjustment, as j

necessary, of the trip actuating device so that it j

actuates at the required Setpoint within the required accuracy.p

)

i i

WCGS-Mark-up ofNUREG-1431 -ITS 1.0 1.1 6-5/1587 i

_=

DIFFERENCES FROM NUREG-1431 Section 1.0 This enclosure contains a brief discussion / justification for each marked up technical change to NUREG 1431. Revision 1. to make them plant specific to incorporate generic changes resulting from the Industry /NRC generic change process. The change numbers are referenced directly from the NUREG 1431 mark-ups. For Enclosures 3A. 3B. 4, 6A and 6B. text in brackets "[]". indicates the information is plant specific and is not common to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets inidcate that other JLS plants may have plant specific information in that location.

CHANGE NUMBER JUSTIFICATION pq 1.1 1 ke NU 1431

.1 initio of Chann 1 Calibration stat. "T C

L CALI TIO all e pass th entire channel, in udin he quired nsor

larm, erlock.

' splay, and' trip fu ions." This Ichanp. clari s what ncompass the entire channel rewor ing the gefinitio o sta. "The C EL CALIBRATION shall ncomp s those compo ts, su as senso. alarms, displays. a trip nction r

ired t erform t specified safety func on(s)." The Ch nel /

O al Test, d Trip Actu ting Devic perati al Test efinifions hperati e

milarly r ised. This nge is sistent ith TST -64. wssex g.S

^

1.1 2 Not used.

i 1.1 3 Adds new example to ITS 1.4 to clarify meaning of SR Notes of the type "Only required to be performed in M00E...". This change is consistent with traveler @ 4gyd.

i Q'T.5TP *2.'10}l_G I 4 ~ \\ _ )

1.1-4 Not used.

1.1 5 The definitions for ESF Response Time and RTS Response Time would be revised to substitute the word " verified" in lieu of " measured" consistent with the requirements of NUREG 1431 SR 3.3.1.16 and SR 3.3.2.10.

This change would ensure consistency between the definitions for Response Time and the requirements to periodically verify Response Time is within limits. This change is consistent with traveler TSTF-111. Rev. 1.

1.1 6 The definition of the Pressure and Temperature Limits Report (PTLR) would be revised to include the maximum allowable PORV lift settings and arming temperature associated with the [ Low Temperature Overpressure Protection (LTOP)] System. and to be consistent with the l

COLR definition. Improved Technical Specification 3.4.12 states that the PORV lift settings are specified in the PTLR. The current i

definition for PTLR does not identify these lift settings as being contained in the PTLR.

VCGS-Differences from NUREG-1431 - ITS 1.0 1

5/15/97

INSERT 6A-lb 0 1.1-2 The NUREG-1431 Rev. 1 definitions of Channel Calibration, Channel Operational Test, and Trip Actuating Device Operational Test use language to describe the scope of testing similar required sensor, alarm, interlock, display, and trip functions.

The word " required" is ambiguous and subject to misinterpretation as to whether the list is inclusive or representative.

This change clarifies what components are inicuded by specifying "all devices in the channel required for channel OPERABILITY." A similar clarification is provided for the Actuation Logic Test.

This change is consistent with TSTF-205.

i I

l l

l r

CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 rageior2 SECTION 1.0 -

DIFFERENCE FROM NUREG-1431 REV.1 APPLICABILITY NUHBER DESCRIPTION DIABLO CAllYON COMANCHE PEAK WOLF CREEK CALLAWAY 1.1-1 This ange ld c rify what ene m

s the enti ]

Yes Yes Yes Yes ch I

rewor the finiti to ate "The I

CALI ON sha ene ss t c

nt s in cha

. such sensor, ala splay, and p funct ns, tha are red t per t

g (specifi safety tion (s The T and T T

yieft ions er imilarly evis.

1.1-2 Not used N/A N/A N/A N/A 1.1-3 Adds new exanple to ITS 1.4 to clarify meaning of SR Yes Yes Yes Yes.

Notes of the type. "Only required to be performed in HDDE..

  • 1.1-4 Not used N/A N/A N/A~

N/A 1.1-5 The definitions for ESF Response Time and RTS Response Yes Yes Yes Yes Time would be revised to substitute the word

" verified" in lieu of

1.1-6 The definition of the Pressure and Temperature Limits Yes Yes Yes Yes Report would be revised to include the maximum allowable PORY lift settings and the arming temperature associated with the system. and to be consistent with the COLR definition.

%[.:k claddies +he.deftnihdas =f 64MML, CAL.tSRATto c.cfr, -. J TADaT* b3 replac.Q 4%e Mipm i.iorag Jth "ae.v.6a.s sa &c channet ve4sunad be channel oPentanii.sry.

Qhe. AcmahN Logic ~i's.s+ ciafinifi=A Lsy similach _ revisady S/15/97 WCGS-Conversion Comparision Table-ITS 1.0

=

ADDITIONAL INFORMATION COVER SHEET 4

ADDITIONAL INFORMATION NO: Q 1.1-3 APPLICABILITY: CP, WC, CA REQUEST:

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 j

justification. Revise the DOC by incorporating the information contained in the j

associated NSHC.

FLOG RESPONSE: Additional information supporting this DOC is in NSHC LS-1 in Enclosure

4. DOC 1-06-LS-1 is revised to include the following information:

"The proposed revision more explicitly defines those operations that have a potential for adding positive reactivity to the core and excluding from the definition the use of "non-core" components (such as cameras, lights, etc.) that would not significantly alter core reactivity. This would allow movement cf other components within the reactor vessel (with fuel in the vessel) that would have no effect on core reactivity. The proposed change would continue to maintain the required level of safety while eliminating unnecessary restrictions on the movement of items such as cameras, etc. The proposed change would continue to allow the application of appropriate limits to the movement of components that could affect core reactivity."

For WCGS, Amendment No.109 dated September 18,1997 revised the CTS CORE ALTERATION definition (1.9) to the wording in NUREG-1431, Rev.1. Therefore, DOC 1-06-LS 1 and DOC 1-33-A are no longer applicable to WCGS.

ATTACHED PAGES:

Encl. 2 1-2, Encl. 3A 1,2,6 Encl. 3B 1, 4 Encl. 4 1,15,16

f1.0 USE AND APPUCATIONl 1.0 hEFINITION fAMTAIMMCMT 1MTC/*_DITV 4F { AMT A nam arkrr tuyge_gSr?V.

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CORE ALTERATION i

e - --

1 4,8 CORE ALTERADOR shall be the ement ^'---[

of an hsel M[

ll9 48 ' l-3l

  • -' # " p'a i

[ sources, or roastIv tv c nonts within reactor vessel e

M~Q*4F '

vessel moved and the vesselc nsion of COR ERATION d

f

_all sh reclude compi of move f a componenti afe eensesvebve i

CORE OPERATING LIMITS REPORTdCOLRQ

\\

4,40 The COLR is the unit-specific

' ' ' ^ ~ '

~ 101 A7" document that providesicycle specific param;^. x:: :;:.L. ; limits for the current eposehag reload cycle. These cycle-specific er :; _. ;;+rametedlimits shall be determined for each reload cycle in accordance with Specification 6.9.1.9.

Plant operation within these operating limits is addressed in individual Specifications.

2

[

y_

f l

'll,9 CORE ALTEK4Tio*J shall W +he m.vment of g ua.R.,

sou.rcas., or reach'v'% convirf. componerh wiM tN.

reactar vessel tal A the. vessel b.ad. removrd mL fu.at i ha. nssel. Susysiaw of CORE At.Trr. EAT *lo*a shall not A8 clude, comp A+886 6'f' "* * *"Y d "-

A P

compoM tu o safe posittin.

WOLF CREEK UNIT 1 1-2 Amendment No. 64. 8%

Mark-up of CTS 1.0 3/15/97

i DESCRIPTION OF CHANGES TO CURRENT TS Section 1.0 This enclosure contains a brief description / justification for each marked up change to current Technical Specifications.. The changes are identified by change numbers contained in Enclosure 2 (Mark up of the current Technical Specifications). In addition, the referenced No Significant Hazards Considerations (NSHCs) are contained in Enclosure 4.

Only technical changes are discussed: administrative changes (i.e..

format, presentation, and editorial changes) made to conform to the improved Technical Specifications are not discussed. For Enclosures 3A, 3B, 4, 6A and 6B, text in brackets "[ ]" indicates the information is plant specific and is not comon to all the Joint Lwensing Subcommittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that location.

CHANGE NUMBER NSiC DESCRIPTION 1 01 A

These definitions would be reworded to be consistent with NUREG 1431. The proposed reworoing included in this category does not involve any changes of a technical nature.

1,02 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38).

g jg 1 03 M

The definition of channel halibration is reworded to be consistent with NUREG 143P. The revised wording provides additional detail concerning calibration of instrument channels with RTD's or thermocouples.

,,i i

1 04 y LCr This d nition uld no 1 nger be d and s

icati in ITS tion 3 and A strative ontrol ection d be r sed ac dingly.

cur t TS d ition Contai nt Integr y would eted e cons ent wi UREG 143 This nition is ef ctively corpor into th REG 14 ases r

t new Co inment iting Co tion f perat (ITS 3.6.1) the inistrat Contro ectio or the Co inmen akage Ra esting ogram the Contai t Tendon rveillanc Progr Nsstti 3A-l 1 05 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

[W4 l 1 06 I,,S-t-The cur t TS ini d for C eAlter3tfonswofdbe led c isten ith NU 1431. tyqualify/a cor tera as ement of uel, sou,rx~es, or her reas vity c trol co nents. Tirfs pro ed ch geis{

tidt 3pplicable to W.&S. Sec'Conversan CampwnpTada }

ndowm. 3Gi).

WCGS-Description of Changes to CTS 1.0 i

S/15/97

CHANGE NUMBER NSE DESCRIPTION l9.i-3 Iess stri ' ve' ce th curr t TS finit n def nes l

Lt mov t of ny c nent ithin re tor v sel ith f 1

ve 1 as Core erat n.

ve,

si t

ropose defini on wou limi core te tions Lot manip ations at cou affe core ea ivity, I th repose hange accept le fr the a

int of heal and sa y of t _ publ 1 07 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

1 08 A'

The current TS definitions for Engineered Safety Features Response Time and Reactor Trip System Response Time would be modified to be consistent with NUREG 1431. In addition, the term " measured" would be replaced by

" verified" to be consistent with the requirements of improved TS SR 3.3.1.16 and SR 3.3.2.10 to verify response time is within limits. The addition of the statement that response time may be verified by means of any series of sequential, overlapping, or total steps so that the entire response time is verified, is aditinistrative in nature.

This is consistent with the methodology presently described in the current TS Bases for demonstrating total channel response time.

1 09 A

The current TS definition for Frequency Notation (and Table 1.1, Frequency Notation) would be deleted to be consistent with NUREG 1431. The acronyms defined in Table 1.1 Frequency Notation, are no longer used in NUREG 1431.

Surveillance frequencies are spelled out in NUREG 1431, thereby obviating the definition. This is a non technical change made to conform to NUREG-1431.

=

Q s.4,...(l 1 10 g

T ew inition r ma al able primary ntai nt leak e rat (L. )

uld be dded t the imp ved TS t con stent ith NURE 1431.

is ition h nd ermin to be admin trative change o the bas tha his def ition s simpi y

[ cop from S Ad nistrati Contr s Secti 6.8.41]

t he defin ions.

t4at uwd.

1 11 A

The current TS definitions for Identified Leakage.

Unidentified Leakage, and Pressure Boundary Leakage have been merged into one definition for Leakage. This is a nontechnical change since it will not alter the manner in which leakage is accounted for and treated from present WCGS-Description of Changes to CTS 1.0 2

S/15/97

CHANGE NLABER HSE DESCRIPTION improved TS. The proposed changes are administrative in nature and by themselves arf no_t techni_ cal changes, incorporating travelers @rn#4,,atiti,20fd3 IG l 4-11 hsTh 2.a,"1_M T5TF$107 1 27 Not applicable to WCGS. 5ee conversion comparison Table (enclosure 3B).

1 28 LG The current TS definition of CONTROLLED LEAKAGE is deleted to be consistent with NUREG 1431. Rev. 1.

The RCP seal water return flow limit is moved to a licensee controlled document.

[idua.T 34 -6% o s.s.s -zj 1 29-

'Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38).g4Tp-2nc -

Consistent with(LS;F15HfeiV1) the definitions of Channe1NI'l"I k 1 30'-

A Operational Test (C0T).,[ ] and Trip Actuating Device

~

c L tvwske Rety'Ted.

Operational Test (TADOT) is expanded to include the Qteva. RsJg Tes+,

details of acceptable performance methodology.

Performance of these te in a series of. sequential, overlapping, or total steps provi he necessary C'

assurance of appropriate operation of the channe1Q j

This change also makes the COT?[ ] and TADOT definitions l

consistent with the current TS and the NUREG 1431 definition of channel calibration which already contains similar wording,

(, retag, or cienca.,respechg Not le t See,,46nvepdonF4moarfsonTg>1e) h 1 31 1

re 3B. IN SEe.T SA -(.b H cp i. t 1 {

1 32 A

The definition of channel calibratic and TADOT is

@ t. t - 2.T h

reworded to be consistent with TSTFQto clarify the phrase-

" entire channel" thus reducing the potential for inconsistent interpretatian af

  • nhraw as exnerienced by a number of

,["[

.f.j,M'" [

g g,g.3 }

P 1 33

- Thi an fievi st de initio of Co Alt ati s to ete "

man lati " and conser ative" consi ten with NURE 431.

wo s as ed in de nitio wer redu ant I

delet the rds s not er t mea ng f the a

definiti n.

e4.4,77h c=Rs 4o IM(rs. See. Cowiew Cqer A

%Ra. (Encl s.una.3 B').

M

[.34 44 a p(licMa.in (ACGS. se.e. C.*nvesuew Ca'E *r ts.z.

f r wt Enc 4== 2,a 3.

g --;

l-3 5Meegh l-41 145 EAT 3 Sechek J.6 KAT.n.

a WCGS-Description of Changes to CTS 1.0 6

S/258 7

1 CONVERSION COMPARISON TABLE - CURRENT TS 1.0 raceteri APPLICABILITY TECH SPEC CHANGE

^

DIABLO CANYON COMANCE PEAK WOLF CREEK CALLAWAY NUPEER DESCRIPTION 1-01 These definitions would be reworded to be consistent with Yes Yes Yes Yes A

NLREG-1431. The proposed rewording included in this category does not involve any changes of a technical nature.

1 02 The definitions for Analog Channel Operational Test and No - do not have Yes No - do not have No " Digital" is A

Digital Channel Operational Test would be co sined into a the Digital Channel the Digital Channel not included in single definition of Channel Operational Test (CDT).

Operational test Operational test current TS.

definition.

definition.

1-03 The definition of channel calibration is reworded. The Yes Yes Yes Yes M

revised wording provides additional detail concerning calibration of instrument channels with RTD's or ther--E 2ples.

1-04 This definition would no longer be used and the Yes Yes Yes Yes c

(A I.G specifications in Section 3.6 would be revised accordingly.

T5 3.6 t be car sene) b be.OPERM cy 3.6.g.Q

~

The current TS definitign__for Containment Integrity would be.

t deleted. (il hais been replacad-ioi& 4he, ncia regeAlerrne td betwed n

1 05 The current TS definition for Controlled Leakage would be Yes Yes No. See Change No. See Change Nuder 1 28-LG.

Nueer 1-28 LG.

A deleted.

v4o. h.b bNes 1-06 The current TS definition for Core Alterations would be No. Already in CTS.

Yes see incorporated f g,g 3 j LS 1 modified to qualify a core alteration as movement of fuel.

y :T5 uefdQ./

s sources. or other reactivity control c me wnts.

1-07 A The location of the thyroid dose conversion factors used for Yes No. already in CTS No already in CTS No. already in CTS DOSE EQUIVALENT l-131 have been added in accordance with NUREG-1431. Rev. 1.

1-08 The current TS definitions for Engineered Safety Features Yes Yes Yes Yes Response Time and Reactor Trip System Response Time would be A

modified. In addition, the term " measured" would be replace by " verified" to be consistent with the requirements of improved TS SR 3.3.1.16 and SR 3.3.2.10 to verify response time is within limits.

5/15/17 e r rre c......

r,..

...;.-;,,,, Tar Mo* - ( T V U 11

CONVERSION COMPARISON'rABLE - CURRENT TS 1.0 rage 4 or 4 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION jDIABLOCANYON COMANCHE PEAK WOLF CREEK CALLAWAY 1-28 The definition of CONTROLLED LEAKAGE is deleted. The RCP No See change No - See Change Yes. Hoved to USAR Yes. Hoved to FSAR

~

LG seal water return flow limit is moved to a licensee nunber 1-05 A.

Nunter 1-05 A.

Section 16.

Section 16.4.

controlled document.

1-29 Allows measuring of QPTR when one or more excore detectors No Yes, Portion of No No definition being LS 3 channels are inoperable with moveable incore detectors.

changed only in CPSES CTS The definition of Channel Operational Test (C0T).f[ ] and Yes Yes Yes Yes A

TADOT is expanded to include the details of acceptable

ekbl, lg g,i_ ; ]

1-30 performance methodology. Performance of this test in a S12ve Reig ' Tad' series of sequential, overlapping, or total channel steps provides the necessary assurance of appropriate __ operation of the @channepe123,~ordevid. respseg

- Jeb

((N 1-31 Definitions of specific plant systems which are defined by Yes Yes Yes Ves A

the plant design are deleted.

1-32 The definitions of CHANNEL CALIBRATION. COT. [ ] and TADOT Yes Yes Yes Yes (Qt.t-2.]

A are reworded to be consistent with the TSTF-@*' lhe revised QZo D Chi" '8d -)

i lay. T8d s's SN' wording clarifies what is meant by " entire channel."(The clef inihin of Aciushr c-1-33 This change revised the CTS definition of CORE ALTERATION to Yes Yes J #e,80. AmMmd yes A

delete delete "or manipalation" and " conservative"

[ 109 Acorporded.

"~"-'-l 4 I

  • I ~3]

oc'dQj I[

tusen 38-4 os.icij 34 SecWm 3.(. RAT kl 5/15/97 renversimo Consonrision Tame - Courrent TS 1.0

=. -

NO SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC)

CONTENTS i

l 1.

Organi za ti on........................................ 2 II.

Description of NSHC Evaluations...................... 3 III.

Generic No Significant Hazards Considerations "A" - Administrative Changes.........................

5 "R"

Relocated Technical Specifications............. 7 "LG" Less Restrictive (Moving Information Out of the Technical Speci fications)................. 10 "H"

More Restrictive Requirements................. 12 IV.

Specific No Significant Hazards Considerations "LS" MA. m.I.Iuchle.h Q l'l-3

.1';

LS1..................................m.

m..

LS 2.............................OM Aiirl!.<Ah44.....#p o i. i. t )

LS 3.....................................Not'Applicable WCGS-NSHCs-CTS 1.0 1

5/15/9I

[

Delsh.

\\ Q l \\-3 )

IV; SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS L

NSHC LS 1 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE-REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS The current.TS definition of Core Alterations would be modified to conform NUREG-1431 by qualifying a core alteration as a movement of fuel, sources, or othe reactivity control components. Other reactivity control components include items s as shutdown and control rods and neutron absorbers. This would allow movement of r components

. within the' reactor vessel (with fuel in the vessel) that would have effect on core reactivity. The proposed change would continue to maintain the r red level of safety while eliminating unnecessary restrictions on the movement of ens such as cameras.

etc.

1 LThis proposed TS change has been evaluated and it has bee determined that it involves

'no' significant hazards consideration.. This determ. ation has been performed in accordance with the criteria set forth in 10 CFR 50.

(c) as quoted below:

"The Cannission may make a final determin ion, pursuant to the procedures In 50.91. that a proposed amendnent to an rating license for a facility licensed under 50. 21 (b) or 50.22 cr for a t ting facility involves no significant hazards consideration. If operatio of the facility in accordance with the proposed a'mendnent would not:

1.

Involve a significant i rease in the probability or consequences of an accident previously e aluated; or 2.

Create the possib' ity of a new or different kind of accident from any accident previo ly evaluated; or

.I 3.

Involve a s nificant reduction in a margin of safety."

The following evaluati i is provided for the three categories of the significant hazards consideration stand ds:

1.

Does the nge involve a significant increase in the probability or consequences of an a ident previously evaluated?

The propos change would continue to allow the application of appropriate limits to the mov of components that could affect core reactivity. The proposed change would

. not aff t the initiators of any analyzed events and will not alter assumptions relative to mi gation of accident or transient events. The probability of any core reactivity acc is not increased since the proposed change ensures control of those components ing the potential for impact on the accident analyses. Therefore, this change does t involve a significant increase in the probability or consequences of an accident previously evaluated.

. WCGS-NSHCs-CTS 1.0 15 S/ESRI j

o

DsWe.

Qld-3 IV.

SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 1

. continued)

{

(

2.-

Does the change create the' possibility of a new or different kind accident 1

i; from any' accident previously evaluated?

The proposed change does not necessitate a physical alteration of plant (no new or i

different type of equipment will be installed) or changes in par ers governing normal 4

plant operation. The proposed change does impose differen equirements. However, these changes are consistent with assumptions made in the ety analysis and licensing i

basis. Thus, this change does not create the possibil y of a new or different kind-of. accident from any accident previously evaluated.

3.-

Does this change involve a significant uction in a margin of safety?

Since the proposed change will continue t allow the application of appropriate limits to the movement of components within t reactor vessel (with fuel in the vessel) that could affect core reactivity, the oposed change will not result in a significant j

. reduction in a margin of safety.

i ND SI ICANT HAZARDS CONSIDERATION DETERNINATION s

Based on the above aluation it is concluded that the activities associated with NSHC "CS 1". resulti from the conversion to the improved TS format satisfy the no significant' ards consideration standards of 10 CFR 50.92(c): and accordingly, a no significa azards consideration finding is justified.

