ML20236K821

Requests Addl Info on Proposed Conversion to Improved Std Tss.Response Requested within 30 Days of Date of Ltr

ML20236K821
Person / Time
Site:	Callaway
Issue date:	07/07/1998
From:	Thomas K NRC (Affiliation Not Assigned)
To:	Randolph G UNION ELECTRIC CO.
References
TAC-M98803, NUDOCS 9807100095
Download: ML20236K821 (8)

Text

July-7, 1998

- Mr, Girry L. R ndolph 4

Vica Pr:sidsnt end Chi:f Nucl:ar Offic:r b

Union Electric Company Post Office Box 620

~ Fulton, Missouri 65251

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED L,

CONVERSION TO THE IMPROVED STANDARD TECHNICAL

' SPECIFICATIONS FOR CALLAWAY PLANT, UNIT 1 (TAC NO. M98803)

Dear Mr. Randolph:

~

l The Nuclear Regulatory Commission staff is reviewing Union Electric Company's proposed.

license amendment to convert the current technical specifications for Callaway Plant, Unit 1 to the improved Standard T.echnical Specifications. Union Electric Company 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 Secuon 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 Callaway Plant, Unit 1 as identified in the table within the enclosure.

To assist the staff in maintaining its review schedule, please respond to the questions pertaining to Callaway Plant, Unit 1 within 30 days of the date of this letter, if you have any questions regarding the RAI, please contact me at_(301) 415-1362. If all four utilities would like to have a common discussion, a single meeting, or phone call, it can be coordinated by contacting the NRR Lead Project Manager, Timothy J. Polich at (301) 415-1038.

Sincerely,.

f Original. Signed By

'l Kristine M. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects Ill/IV h/

Office of Nuclear Reactor Regulation Docket No. 50-483 DISTRIBUTION:

' Docket -

OGC

Enclosure:

' Request for Additional Information PUBLIC ACRS PDIV-2 Reading PGwynn, RIV

= cc w/ encl: See next page EAdensam (EGA1)

WJohnson, RIV WBateman WBeckner Document Name: CALITS.RAI KThomas EPeyton JLuehman.

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NAME' 'KIh$as E'PeyFoF wBeckner DATE 7 / 7/98-7 / lo/ 98 7 /'[/98 OFFICIAL RECORD COPY L;

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Mr. Garry L. Randolph July 7, 1998 cc w/ encl:

Professional Nuclear Mr. Otto L. Maynard Consulting, Inc.

President and Chief Executive Officer 19041 Raines Drive Wolf Creek Nuclear Operating Corporation Derwood, Maryland 20855 Post Office Box 411 Burlington, Kansas 66839 Gerald Chamoff, Esq.

Thomas A. Baxter, Esq.

Mr. Dan 1. Bolef, President Shaw, Pittman, Potts & Trowbridge Kay Drey, Representative 2300 N. Street, N.W.

Board of Directors Coalition Washington, D.C. 20037 for the Environment 6267 Delmar Boulevard Mr. H. D. Bono University City, Missouri 63130 Supervising Engineer Quality Assurance Regulatory Support Mr. Lee Fritz Union Electric Company Presiding Commissioner Post Office Box 620 Callaway County Court House Fulton, Missouri 65251 10 East Fifth Street Fulton, Missouri 65151 U.S. Nuclear Regulatory Commission Resident inspector Office Mr. Alan C. Passwater, Manager 8201 NRC Road Licensing and Fuels Steedman, Missouri 65077-1302 Union Electric Company Post Office Box 66149 Mr. J. V. Laux, Manager St. Louis, Missouri 63166-6149 Quality Assurance Union Electric Company Post Office Box 620 Fulton, Missouri 65251 Manager-Electric Department Missouri Public Service Commission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102

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FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS 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])

i Comment: The BACKGROUND uses the acronym DNBR. The li::ensee should include

" 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 2.0-3j; 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.

FLOG Response:

2.0-3 i

~ 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 i

transient that establishes the required relief capacity, and hence valve size requirements and lift settings, is a ;;.T.p';;; enefedemeHead Jurbine trip without a direct reactor trip. Cases with and without pressurizer spray and POR_Vs are analyzed. C;-ln;; tre tram:st, n; ;;.. tid

n ;;; en;-.;d, ;;;pt it.;; tra Safety valves on the secondary plant side are assumed to open when the steam pressure reaches the seeendertplant safety valve settings, end cominel Main feedwater supply is mentained-5st at the time of turbine trip.

Justify the revised STS Bases 2.1.2 changes.

FLOG Response:

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~ 2.0 4 NURGE-1431 Bases (markup)

B 2.1.1 Reactor Core SLs (Diablo Canyon [page B 2.0-d])

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

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;;;ter ;;;;; h;;d ;l;;ur; bslt; er; not 'u:ly liihten;d 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 l

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FLOG RAI APPLICABILITY TABLE FOR ITS SECTION 2.0 RAI#

CALLAWAY COMANCHE DIABLO CANYON WOLF CREEK PEAK 2.0-1 X

2.0-2 X

X 2.0-3 X

X X

X 2.0-4 X

2.0-5 X

j 2.0-6 X

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FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENT 8 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 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:

3.0 2 ITS SR 3.4.13.2 / Administrative Controls Section 5.5.9 I

CTS 4.0.6.4a (Comanche Peak)

DOC 1-15-A i

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:

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 ITS SR 3.0.2 Bases (All FLOG Plants)

Comment: Justify the revised STS SR 3.0.2 Bases. The STS provides an explanation for the inapplicability; the ITS does not.

FLOG Response:

K 3.0 5 ITS LCO 3.0.1 & 3.0.2 CTS 3.0.1 & 3.0.2 (All FLOG Plants) l 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:

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: The 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:

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a FLOG RAI APPLICABILITY TABLE FOR ITS SECTION 3.0 RAI #

DIABLO COMANCHE WOLF CREEK CALLAWAY CANYON PEAK 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

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