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{{#Wiki_filter:- | {{#Wiki_filter:- | ||
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l W$LF CREEK | l W$LF CREEK NUCLEAR OPERATING CORPORATION i | ||
Clay C. Warren | Clay C. Warren Vee President and Chief Operating Omcer NOV 2 41998 WO 98-0105 | ||
) | |||
Mail Station Pl-137 | U. S. Nuclear Regulatory Commission i | ||
Washington, D. C. 20555 | ATTN: Document Control Desk Mail Station Pl-137 Washington, D. C. | ||
20555 | |||
==Reference:== | ==Reference:== | ||
: 1) Letter ET 98-0078 dated September 24, 1998, from R. A. | : 1) Letter ET 98-0078 dated September 24, 1998, from R. | ||
A. | |||
Muench, to USNRC | Muench, to USNRC | ||
: 2) Letter ET 98-0071 dated August 28, 1998, from R. A. | : 2) Letter ET 98-0071 dated August 28, 1998, from R. | ||
Muench, to USNRC | A. | ||
: 3) Letter WO 98-0078 dated August 5, 1998, from C. C. | Muench, to USNRC | ||
Warren, to USNRC | : 3) Letter WO 98-0078 dated August 5, | ||
: 4) Letter ET 98-0049 dated June 30, | 1998, from C. | ||
: 5) Letter | C. | ||
Warren, to USNRC i | |||
: 4) Letter ET 98-0049 dated June 30, 1998, from R. | |||
A. | |||
1 Puench, to USNRC l | |||
: 5) Letter ET 97-0050, dated May 15, | |||
: 1997, from R. A. Muench to USNRC | |||
==Subject:== | ==Subject:== | ||
Docket No. 50-482: Follow-up Items Related to the Proposed Conversion to the Improved Technical Specifications Section | Docket No. 50-482: Follow-up Items Related to the Proposed Conversion to the Improved Technical Specifications Section | ||
1.0, | ) | ||
1.0, 3.4, 3.5, and 3.6 | |||
[ | [ | ||
Gentlemen: | Gentlemen: | ||
Wolf Creek Nuclear Operating Corporation (WCNOC) requested an amendment to the Wolf Creek Generating Station (WCGS) Unit 1 facility cperating license (NPF- | Wolf Creek Nuclear Operating Corporation (WCNOC) requested an amendment to the Wolf Creek Generating Station (WCGS) Unit 1 facility cperating license (NPF- | ||
: 42) by incorporating changes to the WCGS Technical Specifications (TS) as previded in Reference 5. | : 42) by incorporating changes to the WCGS Technical Specifications (TS) as previded in Reference 5. | ||
The NRC staff request ed additional information regarding Section 3.4, | |||
L | " Reactor Coolant System," | ||
and Section 5.0, | |||
" Administrative Controls," which was provided in Reference 1. | |||
The NRC staff requested additional information regarding Section 1.0, "Use and Application," | |||
not provided in the original Request for Addition Information response, (2) answers to follow-up questions, or (3) additional changes identified by the | L Section | ||
l-l | : 2. 0, | ||
" Safety Limits," and Section | |||
: 3. 0, | |||
" Limiting Conditions for Operation Applicability / Surveillance Requirement Applicability" which was provided in Reference 2. | |||
The NRC staff requested additional information j | |||
regarding Section 3.1, | |||
" Reactivity Control Systems," Section 3.2, | |||
" Power l | |||
Distribution Systems," Section 3.5, " Emergency Core Cooling Systems," Section l | |||
3.9, " Refueling Operations," and 4.0, " Design Features," which was provided in j. | |||
Reference 3. The NRC staff requested additional information regarding Section 3.6, " Containment Systems," which was provide'd in Reference 4. The Attachments to this letter provide (1) additional information or supporting documentation not provided in the original Request for Addition Information response, (2) answers to follow-up questions, or (3) additional changes identified by the i | |||
licensee. | |||
l-l This letter and Enclosure are not a supplement to Reference 5 and have not been reviewed by the Plant Safety Review Committee or Nuclear Safety Review Committee. A supplement to Reference 5 will be provided at a later date. | |||