- WCGS-NSHCs-CTS 1.0 16 S/25/97

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1.1-4 APPLICABILITY: DC, CP, WC, CA REQUEST:

CTS 1.13, Engineered Safety Features Response Time [Diablo Canyon, Wolf Creek, and Callaway)

CTS 1.14, Engineered Safety Features Response Time [ Comanche Peak)

CTS 1.27, Reactor Trip System Response Time [ Wolf Creek 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: If NRC 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 will not be reviewed on a plant-specific basis. Also, revise the DOC to include TSTF-111 applicability.

FLOG RESPONSE: The response to Comment Number 1.1-4 will be provided separately after the August 17,1998 NRC letter to NEl on TSTF-111 has been fully evaluated.

ATTACHED PAGES:

None 1

l

ADDITIONAL INFORMATION COVER SHEET i

ADDITIONAL INFORMATION NO: O 1.1-5 APPLICABILITY: DC, CP, WC, CA REQUEST:

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 hft settings, 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 Wolf Creek) 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. If WOG-67 is not approved by the TSTF, then this change should be withdrawn from the conversion submittal at the time of the TSTF rejection. If WOG-67 has not been acted upon by TSTF, or has been j

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: WOG-67, Rev.1 has been designated TSTF-233 and was issued to the NRC by NEl on March 10,1998. The latest status report from the TSTF j

industry database, dated July 27,1998, indicates that the NRC has approved TSTF-233. The proposed wording in TSTF-233 was modified from WOG-67 and these modifications have been incorporated into the ITS. In addition, the PTLR definition includes the PORV lift settings consistent with the traveler's change to ITS Section 5.5.6. The FLOG continues to pursue the changes proposed by this traveler.

ATTACHED PAGES:

Encl. 2 1-5 Encl. 3A 3

Encl. 5A Traveler Status page,1.1-5 Encl.6A 2

h'.

(i 0 USE AND APPLICATIONl 1.0@EFINITION l

I pAESSUPE BOUNDARY LEA AGE

_'l-l l-A,

gm t22 ooESSURE 900MO?ov LEAvAOE chm M 'dep (r e-* d--

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b t;, ;!; r::", c? "^T-

' r:2!

omnrece enuront monroang t22 The P90 CESS COMTPOL P90Go ^ (oCP) the!! cente!r 'he curren* ferrr'r 4-16-LG?

- r;!!ng, cr2; :, tett, 2nd d:*:r rMe.: te be r de te :=ur: thet

^

t pr-~ ; :nd ;r-M;.; ^'- "' --diere"r: rree- '- :1 en d:m:.:tried prer- :5; cf s'"rr' ^' :! r'-'rd reet : "d r-er r"! M rerr ;!bhrd !-

re. : v :; n te r:r e cer;"r.ce w S to CFo one 20, St. 2nd ?*, St?e

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,u.--.

3 BMBfeft:dtWBfaHi 7F15-Al 9 ms~

t24 o0POE c: UPO!NG che!! M cr; cen"e!'ed p-- er cf dM$2 ;:n; :!: er LCD 3.4.3, "RCS bWC, d

-n f:cm cc.1xmrf te m !ntrin ::r; --ture, prerr, humidi'"', cencent--tien

-....a,_-~-.me....a----_.-;,-,,...;,

'Temperabrv., (P/T) Limik,.. ad I,_m..---,-u---- am--

,'. ~ L__~. E_.Z_,'.17. C_ i_ _.... _.. _.

L.Co 3.+.12.. "imTem. atu.or C Ji- ~ '- ~~

~

~ " - ' ' " ~

,p f(NEW) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) l bd*'" * " _ _

The PTLR is the unit specific document that provides the reactor vessel pressure ' 'HN74]-

and temperature limits, including hostup and cooldown rates and the power operated relief valve lift settings and the Low Temperature Ca.v::are Protection (LTOP) System arming temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined Plant operation within these imits are addressed inidLC' CS 'D])% g,g g {

for each fluence period in accordance with the Admini_strative Controls section.

J QUADRANT POWER TILT RATIOlf0PTR)}

e.natay

  • 25 CUADP_^?T oC'f.5P !LT

^T!O!OPTR)shall be the ratio of the maximum 1n18-At.

1 upper excore detector calibrated output to the average of the upper excore detector

"*g*~~*""

calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater. With one excore detector inoperable, the remaining three detectors shall be used for computing the average.

RATED THERMAL POWERfiRUI) 4,23 o nTED TPEot' A.L PO'?.TR!RTP)shall be a total (reactorjcore heat transfer

]Ijl [

rate to the reactor coolant of 3565 MWt.

REACTOR TRIP SYSTEMfRTS'51 RESPONSE TIME R

4-27 The REACTOP "' SYSTE**MTSIRESPONSE TIME shall be the time T.108 A?

interval from when the monitored parameter exceeds its Trip Setpoint at the channel sensor untilloss of stationary gripper coil voltaoe.[The response time Jmay be venfied by means of any series of sequential overlapping, or total (t; tops so that the entire response time is verified.J oconoramiecucur 4 2S ^ PEPOPT^ OLE EVEMT de'! be cr; cf *ere rend!!!cne cerfed !-

il-19-Al S etien 50 72 ! i0 CF" t'* 50 WOLF CREEK - UNIT 1 1-5 Amenament No. 42,64.69 Mark-up of CTS 1.0 W15/97

CHANGE Nl#6ER EilC DESCRIPTION practice. The definition of unidentified leakage has been expanded to include "except RCP seal water [ ] leakoff."

to be consistent with NUREG 1431.

1112 A-The current TS definition for Member of the Public, would be deleted to be consistent with NUREG 1431. This.

definition would be deleted on the basis that it is

. defined in 10 CFR 20 and_40 CFR 190.

_ 1 13 A.

The current TS definition of the Offsite Dose Calculation Manual (0DCM) [ ] would be [ ] incorporated into the Administrative Controls section of the improved STS.

This change is nontechnical because the definition of the ODCM [ ] will be [ ] moved to another section of the improved TS.

1 14 A

The current TS definition for Operational Mode would be revised to " Mode" and the wording would be revised to be consistent with NUREG 1431. The changes are nontechnical since_ they will not affect current practice.

1 15 A

The current TS definitions of HVAC systems and functions would be deleted to be consistent with NUREG 1431.

'gg,,,,,7g C."Mit>hlt10D4thedtJdaWDsfeq,7JJ" Purge -

8 urging" and " Venting"; where used, do not require special definitions. [ EAT 34 33

@ t.t 4 l-

'l 16 LG The current TS definition of the Process Controls Program (PCF) would be relocated outside of the TS along with the Administrative Controls description of this program to be consistent with NUREG 1431. The PCP. definition and program description from Administrative' Controls are moved into the USAR. The PCP implements regulatory requirements and need not be restated in the TS. The requirement to' comply with applicable Federal and State regulations for the processing of radioactive waste provides sufficient control of future changes to the PCP.

1 17 A:

The definition of a Pressure Temperature Limits Report (PTLR) would be added to be consistent with NUREG 1431 and hF GENFVRM he definition will support the use of a[Qi.t-y PTLR. Adding t _ definition is purely administrative in -

_ nature.lin addhn,1he. PTLR defmWin e e m-hl Qm,a.vgggg.

natstemt 4m**. hve. tera c%, teg 1 18 A

ine pornon or tne' definition for OPTR dealing with an inoperable excore detector is addressed in the Conditions and surveillance Requirements of improved TS 3.2.4.

I-Qt.t-el

^ WCGS-Description of Changes to CTS 1.0 3

5/15/97

INDUSTRY TRAVELERS APPL'ICABLE TO SECTION 1.0 TRAVELER #

STATUS DIFFERENCE #

COMMENTS TSTF-19, Rev.1

@ incorporated

/af.o.ma y TSTF W Incorporated 1.1-9 h

@ ' l-8 I CT W R / InctfrporA 7

713P?

r o i.i - 2. \\

Q$/

46corperilted] f R-

. \\ Q t.t-A \\

TSTF-111, Rev.1 Incorporated 1.1-5 QWp61gey/D Incorporated 1.1-6 (Qbhp,} @ M ~R NG4W,1)

Incorporated 1.1-3

{Q I 4-1 l I

M Incorporated 1

1.1-11 la t 4-I \\

-e a 3.

.s -c.

Q 3.6.t - 6) ti.

i S/15/97

yQ %

v

'1:11 1.1 Definitions - (continued)

PHYSICS TESTS b.

Authorized under the provisions of 10 CFR 50.59; (continued)-

or c.

Otherwise approved by the Nuclear Regulatory Commission.

PRESSURE AM)

The PTLR is the unit specific document that TDFERA11JRE LIMITS pmvides the reactor vessel pressure and -

REPORT (PTLR) temperature limits, including heatup and cooldown g gy rates and;theEpower.6perattd!reHeCvalTre lif(

settiner andShe= %7tjaraturee09erpressure Pto!:ectioni(50P) SDDungssigtt.emperature;; for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with p,,,,,, j Specification 5.6.6.

Plant operation within these A h./

limitsg gqessp_

gy t

N..y......

,,,.,, ' ~ =.. r:

Tr.,.;r;tur; ^.;ri,c;;;;r; I. et;ttr. C.T^^' %;t;;;;."

00ADRANT POWER TILT QPTR sha'11 be the ratio of the maximum upper RATIO (QPTR) excore detector calibrated output to the average of the upper excore detector calibrated outputs. or the i

ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

l RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of. 3565 Wt.

gggypsr REACTOR TRIP The RTS RESPONSE TIME shall be that time interval SYSTEM (RTS) RESPONSE from when the monitored parameter exceeds its RTS TIME trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured verified by means of any series of sequential. overlapping, or total steps so that the

%EES%

entire response time is meesweed verified.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be (continued)

WCGS-Mark-up ofNUREG-1431 -ITS 1.0 1.1 5 5/15M7

A

= _ _ _

. ~ - -

W-ln ed&Mn,42 PTLA ch.64, Men ActaAeo ke. PbM I "fY "'b' conM. tut with %. tve rste.v's chy CHANGE NUMBER JUSTIFICATION @

on sA.c.

p,,,,,

~

I The [LTOP] arming temperature was added to the PTLR. since changes in the heatup/cooldown figures could change the arming temperature. This change corrects the PTLR definition to be consistent with all of the requirements contained in the PTLR. Referenced methodologies for the PTLR would contain the methodology used to develop the heatup and

]

cooldown figures, as well as the methodology for developing the [LTOP] )

l-setpoints. This change is consistent with traveler W6)Gatge

1 C6rer-am.swice u-s-1 1.1 7 Not applicable to WCGS. See Conversion Comparison Table (t.nclosure goI.t-L

'1.1 8

'IThe r itor ssel ad os e bol reW ts r H00E

4. 5 h

ar lari p pos cha revis s foot ebf MODES and k

to r r to " equ ed r ctor ssel ad clo re bol fully l

ten ned" no cf MODE is re sed to ead "

uired eacto

{

sel clo re ts les than 11y t ioned." The ansit n I

Ipoint wee ES and 6 uld a so be c rifi as occ ring t

equir rea r vess head osure its ar less n fu y tensio requir number closu bolt, which y

ess i

tha he tot number is esta ished anal is tha demon rat ate ing c ssion preve leak and sure t

i Spction I stres imits f aff ed c s

exc (Thi,s nge is nsisten ith T 88.

IM Applic3LA.a.4s 14ast. S**.

(C_ og.v.4.r_a.iy de >p3 v s e 44A- ( E h 8 L**y.64. 88 # *}

  • 1.1 9' Consistent with idit,Altr3elvT. the definition of Channel Operational Test (C0T).,[ ] and Trip Actuating Device Operational Test (TADOT) is ig,g aos

%gy.),

expanded to include the details of aci.eptable performance methodology.1 i

Performance of this test in a series of sequential, overlapping, or N* Y ****

total @ steps rovides the necessary assurance of appropriate operation of the echannelhThischangealsomakestheCOT.,.

l j

definition consistent with the defynition of channel calibration which l

already contains similar wording. (fret 33,ordema.<gacto*g l

1.1-10 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 68).

1.1 11 Adds new example to ITS Section 1.4 to clarify surveillance frequencies l

that are contingent on both a specified frequency and plant conditions.

The ITS contains many Surveillance Frequencies that are contingent on both a "specified Frequency" and plant conditions. For example.

"Within 7 days prior to the initiation of Physics Tests." and " Prior to entering MODE 4 from H00E 5 if not performed within the previous 92 days." These Frequencies do not fall clearly under any of the existing Section 1.4 examples. The proposed example is needed to make clear WCGS-Differencesfrom NUREG-1431 - ITS 1.0 2

5/15/97

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1.1-6 APPLICABILITY: DC, CP, WC, CA REQUEST:

CTS 1.24, Purge - Purging [Callaway and Wolf Creek)

CTS 1.26, Purge - Purging (Diablo Canyon and Comanche Peak)

CTS 1.38, Ventilation Exhaust Treatment System [ Wolf Creek)

CTS 1.39, Ventilation Exhaust Treatment System (Callaway)

CTS 1.39, Venting [ Wolf Creek]

CTS 1.40, Venting CTS 1.40, Waste Gas Holdup System [ Wolf Creek)

CTS 1.41, Waste Gas Holdup System (Callaway]

j CTS 1.41, Ventilation Exhaust Treatment System [Diablo Canyon)

CTS 1.42, Venting [Diablo Canyon)

DOC 1-15-A l

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.

1 FLOG RESPONSE: DOC 1-15-A has been revised to provide additional justification that the deletion of the subject definitions are administrative in nature. The deletion of the subject definitions is consistent with NUREG-1431. These definitions are deleted since the CTS referring to the definitions no longer contain their use, or no longer are retained in the ITS. Discussion of the technical aspects of this change are addressed in each TS where they apply. Thus, the removal of the definition is considered administrative, with no impact of its own.

ATTACHED PAGES:

Encl. 3A 3

l t

1 CHANGE NUMBER H2C DESCRIPTION practice. The definition of unidentified leakage has been expanded to include."except RCP seal water [ ] leakoff."

to be consistent with NUREG 1431.

1 12 A

The current TS definition for Member of the Public, would be deleted to be consistent with NUREG 1431. This definition would be deleted on the basis that it is defined in 10 CFR 20 and 40 CFR 190.

1 13 A

The current TS definition of the Offsite Dose Calculation Manual (00CM) [ ] would be [ ] incorporated into the Administrative Controls section of the improved STS.

This change is nontechnical because the definition of the 00CM [ ] will be [ ] moved to another section of the improved TS.

i 1 14 A

The current TS definition for Operational Mode would be revised to " Mode" and the wording would be revised to be consistent with NUREG 1431. The changes are nontechnical i

since they will not affect current practice.

1 15 A

The current TS definitions of HVAC systems and functions would be deleted to be consistent with NUREG-1431.

g' i,3 f j

[ ADhttiop4RhowitJefapnifit'DsfespT" Purge -

Jurging" an'd " Venting", where used, do not require special definitions. [a# 34 3p y i,g g l 1 16 LG The current TS definition of the Process Controls Program (PCP) would be relocated outside of the TS along with the Administrative Controls description of this program to be -

consistent with NUREG 1431. The PCP definition and program

(

description from Administrative Controls are moved into the USAR. The PCP implements regulatory requirements and need not be restated in the TS. The requirement to comply with applicable Federal and State regulations for the processing of radioactive waste provides sufficient control of future changes to the PCP.

.1 17 A

The definition of a Pressure Temperature Limits Report PTLR) would be added to be consistent with NUREG 1431 and hF-2.S1 00lWRMIJ Jhe definition will support the use of a[Qi.g-vj PTLR. Add _ing thhdefinition__is purely administrative in -

~-

. _ nature. fin addition,ihs. PTt R defiWan e 6-h t

QPe,nvjgttjy"comtsht J*h he.1 era ch&n 1 18 A

ine poruon or Ine definition for QPTR dealing with an l:

inoperable excore detector is addressed in the Conditions i

and surveillance Requirements of improved TS 3.2.4.

D Q l.1-0 l WCGS-Description of Changes to CTS 1.0 3

S/15/97

INSERT 3A-3a 0 1.1-8 The CTS definition of Quadrant Power Tilt Ratio requires with one excore detectcr inoperable inoperable, the remaining three detectors shall be used.

~ITS SR 3.2.4.1-Note 1 incorporates the CTS definition requirement such that with input from. one or more Power Range Neutron Flux Channel inoperable, the remaining three Power Range Channel inputs can be used for calculating QPTR.

In addition, for Callaway and Wolf Creek, see DOC 4-09-A in Section 3.2 (Attachment No.8) which reflects that portion of the OPTR definition dealing with an inoperable excore detector and Note 1 to ITS SR 3.2.4.1.

INSERT 3A-3b 0 1.1-6 These definitions are deleted since the CTS referring to the definitions no longer contain their use, or no longer are retained in the ITS.

Discussion of the technical aspects of this change are addressed in each TS where they apply.

1 1

I

,---r w

p 3-.,

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1.1-7 APPLICABILITY: DC, CP, WC, CA REQUEST:

CTS 1.40, Waste Gas Holdup System [ Wolf Creek)

CTS 1.41, Waste Gas Holdup System [Callaway and Comanche Peak)

DOC 1-15-A DOC 1-31-A For Callaway and Wolf Creek, the 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.

1 Comment: Clarify this deviation and, if appropriate, revise the CTS markup with the correct DOC for the particular plant.

FLOG RESPONSE: DOC 1-15-A was intended to describe the deletion of definitions for HVAC i

processes which are in the CTS, Section 1.0. DOC 1-31-A describes the deletion of definitions for specific systems which are defined by the plant design and which are in the CTS, Section 1.0.

DOC 1-15-A will be revised to insert the word " processes" after "HVAC" and delete the words " systems and functions" which led to this confusion.

The bracketed systems will also be deleted from DOC 1-15-A.

The " Waste Gas Holdup System" (for all FLOG plants except DCPP) and

" Ventilation Exhaust Treatment System" (for all FLOG plants except CPSES) are not HVAC processes. The correct DOC for the deletion of the definitions of these systems is DOC 1-31-A. The Callaway, Diablo Canyon, and Wolf Creek references in their respective CTS markups will be changed to DOC 1-31-A.

ATTACHED PAGES:

Encl. 2 1-7 Encl.3A 3, 6 Encl. 3B 2, 4 i

I I

l

.m

_ _ _ _ _ _ _ _ _ _ _ ~

1 l

[1.0 USE AND APPUCATION]

I 1.0@EFINITION I

i l EklihEkfTle! Eft I C AVanc

?jg gy{dM NN8NN4M$hbN4 4 GA

-- 1 lu1MEk. f.TietPP1 1_E A S/ A N_ E _ L _te km_ _.39. s _ _ e.

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i nunceToiPTen aoca R" w kz w a QUAB W

4.. *.M..A_. t.tu. B E cT. D.I.PT. E_M.A SE A..u._ll u_ _ _-..,. _ _

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4..e..n A u. cuTi_, A.Ti.n_ u. e_v.u A n ie_T.Te.e A.Ta.e uT e.v. e r. e_u.. _'._.. u_ -.,... - __- -.

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WOLF CREEK - UNIT 1 17 Amendment No. 61

)

- Mark-up of CTS 1.0 5/15M

l CME j

NUMER EC DESCRIPTION practice. The definition of unidentified leakage has been expanded to include "except RCP seal water [ ] leakoff."

to be consistent with NUREG 1431.

1 12 A

The current TS definition for Member of the Public, would be deleted to be consistent with NUREG-1431. This definition would be deleted on the basis that it is defined in 10 CFR 20 and 40 CFR 190.

-1 13 A

The current TS definition of the Offsite Dose Calculation l

Manual (ODCM) [ ] would be [ ] incorporated _into the Administrative Controls section of the improved STS.

This change is nontechnical because the definition of the ODCM [ ] will be [ ] moved to another section of the l

improved TS.

1 14 A

The current TS definition for Operational Mode would be revised to " Mode" and the wording would be revised to be consistent with NUREG 1431. The changes are nontechnical since they will not affect current practice.

1 15 A

The current TS definitions of HVAC systems and functions would be deleted to be consistent with NUREG 1431.

fq,3.q-( "#ent141111oDfRheuttJdalsufit}sfeg/3" Purge -

~'

Jurging" and " Venting", where used, do not require special l

definitions. [ EAT 34 33

@ t.t t,,1 1-16 LG The current TS definition of the Process Controls Program (PCP) would be relocated outside of the TS along with the Administrative Controls description of this program to be I

consistent with NUREG 1431. The PCP definition and program description' from Administrative Controls are moved into the USAR. The PCP implements regulatory requirements and need not be restated in the TS. The requirement to comply l

with applicable Federal and State regulations for the l

processing of radioactive waste provides sufficient control of future changes to the PCP.

1 17 A

The definition of a Pressure Temperature Limits Report PTLR) would be added to be consistent with NUREG 1431 and F.r.51L OgMFVRpO} Jhe definition will support the use of a[qu yj PTLR. Adding thhdefinition_ is purely administrative in -

_ nature.lln add %n,1hc PTLR. defid.Wan e e" Wa T getwo.vgyge enteht wiW*a hiera ch% h) t 1 18 A

- ine poruon or Ineliefinition for QPTR dealing with an j

inoperable excore detector is addressed in the Conditions and surveill_ance Requirements of improved TS 3.2.4.

p 3 A " h Q t.t-e l WCGS-Description of Changes to CTS 1.0 3

S/25/97 l

l'

CHANGE NLNBER EilC DESCRIPTION improved TS. The proposed changes are administrative in nature and by themselves are not technical changes.

incorporating travelers @P74.,mitiM IG l 4-13

-CYsTh 2F7_: pod.

T5TF51D 1 27 Not applicable to WCGS. See conversion comparison Table (enclosure 38).

1 28 LG The current TS definition of C0KTROLLED LEAKAGE is deleted to be consistent with NUREG 1431. Rev. 1.

The RCP seal water return flow limit is moved to a licensee controlled document.

gameT 34 -

o.3, s.s. z j 1 29 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

,g Consistent with(L5FGHtiM) the definitions of Channe15Gl*l"I k 1 30 A

Operational Test (C0T).4[ ] and Trip Actuating Device L tvwske Wh' Tot.

Operational Test (TADOT) is expanded to include the Qtavw. Ralf***.

details of acceptable performance methodology.

Performance of these te in a series of sequential.-

overlapping. or total steps provi he necessary L'

assurance of appropriate operation of the channelp This change also makes the COT?[ ] and TADOT definitions I

consistent with the current TS and the NUREG 1431 definition of channel calibration which already contains similar wording.

