ML20197B696
| ML20197B696 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/05/1998 |
| From: | Alexion T NRC (Affiliation Not Assigned) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| TAC-M95529, TAC-M95530, NUDOCS 9803110345 | |
| Download: ML20197B696 (14) | |
Text
_ - _ _ . - - _ _ _ _ _ __ __ _ _ .
=4 March 5, 1998 Mr. Wdliam T. Cottle President and Chief Executive Off.::er STP Nuclear Operating Company i
South Texas Froject Electric '
Generating Station P. O. Box 289 Wadswortn, TX 77483
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPEC'FICATIONS, SOUTH TEXAS PROJECT, UNITS 1 AND 2 (STP)(TAC NOS. M95529 AND M95530)
Dear Mr. Cottle:
The Nuclear Regulatory Commission staff is reviewing STP Nuclear Operating Company's
- (STPNOC's) proposed license amendment to convert to the format of the Improved Standard Technical Speci'ications. STPNOC provided a major supplement to the proposed license amendment (Supplement 1) by letter dated July 22,1997. _
The staff has reviewed selected portions of the application and its supp!ements. Based on its review, tb.* staff has determined that additional information is ,needed, as discussed in the enclosure.
Sincerely, ORIGINAL SIGNED BY:
Thomas W. Alexion, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/lV Office of Nuclear Reactor Regulation
. DocFat Nos. 50-498 and 50-499
Enclosure:
As stated cc w/ encl: See next page
. DISTPlBUTION:
Docket File PUBLIC PD4-1 r/f /
EAdensam (EGA1) 'JHannon TAlexion OGC CHawes ACRS
/
TGwynn, RIV WBeckner.
Document Name: STP95529.RAI OFC PMf% LA/PD4-1 BC/TSB A PD/PDiV-1 NAME TAh CHaweh WBeck$er JHannonk OATE 3 /" 198 6/ N l98 *) / i 198 'l (198 Y COPY hEk/NO YES/NO YES/NO YES/NO OFFICIAL RECORD COPY
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9803110345 990305 PDR P ADOCK 05000498 PDR NHC FiiE CENIB COPY 11,11#lilllllll1,1ll'
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p rnaou p4 t UNITED STATES s# j NUCLEAR RECULATORY COMMISSION WASHINGTON. D.C. 30666 4 001 4***** March 5, 1998 Mr. William T. Cottle President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Ebetric Generatlag Station P. O. Box 289 Wadsworth, TX 77483
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS, SOUTH TEXAS PROJECT, UNITS 1 AND 2 (STP) (TAC NOS. M95529 AND M95530)
Dear Mr. Cottle:
The Nuclear Regulatory Commission staff is reviewing STP Nuclear Operating Company's (STPNOC's) proposed license amendment to convert to the format of the improved Standard Technical Specifications. STPMOC provided a major supplemer.t to the proposed licenss amendment (Supplement 1) by letter dated July 22,1997.
The staff has reviewed selected portions of the application and its supplements. Based on its review, the staff has determined that additionalinformation is needed, as discussed in the
- enclosure.
Sincerely, Y (QYU L.i &
Thomas W. Alexion, Project Mar.sger Project Directorate IV-1 Division of Reactor Projects lil/IV Office of Nuclear Reactor Reguistion Docket Nos. 50-498 and 50-499
Enclosure:
As stated cc w/ encl: See next page
_-_-_._.0
Mr. Wilfrm T. Cottle STP Nuclear Operating Company South Texas, Units 1 & 2 cc:
Mr. David P. Loveless Jack R. Newman, Esq.
