ML20236S220

Forwards RAI Re Util Proposed License Amend to Convert Current TSs for Plant,Unit 1 to Improved Tss.Response Requested within 30 Days of Receipt of Ltr

ML20236S220
Person / Time
Site:	Callaway
Issue date:	07/21/1998
From:	Thomas K NRC (Affiliation Not Assigned)
To:	Randolph G UNION ELECTRIC CO.
References
TAC-M98803, NUDOCS 9807240207
Download: ML20236S220 (16)

Text

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

Mr. G:ny L. Randolph July 21, 1998

' Vice President end Chtf Nucle r Officer Union Electric Company Post Office Box 620 Fulton, Missouri 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 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 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 3.4, Reactor Coolant System, 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 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, Origina l Signed By Kristine M. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects lil/IV j

Office of Nuclear Reactor Regulation (

Docket No. 50-483 DISTRIBUTION:

Enclosure:

Request for Additional Information Docket PUBLIC OGC ACRS hf PDIV-2 Reading PGwynn, RIV cc w/ encl: See next page EAdensam (EGA1) WJohnson, RIV WBateman WBeckner KThomas EPeyton

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Mr. Garry L. Randolph July 21, 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 l Fulton, Missouri 65251 Callaway County Court House 10 East Fifth Street

! U.S. Nuclear Regulatory Commission Fulton, Missouri 65151 i

Resident inspector Office 8201 NRC Road Mr. Alan C. Passwater, Manager Steedman, Missouri 65077-1302 Licensing and Fuels I

Union Electric Company Mr. J. V. Laux, Manager Post Office Box 66149 ,

Quality Assurance St. Louis, Missouri 63166-6149 l

Union Electric Company Post Office Box 620 Fulton, Missouri 65251

! Manager- Electric Department l ' Missouri Public Service Commission L 301 W. High l- Post Office Box 360 Jefferson City, Missouri 65102 i Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & PM! ion 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 i

FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS SECTION 3.4 - REACTOR COOLANT SYSTEM (By ITS Section) 3.4.1 1 Difference 3.4 38 Comment: TSTF-105 has been rejected by the NRC.

FLOG Response: ,

3.4.12 Difference 3.4 40 Comment: WOG-99 has not yet become a TSTF.

FLOG Response:

3.4.1-3 ITS 3.4.1 Bases Applicable Safety AnaldA IDiablo Canyon)

Comment: it is stated that the DNBR correlation limit of greater than or equal to 1.17 is the

" acceptance limit for RCS DNB parameters." While that may be the post-transient limit, as  !

discussed in the CTS Bases, a DNBR of greater than or equal to 1.3 is the assumed normal limit. Is the minimum DNBR of 1.3 what is being restored when the Bases for ITS Required

- Action A.1 discusses restoring DNB margin or is the margin being restored only enough to ensure the post-transient limit of 1.17 is not violated?

FLOG Response:

1 3.4.2-1 Difference 3.4-33 Comment: TSTF 27 Rev. 3 is still pending NRC approval.

4 FLOG Response:

l 3.4.3-1 ITS 3.4.3 Bases References l Comment: WCAP-14040-NP-A, Rev. 2 January 1996, has replaced WCAP-7924-A, April 1975.  !

I Please summarize the differences / applicability to the FLOG.

FLOG Response: i l

3.4.4-1 ITS 3.4.4 Bases i Comment The Bases refer to the DNBR limit in the safety limits. Where is it? (this appears to be a problem with the STS, as well as these conversions).

FLOG Response:

~

'3.4.5 1 Change 1 14 LS 22. (Callaway and Wolf Creek)

Comment: The change discussion is not adequate. The NSHC contains the necessary l Justification.