(, relf or devni qubg r

Not ke t '

,_See dnvepdon f/mDyggon TgMe) h 1-31 1

re 3B. n W 5Ee.T.SA -(.b j j o s i-, [

The definition of channel calibratio

. and TADOT is 1 32 A h reworded to be consistent with TSTF$to clarify the phrase lcp t.t-2

" entire channel" thus reducing the potential for inconsistent j

interpretation nf the nhrase as exnerienced by a number of

,[g, y,$,N8*

q g,g _3 \\

P 1 33 Thi a

evi st de initio of Co e Alt ati s to ete " r man lati " and conser ative" consi en with j

NURE 431.

wo s as ed in de nitio wer redu ant i

a delet the rds s not er t mea ng f the definiti n.

t4.+ applic=A4e LMGS. See. Cowvemb Ca9 mew "T2A (r::nd.muu 36').

M h.34 Not applicaMA ib (4 CGS. See. C*nw85tr" P '")"

LS. 2.

- p =

c NT5**= M qqi.t.y

- s5%+ I-4I tusenT a& su.+s.s.t. g.sn WCGS-Description of Changes to CTS 1.0 6

S/158 7

. -.._~.

INSERT 3A-6a 0 3.5.5-2 i

CONTROLLED LEAKAGE as defined in the CTS has nothing to do with the performance of the ECCS system. That definition relates only to the proper performance of the RCP seals. Facility performance and operational details are required to be described in the USAR by 10CFR50.34. It is therefore acceptable to move the RCP seal water return flow limit to the USAR since that return flow limit does not satisfy any of the four criteria in 10CFR50.36 and since that type of detailed information will be adequately controlled in the USAR. Therefore, it is appropriate to delete the CONTROLLED LEAKAGE definition 3

and maintain seal leakoff limits in the USAR. See also DOC 6-28-LG in Section 3.4.

i INSERT 3A-6b 0 1.1-7 Definitions of specific plant systems which are defined by the plant design are deleted consistent with NUREG-1431.

The definitions contained in ITS.I.0 are intended for definitions that are necessary for the understanding of the specifications and can be generically defined for.most plants.

Definitions of systems that are not used in the specifications, or are specific to a particular plant (or only a few plants) are no longer defined in this section.

Where necessary, such terms are defined in the Bases for the applicable specifications.

I i'

_ _ _ = _..

r i

4 CONVERSION COMPARISOltTABLE - CURRENTTS 1.0 P.se 2.r4

'L TECH SPEC CHANGE

-APPLICABILITY t

NUpBER DESCRIPTION DIABLO CMlYON COMANCE PEAK lWOLFCREEK CALUNAY 1-09 The current TS definition for Frequency Notation (and Table Yes Yes Yes Yes A

1.1. Frequency Notation) would be deleted to be consistent l

with NUREG-1431. The acronyms defined in Table 1.1.

5 Frequency Notation. are no longer used in NLAtEG 1431.

1-10 The ra Cont s

on in Jee " N A Jee 64A Jae"- MA Jet

  • N A f

A-imum ow pri cont (L )

!"# '~' !

f wou to t i

4 F 4A se A.

i 1-11 The current TS definitions for Identified Leakage.

Yes

~

Yes Yes Yes l

A Unidentified Leakage, and Pressure Boundary Leakage have been merged into one definition for Leakage and reworded to be consistent with NUREG-1431.

L 1-12 The current TS definition for Member of the Public would be Yes Yes Yes Yes i

A deleted.

i 1-13 The current TS definition of the Offsite Dose Calculation Yes Yes Yes Yes

.j

+

A Manual (00CM)[ ] would be moved to the Administrative i

Controls Section of the ITS.

l 1-14 The current TS definition of *0perational Mode

  • would be Yes Yes Yes Yes i

e A

revised to

  • Mode
  • and re-w M.

1-15 The current TS definitions of HVAC systems and functions _

Yes Yes Yes Yes

_ecystaf"D

{qi.i f A

would be deleted.(Dedtilatrog/7gvir--

c Purge - Purging" and " Venting, where used, do not require-special definitions.

i 1-16 The current TS definition of the Process Controls Program Yes. Moved to FSAR.

Yes. Moved to FSAR.

Yes. Moved to USAR.

Yes. Moved to FSAR Section 16.25.

LG (PCP) would bemoved outside of the TS along with the i

Administrative Controls description of this program.

l 1-17 The definition of a Pressure Temperature Limits Report Yes Yes Yes Yes e

A (PTLR) would be added to. 4 the use of a PTLR.

Yes Yes Yes Yes i

1-18 The portion of the QPIR definition dealing with an A

inoperable excore detector is addressed in the Conditions 1

and Surveillance Requirements of 1,v

TS 3.2.4.

i SH5M7

?

WrGsrenversion Conwarision Tame - CTS 1.0 i

CONVERSION COMPARISONTABLE - CURRENT TS 1.0 rage 4 or4 TECH SPEC CHANGE APPLICAfsILITY CJMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 1 28 The definition of CONTROLLED LEAKAGE is deleted. The RCP No - Se'e change No - See Change Yes. Moved to USAR Yes. Moved to FSAR LG seal water return flow limit is moved to a licensee nunter 1-05-A.

Number 1-05-A.

Section 16.

Section 16.4.

controlled % - nt.

1-29 Allows measuring of QPTR when one or more excore detectors No Yes. Portion of No No LS-3 channels are inoperable with moveable incore detectors.

definition being changed only in CPSES CTS 1-30 The definition of Channel Operational Test (C0T).F[ ] and Yes Yes Yes Yes A

TADOT is expanded N include the details of acceptable Mk, ReQh}

p g,g. l j performance methodology. Performance of this test in a 3g,y,, g,g g4' series of sequential, overlapping, or total channel steps

=

provides the necessary assurance of appropriate operation of the @channefelag,ordevu.a. respsve.g]

- jled d[N 1-31 Definitions of specific plant systems which are defined by Yes Yes Yes h

A the plant design are deleted.

1-32 The definitions of CHANNEL CALIBRATION, COT. [ ] and TADOT Yes Yes Yes Yes

[q s. t - 2. j A

are reworded to be consistent with the TSTF- @ The revised _ QoD wording clarifies what is meant by " entire channel."(Thidef inihh of AchhrslohcTesth_Sm" kd*rNhb ies No. Amendm Yes 1-33 This change revised the CTS definition of CORE ALTERATION to Yes Yes LO9 Accepe(Ned.

r-

! O I*I-A delete delete "or manipulation" and " conservative".

Q ua4.j I

idSER.T 3B-4 a gog.gogl kocs 1-3 Aru.1 -4 sechb 3A g(E 5/15M7 nmrmion Osmnarision Talrie - Current TS 1.0

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1.1-8 APPLICABILITY: CP, WC, CA REQUEST:

CTS 1.25, Quadrant Power Tilt Ratio [ Wolf Creek 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 OPTR 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: As discussed in the transmittal letter and the

  • Methodology For Mark-Up of Current TS"in the back of Enclosure 2, the CTS has been marked up to reflect the substance of NUREG-1431, Revision 1. In general, only technical changes have been identified. However, some non-technical changes have also been included when the changes cannot easily be determined to be non-technical by a reviewer, or if an explanation is required to demonstrate that the change is non-technical. In generalif the requirement was relocated to a specification in the improved TS which does not correspond with the specification in which that requirement is located in the current TS, a DOC numt,ar was generated but the current TS text was not struck through.

DOC 1-18-A is revised to include the following: "The CTS definition of Quadrant Power Tilt Ratio requires with one excore detector inoperable, the remaining three detectors shall be used. ITS SR 3.2.4.1 Note 1 incorporates the CTS definition requirement such that with input from one Power Range Neutron Flux Channel inoperable, the remaining three Power Range Channelinputs can be used for calculating QPTR. In addition, for Callaway and Wolf Creek, see DOC 4-09-A in Section 3.2 (Attachment No.8) which reflects that portion of the OPTR definition dealing with an inoperable excore detector and Note 1 to ITS SR 3.2.4.1."

The CTS markup is consistent with the methodology discussed in the back of Enclosure 2.

ATTACHED PAGES:

Encl. 3A 3

. _-.-. - - -- ~.. --_-.

CHANGE l

NLDBER H2iG DESCRIPTION practice. The definition of unidentified leakage has been expanded to include "except RCP seal water [ ] leakoff."

to be consistent with NUREG 1431.

1 12 A

The current TS definition for Member of the Public. would be deleted to be consistent with NUREG 1431. This definition would be deleted on the basis that it is defined in 10 CFR 20 and 40 CFR 190.

1 13 A

The current TS definition of the Offsite Dose Calculation Manual (ODCH) [ ] would be [ ] incorporated into the Administrative Controls section of the improved STS.

This change is nontechnical because the definition of the ODCM [ ] will be [ ] moved to another section of the improved TS.

j 1 14 A

The current TS definition for Operational Mode would be revised to " Mode" and the wording would be revised to be consistent with NUREG 1431. The changes are nontechnical since they will not affect current practice.

l i

l 1 15 A

The current TS definitions of HVAC systems and functions would be deleted to be consistent with NUREG 1431. g,g y j L.78htM1Rio*D@ bust)ffaWjgfaq/J" Purge -

> urging" an' " Venting". where used, do not require special d

[ SAT 34 33 y i.t g 1 definitions.

1 16 LG The current TS definition of the Process. Controls Program (PCP) would be relocated outside of the TS along with the Administrative Controls description of this program to be consistent with NUREG 1431. The PCP definition and program

' description from Administrative Controls are moved into the USAR. The PCP implements regulatory requirements and need not be restated in the TS. The requirement to comply with applicable Federal and State regulations for the processing of radioactive waste provides sufficient control of future changes to the PCP.

1-17 A

The definition of a Pressure Temperature Limits Report

.(PTLR) would be added to be consistent with NUREG-1431 and hF NVRM Jhe definition will support the use of alQi.l-v}

PTLR. Add _ing thhdefinition is purely adm_inistrative in -

-~-

nature.lin addition,4he. PTt.R defi4tian tA e "- **.T t

ptwa.v j g ttp constsht s4* *a. hve.lera ek% u) 1 18 A

- ine poruon or Ine definition for QPTR dealing with an inoperable excore detector is addressed in the Conditions and surveillance Requirements of improved TS 3.2.4.

" h Q t.l-e l P

WCGS-Description of Changes to CTS 1.0 3

5/15/97

_.. ~.

1 INSERT'3A-3a 0 1.1-8 1

The CTS definition of Quadrant Power Tilt Ratio requires with one excore l

detector inoperable inoperable, the remaining three detectors shall be used.

ITS SR 3.2.4.1' Note 1 incorporates the CTS definition requirement such that with input from one or more Power Range Neutron Flux Channel inoperable, the remaining three Power Range Channel inputs can be used for calculating QPTR.

In addition, for Callaway and Wolf Creek, see DOC 4-09-A in Section 3.2 j

L (Attachment No.8) which reflects that portion of the OPTR definition dealing with an inoperable excore detector and Note 1 to ITS SR 3.2.4.1.

INSERT 3A-3b 0 1.1-6 These definitions are deleted since the CTS referring to the definitions no longer contain their use, or no longer are retained in the ITS. - Discussion of

(

the technical aspects of this change are addressed in each TS where they apply.

l.-

L l

I I

i i

1 I

l l

t l-I

l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1.1-9 APPLICABILITY: DC, CP, WC, CA REQUEST:

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 i

'~

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 if NRC has not approved TSTF-88 by the t'*ie the draft safety evaluation is prepared, then this change should be withdrawn from.:- conversion submittal at that l

time. This change will not be reviewed on a plant-specific basis.

~

FLOG RESPONSE: TSTF-88 has been withdrawn by the TSTF. Comanche Peak, Diablo Canyon, and Wolf Creek have deleted the changes discussed in TSTF-88 and have adopted the STS footnotes. Callaway intends to pursue these changes as an out of scope item given the plant-specific NRC safety l

evaluation cited in new DOC 1-34-LS-2. DOC 1-25-LS-2 has been reworded and revised to be DOC 1-25-A (see attached), applicable to all FLOG plants. New DOC 1-34-LS-2 is only applicable to Callaway.

ATTACHED PAGES:

I Encl. 2 1-9 Encl. 3A 5, 6 Encl. 3B 3, 4 Encl. 4 1,17,18 i

Encl. 5A Traveler Status page,1.1-7 l

Encl.6A 2

]

Encl.6B 2

I l

l.

4 i

f i

I

60 USE AND APPUCATION) 1.01pEFINITION TABLE M i

Sj"s9f #

QialiRAT4CNAL MODES mesu)msadzQl.l-9 l i

l-25-A AVERAGE REACTIVITY

% RATED

[ REACTOR) COOLANT MODE CONDITION. K g THERMAL POWE TEMPEF.ATUREFF)

1. POWER OPERATION t 0.99

>5%

2.STARTUP 1 0.99 55%

3. HOT STANDBY

' <0.99 Q

t 350e5

4. HOT SHUTDOM

< 0.99 h

35095 > T,yg> 2M

5. COLD SHUTDOM

< 0.99

$200 5

6. REFUELIN Q

i l

i ciuding decay heat.

". =."- t :- " - ~; : - ' ;;".'_. '30 :--- ' ' ::" ' r- ' ": '^^: .-. 'f/

...,..m a....<__m.-...._2. - -.

s

_2 b) vessel hosd closure bolts fully tensioned.'

(c) dF_f actor vessel head closure bolts less than fully Ig(('

( / m ioned.

l-25 -A o

N l

l l

4 a

WOLF CREEK - UNIT 1 1-9 Mark-up ofCTS 1.0 5/15/97

' CHANGE NUMER H2C DESCRIPTION would be tested each month during any given quarter.

1 24 =

A The current TS definition of Site Boundary and Unrestricted Area are deleted to be consistent with NUREG-1431. These definitions are deleted on the basis that they are defined in 10 CFR 20.1003.

1 25-y/2 A Table 1.2 of the current TS would become Table 1.11 in the improved TS.. The following changes would be made to g t.t-9]

conform to NUREG 1431. In new table 1.11, the notation "NA" would replace "0" under

  • Rated Thermal Power for Modes 3, 4, 5, and 6. This is a nontechnical change since with K,, less than 0.99, thermal power would be zero

~

anyway. For Mode 6, the temperature has been replaced with NA since there is no safety analysis basis for the value of 140T specified in the current TS. Also for Mode 6, the reactivity condition has been designated NA since the value of 0.% is specified in the Bases for improved TS 3.9.1..The temperatures for Modes 1 and 2 are designated as NA on the basis that temperature for these modes is dictated by the minimum temperature for criticality and the operating program for reactor coolant system Tava. A new note b has been added to Modes 4 and 5 stating that thEMeactor vessel head closure g_q }.

bolts are fully tensioned, and a new note c ' replaces the note _ap>11ed to Mode 6. The new note c states that @

=j Ers@@ep reactor vessel head closure bolts are less than' j

m i

fu1Ty tensioned., The new note c no longer specifies that C.3 fuel is in the vessel because the condition of fuel in the

. vessel is addressed by the definition of the term Mode.

This definition stipulates that fuel be in the vessel in order to be in a " MODE." These changes are e

s 2

g,, q 1 26 A

New sections 1.2, 1.3, and 1.4 would be incorporated into the improved TS to be consistent with NUREG 1431. Section 1.2 provides specific examples of.the use of the logical connectors 8M1 and QE and the numbering sequence associated with their use in the improved TS. Section 1.3 deals with the proper use and interpretation of completion times, and specific examples are given that will aid the user in understanding completion times. Section 1.4 deals with the proper use and interpretation of surveillance frequencies. Specific examples are given that will aid the user in understanding completion times. Specific examples are given that will aid the user in understanding surveillance frequencies as they will appear in the 1

WCGS-Description of Changes to CTS 1.0 5

5/15/97

l CHANGE NLNBER EiHC DESCRIPTION improved TS. The proposed changes are administrative in nature and by themselves are no_t t_echnical changes, h I 4-O incorporating travelers @E44,,miti)NJA3

@sre se t M T15TF 2707 1 27 Not applicable to WCGS. See conversion comparison Table (enclosure 38).

1-28 LG The current TS definition cf CONTROLLED LEAKAGE is deleted to be consistent with idREG 1431. Rev.1. The RCP seal water return _ low limit is moved to a licensee controlled f

document.

{dsan.T 34 -

o.3. s.s - z y 1 29 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).gsrg 2op Consistent with Wed the definitions of Channel SI l"I) 1-30 A

Operational Test (C0T).,[ ] and Trip Actuating Device rywsw Rey"Te*+.

Operational Test (TADOT)'is expanded to include the T

5tw*.R*1'5 * **.

details of acceptable performance methodology.

Performance of these te in a series of sequential, overlapping, or total steps provi he necessary

(*

assurance of appropriate operation of the channelq This change also makes the COT.*[ ] and TADOT definitions l

consistent with the current TS and the NUREG 1431 definition of channel calibration which already contains similar wording.

(, relag, ov devic 4.,resputg 1 31 Not le t

__S_ eeMnver/ ion GdinoarMon Tgb/le) c1 re 3B. L W 5EE.T.3A-Gbj

[ epi.-,{

1 32 A

The definition of channel calibratio

, and TADOT is jeg i. t. 2.}

b reworded to be consistent with TSTFMto clarify the phrase l

" entire channel" thus reducing the potential for inconsistent interpretatinn nf the ohrase as exnerienced by a number of

-f,

,U"

  • 9 g g,g_3 \\

P 1 33 Thi a

evi st de initio of Co e Alt ati s to ete " r man lati " and conser ative" consi ten with NURE 431.

wo s as ed in de nitio wer redu ant I

ar# delet the rds d s not er t mea ng f the definiti n.

t4.4-syyll c=MA h WC(r5. Se.e. Carvws0m Cogane l

%Ra. (E:ndemuu 3B').

M v--

h. 34

\\.S. 2.

4:d a plic3MA.b (4C4r5. Se.e. <~*nve855m C*

(*

www.m.,.

-3 5 4 re y h I-41 IMSEAT 3 seafaa.y.s n WCGS-Description of Changes to CTS 1.0 6

S/15/97

CONVERSION COMPARISON TABLE

CURRENT TS 1.0 rose s er4 r

TECH SPEC CHANGE APPLICABILITY NUlBER DESCRIPTION DIABLO C#fVON CONANCHE PEAK WOLF CREEK CALLAWAY l

l 5

i 1-19 The current TS definition of Reportable Event is not used in Yes-Yes Yes Yes 1

A the improved TS and is deleted.

1-20' The current TS definition of Shutdown Margin is revised.

Yes

'Yes' Yes Yes M

The requirement to account for any RCCAs not capable of J

being fully inserted was sisply moved from current TS Action I

and surveillance requirements. The only substantive technical change to this definition is the addition of the requirement that, in Modes 1 and 2. the fuel and moderator f

temperatures be ch M to the hot zero power temperatures.

1-21 Not used.

N/A N/A N/A N/A l

1 22 The definition of Source Check is deleted.

Yes Yes Yes Yes

[

A i

1-23 The current TS definition for Staggered Test Basis would be Yes Yes Yes Yes A

revised. The test intervals for surveillance requirements

[

throughout the improved TS that are to be perfonned on a staggered test basis will be revised to be consistent with the new definition.

1-24 The current TS definitions of Site Boundary and Unrestricted Yes Yes Yes Yes A

Area would be deleted.

1 25 Table 1.2 of the current TS would become Table 1.1-1 in the Yes Yes Yes Yes I

improved TS. Several changes would be made to conform to A

NUREG-1431 (e.g.. ITS Table 1.1-1. the notation *NA" would I

replace *0" under_ t_ Rated Thermal Power for Modes 3. 4. 5.

~

re tr le T

d s

f her

-2.

_~

t 1-26 New sections 1.2.1.3. and 1.4 would be incorporated into Yes~

Yes Yes Yes l

i A

the improved TS.

1-27 The definition of Restricted AFD Operation (RAF00)is No '

No No-Yes, definition only in Callaway M

deleted, CTS i

i f

5/158 7 Conversion Congparision Tame - Current TS I.0 i

CONVERSION COMPARISON'I'ABLE

_ CURRENT TS 1.0 rage 4 or 4 LECH SPEC CHANGE APPLICABILITY NUPEER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 1-28 The definition of CONTR0llED LEAKAGE is deleted. The RCP No - Se'e change No - See Change Yes, Moved to (JSAR Yes. Hoved to FSAR LG seal water return flow limit is moved to a licensee number 1 05-A.

Number 1-05-A.

Section 16.

Section 16.4.

controlled document.

1-29 Allows measuring of QPTR when one or more excore detectors No Yes. Portion of No No definition being LS-3 channels are inoperable with moveable incore detectors.

changed only in CPSES CTS i

Yes Yes Yes The definition of Channel Operational Test (C0T).i ] and h g_ _h,

lgg,g g j 1-30

%), Re A

TADOT is expanded to include the details of acceptable performance methodology, Performance of this test in a 3gg geg5

,4' 4

series of sequential, overlapping. or total channel steps

+

provides the necessary assurance of appropriate operation of the @channe'fe13,ordevis.a. respWve.g

- Jied N[M -

1-31 Definitions of specific plant systems which are defined by Yes Yes A

the plant design are deleted.

jes Yes 1-32 The definitions of CHANNEL CALIBRATION. COT, [ ] and TADOT Yes_

Yes Yes Yes

{p g. t - 2. )

A are reworded to be consistent with the TSTF- @ The revised __ uceC

-i Qtc Task $5A' I I

b wording clarifies what is meant by " entire channel."@hidef i.sihdi et Achobe QC **

1-33 This change revised the CTS definition of CORE ALTERATION to Yes Yes J -Ve+ 00. AmeMmh Yes.

A delete delete "or manipulation" and " conservative".

[ LO9 Accepo(Ned.

[--

! O I I-b edd h j

~

'[ _tussser as-4 o u oi [

4 Sechb 34 P AT 5/15/97 renvmian Ormnarision Ta!>le - Otrrent TS 1.n

INSERT 3B-4a 0 1.1-9 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 1-34 In a Callaway-specific change, new notes b No No No Yes LS-2 and c to current TS Table 1.2 are worded

" Required reactor vessel head closure bolts fully tensioned" and " Required reactor vessel head closure bolts less than fully tensioned", respectively.

