ML20212G855
| ML20212G855 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 09/08/1997 |
| From: | Kelly G NRC (Affiliation Not Assigned) |
| To: | Leslie Liu IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| References | |
| TAC-M97197, NUDOCS 9711070137 | |
| Download: ML20212G855 (90) | |
Text
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Septctbar 8, 1997
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'* ^ Mrs Lee Liu .
Chairman of the Board 4 and Chief Executive Officer IES Utilities Inc. '
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E 200 First Street, SE, ' '
P.O. Box 351
' Cedar Rapids, IA 52406-0351
SUBJECT:
DUANE ARNOLD ENERGY CENTER (DAEC)- REQUEST FOR ADDITIONAL INFORMATION (RAI) ON THE DAEC IMPROVED TECHNICAL SPECIFICATIONS ('TS) (TAC NO. M97197)
Dear Mr. Liu:
On October 30,1996, IES Utilities Inc submitted a request for a license amendment j; to conve:1 *he DAEC Technical Specification:: to iTS. The staff requires additional information (RAl) in order to complete its review. The staff requests that you provid: a response to the enclosed questions within 30 days to meet the staff's review schedule.
Because of time constraints and staff resource limitations, the staff is transmitting these RAls
' although they are not as precise as normally would be expected. The enc!osed questions cover Sections 3.0, 3.1, 3.2, 3.5, and 3.8.
Sincerely, ORIGINAL SIGNED BY:
Glenn B. Kelly, Senior Project Manager Project Directorate 111-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosures:
As stated cc w/encls: See next page {smus G9 Mf %au-F @ m d[d@a %
Distribution:
< J Docket File J P PUBLIC PDIII-3 R/F EAderisam (EGAl) JCaldwell, RIII ACRS OGC,015B18 GMarcus m
G:\DUANEARN\97197RAI.WPD a
OFFICE PM:PDlII-3 -lE LA:PDill-3 l E NAME GKelly 7y;( CBoyle c4 hh fh h h 1hh DATE r/f/97!
1 '1// /97 1/2cnh(
- OFECIAL RECORD COPY I
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Les Liu Duane Arnold Energy Center d
IES Utilities Inc.
cc:
Jack Newman, Esquire Kathleen H. Shea, Esquire Morgan, Lewis, & Bocklus 1800 M Street, NW.
Washington, DC 20036-5869 Chairman, Linn County Board of Supervisors i Cedar Rapids,IA 52406 IES Utilities Inc.
ATTN: Gary Van Middlesworth -
Plant Superintendent, Nuclear 3277 DAEC Road Palo, IA 52324 John F. Franz, Jr.
Vice " resident, Nuclear Duane Arnold Energy Center -
3277 DAEC Road Palo,IA 52324 v
- Ken Peveler Manager of Regulatory Performance Duane Arnold Energy Center 3277 DAEC Road Palo,IA 52324 U.S. Nuclear Regulatory Commission Resident inspector's Office Rural Route #1 Palo, IA 52324
~ Regional Administrator, Rlli U.S. Nuclear Regulatory Commission
- 801 Warrenville Road Lisle, IL 60532-4531 Parween Baig Utilities Division lows Department of Commerce Lucas Office Building, 5th floor
' Des Moines, IA 50319
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DUANE ARNOLD ENERGY CENTER j
ITS 3.0 LCO Apphcability & SR Applecatwhty s
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ITEM DOC ore CTS /STS.{ , Description of. Issue 7 y~e <
COMMENTS ' n.1 . ' STATUS /
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! 3.0 JFD P1. STS LCO 3.0.3 JFD P1 provides justification for Your 10/30/96 transmittal letter stated OPEN .
.I extending the LCO 3.0.3 ^ that this change had beer determined to
- } completion time to reach Mode 2 ' be potentially genenc and that a . ;
- i. from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />. proposed Traveler had been submitted to t
the BWROG. What is the status of the j
- BWROG review of the proposed
l Traveler? Also, JFD P1 stated that part i of the reason for requesting the i extensior, was based on review of three l controiled shutdowns in 1993 & 1994. i What has been your experience with i controlled shutdowns between 1994 & !
the present? Do you have addstional data to support the position that 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> 1
- to reach Mode 2 is not long enough, [
either from DAEC or other plants?
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DUANE ARNOLD ENERGY CENTER ITS 3.0 LCO Applicatnhty & SR Applicabikty ,
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- ITEEIS DOC orl : CTS /STSi K Description b!iss,ue 1 4 ~ COMMENTS; i ; ! =STATUSI' '
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- 3.0-2 JFD P2 STS LCO 3.0.4 - JFD P2 notes that the reviewer's Has the review descnbod in the subject OPEN ;
& SR 3.0.4 notes associated with STS LCO reviewer's notes been performed? If so,. -
3.0.4 & SR 3.0.4 have been What were the results? If not, why not?
deleted. These rav s..;.'s notes 4
indicate that, before the STS l version of LCO 3.0.4 & SR 3.0.4 ;
1 ; can be implemented on a plant- i specific basis, the licensee must .
review the existing TS to i
determine where specific .j restrictions on Mode changes or i
Regtired Actions should be I included in individual LCOs to justify the changes.
3.0-3 DOC A5 STS LCO 3.0.6 DOC A5 describes the addition of The staff does not agree that the OPEN ;
the provisions in STS LCO 3.0.6 addition of the provisions in LCO 3.0.6 i to the ITS. No equivalent is an administrative change. Under the i provisions exist in the CTS. The CTS, anytime a support system 1 LCO 3.0.6 provisions provide inoperatnisty also made a supported 2
guidance regarding the system inoperable, actions would have appropriate actions to be taken to be taken under the specifications for !
when a single inoperabihty (e.g., both systems. These are less restrictive support system) also potentially changes.
results in the inoperatzkty of one i or more related systems (e.g., .t supported systems). DOC AS-also states that this new provision is deemed to be administrative in nature.
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DUANE ARNOLD ENERGY CENTER '
ITS 3.0 LCO Applicabikty & SR Appkcabikty ew 7, ,.
.x A; :COMMENTSIAM!
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DOC or! CTS /STS ;- Description of issuei "~L ITEM :. -
'; STATUS*'1 fu
JFDF::= LCO? - - '
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3.0-4 DOC R1 CTS Definition 26 contains a DOC R1 provides no justification as to Definitioa 26 statement that it is not intended why it is acceptable to relocate this that the 25% extension to provision to the Bases. The DOC merely '
perform SRs be useo repeatedly descnbes what the change is an not as a converwence to extend non- why it is acceptable.' Please revise DOC outage related Surveillance R1 to provide a justification for the intervals. DOC R1 states $st change.
this type of descriptive material is not in the ITS and is relocated to-the Bases.
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4 DUANE ARNOLD ENERGY CENTER ITS 3 5.1 ECCS-Operating ITEM # , DOC or- CTS /STS Description of issue , COMMENTS S STATUS JFD# ' LCO 3.5.1-1 L1 CTS 4.5.A.1.a The referenced CTS SRs require This change is beyond the scope REJECTED CTS 4.5.D.1.s testing of the CS, LPCI, & HPCI of the conversion to the STS and open l
CTS 4.5.D.1.d subsystems. The corresponding does not appear to be an issue pending P24 STS SR 3.5.1.3 ITS requirements are contained in that is specific to DAEC. The submittal
- P23 STS SR 3.5.1.10 SR 3.5.1.5 & SR 3.5.1.7. These staff does not agree that it is revision l
SRs have been modified by a necessary to include these notes .
! Note (not contained in the STS) in the subject ITS SRs. The I that allows delaying entry into current Completion Times for the the Conditions & Required ECCS subsystems provide more Actions for a number of hours than adequate time to perform during performance of the SRs. the tests. The staff believes that DOC L1 states that these notes it is generally not prudent to call reflect DAEC operating practice equipment operable when it is, in and are necessary because the fact, inoperable. This issue is not subject SRs render the ECCS specific to DAEC, and therefore, subsystems inoperable for a should be pursued on a generic -
period of time. This change is basis. Please revise your less restrictive than the CTS and submittal to delete these nc;es less restrictive than the STS. from the ITS.
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]COMMENTSltf I% MSTATUS.I ,
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3.5.1-2 L10~ CTS 3.5.A.3. DOC L10 states that a note This change is beyond the scope REJECTED l P19 STS SR 3.5.1.2. clarifying alignment requirements of the conversion to the STS and open -
of the LPCI subsystem has been. does not appear to be ar issue pendmg included in ITS SR 3.5.1.2. The that is specific to DAEC. De : submettal , :l Note provides an allowance . staff does not agree that it es revision
- delaying entry into the Conditions necessary to include these notes -
! & Required Actions for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in the subject ITS SR. The !
l durmg performance of the SR or current Completion Twne for the +l j when operating in the RHR LPCI subsystem provides more ;
suppression pool cochng mode. than adequate time to perform j DOC L10 states that this note. the tests & operations. - The staff 1 reflects the CTS " philosophy" o.f believes that it is generally not not entering Actions during prudent to call equipment testing. This change is less' operable when it is, in fact,-
. rertrictive than the CTS and less inoperable. This issue is not .
restrictive than the STS. specific to DAEC, and therefore, .i should be pursued on a generic bases. Please revise your !
submittal to delete these notes j from the ITS..- .
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DUAME ARNOLD ENERGY CENTER .
4 - ITS 3.5.1 ECCS-Operating -
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ITEM #f : DOC'or:t, lip Q' l& Ci n .'ptk,. ofissue 4 7{ ; (COMMENTSA M% JSTATUSi j ED#X W CTS LCOO/S"V^
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4 7- N'%1 + M~ -s u 4 i 3.5.1-3' R5 CTS 4.5.A.3.e' The CTS require visual inspection DOC R5 states that the CTS OPEN j to ve6ify that RHR valve panel requirement was based on the -!
lights & instrumentation are fact that the RHR valve power ;
functionally normally. DOC R5 bus is not instrumented. The provides a justification for DOC goes on to state that ITS SR :
. , relocating this requirement to 3.5.1.7 includes a test of the - 1
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plant procedures. power-seeking logic of the LPCI ,!
,j swing bus. The DOC also directs i '
the reader to reference ITS SR i } 3.5.1.2 for valve line-up j i! verification. The relationship between all of these items is not 1 obvious to the reader. Please t provide additional explanation as to how ITS SRs 3.5.1.2 & -
3.5.1.7 relate to the CTS i requirement being relocated. '!
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Include this as further l justification in DOC RS. j i
3.5.1-4 L2 CTS 3.5.A.4 " DOCS L2 and P4 discuss the This change is beyond the scope REJECTED !
CTS 3.5.A.5 addition of Action C which of the conversion to the STS and open P4- STS 3.5.1 Actions establishes a Condition, Required does not appear to be an issue - pending '2 Actions, & Completion Times for that is specific to DAEC. submittal one inoperable core spray Therefore, please revise your - revision subsystem in combination with submettal to delete Action C.
one or two inoperable RHR pump {s). . This change is less restrictive than the CTS and less ;
restnctive than the STS. '!