0 | 0 | ||
~ | |||
9812010110 981124 PDR ADOCK 05000482-p PDR P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Employer HAT /He/ VET | |||
L t | L t | ||
WO 98-0105 Page 2 If you have any questions concerning this response, please contact me at (316) 364-4048, or Mr. Michael J. Angus, 316-354-4077. | WO 98-0105 Page 2 If you have any questions concerning this response, please contact me at (316) 364-4048, or Mr. Michael J. Angus, 316-354-4077. | ||
Ve y truly y urs, C. | Ve y truly y urs, C. | ||
cc: | ' C. Warren Attachments Enclosure CCW/r1r cc: | ||
k r | W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a B. A. Smalldridge (NRC), w/a K. M. Thomas (NRC), w/a i | ||
k r | |||
i l | |||
l l | l l | ||
I I | |||
l l' | |||
l' i | i i | ||
t s | |||
(- | (- | ||
- -~ | |||
.= -.. ~. | |||
~. - | |||
i i | i i | ||
? | |||
i STATE OF KANSAS | i STATE OF KANSAS | ||
) | |||
COUNTY OF COFFEY | ) | ||
Clay C. Warren,' of lawful age, being first duly sworn upon oath says that he is Chief Operating Officer of Wolf Creek Nuclear Operating Corporation; that | ss COUNTY OF COFFEY | ||
) | |||
executed that same for and on behalf of said Corporation with full power and authority to do so; and that the facts.therein stated are true and correct to | Clay C. | ||
the best of his knowledge, information and belief. | Warren,' of lawful age, being first duly sworn upon oath says that he is Chief Operating Officer of Wolf Creek Nuclear Operating Corporation; that | ||
' he has read the foregoing. document and knows the centent thereof; that he has executed that same for and on behalf of said Corporation 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. | |||
My Appt. Expires id/ | l MARY E. GIFFORD My Appt. Expires id/ 09(y Kanees Notary Public-State By 1993 Clay Warren | ||
Chi . Operating Officer | + | ||
SUBSCRIBED and sworn to before me this N | Chi. Operating Officer SUBSCRIBED and sworn to before me this N day of hloV 1998. | ||
5lW. $- | 5lW. $- | ||
Notary Public | |||
~ | |||
Expiration Date OMRM p | |||
4 4 | |||
Attachm:nt 1 to WO 98-0105 Page 1 of 2 The item numbers are formatted as follows: [ Source][lTS Section)-[nnn) | Attachm:nt 1 to WO 98-0105 Page 1 of 2 The item numbers are formatted as follows: [ Source][lTS Section)-[nnn) | ||
Source = | Source = | ||
WC - WCNOC CP - TU Electric TR - Traveler ITS | Q - NRC Question NR - NRC Follow-up Question l | ||
3.5 | CA - AmerenUE DC-PG&E WC - WCNOC CP - TU Electric TR - Traveler ITS Item Number Applicability Enclosed 1.0 Q 1.1-4 DC, CP, WC, CA YES 1.0 NR 1.0-001 (new) | ||
DC NA 3.4 Q 3.4.9-3 CP, WC YES 3.4 Q 3.4.12-5 CA, WC YES 3.5 Q 3.5.5-2 WC, CA YES 3.6 Q 3.6.1-5 DC NA 3.6 Q 3.6.1-6 DC, CP, WC, CA YES 3.6 Q 3.6.2-6 DC, CP, WC, CA YES 3.6 Q 3.6.3-1 CP, WC YES 3.6 Q 3.6.3-4 CP, WC, CA YES 3.6 Q 3.6.3-7 DC NA 3.6 Q 3.6.3-10 DC, WC, CA YES 3.6 Q 3.6.3-11 DC, CP, WC, CA YES 3.6 Q 3.6.3-13 WC, CA YES 3.6 Q 3.6.3-14 CP NA 3.6 Q 3.6.3-15 WC, CA YES 3.6 Q 3.6.3-16 DC NA 3.6 Q 3.6.3-17 WC, CA YES 3.6 O 3.6.3-21 WC, CA YES 3.6 Q 3.6.3-24 WC, CA YES 3.6 Q 3.6.3-28 DC, CP, WC, CA YES 3.6 Q 3.6.3-30 CP NA 3.6 Q 3.6.3-33 WC, CA YES l | |||
3.6 Q 3.6.3-34 CA NA 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 O 3.6.3-56 DC,CP NA l | |||
l | l | ||
Attrchment 1 to WO 98-0105 Page 1 of 2 ITS | Attrchment 1 to WO 98-0105 Page 1 of 2 ITS ltem Number Applicability Enclosed 3.6 Q 3.6.5-4 DC, WC NA 3.6 Q 3.6.6-2 DC NA 3.6 O 3.6.6-8 DC NA 3.6 Q 3.6.6-13 DC, WC, CA YES 3.6 Q 3.6.6-15 DC NA 3.6 Q 3.6.6-18 CA NA 3.6 Q 3.6.7-4 DC NA 3.6 Q 3.6.7-12 CP NA t | ||