I NO SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC)

CONTENTS I.

Orga ni zati on........................................ 2 j

1 II.

Description of NSHC Evaluations...................... 3 III.

Generic No Significant Hazards Considerations i

l "A"

Administrative Changes......................... 5 "R"

Relocated Technical Speci fications............. 7 "LG" Less Restrictive (Moving Information Out of the Technical Speci fi cations)................. 10 "M"

More Restrictive Requirements................. 12 IV.

Specific No Significant Hazards Considerations "LS" M IIucale.

h Q I I~I LS 1..................................._.._

.Am.. m...--t5-ts.2.............................OM.wg.ew.... ira m. i - 3 i 1

LS 3.....................................Not'Applicable l

l wcas-ssucs-crs1.o i

sns/97

~l Q l \\-

IV.

SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 2 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE EQUIREMENTS WITHIN THE TECHNICAL SPECIFICATION Current TS Table 1.

(improved TS Table 1.11) is revised such that he required reactor vessel head closure it requirements for H0 DES 4. 5 and 6 are clarified. Currently a footnote applicable o y to MODE 6 defines that Mode. in part by reference to " vessel head closure bolts less than fully tensioned." That foot te does not specify the transition point between ES 5 and 6 with regard to the r of vessel head closure bolts that must be fully t sioned, leaving the issue open to interpretation.

The proposed change provides the ecessary clarification y adding a footnote to MODES 4 and 5. consistent with the opp ach used in NUREG-31 Rev. 1. to define those Modes as having the required number o reactor vessel ad closure bolts fully tensioned.

The transition point between H00E 5 and 6 woul also be clarified as occurring when the required reactor vessel head osure bolt are less than fully tensioned.

The required number of closure bolts, hich ma be less than the total number, is established by analysis that demonstrat ad ate 0 ring compression to prevent leakage and ensures that ASME Section III st s limits for affected components are not exceeded. This change is consistent wit raveler TSTF 88.

A.

This proposed TS' change has been eval ted and t has been determined that it involves no significant hazards considerati n.

This etermination has been performed in accordance with the criteria set f th in 10 CFR 0.92(c) as quoted below:

"The Comission may make final determinati

. pursuant to the procedures in 50.91 that a proposed a nctnent to an operating license for a facility licensed under 50.21 (b) or 50 2 or for a testing fact ity involves no significant hazards consideratio if operation of the faci 'ty in accordance with the proposed amendment uld not:

1.

Involve a ignificant increase in the probabilit or consequences of an acciden previously evaluated; or 2.

Cre e the possibility of a new or different kind o accident from any a ident previously evaluated; or 3.

Involve a significant reduction in a margin of safety."

The foll ing evaluation is provided for the three categories of the signi? ant hazards consi ration standards:

1.

Does the change involve a significant increase in the probability or cons uences of an accident previously evaluated?

WCGS-NSHCs-CTS 1.0 17 S/lS/97

-@t.t-qj IV.

SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 2 (continued)

Overall p tection system performance will remain within the bounds of t accident i

analyses. si e no hardware changes are proposed. The proposed change wi not affect the probabilit of any event initiators nor will the proposed change aff t the ability of any safety lated equipment to perform its intended function.

re will be no degradation in t performance of nor t.n increase in the number of a11enges imposed on safety related ipment assumed to function during an cident situation.

Therefore, the pro ed change does not involve a signific t increase in the probability or conseq ces of an accident previously evaluat 2.

Does the change cre e the possibility of a new or ifferent kind of cccident from any accident pre ously evaluated?

There are no hardware changes r are there any ch s in the method by which any safety related plant system perfo its safety fu ion. The method of plant operation is unaffected. Leakage would be p luded by t analysis: however, if leakage were to result from having less than the tal n of closure bolts fully tensioned it j

would be-detected by an increase in t

rature on the leak off line from the annular, space between the inner and o er vessel head 0 rings. - That temperature increase would be detected by installed emperature indicators and alarmed in the control room. Any leakage would be detec s an increase in RCS identified LEAKAGE.

No new accident scenarios, transient p rsor failure mechanisms, or limiting single failures are introduced as a result of is cha

. Therefore, the proposed change does not create the possibility of a new different ind of accident from any previously evaluated.

3..

Does this change involv a significant reductio in a margin of safety?

The proposed change does t affect the acceptance crite, 'a for any analyzed event.

There will be no effect o the manner in which safety limits r limiting safety system settings are determined r will there be any effect on those lant systems.necessai'y to assure the accompli nt of protection functions. There w 1 be no impact on any margin of safety.

N') SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the bove evaluation, it is concluded that the activities assoc ted with NSHC "LS 2" re iting from the conversion to the improved TS format sa sfy the ho signific t hazards consideration standards of 10 CFR 50.92(c): and accor 'ngly, a no signifi ant hazards consideration finding is justified.

WCGS-NSHCs-CTS 1.0 18 5/13/97

INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 TRAVELER #

STATUS DIFFERENCE #

COMMENTS TSTF-19, Rev.1

@ incorporated p

f)fMNIEC al proved seM i

1.1-42, dravMioff.def'.

%.m j e

TSTF W Incorporated 1.1-9 h

@ ' L-' l (TyPfr# f Mpow f

71.g F o i.i - 2 \\

QSIF48 /

AScorporated] /R

\\ @ t. t

  • \\ \\

TSTF-111, Rev.1 Ir.corporated 1.1-5

@#ChgeyJ/

Incorporated 1.1-6 (Qp6ppy} @ %

G 4 W,1 )

Incorporated 1.1-3

[G t.4-1 l M

Incorporated 1.1-11 la t.4-I \\

rSTf:-52.

locogoreted t 1 - I'b incor pr#cA. d<d+ 9e.L d -

-s

-u t

t 5/15/97 l

I

Definitions 1.1 Table 1.1 1 (page 1 of 1)

MODES

  • RATED AVERAGE REACTIVITY REACTOR COOLANT H0DE TITLE CONDITION POWER a TEMPERATURE (k,y)

(*F)

.1 Power Operation

= 0.99

>5 NA 2

Startup

= 0.99 s5 NA 3

Hot Standby

< 0.99 NA az350 gggggg 4

Hot Shutdown (b)

< 0.99 NA 350 >T,>

200 j;gggggy 5

Cold Shutdown (b)

< 0.99 NA s 200 ggggggg 6

Refueling (c)

NA NA NA (a)

Excluding decay heat.

b)* [PfeTaqldrA3) reactor vessel head closure bolts fully tensioned.

g anAmt.t L

(c)

Or.;; er ;;a $pqdpdi[) reactor vessel head closure bolts less than fully (Q g.t.q 1 tensioned.

l l

i l

{'

WCGS-Mark-up ofNUREG-1431 -IIS 1,0 1.1 7 S/1SB 7 L

in adA&, &s PTI.A definWen 4claAss, he. PbR y CHANGE un s%s endetent with %e. traveleds ch, NUMBER JUSTIFICATION @

  • " 8-

p,i.g j l

The [LTOP) arming temperature was added to the.PTLR. since changes in the heatup/cooldown figures could change the arming temperature. - This l

l change corrects the PTLR definition to be consistent with all of the l

requirements contained in the PTLR. Referenced methodologies for the PTLR would contain the methodology used to develop the heatup and cooldown figures, as well as the methodology for developing the_[LTOP) )

setpoints. This change is consistent with traveler (gWl5)('Je@v I Ctsrsr-as.z> tar i.e d 1.1 7 Not applicable to WCGS. See Conversion Comparison Table anciosure go 1.i-9 l

1.1 8 fTher ctor ssel ad os e bol r5df ts r MODE 4.I h

a lari ed.

pr pos chan revis s foot ebf MODES and i

1 I

f to r r to " equ ed r ctor ssel ad clo re bol fully ten ned" no ef MODE is re sed to ead "

1 red eacto

{

sel clo re ts les than 11y t ioned." The ansit n-

) point ' c --

ES and 6 1d a so be c rifi as occ ring J

t uir rea r vess head osure its ar less n fu y l

L sio requir number closu bolt, which y

ess l

tha he tot ntaber is est ished anal s tha demon rat l

te ing c ession prev leak and sure hat LSpction I stres inits f aff ed s

exc

~

(This nge is nsisten ith 88.

164 Applie=LA.a.43 tM.dr5. Sam.

LcArca.r ys G.w ps,% %

  • b4A (IEM a.LaS6.6M. 6 sed.

l 1.1 9 Consistent with TSTJAEr3eVD. the definition of Channel Operational zos.J Test (CDT).,[ ] and Trip Actuating Device Operational Test (TADOT) is ig g,g )

Q {

.yg' expanded to include the details of acceptable performance methodology.1 i

Performance of this test in a series of sequential, overlapping, or i

N" Y "*h total @ steps rovides the necessary assurance of appropriate operation of the e channelhThis change also makes the COT 4 definition consistent with the defLnition of channel ca_ ibration which l

already contains similar wording. [ gel 33,ordence. rytig 1.1 10 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 68).

1.1 11 Adds new example to ITS Section 1.4 to clarify surveillance frequencies i

that are contingent on both a specified frequency and plant conditions.

The ITS contains many Surveillance Frequencies that are contingent on both a "specified Frequency" and plant conditions. For example.

"Within 7 days prior to the initiation of Physics Tests." and " Prior to entering H0DE 4 from H0DE 5 if not performed within the previous 92 i~

days." These Frequencies do not fall clearly under any of the existing Section 1.4 examples. The proposed example is needed to make clear

' WCGS-Differencesfrom NUREG-1431 -ITS 1.0 2

5/15/97

b Page 2 of 2 CONVERSION COMPARISON T4BLE FOR DIIFERENCES FROM NUREG-1431 i

t SECTION 1.0 APPLICABILITY DIFFERENCES FRON MlREG-1431 REV.1

~

NUPBER DESCRIPTION DIABLO, CANYON CONANCE PEAK ICLF CREEK CAllJMAY Cellmag-sp.f$U@

~

1.1-7 The definition of Channel Functional Test in the Yes No - Not part No - Not part No - Not part I

t of current TS.

of current TS.

of current i

current TS will be retained in the improved TS. This TS.

definition is not in NlNtEG-1431 Rev 1.

i 1.1-8 baNote b is revised to refer to the " Required reactor de 4es do

~ h do Yes

} 4 6.t-kj vessel head closure bolts fully tensioned" and note c

~

}

is revised to read " Required reactor vessel head

)

closure bolts less than fully tensioned."

f 1-1-9 The definition of Channel Operational Test (C0T). [ ]

Y Yes Yes Yes-and TA00T are expanded to include the details of (f tvtes4mr Rs.h T

gg_,

acceptable perfomance methodology. Performance o St Raty Test, j

this test a series of sequential, overlapping, or total steps provides the necessary assurance of arrivyriate operation of the@channe[vagar dewica.,resh v s3Q 1.1-10 This change is based on the current TS definition of No - Not part No - Not part No -

Yes l

CONTROLLED LEAKAGE. This change is a clarification of current TS.

of current TS.

Naintaining ISTS wording.

l only and does not affect the way RCS water inventory.

v balances are perfomed.

1.1-11 Adds new example to ITS Section 1.4 to clarify Yes Yes Yes.

Yes surveillance frequencies that are contingent on both a specified frequency and plant conditions.

i (i. 3 - t[ tU s s a.T (,a _ @ r a g,o. c o s,g -

i l

ti IktsERT6,8 4 3. 6..t - (,j i

t l

SHSM7 WCGS-Conversion C..;_ k TnNe-ITS1.0 l

1

{

I

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1.4-1 APPLICABILITY: DC, CP, WC, CA REQUEST:

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 propnsed to be included in ITS. The DOC and the JFDs state that these ITS changes are to incorporate travelers WOG-74 and WOG-90.

l Comment: Provide the current status of WOG-74 and WOG-90. If WOG-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. If WOG-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 will not be reviewed on a plant-specific basis.

FLOG RESPONSE: WOG-74 and WOG-90 have been approved by the TSTF and are designated as TSTF-270 and TSTF-267, respectively. Both of these travelers have been submitted to the NRC and are under review. The proposed wording in TSTF-270 was modified from WOG-74, Rev. 2, and these modifications have been incorporated into the ITS. The FLOG continues to pursue the changes proposed by these travelers.

ATTACHED PAGES:

Encl. 3A 6

Encl.5A Traveler Status page, 1.4-5,1.4-6 Encl.6A 1, 3 i

4

E CHANGE NLM ER Eit(

DESCRIPTION 4

i:aproved TS. The proposed changes are administrative in nature and by themselves are not tech _nical changes,

~ i ncorporati ng travel ers @rn<74A,WOfr93 h I 4-Il fCTsTh zah M TSTF'256)

[

1 27-Not applicable to WCGS. See conversion comparison Table (enclosure 38).

i

}

1 28 LG.

The current TS definition of CONTROLLED LEAKAGE is deleted to be consistent with NUREG 1431. Rev. 1.

The RCP seal F

water return _ flow limit is moved to a licensee controlled document.

[ptsaa.T 34 -@ o a.s.s - zJ j

1 29 Not. applicable to WCGS. See Conversion Comparison Table (Enclosure 38). M M ~ Y Consistent with %5W'19 RGM] the definitions of ChannelkGi l"I 1 30 A

Operational Test (C0T),,[ ] and Trip Actuating Device rvwokeR*1gTet.

Operational Test (TADOT) is expanded to include the -

Steve Ra}f***.

details of acceptable performance methodology.

Performance of these te in a series of sequential, overlapping, or total steps provi he necessary L'

assurance of appropriate operation of the channelQ This change also makes the COT.'[ ] and TADOT definitions '

I

~

consistent with the current TS and the NUREG 1431

' definition of channel calibration which already contains similar wording.

Q rang or davaa.,resputg

.1-31' Not le t

,_See/onvepdon f/noac(son TgMe)

~

_ re 3B.p 5Ee SA -lab H en i,i, j 1

T 1 32 A

The definition of channel calibratio

. and TAD 0T is A i. i 2.]

reworded to be consistent with TSTFQto clarify the phrase

" entire channel" thus reducing the potential for inconsistent 9&pretatinn af the nhrase as exoerienced by a nu inter fff f, I "fY'* %

a g.t 1 \\.

1 33

'Thf an evi st TS de initio of Co e Alt ati s to ete " r man lati " and conser ative" consi ten with 431.

wo s as ed in de nitio wer redu ant I

NURE

^ er t mea ng f the a

delet the rds d s not definiti n.

@ appli c=Rs.4o (MGS. See. Cowiew Cqme 72bla. (Encl muu.3B').

M Cl _

M spplicaW.4 in W.&S. se.e. (enveom I-awTwe 1.5-2.

- _ f, mra ble (EMosure..5e), "_

4Q t.t-4 \\

i m-IMSEAT 3

,suba% 3,g, g,s 3,,

QCs l~ 35baQ I.

WCGS-Description of Changes to CTS 1.0 6

5/lS/97

INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 TRAVELER #

STATUS DIFFERENCE #

COMMENTS TSTF-19, Rev.1

@ incorporated ggfo. g j TSTF W Incorporated 1.1-9 h 14 l 1-8 l (TWR /

W rpo p 7

M i a i.i - 2. \\

QSJH8/CKcorperftedd J%

. I @ l 1-A I TSTF-111, Rev.1 Incorporated 1.1-5

'QVACg7gey/D Incorporated 1.1-6 (Ests,apvd]lOI"~"I

~

y h

% 6.1J Incorporated 1.1-3 14I4-1l

/

M Incorporated 1.1-11 la I A~ ' I m..sc= w

.w i.i..e aa s o.i w

,_ y pm 4 3.4..i -c.

~-

q 3, g,i. 4, n

i

}

5/15/97 i

_. _ _ _. _ _.. _. _.._. _ _ _... _.. _._ - _. _._ _ _ _ _ _ _ ~ _ _ _ _ _

4 i

1 Frequency 1.4 a

h.

1.4 Freatancv

)

4 i

EXAMPLES EXAMPLE T 4 4 Rii1}3$1 j

.(Continued);

1

~ SLRVEILLANCEiREQUIREENTS 1

l SERVEILLANCE FREQUENCY

- - ;- -Lif+?2i&NME- - - - - - - -- - - - - -?

Only required'.to be performed in MODE 1

.....q::...:.=..........:..............

Perform complete. cycle of:the valve.

7' days The interval continues, whether or not the-unit operation is.in MODE'1, 2Ior'3' (the-assumed Applicability ofithe associated LCO) between performances.

As the Note modifies the required performance of.the Surveillance,ithezNote is. construed to beg lprtiofTthe 7specified FrequencyjC5hould the37 day; interval bemesseded.while operationXR1RitBE:IL.this Note T1]RsJntry.;1 Wand

. operation;1MEDES;2:and;3;to perfom iSitweillanceE3he Surveillance?fststill? considered to be pert 5rmed Within the "specifiedTrequency.*.~1f? completed prior;.tqtenteringiMODE~1.,

Therefore, if'tha. Surveillance were not perfomed within.the:7 day (plus the. extension allowed by SR'3.0;2); interval...but e

operation was.not:in: MODE 1,'it would noticonstitute.a; failure of the SR:or; failure to meet the LCO. Alsokp. violation.of SR s

3.0.4: occurs when changingsHODES, even with the T^ day Frequency not met, provided operation does not result in: entry.into NODE 1.

Once the unit-reaches MODE 1, the requirement-for the-Surveillance; to-be. performed within its.specified Frequency applies and;would. require that the Surveillance have been -

perforised.LIOthe Surveillance were not performed prior to-MODE l'. there:would then beAfa11ure to perform;a. Surveillance within the specified Frequet.cy, and the provisions of3t 3.0.3 would apply WaWyv1pntjdh grs1549<Q.

[ q i,4 (continued)

WCGS-Mark-up ofNUREG-lol-ITS 1.0 1.4 5 S/15/97

... - ~. -. -.. - - -..... _. -. -

Frequency 1.4 1.4 Frennancy EXAMPLES EXAMPLE 1.4-5 ggg;11e (Continued)m.

~

i SLRVEILLANCE REQUIREENTS SLRVEILLANCE FREQUENCY Verify each containment' isolation. manual Prior-tot i

l valve is closed:

entering; MODE 4' from MODE % )f not' performed Withindhe j

prevfous1927dayQ q1.+ 1 f

In Example 1.4 57 the "specified Frequency"~1swasured'from.when l

the Surveillance was_last performed; Should the:.intervalf be exceeded, the. Shrve111ance is not; required to be: performed'until certain conditions are met. TherShrve111ance'is: allowed'to be delayed until prior;to entering. MODE 4:from MODE? 5:1f;.the.92' day "specified Frequency"fhas expi, red.~ The 92' day. interval mmnbe extended to IMMmes the3stateCinterval'asJiigwedhMJilH2 fer. operationaTlfDKibility. ~llgitfor4;1ff th0Dhre11Tance':~gstd not performedWthirtthe192 dat(plus the;exteetton;a 370.2) interva1Ebut operationitiesTnotttransitToning..freen _ m to. MODE 4, It-nsould nottconstitute a failure:of2the SREora failure to meet:the LCO. The.next' time the unit" proceeds from MODE 5 to MODEMi.the surveillance would be requ. ired to,be performed prior to the: transition:

s The measurement of;this. interval ~ continues at;all times,0 even when the SR is;not required to be met per SR'3.0.1 (such as when the equipment;isiinoperable, a; variable.is;outside specified i

limits, or the _ unit'is outside2thejApplicabili.ty.of:the LCD).,If l

the conditions;in the Frequency;are met and thecinterval l

specified by SR;3.0.2 is. exceeded without the Surve111ancediaving l

been performed and the performance of-the Surveillance is~not j

otherwise modified (refer-to ERample 1.4-3), then SRt3.0.3 becomes applicabl.e.

I i

i 1

WCGS-Mark-up ofNUREG-161 -ITS 1.0 1.4 6 5/15/97

~

i DIFFERENCES FROM NUREG-1431 i

Section 1.0 This enclosure contains a brief discussion / justification for each marked up technical change to NUREG 1431.' Revision 1. -to make them plant specific to incorporate generic i

changes resulting from the Industry /NRC generic change process. The change n"mbers are referenced-directly from the NUREG-1431 mark ups. For Enclosures 3A. 3B, 4. 6A and 6B. text in brackets "[]". indicates the information is plant specific and is not common to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets inidcate that other JLS plants may have plant specific information in that location, j

CHANGE NUMBER JUSTIFICATION i

g,g 1.1 1.

kN 1431

.1 initio of Chann 1 Cal ration stat. "T C

L CALI TIO all en pass th entire channel, in udin he i

quired nsor larm.

erlock.

' splay. and trip fu ions This I

chan clari s what ncompass the entire channel rewo ng the \\

initio o sta "The C EL CALIBRATION shall ncomp s those compo ts. su as senso. alarms, displays. a trip nction r

ired t rform t specified safety func on(s)." The Ch nel /

Operati 1 Test.

Trip Actujting Devic perati al Test efindions h

milarly r ised. This change is sistent ith T

64. MssRT a.Sj 1.1 2 Not used.

1 1.1-3 Adds new example to ITS 1.4 to clarify meaning of SR Notes of the type "Only required to be performed in MODE...".

This change is consistent with traveler @0J f4 ATQ rsrF-570}l_ce i.4 -Q 1.1 4 Not used.

1.1 5 The definitions for ESF Response Time and RTS Response Time would be revised to substitute the word " verified" in lieu of " measured" consistent with the requirements of NUREG 1431 SR 3.3.1.16 and SR 3.3.2.10. This change would ensure consistency between the definitions for Response Time and the requirements to periodically verify Response Time is within limits. This change is consistent with traveler TSTF-111. Rev. 1.

1.1' 6 The definition of the Pressure and Temperature Limits Report (PTLR) l would be revised to include the maximum allowable PORV lift settings l

l and~ arming temperature associated with the [ Low Temperature L

Overpressure Protection (LTOP)] System, and to be consistent with the

'COLR definition. Improved Technical Specification 3.4.12 states that the PORV lift settings are specified in the PTLR. The current i

definition for PTLR does not identify these lift settings as being contained in the PTLR.

