ULNRC-03946, Forwards RAI Re Proposed Conversion to Improved Tech Specs Sections 1.0,3.1,3.2,3.3,3.4,3.7,3.9 & 5.0.Suppl to Ref Will Be Provided at Later Date

Forwards RAI Re Proposed Conversion to Improved Tech Specs Sections 1.0,3.1,3.2,3.3,3.4,3.7,3.9 & 5.0.Suppl to Ref Will Be Provided at Later Date

ML20198J708
Person / Time
Site:	Callaway
Issue date:	12/22/1998
From:	Passwater A UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198J711	List: ML20198J730 ULNRC-03946, Forwards RAI Re Proposed Conversion to Improved Tech Specs Sections 1.0,3.1,3.2,3.3,3.4,3.7,3.9 & 5.0.Suppl to Ref Will Be Provided at Later Date
References
TAC-M98803, ULNRC-03946, ULNRC-3946, NUDOCS 9812300246
Download: ML20198J708 (7)

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union Doctric One Am ren I'laza 1901 Chouteau Avenue December 22,1998 PO lbx 66149 st 1,ou's. uo naincmi 49 msnam U. S. Nuclear Regulatory Commission ATTN: Document Control Desk

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Mail Station PI-137 Washington, D.C. 20555-0001 ULNRC-0394 6 Y

Gentlemen:

TAC NO. M98803 DOCKET NUMBFR 50-483 CALLAWAY PLANT UNION ELECTRIC COMPANY FOLLOW-UP ITEMS RELATED TO THE Mt PROPOSED CONVERSION TO THE IMPROVED TECHNICAL Dggg jiPECIFICATIONS SECTIONS 10. 3.1. 3.2. 3.3. 3.4. 3.7. 3.9. AND 5.0

References:

1.ULNRC-03578 dated May 15,1997

2. ULNRC-03889 dated August 27,1998

3. ULNRC-03877 dated August 4,1998

4. ULNRC-03927 dated November 25,1998

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5. ULNRC-03900 d.ted September 24,1998 L

6. ULNRC-03905 dated October 21,1998 m

7. ULNRC-03f 08 dated October 21,1998

8. ULNRC-03926 dated November 23,1998 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 1.0, "Use and Application," Section 2.0, " Safety Limits (P.s)," 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 3.1, " Reactivity Control Systems,"

Section 3.2, " Power Distribution L,imits," Section 3.5, " Emergency Core Cooling Systems," Section 3.9, " Refueling Operations," and 4.0, " Design Features," which was provided in Reference 3. The NRC staff sequested additional mformation regarding Section 3.3, "Instmmentation," which was provided in Reference 4. The NRC staff requested additional information regarding Section 3.4, " Reactor Coolant System," and Section 5.0, " Administrative Controls," which was provided in Reference 5. In addition, the NRC staff requested additional information regarding Section 3.7, " Plant Systems," which was provided in Reference 6.

e 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 c

Sections 1.0, 3.1, 3.2, 3.3, 3.4, 3.7, 3.9, and 5.0. Reference ' provided the first follow-up letter, afr ting ITS Sections 3.1, 3.2, 3.4,3.5, and 5.0. Reference 8 ec provided the secand follow-up letter, affecting ITS Sections 1.0,3.4,35,3.6,3.7, and 3.9.

9812300246 981222 PDR ADOCK 05000483 P

PDR

7 U. S. Nuclear Regulatory Commission 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, afs Alan C. Passwater Manager, Corporate Nuclear Senices GGY/ptr Attachments l

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STATE OF MISSOURI )

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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 de so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By

/

A Alan C.

Passwater Manager, Corporate Nuclear Services SUBSCR BED and sworn to before me this 22//

day of 9 Pef rif*)

, 1998.

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nouRY PUBUC-4MTEOF1550WI sr.LouscoUNTY MycasamesmeExpuesos.st,see

Fletcherv[A cc:

M. H.

Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 RegionalAdministrator'v[a.