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DUANE ARNOLD ENERGY CENTER l ITS 3.5.1 ECCS-Operating ITEM #f ~ $3C $rQ" ~CTS /STS 'g I Description of issue ' .
c u iCOMMENTS
.' : STATUS JFD# "
LCOe -S-3.5.1-5 L3 CTS 3.5.A.2 DOCS L3 and P4 discuss the This change is beyond the scope REJECTED P4 STS 3.5.1 Actions addition of Action D whech of the conversion to the STS and open establishes a Condition, Required does not appear to be an' issue pending Actions, & Completion Tunes for that is specific to DAEC. subnuttal1 two inoperable core spray Therefore, please revise your , revision subsystems.. This change is less subnuttal to delete Action D.
restnctive than the CTS and less restnctive than the STS.
i 3.5.1-6 P21 STS Condition H DOC P21 discusses a change to Since the staff has rejected the REJECTED
- N) to add the phrase "for reasons D, please revise current ITS pendmg other than Condition C or D* to Condetson N accordmgly. sutwrwttal the first half of the Condition. reviseon 3.5.1-7 L9 CTS 4.5.A.1.d DOC L9 desenbes changes to the The technical staff is reviewing OPEN CTS 4.5.A.3.d acceptance criteria for ECCS the acceptabelsty of these pendeng CTS 4.5.D.1.d subsystem flow tests based on changes. Additional questions technical CTS 4.5.D.1.e analysis contamed in the DAEC may follow related to these staff SAFER /GESTR-LOCA analyses. changes. resolution -
3.5.1-8 L6 CTS 3.5.D.2 DOCS L6 and P4 discuss the This change is beyond t' e scope REJECTED P4 STS 3.5.1' Actions addition of Action G which of the conversion to the STS and - open establishes a Condition, Required does not appear to be an issue pending Actions, & Completion Times for that is specific to DAEC. subnwttal -
one inoperabee HPCI subsystem Therefore, please revise your- revision in combmetion with one . submittal to delete Action G.
inoperable RHR pump. This change is less restrictive than the CTS and less restrictive than the STS.
4 August 27,1997
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' ITS 3.5.1 ECCS-Operating I
- ~ NN ITEM'#hj DOC or[ ' C T S fS i b j"".. J~ Description of IssueI V " [ COMMENTS QSTATUS?
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3.5.1-9 L7 CTS 3.5.D.2 DOCS L7 and P4 discuss the Since the staff has rejected the ' REJECTED P3 STS 3.5.1 Actions addstion of Action H which addition of current ITS Condmon open ;
establishes e Condition, Required G, please revise current ITS pendmg Actions, & Completion Tunes for Condetion H to delete the phrase' submsttal one inoperable HPCI subsystem "for reasons other than Condition revision
,. in combination with one low A"in the second half of the l pressure ECCS subsystem inoperable for reasons other than Condstoon.
j
- Condition A.
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i 3.5.1-10 L8 CTS 3.5.D.2 DOCS L8 and P4 descuss the This change is beyond the scope RElECTED P4 STS 3.5.1 Actions addition of Action I which of the conversion to the STS and - open establishes a Condition, Required does not appear to be an issue pending Actions, & Completion Twnes for that is specific to DAEC. submittal one inoperable HPCI subsystem Therefore, please revise your revision in combmetion with one submittal to delete Action I.
inoperable ADS valve. This -
change is less restrictive than the CTS and less restrictive than the STS. ,
3.5.1-11 P7 STS 3.5.1 Actioris DOC P7 describes the addition of Since the addition of Conditions - OPEN Action J to ITS 3.5.1 for the . G and I have been rejected by the Condition when the Required staff, please revise Condition J -
Action and associated .
accordmgly.
Completion Twne of Condition F, .
G, H or I are not met.
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'?*? COMMENTS
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, 3.5.1-12 P3 STS Condition F - COC P3 discusses the' addition of This change is beyond the scope REJECTED i
open
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.. the phraseL"for reasons other of ttw conversion to the STS and than Condition A" to the second does not appear to be an issue pending half of STS Condition F (current that is specific to DAEC. .. sutettal ITS Condition L).' This change is Therefore, please revise your revision less restrictive than the CTS and submittal to delete the phrase j
less restrictive than the STS . added in current ITS Condition L.
I because the proposed change j would allow 30 days for the i combination ci one inoperable ADS valve and one inoperatJe RHR pump.
.l 3.5.1-13 P8 STS Condition H DOC PB discusses changes to Sence the staff has rejected the REJECTED STS Condition H (ITS Condition - other changes upon which this ~ open N) based on the addition of other change is based, please revise pending Conditions to the STS. current ITS Condition N to delete - submittal all changes made to the STS revision wording under DOC P8.
3.5.1-14 unknown CTS 4.6.D.3 The markup of CTS 4.6.D.3 DOC A7 does not appear to be" OPEN identifies a change in the related to this enange. Please frequency for manually operation provide a corrected DOC' of relief valves from "once per reference for the change.
OPERAT'NG CYCLE"in the CTS to "24 months" in the ITS. DOC A7 is referenced for this' change as it relates to ITS 3.5.1. _
6 Ausuet 27,1997 ~
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' ITS 3.5.1 ECCS-Operating 3l *s W ny " "c < . . <, . .
(BOD.fitg. : CTS /STS# r'1 : Dew.4t;on of issue ( .
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ITEM #.?' < COMMENTSL _ 3, . STAWS '
e<-=J.; JFD# N 'LCOi ~ : i ~. 1~ 'i - l t
3.5.1-15 1.,2 - various DOCS ic & Ic.: describe These changes are currently OPEN J ly., - changes to various CTS under review by the technical surveillance frequencies to staff. Additional questions accommodate a 24-month fuel related to these changes may '[
cycle, follow. i ll 3.5.1-16 N/A ITS 3.5.1 There appears to be an Please make the approporiate OPEN :!
li changes to ensure consistent use
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inconsistent use of the terms l subsystem and system when of ei*ber the term subsystem or referring to LPCI. For example, system when referring to LPCI to the majority of uses in ITS 3.5.1' avoid confusion.- 1 refer to the LPCI subsystem, however, SR 3.5.1.2, Note 2 ;
refers to the LPCl System, even though the Note directly i preceding it refers to the LPCI subsystem. Also, changes have been made to the STS Bases to change from the use of subsystem to using system when :
referring to LPCI. 1 i
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ITS 3.5.1 ECCS-Operstmg
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ECOMMENTS9;MP.
ITEM #? DOC orf , iCTS/STS & Description,of issue)r M' c. tSTATUSj LCO O E?E MJ ~ h ' ~
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3.5.1-17 Bases P8 Bases for Bases DOC P8 discusses the The staff does not agree with REJECTED :
STS SR 3.5.1.2 addition of inserts to the Basss your interpretation of the intent open discussion for STS SR 3.5.1.2. of this SR as exemphfied in the'- pendmg ,
The mserts include statements - referenced Bases additions. The' submittal
, that the SR does not apply to staff is unsure of what is meant revisoon valves that are temporarily by the statement that " accidents -
shgned in the nonaccident are assumed to not occur when i positen and under approporiste systems are in secondary modes
! administrative and procedural .of operation." .The staff does not controls and that this is see the tie between the likehhood .!
acceptable since accidents are of an accident and the aligriment '
assumed to not occur when of a particular system. Also, the systems are in secondary modes staff does not agree that systems .
of operation. DOC P8 states that not capable of meetmg their this insterpretation is consistent intended safety' function (e.g.,
with the DAEC CLB. with valves rmsabgned) would be '
considered opercble under your-CTS. . Please revise your .
submittal to delete the referenced Bases additor s.'
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DUANE ARNOLD ENERGY CENTER ITS 3.5.2 ECCS - Shutdown
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ITEM #:! DOCN'l CTS /STSl Descriptio.1 M issue : ' -
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3.5.2-1 L4 CTS 3.5.G The referenced STS SR requires The staff does not agree that it is REJECTED. ,
P23 STS SR 3.5.2.6 testing of the CS & LPCI necessary to include these notes open subsystems. The corresponding in the subject ITS SRs. You state pending ITS requirement is contained in in DOC L4 that when LPCIis submittal SR 3.5.2.6 and has been tested, the ECCS function is - revision modified by a Note (not maintained by the two CS l contained in the STS) that subsystems and when a CS allows delaying entry into the subsystem is tested, the ECCS Conditions & Required Actions function is maintained by LPCI
! for a number of hours during and the other CS subsystem.
performance of the SR. DOC L4 This same logic would say that states that these notes reflect - the proposed note is not DAEC operating practice and are necessary given that ITS 3.5.2 necessary because the subject only requires two subsystems be SRs render the ECCS subsystems operable. Also, the staff believes inoperable for a period of time. that it is generally not prudent to call equipment operable when it is, in fact, inoperable. This issue is not specific to DAEC, and therefore, should be pursued on a generic basis. Please revise your submittal to delete the note from ITS SR 3.5.2.6.
1 August 27,1997
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'I '3.5.2-2 Bases P8 Bases for Bases DOC P8 discusses the . The staff does not agree with REJECTED STS SR 3.5.2.4 addition of inserts to the Bases your interpretation of the intent ~ open discussion for STS SR 3.5.2.4. of this SR as exempkfied in tFa; pending .
The inserts include' statements referenced Bases addstions. The submittal that the SR does not apply to staff is unsureof what is moent revision valves that are temporarily by the statement that " accidents abgned in the nonaccident are assumed to not occur when position and under cpproporiste systems are in secondary modes administrative and procedural of operation." The staff does not controls and that this is'- see the tie between the likehhood acceptable since accidents are of an accident and the alignment.
1 assumed to not occur when of a particular system. Also, the -
systems are in secondary modes staff does not agree that systems of operation. DOC P8 states that not capable of meeting their; this ineterpretation is consistent intended safety function (e.g.,
with the DAEC CLB. with valves misaligned) would be ' u considered operable under your CTS. Please revise your. ~
submittal to delete _the referenced
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DAEC NUREG MARKUP e; 3.8.3 3.8'.3 DOC #3 , CTS /STS DESCRIPTION OF IS3UE C0tt1ENTS . 1 STATUS-1 ISSUE: or - @ REF.
l #- JFD # 4 1 FJ7 LCO 3.8.3 Change P37 includes reTerence The licensee should DATE
, Condition C to a periodic test for revise the submittal. OPENED i viscosity, water, and to address staff 8-11-97 l
sediment as a justification concerns.
i for increasing the corrpletion l
time for Required Action C.1 4 from 7 days to 30 days. The staff questions whether a test for water a d sediment (by centrifuge) will provide any meaningful data regarding the particulates addressed by Condition C and SR 3.8.3.3. j The licensee should expand !
this discussion to address the staff's question./ In the interim. the staff concludes that the proposed completion time extension is not adequately justified and is, therefore, rect acceptable. l
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- STATUS 3.8.3 J DOC f ~ CTS /STS?
DESCRIPTIONOF(ISSUE 1 '
C0lmENTSt ISSUE:- orc REFs~
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- JFD # -
2 P43 LCO 3.8.3 Change P42 is inconsisten: The licensee should DATE.
P43 Condition E with other sections of the provide additional OPENED proposed ITS wherein the term justification, or . 8-11-97
" required" is deleted. 'The revise the sutaittal discussion provided does not to address staff provide any insight as to why concerns.
this inconsistency is necessary or desirable. The licensee should provide an adequate justification for the change. or delete-it.
3 P42 SR 3.8.3.4 Change P42.is inconsistent- The licensee should DATE.
with other sections of the provide additional OPENED proposed ITS wherein the term justification, or 8-11-97 ,
" required" is deleted. The. revise the submittal-discussion provided does not to address staff.
provide any insight as to why concerns.
this inconsistency is .
necessary or desirable. The
' licensee should provide an adequate justification for the change. or delete it. .