VCGS-Differences from NUREG-ID1 - ITS 1.li 1

5/15/97 l

f i

CHANGE NUMBER JUSTIFICATION that 1) the SR 3.0.2 extenstion of 1.25 times the specified frequency applies to the specified Frequency, and 2) that the interval allowed to perform a missed Surveillance by SR 3.0.3 applies.

SR 3.0.2 is clear that the 1.25 extension may be applied to "the interval specified in the Frequency," so the proposed change does not change the intent of the Specifications. SR 3.0.2 applies if a Surveillance is not performed within the "specified Frequency." Again, the example does not change the intent of the Specifications but only makes clear the application of SR 3.0.2 and 3.0.3 to Surve111ances with Frequencies tied to plant conditions. This change will eliminate confusion and misapplication of the ITS and will ensure consistent application of SR 3.0.2 and 3.0.3 to these types of Surveillance Frequencies. This change is consistent with traveler C7 7f7p @p t.4,y

_ - = cg m i.o _cou i.i-iz ms.ar u 13 iWEtT GA Q 3. 6.1 -l=[

s t

i WCGS-Differencesfrom NUREG-1431 - ITS 1.0 3

SIESAI

l l

ADDITIONAL INFORMATION COVER SHEET l

ADDITIONAL INFORMATION NO: TR 1.0-006 APPLICABILITY: DC, CP, WC, CA l

I REQUEST:

Incorporate NRC-approved traveler TSTF-19 Revision 1 to move the details of the RTD and thermocouple calibration process from the CHANNEL l

CAllBRATION definition to the appropriate Section 3.3 Bases. Section 3.3 Bases mark-ups are tracked under No. TR 3.3-004.

I ATTACHED PAGES:

l l, CTS 1.0 - ITS 1.0 l

Encl. 2 1-1 i

Encl. 3A 1

Encl. 5A Traveler Status page,1.1-1 l

Encl. 6A 3

l Encl. 68 2, CTS 3/4.3 -ITS 3.3 (See changes labeled TR 3.3-004)

Encl. 5A Traveler Status page Enci5B B 3.3-61, B 3.3-152, B 3.3-159 1

i

~

. - - - ~ _.. - ~ ~ _. -

(1.0 USE AND APPLICATION]

1.0@EFINITION i

The defined terms of this section appear in capitalized type and are applicable

""Tl01-A~",

throughout these Technical Specifications [and Bases.)

' " ~#~"

ACTION 1

M ACTION shall be that partof a T 0--

" C-- 1.ca ' n which that presenbes

{" p

  • t;A C i
    • d

--- ':' -- m: ::-?:f: r;'-M Actions to be ta nder designated conditionsfwithin the specified Completion Times.)

ACTUATION LOGIC TEST of m. logic. Circd

'~ h g,i. z.)

U"41:AV7T PM M An ACTUATION LOGIC TEST shall be the application of various simulated

% combinations in conjunction with each possible interlock logic state nd vertilcation of the required logic output The ACTUATION LOGIC TEST shall.@

)

@ include a continuity check, ase.mmmum, of output devices etalldevice6 iMbc. channel (d91tNA ANALOG CHANNEL OPERATIONAL TEST (COI)

-for channel CPERASit_ tty,

~__

SL CPEP_^7?Cf!^1 TES'[A CODshall be the injection of a__

%%AQ

~

M.^

^"^1M C"Ionw into the channel as close to the sensor as practicable to -

"O" #

simulatedtiractual venty OPERASILITYRoelGdipstilz:t--_- O btfie;strearthirtuen set.langsf,1 e641ame. i ^t' '1

. ame trinO. ;;._ '--2 'd tMierfenh the"tpeelM "D 32EA Y 3 "d

reerles of : r_ - ^"-. c..."

or total channel steps so that the entire chann]el) faelfqgj(t' "'1'__1_; *-j ^.- "- ;.Jhe COT may be performed by means of any l

adjustments, as necessary, of C "rm, interlock and/or Trip Setpoints)

@{ct i. t -2.

Je testedJ The ^".^iT C".".'"CL CP5"^7!C"^1 T55=Eshall include i,I-I j

l W mauho S@oints m Wh g and accam dd h channt e

AM$AL FLUX DIFFERENrTEI6D 0

NI LD -

6 AFD shall be the difference in normalized flux signals - N14A73

)

ONS between the top and bottom halves of e4wo4eelien an excore neutron detector. ___ _

(output sue e**** QNha4 $_ chm ["'

"mmg (Cp l.l="1.}

"" Y8 L'88 CHANNEL CALIBRATION f M AC NNEL CALIBRATION shall be as necessary, of a ' #143-M

" ' ' ^ ^ " ' ' "

charynel it responds within nge and accuracy t 3

" % _. -- The CHANNEL CALIBRATI il encompos;"". _. _. 2:1.::

tysome5'_ _'r_s"_"- 'f-- Se h_w--'t1 misdeels endioGMysl5MlbsfoqGips4; p WZ"' - Jd wtfon(pf ]

FCalibration of L ^ _ :_:.; channels with resistance temperature detector (RTD) or

%32F" thermocouple eenoore may consist of an inplace qualitative assessment of

' sensor behaylor and normal calibration of the remaining adjustable devices in the CA n

c li the

""f M I O

  • N
_,_,,,,;. - - - -+__ "-- t i The CHANNEL

.CAllBRATu T."J.

.9ay be performed by anym of_ sequential, overlapping, or total channet stepe@eN]hefthMmye chparSlisa:51W g Q yg Wg

,,;4 j chewa\\ reetM M l'

@m PERAtitt.tTyd CHANNEL CHECK

. M A CHANNEL CHECK shall be the qualitative assessmentby observation) '

9NIF*

l of channel behavior during operation by-ebsewehen This determination shall

~

include l

%r, where possible, comparison of the channel indication and/or status with indicehons and/or status derived from independent instrument channels measuring the same parameter.

l l

l WOLF CREEK UN;T 1 1-1

~ Mark-up of CTS 1.0 S/1S>97

1 DESCRIPTION OF CHANGES TO CURRENT TS Section 1.0 This enclosure contains a brief description / justification for each marked up change to current Technical Specifications. The changes are identified by change numbers contained in Enclosure 2 (Mark up of the current Technical. Specifications). In addition, the referenced No Significant Hazards Considerations (NSHCs) are contained in Enclosure 4.

Only technical changes' are discussed: administrative changes (i.e.,

format, presentation. and editorial changes) made to conform to the improved

. Technical Specifications are rs discussed. For Enclosures 3A 3B, 4, 6A and 68, text in brackets "[ ]" indicates the information is plant specific and is not conson to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that location.

CHANGE NUMBER

. EitlC DESCRIPTION 1 01 A

These definitions would be reworded to be consistent with i

NUREG 1431. The proposed rewording included in this category does not involve any changes of a technical nature.

1,02

. Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38),

g 7

l 1 03 M

The definition of channel hal1bration is reworded to be consistent with NUREG 143R The revised wording provides additional detail concerning calibration of instrument channels with RTD's or thermocouples.

1 04 y Lcr This d ition uld no 1 nger be and s

icati in ITS tion 3 and strative ontrol ection d be r sed ac dingly.

cur t TS ition Contai nt Integ y woul E

eted cons ent wi EG 143 This nition is ef ctively corpor into t EG 14 ases r

i t

new Co inment iting Co ion f rat (ITS (

l 3.6.1) the inistrat Contro ectio or the

/

L Co inmen akage Ra esting ogram the l

Contai t Tendon rveillanc Progr INssnt 3A-lj 1 05 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

'%\\

[

' 1 06 LS r" The cu t TS ini for C e Alter ons wo d be L

1ed c sten ith N 1431, t qualif cor E

tera as ement of uel,soufres,or her j

rea vity c trol e nents. Tnis pro ed ch geis(

I tidt 3ppucAle to WC&i See conversikn Campens6nTaa )

nc.temuw., 38i).

WCGS-Description of Changes to CTS 1.0 1

S/1587 l

1

INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 TRAVELER #

STATUS DIFFERENCE #

COMMENTS TSTF-19, Rev.1

@ incorporated ggg,g j b

TSTF W Incorporated 1.1-9 h

@ ' L-8 I CT W M _ f _ Loc 6rpor>Wd

/~

M

' G ' '

  • 2- \\

(T'SJJ411/~ i4corpeditedf f%

{b 1. t-A I TSTF-111, Rev.1 Incorporated 1.1-5

@3)Cg, Key /D Incorporated 1.1-6 (Napp,.vd]IOI

hD

%%Ap:.1)

Incorporated 1.1 3

[o i.4-i i M

Incorporated 1.1-11 la 1.4-1 I in=<r d am 6 i rw-s2 weda i.i - rs e

pm. 4 2.4.i-c,

_~

N-

~ _

Q 3.6.l - G}

A.

\\

4 S/15/97

=

i Definitions l

1.1 1.0 USE AND APPLICATION 1.1 Definitions

..................................... NOTE----------

The defined terms of this section appear in capitalized type and are applicable i

throughout these Technical Specifications and Bases.

Ittts Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various QgAgg simulated or actual inout combinations in conjunction with I.1 -1 4

each possible interlock logic state'and the verification of Gl'I'N d D' "g the required logic output. The ACTUATION LOGIC TEST. as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux N#' '

signals between the top.and bottog halves of e (AFD) tw ;;;tior, an excore neutron detector._

j ui Shch]

1 CHANNEL CALIBRATION A CHANNEL CALIBRATION sh tne adjustment, as rs essary, of the channel that it resx>nds within the p g.t.2.

E*,"9'. Y *?'*'*? *. $

W-G, a P,,,,,,,

r. ~ r. w..r e r.. ~u........ w.....: =..r,r...,..z n. =. r

. e.

H that N. channa.

n.r.;ti c,r.;. The CHANNEL CALIBRATION shall encompass I--

d I

p;f ion r

t o

f l

ft devic.es ih he channel fu_

on(./ Calibration of instrumeht channels with i

requded b channel resistance temperature detector (RTD) or thermocouple l

i OPERA stuTV' sensors may consist of an inplace qualitative assessment of A-sensor behavior and normal calibrati of the remaining h-adjustable devices in the channel.

n er a nsin (el t'

re ced, he n r

ired NE CALI TI i

1 nel an i lac ross alibr ion at c ar

/Tn;i.o.oot.)

t ot ensi el ts 'ht rece y in all dj E t sens el

.fTheCHANNELCALIBRATI0imaybeperformed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

(continued) l WCGS-Mark-up ofNUREG-1431 -ITS 1.0 1.1 1 S/15/97 l

CHANGE NLIMBER JUSTIFICATION j

that 1) the SR 3.0.2 extenstion of 1.25 times the specified frequency applies to the specified Frequency, and 2) that the interval allowed to perform a missed Surveillance by SR 3.0.3 applies.

SR 3.0.2 is clear that the 1.25 extension may be applied to "the interval specified in the Frequency," so the proposed change does not j

change the intent of the Specifications. SR 3.0.2 applies if a I

Surveillance is not performed within the "specified Frequency." Again.

the example does not change the intent of the Specifications but only makes clear the application of SR 3.0.2 and 3.0.3 to Surveillances with Frequencies tied to plant conditions. This change will eliminate

)

confusion and misapplication of the ITS and will ensure consistent application of SR 3.0.2 and 3.0.3 to these types of Surveillance Frequencies. This change is consistent with traveler to i.4,u gp. g,3

=c l.l-17 16J5ERT GA-34 TE 1.o -oo r, l'5 16J5Ea.T M Q 3.6.1 -le b

i

)

l l

l i

i l

WCGS-Differencesfrom NUREG-1431 - ITS 1.0 3

S/25/97

TNSERT 6A-3a TR 1.0-006 1.1-12 The definition of CHANNEL CALIBRATION is revised per TSTF-19 to move details of RTD and thermocouple calibration to the ITS 3.3 Bases associated with calibration of the components.

INSERT 6A-3b 0 3.6.1-6 1.1-13 Traveler TSTF-52, draft Revision 1, deletes the definition of La.

Since La is defined in 10 CFR 50, Appendix J and ITS Section 5.5-16, Containment Leakage Rate Testing Program, it is redundant to j

include La as a definition. As described in NUMARC 93-03, i

" Writer's Guide for the Restructured Technical Specifications "

Specification 1.1 is a list of defined terms and corresponding definitions used throughout the Technical Specifications.

La is not used throughout the Technical Specifications and is defined in Section 5.5-16.

I 1

CONVERSION COMPARISON T4BLE FOR DIFFERENCES FROM NUREG-1431 Page 2 of 2 SECTION 1.0 DIFFERENCES FROH NUREG-1431 REV. 1 APPLICABILITY NUMBER DESCRIPTION DIABLO, CANYON COMANCHE PEAK WOLF CREEK CALLAWAY kC=113w299puM12 6M 1.1 7 The definition of Channel Functional Test in the Yes No - Not part No - Not part No Not part current TS will be retained in the inproved TS. This of current TS.

of current TS.

of current TS.

definition is not in NtREG-1431 Rev 1.

e te b is revised to refer to the " Required reactor fes-de 4es SI~o fes Mo)

Yes 1 Q l.t-9j 1.1-8 vessel head closure bolts fully tensioned" and note c

^ -

is revised to read " Required reactor vessel head closure bolts less than fully tensioned."

1-1-9 The definition of Channel Operational Test (C0T). [ ]

Ye Yes Yes Yes and TADOT are expanded to include the details of (f tvisstar Re.h w, gg,g _ g acceptable performance methodology. Performance o st R.ig Test, this test a series of sequential, overlapping, or s

total steps provides the necessary assurance of appropriate operation of theMchannefrmh% 5evica_, reshNY elh 1.1 10 This change is based on the current TS definition of No - Not part No - Not part No -

Yes CONTROLLED LEAKAGE This change is a clarification of current TS.

of current TS.

Maintaining ISTS wording.

only and does not affect the way RCS water inventory balances are performed.

1.1-11 Adds new example to ITS Section 1.4 to clarify Yes Yes Yes Yes surveillance frequencies that are contingent on both a specified frequency and plant conditions.

( l.1 - 12.

l>JsEE-TroS-@ Ta 1.o cog iDJSEILT (.

Q 3. 6.t - (o]

5/l5/97 WCGS-Conversion Comparision Table -ITS 1.0

-__.----_-----.-____--__----___.---_-_.---,._-----__-._-._x

_,..___._.--_w

TR 1.0-006~

INSERT 6B-2a

' TECH SPEC CHANGE APPLICABILITY-NUMBER DESCRIPTION DIABLO CANYON-COMMA!!CHE PEAK WOLF CREEK CALLAWAY 1.1-12 The definition of-CHANNEL CALIBRATION is Yes Yes Yes Yes revised.per TSTF-19'to move details.of RTD and thermocouple calibration to the ITS 3.3 J

Bases associated with calibration of the components.

0-3.6 1-6 INSERT'6B-2b'

?

i TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY-1.1-13 Traveler TSTF-52, draft Revision 1,. deletes Yes Yes Yes Yes the definition of La.

Since La is defined in 10.CFR 50, Appendix J and ITS Section 5.5-16, Containment Leakage Rate Testing Program, it 'is redundant to include La as a definition.

si I

)

I L

INDUSTRY TRAVELERS APPLICABLE TO SECTION 3.3 TRAVELER #

STATUS DIFFERENCE #

COMMENTS NSL3:kc64\\

N/A fNft)NRC approved a M

TSTF-19, Rev. I hlncorporated Gr6 M rsist*gEC TSTF-36 Rev.hIncorporated 3.3-34 l'1R 33*El TSTF-37, Rev.1 Net Incorporated NA ITS 5.6.8 still addresses PAM reports. Sections after ITS 5.6.7 were not renumbered.

TSTF-51 Not Incorporated NA Requires plant-specific reanalysis to establish decay time dependence for fuel handling accident.

M QoFIncodraied'.AiA3

%f et ints a dP ptfowa e Val s for ss of

, vol e an - egra d voltage Lillre _ in in t e TS.-

TSTF-111 Rev.1 Incorporated NA TSTF-135 J.3-41(3. 3-4p Trave r'is ob ad op]

Incorporated 3.3-93 in tur,she dh eb n'

ggg 3.3-95 ver sep atet velp.

the tave t

ntly alrif pr t 3.3-122 Po ons 3.s-91

3. 3. ig

@ 3 -l+2-)

>nifi

=-

ope bilit req ' e nts h ve be n ing rpo ated. g34 TSTF-16th Incorporated 3.3-79 fir. s.3.e2.]

g-N M rp g d hj (kr'_r K gr.3.3 aaf TSTF-169 Incorporated 3.3-42 M

2.) Incorporated 3.3-49 p 3.3-tor j h ~ fse Incorporated 3.3-107 duet'453 r.

f.aveler 2f6

/* 3.3 -mfl 5/15/97

RTS Instrumentation L

B 3.3.1-I BASES SURVEILLANCE SR 3.3.1.9 REQUIRENENTS' (continued)

Sr 3.3.1.9 is the performance of a TADOT and is performed every 92 days, as justified in Reference 6 7.

L l

This SR is modified by a Note that excludes verification of l

setpoints from the TAD 0T. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.

i-t SR 3.3.1.10 l

A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the ur.it ;paific setpoint methodology. The differerce ktuur, tk currer; ";s f;;r,d'ielaas 7.r.d tk previ;us I;;; ";; l;72" ;';M; C;t M GT.;i;t;it ;;it,, ti dif ft ;l G;..;;

cad in tk atp; int..atbdelci;y.

l The Frequency of 18 months is based on the e n g tien ;f en L

46-senth assumed calibration interval in the determination of the I

magnitude of equipment drift in the setpoint methodology.

i i

SR 3.3.1.10 is modified by a Note stating that this test shall l

include verification that the time constants are adjusted to the i

prescribed values where applicable. Thi.s_does;not include I

verif,1 cation ofitime_ delay _ relays.ZThese;are verified;by response 31me;testi ng; petSR; 3:3:1;16; p3_91g h3-oog.

SILJ.3.1.11 1

I S5: 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as t

described in SR 3.3.1.10, every 18 months. This SR is modified by e two three' Notes stet 4tig Note l'Lstates that neutron detectors are excluded from the CHANNEL CALIBRATION. Note;2?,

i i'

(continued)

WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3 61 5115/97 l~

INSERT B 3.3-61 TR 3.3-004 Whenever an RTD is replaced in Functions 6 or 7, the next required CHANNEL CALIBRATION of the RTDs is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

l l

i

.. ~

L PAM Instrumentation B 3.3.3 k

BASES' 4

SURVEILLANCE SR 3.3.3.1_(continued)

REQUIREMENTS i

or of something even more serious. A CHANNEL CHECK will detect gross channel failure: thus, it is key to verifying the instrumentation continues-to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar unit instruments located throughout the unit.

Agreement criteria are determir.ed by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.

As specified in the SR, a CHANNEL CHECK is only required for-those channels that are normally energized.

The Frequency of 31 days is based on operating experience that J

demonstrates that channel failure is rare. The CHANNEL CHECK supplements.less formal, but more frequent, checks of channels during normal operational use of the displays associated with the i

LCO required channels.

4 SR 3.3.3.2

{

A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measure parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. Th; ;;libr; tion.ethod fer acutren itectors is specified in the hecs of LOO 3.3.1,

"";nter Trip @te;;; (RTO In:; tic;,t;tien." RjiS XRalag modified by~aTsecond Note.thatl discusses ~anlallowed:sethodology foticalibr_ating:the Containment Radiation'LeveUltighiRangel Function; The Frequency is based on operating experience and consistency with the typical industry refueling cycle.

[ tm. 3. Loo 4 \\

(continued)

WCGS-Mark-up ofNUREG-1431-Bases 3.3 B 3.3-152 5/15l97

INSERT B 3.3-152 TR 3.3-004 Whenever an RTD is replaced in Functions 3 or 4. the next required CHANNEL CAllBRATION of the RTS's is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

Whenever a core exit thermocouple is replaced in Function 15 the next required

- CHANNEL CALIBRATION of the core exit thermocouples is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

l

Remote Shutdown System B 3.3.4 L

i BASES SURVEILLANCE SR 3.3.4.2 (continued) j necessary. The Surveillance can be. satisfied by performance of a l

continuity check. This will ensure that if the control room l

becomes inaccessible, the unit can be placed and maintained in N00E 3 from the cemete Ajp111ary Sehutdown P_ panel and the local centr;l stations. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

(However, this Surveillance is not required to be perfomed only during a unit outage.) Operating experience demonstrates that remote shutdown control channels usually pass the Surveillance test when performed at the 18 month Frequency.

i l

t j;

~SR 3.3.4.3 i.

I CHANNEL CALIBRATION is a complete check of the instrtment loop I

and the sensor. The test verifies that the channel responds to a measured parasoter within the necessary range and accuracy.

1 i

l The Frequency of 18 months.is based upon operating experience and consistency with the typical industry refueling i

cycle.

Notes 3?andIttveltwerCadded :to ' exclude 3hOltutMEdetectors Ol_oteJ11theig!aggc3dp,breakerslandE;jgtenkers"Miote_21 fm!GINilE.QB,R91TE!E hand a 3Q

! TR 3.'5-004 }

L

:

S" 3.':.4.4 is the perf;r.en;; cf ; TA00T ;;;ry 10.enth;. This t;~;t iuld verify tra 0"C"XILI"! ef the r;;;ter trip br;;ker;

'"":;) ep;n sad ;1; sed irdication e 1;tr-^^7 2:~r r ca th; re ~t; ;hutdewa pral. by ;;tu;tia; tre ""s.

Tra I,;g.crey is b;;;;d spa ep;r; ting ;;g;ricre; and ;;a:;i;tency with the twi;;l indu:;try refuelia; cut;;;.

l' REFERENCES 1.