FLOG Response:

3.4.5-2 ITS SR 3.4.5.2 (also SR 3.4.6.2 and SR 3.4.7.2) (Callaway)

Change 1-15M Comment: The sections of the ITS use the phrase "or equivalent" yet the term is not explained in the change or in the ITS Bases. According to the information provided narrow range level is used at the higher temperatures (Modes 3 and 4) and wide range level is used at the lower  :

temperatures (Mode 5), if "or equivalent" means using the wide range at higher temperatures and the narrow range at lower temperatures are the levels specified appticable at the different temperatures? If not, what are the equivalent levels to the values specified in the iTS and how were they determined?

l FLOG Response:

l 3.4.5 3 CTS 4.4.1.2.2,4.4.1.3.2 and 3.4.1.4.1.b and ITS 3.4.5,6 and 7 (Callaway and Wolf Creek)

Comment: Ten percent gjda range level was specified as the necessary heat sink level. Now in the ITS the level is dam 2g range. Was this is a known error in the TS that is now being corrected or was this just discovered as part of the conversion effort? Please provide the technical basis for concluding that 10% (4% for Callaway) narrow range is adequate.

l Additionally explain why different narrow range level values are used at each plant and why I wide range level is used in Mode 5 at one and not the other.

FLOG Response:

3.4.5.4 ITS SR 3.4.5.2 (Comanche Peak)

Comment: 11 should read "SR" rather than "Sr".

l.  !

FLOG Response:

i l 3.4.6-1 Difference 3.4 02 1

Comment: The difference states that the STS doesn't cover all possible configurations and the I language of the STS is potentially confusing. Please explain the basis for these comments.

l FLOG Response:

3.4.6 2 Change 1-17-LG, ITS 3.4.6,ITS 3.4.7,3.4.10 and 3.4.12 (Diablo Canyon)

Comment: WOG-67 Rev.1 has not yet become a TSTF. Additionally, the proposed wording is l Imprecise and confusing. If LTOP is required At or less than 275 degrees F it is inconsistent to l then say "the ternperature below which LTOP is required" because LTOP is required at that l temperature as well as belowit.

1 FLOG Response:

l

! 3.4.7-1 ITS 3.4.7.2 (Wolf Creek)

Comment: It should read " required SGs" rather than " required Sgs".

FLOG Response:

l 3.4.7 2 ITS LCO Bases 3.4.7 and 3.4.8 (Wolf Creek)

Comment: The TS condition " Loops Not Filled" should be defined in the TS Bases subject to l the Bases Control Program and not in an unnamed plant procedure for which the control mechanism is not specified.

l- FLOG Response:

l l

3.4.7-3 ITS Bases 3.4.7 Background (Callaway)

Comment: The last paragraph on smooth Bases Page B 3.4-32 incorrectly states "... above 7%." This error does not appear in the highlight / strikeout version of the Bases.

FLOG Response:

1

3.4.8 1 Difference 3.4 48 Comment. It is unclear why TS 3.0.4 would not apply. If this change is to be considered it ,

should be done on a generic basis. '

FLOG Response:

3.4.8-2 Change 01-20 LS-27, ITS 3.4.8 (Diablo Canyon)

Comment: The justification in the change is inadequate. The NSHC contains appropriate justification.

FLOG Response:

l 3.4.9-1 ITS 3.4.9 Comment: Does 92% (90% for Diablo Canyon) in the pressurizer ensure that upon an inadvertent Si that the pressurizer will not overfill before the operator is assumed to take l action? Other plants have lowered this limit (Robinson) or qualified the PORVs for water (Millstone 3). j

. FLOG Resppnse: l 3.4.9 2 ITS LCO 3.4.9.b (Callaway)

Comment: The ITS should read "..150 Ew."

FLOG Responset: ,

1 l 3.4.9 3 Difference 3.4.17 (Wolf Creek, Diablo Canyon and Comanche Peak)

Comment: TSTF-93 Rev. 3 was approved with a reviewer's note which says that for non-dedicated safety-related heaters which normally operate the frequency is 18 months and for l dedicatJd safety-related heaters which normally don't operate the frequency is 92 days. Each )

! of the plants is asking for the 18 month frequency but it is unclear from the submittais if they l meet the criterion. Please provide information demonstrating consistency with the TSTF.

FLOG Response: ,

1 I

l 3.4.9 4 CTS 4.4.3.3 and ITS 3.4.9.3 (Diablo Canyon)

Comment: There is no justification for this less restrictive change (the CTS require the heaters be energized and the ITS which require the heaters be verified as being capable).