,1./ '
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- - - - - - - m___
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l'3.8.3' DOCT CTS /STSi DESCRIFT10 EOF) ISSUE._ C0leENTS STATUSi ISSUE orJ : REFT l #' JFD #:
4 P26 SR 3.8.3.5 Change P26 appears to The licensee should DATE
- indicate a misunderstanding revise the submittal OPENED of this NUREG SR. This SR is to address staff 8-11-97 intended to check for free concerns.
water in the bottom of the tanks where it provides en ,
environment for the growth of aerobic and anaerobic bacteria. Growth of these bacteria causes fouling of the fuel oil which can easily
- cause engine failure, and ;
tank' corrosion. This " free" l water will not show up in the l' periodic tests for water and sediment in fuel oil. This SR should be reviewed and revised as necessary, to address the above concerns.
l 3
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.s DUANE ARNOLD ENERGY CENTER ITS 3.5.3 RCIC System
" escription of Iswe ITEM # ^ . DOC or CTS /STSi <
COMMENTS STATUS JFD# - LCO ' '
~
~
3.5.3-1 L1 CTS 4.5.E.1.s The referenced CTS SR requires This change is beyond the scope REJECTED P23 STS SR 3.5.3.5 testing of the RCIC System. The of the conversion to the STS and open corresponding ITS requirement is does not appear to be an issue pending contained in SR 3.5.3.5. This SR that is specific to DAEC. The submittal has been modified by a Note (not staff does not agree that it is revision I
contained in the STS) that necessary to include the note in allows delaying entry into the the subject ITS SR. The current Conditions & Required Actions Completion Time for the RCIC l for a number of hours during System provides more than
- performance of the SR. DOC L1 edequate time to perform the states that this note ref!ects test. The staff believes that it is DAEC operating practice and is generally not prudent to call necessary because the snbject equipment operable when it is, in SR renders the RCIC System fact, inoperable. This issue is not inoperable for a period of time. specific to DAEC, and therefore, '
I This change is less restrictive should be pursued on a generic thaa the CTS and less restrictive basis. Please revise your than the STS. submittal to delete this note from ITS SR 3.5.3.5.
3.5.3-2 6 CTS 4.5.E.1.a DOCS le, & Ley.2 describe These changes are currently OPEN Ley. CTS 4.5.e.1.e changes to various CTS under review by the technical surveillance frequencies to etaff. Aiditional questions accommodate a 24-month fuel related . e these crianges may cycle. follow.
1 August 27,1997
. , ni i l MMM
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F DUANE ARNOLD ENERGY CENTER
e .. "
- STATUS--
ITEM s : DocoC.. -CT8/STS OsW- Description by , 11 '^ '"
of issue ?.
g<
E-( 1 COMMENTS '
i LCO2 -
3.5.3-? Barns P8 - Bases for Bases DOC P8 descusses the The' staff does not agree with REJECTED STS SR 3.5.3.2 addition of inserts to the Bases your interpretation of the intent open discussion for STS SR 3.5.3.2. of this SR as exempkfied in the pendmg The inserts include statements referenced Bases additions. The - sutettal ~,
that the SR does not apply to staff is unsure of what is meant revision valves that are temporanly by the statement that
- accidents elegned in the nonaccident are assumed to not (I. cur when j position and under approporiete systems are in secondary modes I l
administrative and procedural of operation." The staff does not
, controls and that this is see the tie between the likelihood acceptable since accidents are of an accident and tiae alignment
~
assumed to not occur when of a particular system. Also, the systems are in secondary modes staff does not agree that systems of operation. DOC P8 states that not capable of iTw.;;i.y their. -
this ineterpretation is consistent intended safety function (e.g.,
with the DAEC CLB. with valves misalogned) would be considered operable under your CTS. Please revise your .
sutettal to delete the referenced L Bases additions.
2 August 27,1997 l
l t _ _ _ _ _ _ _ _ - _ _ _ _ -
I stk. 2sfq7 DAEC I
NUREG MARKUP 3.B.1 3.8.1" DOC #: CTS /STS' DESCRIPTION OF ISSUE - COPMENTS - STATUS ISSUE orL ; REF:
JFD f-
! 1 P41 LC0 3.8.1 Change P41 would add a Note to This change is DATE the Actions for one DG beyond the scope OPENED ing erable if the cause of the of the ITS 8-8-97 inoperability is Core Spray conversion. ,
testing. This proposed change '
is beyond the scope of the ITS conversion. Note: Discussion P41 will have to be revised if this change is to be acceptable when reviewed outside of the ITS - ,
conversion. The discussion will have to include a reason for why
- not entering the DG Actions is considered a safety enhancement.
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3.8:1 DOC 'i CTS /STS DESCRIPTION OF ISSUE- COM NTS STATUS-ISSUE or . REF 4'
- JFD #- ;-
2 P2 Action A.2 The staff does not agree with The licensee DATE l proposed change P2. The CTS should revise the OPENED l require two offsite circuits submittal to 8-8-97 whenever the plant is not in address staff Cold conditions: 1.e. Mcdes 4 & comments.
3
- 5. The wording of the proposed completion time should De " prior to entering Mode 3 from Mode 4" as opposed to " prior to entering Mode 2 from Mode 3." In '
addition, the proposed Completion Time of Action A.2 is an exce) tion to the LC0 applica>ility that is inconsistent with NUREG-1433 and instructions regarding its use.
- Addition of a Note to Required Action A.2 stating that LCO 3.0.4 is Not Applicable does not
- appear to be acceptable. LCO 3.0.4 ap) lies to Mode changes wher, an _C0 is not. satisfied, and not to individual Required Actions within that LCO.
2 e-7m - W- +*1 w- w - - e.- .g- . - , -e- - ,_, , . , ,
. -j DAEC NLREG MARKUP ,
3.8.1 1 3.8.1: DOC:#3 CTS /STSi DESCRIPTIONOFLINSUE:
COPMENTS STATUS ISSUE ori . L REFx ' . . .
i 1 JFD #-
3 P49 SR 3.8.1.2 The staff does not agree with The licensee DATE
- change P49. SR 3.8.1.7 has should revise the OPENED
different acceptance criteria submittal to 8-8-97 than SR 3.8.1.2. and it is not retain the Note. .!
obvious that SR 3.8.1.7 will satisfy SR 3.8.1.2 without the Note. The proposed change is 1 further confusing because without the Note and following -
the licensee *s philoso ty. it could be interpreted t1at SR' ,
. 3.8.1.2 will satisfy the ,
requirements of SR 3.8.1.7.
This, of course, is not the case.
l 4 P32 SR 3.8.1.2 Change P32 is a generic issue This' change is DATE that is beyond the scope of the beyond the scope OPENED- .:
ITS conversion. The issue . of the ITS 8-8-97 i should be addressed by the OGs conversion; ;
as'a generic change to the '! :
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3.8.1- DOC # CTS /STS? DESCRIPTION OF ISSUE f 4 'COMENTS STATUS-ISSUE- or REF. #
- JFD #
5 P11 SR 3.8.1.2 The steff does not agree with The license should DATE Change P11. Including revise the OPENED acceptance criteria in the SR submittal to . 8-8-97 eliminates any confusion that address staff could arise as a consequence of comments.
the necessity to look in two or more places to obtain a complete understanding of the SR. Also.
as a practical matter. placing the acceptance criteria in the Bases has no advantages because any changes to the values are sure to trip the Bases Control criteria which would mandate a license amendment. anyway. This change should be deleted and the voltage and frequency acceptance criteria stated in the SR.
4
- 3.8.1
- DOC Yi CTS /STSi DESCRIPTION OF ISSUE COPMENTS - STATUS
- ISSUE- or . . REF-j # JFD #
6 P32 SR 3.8.1.3 Change P32 ia generic issue that The licensee DATE P11 is beyond the scope of the ITS should revise the OPENED !
I conversion. See issue 4. above. submittal to 8-11-97 address staff
- Change P11 is Not Acceptable. concerns.
The proposed language (greater
- than the assumed accident load) t is a change from CTS requirements (rated load) that has not been justified. The licensee should inc %de the applicable load ranse in the SR.
or use the CTS terminology
" rated load". The staff recomends including the applicable load range in the SR for the reasons outlined in the i comment on Fil for SR 3.8.1.2.
5
f DAEC-NUREG MARKUP 3.8.1 3.8.1 L 00C #' CTS /STSl DESCRIPTION OF! ISSUE ... -
C09tENTSL
- STATUS" ISSUE' or J REF 2
- 1 JFD #.
7 P26 SR 3.8.1.4' Change P26 appears to indicate a The licensee' DATE misunderstanding of this NUREG - should revise the OPENED l SR. This SR is intended to SR to address 8-11 check for free water in the staff concerns.
bottom of the tanks where it ..
provides an' environment for the growth of aerobic'and anaerobic
~ 1 bacteria. Growth of these bacteria causes fouling of the-fuel oil which can easily cause engine failure. and tank corrosion. This " free" water will not show up in the periodic tests for water and sediment in fuel oil. This SR should be reviewed and revised, as necessary, to address.the above ;
l concerns.
The licensee l 8 P3 SR 3.8.1.7 Change P3 is interpreted by the DATE staff to mean that the DAEC. fuel should review the OPENED.'
oil system design only includes DAEC design & 8-11-97.
manual operation of the fuel oil provide a response-transfer pump- There is no to the staff automatic capability. Is this- question and as-correct? a plicable, revise t1e submittal.
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DAEC NUREG MARKUP 3.8.1 3.8.1. ' DOC #I CTS /STS DESCRIPTION'0F ISSUE- C0ttfENTS STATUS-ISSUE- or- .
REFJ
- JFD #:
9 P11 SR 3.8.1.7 Change P11 is Not Acceptable. The licensee DATE-The proposed language (greater should revise the OPENED than the assuned accident load) submittal to 8-11-97 is a change from CTS address staff )
requirements (rated load) that concerns.
has not been justified. The licensee should include the applicable load range in the SR.
or use the CTS terminology
" rated load".The staff.
recomends including the applicable load range in the SR for the reasons outline in the coment on P11 for SR 3.8.1.2.
10 N/A SR 3.8.1.8 Is DAEC currently operating on a The licensee DATE y 24 month cycle? If the answer should provide a OPENE i is no..then this is a change (18 response to the 8-11-97 months to 24 months) that is staff question, beyond the scope of the ITS and revise the conversion. submittal. if applicable.
7
3.8.1 3.8.1- DOC f CTS /STS DESCRIPTION OF.: ISSUE COMMENTS STATUS ISSUE or- REF
- JFD #
11 P9 SR 3.8.1.9 Change P9 indicates a The licensee DATE misunderstanding of NUREG Note should respond to OPENED
- 2. The Note is applicable if. the staff question 8-11-97 the DG is paralleled with the and then revise grid. load to a KW value a the the submittal. as single largest load, and the DG applicable.
breaker is opened. If this SR is to be performed with the associated 4160.vac bus isolated
- from the grid and powered only by the DG, then Note 2 is not l required. What methodology is used at DAEC?
8
. . - . ..._ _ .- _ . . _ . _ _ - _ _ _ _ _ _ . . _ _m.. . . _ _ . . _ . _ . ..
?
.z I i
't
. . j DAEC MREG M4WCIF -
3.8.1-t W
.n :
, 3.8.li DOC # : I Cish E DESCRIPTION OF' ISSUE COPD$ G -
STATUS" t ISSUEl or . b REF' , -
- p. py - :_ . . ,.