10 CFR 50. Appendix A. GDC 19.

i WCGS-Mark-qp ofNUREG-1431-Bases 3.3 8 3.3 159 5/15/97 9

i 1-

.e r

W p

++-t--

r-

A i

INSERT B 3.3-159 TR 3.3-004 Whenever an RTD is replaced in Function 3.a or 3.b, the next required CHANN.EL CALIBRATION of the RTDs is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing elements.

i i

Att:chmtnt 2 to ET 98-0071 Pags 1 of 4 JLS CONVERSION TO IMPROVED TECHNICAL SPECIF! CATIONS CTS 2.0 - SAFETY LIMITS ITS 2.0 - SAFETY LIMITS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION AND LICENSEE INITIATED ADDITIONAL CHANGES i

4 Yn

Atttchm:nt 2 to ET 98-0071 Ptgs 2 of 4 INDEX OF ADDITIONAL INFORMATION ADDITIONAL INFORMATION APPLICABILITY ENCLOSED NUMBER 2.0.G-1 CA, CP, DC, WC YES 2.0-1 CA NA 2.0-2 CA, CP, DC, WC YES 2.0-3 CA, CP, DC, WC YES 2.0-4 DC NA 2.0-5 DC NA 2.0-6 WC YES CP 2.0-001 CP NA DC 2.0-001 -

DC NA DC ALL-002 (2.0 changes only)

DC NA DC ALL-003 (2.0 changes only)

DC NA i

i l

t i

I l

I'

l Attrchm::nt 2 to ET 98-0071 P:ge 3 of 4 JOINT LICENSING SUBCOMMITTEE METHODOLOGY FOR PROVIDING ADDITIONALINFORMATION The following methodology is followed for submitting additional information:

1. Each licensee is submitting a separate response for each section.
2. If an RAI does not apply to a licensee (i.e., does not actually impact the information that

. defines the technical specification change for that licensee), "NA" has been entered in the index column labeled " ENCLOSED" and no information is provided in the response for that licensee.

3. If a licensee initiated change does not apply, "NA" has been entered in the index column labeled " ENCLOSED" and no information is provided in the response for that licensee.
4. The common portions of the " Additional Information Cover Sheets" are identical, except for brackets, where applicable (using the same methodology used in enclosures 3A,3B, 4,6A and 6B of the conversion submittals). The list of attached pages will vary to match the licensee specific conversion submittals. A licensee's FLOG response may not address all applicable plants if there is insufficient similarity in the plant specific responses to justify their inclusion in each submittal. In those cases, the response will be prefaced with a heading such as PLANT SPECIFIC DISCUSSION.
5. Changes are indicated using the redline / strikeout tool of Wordperfect or by using a hand markup that indicates insertions and deletions. If the area being revised is not clear, the affected portion of the page is circled. The markup techniques vary as necessary, based on the specifics of the area being changed and the complexity of the changes, to provide i

the clearest possible indication of the changes.

6. A marginal note (the Additional Infor. nation Number from the index) is added in the right margin of each page being changed, adjacent to the area being changed, to identify the source of each change.
7. Some changes are not applicable to one licensee but still require changes to the Tables provided in Enclosures 3A,3B,4,6A, and 6B of the originallicense amendment request to reflect the changas being made by one or more of the other licensees. These changes are not included in the additional information for the licensee to which the i

change does not apply, as the changes are only for consistency, do not technically affect the request for that licensee, and are being provided in the additional information being provided by the licensees for which the change is applicable. The complete set of changes for the license amendment request will be provided in a licensing amendment request supplement to be provided later.

Attachm::nt 2 to ET 98-0071 i

Page 4 of 4 JOINT LICENSING SUBCOMMITTEE METHODOLOGY FOR PROVIDING ADDITIONAL INFORMATION (continued) 8.

The item numbers are formatted as follows:

[ Source] [lTS Section]-[nnn)

Source = Q - NRC Question CA - AmerenUE DC-PG&E WC-WCNOC CP - TU Electric TR - Traveler i

ITS Section = The ITS section associated with the item (e.g.,3.3). If all sections are potentially impacted by a broad change or set of changes, "ALL" is used for the section number, j

nnn = a three digit sequential number or ED (ED indicates editorial correction with no impact on meaning) l E

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2.0.G-1 APPLICABILITY: DC, CP, WC, CA REQUEST:

ITS 2.0.X Bases General There have been a number of instances that the specific changes to the STS Bases are not properly identified with redline or strikeout marks.

Comment: Perform an audit of all STS Bases markups and identify instances where additions and/or deletions of Bases were not properly identified in the original submittal.

FLOG RESPONSE: The submitted ITS Bases markups for Section 2.0 have been compared to the STS Bases. Some differences that were identified were in accordance with the markup methodologies (e.g., deletion of brackets and reviewer's notes). Most of the differences were editorialin nature and would not have affected the review. Examples of editorial changes are:

1)

Capitalizing a letter with only a " redline" but not striking out the lower case letter that it replaced.

2)

Changing a verb from singular to plural by adding an "s" without

" redlining" the "s" 3)

Deleting instead of striking-out the A, B, C,.. etc. following a specification title (e.g., SR3.6.6A.7).

4)

Changing a bracketed reference (in the reference section) with only a " redline" for the new reference but failing to include the strike-out of the old reference.

5)

In some instances the brackets were retained (and struck-out) but the unchanged text within the brackets was not redlined.

6)

Not redlining a title of a bracketed section. The methodology calls for the section title to be redlined wher, an entire section was bracketed.

7)

Additional text not contained in the STS Bases was added to the ITS Bases by the lead FLOG member during the development of the submittal. Once it was determined to not be applicable, the text was then struck-out and remains in the ITS Bases mark-up.

Differences of the above editorial nature will not be provided as attachments to this response. The pages requiring changes that are more than editorial and are not consistent with the markup methodology are l

attached.

ATTACHED PAGES:

Encl SA B 2.0-3, B 2.0-9 4

Reactor Core SLs B 2.1.1 BASES APPLICABLE The SLs represent a design requirement for establishing the RPS?

SAFETY ANALYSES trip x;,,ei;;ts 21 AL.? identified previously.

(continued)

LC0 3.4.1, "RCS Pressure. Temperature, and Flow Departure from Nucleate Boiling (Die) Limits," or Ngithe asstmed initial conditions of the safety analyses (as indicated in the FSAR M, Ref. 2) provide more restrictive limits to ensure that the SLs are not exceeded.

SAFETY LIMITS The curves provided in F1 2.1.1-1 show he loci of points of THERNAL POWER RCS pressure, and average temperatu ich the M DIER is not less than the safety =lyx; li;;;it.

. 1 W that fuel centerline temperature remains below melting, that the average enthalpy in the hot leg is less than or equal to the enthalpy of saturated liquid, or that the exit quality is within the ' limits defined by the DlBR correlation.

The curves are based on enthalpy hot channel factor limits provided in the COLR gy

.. ~ _

- 3 I

The SL is higher than the limit calculated when the AFD is within the limits of the F (aI) function of the overtemperature 3

AT reactor trip. When the AFD is not within the tolerance, the AFD effect on the overtemperature aT reactor trips will reduce the setpoints to provide protection consistent with the reactor core SLs (Refs. 3 and 4).

APPLICABILITY SL 2.1.1 only applies in MODES 1 and 2 because these are the only MODES in which the reactor is critical. Automatic protection functions are required to be OPERABLE during MODES 1 and 2 to ensure operation within the reactor core SLs. The steam generator safety valves or automatic protection actions serve to prevent RCS heatup to the reactor core SL conditions or to initiate a reactor trip function, which forces the unit into MODE 3.

L;,,,eid.s mfor the reactor trip functions are specified in LC0 3.3.1, " Reactor Trip System (RTS)

Instrumentation." In MODES 3, 4, 5, and 6. Applicability is not required since the reactor is not generating significant THERMAL W55'M m

POWER.

T2.0.6 - d h 0 5 k. S. %. 5. ?.:ry;i ;d - k h.3..w a ~ - - w --n%$ t.f N-l I d

Nc '"I ?

7 p;_ 77,_

m.

q,

~ ~

y..p 3., _

.. -... - rw m...-

r___.

_ ~ _

(continued)

WCGS-Mark-pp ofNUREG-1431-Bases 2,0 B 2.0-3 S/1587

l l

RCS Pressure SL B 2.1.2

)

i BASES (continued)

I i

i SAFETY LIMITS The maximum ransient pressure allowed in the RCS pressure vessel unde the ASME Code,Section III, is 110% of design pressure. y,a.axirar trerai;r.t pre;;uri ell u;d ir, tra RCS pipir,g, velv;;, er,d fittir.;; w.&r ['i,",S, Sectier, 031.1 '?;f. S'] i: 120t of i;ig, pre;;ur;. Da

re;t li;;;itir,; ef tt.;;; ti; ;;11;;ra;; i; tt.; 110t of de;ip, pic;;;r;. tdypfhe SL on maxima allowable D'

'N RCS pressure is 2735 psig. (

i l

I APPLICABILITY SL 2.1.2 applies in MODES 1, 2, 3, 4, and 5 because this i

SL could be approached or exceeded in these MODES due to overpressurization events. The SL is not applicable in MODE 6 because of tra r;;;ter v;;;;l F.;;d ci;;ur; heit; er; r.et fully ti,l ^ar,ed, the' plant conditions making it unlikely that the RCS can be pressurized, i

SAFETY LIMIT The following SL violations are applicable to the RCS l

VIOLATIONS pressure SL.

J 2.2.2.1 i

l If the RCS pressure SL is violated when the reactor is in MODE 1 or 2, the requirement is to restore compliance and be in MODE 3 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

l l

Exceeding the RCS pressure SL may cause inmediate RCS failure and create a potential for radioactive releases in excess of 10 CFR 100, " Reactor Site Criteria," limits (Ref. 4).

i The allowable Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> recognizes the importance of reducing power level to a MODE of operation where the potential for challenges to safety systems is minimized.

l l

2.2.2.2 l

l If the RCS pressure SL is exceeded in MODE 3, 4 or 5, RCS pressure must be restored to within the SL value within 5 minutes. Exceeding the RCS pressure SL in MODE 3, 4.

or 5 is more severe than exceeding this SL in MODE 1 or 2, since the reactor vessel temperature may be lower and the (continued) i WCGS-Mark-up ofNUREG-1431-Bases 2.0 B 2.0 9 5/158 7 w

ADDITIONAL INFORMATION COVER SHEET l

l ADDITIONAL INFORMATION NO: Q 2.0-2 APPLICABILITY: CA, CP, DC, WC REQUEST: NUREG-1431 Bases (markup)

B 2.1.1 Reactor Core SLs (Callaway and Comanche Peak [pages 2.0-3])

Comment: The SAFETY LIMITS refer to Figure B 1.1.1-1. This figure was not included l

In the B 2.1.1 markup of NUREG-1431. Provide Figure B 1.1.1-1.

FLOG RESPONSE: The FLOG has carefully examined the use of examples and typical information in the Bases of the ITS. The intent of these examples and typical information is to clarify the meaning of the Bases and thus the meaning of the ITS. In some cases, the examples and typicalinformation l

may create a human factors problem. If an example or typicalinformation is not identical to the ITS, the operator may become confused and inadvertently use the information in the Bases. Although this scenario should be unlikely, the value of the clarification provided must be weighed against the possibility and consequences if an operator error is induced.

For the subject figure, it was the best judgement of the licensees that the typical information provided in the STS Bases figure should not be included in the ITS Bases and the figure is being intentionally deleted.

Callaway and Comanche Peak removed the figure in their initial submittals. Diablo Canyon and Wolf Creek have revised the ITS Bases to reflect deletion of this figure from the ITS Bases.

ATTACHED PAGES:

Encl. SB B 2.0-3, B 2.0-6

{

Reacter Core SLs B 2.1.1 dASES APPLICABLE The SLs represent a design requirment for establishing the RPSB SAFETY ANALYSES

t. ';; nt;;;,1C EIEEEEEnEEMEREP1dentified previously.

(continued)

LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DE) Limits," or p assized initial conditions of the safety analyses (as indicated in the RiAR M, Ref. 2) provide more restrictive limits to ensure that the SLs

.are not exceeded.

~

SAFETY LIMITS The curves provided in Fi 2.1.1-1 show loci of points of TIERNAL POER RCS pressure, and average the DER is not less than the safety lyn; lidt M that fuel centerline temperature remains below melting, that the average enthalpy in the hot leg is less than or equal to the enthalpy of saturated liquid, or that the exit quality is within the ' limits defined by the DER correlation.

The curves are based on enthalpy hot channel factor limits provided in the COLR Em Y

The SL is higher than the limit calculated when the AFD is within the limits of the F (AI) function of the overtemperature AT reactor trip. Men the AFD is not within the tolerance, the AFD effect on the overtemperature AT reactor trips will reduce the setpoints to provide protection consistent with the reactor core SLs (Refs. 3 and 4).

APPLICABILITY SL 2.1.1 only applies in MODES 1 and 2 because these are the only MODES in which the reactor is critical. Automatic protection functions are required to be OPERABLE during MODES 1 and 2 to ensure operation within the reactor core SLs. The steam generator safety valves or automatic protection actions serve to ise.ait RCS heatup to the reactor core SL conditions or to initiate a reactor trip function, which forces the unit into MODE 3.

R.,,c,1;1; mor the reactor trip functions are specified in LCO 3.3.1, " Reactor Trip System (RTS)

Instrumentation." In MODES 3, 4, 5, and 6. Applicability is not required since the reactor is not generating significant TERMAL

    • W POER.

Q.o.6 -0 2 9.:.5.5'.,; -h].%g_ "., L; i i l.

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I Reactor Core SLs B 2.1.1 N

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6s r.

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i 570 580 600 610 620 630 V

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Figure B 2.1.1-1 (page 1 of )

actor Core Safety Limits vs. Boundary Protection delde.

p 2.0-2.

WCGS-Mark-ap ofNUREG-1431-Basa 2.0 B 2.0 6

.V1587

r l

l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2.0-3 APPLICABILITY: CA, CP, DC, WC l

REQUEST:

NUREG-1431 Bases (markup)

B 2.1.2 RCS Pressure SL (All FLOG Plants (Callaway and Diablo Canyon [page B 2.0-8), Comanche Peak [page B 2.0-7], and Wolf Creek [page B 2.0-9])

Comment: The APPLICABLE SAFETY ANALYSES has been revised to include,

)

" The transient that establishes the required relief capacity, and hence valve size requirements and lift settings, is a cc p'ete !cre of evte ^.2! !ced turbine trip without a direct reactor trip. Cases with and without pressurizer spray and PORVs are analyzed.

d Ou g the t 2nt!r-t, "e ce"'"c! 2rtiene 2re erru~ed, e*rept th2t '"e Safety valves on the secondary plant side are assumed to open when the steam pressure reaches the recende^j plant safety valve settings,2nd nc :^2! Main feedwater supply is ~'t='

"ad I

lost at the time of turbine trip.

l Justify the revised STS Bases 2.1.2 changes.

FLOG RESPONSE: These mark-ups directly reflect plant-specific accident analyses discussed in USAR Chapter 15.

Plant Specific Discussion USAR Section 15.2.2 states the following: "A loss of external load event results in a NSSS transient that is less severe than a turbine trip event (see Section 15.2.3). Therefore, a detailed transient analysis is not presented for the loss of external load event." As such, the ITS Bases were revised to reflect the turbine trip analyses.

USAR Section 15.2.3.2 specifically states that main feedwater flow is terminated at the time of turbine trip and that cases with and without pressurizer spray and PORVs are analyzed.

Copies of pertinent USAR pages are attached for information.

ATTACHED PAGES:

Encl.58 8 2.0-8 Wolf Creek USAR pages 15.2-2 through 15.2-9 l

..~

RCS Pressure SL B 2.1.2 BASES (continued)

APPLICABLE The RCS pressurizer safety valves, the main steam safety SAFETY ANALYSES valves (MSSVs), and the reactor high pressure trip have i

settings established to ensure that the RCS pressure SL i

will not be exceeded.

The RCS pressurizer safety valves are sized to pr;. A i

4 system pressure from exceeding the design pressure by more

- -than.10%, as-specified in Section III of;the ASE Code for Nuclear Power Plant Cooponents (Ref. 2). The transient that establishes the required relief capacity, and hence 4

valve size requirements and lift settings, is a,let 4ess-of-etternet-4eed Mthout a direct reactor trip. i rir.ii t M L.;; a.t. m a.^..el ee64 ens lves on the secondary N are asstared to open when the steam pressure reaches the eu.,er.,:;r3 pl.t safety valve settings [end-nomine+ Weedwater supply is mainte4ned and.he Adtw3 ee&mster 9,,,3 g f

. xpte.m suppus feeAuster 4

f ftw +..n.ure, adeguate. '_ The Reactor Trip Sys i

' resida:4. swl. he* M)

--, tu (%f. 5), together with the settings of the

^

(c96th.,

i=

u MSSVs, provide pressure protection for normal. operation and A00s. The reactor high pressure trip setpoint is specifically set to provide protection against 4

overpressurization (%f. 5). The safety analyses for both J

the high pressure trip and the RCS pressurizer safety valves are performed using conservative asstaptions relative to pressure control devices.

More specifically, no credit is taken for operation of the following:

i a.

Pressurizer power operated relief valves (PORVs);

i 9

[

b.

Steam'li m reli;f v;1v; M m;

c.

m team Duep System m :

4 d.

Reactor Control System:

2 i

' e.

Pressurizer Level Contml System: or i

f.

Pressurizer spray valvet.

(continued)

)

1

~

WCGS-Mark-agp ofNUREG-1431-Bases 2.0 8 2.0 8 S/1537

WOLF CREEK 15.2.'2 LOSS OF EXTERNAL ELECTRICAL LOAD 15.2.2.1 Identification of causes and Accident Descrintion A major load loss on the plant can result from loss of external electrical load due to some electrical system disturbance. Offsite ac power remains available to operate plant components, such as the reactor coolant pumps; as a result, the onsite emergency diesel generators are not required to function for this event.

Following the loss of generator load, an immediate fast closure of

)

the turbine control valves will occur. The automatic turbine bypass syst.m would accommodate the excess steam generation.

e Reactor coolant temperatures and pressure do not significantly increase if the turbine bypass system and pressurizer pressure i

control system are functioning properly.

If the condenser were not available, the. excess steam generation would be relieved to the atmosphere.

Additionally, main feedwater flow would be lost if the condenser were not available.

For this situation, feedwater flow would be maintained by the auxiliary feedwater

' system.

For a loss of external electrical load without subsequent' turbine trip, no direct reactor trip signal would be generated.

The plant would trip from the reactor protection system if a safety limit

. ere approached.

A continued steam load of approximately 5 w

percent would exist after total loss of external electrical load,

)

because of the steam demand of plant auxiliaries.

Following the loss of load, protection would be provided by high pressurizer pressure, high pressurizer water level, and overtemperature AT trips should a safety limit be approached.

Voltage and frequency relays associated with the reactor coolant pump provide no additional safety function for this event.

Following a complete loss of external load, the maximum turbine overspeed would be approximately 8 to 9 percent, resulting in an l

l overfrequency of less than 6 Hz.

This resulting overfrequency is not expected to damage the voltage and frequency sensors in any way.

Any degradation in their performance could be ascertained at that time.

Any increased frequency to the reactor coolant pump l

motors will result in slightly increased flow rate and subsequent additional margin to safety limits.

For postulated loss of load and subsequent turbine-generator overspeed, any overfrequency condition-is not seen by other safety-related pump motors, reactor protection system equipment, or other safety-related loads.

Safety-related loads are supplied from offsite power or, alternatively, from emergency diesels.

Reactor protection system equipment is supplied from the 118-Volt'ac instrument power supply system which,'in turn, is supplied from the inverters; the inverters are supplied from a de bus energized from batteries or i..

~

by a rectified ac voltage from safety-related busses.

l 15.2-2 Rev. 7

WOLF CREEK In the event that the turbine bypass valves fail to open following a large loss of load, the steam generator safety valves may lift, i

and the reactor may be tripped by the high pressurizer pressure signal, the high pressurizer water level signal, or the overtemperature DT signal.. The steam generator shell side pressure and reactor coolant temperature will increase rapidly.

The pressurizer safety valves and steam generator. safety valves L

are, however, sized to protect the RCS and steam generator against overpressure for all load losses without assuming the operation of the turbine bypass system, pressurizer spray, pressurizer power-

' operated relief valves, automatic rod cluster control assembly L

(RCCA), control, or direct reactor trip on turbine trip.

l l

The steam generator safety valve capacity 10 si. zed to remove,the L

steam flow at the engineered safety features rating (105 percent i

of steam flow at rated power) from the steam generator, without exceeding 110 percent of the steam system design pressure.

The pressurizer safety valve capacity is sized to accommodate a i

complete 1 css of heat sink, with the plant initially operating at the maximum calculated turbine load along with operation of the steam generator safety valves. The pressurizer safety valves are 1

then able to relieve sufficient steam to maintain the RCS pressure within 110 percent of the RCS design pressure.

A more complete discussion of overpressure protection can be'found in Reference 1.

i.

A loss of external load is classified as an ANS Condition II l

event, faulc of moderate frequency.

See Section 15.0.1 for'a discussion of Condition II events.

A loss of external load event results in a nuclear steam supply l-system transient that'is bounded by the turbine trip event analyzed in Section 15.2.3.

Therefore,.a detailed transient analysis is not presented for the loss of external load event.

i L

The primary side tranaient is caused by a decrease in heat l'

transfer capability from primary to secondary, due to a rapid l

termination of steam flow to the turbine,-accompanied by'an l

automatic' reduction of feedwater flow (should feedwater flow not be reduced, a larger heat sink would be available and the transient would be less severe).

Termination of steam flow to the turbine following a loss of external load occurs due to automatic l

fast closure'of the turbine control valves in approximately 0.3 seconds.

Following a turbine trip event, termination of steam flow occurs via turbine stop valve closure, which occurs in approximately 0.1 seconds.

Therefore, the transient in primary pressure, temperature, and water volume will be less severe for the loss of external load than for the turbine trip, due to a slightly slower loss of heat transfer capability.

15.2-3 Rev. 0

(

WOLF CREEK The protection available to mitigate the consequences of a loss of external load is the same as that for a turbine trip, as listed in Table 15.0-6.

15.2.2.2 ' Analysis of Effects and Consecuences Refer to Section 15.2.3.2 for the method used to analyze the limiting transient (turbine trip) in this grouping of events. The

-results of the turbine trip event analysis bound those expected i

for the loss of external load, as discussed in Section 15.2.2.1.

l l

Plant systems and equipment which may be required to function to mitigate the effects of a complete loss of load are discussed in Section 15.0.8 and listed in Table 15.0-6.

i The reactor protection system may be required to function to terminate core heat input and to prevent departure from nucleate boiling (DNB).

