ML20236R302

Forwards Request for Addl Info Re Proposed Conversion to Improved Std TS for Plant,Units 1 & 2

ML20236R302
Person / Time
Site:	Comanche Peak
Issue date:	07/14/1998
From:	Polich T NRC (Affiliation Not Assigned)
To:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
TAC-M98778, TAC-M98779, NUDOCS 9807210354
Download: ML20236R302 (9)

Text

_ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - - - - - - __ . -- . .

Mr. C. Lance Terry July 14, 1998

, TU Electric Senior 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 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 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 (RAI) questions for all four utilities,. However, you need only reply to the RAI questions associated with Callaway Plant, Unit f as identified in the table within the enclosure.

To assist the siaff in maintaining its review schedule, please respond to the questions pertaining to CPSES Units 1 and 2 within 30 days vf 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, ORIGINAL SIGNED BY:

Timothy J. Polich, Project Manager 7

Project Directorate IV-1 Division of Reactor Projects lil/IV ,/

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 Document Name: CPITS.RA!

OFC PD4-1 PD4-2 TSB WD6 NAME TPolich WBeckner

'JATE 7/ 9 /98 7 /Cf / 98 7 /9 /98

'JFFICIAL RECORD COPY ql th ,3 gg - - -

y p' fi if 9807210354 980714 hG 2 4 ~ ~ * ~

PDR ADOCK 05000445 p PDR

p f."%,\

• UNITED STATES

.: NUCLEAR REGULATORY COMMISSION k wAsmwoton, o.c. sose.ani

+.,***** July 14, 1998 Mr. C. Lance Terry TU Electric Senior 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 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 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 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 inve any questions regarding the RAI, please contact me at (301) 415-1038. If allfourutilitieswouldlike to have a common discussion, a single meeting, or phone call can be coordinated.

Sincerely, Timothy J. P ich, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/lV l Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

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

1 J

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 215g P. O. Box 851 Glen Rose, TX 76403-215g Glen Rose,TX 76043

)

Regional Administrator, Region 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 l Citizens Association for Sound Energy 1426 South Polk Arthur C. Tate, Director Dallas, TX 75224 Division of Compliance & Inspection i Bureau of Radiation Control l 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 i George L. Edgar, Esq. Electric industry Analysis Morgan, Lewis & Bockius P. O. Box 13326 i

1800 M Street, N.W. Austin, TX 78711-3326 Washington, DC 20036-5869 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 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. j FLOG Response:

1.1-2 CTS 1.3, Analog Channel Operations Test CTS 1.5, Channel Calibration ]I 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 [Ciablo Canyon)

I DOC 1-32-A ITS 1.1, Channel Calibration i ITS 1.1, Channel Operational Test (COT) l ITS 1.1, Trip Actuating Device Operational Test (TADOT)

JFD 1.1-1

{

i.

l l

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.

l l

1 l l i

Comment: If NRC has not approved TSTF-64 by the time the draft safety evaluation is prepared, then thase 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 technicaljustification to support this change.

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:

1.1-4 CTS 1.13, Engineered Safety Features Response Time [Diablo Canyon, Wolf Creek, and Callaway)

CTS 1.14 Engineered Safety Features Response Time [ Comanche Peak) i 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:

___---_------_--_a

1.1 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 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.

FLOG Response:

i

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 l 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 (QPTR)

The DOC states that the portion of the QPTR 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 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 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 1,4-1 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 proposec' 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:

l I,

i.

I l

f l

• l i

1.0 RAI APPLICABILITY RAI NO. DIABLO COMANCHE WOLF CREEK CALLAWAY l 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 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

t l

t

)

1 i

_ - _ _ _ _ _ _ _ _ _ _ . . _ _ _