ML20236Q671
| ML20236Q671 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/15/1998 |
| From: | Thomas K NRC (Affiliation Not Assigned) |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| TAC-M98803, NUDOCS 9807200401 | |
| Download: ML20236Q671 (8) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-__ _ _
. July 15, 1998-Mr,'Girry L. R:ndolph
'Vice Presid:nt cnd Chl:f Nuclear Officer
- Union Electric Company.
l~
. Post Office Box 620 L'
Fulton, Missourl. 65251-
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:
The Nuclear Regulatory Commission staff a 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 -
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 deterrained that additional information is needed in Section 5.0, Administrative Controls, as i
discussed ir the enclosure, Since you worked with three other utilities in preparing your L:
~ submittal, the enclosure contains the request for additional information (RAI) questions for all four utilities.L 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 -
l questions regarding the RAI, please contact me at (301) 415-1362.= if all four utilities would like l
7 to have a common discussion,"a single mseting, or phone call, it can be coordinated by 1
contacting the NRR Lead Project Manager, Tin;othy J. Polich at (301) 415-1038.-
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^
i Sincerely, l Signed By Origina l
l
) Kristine M. Thomas, Project Manager
/
Project Directorate IV-2 Division of Reactor Projects lil/lV
[
Office of Nuclear Reactoi Regulation b
( Docket No. 50-483 DISTRIBUTION-y Docket,
OGC g
Enclosure:
- Request for Additional )nformation PUBLIC ACRS PDIV-2 Reading PGwynn, RIV cc wiencl: See next page
.EAdensam (EGA1) WJohnson, RIV WBateman WBeckner f
Document Name: CALITS.RAI KThomas EPeyton JLuehman OFC PD4-2 PD4-2 TSB (pD6 NAME: Kbms EIyt WBeckner DATE-7 /l9/98 7 /H/ 98 7 /N98 OFFICIAL RECORC COPY
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Mr. Garry L. Randolph July 15, 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, Missourl 65077-1302 Licensing and Fuels Union. Electric Company Mr. J. V. Laux, Manager Post Office Box 66149
- 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
FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS SECTION 5.0 - ADMINISTRATIVE CONTROLS I
5.1 1 CTS 6.1.1, ITS 5.1.1, Change 0101-A and Difference 5.1-2 (Callaway)
Comment: Difference 5.1-2 states that the STS is revised to " maintain CTS." However, given that Change 01-01-A Insert 1 includes new language into the CTS it is unclear how the CTS is being maintained. This addition of new language into the CTS and deviation from the STS is notjustified. ProvideJustification.
FLOG Response:
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5.2-1 STS 5.2.2 b and Difference ?. 2 2 Comment: TSTF-121 has been withdrawn for modification, combination and resubmission.
l Use current ITS.
)
FLOG Response:
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D-1 ITS 5.3.1 (Wolf Creek, Callaway and Diablo Canyon)
. Comment: Part 55 of Title 10 of the Code of Federal Regulations was revised in March 1987 to establish upgraded requirements for licensed reactor operators. NRC Regulatory Guide (RG) 1.8, Revision 2, April 1987, describes methods acceptable to the staff for complying with the revised rule. The Statements of Consideration for the Part 55 rule change state that,"Those facility licensees that have made a commitment that is less than that required by the new rules must conform to the new rules automatically." The staff is concemed some facilities continue to have technical specifications that reference older industry standards that may not fully meet the revised requirements of 10 CFR Part 55.
The staff previously considered that the standards applied through the industry's accreditation process were equivalent to the guidance contained in RG 1.8, Revision 2. However, the staff ha& recently found that current INPO guidance in this area is very general; only advising licensees to follow regulatory requirements, in RG 1.8, Revision 2, the NRC staff endorses, with cor,ditiona, cerialn parts of industry standard ANSI /ANS-3.1 1981 as an acceptable approach for complying with the qualification and training requirements of 10 CFR Parts 50 and
- 55. This endorsement applies to the positions identified as shift supervisor, senior operator, licensed cperator, shit technical advis=, and radiation protection manager. For positions other than those identified, tne RG finds acceptable the approach provided in ANSI N18.1-1971.
For Callaway, the ITS proposes to adopt the CTS which adopts ANSI /ANS 3.1-1978 for the unit staff (besides SROs, ROs and STAS) and RG 1.8, September 1975 for the radiation protection manager. For Wolf Creek, the ITS proposes to adopt the CTS which adopts ANSI /ANS 3.1-1978 for the unit staff (besides SROs and ROs) and RG 1.8, September 1975 for the radiation
protection manager. For Diablo Canyon, the ITS propost to adopt the CTS which adopts ANSI /ANS 3.1-1978 for the unit staff (besides the radiation protection manager) though it does j
makes a reference to ROs and SROs having to meet the minimum qualifications of Part 55.
Please describe how your commitment to an ANSI standard other than that endorsed by NRC RG 1.8, Revision 2 currently meets the requirements of 10 CFR Part 55, as discussed in the Statements of Consideration for the rule change and would meet those requirements with the ITS as proposed.