Depending on the magnitude of the load loss, pressurizer safety valves and/or steam generator safety valves may be required to open to maintain system pressures below allowable limits.

No single active failure will prevent operation of any system required to function.

Normal reactor control systems and engineered safety systems are not required to function.

The auxiliary feedwater system may, however, be automatically actuated

'following a loss of main feedwater; this will further mitigate the effects of the transient.

)

15.2.2.3 Conclusions Based on results obtained for the turbine trip event (see Section 15.2.3) and considerations described in Section 15.2.2.1, the applicable acceptance criteria for a loss of external load event are met.

15.2.3 TURBINE TRIP l

15.2.3.1' Identification of causes and Accident Descrintion For a turbine trip event, the reactor would be tripped directly (Direct reactor trip on turbine trip is blocked below 50% power by the P-9 interlock) from a signal derived from the turbine stop emergency trip fluid pressure and turbine stop valves.

The turbine stop valves close rapidly'(typically 0.1 second) on loss of trip fluid pressure actuated by one of a number of possible turbine trip signals.

Turbine trip initiation signals include:

i I

l 15.2-4 Rev. 7 e--.

e-

i l

WOLF CREEK l

a.

Generator trip b.

Low condenser vacuum c.

Loss of lubricating oil d.

Turbine thrust bearing failure e.

Turbine overspeed f.

Manual trip Upon initiation of stop valve closure, steam flow to the turbine stops abruptly. Sensors on the stop valves detect the turbine trip and initiate turbine bypass, and, if above 50-percent power, a reactor trip. The loss of steam flow results in an almost immediate rise in secondary system temperature and pressure, with a resultant primary system transient as described in Section 15.2.2.1 for the loss of external load event. A slightly more severe transient occurs for the turbine trip event, due to the more rapid loss of steam flow caused by the more rapid valve closure, hence a more rapid loss of primary-to-secondary heat transfer.

The automatic turbine bypass system would accommodate up to 40 percent of rated l

steam flow. Reactor coolant temperatures and pressure do not increase significantly if the turbine bypass system and pressurizer pressure control system are functioning properly. If the condenser were not available, the excess steam generation would be relieved to the atmosphere, and main feedwater flow would be lost. For this situation, feedwater flow would be maintained by the auxiliary feedwater system to ensure adequate residual and decay heat removal capability. Should the turbine bypass system fail to operate, the steam generator safety valves may lift to provide pressure control. See Section 15.2.2.1 for a further discussion of the transient.

A turbine trip is classified as an ANS Condition II event, fault of moderate frequency. See Section 15.0.1 for a discussion of Condition II events.

A turbine trip is more limiting than loss of external load, loss of condenser vacuum, and other events which result in a turbine trip as a result of the more rapid loss of steam flow during the turbine trip. As such, this event has been analyzed in detail. Results and discussion of the analysis are presented in Section 15.2.3.2.

15.2.3.2 Analysis of Effects and Consecuences Method of Analysis In this analysis, the behavior of the unit is evaluated for a complete loss of steam load from 102 percent of full power, without direct reactor trip, primarily to show the adequacy of the pressure relieving devices, and also to demonstrate core protection margins; that is, the turbine is assumed to trip l

15.2-5 Rev. 7 l

l

WOLF CREEK 1

l l

without actuating all the sensors for reactor trip on the turbine stop valves.

This assumption delays reactor trip until conditions in the RCS result in a trip due to other signals.

Thus, the analysis assumes a worst transient. In addition, no credit is taken for the turbine bypass system. Main feedwater flow is terminated at the time of turbine trip, with no credit taken for auxiliary feedwater to mitigate the consequences of the transient.

The turbine trip transients are analyzed by employing the detailed digital computer program RETRAN-02 Mod 5 (Ref 5).

RETRAN-02 has been found acceptable by the NRC for use as a licensing basis safety analysis code.

RETRAN-02 is a thermal-hydraulic systems analysis code employing a one-dimensional, homogeneous equilibrium mixture thermal-hydraulic model for the RCS, a point kinetics model for the reactor core, special component and suxiliary models (ex., pumps, temperature transport, non-equilibrium pressurizer) and control system models. The code computes pertinent plant transient information including core power level, RCS pressure and temperature. VIPRE-01 (Ref 6) is used to evaluate the core thermal limits to determine DNBR.

RETRAN-02 generated state points are used as VIPRE-01 boundary conditions to perform a Statistical Core Design (SCD) DNB analysis.

The turbine trip event is analyzed for RCS overpressurization assuming nominal initial conditions including allowances for measurement errors. DNBR ffs l evcluated using Westinghouse RTDP methodology - (Ref. 7) ~which assumeA~ nominal initi_a_l_c,o_nd_i_tions. - -

u"w M -

-~ ~ ~~ ~ ' ' " ~

~ ~~

The major assumptions used in the analysis are summarized below:

a.

Initial operating conditions (overpressure)

Initial reactor power and RCS temperatures are assumed at their maximum values consistent with steady state full power operation, including allowances for calibration and instrument errors. The initial RCS pressure is assumed at a minimum value consistent with steady state full power operation, including allowances for calibration and instrument errors. This is to maximize the heat up time prior to reactor trip and therefore, maximizing the peak RCS pressure and peak pressurizer level during the transient.

b.

Initial operating conditions (DNB)

The initial pressure, reactor power and RCS temperatures are assumed at their nominal values consistent with steady state full power operation. Allowances for calibration and instrument errors are treated statistically by the DNBR evaluation code.

l 15.2-6 Rev. 10 i

I l

WOLF CREEK l

c.

Reactivity coefficients (two cases are analyzed):

1.

Minimum reactivity feedback A most positive moderator temperature coefficient and a least negative Doppler-only power coefficient are assumed.

2.

Maximum reactivity feedback A conservatively large negative moderator temperature coefficient and a most negative Doppler-only power coefficient are assumed.

Cases for DNB and system overpressurization are analyzed for both the minimum and maximum reactivity feedback conditions.

d.

Reactor control From the standpoint of the maximum pressures attained, it is conservative to assume that the reactor is in manual control.

If the reactor were in automatic control, the control rod banks would move prior to trip and reduce the severity of the transient.

e.

Steam release No credit is taken for the operation of the turbine bypass system or steam generator atmospheric relief valves. The l

steam generator pressure rises to the safety valve setpoint where steam release through safety valves limits secondary steam pressure at the setpoint value.

f.

Pressurizer spray and power-operated relief valves 1.

DNB Full credit is taken for the effect of pressurizer spray and power-operated relief valves in reducing or limiting the coolant pressure.

Safety valves are also available.

2.

Overpressure No credit is taken for the effect of pressurizer spray and power-operated relief valves in reducing or limiting the coolant pressure.

Safety valves are operable.

g.

Feedwater flow Main feedwater flow to the steam generators is assumed to be lost at the time of turbine trip. No credit is taken for auxiliary feedwater flow, since a stabilized plant condition will be reached before auxiliary feedwater initiation is normally assumed to occur; however, the auxiliary feedwater pumps would be expected to start on a trip of the main feedwater pumps.

The l

l l

l 15.2-7 Rev. 11 l

WOLF CFGEK l

auxiliary feedwater flow would remove core decay heat following plant stabilization.

h.

Reactor trip is actuated by the first reactor protection system trip setpoint reached, with no credit taken for the direct reactor trip on the turbine trip.

Trip signals are expected due to high pressurizer pressure, overtemperature AT, and low-low steam generator water level.

Plant characteristics and initial conditions are further discussed in Section 15.0.3.

Plant systems and equipment which may be required to function to mitigate the effects of a turbine trip event are discussed in Section 15.0.8 and listed in Table 15.0-6.

The reactor protection system may be required to tanction following a turbine trip.

Pressurizer safety valves and/or steam generator safety valves may be required to open to maintain system pressures below allowable limits.

No single active failure will prevent operation of any system required to function. Normal reactor control system and engineered safety systems are not l required to function.

Results

~

The transient responses for a turbine trip from 102 percent of full power operation are shown for four cases in Figures 15.2-1 through 15.2-8.

Two cases are presented without pressure control (i.e.,

PORVs, pressurizer spray) to ensure 110% of the design pressure (2750 psia) is not exceeded and two cases using nominal initial plant conditions and pressure control are analyzed to provide boundary conditions for DNB analysis. Each case is analyzed assuming minimum and maximum reactivity feedback to ensure the worst case is analyzed.

The calculated sequence of events for the accident is shown in Table 15.2-1.

Figures 15.2-1 and 15.2-2 show the transient responses for the total loss of steam lead overpressure evaluation with minimum reactivity feedback, assuming no credit is taken for the steam bypass.

The reactor is tripped on the high pressurizer pressure signal.

The neutron flux increases slightly above 102 percent of full power until the reactor is tripped, due to the positive moderator temperature coefficient.

In this case, the pressurizer safety valves are actuated, and maintain RCS pressure below 110 percent of the design value.

Figures 15.2-3 and 15.2-4 show the responses for the total loss of steam load overpressure evaluation with maximum reactivity feedback. All other plant parameters are assumed to be the same as in the previous case. Again, the reactor is tripped on high pressurizer pressure and the pressurizer safety valves are actuated to limit primary pressures.

15.2-8 Rev. 7

WOLF CREEK I

l The DNB evaluation for the turbine trip event was analyzed assuming full pressure control and nominal initial conditions. The errors in initial

, conditions are treated statistically in the VIPRE model (Ref 5).

Figures 15.2-5 and 15.2-6 show the transient responses for the total loss of steam load with minimum reactivity feedback for the DNB evaluation. No credit is taken for the steam bypass. Due to the positive moderator temperature coefficient, the power increases to approximately 110 percent of nominal before the reactor is tripped by the high pressurizer pressure trip channel. Steam is released through the l

pressurizer' safety valves for this_ case and the maximum RCS pressure is maintained-below 110 percent of the design pressure. The steam generator

-safety valves limit the secondary steam conditions to saturation at the safety valve setpoint. Minimum DNBR remains above the safety analysis limit.

Figures 15.2-7 and 15.2-8 show the response for the DNB e, valuation with maximum reactivity feedback. The reactor is tripped by the high pressurizer pressure trip channel but the pressurizer safety valves are not actuated for this case.

Reactor power remains essentially constant until the trip occurs. The steam generator safety valves limit the secondary steam conditions to saturation at the safety valve setpoint. Minimum DNBR remains above the safety analysis limit.

Reference 1 presents additional results of analysis for a complete loss of heat sink, including loss of main feedwater. This analysis shows the overpressure protection that is afforded by the pressurizer and steam generator safety

.-~ _,

1 15.2.3.3 Conclusions I

Results of the analyses show that the plant design is such that.a turbine trip without a direct or immediate -reactor trip presents no hazard to the integrity of the RCS or the main steam system. Pressure-relieving devices incorporated in the two systems are adequate to limit the maximum pressures to within the design limits.

The analyses show'that the DNBR will not decrease below the safety analysis limit at any time during the transient. Thus, the DNB design basis, as i

described in Section 4.'4, is met.

15.2-9 Rev. 10 l

l i

I

_ ~. _ _ _...

l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 2.0-6 APPLICABILITY: WC REQUEST:

NUREG-1431 Bases (markup)

B 2.1.2 REC Pressure SL (Wolf Creek (page B 2.0-9))

Comment: The APPLICABILITY states that, "...The SL is not applicable in MODE 6 i

because of t'e r?r^'^firrerrd c'^ r'e '^!!! ric et 'u!!' ?!@tered the plant conditions making it unlikely that the RCS can be pressurized. The basis of this change is CTS 1.0, Table 1.2 and TSTF-88. TSTF-88 has not been approved. If TSTF-88 is

{

not approved in time for the draft Safety Evaluation (SE) to be prepared, the B 2.1.2, RCS Pressure SL, APPLICABILITY change will not be included in the improved i

Technical Specifications (ITS). Justification must be provided for this change.

FLOG RESPONSE: The changes to the APPLICABILITY were not based on TSTF-88 as l.

discussed above.- Wolf Creek modified this Bases for the following L

reasons. MODE 6 is entered when the first head bolt is less than fully i

I tensioned. There can be a period of time in MODE 6 in which the RCS l

could be pressurized. ITS 3.4.12, " Low Temperature Overpressure l

Protection (LTOP) System," requires overpressure protection in MODE 6 with the reactor vessel head on. The ITS 3.4.12 Bases further states that j-when the reactor vessel head is off, overpressurization cannot occur.

Therefore, the ITS 2.1.2 Bases changes were made to more accurately reflect why the Safety Limits are not applicable in MODE 6.

ATTACHED PAGES:

l None p

l'

.. _,.-~

~-.

i Att: chm:nt 3 to ET 98-0071 Pago 1 of 4 l

i i

?

JLS CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS l

CTS 3/4.0 - LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS f

l ITS 3.0 - LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS l

l' RESPONSE TO REQUEST FOR ADD;TIONAL INFORMATION AND LICENSEE INITIATED l

ADDITIONAL CHANGES 1

l l

Att: chm:;nt 3 to ET 98-0071 Pcga 2 of 4 INDEX OF ADDITIONAL INFORMATION ADDITIONAL INFORMATION APPLICABILITY ENCLOSED NUMBER 3.0.G-1 DC, CP, WC, CA YES l

3.0-1 DC, CP, WC, CA YES 3.0-2 CP NA I

3.0-3 DC, CP, WC, CA YES l

3.0-4 DC, CP, WC, CA YES 3.0-5 DC, CP, WC, CA YES I

3.0-6 DC, CP, WC, CA YES 3.0-7 DC NA l

TR 3.0-001 DC, CP, WC, CA YES TR 3.0-002 DC, CP, WC, CA YES DC 3.0-001 DC NA w

e e

..- -.- -- - ~.-. _ -.~ -.. - - -. -..- -

I Attachm:nt 3 to ET 98-9071 '

Pcge 3 of 4 i

JOINT LICENSING SUBCOMMITTEE METHODOLOGY FOR PROVIDING ADDITIONALINFORMATION i

j The following methodology is followed for submitting additional information:

1. Each licensee is submitting a separate response for each section.'

\\

i i

2. If an RAI does not apply to a licensee (i.e., does not actually impact the information that defines the technical specification change for that licensee), "NA" has been entered in the index column labeled " ENCLOSED" and no information is provided in the response for that licensee.
3. If a licensee initiated change does not apply, "NA" has been entered in the index column labeled
  • ENCLOSED" and no information is provided in the response for that licensee.
4. The common portions of the " Additional Information Cover Sheets" are identical, except for brackets, where applicable (using the same methodology used in enclosures 3A,3B, 4,6A and 6B of the conversion submittals). The list of attached pages will vary to match the licensee specific conversion submittals. A licensee's FLOG response may not address all applicable plants if there is insufficient similarity in the plant specific responses to justify their inclusion in each submittal. In those cases, the response will be prefaced with a heading such as PLANT SPECIFIC DISCUSSION.
5. Changes are indicated. using the redline / strikeout tool of Wordperfect or by using a hand markup that indicates insertions and deletions. If the area being revised is not clear, the affected portion of the page is circled. The markup techniques vary as necessary, based on the specifics of the area being changed and the complexity of the changes, to provide the clearest possible indication of the changes.
6. A marginal note (the Additional Information Number from the index) is added in the right

. margin of each page being changed, adjacent to the area being changed, to identify the -

source of each change.

~

- 7. Some changes are not applicable to one licensee but still require changes to the Tables provided in Enclosures 3A,38,4,6A, and 6B of the originallicense amendment request to reflect the changes being made by one or more of the other licensees. These changes are not included in the additional information for the licensee to which the change does not apply, as the changes are only for consistency, do not technically affat L

. the request for that licensee, and are being provided in the additional information being provided by the licensees for which the change is applicable. The complete set of changes for the license amendment request will be provided in a licensing amendment request supplement to be provided later.

i l:

p m.

Attrchm:nt 3 to ET 98-0071 l

P gs 4 of 4-1 l

JOINT LICENSING SUBCOMMITTEE METHODOLOGY FOR PROVIDING ADDITIONALINFORMATION (continued) 8.

The item numbers are formatted as follows:

(Source)[lTS Section]-[nnn)

Source = Q - NRC Question CA-AmerenUE DC-PG&E WC-WCNOC CP - TU Electric TR - Traveler ITS Section = The ITS section associated with the item (e g.,3.3). If all sections are potentially impacted by a broad change or set of changes, "ALL" is used for the section number, nnn = a three digit sequential number or ED (ED indicates editorial correction with no impc';t on meaning) i i

i

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.0.G-1 APPLICABILITY: DC, CP, WC, CA REQUEST:

ITS 3.0.X Bases General i

There have been a number of instances that the specific changes to the STS Bases are not properly identified with redline or strikeout marks.

Comment: Perform an audit of all STS Bases markups and identify instances where l

additions and/or deletions of Bases were not properly identified in the original submittal.

FLOG RESPONSE: The submitted ITS Bases markups for Section 3.0 have been compared i

to the STS Bases. Some differences that were identified were in accordance with the markup methodologies (e.g., deletion of brackets and reviewer's notes). Most of the differences were editorial in nature and would not have affected the review. Examples of editorial changes are:

1)

Capitalizing a letter with only a " redline" but not striking out the lower case letter that it replaced.

2)

Changing a verb from singular to plural by adding an "s" without i

" redlining" the "s".

3)

Deleting instead of striking-out the A, B, C,.. etc. following a specification title (e.g., SR3.6.6A.7).

4)

Changing a bracketed reference (in the reference section) with only a " redline" for the new reference but failing to include the strike-out of the old reference.

5)

In some instances the brackets were retained (and struck-out) but the unchanged text within the brackets was not redlined.

6)

Not redlining a title of a bracketed section. The methodology calls for the section title to be redlined when an entire section was bracketed.

7)

Additional text not contained in the STS Bases was added to the ITS Bases by the lead FLOG member during the development of the submittal. Once it was determined to not be applicable, the text was then struck-out and remains in the ITS Bases mark-up.

Differences of the above editorial nature will not be provided as attachments to this response. The pages requiring changes that are more than editorial and are not consistent with the markup methodology are l

attached.

I ATTACHED PAGES:

l None

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.0-1 APPLICABILITY: DC, CP, WC, CA REQUEST:

ITS SR 3.0.3 l

CTS SR 4.0.3 (All FLOG Plants)

DOC 1-20-A Comment: The CTS Markups of CTS SR 4.0.3 for all FLOG plants do not accurately reflect the ITS end product, SR 3.0.3 (ITS 3.0.3 is compatible with the STS and acceptable). Correct CTS Markup, or revise ITS Markup and provide justification.

FLOG RESPONSE: The markups for CTS SR 4.0.3 and CTS SR 4.0.1 have been revised to be consistent with ITS SR 3.0.3 and ITS SR 3.0.1.

The CTS markups have been revised to reflect moving CTS SR 4.0.3 phrases into CTS SR 4.0.1 and DOC 1-20-A revised to state: " Editorial changes to CTS SR 4.0.1 are made for consistency with NUREG-1431 SR 3.0.1. The CTS SR 4.0.3 phrase " Failure to perform a Surveillance Requirement... for a Limiting Condition of Operation." was moved to CTS SR 4.0.1 (ITS SR 3.0.1) to establish the relationship between Surveillance Requirements and meeting the requirements of the LCO. In addition, the words "except as provided in Specification 4.0.3" are added at the end of the moved sentence to retain the exception provided by the CTS markup of SR 4.0.3. The CTS SR 4.0.3 phrase " Surveillance Requirements do not have to be performed on inoperable equipment." was moved to CTS SR 4.0.1 (ITS SR 3.0.1) to establish the relationship between Surveillance requirements and meeting the requirements of the LCO. This phrase has also been modified to include variables not within limits since Specifications cover more than equipment (e.g., containment pressure)."

CTS SR 4.0.3 is revised to specify required actions whenever the Surveillance Requirement fails or whenever the delay period is exceeded.

DOC 1-08-LS and NSHC LS-4 have been modified to specifically address this change by adding the following words: "The CTS has been revised to add the phrases "If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered." and "When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered." to clarify the delay period."

ATTACHED PAGES:

Encl. 2 0-2 Encl.3A 4, 5 Encl. 3B 3

Encl. 4 50

__ __. _ __. _. _ _.~_.._._ _ _._..._..__ _ _._..__ _ _ _ _ _ _

1 APPLICABILITY i

SURVEILLANCE REQUIREMENTS l

4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES i

or other condibons specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

- b A $ 3a-l_]

r~-.*

4.0.2 Each Surveillance Requirement shall be performed within the specified I

surveillance interval with a maximum allowable extension not to exceed 25% of 1

l the specified interval, i

j for frequencies specified as "once," the above interval extension does not apply { [jg

{]

'If a Completion time requires periodic performance on a 7

i 1

"once per " basis, the above Frequency extension applies to toech performance after the initial performance.

]'

(Exceptions to this Specification are stated in the individual Specifications.]{gg]

silure to perform a Surveillance Requirement within the

.]Q3.o-i]

J surveillance interval, defined by Specification 4.0.2, shall constitute riern~,,,,Aisnce with the OPERABILITY requirements for a Umibna Condition for 3

@peration.

x:..r _ r C x-._

. __ -'_ e.^ CTS : x __;n^ =

@[g$"484449

____..m.m_

1, a _._ _ _ _.

m._ _

__o__..

_ _. m_

e

<> w l

i S x [. U 5 U T! U : h '_[.5 [.._ S A M U, 3 6 5 24 h r.

884.88 du Vid8d h j

i e;u:ex ;1xee=r.-m=n=e 1 ^:rrox:=

speedica '

+.a.3 i_ e e.^. " "'-- ' _. r._ = ':x ^^r. 24 5:nftit is discovered that a Fourveillance wee not i, A,i-cf whhin its specified Frequency, then compliance with ]- u-t l the requirement to declare the LCO not met may be delayed, from the time of discovery),

I up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less.

i Jhis delay period is permitted to allow performance of the SurveillanceJSurveillaiice Recuerements do not have to be performed on inoperable equipment [or variables]

$%Z"

@utside specifkd limits)

-e L93 o-t 1 4.0.4 Entry into an OPERATIONAL MODE or other specriled condition shall not 4

be made unless the Surveilience Requirement (s) r,ssociated with a Limiting Condibon of Operation has been performed witnin the stated surveillance interval or as otherwise specified This provision shall not prevent passage 3

through or to OPERATIONAL MODES as required to comply with ACTION requirements @r that are part of a shutdown of the unit)

${$ $ 1]

3R 4.0.4 is only applicable for entry into a MODE or other specified condition'

[TM&fl I-p the Applicability in MODES 1,2,3, and 4.