3 12 Pil SR 3.8.1.9 The staff does'not agree with The licensee DATE Change P11. Including should revise the OPENED acceptance criteria in the SR stteittal to 8-11-97 !
!. eliminates any confusion that address staff i: could arise as a. consequence of concems. -
- l the necessity to look in two or i more places to obtain a complete !'
understanding of the SR. Also.
i as a practical matter. placing
- j. the acceptance criteria in the l Bases has no advantages because ;
j .' s any changes to the values are i sure.to trip the Bases Control i
i' k criteria which would mandate a i license amendment. anyway. This j q change should be deleted and the !
- l. voltage and frequency acceptance criteria stated in the SR.
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DAEC NUREG MARKUP 3.8.1 DESCRIPTION OF ISSUE CCPfiENTS STATUS 3.8.1 DOC # CTS /STS ISSUE or REF
- JFD #
13 P13 SR The staff does not fully The licensee DATE 3.8.1.11 understand the discussion should revise the OPENED associated with change P13. It submittal to 8-11-97 appears that the DAEC design is address staff such that the DGs dc not start concerns.
when a LOCA signal, alone. is present. Therefore. NUREG-1433 SR 3.8.1.12 would not be applicable. However, the discussion also indicates that the system response to a LOOP.
I by itself. is different than the system response to a LOOP /LOCA combination. It is these different system responses that determine the requirement for individual SRs. In light of this combining NUPEG-1433 SRs 3.8.1.11 & 3.8.1.19 (to become ITS SR 3.8.1.13) is Not Acceptable. h l
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DAEC IUtEG MARKUP 3.8.1 3.8.1 DOC # CTS /STS DESCRIPTION OF ISSUE COPMENTS STATUS ISSUE or- REF-
,- #- JFD f i 14 P12 SR Change P12 does not appear to be The licensee DATE 3.8.1.12 acceptable. The DAEC design is should revise the OPENED such that the DGs should start, submittal to 8-11-97
' achieve rated speed and voltaoe address staff in 10 seconds. and run unloaded concerns.
in the presence of a LOCA signal. The onsite power systeit is not designed to do anything else in this situation. The NUREG-1433 SR is intended to demonstrate what does not hapxm in this scenario as much as w1at does happen. Canbining this SR with NUREG SR 3.8.1.19 (to become ITS SR 3.8.1.13) does not demonstrate this design feature and is therefore. Not Acceptable.
15 P13 SR The proposal to courine NUREG- The licensee DATE 3.8.1.13 1433 SR 3.8.1.11 and SR 3.8.1.19 should revise the OPENED is Not Acceptable. See the submittal to 8-11-97 discussion for item nutter 13. address staff .
above. for details. The concerns.
combined SRs would become ITS SR 3.8.1.13.
11
.MLREG MARKUP 3.8.1 i
l 3.8.1 DOC # CTS /STS DESCRIPTION OF ISSUE COMENTS STATUS ISSUE or REF-
- 3FD i 16 P11 SR The staff does not agree with The licensee DATE 3.8.1.13 Change P11. Including should revise the OPENED 4 acceptance criteria in the SR submittal to 8-11-97 i eliminates any confusion that address staff could arise as a consequence of concerns.
- the necessity to look in two or more place to obtain a complete i understanding of the SR. Also, as a practical matter. placing the acceptance criteria in the Bases has no advantages because any changes to the valves are sure to trip the Bases Centrol criteria which would mandate a
. license amendment. anyway. This
- cnange should be deleted and the
- voltage and frequency acceptance criteria stated in the SR i
4 1
e 12
DAEC NUREG MARKUP 3.8.2 3.8.2 00C f CTS /STS DESCRIPTION OF ISSUE COPMEhTS STATUS ISSUE #. or: REF JFD #
1 P13 SR 3.8.2.1 The proposed deletion of The licensee DATE
, NUREG-1433 SRs covered by should revise OPENED l this change is Not the subcittal 8-11-97 l Acceptable because the to address l LCO 3.8.1 changes covered staff
- by P13 are not concerns.
i acceptable.
2 P7 SR 3.8.2.1 What change to this SR is The licensee DATE covered by justification should OPENED P7? provide a 8-11-97 response to the staff question.
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A DAEC ,
CTS MARKUP ,
3.8.3 3.8.3 DOC CTS /STS DESCRIPTION OF' ISSUE COPtiENTS STATUS or ITEM f LCO JFD #
1 C~ M2 4.8.A.2 The CTS requirement for The licensee should DATE OPENED operation of the starting air revise the DOC to 8-6-97 compressors on a monthly address staff basis is deleted. and a coments.
requirement to verify air receiver pressure on a monthly basis is added. The
- above deletion is acceptable i in concept. However. the justification (DOC M2) does
- not adequately address why this deletion is acceptable.- '
The DOC should be revised to include details such as "The i time required to refill the ;
air receivers is not a safety i issue" and "The air receiver ,
pressure is the only l parameter that has a bearing on DG OPEPABILITY. ;
i 1
DAEC NUREG MARKUP 3.8.5 3.8.5 - DOC f CTS /STS DESCRIPTION OF ISSUE COPMENTS STATUS ISSUE #- or REF JFD #
1 P14 SR 3.8.5.1 Change P14 is not The licensee DATE necessary. Since the should revise OPENED DAEC design includes the submittal 8-11-97 spare battery chargers, to address it is possible for SR staff concerns.
3.8.4.6 to be current without comaromising the DC power su) system during shutdown. This can be done by perfonning the SR on a charger for which credit is not taken to I satisfy the LCO. and then substituting that charger for the one(s) that is/are credited for satisfying the LCO. Tne submittal should be revised to retain this SR.
1 1 _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
DAEC IM EG MARKUP 3.8.6 l 3.8.6 00C#. CTS /STS. DESCRIPTION OF ISSUE C0f9ENTS STATUS
, ISSUE or REF ~4
- ' JFD ft 1 P15 LCO 3.8.6 As 3ro wsed. Change P15 appears The licensee should DATE Condition A to m %t Acceptable. The provide the OPENED and Condition licensee should provide additional 8-11-97 B additional information regarding information float voltage and open circuit required by the voltage and overall battery staff.
capacity. The licensee should also provide the rationale for why he thinks unlimited operation on 57 cells is allowed by CTS.'
i i
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DAEC NLREG MARKUP i 3.8.6 3.8.6 00C# CTS /STS DESCRIPTION OF ISSUE CDPetENTS STATUS'
, ISSUE or- REF
- JFD #
I 2 P17 SR 3.8.6.1 Change P17 does not appear to be The proposed change DATE acceptable because the is beyond the scope- OPENED justification is not adequate. of the conversion 8-11-97 Some of the problems associated to ITS.
i with DOC L2 (referenced by P17) include statements regarding i
battery cell parameters not providing any useful "early warning" signs and vague statements regarding battery.
j degradation versus time and projected batters ca acity.
These statements lact qualitative and quantitative support, and appear to be inappropriate for inclusion in a justification.
- The DOC is also confusing because .
it references IEEE-450 :
. (1987)whereas other DOCS i reference IEEE-450 (1995). In l addition. the proposed change is l beyond the scope of the ITS i conversion. j 2
3.8.6 I 3.8.6 00Cf CTS /STS DESCRIPTION OF. ISSUE C0leENTS STATUS
- ISSUE. or REF.
- JFD #-
3 P15 Table 3.8.6-1 As )roposed. Change P15 appears The licensee should DATE i to :e Not Acceptable. The provide the OPENFD licensee should provide additional 8-11-97 additional information regarding information float voltage and open circuit required by the voltage and overall battery staff.
capacity. The licensee should also provide the rationale for why.he thinks unlimited operation on 57 cells is allowed by CTS.
4 4 P45 Table 3.8.6-1 Change 45 appears to be This is a beyond DATE Footnote a acceptable. However, this also scope issue. OPENED ayears to be a generic issue 8-11-97 t1at is beyond the scope of conversion to the ITS.
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DAEC NLREG MARKUP 3.8.7 3.8.7 -
DOC f CTS /STS DESCRIPTION OF ISSUE COMMENTS STATdS ISSUE # or. REF-JFD # --
1 N/A LCO 3.8.7 The proposed Condition (One or more The licensee DATE Condition B 125 vdc electrical power dist should revise OPENED subsystems inoperable) is the submittal to 8-11-97 inconsistent with Condition D of LCO address staff 3.8.4 (two DC sources inoperable). concerns.
Condition D (of LCO 3.8.4) requires immediate entry into 3.0.3 for this Condition. If two 125VDC batteries are inoperable. the Condition reflecting this in this LCD should be consistent with the rest of the ITS. The submittal should be revised accordingly (Note: the definition of OPERABLE requires that a system / component must be capable of performing its intended safety function in order to have OPERABILITY: a dc distribution system powered by anything other than its associated battery is inoperable because with a LOOP. the distribution system is deenergized.)
I 1
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DAEC NLREG MARKUP 3.8.7 C0tmENTS STATUS 3.8.7 DOC i' CTS /STS DESCRIPTION OF ISSUE' ,
l ISSUE # or REF JD # '
2 P46 LC0 3.8.7 Change P46 is Not Acce) table because The licensee DATE !
Act. B1 it is inconsistent wit 1 the should revise OPENED l definition of OPERA 8ILITY and other the submittal to 8-11-97 !
parts of the ITS as discussed above. address staff Also. NOTE that TSTF-16 has not been concerns.
accepted by the staff.
3 P25 LCO 3.8.7 The proposed default Condition is The proposed DATE Cond. C Not Acceptable because proposed Condition should OPENED Cond. B is Not Acceptable. This be revisited 8-11-97 default Condition s1ould be following revisited following resolution of resolution of the comments on Cond. B. item 2. above.
4 P25 LCO 3.8.7 This default Condition may not be The Condition DATE Cond. G acceptable in its current form. should be ODENED Changes may be required as a result revised based on 8-11-97 of resolution of comments on Cond. changes to B. {oposedCond.
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b DAEC IRJREG MARKUP 3.8.7 3.8.7J . DOC f. CTS /STS- DESCRIPTION OF ISSUE C0f9 TENTS STATUS ISSUE f- or: REF.
, JFD #
L 5 P20 LCO 3.8.7 Change P20 adds Conditions D. E. and The licensea DATE F. This reflects the DAEC design should revise OPENED i and is acceptable. However. the the submittal to 8-11-97
!. proposed ITS do not include a address staff default Condition if the Required concerns.
Actions and Completion Times are not met. A default Condition thould be provided in order to be consistent with the rest of the ITS.
, 6 P47 SR 3.8.7.1 Change P47 discussion should be The licensee DATE expanded. Is there no voltage should provide OPENED indication of any kind available on additional 8-11-97 some of the AC and DC busses? Is infonnation there !ocal voltage indication (Load required by the Centers. accs. etc) that could be- staff.
checked during the breaker alignment verification? The licensee should provide trore details.
3
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. 3.8.7 ' DOC # CTS /STS DESCRIPTION OF ISSUE C0tmENTS STATUS
- ISSUE f: or REF JFD #
7 P30 SR 3.8.7.2 This SR bas no corresponding LCO. DATE Condition. Required Action. OPENED
! Completion Time, or default 8-11-97 Condition in any other part of the ITS. This is inconsistent with the organization of NUREG-1433 and the ITS. The submittal should be revised to add the necessary LC0 statement and other requirements discussed herein. I t
4
! 4
DAEC NUREG MARKUP 3.8.8 3.8.8 DOC # CTS /STS DESCRIPTICH OF ISSUE COPMENTS STATUS ISSUE # or REF JFD #
1 P50 LCO 3.8.8 Change P50 appears to be This appears to DATE Act. A. 2.5 a generic issue that may be a beyond scope OPENED be outside the scope of issue. 8-11-97 an ITS conversion. Has this change been addressed generically?