Senior Resident inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
P. O. Box 910 Washington, DC 20036 5869 Bay City, TX 77414 Mr. Lawrence E. Martin A. Ramirez/C. M. Canady Vice President, Nuc. Assurance & Licensing City of Austin STP Nuclear Operating Company Electric Utility Department P. O. Box 289 721 Barton Springs Road Wadsworth,TX 77483 Austin, TX 78704 Office of the Govemor Mr. M. T. Hardt ATTN: John Howard, Director Mr. W. C. Gunst Environmental and Natural City Public Service Board Resources Policy P. O. Box 1771 P. O. Box 12428 San Antonio, TX 78296 Austin, TX 78711 Mr. G. E. Vaughn/C. A. Johnson Jon C. Wood Central Power and Light Company Matthews & Branscomb P. O. Box 289 One Alamo Center Mail Code: N5012 106 S. St. Mary's Street, Suite 700 Wadsworth, TX 74483 San Antonio, TX 78205-3692 INPO Arthur C. Tate, Director Recorrh Center Division of Compliance & Inspection 700 Galleria Parkway Bureau of Radiation Control Atlanta, GA 30339-3064 Texas Department of Health 1100 West 49th Street Regional Administrator, Region IV Austin, TX 78756 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Jim Calloway Ar'ington, TX 76011 Public Utility Commission of Texas Electric Ind Jstry Analysis D. G. Tees /R. L. Bsicom P. O. Box 13326 Houston Lighting & Power Co. Austin, TX 78711-3326 P. O. Box 1700 Houston,TX 77251 Judge, Matagorda County .
Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 a
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soum Tam unns 1 and a oenerte conenent n---a ersAst r 2 l
Generic #1 DOC M4 and JFD #5 & #6 ITS 3.5.2, Action A and B, Completion Times DOC M7 and Jf D #11 ITS 3.6.6, Action A and B, Completion Times CTS 3.5.2 and CTS 3.5.6 have been combined into ITS 3.5.2. CTS 3.6.2.1 and CTS 3.6.2.3 have been combined into ITS 3.6.6. Now, ITS 3.5.2 and 3.6.6 have separate Actions A and B for two different non-related systems inoperable. These situations do not appear to be covered under Section 1.3, Example 1.3-3 which attempts to limit the time spent in the respective actions because there is no Action in either ITS 3.5.2 or 3.6.6 which corresponds to Action C in Example 1.3-3.
Comment: STP is to eglain in detail the operational " maneuvering" which occurs between Actions for ITS 3.5.2 as is discussed in DOC M4 and the limiting of " serial entries" as discussed in DOC M7 for ITS 3.6.6. Provide explicit exanspies. Provide this for each LCO where this example is applied. In addition, exple!c which Action of the LCO relates directly to the respective Actions A, B and C of the Example 1.3 3.
STP Response:
Generic #2 DOC L17 - CTS 4.5.6.1 JFD #5 - ITS SR 3.5.2.3 DOC A27 - CTS 4.6.2.1.a JFD #5 - ITS SR 3.6.6.4 DOC L25 - CTS 4.7.7.b and CTS 4.7.7.e.3 JFD #20 - ITS SR 3.7.11.1 & SR 3.7.11.4 DOC L20 - CTS 4.7.8.a and 4.7.8.d.3; CTS 4.9.12.a and 4.9.12.d.3
- JFD #5 - ITS SR 3.7.12.1 & 4; and ITS SR 3.7.13.1 & 4 ITS 3.5.2, 3.6.6, 3.7.11, 3.7.12 and 3.7.13 contain STAGGERED TEST BASIS requirements which have changed as a result of the adaptation of the two train STS to the three-train STP '
dasign. The CTS 1.35, STAGGERED TEST BASIS is changed significantly by the STAGCERED TEST BASIS revised definition in the STS. These changes have resulted in the identification of new freqtency intervals that can not t,e determined to match the revised STAGGERED TEST BASIS definition.
Comment: Each application of the new STAGGERED TEST BASIS definition must be evaluated to determine if it is more frequent, less frequent or the same. STP is requested to provide the following for each situation.1) State the current test cycles per train as derived directly from the CTS requirements; 2) It the specific number of days intervalis not stated, and it is in accordance with CTS 4.0.5, then state the interval from the ASME cade and ide.ntify the applicable code section.; 3) State the test cycles per train as derived directly from the STS requirements; 4) State the test cycles per train as cerived directly from the proposed ITS requirements. Using DOC L17 as an example, use the format shown on page 7 in the STPEGS February 11,1997 letter, #ST-HL-AE 5571. DOC L17 describes the addition of a fourth Train D in order to make the testing fit a 12-week cycle. A 12-week cycle is equally divisible by three as it is by four, so please explain what is this fourti. train? Please provide the instrumentation schematics which are necessary to understand the addition of Train D.
