ULNRC-03908, Forwards Response to NRC RAI Re Proposed Amend to License NPF-30,converting to Improved Tech Specs.Proposed Sections 3.1,3.2,3.4,3.5 & 5.0 Also Encl

Forwards Response to NRC RAI Re Proposed Amend to License NPF-30,converting to Improved Tech Specs.Proposed Sections 3.1,3.2,3.4,3.5 & 5.0 Also Encl

ML20154S227
Person / Time
Site:	Callaway
Issue date:	10/21/1998
From:	Passwater A UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20154S232	List: ML20154S237 ULNRC-03908, Forwards Response to NRC RAI Re Proposed Amend to License NPF-30,converting to Improved Tech Specs.Proposed Sections 3.1,3.2,3.4,3.5 & 5.0 Also Encl
References
TAC-M98803, ULNRC-03908, ULNRC-3908, NUDOCS 9810270353
Download: ML20154S227 (6)

Text

_ . _ _ _ _ _ _ _

Union Dectric l One Ameren Plaza 1901 Chouteau Avenue October 21,1998 ,s PO Box 66149 i i

St. Louis, MO 6.1166-6149 314 621.3222 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, D.C. 20555-0001 ULNRC-03908 Gentlemen: TAC NO. M98803 DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC COMPANY FOLLOW-UP ITEMS RELATED TO TIIE g

PROPOSED CONVERSION TO THE IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 3.1,3.2,3.4. 3.5. AND 5.0 T((N8[88

References:

1) ULNRC-03578 dated May 15,1997 UE 2) utNRC.03877 dated August 4,1998

3) ULNRC-03900 dated September 24,1998 Union Electric Company requested an amendment to the Callaway Facility Operating License (NPF-30) by incorporating changes to the Technical Specifications (TS) as provided in Reference 1. The NRC staff requested additional information regarding Section 3.1, " Reactivity Control Systems," Section 3.2, " Power Distribution Systems," Section 3.5, " Emergency Core Cooling Systems," Section 3.9,

" Refueling Operations," and 4.0, " Design Features," which was provided in Reference

2. In addition, the NRC staffrequested additionalinformation regarding Section 3.4,

" Reactor Coolant System," and Section 5.0, " Administrative Controls," which was provided in Reference 3.

The Attachments to this letter provide (1) additional information or supporting documentation not provided in the original RAI responses, (2) answers to follow-up questions, and (3) additional changes identified by the licensee for ITS Sections 3.1,3.2,3.4,3.5, and 5.0.

This letter and its Attachments are not a supplement to Reference 1 and have not been reviewed by the Onsite Review Committee or Nuclear Safety Review Board.

A supplement to Reference I will be provided at a later date.

Ifyou have any questions concerning this response, please contact us.

Sincerely, 7 ..,c-,

9810270353 DR 981021 Alan C. Passwater p ADOCK 0500 3 Manager, Corporate Nuclear Services f

l GGY/ptr Attachments [(~ L . I t n subsidisty of Amoren Corporation

3 _.

j t

STATE OF MISSOURI )

) SS CITY OF ST. LOUIS }

Alan C. Passwater, of lawful age, being first duly sworn upon oath says that he is Manager, Corporate Nuclear Services for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief. ,

~

By Alan C. Passwater Manager, Corporate Nuclear Services SUBSCRIBED and sworn to before me this 8/M day of CAAf44 , 1998.

. tahL $ fhtf97,hAL-( '

t.. = = , ,

e :m ons e

'%mpyWi

.5_AIEb PATRICIA L REYNOLDS NOTARY PUBUC-8 TATE 0Flem0m ST. LOUIS COUNTY MY Colma8610N EXMIER DELII,me

\

cc: M. H. Fletcher Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 Regional Administrator U.S. Nuclear Regulatory Commission Region ~IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mel Gray (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint,-North, Mail.Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Denny Buschbaum TU Electric P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent Pacific Gas &' Electric

' Regulatory Services P.O. Box 56 Avila Beach, CA 93424

l l

l

• l

- The item numbers are formatted as folloNs: (Source] [lTS Section]-[nnn]

Source = Q - NRC Question NR - NRC Follow-up Question CA - AmerenUE DC-PG&E WC - WCNOC CP - TU Electric TR - Traveler ITS item Number Applicability Enclosed 3.1 Q 3.1-19 CA, WC YES 3.1 Q 3.1-20 CP,DC NA 3.1 CA-3.1-005 (new) CA YES 3.2 0 3.2-3 CA, CP, DC, WC YES 3.4 Q 3.4.13-5 DC NA 3.4 Q 3.4.13-6 CA YES 3.5 O 3.5.5-1 CP,DC NA 3.5 CA-3.5-001 CP (new) NA 3.5 CA-3.5-002 CA, CP, DC, WC YES l 3.5 CA-3.5-004 (new) CA YES 3.5 CP-3.5-003 (new) CP NA )