Has a TSTF number been assigned? What is the status of the generic review?
2 P47 SR 3.8.8.1 Change )47 discussion The licensee DATE i should be expanded. Is should provide OPENED there no voltage the details 8-11-97 indication of any kind requested by the s available on some of the staff.
AC and DC busses? Is there local voltage ,
indication (load centers.
MCCs. etc) that could be checked during tie '
breaker alignment -:
verification? The licensee should provide '
more details.
t e
e 1
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< CTS MARKUP
< 3.8.1 3.8.1~ DOC CTS /STS DESCRIPTION OF ISSUE ComENTS STATUS ~!
ITEM i~, or LCO
- 3D # .
i 10 L.6 4.8.G.1 Change L.6 does not appear to be The licensee should DATE OPENED acceptable. NUREG-1433 only provide a stand- 8-5-97 requires one DG test during the alone justification
' this convention. However, the restrictive change NUREG requirements are based on a to CTS is 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A0T. not the 7 day ACT accaptable, or proposed to be retained at DAEC. revise the submittal The licensee has not provided an to retain the CTS adequate justification for why requirements.
extending the DG test interval from a NUREG maximum of once in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to the DAEC ITS maximum of once in 7 days is acceptable.
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i DAEC -
i CTS MARKUP i 3.8.1
! 3.8.1 . DOC CTS /STS DESCRIPTION OF ISSUE. CDPMENTS' STATT .
! ITEM i or LC0 - .
JFD #
! 2a. M.12 3.8.A The staff understands the DATE OPENED i proposed change. but does not 8-5-97
- agree with the proposed wording of Required Action A.2. The CTS requires two offsite circuits whenever the reactor is not in a cold conditi>ri (i.e.. not in Mode 4 or 5). The Completion Time should read " Prior to entering Mode 3 from Mode 4" instead of
" prior to entering Mode 2 from Mode 3".
In addition to the above it is not clear that the proposed ITS will work. Proposed Required Action A.2 is modified by a Note which states that LCO 3.0.4 is L F
Not Applicable. The purpose of this note is not clear since LCO t 3.0.4 ap) lies to Mode changes L when an 'C0 is not satisfied, and not to Required Actions of that ;
, LCO.
2 1
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3.8.1 DOC- CTS /STS DESCRIPTION OF ISSUE COPF .TS STATUS ITEM # or .
LCO JFD #
2aCONT. M.12' 3.8.A Also, the proposed Completion DATE OPENED Time of Action A.2 is an 8-5-97 exception to the Applicability of the LCO that is inconsistent with NUREG-1433 and instructions regarding its use.
3 a- N/A N/A The Bases discussion for LCO DATE OPENED 3.8.1 indicates that the 8-5-97 emergency loads are sequenced on '
to the offsite power as well as the DGs. The staff interprets this to mean that the sequencer ,
is an essential element in the ECCS success path and is, therefore. a recuirement that should be incluced in the LCO.
i Absent the appropriate Condition in the LCO. failure of a sequencer would. as a minimum, invoke Actions associated with a dead bus.
3
.; DAEC .'
i CTS MARKUP j 3.8.1 1
3.8.1 DOC CTS /STS DESCRIPTION OF ISSUE COMENTS~ STATUS:
- ITEM i or- LCO ~~
i JFD #
4 c-- L1 3.8.A.2.c Changes L1 and M9 do not appear The license should 8-5-%
M9 to be acceptable. CTS 3.8.A.2.c provide a better i requires all_ low pressure cooling justification for
- systems to be OPERABLE. there are the proposed i no allowances. and the changes, or retain OPERABILITY determination must be the CTS. !
2 made immediately. Failure to i meet CTS requirements invokes 3.0.3. In addition. CTS
! 3.8.A.c.1 requires one or both offsite circuits to be restored ,
immediately. or commence a plant
- shutdown. Proposed Required Actions C.1 and C.2 would allow 12 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> respectively, to complete these same actions. !
DOCS L1 and M9 do not provide an , ,
i adequate rationale for the 'i.
pronosed changes. es wcially when !r viewed in light of tw retention !
1 of the CTS allowance for !
j unrestricted operation with one l!
offsite circuit inocerable. i l
=
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- 3. 8.1 DOC- CTS /STS DESCRIPTION 0F ISS'JE COPMENTS i; STATUS ITEM f- or : LCO cy JFD f. y 5 M8 3.8.A.2.c.2 The staff does not agree that the Revise the Dit and l 3-5-95 1 proposed addition of Conditio: E DOC classiffcAten and Required Action E.1 is a more acccrdingly. A restrictive change. CTS 3.8.A.2.a requires the remaining offsite circuit to be maintained OPERABLE. Since the CTS do not include a default statement.
failure to cowly with CTS requirements invokes 3.0.3 or the DAEC equivalent. This is implicit in the CTS. Adding a default Condition (E) states in explicit terms what is implicit in the CTS. and makes the ITS rre understandable. It is not.
however, a more restrictive g
. change. I f
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4 DAEC -
1 CTS MAllKUP ,
! 3.8.1 i i
l 3.8.1 DOC CTS /STS' DESCRIPTION OF ISSUE - C0pt!ENTS STATUS'
! ITEM i or LCO. -
=
i j JU # -
1 :
j 6 a._ M2- NA The staff does not agree that the The licensee should DATE OPENED proposed addition of Condition F revise the DOC and 8-5-97 j is a more restrictive change. As DOC classification 3
with. Condition E (discussed ,,
accordingly.
- above). Condition F alse states i in explicit terms what is implicit in the CTS. Adding a j
j i Condition for 3 or more AC :
sources inoperable makes the ITS l
! more understandable but is not a
! more restrictive change.
l .
i 7cm M1 4.8.A.l.a The staff does not agree that the The 1;censee should DATE OPENED proposed addition of Required revise the 00C and 8-E-97 Action A.1 is a more restrictive DOC classification change. CTS 3.8.A.2a addresses accordingly.
j one offsite circuit inoperable i and includes the requirement to
" maintain the other offsite !
- source OPERABLE.* Required ;
Action A.1 provides a specific '
, method whereby this CTS -
i requirement can be met. and makes i the ITS more understandable. It 1 i is not. however, a more i restrictive change.
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DAEC CTS MMg(UP J 3.8.1 3.811 DOC- CTS /STS- DESCRIPTION OF ISSUE' CG90fTS STATUS-ITEM #;
or. . LCD -
gg g i 8s A5 4.8.A.1.b CTS 4.8.A.I.b requires The licensee should DATE OPENED verification "that both emergency revise the DOC and 8-5-97 diesel generators are either DOC classification OPERABLE or operating" when an accordingly.
offsite circuit is inoperable.
This requirement is not carried over to the ITS. The justification provided is AS.
The staff agrees with deleting the CTS requirement but does not agree that it is an administrative change. This is a less restrictive change and I should be justified as one.
7
DAEC CTS MARKUP 3.8.1 C0tetENTS STATUS 3.8.1 DOC CTS /STS DESCRIPTION OF. ISSUE ITEM # or .
LCO JFD #
9a_ A3 4.8.A.2 The use of a prelube period prior The licensee should DATE OPENED to DG starts is acceptable. revise the DOC and 8-5-97 However, this permissive does not DOC classification exist in the CTS..and the staff accordingly.
does not agree that the US can be interpreted as containing this .
permissive. This is a less -
I restrictive change.
Gradual loading of the DGs is acceptable. However, this permissive does not exist in the CTS. and the staff does not agree that the CTS can be interpreted as containing this permissive.
This is a less restrictive change.
10 A A4 4.8.A.2 The allowance to use The licensee should DATE OPENED methods / signals othcr than manual revise the DOC and 8-5-97 for DG starting has been DOC classification a
determined to be a less accordingly.
I restrictive change by NRC OGC.
DOC A4 must be changes ;
accordingly.
8 ,
DAEC <
CTS MARKUP 3.8.1 3.8.1- DOC CTS /STS- DESCRIPTION OF ISSUE COPMENTS STATUS ITEM i ~ or LCO JFD #
ll o L2 4.8.A.2 Change L2 does not appear to be The licensee should DATE OPENED f' acceptable. NUREG-1433 and RG revise the submittal 8-5-97 1.9. Rev. 3 allow a load range to address the when testing DGs. However, this staff's concern.
range is based on 90-100% of continuous duty rating (rated load). and is meant to preclude routine DG overloading. Neither i the NUREG or RG 1.9 contain any language regarding accident ,
loading. Rated load is used i because operation at 90-100% of i rated load with no anomalies i provides adequate assurance that ;
the DGs have not degraded. .
Operation below this range (i.e.. '
accident loading) could mask a developing DG problem. ,
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1 DAEC -
1 CTS wave i
3.8.1 i
s i 3.8.1- DOC CTS /STS DESCRIPTION OF~ ISSUE CatmENTS STATUS'
. ITEM # or LCO i
Jm i
! 12 g N/A N/A The following inconsistencies The licensee should DATE OPENED were noted on Pg. 7 of 28 in the correct the 8-5-97 DAEC ITS submittal: inconsistencies.
- Doc A4 is shown as being applicable to Note 3 of ITS SR 4
3.8.1.3. However. Note 3 addresses a subject that is completely different from that addressed in the D0C. -
- The last part of the first j paragraph of this CTS (4.8.A.2)
- addresses substituting this SR <
i for another SR. The CTS markup i indicates that this CTS becomes
- Note 1 to ITS SR 3.8.1.2.
- However. Note 1 to SR 3.8.1.2
! addresses engine prelube not i substitution.
13w LB 4.8.A.2 The issue of OPERA 8ILITY of DGs Delete L8 pending a DATE OPENED L7 (and other safety related generic resolution 8-6-97 components) during performance of of the issue.
SRs is beyond the scom of this conversion effort. T11s issue is
! being reviewed generically.
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3.8.1 3.8.1' 00C- CTS /STS DESCRIPTION 0F ISSUE COMMENTS STATUS ITEM # or LCO JFD f 14 a. R2 4.8.A.2 Change R2 does not appear to be The licensee should DATE OPENED acceptable. The staff is of the revise DOC R2 to 8-6-97 opinion that this SR should be address A staff's relocated to a plant controlled coment.
document for which controls have been established: e.g.. the OG Maintenance Plan established in compliance with 10 CFR 50.65 and RG 1.160.
8-5-97 i
11
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3.8.2- DOC- CTS /STS DESCRIPTION OF ISSUE CDPMENTS STATUS ITEM . or. LCO f JFD f:
l a. L1 3.9.D.1 CTS 3.5.G.3 requires an OPERABLE DG The licensee should DATE OPENED A3 3.5.G.3 associated with at least one core revise the DOCS to 8-6-97 spray pump or RHR puno during address the staff OPDRVs. CTS 3.9.D.1 requires an concerns.
OPERABLE DG associated with SGT.
Control Room SFU. and Control Building Chiller during CORE ALTERATIONS. These requirements are not carried over to the ITS. DOCS A.3 and L1 provide the licensees justification for these changes.