3.6 | 3.6 Q 3.6.7-16 CP NA 3.6 Q 3.6.8-6 CA NA 3.6 Q 3.6.8-7 DC NA 3.6 CA 3.6-001 CA NA 3.6 CA 3.6-004 CA NA 3.6 CP 3.6-006 CP NA 3.6 DC 3.6-001 (new) | ||
3.6 | DC NA 3.6 WC 3.6-ED WC YES 3.6 WC 3.6-006 WC YES 3.6 WC 3.6-010 CA NA 3.7 Q 3.7.1-4 CA NA 3.9 CA 3.9-001 (new) | ||
3.6 | CA NA 3.9 DC ALL-005 DC NA 5.0 Q 5.6-2 DC NA r | ||
3.6 | |||
3.9 | |||
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1.1-4 | ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1.1-4 APPLICABILITY: CA, CP, DC, WC REQUEST: | ||
CTS 1.13, Engineered Safety Features Response Time [Diablo Canyon, Wolf Creek, and Callaway] | |||
CTS 1.14, Engineered Safety Features Response Time (Comanche Peak] | CTS 1.14, Engineered Safety Features Response Time (Comanche Peak] | ||
CTS 1.27, Reactor Trip System Response Time (Wolf Creek and Callaway) | 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) | 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. | 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 | 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 I | ||
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 evaluated. | |||
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. | 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. | 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. | : 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 te read as follows: | DOC 1-08-A has been revised te 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 totel 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 addition of the i | |||
addition of the statement that response time may be measured by means | statement that response times for selected components may be verified by - ther means approved by NRC is also administrative in nature since it allows no response time testing change unless NRC approval has been | ||
first obtrin;d. This stC%nt is consist:nt with S2ction 6.3.4 of IEEE 338-I 1977, traveler TSTF-111, and approved topical reports on response time testing verification methodology." | |||
JFD 1.1-5 has been revised to read as follows: | 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 may be verified by other means approved by NRC is administrative in nature since it allows no response time testing change unless NRC approval has been first obtained. This statement is consistent with Section B.3.4 of EEE 338-1977, traveler TSTF-111, and approved topical reports on response time testing verification methodology.' | |||
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 included in the 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 response time changes approved by NRC in WCAP-13632-P-A as noted in Section 3.3 DOC 1-03-LS-1. | ||
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 included in the 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 response time changes approved by NRC in WCAP-13632-P-A as noted in Section 3.3 DOC 1-03-LS-1. | |||
ATTACHED PAGES: | ATTACHED PAGES: | ||
Attachment No. 4, CTS 1.0 - ITS 1.0 Encl. 2 | Attachment No. 4, CTS 1.0 - ITS 1.0 Encl. 2 1-3,1-5 Encl. 3A 2 | ||
1 | Enci. 3B 1 | ||
Encl.5A Traveler Status page, 1.1 -3, 1.1-5 Encl.6A 1 | |||
Encl. 68 1 | |||
4 1 | |||
;}} | |||
Latest revision as of 17:27, 10 December 2024
| ML20196B482 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek |
| Issue date: | 11/24/1998 |
| From: | Warren C WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20196B486 | List: |
| References | |
| WO-98-0105, WO-98-105, NUDOCS 9812010110 | |
| Download: ML20196B482 (7) | |
Text
-
i l
l W$LF CREEK NUCLEAR OPERATING CORPORATION i
Clay C. Warren Vee President and Chief Operating Omcer NOV 2 41998 WO 98-0105
)
U. S. Nuclear Regulatory Commission i
ATTN: Document Control Desk Mail Station Pl-137 Washington, D. C.