GTP Response:
STP RAl-3.5. 3.0. 3.7 Generic 1 3/4/st ENCLOSURE t _ __ _---- U
soum Texas units 1 and 3 Generic Comment Record ITs AN LCt"- "lons Generic #3 DOC A1 1 for CTS 3.5.2, Action a DOC A1-1 for CTS 3.5.6, Actions a, b, and c DOC A1-3 for CTS 3.5.6, LCO Statement JFD #5 a ad #6 for ITS 3.5.2, All Actions CTS 3.5.2 and CTS 3.5.8 have been combined into one LCO -(TS 3.5.2. ITS 3.5.2 requires three ECCS trains to be Operable. All ITS Actions refer is the inoperability of Si or RHR
" subsystems". The Bases Background discussion uses " trains" and " subsystems" interchangeably when an ECCS train appears to ba composed of components from more than one subsystem.
Comments: The use of the term " subsystems"is not distinct as the use of the term " trains",
The LCO/ Bases terminology should be changed to "ECCS train (s)" or "RHR train (s)". This is because an inoperable RHR heat exchanger in or,e RHR subsystem also makes a "Sl" subsystem flowpath inoperable. Likewise, the RHR " loop" terminology used in this LCO and elsewhere in the ITS should be clarified or RHR " trains" should be used consistently. Ahernately, the two CTS LCOs could be retained as two separate ITS LCOs inJis conversion.
STP Response:
Generic #4 DOC L21 -
CTS 4.6.2.1.c.2 and 4.6.2.3.b ITS SRs 3.6.6.5,3.6.6.6 and 3.6.6.7 DOC A9 -
CTS 4.5.2.e.1 and 2 .
ITS SRs 3.5.2.5 and 3.5.2.6 DOC M3, L22, - CTS 4.7.1.5; 4.7.1.2.1.b.1 & 2 ITS SR J.7.2.1; SRs 3.7.5.3,3.7.5.4 DOC L27; L28 - CTS 4.7.3.a.1 & 2; CTS 4.7.4.b.1,2 & 3 -
ITS SRs 3.7.7.1. 5.7.7.2; ITS SRs 3.7.8.2, 3, & 4 DOC L32; L40 - CTS 4.7.14*: 4.7.7.e.2 ITS SRs 3. i0.1 & 2; SR 3.7.11.3 DOC '.41; - CTS 4.7.P.d.2; 4.9.12.d.2 ITS SR3 3.7.12.3; 3.7.13.3 There are various CTS requirements, as identified above, which have verifications that pumps / chillers / trains or systems, actuate or start on the specified test actuation signal. ITS has changed these re:tuirements to permit credit for either an " actual or simulated" test signal be given to satisfy this test for Operability.
Comment: It is acceptable to make this ITS change; however, there are consistency issues existing in the technicaljustification for these changes that needs a uniform resolution. These identical CTS changes have been justifie6 simultaneously, at more restrictive, less restrictive __ __
and as administrative. It is proposed that DOC L21 of CTS 3/4.6.2 be used as a standard which has the following features: It is justified as less restrictive change end the specified design actuation signal is relocated to the Bases of the SR description with an "LA" DOC justification.
STP is requested to standardize each CTS change which use these features.
STP Response:
- sTP RAl.3.5,3.8,3.7 Generic .2 3/4/98
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south Tosse Units 1 and s comment Record ITs secuan 1.8. ECCs i.J-4 3.5.2, ECCS - Operating 3.5.2 1 JFD #3 STS 3.6.2, Applicability, Note #1 STS 3.5.2, Applicability, Note #1 permits both (SI) pump flow paths to be isciated by closing the isolation valves for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform pressure isolatien valve testing. The ITS deletes this note without adequate technical explanation.
Comment: Specifically explain how does STP perform PlV testing without isolating the ECCS flowpaths, without entering Actions and without the need of this exception to the LCO -
Applicability?