The staff has reviewed the licensee *s :ubmittals and has cond:M Liat the DOCS are not adequate. DOC A.3 and L.1 include a description of the change and a reference to LCO 3.8.7. However, the licensee *s submittal does not show how the CTS requirement is reflected in the ITS. and do not present an adequate case for why these changes are acce) table. The changes associated wit 1 DOCS A3 and L1 will be considered Not Acceptable r
4 1
DAEC r CTS MARKijP 3.8.2 3.8.2 DOC CTS /STS DESCRIPTION OF. ISSUE COMMENTS STATUS ITEM or LCO
- JFD # -
IN L1 3.9.D.1 until adequate justifications are DATE OPENED CONT. A3 3.5.G.3 provided. Note also that the change 8-6-97 associated with DOC A3 appears to be
- a less restrictive change rather than administrative.
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DAEC NUREG MARKUP 3.8.4 3.8l4' . DOC #- CTS /STS DESCRIPTION OF ISSUEL COPMENTS STATUS'
' ISSUE #' ors . ~ REFL JFD # 4
- 1 P18 LCO 3.8.4 The discussion for Change P18 The licensee DATE Condition A appears to reflect a lack of should revise the OPENED .
, understanding of how TS work and submittal to 8-11-97
- what the purpose of Conditions. address staff ReqJired Actions. and Completion concerns.
Times is. In this case. a 125 V de electrical subsystem is inopersble, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is allowed to restore it. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> constraint is imposed because with the one 125V dc subsystem inoperable, the plant could not cope with a DBA coincident with a '
single failure (of the other 125V ,
ds subsystem or other ,
systems / components), and the time in this plant status must be limited. The discussion addressed the ino wrable 125V dc AS the SINGLE FAILURE. This is not correct. The discussion should be modified. accordingly.
1
--s. .. . - - -
O
/
8.4 DESCRIPTION
OF ISSUE: COPMENTS : STATUS ,
- 3. 8.4 ~' 00C#- CTS /STS4 -1 ISSUE # or REF-JFD #
2 P36 SR 3.8.4.1 Change P36 is Not Acceptable The licensee DATE because. 1- The proposed change should revise the OPENED is beyond the scope of ITS submittal to 8-11-97 conversions: 1.e., does not address staff reflect either the NUREG or CTS. concerns.
and 2- The justifications associated with the DAEC ITS conversion reference the 1980. 1987, and 1995-versions of IEEE-450. Only one of these versions is acceptable as a '
reference.
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DAEr NUREG MARKUP 3.8.4 3:824 DOC #< CTS /STS; DESCRIPTION OF ISSUE COPEENTS 3TATUS.
ISSUE #a or ~ REF-i JFD #:'
1, 3 P11 SR 3.8.4.2 The staff does not agree with The licensee RG Change P11. Including acceptance should revise the OPENED criteria in the SR eliminates any submittal to 8-11-97 confusion that could arise as a dddress staff consequence of the necessity to concerns.
look in two or more places to obtain a complete understanding of the SR. Also, as a practical matter, placing the acceptance criteria in the Bases has no advantages because any changes to the valves are sure to trip the -
Bases Control criteria which would mandate a license amendment, anyway. This change should be deleted and the resistance valves stated in the SR.
4 N/A SR 3.8.4.4 The licensee has not provided a The licensee DATE justification for the proposed should provide a OPENED change to the NUREG-1433 SR. justification for 8-11-97 the change.
3 -
. DAEC NUREG MARKUP 3.8.4 3.8.4 00C# CTS /STS~~ DESCRIPTION'0F;ISSUEL ComtENTSt STATUS ISSUE # or- .
REF JFD #
5 P11 SR 3.8.4.5 The staff does not agree with The licensee DATE Change P11. Including acceptance should revise the OPENED criteria in the SR eliminates any submittal to 8-11-97 confusion that could arise as a address staff consequence of the necessity to concerns.
look in two or more places to obtain a complete understanding of I the SR. Also, as a practical
~
matter. placing the acceptance criteria in the Bases has no advantages because any changes to the valves are sure to trip the Bases Control criteria which would mandate a license amendment, anyway. This change should be deleted and the resistance valves stated in the SR.
6 P14 SR 3.8.4.7 Change P14 is acceptable in The licensee DATE concept. However, complete should revise the OPENED removal of the NUREG Note goes too submittal to 8-11-97 far. The Note should be retained, address staff but modified to state that the SR concerns.
shall not be performed on the OPERABLE Charger (s). The submittal s;iould be revised accordingly.
4
DAEC NUREG MARKUP 3.8.4 3.8.4 DOC # CTS /STS DESCRIPTION OF-ISSUE' COPMENTS STATUS-
- i ISSUE # ~or REF j!
JFD #
!! 7 P35 SR 3.8.4.7 Note 1 to proposed ITS SR 3.8.4.7 DATE ,
does not appear to reflect either OPENED CTS or NUREG-1433 SR 3.8.4.7 8-11-97
- accurately. CTS states that the performance discharge test WILL be conducted in lieu of the service test every 5 year. A subset of this CTS requirement is that the wrformance discharge test may not m substituted for the service test at any other time. The NUREG includes a permissive to substitute the performance test ,
for the service test, but limits their permissive to once every 60 months. The proposed ITS reflect the NUREG permissive but without the 60 month permissive. As proposed. ITS SR 3.8.4.7 Note 1 is '
Not Acceptable. The submittal should be revised to address the above noted discrepancies. It is suggested that use of modified performance discharge test ba considered.
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t DAEC CTS MARKUP 3.8.4 3.8.4 DOC CTS /STS DESCRIPTION OF ISSUE COPMENTS STATUS ITEM or LC0
_# JFD#
lot R2 3.8.B.1 Change R2 does not appear to be The licensee should DATE OPENED i acceptable. The licensee has provide an adequate 8-6-97 ,
4 not established that the 24 V dc justification for battery does not satisfy any of the relocation, or the four criteria in 10 CFR retain the CTS.
50.36 for inclusion in TS. -
Consequently. the licensee has ,
not made the case that this CTS l requirement can be relocated to -
licensee controlled documents.
2 a- L1 4.8.B.1 Change L1 does not appear to be The licensee should DATE OPENED acceptable. The licensee has retain the CTS 8-6-97 not provided an adequate requirement for a 7 justification for changing the day SR frequency.
frequency of this SR from 7 days to 31 days. IEEE-450 (1995) does not support this pro msed change, and the licensee las not provided specifics regarding "past history" that he states will support this change.
1
7.
1 DAEC CTS MARKUP 3.8.4 COMMENTS STATUS 3.8.4 ' 00C CTS /STS DESCRIPTION OF ISSUE --
ITEM or LCO
- JFD#
3o_ R2 4.8.B.1.C Change R2 does not appear to be The licensee should DATE OPENED acceptable. The licensee has provide adequate 8-6-97 not established that the 24 V dc justification for battery does not satisfy any of the relocation. or the 4 criteria in 10 CFR 50.36 retain the CTS.
for inclusion in TS. :
Consequently, the licensee has l not made the case that this CTS requirement can be relocated to licensee controlled documents. ,
4A R1 3.8.B.2 Change R1 does not appear to be The licensee should DATE OPENED acceptable. The licensee has provide an adeguate 8-6-97 not provided an adequate jtstification tor-justification for relocating the relocation, or these items. A justification retain the CTS.
which shows that these CTS do ~
not meet the criteria in 10 CFR 50.36 for retention in TS must be provided, or retain the CTS.
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DAEC-CTS MARKUP 3.8.4
,. 3.8.4 DOC CTS /STS DESCRIPTION OF ISSUE COP 9ENTS STATUS ITEM' or LCO
- # JFD#
So R4 3.8.B.2 Change R4 does not appear to be Revise the DATE OPENED acceptable. CTS require submittal to 8-7-97 immediate verification of low address the staff pressure cooling OPERABILITY. concerns.
. In the proposed ITS. this verification would be a function within the SFDP. However. it is not' clear that the inoperability P
of a 125 V de system would immediately invoke LCO 3.0.6 and the SFDP. Unless it can be shown that the SFDP is invoked imediately this is a less restrictive change which has not been justified. Also, the CTS do not. include a default statement if the TS requirement 1s not met. In such a case.
3.0.3 (or equivalent) is applicable. In the ITS.
> assuming 3.0.6 is invoked imediately, the SFDP would require entry into the LCO of the.affected system /couponent if an inoyerability is found. The SFDP. )y itself, would not require a plant shutdown.
3 e
_ __ . . _ .. = - _ _ _ - _ _ = .-
r DAEC CTS MARKUP 3.8.4 3.8.4 DOC CTS /STS DESCRIPTION OF ISSUE COMMENTS STATUS ITEM or LC0
- JFD#
5R R4 3.8.B.2 Therefore, in any case, this DATE OPENED CONT. proposed change is less 8-7-97 restrictive and should be addressed as such.
6 a_ R3 4.8.B.I.C Change R3 is acceptable in The licensee should DATE OPENED concept. ilowever, the DOC does revise the 8-7-97 not provide an adequate submittal to justification for the change. address staff Removal of this CTS material is concerns.
acceptable.because it details how to perform the SR. -This detail is not necessary to adequately state the TS requirement for performance of.a battery service test, and can be relocated to plant procedures.
It should also be noted that plant procedures are not
, controlled under 10 CFR 50.59.
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O DAEC CTS MARKUP 3.8.4 3.8.4 DOC CTS /STS DESCRIPTION OF ISSUE COMMENTS STATUS ITEM or LCO
- JFD#
7o N/A 4.8.B.1.d Note 1 to proposed ITS SR The licensee should DATE OPENED 3.8.4.7 does not appear to revise the 8-7-97 reflect either the CTS or NUREG- submittal to 1433 (SR 3.8.4.7) accurately. address staff The CTS state that the concerns.
wrformance discharge test will m conducted in lieu of the service test every 5 years.
(Note: The reverse of this CTS !
requirement is that the performance discharge maY not be substituted for the service test any other time.) NUREG-1433 includes a oermissive to substitute the performance test for the service test, but limits the armissive to once every 60 mont1s. The proposed ITS o reflects the NUREG mrmissive.
but without the NUREG 60 month criteria. As proposed. ITS SR 3.8.4.7 Note 1 is not acceptable. The submittal must be revised. The licensee may want to consider use of the modified wrformance discharge test in t1e revision.
5
3.8.6 3.8.6 dDOCf CTS /STS DESCRIPTION OF ISSUE '
COMENTS- STATUS or:
~
ITEM #' .
LCO JFD # -
! la L2 4.8.B.1.a Change L2 does r.ot appear to The licensee should DATE OPENED ,
- be acceptable because the revise the submittal 8-7-97 4
justification is not to address staff adequate. Some of the concerns, or retain ;
! 3roblems associated with DOC the CTS.
l _2 include statements
- regarding battery cell parameters not providing any useful "early warning" signs and a vague statement regarding battery l degradation versus time and i projected battery caJacity. i These statements lact qualitative and quantitative ;
support, and appear to be inappropriate for inclusion in a justification. The DOC !
is also confusing because it l references IEEE-450 (1987) whereas other DOCS reference !
IEEE-450 (1995). In addition. this pro)osed :
change is teyond t1e scope ;
of conversion to the ITS. !
