ULNRC-03926, Forwards Addl Info or Supporting Documentation Not Provided in Original RAI Responses,Answers to follow-up Questions & Addl Changes Identified by Licensee for ITS Sections 1.0, 3.4,3.5,3.6,3.7 & 3.9
| ML20196C981 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/23/1998 |
| From: | Passwater A UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20196C989 | List: |
| References | |
| ULNRC-03926, ULNRC-3926, NUDOCS 9812020129 | |
| Download: ML20196C981 (8) | |
Text
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Union Drctric One Ameren Plaza 1901 Chouteau Avenue e
PO Ilox 66149 November 23, 1998 h
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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, D.C. 20555-0001 ULNRC 03926 Gentlemen:
TAC NO. 98803 DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC COMPANY M4 FOLLOW-UP ITEMS RELATED TO THE PROPOSED ggggg CONVERSION TO THE IMPROVED TECHNICAL ENCIFICATIONS g
SECTIONS 1.0. 3.4. 3.5. 3.6. 3.7. AND 3.9 4
References:
- 1. ULNRC-03578 dated May 15,1997
- 2. ULNRC-03889 dated August 27,1998
- 3. ULNRC-03900 dated September 24,1998
- 4. ULNRC-03877 dated August 4,1998
- 5. ULNRC-03853 date June 26,1998
- 6. ULNRC-03905 dated October 21,1998
- 7. ULNRC-03908 dated October 21,1998 Union Electric Company requested an amerdment 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 1.0, "Use and Application," Section 2.0, " Safety Limits (SLs)," and Section 3.0, " Limiting Condition for Operation (LCO) Applicability and Surveillance Requirement (SR) Applicability," which was provided in Reference 2. The NRC staff requested additional information regarding Section 3.4, " Reactor Coolant System,"
and Section 5.0, " Administrative Controls," which was provided in Reference 3. The
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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 Operadons," and 4.0, " Design Features,"
which was provided in Reference 4. The NRC staff requested additional information regarding Section 3.6, " Containment Systems," which was provided in Reference 5.
In addition, the NRC staffrequested additional information regarding Section 3.7,
,.,, a
" Plant Systems," which was provided in Reference 6.
a The Attachments to this letter provide (1) additional information or supporting documentation not provided in the origirial RAI responses, (2) answers to follow-up questions, and (3) additional changes identified by the licensee for ITS Sections 1.0,3.4,3.5,3.6,3.7, and 3.9. Reference 7 provided the first follow-up letter, affecting ITS Sections 3.1,3.2,3.4,3.5, and 5.0.
I 9812020129 981123 3 PDR ADOCK 05000403 P
PDR ;.;
a sdsidoary of Amoren Corporation
a-U. S. Nuclear Regulatory Commission o
ULNRC-03926 Page 2 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, i
1
.rr Alan C. Passwater Manager, Corporate Nuclear Services Attachments i
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_ _ _ _ _ _.__.._ _ _._..~. - _ ___.... _ __ _
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l STATE OF MISSOURI )
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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
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1 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.
1
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- 7" By Alan C. Passwater l
Manager, Corporate Nuclear Services l
SUBSCRI ED and sworn to before me this day of
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1998.
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PATRICIA L REYNOLDS l
ISTARY PUBUC-STATE OF MW800N sT. Louis county Iff(XItsRS640N EXPNB DEC.II,280 f
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cc:
M. H. Fletcher W/*.
Professional Nuclear Consulting, Inc.
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19041 Raines Drive-I Derwood, MD 20855-2432 Regional' Administrator u/o U.S. Nuclear Regulatory Commission Region IV i
611 Ryan Plaza Drive i
Suite 400 Arlington, TX 76011-8064 i
Senior Resident Inspector wA.
Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mel Gray (2)
UA Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission i
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 i
Department of Natural Resources P.O. Box 176 Jefferson City, MO'65102 Denny Buschbaum *J/s TU Electric P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent w/o Pacific Gas & Electric Regulatory Services I
P.O. Box 56 Avila Beach, CA 93424 i
L
Tha it::m numbIrs tra formitt::d as follows: [Sourco) [lTS Ssction]-[nnn)
]
Source =
Q - NRC Question NR - NRC Follow-up Question -
CA-AmerenUE DC-PG&E WC - WCNOC CP - TU Electric ITS item Number Applicability Enclosed l
1.0 Q 1.1-4 CA, CP, DC, WC YES 1.0 NR 1.0-001 (new)
DC NA 3.4 Q 3.4.9-3 CP, WC NA 3.4 Q 3.4.12-5 CA, WC YES 3.5 Q 3.5.5-2 CA, WC YES 3.6 O 3.6.1-5 DC NA 3.6 Q 3.6.1-6 CA, CP, DC, WC YES 3.6 O 3.6.2-6 CA, CP, DC, WC YES 3.6 Q 3.6.3-1 CP, WC NA 3.6 Q 3.6.3-4 CA, CP, WC YES 3.6 Q 3.6.3-7 DC NA 3.6 O 3.6.3-10 CA, DC, WC YES Q
3.6 O 3.6.3-11 CA, CP, DC, WC YES
/
3.6 O 3.6.3-13 CA, WC YES 3.6 O 3.6.3-14 CP NA i
3.6 Q 3.6.3-15 CA, WC YES 3.6 Q 3.6.3-16 DC NA 3.6 O 3.6.3-17 CA, WC YES 3.6 Q 3.6.3-21 CA, WC YES 3.6 Q 3.6.3-24 CA, WC YES 3.6 Q 3.6.3-28 CA, CP, DC, WC YES 3.6 Q 3.6.3-30 CP NA 3.6 O 3.6.3-33 CA, WC YES 3.6 Q 3.6.3-34 CA YES l
3.6 Q 3.6.3-35 DC NA 3.6 Q 3.6.3-39 DC NA 3.6 Q 3.6.3-43 DC NA 3.6 Q 3.6.3-44 DC NA 3.6 Q 3.6.3-48 DC NA 3.6 Q 3.6.3-56 CP, DC NA 3.6 Q 3.6.5-4 DC,WC NA 3.6 Q 3.6.6-2 DC NA 3.6 Q 3.6.6-8 DC NA 3.6 Q 3.6.6-13 CA, DC, WC YES 3.6 Q 3.6.6-15 DC NA f
3.6 O 3.6.6-18 CA YES
\\
3.6 Q 3.6.7-4 DC NA 3.6 O 3.6.7-12 CP NA 3.6 Q 3.6.7-16 CP NA 3.6 Q 3.6.8-6 CA YES E
3.6 Q 3.6.8-7 DC NA
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3.6 CA-3.6-001 CA YES 3
1 3.6 CA-3.6-004 CA YES
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3.6 CP-3.6-006 CP NA 3.6 DC-3.6-001 (new)
DC NA 3.6 WC-3.6-ED WC NA 3.6 WC-3.6-006 WC NA 3.6 WC-3.6-010 CA YES 3.7 O 3.7.1-4 CA YES 1
3.9 CA 3.9-001 (new)
CA YES 3.9 DC-ALL-005 (3.9 Section only)
DC NA 4
5.0 Q 5.6-2 DC NA i
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a ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 1.1-4 APPLICABILITY: CA, CP, DC, WC
]
l REQUEST:
CTS 1.13, Engineered Safety Features Response Time [Diablo Canyon, Wolf i
Creek, and Callaway]
i 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 i
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 j
The definitions for ESF Response Time arW RTS Response Time are proposed to be i
revised to substitute the word " verified"in !ieu of " measured." The JFD states that this change is msde 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.
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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 (original): The response to Comment Number 1.1-4 will be provided separately after the August 17,1998 NRC letter to NEl on TSTF-111 has been fully 1
l evaluated.
I FLOG RESPONSE (revised): This is a modified response, which replaces the original response provided in Reference 2 of the cover letter, in order to provide the requested response.
The FLOG continues to pursue the changes proposed in TSTF-111 Rev. 4. The attached CTS and ITS mark-ups reflect that traveler's definition changes. In addition, DOC 1-08-A and JFD 1.1-5 have been revised.
DOC 1-08-A has been revised to read as follows:
"The current TS definitions for Engineered Safety Features Response Time and Reactor Trip System Response Time are modified to be consistent with NUREG-1431 Rev.1, as modified by TSTF-111. The addition of the statement that response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured, is administrative in nature. This is consistent with the methodology presently described in the current TS Bases for demonstrating total channel response time. Likewise, the adoition of the statement that response times for selected components may be verified by other means approved by NRC is also administrative in nature since it allows no response time testing change unless NRC approval has been first obtained. This statement is consistent with
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Section 6.3.4 of IEEE 338-1977, traveler TSTF-111, and approved topical reports on response time testing verification methodology."
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I JFD 1.1-5 has been revised to read as follows:
"The definitions for ESF Response Time and RTS Response Time are revised consistent with traveler TSTF-111. The addition of the statement that response times for selected components j
may be verified by other means approved by NRC is administrative in nature since it allows no i'
response time testing change unless NRC spproval has been first obtained. This statement is consistent with Section 6.3.4 of IEEE 338-1977, traveler TSTF-111, and approved topical reports on response time testing verification methodology."
i Since NRC has not approved WCAP-14036-P, the bracketed references to that document and its discussion of allocated response times for signal conditioning and actuation logic that are i
included in the STS 3.3 Bases revisions specified by TSTF-111, Revision 4, are not included in the plant specific markups. However, Callaway and DCPP continue to pursue the sensor j
response time changes approved by NRC in WCAP-13632-Wh as noted in Section 3.3 DOC 1-03-LS-1.
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i ATTACHED PAGES:
i, pages 1-3,1-3a,1-5, and 1-Sa l A, page 2 i, B, page 1 Enclosure SA, Traveler Status Sheet j
Enclosure SA, pages 1.1-3 and 1.1-5
- A, page 1
' B, page 1 i
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