FLOG Response:

f 3.4.10-1 ITS 3.4.10 Bases Applicable Safety Analyses l Comment: What justifies the differences between the ITS Bases and the STS Bases and between the plant Bases (especially Callaway and Wolf Creek) of the lists of possible over pressurization events?

FLOG Response:

3.4.11-1 Change 4 04 LG Comment : The requirement is in the CTS and the STS. The justification for not putting it in the i ITS is that automatic actuation to open is not required. However, proper calibration also l ensures that the PORV does not prematurely open creating as stated in the Bases "in effect a l small break LOCA."

l l FLOG Response:

3.4.11-2 Change 4-08 LS 34 and Difference 3.445 i Comment: 'WOG-60 has not yet become a TSTF.

l FLOG Response:  ;

3.4.11-3 Change 4-05 LS 31 and Difference 3.4-39 Comment: TSTF-113 (presently Rev. 4) has not yet been approved by the NRC staff.

FLOG Response:

3.4.11-4 Change 4-09 LS-36, Difference 3.4 47, Change 3-04 and Difference 3.4-31 Comment: WOG-87 has not yet become a TSTF.

t t l

1 l

l l

FLOG Response: j i

3.4.11-5 ITS Bases 3.4.11 Background (Wolf Creek) i l Comment: On the top of smooth Bases Page 3.4-55 the sentence beginning "The functional

! design..." should not end with "... Pressurizer." It should include the phrase that comprises the I~ next paragraph.

I FLOG Response:

3.4.116 Difference 3.4 49 (Wolf Creek, Comanche Peak and Callaway) j r

Comment: This difference does not address the addition of the "immediately" in Required ,

Actions D.1, E.1, and G.1 of ITS 3.4.11 l FLOG Response:

l i 3.4.12-1 Difference 3.4 49

Comment

WOG-100 has not yet become a TSTF.

l FLOG Response:

l 3.4.12-2 Differences 3.4-23 and 3.4-45 Comment: WOG-51 Rev.1 has not yet become a TSTF. ,

L FLOG Response: . ,

l l

l- 3.4.12-3 Difference 3.4 09 ,

4 Comment: The difference does not adequately justify not adopting STS SR 3.4.12.7. The SR is intended to apply to valves besides manuel valves. Performing SR 3.4.12.4 does not verify the same status as that verified by SR 3.4.12.7.  ;

FLOG Response:

L 1

I-I 7

~

3.4.12 4 ITS Bases 3.4.12 Applicability (Comanche Peak, Wolf Creek, and Callaway)

, Comment: The intent of the addition to the end of the first paragraph of the Applicability Bases j is unclear. The LCO applies if the head is on. The added discussion essentially states LTOP l

(COMS) protection is not needed with the head on and the bolts fully detensioned. If that is the argument then rather than adding it to the Bases discussion, the case should be made for modifying the LCO Applicability.

FLOG Response

3.4.12-5 Differences 3.4-16 and 3.4-45 (Wolf Creek and Callaway)

Comment: The justification for the 4-hour pump swap is inadequate. The STS allows 15 minutes. The CTS is used as justification however, finding a pump inoperable and then restoring it (which is the case covered by the CTS) is very different than simply switching from l one operable pump to another.

FLOG Response:

I 3.4.12 6 ITS Bases Pages B 3.4-56,59,60,62 and 63 (Diablo Canyon)

Comment: These pages in the smooth copy of the Bases contain formatting errors which have created gaps in the text.

i FLOG Response: )

3.4.12-7 ITS 3.4.12 Required Action D.1 (Comanche Peak)

Comment: Is there an approved analysis that demonstrates that this new action is sufficient l protection from an accumulator discharge?

FLOG Response:

i-l 3.4.12-6 ITS 3.4.12 Required Action D.2 (Comanche Peak) l l

Comment: What RCS temperature has to be greater than 350 degrees F? Tave (enter Mode 3)? One or more cold leg temperature (s)? j FLOG Response:

i f

l l _- - _ _ . _- _ _ _ _ _ _ . _ - _ _ _ _ - - _ _ _ _ _ - _ - _ _ _ _ -

3.4.13 1 Change 6-25 LS 26 (Diablo Canyon and Wolf Creek)

Comment: The change discussion is not adequate. The t:SHC contains the necessary justification.