1
DAEC CTS MARKUP 3.8.6 3.8;6 - 00C CTS /STS-. DESCRIPTION OF ISSUE . C0mENTS - STATUS 1 ITEM f or . LCD-l JFD #- t 2A L1 4.8.B.I.b DOC L1 includes a statement The licensee should DATE OPENED regarding IEEE-450 (no revise the submittal 8-7-97 revision provided) and the to address the staff definition of representative concerns.
cells: i.e.. one out of every 6 cells. The staff has not been able to identify any such definition in IEEE-450 (1995). ' Absent any rationale for the
~
change, the staff is of the opinion that the CTS requirement of every 5th cell be retained. 1 l
2
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3.8.6 L. 00C)- CTS /STSL DESCRIPTION OF ISSUE 'COPMENTS -
STATUS ITEM #1 or -1 LCO -
.l JFD # -
1 3 a. L3 3.8 Bases Change L3 (addition of The licensee should' DATE OPENED l.
- Category C limits) is revise the submittal 8-7-97 1 acceptable in concept. to address the . staff j However, the DOC does not concerns.
j provide an adequate [
l justification for this change. The DOC should be revised to address the ITS ;
Category C valves and why '
they are acceptable: e.g.,
the battery state of charge is less than full charged but is still adequate to power emergency 1oads, etc.
Also the DOC should address why it is acceptable to be in a condition where Category A&B valves are not met. but the Category C valves are met.
3 .
l 3.8.6 i
3.8.6 DOC CTS /STS DESCRIPTION OF' ISSUE-COMENTS STATUSi ITEM # or LC0 JFD #.-
4m R1 4.8.B.1 Change R1 is acceptable in The licensee should- DATE OPENED concept. However, the DOC revise the submittal 8-7-97 does not provide an adequate to address staff justification for the concerns.
change. Removal of the CTS material is acceptable 4
because it consists of details of how to perform the SR. These details are not necessary to adequately state the Ts requirement to periodically measure battery j cell parameters and can be '
relocated to plant i procedures without an impact on safety. It should also be noted that plant procedures are not controlled under CFR 50.59.
4
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DAEC CTS MARKUP 3.8.7 3.8.7 00CL CTS /STS-' DESCRIPTION OF-ISSUE- COPMENTS ~ STATUS ITEM #- or LC0-JFD #
lo N/A 3.8.B.1 The CTS markup of CTS 3.8.B.1 shows The licensee DATE OPENED >
the 24 V dc system deleted. However. should provide a 8-7-97 no justification for this change has justification for been provided in this section (3.8.7). the proposed Consequaltly deletion of the 24 V de change. or retain system is not acceptable. the CTS. i i
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DAEC CTS MARKUP - e 3.8.7 3.8.7 DOC CTS /STS DESCRIPTION OF ISSUE- COMMENTS- STATUS- -
ITEM f' or-
~
LCO JFD #-
2m R3 3.8.B.2.b Change R3 does not appear to be The licensee. DATE OPENED acceptable, The CTS require immediate should revise the 8-7-97 verification of low pressure cooling submittal to OPERABILITY. In the pro msed ITS. address the staff this verification would m a function concerns.
within the SFDP. However, it is not I clear that the inoperability of a 125 V dc system would immediately invoke LCG 3.0.6 and the SFDP. Unless it can be shown that the SFDP is invoked immediately this is a less restrictive change which'as not been justified. Also, the CTS do not include a default statement if the TS requirement is not met. In such a case. 3.0.3 (or equivalent) is applicable. In the ITS. assuming that 3.0.6 is invoked imediately. the SFDP l
would require entry into the LCO of the affected system / component if an l
inoperability is found. The SFDP. by itself. would not require a shutdown.
Therefore, in any case, this pro wsed ,
' change is less restrictive and siould i be addressed as such.
2
'3.8.7- DOCI CTS /STSI .. DESCRIPTION 0F-ISSUE N +-<. C0tttENTS STATUS ITEM f~ or LCO' JFD #~ ' -- '
P'- ^
3o N/A 3.8.B.2 The part of CTS 3.8.B.2 which The licensee DATE OPENED addresses the 250 V dc system is shown should revise the 8-7-97 t as becoming Action E in ITS LC0 3.8.7. sutaittal to -
,However, the proposed ITS do not address the staff include the requirement to verify CTS concerns.
3.5.0 and 3.7.B are met. and the -
markup does not show them as being deleted. The licensee should address what the disposition of this CTS requirement is. If the intent was/is
~
for this to be relocated to the SFDP.
the licensee should consider the staff cor.cerns regarding the SFDP as discussed in item 2. above.
+
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- CTS MARKUP --
3.8.7 C0pmENTS STATUS?
3.8.7 DOCi ! CTS /STS' DESCRIPTI'ON.0F? ISSUE _
ITEM #- or E . , LCO:
MD#
N/A The licensee is proposing to add The licensee DATE OPENED 4( M2-Action G in LCO 3.8.7. This addition should revise the 8-7-97 is classified as more restrictive, and submittal to addresses two or more power address the staff distribution systems inoperable that - concerns.
result in a loss of function. The staff does not. agree that this is.a more restrictive change. To the contrary, this appears to be a less restrictive change for-which a .
justification has not been provided.
The CTS do not have a requirement:
covering two or more AC or DC sources inoperable at the same time. In such
- a. case, the plant is in an unanalyzed condition and 3.0.3 (or equivalent) applies. This would mean an immediate' shutdown.. regardless of loss of function or no' loss of function. The ,
proposed ITS would allow continued plant operation under the.same conditions of-a loss of function had-not. occurred. This is less restrictive and must be justified.
S a.L R2 4.8.C.1 Change R2 does not appear.to be.. The' licensee DATE OPENED.
acceptable. The DOC does not provide- should revise the 8-8-97 an' adequate justification for the submittal to- :
change. Specifically, the criteria , address the staff
> for retention in TS from 10 CFR 50.36 concerns.
have not been applied to the proposed change. In addition, the licensee has.
not stated where the CTS requirement will be relocated to. or why 10 CFR' 50.59 will be the appropriate control.
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J DAEC ITS 3.1.1 SHUTDOWWN MARGINS (SDGB)
- 3.1.14 DOC CHANGE l DIFFERENCE - COMMENT;
.1 AN. The just6 cation for the More Restrictive
- Ms Requrements throughout Section 3.1 lack sufficsent justifications for the acceptatzhty of the changes. A mere desenpton of the charige does not provide justscahon for the aca@muty of the change for your plant. These changes must alsc be discussed based on your pH opershons, impact on
-; current licensing bases, and the degree to
! . which they change parameters that are ";
. ; afrected.
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., 2 L1 CTS 3.3.A.1 requires that the SDM be less than or equal Provide A h discussion and ,
to 0.38% e.k/k. The CTS 3.3.A.1 Bases clanfies that this justificaton based on plant opershon, the SDM limit is with the highest worth control rod unpact on SDM, and the dSerences analyticaNy determmed. ITS 3.1.1 adds a less restrictrve between what the CTS requwes and what requirement, that allows the SDM to be less than or the change would allow in the ITS. Also, equal to 0.28% Ak/k when the highest worth control rod if the uncertamhes are accounted for in is determined by test. the analysis, and tne uncertairy:y is conservative, why wouki the ana:ytical method pose a problem.
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,r DAEC ITS 3.1.1 SHUTDOWWN MARGINS (SDM) !
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? 3.1.1 - DOC ,
- CHANGE / DIFFERENCE - COMMENT- - t r i 3 L2 CTS 3.3.A.1 requires testmg dunng the first startup There is no Justificaten for Mm
! follomng Core Alterations, that includes the ad& hon, acceptabihty of this change, only a --
! removal, relocation or movement of fuel, sources, incore desenpten of the change and the instnunentaten or reactuty controls ethin the pressure statemerit that it is consestent with the - t vessel with the head remcved and fuel in the vessel. ITS STS. Provide ad&honal escussion and l SR 3.1.1.'.' only requaes performance of the SR after jushfication bases on plant operaten and
, fuel movement wthin the RPV or after Control Rod the effect on SDM. Also indicale whether ,
!, Replacement. Many of the items included in the CTS the changes in the scope of the ITS I
!l d63rnhon of Core Alterrtions, but not included in the ITS Survedlance Requrement definihons SR, could influence the dMation of the SDM. effect the determmahon of the SDM since
, , the ITS Surveillance Requirement doesn1 have the encompassing scope as does ';
the CTS Survedlance Requirement. ;
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DAEC ITS 3.1.2 REACTMTY ANOMAUES 1 a 4
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3.1.2 - DOC . CHANGE / DIFFERENCE COMMENT.
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!' 1 R.1 CTS 3.3.E.1 requires an analysis to determine and The jushficaten for relocabon indcates i explain the cause of the reactivity difference exceedmg that this requrement will be relocated in 1 the 1 % delta k/k between the actual and the predcted the Bases. R;ever, the Bases for ITS rod density. ITS 3.1.2 has deleted this ".iivir..& r tion and 3.1.2 does not require the evaluation to moved it to the Bases of ITS 3.1.2. ITS Basis 3.1.2 be cuir6:ed as was requred by CTS !
states " Restoration to withm the limit could be performed 3.3.E.1, it only provides an opbon that an by an evaluation of the core design and safety analysis evaluabon "could be per'ormed". This is l
- l to determme the reason for the anomaly. This significantly dWerer.t than the original l evaluation normally reviews the core condsbons to requimment contairaxi in CTS 3.3.E.1.
l
, i determme their consistency with m " put to design Provide information as indicated in the ."
i calculabons. Measured core and process parameters Bases. l lI are also normally evaluated to determine that they are l within the bounds of the safety analysis, and the safety l analysis calculational models may be reviewed to venfy [
! that they are adequate i+eee.-;ation of the enre !
condMions." ,
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-l: 3.1.3 : DOC -
CHANGE / DIFFERENCE - COMMENTo t
l' 1 L7 CTS 3/4.3.A.3 requires that the Control Rod Dnve (CRD) Identdy the specde plard configuration j housmg support is in place whenever the reactor is management documents that ensure the i
~! pressunzed. This is to ensure the operabihty of the housings are in place. In addibon, .}
! Control Rods and to saissfy the transient accident identdy the specdc change controls t
- i analysis. The ITS 3.1.3 deletes this requirement
- rom associated with these documents. !
,, the Control Rod OPERABILITY section. The docussson of Change L7 states that the OPERABILITY !
requirements assumed in the safety analysis (UFSAR l Sechon 3.9A.1.4) are the same as the control rod l OPERABILITY requwemente. In addition, plant -
! configuranon management provides adequate controls i for ensuring the housmgs are in place.
! 2 L1 CTS 4.3.A.2.(i) requires that each partially or fuNy This extension of the CTS SurveiNance i l j withdrawn OPERABLE control rod is exercised at least Test interval needs further,L'! :-t- , i
! once per week. ITS SR 3.1.3.3 requires each partiaNy rele> to plant opershons. i withdrawn control rod one notch every 31 days. For !
partlepywithdrawn control rods, this is an extension of j the surveiNance times from the CTS requwement of once per week to once every 31 days. ;
3 L3 CTS 4.3.A.2.f requiret exerciseng each partisNy or fully Same as above i jj withdrpwn OPERABLE control rod one notch every i
, ; week. ITS SR 3.1.3.3 for partispy withdrawn control l
- l rods requees inserting the OPERABLE control rods one notch every 31 days.
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DAEC ITS 3.1.3 CONTROL ROD OPERABM. TTY ,
! '3.1.3 DOC CHANGE / DIFFERENCE COMMENT i'
'j 4 A.2 CTS 3.3.A.2.d requires that each control rod drive is 3.1.3.5 deals with overtravel. The coupled to its drive. ITS 3.1.3 does not contain this comment is confusmg. What other i requirement. The DOC states that the control rod is spediei is being referred to.