3.5 DC-3.5-002 DC NA 3.5 DC-3.5-006 DC NA 5.0 NR-5.0-001 (new) CA, CP, DC, WC YES 1

l l

. - _ _ . - _ - - - . ~- _

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.1-19 APPLICABILITY: CA, WC REQUEST: ITS 3.1.7 Rod Position indication CTS 3.1.3.2 Position Indication Systems - Operating (Wolf Creek & Callaway)

DOC 13-05-A & 13-09-LS-23 & 13-06-A JFD 3.1-7 & 3.1-12 Comment: The ITS retains Conditions and associated Required Actions from the CTS addressing more than one inoperable digital rod position indicator (DRPI) per group, which is not addressed in the STS. However, not all associated CTS Required Actions have been retained in the ITS; the Required Actions to take manual control of the rods and to record reactor coolant temperature every hour have not been retained. These actions, in one case affect rod movement and in the other case provide an indication that the rod (s) position may have changed, and therefore have a bearing on SDM and therefore should not be deleted if the overall condition of more than DRPI per group is inoperable is retained. Either retain the CTS requirements completely, adopt the STS requirements, or provide a betterjustification for the ITS proposals. The STS wording of the note permitting separate condition entry should be retained with the STS Conditions and Required Actions.

FLOG RESPONSE (original): The wording of ITS Condition B, with its Required Actions B.1 and B.2, and the change to the Actions Note on separate Condition entry were made pursuant to traveler TSTF-234. TSTF-234 was created based on the Callaway and Wolf Creek CTS; however, Westinghouse and the Westinghouse Owners Group felt that Action Statements b.1.b) and b.1.c) were unnecessary compensatory actions. The justifications for deleting CTS 3.1.3.2 Action Statements b.1.b) and b.1.c) are discussed in Enclosure 4 under LS-23. In order to capture those justifk:ations under Enclosure 3A, DOC 13-09-LS-23 is revised to add the following:

"The proposed change would delete the Actions to place control rods in manual and record RCS T, houriy if multiple DRPIs per group are inoperable. Multiple inoperable DRPIs, of themselves, have no impact on SDM in MODES 1 and 2 if the control rod positions are verified by altamate means (e.g., movable incore detectors). The requirement to place control rods in manual may not be appropriate in all situations and may be detrimental for load rejection transients unless operator achon is assumed to simulate the rod control system in automatic.

Accidents analyzed using the [ improved Thermal Design Procedure (ITDP)) assume that the control rods are in [ automatic). Automatic rod movement can accommodate a 10% load rejection. Placing rods in manual may impact the load rejection capability assumed when the P-9 setpoint was establisned at 50% RTP. The steam dump system can accommodate a 40%

RTP load rejection and with the rod control system in automatic, a 50% RTP load rejection can be accommodated without a reactor trip. While manual operator action can be just as timely as automatic rod control, there is no need to have this limitation in the Technical Specifications.

Corrective schons for excessive rod motion are covered under ITS 3.1.7 Condition C. The requirement to monitor and record T, hourly is unnecessary given the available indicators and alarms, e.g., T,- T,,, deviation alarm, to alert operators to changing moderator conditions."

s FLOG RESPONSE (revised): This is a modified response, which replaces the original response provided in Reference 2 of the cover letter, in order to respond to NRC reviewer comments.

The wording of ITS Condition R, with its Required Actions B.1 and B.2, and the change to the Actions Note on separate Condition entry were made pursuant to traveler TSTF-234. TSTF-234 was created based on the Callaway and Wolf Creek CTS; however, Westinghouse and the Westinghouse Owners Group felt that Action Statements b.1.b) and b.1.c) were unnecessary compensatory actions. The justifications for deleting CTS 3.1.3.2 Action Statements b.1.b) and b.1.c) were discussed in Enclosure 4 under LS-23. However, based on NRC staff review, ITS 3.1.7 Condition B will be revised to include Required Actions to place the control rods in manual and to monitor and record RCS Tm hourly, as required by the current TS. The separate condition entry note does not need to include "per group" or "per bank" since the wording of the respective Conditions already provides those restrictions and including that wording in the note is redundant and potentially misleading to the operator. This is an editorial change.

ATTACHED PAGES:

Attachment 7, CTS 3/4.1 -ITS 3.1 Enclosure 2, page 3/41-17 Enclosure 3A, page 12 Enclosure 3B, page 8 Enclosure 4, pages 1, 50, and 51 Enclosure SA, Traveler Status Sheet Enclosure SA, pages 3.1-17 and 3.1-18 Enclosure 58, page B 3.1-48 Enclosure 6A, page 2 Enclosure 6B, page 1 t

l