ML20236P309
| ML20236P309 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/09/1998 |
| From: | Thomas K NRC (Affiliation Not Assigned) |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| TAC-M98803, NUDOCS 9807160245 | |
| Download: ML20236P309 (8) | |
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Mr. Garry L. Randolph July 9, 1998 Vice Presid:nt cnd Chi;f Nucl:ar Officer l
Union Electric Company l
Post Office Box 620 Fulton, Missouri 65251 l
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR CALLAWAY PLANT, UNIT 1 (TAC NO. M98803)
Dear Mr. Randolph:
1 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 Technical Specifications. Union Electric Company provided their i
proposed license amendment request by letter dated May 15,1997.
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The staff has reviewed selected portions of the application. Based or)lts review, the staff has l
determined that additional information is needed in Section 1.0, Use and Application. as l
discussed in the enclosure. Since you worked with three other utilities in preparing your l
submittal, the enclosure contains the request for additional information (RAl) questions for all i
four utilities. 'However, you need only reply to the RAI questions associated with Callaway I
Plant, Unit f 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 I
questions regarding the RAI, please contact me at (301) 415-1362. If all four utilities would like i
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, 1
Original Signed By Kristine M. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50-483 DISTRIBUTION:
Docket OGC l
Enclosure:
Request for Additional Information PUBLIC ACRS l
PDIV-2 Reading PGwynn, RIV i
cc w/ encl: See next page EAdensam (EGA1) WJohnson, RIV WBateman WBeckner Document Name: CALITS.RAI KThomas EPeyton JLuehman OFC h)D4-2 PD4-2 TSB wt4 1
AMN WBeckner NAME KT as DATE 7 / 3 / 98 7 / Q / 98 7 /i98 p' b\\
OFFICIAL RECORD COPY pm + e kcb.a L a
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9807160245 980709 PDR ADOCK 05000483 L
P PDR L _ __. _ _.
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Mr. Garry L. Randolph July 9, 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 John O'Neill, Esq.
Shaw, Pittman, Potts & Trowbridge Mr. Dan 1. Bolef, President 2300 N. Street, N.W.
Kay Drey, Representative Washington, D.C. 20037 Board of Directors Coalition for the Environment Mr. H. D. Bono 6267 Delmar Boulevard Supervising Engineer University City, Missouri 63130 Quality Assurance Regulatory Support Union Electric Company Mr. Lee Fritz Post Office Box 620 Presiding Commissioner Fulton, Missouri 65251 Callaway County Court House 10 East Fifth Street U.S. Nuclear Regulatory Commission Fulton, Missouri 65151 Resident inspector Office 8201 NRC Road Mr. Alan C. Passwater, Manager Steedman, Missouri 65077-1302 Licensing and Fuels Union Electric Company Mr. J. V. Laux, Manager Post Office Box 66149 l
Quality Assurance St. Louis, Missouri 63166-6149 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 1.0 - USE AND APPLICATION 1.1 Definitions l
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 Dcvice 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 (DDOT)
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 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 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 l
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.
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.. Comment: If NRC has not approved TSTF-64 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.
l FLOG Response:
i 1.1-3 CTS 1.9, Core Alteration DOC 1-06-LS l.
l The DOC does not provide adequate technicaljustification to support this change.
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Comment: The associated NSHC for this change appears to provide the necessary justification. Revise the DOC by incorporating the information contained in the associated
'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:
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i l 1.1-5 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 lift 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 I
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]
CTS 1.42 Venting [Diablo Canyon]
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.
j FLOG Response:
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. 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 en 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:
1.1-9 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 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 i
scope of the conversion review.
j 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 Rosponse:
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1.4 Frequency 1.4-1 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.
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:
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DIABLO COMANCHE WOLF CREEK CALLAWAY CANYON PEAK l
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
1.1-5 X
X X
X 1.1-6 X
X X
X 1.1 X X
X 1.1-8 X
X X
1.1-9 X
X X
X i
1,4-1 X
X X
X I
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