STP Response:
3.5.2-2 JFD #5 and #6 ITS 3.5.2 Actions A, B, C, D, F and G Comment: This is the same as Generic Comments #1 ar.d #3.
STP Response:
3.5.2-3 JFD #5 ITS 3.5.2 Action B, Completion Time and Action F The JFD #5 justification in Action B for adding "21 days from discovery of failure to meet the LCO" implies this is part of the current licensing basis which is not the case. JFD #5 should only apply to the 7 day Completion Time. The JFD #5 justification in ITS Action F implios this new-action is part of the current licensing basis which is not the case.
Cornment: Please revise the submittal to clarify the difference between the proposed new requirements and the current licer' sing basis.
STP Response:
3.5.2-4 JFD #3 STS SR 3.5.2.1 000 L4 CTS 4.5.2.a CTS 4.5.2.a lists two valves in each ECCS train which needs to have position verified every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.5.2 deletes this CTS surveillance.
Comment: it is agreed that these valves are not those valves where a misalignment of a single valve will cause the defeat of multiple trains of equipment. A misaligned valve can re-direct ECCS flow, however, away from the intended cold-leg injection flowpath to the reactor core.
south Tenas Units 1 and 2 Comment Record ITS section 3.5, EcCS s Coms STP has already been provided with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Frequency which is a relaxation from the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> required by the rnore common Westinghouse iiCCS design and the STS. With the proposed deletion of this verification, STP should ste.te specific.*y how these valves will be verified in their correct position and at what frequency. Will ITS SR 3.b.2.1, as written, appiy to these 'ype of valves? It appears both sets of these valves are not controlled in the same manner. It has been verified on the ECCS F&lD's that the three Hi;h Head Hot Leg Recirculation valves state "puwer lockout" but the three Low Head Hot Leg Recirculation isolation valves are not equally indicated.
STP should explain this difference.
STP Response:
3.5.2-5 DOC A1-2 CTS 4.5.2.b.2,4.5.2.e.1 and 2,4.5.2.f JFD #4 ITS SRs 3.5.2.1, 3.5.2.4 and 3.5.2.5 CTS 4.5.2.b.2,4.5.2.e.1 and 2,4.5.2.f have been modified to change "ECCS" to the specific names and identity of the componei ' to be tested in each ECCS train flowraths. This similar change has been made inconsistently in the ITS to SRs 3.5.2.1,3.5.2.4 and 3.5.2.5.
Comment: Because of the new ITS SR 3.5.2.3, the ITS 3.5.2.4 does not need to redundantly verify the RHR developed pump head. Also, the LCO applies to ECCS trains and the Bases l define the components !n each ECCS train. Therefore, reference to each valve in art ECCS train will apply equally to all the valves in the HHSI, LHSI and the RHR piping, it appears t'at only ITS <
l SR's 3.5.2.3 and 3.5.2.4 need specific name clarification. STP is requested to revise the submittal or otherwise explain if there is another plant specific reason to identif; .ach component differently than the STS. Please note resolution of Generic Comment #3 may affect this comment.
STP Respnnre:
3.5.2-6 DOC A1-5 CTS 3.5.6 Action b ITS 3.5.2, Action C CTS 3.5.6 Action b sistes "With two RHR loops inoperable, restore at least two RHR loops to Operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />...". ITS 3.5.2 Action C requires one rostored Operable.
Comment: This is a technical change which has been justified with en editorist DOC A1. At question, specifically, is whether two inoperable trains must both be made Operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> oris only one inoperable train to be made Operable in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. STP is requested to explain how this is currently interpreted and procedurally implemented for the CTS and provide an appropriate L DOC or exp'ain why this is not necessary.
STP Response:
~ ' ' - _ _ _ _ _ _
south Texas units 1 and t L_f Record ITs sec#en 3.8.ECCs sg (
3.5.2 7 DOC A8 CTS 4.5.2.e.1 ITS SR 3.5.2.1 CTS 4.5.2.e.1 verifies that aggb valve actuates is the correct position on an Automatic Switchover to Containment Sump test signal. ITS ER 3.5.2.4 exempts from repeated verification any valve that is locked. sealed or otherwise secured in position.