20555
Reference:
- 1) Letter ET 98-0078 dated September 24, 1998, from R.
A.
Muench, to USNRC
- 2) Letter ET 98-0071 dated August 28, 1998, from R.
A.
Muench, to USNRC
- 3) Letter WO 98-0078 dated August 5,
1998, from C.
C.
Warren, to USNRC i
- 4) Letter ET 98-0049 dated June 30, 1998, from R.
A.
1 Puench, to USNRC l
- 5) Letter ET 97-0050, dated May 15,
- 1997, from R. A. Muench to USNRC
Subject:
Docket No. 50-482: Follow-up Items Related to the Proposed Conversion to the Improved Technical Specifications Section
)
1.0, 3.4, 3.5, and 3.6
[
Gentlemen:
Wolf Creek Nuclear Operating Corporation (WCNOC) requested an amendment to the Wolf Creek Generating Station (WCGS) Unit 1 facility cperating license (NPF-
- 42) by incorporating changes to the WCGS Technical Specifications (TS) as previded in Reference 5.
The NRC staff request ed additional information regarding Section 3.4,
and Section 5.0,
" Administrative Controls," which was provided in Reference 1.
The NRC staff requested additional information regarding Section 1.0, "Use and Application,"
L Section
- 2. 0,
" Safety Limits," and Section
- 3. 0,
" Limiting Conditions for Operation Applicability / Surveillance Requirement Applicability" which was provided in Reference 2.
The NRC staff requested additional information j
regarding Section 3.1,
" Reactivity Control Systems," Section 3.2,
" Power l
Distribution Systems," Section 3.5, " Emergency Core Cooling Systems," Section l
3.9, " Refueling Operations," and 4.0, " Design Features," which was provided in j.
Reference 3. The NRC staff requested additional information regarding Section 3.6, " Containment Systems," which was provide'd in Reference 4. The Attachments to this letter provide (1) additional information or supporting documentation not provided in the original Request for Addition Information response, (2) answers to follow-up questions, or (3) additional changes identified by the i
licensee.
l-l This letter and Enclosure are not a supplement to Reference 5 and have not been reviewed by the Plant Safety Review Committee or Nuclear Safety Review Committee. A supplement to Reference 5 will be provided at a later date.
0
~
9812010110 981124 PDR ADOCK 05000482-p PDR P.O. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Employer HAT /He/ VET
L t
WO 98-0105 Page 2 If you have any questions concerning this response, please contact me at (316) 364-4048, or Mr. Michael J. Angus, 316-354-4077.
Ve y truly y urs, C.
' C. Warren Attachments Enclosure CCW/r1r cc:
W. D. Johnson (NRC), w/a E. W. Merschoff (NRC), w/a B. A. Smalldridge (NRC), w/a K. M. Thomas (NRC), w/a i
k r
i l
l l
I I
l l'
i i
t s
(-
- -~
.= -.. ~.
~. -
i i
?
i STATE OF KANSAS
)
)
ss COUNTY OF COFFEY
)
Clay C.
Warren,' of lawful age, being first duly sworn upon oath says that he is Chief Operating Officer of Wolf Creek Nuclear Operating Corporation; that
' he has read the foregoing. document and knows the centent thereof; that he has executed that same for and on behalf of said Corporation 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.
l MARY E. GIFFORD My Appt. Expires id/ 09(y Kanees Notary Public-State By 1993 Clay Warren
+
Chi. Operating Officer SUBSCRIBED and sworn to before me this N day of hloV 1998.