FLOG Response:

3.4.13-2 Change 6-26 LS 30 and Difference 3.4-36 (Diablo Canyon, Callaway and Wolf Creek)

Comment: TSTF-116 has not yet been approved by the NRC.

FLOG Response:

3.4.13 3 ITS 3.4.13 Bases LCO c. (Wolf Creek, Callaway, and Comanche Peak)

Comment: How is the addition of what does not constitute identified leakage consistent with the definition in ITS Section 1.17 FLOG Response:

3.4.13-4 ITS 3.4.13 Bases SR 3.4.13.1 (Comanche Peak and Diablo Canyon)

Comment: The Bases for SR 3.4.13.1 define steady state as Tavg changing by less than 5 degrees F/hr (Comanche Peak) and Tavg changing by less than 5 degrees /hr and stable RCS pressure etc. (Diablo Canyon). The text for Diablo Canyon then goes on to define steady state as changing less than 5 degrees /hr and for Comanche Peak ITS Bases 3.4.15 Required Action B.1.1 and B.1.2 and B.2 defines steady state in terms of stable RCS pressure and then refers back to SR 3.4.13.1, Which statement or statements define steady state?

FLOG Response:

3.4.13-5 ITS Bases 3.4.13 LCO and Bases SR 3.4.13.1 (Diablo Canyon)

Comment: The discussions include CRDM canopy welds as exceptions to the definition. That exception is not included in the Bases discussion for ITS 3.4.13 Actions B.1 and B.2 and the exception is notjustified.

FLOG Response:

.g.

3.4.13-6 ITS 3.4.13 Bases LCO a. (Callaway)

Comment: The intent of the addition that leakage past hstrumentation lines not being pressure boundary leakage is unclear, is that leakage upstream of isolation valves? If it is is there a line size lirr.it and is this consistent with the description of pressure boundary in the FSAR and the definition in ITS Section 1.1?

FLOG Response:

3.4.14-1 Difference 3.4-13 (Callaway, Wolf Creek and Comanche Peak) l Comment: What is the justification for restricting the testing to check valves with the addition of the term " check" in three places in SR 3.14-1 and its Bases? All PlVs at a plant may be check valves however, the addition is not consistent with the "or isolation valve" part of the first sentence of the SR Bases or with the words of required Action A of.lTS 3.4.14. For Callaway  !

and Wolf Creek simple deletion of " check" causes a problem with CTS 4. 4.6.2.2.d and I 4.4.5.2.2.d for Comanche Peak.

FLOG Response:

3.4.14-2 Change 6-11 LS 11 (Wolf Creek, Diablo Canyon and Comanche Peak)

Comment: The change justifies isolation by a single valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and the use of check l valves as isolations. However, the change does not justify the practice of using a second isolation valve.

FLOG Response:

l t

3.4.14-3 ITS 3.4.14 Actions Notes 1 and 2 Comment: The adoption of the STS notes (especially #1 which is a less restrictive change) is not discussedfjustifed.

FLOG Response:

l 3.4.14-4 Change 6-24 M (Callaway and Wolf Creek)

Comment: Cold shutdown rather than hot shutdown is more restrictive however, the discussion does not address the extension of the time from 12 to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

FLOG Response:

l

3.4.14-5 Change 6-25 LS 26 (Diablo Canyon and Wolf Creek)

Comment: The justification of the change is inadequate. The NSHC contains the proper justification.

FLOG Response:

l 3.4.15-1 ITS 3.4.15 and Bases ITS 3.4.15 Required Action E.1 (Callaway, Diablo Canyon and Wolf Creek) l Comment: Callaway and Wolf Creek: As written ITS 3.4.15 does not implement CTS 3.4.6.1 as marked up (allowing up to two methods to be inoperable). Specifically, in the ITS as written.

with two monitoring methods inoperable TS 3.0.3 would have to be entered as there is no i Condition for two methods inoperable. Diablo Canyon: ITS 3.4.15 and Bases ITS 3.4.15 Required Action E.1. E.1 Bases state that "With two of the three groups of leak detection monitoring not operable, the two groups will enter their respective ACTION and Completion

( statements." What in the construct!on of the ITS supports that statement and more importantly  !

what is the justification for this as the CTS requires 2 of 3 groups of equipment to be operable?

