ML20236P162
| ML20236P162 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/09/1998 |
| From: | Thomas K NRC (Affiliation Not Assigned) |
| To: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| TAC-M98738, NUDOCS 9807160182 | |
| Download: ML20236P162 (8) | |
Text
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' Mr. Otto L. Maynard July 9, 1998 Pr:sid:nt and Chief Ex::cutive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, Kansas 66839
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED l
CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR WOLF CREEK NUCLEAR GENERATING STATION, UNIT NO.1 (TAC NO. M98738) l
Dear Mr. Maynard:
The Nuclear Regulatory Commission staff is reviewing the Wolf Creek Nuclear Operating Corporation's proposed license amendment to convert the current technical specifications for Wolf Creek Nuclear Generating Station, Unit No.1 to the improved Standard Technical Specifications. Wolf Creek Nuclear Operating Corporation provided their proposed license amendment request by letter dated May 15,1997.
I The staff has reviewed selected portions of the application. Based on its review, the staff has determined that additional information is needed in Section 1.0, Use and Application, as discussed in the enclosure. Since you worked with three other utilities in preparing your submittal, the enclosure contains the request for additional information (RAl) questions for all
. Tour utilities. However, you need only reply to the RAI questions associated with the Wolf Creek Nuclear Generating Station, Unit No.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 Wolf Creek Nuclear Generating Station, Unit No.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 f
meeting, or phone call, it can be coordinated by contacting the NRR Lead Project Manager, I
Timothy J. Polich at (301) 415-1038.
Sincerely, Original Signed By Kristine M. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket No. 50-482 DISTRIBUTION:
Docket OGC j
Enclosure:
Request for Additional Information PUBLIC ACRS j
PDIV-2 Reading PGwynn, RIV i
EAdensam (EGA1)
WJohnson, RIV l
cc w/ encl: See next page WBateman WBeckner KThomas EPepon 0!
Document Name: WCITS.RAI JLuehman T)\\
OFC PD4-2 PD4-2 TSB wb6 NAME Kdomas EPe WBeckner DATE 7 /9 /98 7 /Cf / 98 7 / 9 /98 OFFICIAL RECORD COPY
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PDR ADOCK 05000482 P
Mr. Otto L. Maynard July 9, 1998 cc w/ encl:
Jay Silberg, Esq.
Chief Operating Officer Shaw, Pittman, Potts & Trowbridge Wolf Creek Nuclear Operating Corporation 2300 N Street, NW P. O. Box 411 Washington, D.C. 20037 Burlington, Kansas 66839 Regional Administrator, Region IV Supervisor Licensing U.S. Nuclear Regulatory Commission Wolf Creek Nuclear Operating Corporation 611 Ryan Plaza Drive, Suite 1000 P.O. Box 411 Arlington, Texas 76011 Burlington, Kansas 66839 Senior Resident inspector.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Resident inspectors Office
- P. O, Box 311 8201 NRC Road Burlington, Kansas 66839 Steedman, Missouri 65077-1032 Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road i
Topeka, Kansas 66604-4027 Office of the Govemor State of Kansas
. Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W.10th 2nd Floor Topeka, Kansas 66612 County Clerk Coffey County Courthouse Burlington, Kansas 66839 Vick L. Cooper, Chief I
Radiation Control Program Kansas Department of Health l
and Environment Bureau of Air and Radiation Forbes Field Building 283 Topeka, Kansas 66620 i
)
l L'
FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS SECTION 1.0 - USE AND APPLICATION 1.1 Definitions 1.1-1 CTS 1.3, Analog Channel Operations Test CTS 1.3, Channel Operational Test [Diablo Canyon)
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)
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 tima 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 revieNed on a plant-specific basis. In addition, correct the Diablo Canyon ITS markup for COT.
FLOG Response:
1.1-2 CTS 1.3, Analog Channel Operations Test CTS 1.5, Channel Calibration 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 1-32-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 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.
1
. 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.
FLOG Response:
1.1-3 CTS 1.9, Core Alteration DOC 1-06-LS
)
The DOC does not provide adequate technical justification to support this change.
1 Comment: The associated NSHC for this change appears to provide the necessary i
justification. Revise the DOC by incorporating the information contained in the associated j
NSHC.
FLOG Response:
1 1.1-4 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:
t
. l 1.1 -5 DOC 1-17-A ITS 1.1, Pressure and Temperature Limits Report (PTLR)
JFD 1.1-6 l
The definition of Pressure and Temperature Limits Report (PTLR)is added to be consistent I
f with STS. While this is acceptable, the changes to both CTS and ITS to include the maximum I
allowable PORV lift settings, arming temperature associated with the cold overpressure mitigation system (COMS) [for Callaway only), and arming temperature associated with low l
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 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:
1.1-6 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]
CTS 1.41, Ventilation Exhaust Treatment System [Diablo Canyon]
l CTS 1.42, Venting [Diablo Canyon) i DOC 1-15-A 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.
l FLOG Response:
lJ L_____-.----__---
. 1.1-7 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.
Comment: Clarify this deviation and, if appropriate, revise the CTS markup with the correct DOC for the particular plant.
FLOG Response:
1.1-8 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 (OPTR)
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 marl <up to reflect associated DOC and ITS.
FLOG Response:
1,1-9 CTS Table 1.2, Ope'ational Modes, added footnotes (b) and (c)
DOC 1-25-LS ITS Table 1.1-1, Modes, footnotes (b) and (c)
JFD 1.1-8 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 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.
FLOG Response:
. 1.4 Frequency 1.4 's 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 proposed to be included in ITS. The DOC and the JFDs state that these ITS changes are to incorporate travelers WOG-74 and WOG-90.
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:
1.0 RAI APPLICABILITY RAINO.
DIABLO COMANCHE WOLF CREEK CALLAWAY i
CANYON PEAK 1.1-1 X
X X
X 1.1-2 X
X X
X 1.1-3 X
X X
1.1-4.
x x
x x
I 1.1-5 X
X X
X i
1.1-6 X
X X
X 1.1-7 X
X X
1.1-8 X
X X
1.1-9 X
X X
X 1.4-1 X
X X
X l
l l
l
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