- Comment: This change is acceptable to make because it is a relaxation provided in the
' guidance of NUREG-1431. The categorization by STP is in error. This change is not an H administrative change but it is a less restrictive technical chanac because there is a reduction in 5 the number of valves positions to be checked. STP should revise the submittal and provide a revised "L" DOC.
STP Response:
3.5.2-8 DOC A9 CTS 4.5.2.e.1 and 2
- ITS SRs 3.5.2.5 and 3.5.2.6
' CTS 4.5.2.e.1 and 2 verifies that each valve actuates to the correct position on an Automatic Switchover to Containment Sump or a Safety injection test signal. The ITS SR 3.5.2.5 and SR 3.5.2.6 uses these same test signals or an actual actuation signal. -
Comment:- This change is acceptable to make because it is a relaxation provided in the guidance of NUREG-1431. The categorization by STP is in error. This change is not an administrative change but it is a less restrictive technical change. STP should revise the submittal and provide a revised "L" DOC just like the L21 for LCO 3.6.6 for the same CTS change.
STP Response:
3.5.2-9 NOT USED 3.5.2-10 NOT UE ED
__3.5.2 11 DOC A1-4 CTS 4.5.2.f ITS SR 3.5.2.4 CTS 4.5.2.f has been revised to eliminate the specific reference to test the pumps on recirculation flow. ITS SR 3.5.2.4 provides that pump performance may be verified with more accuracy at the " test flow point" with higher flows.
Comment: This technical change in the pump test requirements is justified as a " DOC A.1" which is for reformatting or editorial CTS changes. STP should revise the submittal to provide a new technical DOC justification which specifically addresses this change in pump testing requirements.
STP fUU 3.5 3.6-3 3/4/98
couth Texas Units 1 and 3 Comment Record ris section 3.8. ECCs syComs STP Response:
3.5.2 12 DOC LA4 CTS 3.5.2 and Action a CTS 3.5.0 ITS 3.5 2 CTS 3.5.2 and 3.5.6 explicitly define the components which make each ECCS train and RHR loop Operable. ITS 3.5.2 has relocated these descriptions of the Operability requiremer.ts to the Bases.
Ccmment: This relocation is acceptable; however, the text descriptions are confusing due to the comments noted in Generic Comment #3. Resolution of this Comment is dependent upon the generic resolution.
STP Recponse:
3.5.2-13 DOC A7 and L2 CTS 4.5.2 Action a ITS 3.5.2 Action D, E and F l
CTS 4.5.2 Action a prcvioes compensatory action when only one ECCS train is inoperable.
When two ECCS trains are inoperable, LCO 3.0.3 is invoked. ITS 3.5.2 adds Action D with two ECCS trains inoperable which allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore two trains Operable before going to Mode 3. ITS 3 5.2 also adds Action F with three ECCS trains inoperable which invokes LCO
3.0.3. Comment
In the CTS, the invoking of LCO 3.0.3 begir,s when two ECCS trains become inoperable rather than after three tralas are inoperable. DOC A7 is not an administrative change but a technica,I CTS change which is really pari of DOC L2. It is contractictory as presented in the l
CTS markup to justify these CTS cr. nges as both administrative and los restrictive technical, concurrently. STP is requested to delete DOC A7 and just expand DOC L2, accordingly.
STP Response:
3.5.2-14 NOT USED 3.5.2-15 DOC LA4 CTS 3.5.6 Footnote (*)
CTS 3.5.6 Footnote (*) states that valves MOV-0060 and MOV-0061 may have power removed to support the Fire Hazards Analysis Report (FHAct) assumptions. This footnote is not retained in ITS 3.5.2.
Comment: DOC LA4 discusses the relocation of the Operability requirements for the ECCS trair,s and the RHP loops. There is no specific justification for not retaining this CTS 3.5.2 sTP RAI 3.8 3.5 4 3/4/96 l
a __J
south Texas Units 1 and 2 Comment Record ITs sect 6on 3.5, ECCs systena Footnote (*). These valves are apparent!y the RHR Suction isolation valves which piotect the RHR from the higher RCS pressure. Why was this footnote placed in the CTS? Doesn't the RHR System interlock perform the same function? The Bsses apparently do not contain any discussion to explain why these RHR valves are deactivated to support the FHAR assumptions.
