ML20236K812

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Requests Addl Info Based on Review of Selected Portions of Application.Addl Info Needed in Section 2.0,safety Limits & Section 3.0,limiting Condition for Operation Applicability Surveillance Requirement Applicability
ML20236K812
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/07/1998
From: Polich T
NRC (Affiliation Not Assigned)
To: Terry C
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
TAC-M98778, TAC-M98779, NUDOCS 9807100090
Download: ML20236K812 (9)


Text

- _ _ _ _

4

. Mr. C. Lance Terry July 7, 1998

- TU Electric LSenior Vice President & Principal Nuclear, Officer ATTN: Regulatory Affairs Department P.O. Box 1002 Glen Rose, Texas 76043

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED i

CONVERSION TO THE IMPROVED STANDARD TECHNICAL j

>~

SPECIFICATIONS FOR COMANCHE PEAK STEAM ELECTRIC STATION, i

(CPSES), UNITS 1 AND 2 (TAC NOS. M98778 AND M98779) l

Dear Mr. Terry:

The Nuclear Regulatory Commission staff is reviewing TU Electric's proposed license -

amendment to convert the current technical specifications for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, to the improved Standard Technical Specifications,

.TU Electric provided their proposed license amendment request by letter dated May 15,1997.

a The staff has reviewed selected portions of the application. Based on its review, the staff has 1

determined that additional information is needed in Section 2.0, Safety Limits and Section 3.0, Limiting Condition for Operation Applicability / Surveillance Requirement Applicability, as discussed in the enclosure. Since you worked with three other utilities in preparing your submittal, the enclosure,contains the request for additional information (RAI) questions for all

~ four utilities. However, you need only reply to the RAI questions associated with CPSES Units 1 and 2, as identified in the table within the enclosure.

To assist the staff in maintaining its review schedule, please respond t) the questions pertaining to CPSES Units 1 and 2 within 30 days of the date of this letter. If you have any questions regarding the RAl, please contact me at (301) 415-1038. If all four utilities would like to have a common discostilun, a single meeting, or phone call can be coordinated.

Sincerely,

-ORIGINAL SIGNED BY:

/

Timothy J. Polich, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/IV khf Office of Nuclear Reactor Regulation Docket Nos. 50-445 DISTRIBUTION:

and 50-446 Docket OGC PUBLIC ACRS

Enclosure:

Request for Additional PDIV-1 Reading PGwynn, RIV information EAdensam (EGA1)

CHawes JHannon WBeckner cc w/ encl: See next page TPolich JLuehman l

Cocument Name: CPITS.RAI l

1 OFC PD4-1 PD4-2 TSB rAb

([f h[

NAME TPolich F EP WBeckner DATE-7 / 6/98 7 ' / b/ 98 7 /7 / 98 OFFICIAL RECORD COPY-

-..G_S'9"lfl4f 9eo71ooo90 980707

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PDR ADOCK 05000445 P

PDR-J

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i UNITED STATES

j.

j NUCLEAR REGULATORY COMMISSION l

WASHINGTON, D.C. 20086 0001 i

e July 7, 1998 Mr. C. Lance Terry TU Electric Senior Vice President & Principal Nuclear Officer ATTN: Regulatory Affairs Department l

P.O. Box 1002 Glen Rose, Texas 76043

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR COMANCHE PEAK STEAM ELECTRIC STATION, (CPSES), UNITS 1 AND 2 (TAC NOS. M98778 AND M98779)

Dear Mr. Terry:

The Nuclear Regulatory Commission staff is reviewing TU Electric's proposed license amendment to convert the current technical specifications for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, to the improved Standard Technical Specifications.

TU Electric provided their proposed license amendment request by letter dated May 15,1997.

The staff has reviewed selected portions of the application. Based on its review, the staff has determined that additional information is needed in Section 2.0, Safety Limits and Section 3.0, Limiting Condition for Operation Applicability / Surveillance Requirement Applicability, as discussed in the enclosure. Since you worked with three other utilities in preparing your submittal, the enclosure contains the request for additional information (RAI) questions for all four utilities. However, you need only reply to the RAI questions associated with CPSES Units 1 and 2, as identified in the table within the enclosure.

To assist the staff in maintaining its review schedule, please respond to the questions pertaining to CPSES Units 1 and 2 within 30 days of the date of this letter. If you have any questions regarding the RAl, please contact me at (301) 415-1038. If all four utilities would like to have a common discussion, a single meeting, or phone call can be coordinated.

Sincerely, M

Timothy J. Poli h, Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446 l

Enclosure:

Request for Additional Information cc w/ encl: See next page i

Mr. C. Lance Terry TU Electric Company Comanche Peak, Units 1 and 2 cc:

Senior Resident inspector Honorable Dale McPherson U.S. Nuclear Regulatory Commission County Judge P. O. Box 2159 P. O. Box 651 Glen Rose, TX 76403-2159 Glen Rose, TX 76043 Regional Administrator, Reg!on IV Office of the Govemor U.S. Nuclear Regulatory Commission ATTN: John Howard, Director 611 Ryan Plaza Drive, Suite 400 Environmental and Natural Arlington, TX 76011 Resources Policy P. O. Box 12428

{

Mrs. Juanita Ellis, President Austin, TX 78711 Citizens Association for Sound Energy 1426 South Polk Arthur C. Tate, Director Dallas, TX 75224 Division of Compliance & Inspection Bureau of Radiation Control Mr. Roger D. Walker Texas Department of Health TU Electric 1100 West 49th Street Regulatory Affairs Manager Austin, TX 78756-3189 P. O. Box 1002 Glen Rose, TX 76043 Jim Calloway Public Utility Commission of Texas George L. Edgar, Esq.