U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 SeniorResidentInspectorWifA Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mel Gray (2) Nf4 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 DennyBuschbaumw[a TU Electric P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent W[4 Pacific Gas & Electric Regulatory Services P.O. Box-56 Avila Beach, CA 93424

Th3 itam numbsrs cra formatt:d as follows: [ Source][lTS Section]-[nnn)

Source =

0 - NRC Ouestion NR - NRC Follow-up Question CA-AmerenUE DC-PG&E WC-WCNOC CP - TU Electric TR - Traveler ITS ltem Number Applicability Enclosed 1.0 O 1.4-1, TSTF-267, TSTF-270 CA, CP, DC, WC

'/ES 3.1 O 3.1-25, WOG-105 CA, CP, DC, WC YES 3.2 O 3.2-6, TSTF-241 CA, CP, DC, WC YES 3.3 TR-3.3-007 (NEW), TSTF-311 CA, CP, DC, WC YES 3.3 CP-3.3-011 (NEW)

CP NA 3.3 WC-3.3-019 (NEW)

CA, CP, DC, WC YES 3.4 O 3.4.1-2. TSTF-282 CA, WC YES 3.4 O 3.4.5-2 CA, WC YES 3.4 O 3.4.11-3 TSTF-113 CA, CP, DC, WC YES 3.4 O 3.4.121, TSTF-280 CA, CP, DC, WC YES 3.4 WC-3.4-010 CA YES 3.4 WC-3.4-011 (NEW)

WC NA 3.6 O 3.6.3-23, WOG-126 CP,DC NA 3.7 O 3.7.G-1 CA YES 3.7 O 3.7.1-4, TSTF-235 CA, CP, WC YES 3.7 O 3.7.10-14, TSTF-287 CA, CP, WC YES 3.7 O 3.7.13.2-2, TSTF-287 CA, WC YES 3.7 CA-3.7-ED CA YES 3.9 O 3.9-7, TSTF-312 CA, CP, DC, WC YES 5.0 0 5.5-4, TSTF-308 CA, CP, DC, WC YES l

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ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1.4-1 APPLICABILITY: CA, CP, DC, WC REQUEST:

DOC 1-26-A ITS Example 1.4-4 ITS Example 1.4-5 JFD 1.1-3 JFD 1.1-11 l

Additional examples, Example 1.4-4 and 1.4-5, are proposed 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, than 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 (original): WOG-74 and WOG-90 have been approved by the TSTF and are designated as TSTF-270 and TSTF-267, respectively. Both of these travelers have been submitted to the NRC and are under review. The proposed wording in TSTF-270 was modified from WOG-74, Rev. 2, and these modifications have been incorporated into the ITS. The FLOG continues to pursue the changes proposed by these travelers.

FLOG RESPONSE (supplement): Based on the present status of the generic change process for the STS, it appears that travelers TSTF-267 and TSTF-270 will not be approved by the NRC in time to support the initiallicense amendments for the FLOG plants. In order to facilitate the issuance of these initiallicense amendments, an altemate approach has been developed which relies on the CTS, plant-specific information, and/or the NUREG but does not rely upon the travelers. This alternate approach is hereby provided as an interim submittal to allow issuance of the initiallicense amendments. The changes which rely upon the travelers can be processed in subsequent license amendments following approval of the travelers by the NRC.

The FLOG believes that these travelers reflect correct rules of usage for the ITS and will include them in operator training and plant procedures pending approval of the travelers.

At this time, Examples 1.4-4 and 1.4-5 of ITS Section 1.4 have been deleted and JFDs 1.1-3 and 1.1-11 have been revised to indicate "Not used."

l ATTACHED PAGES:

., CTS 1.0 - ITS 1.0

' A, page 6 i

Enclosure SA, Traveler Status Sheet

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.. _._..... _ _ __ A, pages 1.4-5 and 1.4-6 l

. Enc osure BA, pages 1,2, and 3 Enclosure BB, pages_1 and 2 '

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