FLOG Response:  !

l 1 3.4.15-2 CTS 3.4.6.1 b&c and CTS 4.4.6.1 b&c markups (Callaway and Wolf Creek)

Comment: Have the systems been renamed, were the names in the CTS incorrect, or are different systems being relied on in the ITS?

FLOG Response:

4 3.4.15 3 ITS Bases Page B 3.4-97 (Wolf Creek) l Comment: In the smooth Bases discussion of A.1 and A.2 it should be "and makeup" not "andmakeup" FLOG Response:

I 3.4.15 4 ITS 3.4.15.3 (ComeNhe Peak and Diablo Canyon)

Comment: The SR requires a Channel Calibration of the sump monitors. However, ITS LCO 3.4.15.a only requires one monitor (level and discharge flow) [ Comanche Peak) or one monitor system [Diablo Canyon) to be operable. What other monitor (s) is the SR referencing?

FLOG Response:

- 11 -

3.4.15-5 ITS SR 3.4.15-5 (Diablo Canyon) l Comment: Only one CFCU condensate collection monitor is required by ITS LCO 3.4.15.

However, the SR specifies that required monitors be calibrated, i

FLOG Response:

I 3.4.16 1 Difference 3.4 39 i

l Comment: TSTF-113 has not yet been approved by the NRC staff.

FLOG Response:

3.4.16 2 ITS Figure 3.4.16.1 (Wolf Creek)

Comment: In order to be consistent with the ITS LCO and CTS Figure 3.4-1 the units should be micro (p) Curies /gm and not milli (m) Curies /gm as indicated.

FLOG Response:

3.4.16-3 ITS Bases 3.4.16 Applicability (Wolf Creek)

Comment: Page B 3.4-103 of the smooth Bases should read "the reactor" not "thereactor" FLOG Response:

3.4.G-1 CTS 3.4.8.2 and Change 9-05-R (Comanche Peak)

Comment: The CTS Cross Reference Table shows this specification is relocated to the FSAR.

Since this is an operational requirement shouldn't it be in the PTLR or a plant procedure?

FLOG Response:

l l

__ ____.____._______._____.m_____________._____________mm._______

j FLOG RAI APPLICABILITY TABLE FOR ITS SECTION 3.4

! Comment Callaway Comanche Peak Diablo Canyon Wolf Creek l 3.4.1-2 -

X X X X 3.4.1-2 X X X X 3.4.1-3 X 3.4.2-1 X X X X l 3.4.3-1 X X X X 3.4.4-1 X X X X 3.4.5-1 X X l 1

3.4.5-2 X l 1

3.4.5-3 X X j 3.4.5-4 X 3.4.6-1 X X X X 3.4.6-2 X 3.4.7-1 X 3.4.7-2 X 3.4.7-3 X 3.4.8-1 X X X X 3.4.8-2 X 3.4.9-1 X X X X 3.4.9-2 X 3.4.9-3 X X X 3.4.9-4 X 3.4.10-1 X X X X 3.4.11-1 X X X X 3.4.11-2 X X X X 3.4.11-3 X X X X 3.4.11 4 X X X X 3.4.11-5 X l

j 2

3.4.11-6 X X X 3.4.12-1 X X X X 3.4.12-2 X X X X I 1

j 3.4.12-3 X X X X i 3.4.12-4 X X X l

L 3.4.12-5 X X l 3.4.12-6 X .

3.4.12-7 X 3.4.12-8 X 3.4.13-1 X X I 3.4.13-2 X -

X- X 3.4.13-3 X X X 3.4.13-4 X X  ;

L 3.4.13-5 X 3.4.13-6 X 3.4.14-1 X X X 3.4.14-2 X X X 5

, 3.4.14-3 X X X X 3.4.14 4 X X 3.4.14-5 X X 3.4.15-1 X X X 3.4.15-2 X X 3.4.15-3 X 3.4.15-4 X X 3.4.15-5 X 3.4.16-1 X X X X 3.4.16-2 X 3.4.16-3 X i

i 9 i e 3

3.4.G-1 X e

I

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