There is no discussion for how long these valves are deactivated and how often? STP is requested to provide a separate "LA" DOC for this CTS change.
STP Response:
3.5.2-16 DOC L17 CTS 4.5.6.1 ITS SR 3.5.2.3 Comment: This is the same as Generic Comment #2.
STP Response:
3.5.2-17 JFD #3 STS SR 3.5.2.7 The ITS has not adopted SR 3.5.2.7 based on JFD #3.
Comment: It is assumed from JFD #3 that there aro no ECCS throttle valves in the STP design.
Verify if this assumption is correct.
STP Response:
l 3.5.2 18 ITS 3.5.2 Actions CTS 3.5.2 Actions CTS 3.5.6 Actions CTS 3.5.2 & 3.5.6 provide Actions for the Safety injection and RHR Systems. ITS 3.5.2 Actions combine these requirements into one LCO.
Comment: ITS 3.5.2 does not contain Conditions for various combinations of Safety injection and RHR Systems inoperaole. As written, each applicable individual Condition would be entered for any combination. Was this the intention? If so, what was the purpose of combining these systems into one LCO?
STP Response:
sTP RA13.6 3.54 3/4/98 ms . d
South T&as Units 1 and 2 Comment Record ITS Section 3.6, Contelnment Systems 3.6.6, Containment Spray and Cooling System 3.6.6-1 JFD #11 ITS 3.6.6, Action A and B, Completion Times DOC M7 CTS 3.6.2.1 Action a and CTS 3.6.2.3 Action a Comment: This is the same as Generic Comment #1. .
STP Response:
3.6.6-2 JFD #5 ITS 3.6.6 Condition B, Note DOC A23 CTS 3.6.2.3, LCO Statement CTS 3.6.2.3 states "Three independent groups of RCFCs shall be Operable with a minimum of two units in two groups and one unit in the third group." The following note is added to ITS 3.6.6 Condition B: "One RCFC fan of one RCFC train may be removed from service without entering Condition B for that train. If more than one RCFC fan is removed from serv;ce, appropriate condition (s) must be entered."
Comment: The retention of this CTS requirement is acceptable. However, the following rewording is proposed to the Note: "One RCFC f an of one RCFC train may be removed from service without entering Condition B for that train, if more than one RCFC fan is removed from service, enter applicable appropria:; Conditions and Required Actions." This is censistent with other Action table notes in the STS.
STP Response:
3.6.6-3 ITS 3.6.6 Actions CTS 3.6.2.1 Actions CTS 3.6.2.3 Actions CTS 3.6.2.1 & 3.6.2.3 provide Actions for the Containment Spray System and the RCFCs.
ITS 3.6.6 Actions combine these requirements into one LCO.
Comment: ITS 3.6.6 does not contain Conditions for various combinations of containment spray trains and RCFCs inoperable. As written, each applicable individual Condition would be entered for any combinction. Was this the intention? If so, what was the purpose of combining these systems into one LCO?
STP Response:
a l
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a south Tnmes ursts 1 and 2 Comment Record ris section 3.6, f'yteinment systems
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3.6.6-4 NOT USED
-3.6.6 5 JFD #12 ITS 3.6.6 Action F DOC A26 ITS 3.6.6 Action F has been modified to replace the "Any combination of three or more trains inoperable" with "Three RCFC trains inoperable."
Comment: DOC A26 is not a single administrative CTS change, it contains multiple of technical CTS changes which are inadequately justified. It appears that being in Condition C and Condition D simultaneously is equally or more degraded than the new ITS Action F Condition statement. Adopting the STS Action F Ccndition statement, as is, prsvents four trains of the six total Containment Spray and Cooling trains being inoperabis. STP is l requested to explicitly state the percentage of cooling capacity remaining, as each train and combinations of trains are assumed unavailable, untilloss of function exists as defined by the safety analysis nf record.