5lW. $-
Notary Public
~
Expiration Date OMRM p
4 4
Attachm:nt 1 to WO 98-0105 Page 1 of 2 The item numbers are formatted as follows: [ Source][lTS Section)-[nnn)
Source =
Q - NRC Question NR - NRC Follow-up Question l
CA - AmerenUE DC-PG&E WC - WCNOC CP - TU Electric TR - Traveler ITS Item Number Applicability Enclosed 1.0 Q 1.1-4 DC, CP, WC, CA YES 1.0 NR 1.0-001 (new)
DC NA 3.4 Q 3.4.9-3 CP, WC YES 3.4 Q 3.4.12-5 CA, WC YES 3.5 Q 3.5.5-2 WC, CA YES 3.6 Q 3.6.1-5 DC NA 3.6 Q 3.6.1-6 DC, CP, WC, CA YES 3.6 Q 3.6.2-6 DC, CP, WC, CA YES 3.6 Q 3.6.3-1 CP, WC YES 3.6 Q 3.6.3-4 CP, WC, CA YES 3.6 Q 3.6.3-7 DC NA 3.6 Q 3.6.3-10 DC, WC, CA YES 3.6 Q 3.6.3-11 DC, CP, WC, CA YES 3.6 Q 3.6.3-13 WC, CA YES 3.6 Q 3.6.3-14 CP NA 3.6 Q 3.6.3-15 WC, CA YES 3.6 Q 3.6.3-16 DC NA 3.6 Q 3.6.3-17 WC, CA YES 3.6 O 3.6.3-21 WC, CA YES 3.6 Q 3.6.3-24 WC, CA YES 3.6 Q 3.6.3-28 DC, CP, WC, CA YES 3.6 Q 3.6.3-30 CP NA 3.6 Q 3.6.3-33 WC, CA YES l
3.6 Q 3.6.3-34 CA NA 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 O 3.6.3-56 DC,CP NA l
l
Attrchment 1 to WO 98-0105 Page 1 of 2 ITS ltem Number Applicability Enclosed 3.6 Q 3.6.5-4 DC, WC NA 3.6 Q 3.6.6-2 DC NA 3.6 O 3.6.6-8 DC NA 3.6 Q 3.6.6-13 DC, WC, CA YES 3.6 Q 3.6.6-15 DC NA 3.6 Q 3.6.6-18 CA NA 3.6 Q 3.6.7-4 DC NA 3.6 Q 3.6.7-12 CP NA t
3.6 Q 3.6.7-16 CP NA 3.6 Q 3.6.8-6 CA NA 3.6 Q 3.6.8-7 DC NA 3.6 CA 3.6-001 CA NA 3.6 CA 3.6-004 CA NA 3.6 CP 3.6-006 CP NA 3.6 DC 3.6-001 (new)
DC NA 3.6 WC 3.6-ED WC YES 3.6 WC 3.6-006 WC YES 3.6 WC 3.6-010 CA NA 3.7 Q 3.7.1-4 CA NA 3.9 CA 3.9-001 (new)
CA NA 3.9 DC ALL-005 DC NA 5.0 Q 5.6-2 DC NA r
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 1.1-4 APPLICABILITY: CA, CP, DC, WC REQUEST:
CTS 1.13, Engineered Safety Features Response Time [Diablo Canyon, Wolf Creek, and Callaway]
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 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 I
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 evaluated.
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 te 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 totel 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 addition of the i
statement that response times for selected components may be verified by - ther means approved by NRC is also administrative in nature since it allows no response time testing change unless NRC approval has been
first obtrin;d. This stC%nt is consist:nt with S2ction 6.3.4 of IEEE 338-I 1977, traveler TSTF-111, and approved topical reports on response time testing verification methodology."
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 may be verified by other means approved by NRC is administrative in nature since it allows no response time testing change unless NRC approval has been first obtained. This statement is consistent with Section B.3.4 of EEE 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 included in the 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 response time changes approved by NRC in WCAP-13632-P-A as noted in Section 3.3 DOC 1-03-LS-1.
ATTACHED PAGES:
Attachment No. 4, CTS 1.0 - ITS 1.0 Encl. 2 1-3,1-5 Encl. 3A 2
Enci. 3B 1
Encl.5A Traveler Status page, 1.1 -3, 1.1-5 Encl.6A 1
Encl. 68 1
4 1