FLOG Response:
5.5-1 Change 2-17 LSi (Callaway, Diablo Canyon)
Comment: WOG-85 has not yet become a TSTF. Use current ITS.
FLOG Response:
5.5-2 Difference 5.5-14 Comment: WOG-85 has not yet become a TSTF. Use current ITS.
FLOG Response:
5.5-3 ITS 5.5.4 b&g and Difference 5.5-1 Changes are based on a y' t unnumbered traveler. Use current ITS.
Comment:
e FLOG Response:
5.5 4 ITS 5.5.4 e er:d Difference,5.513 Comment: WOG-72 has not yet become a TSTF. Use current ITS.
FLOG Response:
5.5-5 ITS 5.5.12 c, CTS 6.8.5 a.3 and Difference 5.5-7 (Callaway)
Comment: The CTS Just refers to 10 CFR Part 20 Appendix B. More informaJon is needed to determine which table govems the current requirements.
I.
FLOG Response:
5.5-6 CTS 3.7.6 and Changes 10-15-LG and 10-17-A (Callaway)
Comment: Please provide a better explanation of the deletion of Pressurization System 2200 CFM +600,-200.
FLOG Response:
5.5 7 CTS 3.7.6 and Changes 10-15-LG and 10-17-A (Wolf Creek)
Comment: The CTS markup is inconsistent with the comments as nothing is lined out.
Further, the deletions (at least as they are reflected in ITS 5.5.11) need a better explanation.
Provide explanation.
J FLOG Response:
5.5-8 CTS 3.7.6 (3.7.5.1 and 3.7.6.1 - DCPP and 3.7.7.1 and 3.7.8 -CPSES) and Change 10-08-A '
Comment: it should be specifically noted as to which CTS requirements were carried over to the VFTP and which were deleted (as well as which section of what standard Justified the duplication deletions). Provide explanation and justification.
FLOG Response:
5.5 9 CTS 3.9.13 (3.9.12 - DCPP) and Change 12 04 A (Wolf Creek, Callaway and Diablo Canyon)
Comment: It appears that some of the CTS requirements covered by this change were deleted rather than transferred to ITS 5.5.11 as stated. Justify the individual deletions.
FLOG Response:
5.5-10 ITS 5.5.11.b (Callaway and Wolf Creek) l Comment: The smooth copy of the ITS still has the [] around the plant specific bypass value FLOG Response:
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5.5-11 ITS 5.5.9 d, ITS 5.5.11 b, and 5.5.13 (Diablo Canyon)
Comment: The smooth copy of the ITS contains a number of administrative errors. Page 5.0-19 of the smooth copy of the ITS has two errors. First, the VFTP section title and the (continued) appear before ITS 5.5.11.b when they should appear at the top of Page 5.0-20.
Second, in 5.5.11 b it should not be "10%at". To be consistent with the rest of the section, Page 5.0.15 should have SG Tube (continued) at the top of the page. Similarly, Page 5.0-23 should have a Diesel Fuel (continued) at the top of the page.
FLOG Response:
5.5-12 ITS 5.5.11 and CTS 4.7.6.c.2 (Wolf Creek)
Comment: The value of relative humidity is 70% in the ITS,78% in the CTS markup, and 70%
in the CTS. is it correct to assume the CTS markup value is wrong?
FLOG Response:
5.5-13 Difference 5.5-9 (Diablo Canyon)
Comment: Unlike Comanche Peak, the ITS/ CTS cross reference table does not include any reference to CTS 3/4.11. Therefore, the difference as written is not detailed enough. Either make the tie in the difference discussion or update the cross reference.
FLOG Response:
5.5-14 ITS 5.5.11.e and CTS 4.7.8.d.3 (Comanche Peak)
Comment: The value for the ESF filtration unit is 100 plus or minus 5 kW in the CTS and 100 plus 5 kW in the ITS Provide correction orjustify change.
FLOG Response:
5.6-1 ITS 5.6.5 a.7&8, Changes 03-14&15 M Comment: It is true that the additions would make the COLR more restrictive however, the removal of the specific values from the TS is a less restrictive change that needs to be justified.
Provide justification.
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1,
FLOG Response:
5.6 2 Difference 5.6-2 (Diablo Canyon)
Comment TSTF-37 has not yet been approved by the NRC. Use current ITS.
FLOG Response:
5.71 ITS 5.7.2 and Difference 5.7-2 Comment: TSTF-167 has been rejected by the NRC. Use current ITS.
FLOG Response:
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FLOG RAI APPLICABILITY TABLE FOR ITS SECTION 5.0 RAI Number Callaway Comanche Peak Diablo Canyon Wolf Creek 5.1-1 X
5.2-1 X
X X
X 5.3-1 X
X X
5.5-1 X
X 5.5-2 X
X X
X 5.5-3 X
X X
X 5.5-4 X
X X
X i
5.5-5 X
5.5-e x
5.5-7 X
5.5-8 X
X X
X 5.5-9 X
X X
5.5-10 X-X 5.5-11 X
5.5-12 X
5.5-13 X
5.5-14 X
5.6-1 X
X X
X 5.6-2 X
5.7-1 X
X X
X j
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