Electric Industry Analysis Morgan, Lewis & Bocklus P. O. Box 13326 1800 M Street, N.W.

Austin, TX 78711-3326 Washington, DC 20036-5869 I

FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS i

l SECTION 2.0 - SAFETY LIMITS 2.0-1 NUREG-1431 Bases (markup)

B 2.1.1 Reactor Core SLs (Callaway [page B 2.0-1])

l Comment: The BACKGROUND uses the acronym DNBR. The licensee should include l

" departure from nucleate boiling ratio" first and then use the acronym DNBR.

FLOG Response:

2.0 2 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 in the B 2.1.1 markup of NUREG-1431. Provide Figure B 1.1.1-1, 1

FLOG Response:

l 2.0-3 NUREG-1431 Bases (markup) j 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 ;;mp ;t; l;;; cf cxtem;l l cad turbine trip without a direct reactor trip.' Cases with and without pressurizer spray an_d PORVs are ana_lyzed. Cur lng th; tren;;;nt, ne eentrol

tlen; ;;; ;;;umed, ex;;pt that th; Safety valves on the secondary plant side are assumed to open when the steam pressure reaches the ;;;;nderi plant safety valve settings, end-neminal Main feedwater supply is m;
nts n;d. lost at the time of. turbine trip.

Justify the revised STS Bases 2.1.2 changes.

- FLOG Response:

ENCLOSURE e-

f l

i 2.0 4 i

NURGE-1431 Bases (markup) l B 2.1.1 Reactor Core SLs (Diablo Canyon [page B 2.0-3])

l Comment: In the SAFETY LIMIT VIOLATIONS the licensee needs to correct," following SL violation responses are applicable to the reactor core Sh..."

FLOG Response:

2.0 5 NUREG-1431 Bases (markup)

B 2.1.1 Reactor Core SLs (Diablo Canyon (pages B 2.0-7, B 2.0-8, and B 2.0-9])

Comment: The header markup of Diablo Canyon B 2.1.1 Reactor Core SLs (pages B 2.0-7, B 2.0-8, and B 2.0-9) are incorrect. Corect the header for these pages to "RCS Pressure SL, B 2.1.2."

FLOG Response:

2.0-6 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 because of th; r;;; tor v;;;;;' h;;d ;lc:;ur; bolt:; er; not fu!!y tlr,htened 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 Technical Specifications (ITS). Justification must be provided for this change.

FLOG Response:

l:.

FLOG RAI APPLICABILITY TABLE FOR ITS SECTION 2.0

'RAI#

CALLAWAY COMANCHE DIABLO CANYON WOLF CREEK PEAK 2.0-1 X

j 2.0-2 X

X I

2.0-3 X

X X

X 2.0-4 X

2.0-5 x

2.0-6' X

i j

s

)

I I-l l

(-

l i

l L-

I FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS SECTION 3.0 - LIMITING CONDITIONS FOR OPERATION APPLICABILITY /

SURVEILLANCE REQUIREMENT APPLICABILITY l

3.0 1 ITS SR 3.0.3 CTS SR 4.0.3 (All Fl.OG Plants)

DOC 1-20-A l

l 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 l

CTS Markup, or revise ITS Markup and provide justification.

I FLOG Responsa:

3.0 2 ITS SR 3.4.13.2 / Administrative Controls Section 5.5.9 CTS 4.0.6.4a (Comanche Peak)

DOC 1-15-A Comment: The ITS revises the wording of CTS 4.0.6.4a.8. Is this also applicable to the other FLOG plants in which the location of this paragraph is CTS SR 3/4.4.5; is it generic?

FLOG Response-i 3.0-3 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 STS. Suggest that the first instance this wording is to be revised to state,"the performance of required testing including applicable SRs," since testing to restore equipment to an operable state will frequently include the performance of SRs.

FLOG Response:

\\

3.0-4 l

ITS SR 3.0.2 Bases (All FLOG Plants) l Comment: Justify the revised STS SR 3.0.2 Bases. The STS provides an explanation for the inapplicability; the ITS does not.

FLOG Response:

i s

l

f <

,3.0-5 ITS LCO 3.0.1 & 3.0.2 -

CTS 3.0.1 & 3.0.2 (All 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.

l FLOG Response:

3.0-6 ITS LCO 3.0.4 CTS 3.0.4 (All FLOG Plants)

DOC 1-02-LS1 Comment: The markup of CTS 3.0.4 does not agree with the markup of STS LCO 3.0.4. The markup of STS LCO 3.0.4 is correct. Revise the CTS markup.

FLOG Response:

3.0-7 ITS LCO 3.0.4 Bases (Diablo Canyon)

Comment: Tha redline / strikeout markup of the STS LCO 3.0.4 Bases is incorrect. Correct the markup of the STS LCO 3.0.4 Bases.

FLOG Response:

)

i-o

___...-_..__.__________________--_--____________w

FLOG RAI APPLICABILITY TABLE FOR ITS SECTION 3.0 RAI#

DIABLO COMANCHE WOLF CREEK CALLAWAY CANYON

."EAK 3.0-1 X

X X

X 3.0-2 X

3.0-3 X

X X

X 3.0-4 X

X X

X 3.0-5 X

X X

X 3.0-6 X

X X

X 3.0-7 X

i 1

.