STP Response:
3.6.6-6 JFD #5 l ITS SR 3.6.6.4 I
DOC A27 CTS 4.6.2. I,b CTS 4.6.2.1.b requires verification on a Staggered Test Basis of the listed performance features of the CS pump. ITS SR 3.6.6.4 verifies these performance requirements in accordance with the IST Program.
Comment: This is the same as Generic Comment #2. Also, the testing of the CS pump et the " required developed head" is a technical CTS change and not administrative. STP is L requested to provide a specific technical justification for this change.
STP Rwsponse:
3.6.6-7 JFD #3 ITS SR 3.6.6.5 ITS SF'. 3.6.6.5 verifies if each automatic containment spray valve in the flowpath actuates to the correct position. The ITS has not adopted the phrase which exempts any valve "that is not locked, sealed, or otherwise secured in position".
Comment: The JFD #3 justification is not sufficiently explicit to explain why this phrase la nD1 applicable for STP in ITS SR 3.6.6.5 while it is applicabh for ITS SR 3.6.6.1. STP is requested to provide this additional detailed explanation.
STP Response:
soum re unne i and a conwn.nin.cors Ts section s.o. cone.inm.ni syn.m.
3.6.6-6 DOC A1-1 ~
CT S 3.6.2.1 and CTS 3.6.2.3 ITS 3.6.6 and Bases CTS 3.6.2.1 and CTS 3.6.2.3 require the " independence" of the Containment Spray System (CS) and the RCFC groups in the LCO Statements. ITS 3.6.6 does not retain the
" independence" requirements in the LCO statement but relocates this to tiie Bases where -
the LCO Operability requireroents are established for the respective CS and RCFC trains.
Comment: It is acceptable to make these changes; however, the DOC A1-1 Justification is inadequate when this should be an "LA" DOC. (For reference, see Section 3.7 DOC LA.8 for similar situation.) STP is requested to revise the submittal to provide a new 1 justification.
STP Response:
3.6.6 9 NOT USED 3.6.6 10 NOT USED
! 3.6.6-11 DOC LAll CTS 4.6.2.1.b, c.1, c.2, and d CTS 4.6.2.3.a CTS 4.61.1.b, c.1, c.2, d, and CTS 4,6.2.3.a contain details for how the CTS surveillance requirements are to be performed which are better ulocated to the Bases, in most cases, these requirements have been relocated to the r i.6 Bases.
Commant: It is acceptable to relocate the detas for how to perform the CTS aurveillance requirements to the ITS 3.6.6 Bases. DOC LA11 only justifies the relocation of the
' definition of the components and features for Operability of the Containment Spray and Cooling Cystem. STP is requested to revise the submittal and provide a new "LA" DOC for-relocating these CTS surveillance requirement deteils to the Bases. . in addition, CTS 4.6.2.1.c.2 does not relocate the portion of the CTS requireinent stating " coincident with a sequencer start signal" to the Bases for ITS SR 3.6.6.6. Also, CTS 4.6.2.3 does not relocate the entire portion iridicated as moved to the Bases of ITS SR 3.6.6.2. Please modify the Bases to account for these discrepancies or justify their de.etion from the TS.
STP Response:
3.6.6-12 DOC L21 CTS 4.6.2.1.c.2 and 4.6.2.3.b ITS SRs 3.6.6.5 and 3.6.6.6 Comment: This pertaine to the " actual or simulated test signal" issue of Generic Comment
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e STP Response:
3.6.6 13 DOC LA15 CTS 4.6.2.1.c ITS SRs 3.6.6.5 and 3.6.6.6 CTS 4.6.2.1.c requires various verifications performed "during sliutdown" which ITS 3.C.6 has not retained as a specific requirement.
Comment: It is acceptable to not state this specific requirement in the ITS 3.6.6; however, DOC LA15 states the CTS requirement is relocated to the Bases. A cursory review of the Bases does not show this requirement has been relocated. Please revise the submittalin accordance with DOC LA15 or direct the staff to the appropriate Bases location.
STP Response:
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