~""

4.0.5 Surveillance Requirements for inservice 'z;:J'nend testing of ASME

@"%']A j

Code Class 1,2, and 3 components shall be applicable as follows

. ' x. in 'c:; n' _. e ^ **?'" c5 C'- : 4,2, rd 2 x...;xx'; rd

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e +~rs c+ c re,2, = 2 r,=;_ re =r
=

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j Lcc> wmst immladbtag b dested w,t mei,owd Ma. appu A lQ 3,o,i )

conatti@ mud b

.nte<ea.

When me. Surve.illmc.a. G, padormed-usthhhe, deh peded ad bme. sum u-2 ~t w, w met kneaq wa.awa 4

ort me h ed h appAlcAW.A. ConWih'ev@ rmst ba. catwed.

l WOLF CREEK - UNIT 1 3/4 0-2 AMENDMENT NO.44,47,90 Mark-up of CTS 3M.0 5/158 7

+

n, r.,

i l

CHANGE i

NUMER H5lE DESCRIPTION j

of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the specified Frequency for performance of the surveillance. The allowance to not declare the equipment inoperable upon discovery of a missed surveillance is a relaxation in that ACTIONS for i

inoperable equipment are not entered solely due to a missed surveillance. The change in time to perform the surveillance, could either be a relaxation or restriction 1

based on whether the surveillance Frequency or the Allowed Outage Time were more restrictive. The new requirement is

. based on time to perfom a surveillance and is therefore-more consistent. The change still restricts performance of L

the surveillance to within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery and is seen as acceptable, from the perspective of safety, as equipment is normally demonstrated OPERABLE._not j

inoperable via surveillance performance.Qusraiitsa-@qs.o-q 1 09 LS 1 Surveillance Requirement 4.0.4 was previously applicable for entry into all MODES. The specification has been revised to not prevent unit shutdowns and will apply only to entry into MODES 1, 2. 3, and 4 from lower MODES. This change is less restrictive in that it will allow MODE changes in either direction into MODES 5 and 6 prior to the performance of Surveillance Requirements. As required l.

in the " Reviewer's Note" of NUREG 1431 Rev. 1, SR 3.0.4 a matrix is provided (see LS 1) which documents the plant-specific review of all specifications for determination of where specific restrictions on MODE changes or Required Actions should be included in individual LCOs. The change is acceptable for those specifications for which specific restrictions were not deemed warranted.

I 1 10

.A.

Specification 4.0.5, the surveillance requirements for inservice testing are moved to the Administrative Controls Section 5.5.8 consistent with NUREG 1431 Rev.1. The reference to 10CFR50.55a is unnecessary and has been deleted.

l 1 11 LG The portions of Specification 4.0.5 concerning Inservice Inspection are moved to the Inservice Inspection Program l

Plan..The requirements of 10CFR50.55a are adequate and

' technical specifications are not necessary.

1 12 A

Consistent with NUREG 1431 Programs and Manuals section, ITS 5.5.8. the CTS is clarified to address the frequency (in days) for biennial requirements which was previously j

inferred but not explicitly stated in the CTS.

I WCGS-Description ofChanges to CTS 3M.0 4

5/15/97

INSERT 3A-4a 0 3.0-1 l

l The CTS has been revised to add the phrases "If the Surveillance is not performed within the delay period, the LC0 must immediately be declared not met, and the applicable Condition (s) must be entered." and "When the Surveillance is performed within the delay period and the Surveillance is not i

met, the LCO must immediately be declared not met, and the applicable l

Condition (s) must be entered." to clarify the delay period.

l l

l I

i F

l l

L i

L CHANGE NutBER EC -

DESCRIPTION 1-13 A

Adds applicability of 4.0.3 (SR 3.0.3 in improved TS) for Inservice Testing for consistency with the wording in NUREG 1431. 'In NUREG 1431. Inservice Testing is moved to the Programs and Manuals section (ITS 5.5.8) and is no longer a Surveillance Requirement. Thus an explicit statement that -ITS SR 3.0.3 (CTS 4.0.3) was applicable was necessary to provide for the performance of missed IST requirements. CTS 4.0.5 (Inservice Testing) is currently a Surveillance Requirement and thus, by definition, 4.0.3 applies.

1-14 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38)

I, 1 15 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38)-

l 1 16 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38)

L

'l 17 A

Consistent with the wording used in NUREG 1431, Rev.1.

I Section 5.5.8 the statement concerning performance of inservice testing being in addition to other specified-surveillance requirements, is deleted. The statement is redundant to the usage rules and is not necessary.

1 18 LS 5 Revises LCO 3.0.4 to allow N00E entry if associated ACTION has no time limit, consistent with NRC GL 87-09 and NUREG-j-

1431. Rev. 1.

i j

.1 19 A

Consistent with NUREG 1431, Rev. 1. the phrase " Exceptions to this Specification are stated in the individual specifications" was added to CTS SR 4.0.2 to provide exceptions in individual Frequencies where the allowances provided in SR 4.0.2 are not allowed. This additional wording will.have no impact on current practice regarding l

compliance with SRs.

Cons 'ent w NUR 431.

phr e "or y abl

}i 1 20 A

ide cific mits" added o the teme tha

,surv ance not e to rfo on i pera e t

L pmen. This i tat nical c nge that j

' " var es out specif limits" s expli tly

,s ed in t ITS wher s, in t

CTS, was lic in

+

i the def tion of 1 perable uipme. mw.gt3A.% j l

h Q an-l T

~

6-2,# _.e. e e o ms. w - ~ c~r g [q3,e.rl

-r m.a

( a n n.ta m a. 2 t o WCGS-Descripti5n of CRanges to m 3M.0 5

S/15M7 H

__......__-.._.._.._...m...__

t

' INSERT 3A-Sa 0 3.0-1 Editorial changes.to CTS SR 4.0.1 are made for consistency with NUREG-1431 SR 3.0.1.

The CTS SR 4.0.3 phrase " Failure to perform a Surveillance Requirement

... for-a Limiting Condition of Operation " was moved to CTS SR 4.0.1 (ITS SR 3.0.1) to establish the relationship between Surveillance Requirements and i

meeting the requirements of the LCO.

In addition, the words "except as provided in Specification 4.0.3" are added at the end of the moved sentence to retain the exception provided by the CTS markup of SR 4.0.3.

The CTS SR 4.0.3 i

phrase " Surveillance Requirements do not have to be performed on inoperable l

equipment." was moved to CTS SR 4.0.1 (ITS SR 3.0.1) to establish the l

relationship between Surveillance requirements and meeting the requirements of l

the LCO. This phrase has also been modified to include variables no within I

limits since Specifications cover more than equipment (e.g., containment pressure).

i.

t I

l-l l

(;

I l-I

CONVERSION COMPARISON TABLE -CURRENT TS 3/4.0 Page 3 of 3 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 1-20 fhe ~

e-ariatile tside ific it? a ~

Yes Yes Yes Yes J

he ement t surveill

.es do hagv A

- -ea o

r on i able t.

l EditovM cEqs b c:rsm 4.o.1 are. made. Gw-

)e 3.0 -l \\

combianc3 wi+b e4utsc-1431 sK. 3.o. t.

l-11 tusGAT 38-3b

[ os.o.r j A

e i

N#

WCGS-Conversion Comparison Table - CTS 3N.0

0 3.0-5 INSERT'3B-3b TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK l WOLF CREEK CALLAWAY 1-21 The requirements to meet ACTIONS if LC0 is Yes Yes No - See 1 No - See 1 A not met is moved from LC0 3.0.1 to 3.0.2.

A A

IV.

SPECIFIC NO SIGNIFICANT HAZARDS EVALUATIONS l

NSHC LS 4 10 CFR 50.92 EVALUATION l

FOR L

TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE l

REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS This change is adninistrative in nature as the time allowed to pet form a missed surveillance upon discovery is changed from up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the allowable outage l

time limits of the ACTION requirements to the lesser of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the surveillance frequency interval.. Additionally the equipment is not requir'ed to be declared l

inoperable at the time of discovery of a missed surveillance. This prevents 1

unnecessary entry into Conditions based solely on equipment inoperabilities when the equipment is anticipated to be demonstrated OPERABLE by surveillance performance.

. This change is acceptable because it still restricts performance of the surveillance l

to within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery and the equipment is normally demonstrat to be OPERABLE, not inoperable by performance of the surveillance. (biedt 4.50a.

Q3.b-(

.This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:

"The Connission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendnent to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazdrds consideration, if operation of the facility in accordance with the proposed amendnent would not:

i 1.

Involve a significant increase in the probability or consequences of an accident previously evaluated: or 2.

Create the possibility of a new or different kind of accident fran any accident previously evaluated; or 3.

Involve a significant reduction in a margin of safety."

The following evaluation is provided for the three categories of the significant hazards consideration standards:

- 1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

l Surveillance performance is nominally considered to demonstrate equipment operability. Therefore identifying that a surveillance has been missed usually does l

not result in any true inoperabilities existing as the equipment is demonstrated OPERABLE upon performance of the missed surveillance. This change potentially allows a longer time in some instances for performance of the surveillance from time of discovery that the surveillance was missed. In these cases, if the equipment were truly inoperable. there would be an extended duration in which the appropriate WCGS-NSHCs-CTS 3M.0 50 5/15/97 l

INSERT 4-50a 0 3.0-1 The CTS has been revised to add the phrases "If the Surveillance is not i

performed within the delay period, the LC0 must immediately be declared not met, and the applicable Condition (s) must be entered." and "When the Surveillance is performed within the delay period and the Surveillance is not met, the LC0 must immediately be declared not met, and the applicable Condition (s) must be entered." to clarify the delay period.

1 l

l

-. - -. =....

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.0-3 APPLICABILITY: DC, CP, WC, CA REQUEST:

ITS LCO 3.0.5 Bases (All FLOG Plants)

Comment: The STS Bases has been revised to address "the performance of required testing" versus the " performance of SRs," to be consistent with the TS. Submit a TSTF to revise the FTS. Suggest that the first instance this wording is to be revised to state, "the performr.. ;e of required testing including applicable SRs," since testing to restore equipment to an operable state will frequently include the performance of SRs.

FLOG RESPONSE: The ITS LCO 3.0.5 Bases were revised consistent with traveler TSTF-1 165. The latest status report from the TSTF industry database, dated July 27,1998, indicates that the NRC has approvcd TSTF-165. The FLOG continues to pursue the changes approved in TSTF-165.

ATTACHED PAGF.S:

None l

L l

1 1

i

l ADDITIONAL INFORMATION COVER SHEET l

ADDITIONAL INFORMATION NO: O 3.0-4 APPLICABILITY: DC, CP, WC, CA REQUEST:

ITS SR 3.0.2 Bases (All FLOG Plants) i Comment: Justify the revised STS SR 3.0.2 Bases. The STS provides an explanation for the inapplicability; the ITS does not.

FLOG RESPONSE: The ITS Si,3.0.2 Bases were revised based on Traveler TSTF-52.

Comment Number 3.6.1-6 for Section 3.6, " Containment Systems,"

concerned the revision of the submittal to conform to the 11/2/95 letter from C. Grimes (NRC) to D. Modeen (NEI) and TSTF-52 as modified by the NRC staff. In the FLOG response to Comment Number 3.6.1-6, it was identified that the ITS Bases were revised to incorporate proposed Revision 1 of TSTF-52. The FLOG response provided changes '.o the ITS SR 3.0.2 Bases based on incorporating proposed Revision 1 of TSTF-52.

ATTACHED PAGES:

None d

G 4 '

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.0-5 APPLICABILITY: DC, CP, WC, CA REQUEST:

ITS LCO 3.0.1 & 3.0.2 CTS 3.0.1 & 3.0.2 (A!! FLOG Plants)

DOC 1-01-A Comment: The markup of CTS 3.0.1 and 3.0.2 do not agree with the markup of STS LCO 3.0.1 and LCO 3.0.2. The markup of STS LCO 3.0.1 and 3.0.2 are correct. Revise the CTS markup.

FLOG RESPONSE: The FLOG has re-examined the CTS markups for LCO 3.0.1 and 3.0.2.

The ITS requirements are contained in the CTS markups but may not have been aligned with the same LCOs as in the ITS.

Comanche Peak and Diablo Canyon have modified their CTS markups for LCOs 3.0.1 and 3.0.2 to line up the requirements with their corresponding ITS LCOs. DOC 1-21-A has been drawn to describe the modification.

1 The CTS markups for Callaway and Wolf Creek are already lined up wi.h the ITS and no additional modifications are required.

ATTACHED PAGES:

None l

l l

ADDITIONAL INFORiaATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.0-6 APPLICABILITY: DC, CP, WC, CA REQUEST:

ITS LCO 3.0.4 CTS 3.0.4 (All FLOG Plants)

DOC 1-02-LS1 Cominent: The markup of CTS 3.0.4 does not agree with the markup of STS LCO i

3.0.4. The markup of STS LCO 3.0.4 is correct. Revise the CTS markup.

i FLOG RESPONSE: The FLOG has re-examined the CTS markups for LCO 3.0.4. The actual markup vary slightly although the Comanche Peak markup is essentially identical to the Diablo Canyon markup, and the Wolf Creek markup is essentially identical to the Callaway markups. All four markup were found to mean the same and all four markups were found to be consistent with the ITS. The markup is slightly different but the meaning is identical.

ATTACHED PAGES:

None t

I l

l l

l

i i

l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: TR 3.0-001 APPLICABILITY: DC, CP, WC, CA 1.

REQUEST:

Incorporate NRC-approved traveler TSTF-122 to eliminate confusion in the ITS LCO 3.0.2 Bases that discuss inoperability of redundant equipment.

ATTACHED PAGES:

Encl.5A Traveler Status page Encl. 5B B 3.0-2 1

l l

l l

l l

1 i

l-INDUSTRY TRAVELERS APPLICABLE TO SECTION 3.0 TRAVELER #

STATUS DIFFERENCE COMMENTS

(

k l

TSTF-06, Rev.1 Incorporated 3.0-01 Approved by the j

NRC.

TSTF-08, Rev. 2 Incorporated NA Approved by the NRC.

TSTF-12, Rev.1 Incorporated 3.0-02 Approved by the NRC.

TSTF-52 Incorporated NA (MN.1""

g,i, y TSTF-71 Not NA Will be addressed in Qv.2).

incorporated SFDP.

tun -ter. \\

/

co

=

TSTF-104 Incorporated 3.0-03 Approved by the NRC.

[o '

Cp 3.p.2] $"*O h

TSTF-122 NA M orporated-AQg%

5 h

e ce ed ucc..

e fte of a ve TSTF-136 Incorporated 3.0-02

[^P W]IM3 06l TSTF-165 Incorporated NA PP Wb A

  1. g*

D TSTF-166 Incorporated 3.0-04

[

P u

l S/15)97 j

3

___._._._____.___.__._._.y LCO Applicability B 3.0 BASES

~

LC0 3.0.2 ACTIONS.) The second type of Required Action specifies (continued) the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

The nature of some Required Actions of some Cond'tions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Conditions no 1onger exist. The individual LCO's ACTIONS specify the Required Actions where this is the case. An example of this is in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits."

The Completion Times of the Required Actions are also applicaDie when a system or component is removed from service intentionally.

The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surve111ances, preventive maintenance, corrective maintenance, or investigation of operational. problems. Entering ACTIONS for these reasons must be onA,i done in a manner that does not compromise safety. Intentional i

id. age entry into ACTIONS should not be made for operational convenience.KakecndtidMwould@ result in redundantDD"5 k_A' TID equipment being inowrabl%should be used instead. Doing so nuits tne time boti subsystems / trains of a safety function are

[lfsm-- -

result in LCO 3.0.3 being enter Individual Specifications inoperable and limits the time conditions exist which specify a time limit for performing an SR when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another Specification becomes applicable. In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new Specification becomes applicable, and the ACTIONS Condition (s) are entered.

(continued)

WCGS-Mark-up ofNUREG-1431-Bam 3.0 8 3.0 2 5/1SA7

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: TR 3.0-002 APPLICABILITY: DC, CP, WC, CA REQUEST:

Revise Traveler Status page to reflect NRC approval and latest revision number of travelers TSTF-71 Rev. 2, TSTF-136, TSTF-165, and TSTF-166. Deleted TSTF-103 from the Traveler Status pages as this traveler has been rejected by the NRC and accepted by the TSTF. There are no changes involved to any CTS mark-ups, ITS mark-ups, DOCS, or JFDs.

ATTACHED PAGE!i:

Encl. 5A Traveler Status page i

I

i, a

INDUSTRY TRAVELERS APPLICABLE TO SECTION 3.0 l

TRAVELER #

STATUS DIFFERENCE COMMENTS E

I TSTF-06, Rev.1 Incorporated 3.0-01 Approved by the NRC.

l TSTF-08, Rev. 2 Incorporated NA Approved by the i

NRC.

l TSTF-12, Rev.1 Incorporated 3.0-02 Approved by the NRC.

( M,s.t e w e v.s i

TSTF-52 Incorporated NA i

.c..y - c.

qw.6)

TSTF-71 Not NA Will be addressed in h.2).

incorporated SFDP.

tu.se -tea. l ff l

TSTF-104 i Iuorporated 3.0-03 Approved by the NRC.

h NA

[o' C,0 3p.Q ES#*ll TSTF-122 M orporated Ay4%

B hange acce ed I

TF,Anfte

/

]-

ucc..

y e

rave r cutoff at3,_)

-= _

TSTF-136 Incorporated 3.0-02 (W'nc.M W % tTW.3oei1 u

e l

TSTF-165 Incorporated NA PPM % %.

A

)

unc.

ggfaM h h)

APP TSTF-166 Incorporated 3.0-04

[

1 lI S/15/97

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.6.1-6 APPLICABILITY: DC, CP, WC. CA REQUEST:

DOC 2-05 LG DOC 2-06 A JFD 3.6-1 CTS 4.6.1.1.c (Wolf Creek)

CTS 4.6.1.1.d (Callaway)

CTS 3/4.6.1.2 (Diablo Canyon and Comanche Peak)

STS SR 3.6.1.1 ITS SR 3.6.1.1 and Associated Bases CTS 4.6.1.1.c/d and 3/4.6.1.2 require leak rate testing in accordance with the Containment Leakage Rate Testing Program which is based on the requirements of 10 CFR 50 Appendix J, Option B. STS SR 3.6.1.1 requires the visual examination and leakage rate testing be performed in accordance with 10 CFR 50 Appendix J as modified by approved exemptions. ITS SR 3.6.1.1 modifies STS SR 3.6.1.1 to conform to CTS 4.6.1.1.c/d and 3/4.6.1.2 as modified in the CTS markup. The STS is based on Appendix J, Option A while the CTS and ITS are based on Appendix J, Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr.

Christopher 1. Grimes to Mr. David J. Modeen, NEl, dated 11/2/95 and TSTF-52. While the ITS SR 3.6.1.1 differences from STS SR 3.6.1.1 are in conformance with the letter and TSTF 52 as modified by staff comments, the changes to the ITS Bases as well as ITS 3.6.2 and ITS 3.6.3 and their associated Bases are not in conformance. See Comment Number 3.6.3-28 for additional concerns with regards to CTS 4.6.1.2.c and 4.6.1.2.d at Comanche Peak. Also see Comment Numbers 3.6.0-2,3.6.2-5,3.6.3-27, 3.6.3.28 and 3.6.3-37.

Comment: Licensees should revise their submittals to conform to the 11/2/95 letter and TSTF-52 as modified by the staff. See Comment Numbers 3.6.0-2,3.6.2-5,3.6.3-27,

-3.6.3.28, and 3.6.3-37.

FLOG RESPONSE: Tiia 11/2/95 letter from C. Grimes (NRC) to D. Modeen (NEI), TSTF-52 proposed Revision 1 (which includes the changes proposed oy the staff) were reviewed for incorporation into the ITS. Based on this review, the ITS Bases have been revised to incorporate proposed Revision 1 of TSTF-52. Revision 1 addresses the NRC comments on Revision 0 of this TSTF but has not been approved by the Tech Spec Task Force. The FLOG will continue to evaluate any NRC/ industry approved revisions to TSTF-52 and will incorporate applicable changes into the ITS submittal as appropriate.

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ATTACHED PACES:, CTS 1.0 - ITS 1.0 Encl. 2 (CTS 1.0) 1-3 Encl. 3A (CTS 1.0) 2 Encl. 38 (CTS 1.0) 2 Encl. 5A (ITS 1.0)

Traveler Status page Encl. 5B (,ITS 1.P) 1.1-3 Encl. 6A (ITS 1.0) 3 Encl. 6B (ITS 1.0) 2, CTS 3.0 - ITS 3.0 Enci. 5A (ITS 3.0)

Traveler Status page Encl. 5B (ITS 3.0)

B 3.0-11, B 3.0-12 2, CTS 3/4.6 - ITS 3.6 Encl. 5A (ITS 3.6)

Traveler Status page Encl. 5B (ITS 3.6)

B 3.6-4, B 3.6-5, B 3.6-7 AMachment 18, CTS 6.0 - ITS 5.0 Encl. 5A(ITS 5.0)

Traveler Status page Encl. SB(ITS 5.0) 5.0-27, 5.0-28 i

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Attrchment 4 to ET 98-0071 Pcg31 of 1 LIST OF COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Michael J.

Angus, Manager Licensing and Corrective Action at Wolf Creek Generating Station, (316) 364-8831, extension 4077.

COMMITMENT Due Date/ Event 1

A supplement to Reference 3 (ET 97-0050) will be provided at a To be determined later date.

based on review of RAls.

The response to Comment Number 1.1-4 will be provided After evaluation of

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separately after the August 17,1998 NRC letter to NEl on TSTF-NRC letter.

111 have been fully evaluated.

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