! coupled to its drive is a requwement contamed in ,
i; another Specification.
5 A.4 The CTS does not have requwements for" slow" control This appears to be a more restrictive rods. ITS 3.1.3 Action A.1 requres venfication that the change.
i stuck control Tod separatum criteria are met.
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i j DAEC ITS 3.1.4 CONTROL ROD SCRAM TRAES
- ,3.1.4
- DOC '
CHANGE / DIFFERENCE-COMMENT or?
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i 1 Not used.
2 R.1 CTS 3.3.D requires the scram time testmg from the fully USFAR7, if 50.5g process. Provide withdrawn posson *.o the drop-out of the reed switch at specific plant documentation where this the rod poseon. requirement is located.
l1 3 Li CTS 3.3.D.4 requires a plant shutdown if the average This is a Beyond Scope issue.
i scram time limits specilled in either CTS 3.3.D.1, .2, or
.3 are exceeded. ITS 3.1.4 allows contmued operation
- with up to 6 slow rods for certain comtunation of scram
}'
times, which do not meet the scram times for the
- individual rods as contained in Table 3.1.4-1. The scram times l'sted e for the indwiriusi rods does not cesespe,M to either of the average tunes listed in CTS l 3.3.D.1 or .2. This change in the requirements is based on the supporting analyses contained in BWROG-8754 (9-17-87).
4 None CTS 3.3.D.1 and .2 requires that the scram insertion Some as above times are not greater than the values in the tables based
- j on an average insertson time for all of the control rods as a function of rod posson.11S SR 3.1.4.1 requwes that j j the control rod scram times are within the limits of Table i
3.1.4-1. Related to BWOG-8754 (9-17-87).
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_.__.__.__._._._._________.__..__._____..__.__._._____.__..________________________________________.__m_._____.__ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - , ___.a
- . _ _ . _ . _ _ _ _ _ . . . _ . _ _ _ . _ , _ _ _ . _ _ . _ . _ _ . _ _ _ _ . . _ . . _ _ _ _ . _ _ _ . . _ . _ _ . . _ . _ . . ~ . _ _ _ . . . . . _ . _ _
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l DAEC ITS 3.1.4 CONTROL ROD SCRAM TNIES i i
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i .3.1M- DOC -
CHANGDDIFFERENCE ' _ COMMENT '!
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! 5 P.11 CTS 3.3.D.1 and .2 requwes . ~_..v the scram inserhon Provide analyses supporting the !
i tunes for the average and the for the three fastest statements made in P.11 regarding _
, control rods. These inserhon tunes are venfied prior to delehon of SR 3.1.4.3. This SR should l' exceedmg 40% power. STS 3.1.4.3 requwes venfying be retained unless an analysis can show that each affected control rod scram time is within the othenese. Also jushfy why this is not a lt time lwnsts at any reactor dome pressure prior to genene issue if supportmg analysis is
'l declaring a control rod operable after work on control acceptable. !
, rod or CRD system that could affect scram time. The l ITS 3.1.4 deleted this STS requirement. The STS DOC, i
P.11, for the STS does not provide definshve justificahon for the delebon of the STS requirements, for example, 1 the DOC states, "Addmg this survesNance in the ITS ;
would not significantly increase retcbr safety, since the amount of coverage added by this Surveillance is such a small percentage of a typical operating cycle. In !
addstion, the number of slow or inoperable control rods !
expected to be detected by this surveillance is expected to be very small, based on the past success of scram time testing...". +
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9 DAEC ITS 3.1.4 CONTROL ROD SCRAM TIMES w
3.1.4 DOC CHANGE / DIFFERENCE: COMMENT.
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6 P.6 CTS 4.3.D.1 requires that after each refuehng outage all Gereric Traveler TSTF-88 was retumed l l OPERABLE rods are scram time tested. Restrictions on to the industry. No response has been l the testing are: the system pmsure above 950 psig; received. All changes based on TSTF 88 and the testmg completed prior to exceedmg 40% rejected. j power. ITS 3.1.4.2 requires venfying that the rod scram time is within the limits of Table 3.1.4-1 with the eactor pressure greater or equal to 800 psig prior to exceedmg 40% RTP after work on the CDR that could affect scram times and prior to exceedmg 40% RTP after fuel movement in the pressure vessel. The basis for this change is Generic Traveler TSTF-88.
7 R.1 CTS 3.3.D requires the scram time testmg from the fully USFAR? Identify the control document withdrawn posdion to the drop-out of the reed switch at and the change process.
the rod ponden.
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t DAEC ITS 3.1.5 CONTROL ROD SCRAM ACCUMULATORS i
<3.1.5 DOC CHANGE / DIFFERENCE - COMMENT.
- or. - !
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! d' 1 R.1 CTS 4.3.2.a requires venfymg the accumulator pressure Identdy the plant procedures that contain i
!j and level alarms are OPERABLE once a week. ITS SR the moved requirements. j ji 3.1.5.1 requires vertfymg the accumulator pressure is t
,j greater than or equal to 940 psig every 7 days. The !
, accumulator level verificahon is moved to unspecified t
- ; tant procedures. I l
ltl 2 L1 CTS 3.3.A.2.a.(i) requires that if the rod scram Smce there is little deerence in scram i j accumulator is inoperable, verify the reactor pressure is tunes for the 900 psig and the 950 psig ~l
,; greater than 950 psig. ITS 3.1.5 Action Condson A is in the CTS and since other allowances l l
- defined as one control rod scram accumulator are taken because the STS provides l
- inoperable with reactor steam dome pressure greater some relief, the CTS number of 950 psig j than or equal to 900 psig. should be retained.
l i 3 P.13 CTS 3.3.A.2.a.(iii) a;ed .e tequwes, that if more than one This is an extension of an allowed outage i accumulator is inoperable, fully insertmg the rod and time. Therefore it is a Beyond Scope !
disarming the associated controls is required. ITS 3.1.5 item. !
^
Achon B recc%s that with two or more control rod scram accumulators inoperable with reactor steam dome pressure greater than or equal to 900 psig, restore the ,
i pressure to greater than or equal to 940 osig vnthin one j hour of discovery. The STS allows a 20 mmute recovery !
time from the time of discovery.
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,! 4 A.2 CTS 4.3.A.2.s requires venfying pressure and level once Where did the 970 psig in the CTS I a week to determne that the accumulators are matup come from. It is not in the ITS.
,l OPERABLE. The iTS markup of the CTS indmates that j the words added to CTS should include "venfy ,
, accumulator pressure greater than or equal to 970 psig." >
! ITS SR 3.1.5.1 requires accumulator pressure greater i than or : jual to 940 psig.
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!!1 DAEC ITS 3.1.7 STANDSY UQUE CONTItOL (SLC) SYSTEM l
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- l ;3.1.7 DOC CHANGFJDIFFERENCE COtaAENT i or' i ,
- D i
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, 1 P.17 The)% provided is very
[ cordumns and should be reselmen.
f-l 2 L2 CTS 3.4.B.1 aAours for tw inopersbuty of a SLC Provide ad StionaljueWRcagon for tw ,
Lj system pr::vided met the redundant SLC components ar-r =hany s regelse to plant operatens !
are verlRed to be OPERABLE. ITS 3.1.7 Acton B and cunent Econsing benis.
1 asows two inoperable SLC subsystems for up to 8 l
- 1 hours prior to requiring unit shutdown. I
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-I 3 LCY-2 CTS 4.4.A.2 requires that me survemence test interval This extension of a surveRance test !
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- be at least once per OPERATING CYCLE for testng interval. Therefore, it is a Beyond Scope j various components ===arimaad wim me SLC. The issue. l l' previous OPERATING CYCLE was 18 montis. ITS l ., , 3.1.7.7 and 3.1.7.8 for verfying Wie flour and into Wie i reactor vessel and verifying the heat tracmg pipeg
- . betuneen the storage tank and pump suction is
- unblocised is increased fiom 18 to 24 months. .
i:
4 L.3 CTS 4.4.A.2.b requires testing both exploowe valves in Beyond Scope also. i the SLC System each opersing cyde by finng them l i and injechng flour of dominerabad water into the l reactor vessel. ITS SR 3.1.7.7 requires this test every j
, 24 months on a Staggered Test Basis sudi that both j i valves are tested every 48 months. !
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4 DAEC ITS 3.1.7 STAND 8Y UQUID COKfROL (SLC) SYSTEM i
3.1.7 DOC , CHANGE / DIFFERENCE COMMENT or J JFD -
l l, 5 M.3 CTS 4A.A.2.c reouwes venfying :he sodium is this change acceptable based on ,
pentaborate storage tar
- discharge line conveys 26.2 system desgn and cumut licenssng
, spm at least once per operahng cycle. ITS SR 3.1.7.8 bases. Does it add any opershonal
- adds a second frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after constraints.
solubon te..@More is restored to vnthm limds.
A 6 R.1 CTS 4.4.A.2.a requwes the proper operation and What is the basis for moving this to the sew. of the relief vale is checked at least once per IST. is this the industry gm.
OPERATING CYCLE.
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DAEC ITS 3.1.8 SCRAM DISCHARGE VOLUME (SOV) VENT AND DIIANI VALVES j (3.1.8 DOC ,
p- CHANGE / DIFFERENCE , COMMENT 1 Lcy-2 CTS 4.3.B.3 requires that the surveiBance test interval Beyond Scope be at leest once per OPERATING CYCLE for lestng various components ===an=aad witt #ie SDV. The CTS OPERATING CYCLE is 18 rnonths. ITS 3.1.8.3 for venfying the cioomg time for the vent and drain valves opens when the actuoi or simuished scram signal is l
reset is increased to 24 mones.
2 L2 CTS 3.3.A.2.e and .f requires placing the reactor in a This explains what you did, bui not why
'l; Cold Shutdown wilhin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> r the control rod you did it and its acceptab5ty bened on requeements are not met. ITS 3.1.8 Acton C requires cummt kansmg base, system design or -
operatonal constramts.
that r the required Actions and ===aa=aad completion time are not met, enter into MODE 3 wilhm 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
3 P.12 ITS 3.1.8.2 is a change from the requirements This change is generic and should be e=#shs=hed in STS 3.1.8.2 which requires the handled as such.
surveigance performed every 92 days ratier in accordance with the inservice Testing Program.
4 L1 CTS 4.3.B.2 requees verifying the closura time and Wie Extension of frequency test interval valves are open after removal of tie close signal for Beyond Scope.
Scram Discharge volume vent and Drum valves every quarter. ITS SR 3.1.8.2 requires West the valves cycle from the fupy dosed to the fupy open positen in accordance witi the Inservice Testing Program. ITS SR 3.1.8.3 requires verifying every 24 months an acceptable cecoure time anor recept of a scrarn signal and the valves are open when the scram wgnal is removed.
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'! DAEC ITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)
I!
!. 3.2.1- DOC CHANGE / DIFFERENCE- COMMENT o 1 i
i 1 M.1 " CTS 4.12.A requwes venfying the APLHGRs once per Provide discussion of WM booed i day wher* at 25% HTP. ITS SR 3.2.1.1 requires once on system design, plant operabon or the l!
within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after at 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> impact on cummt licensing basis.
'l i thereafter.
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DAEC ITS 3.2.2 MINIMURE CRITICAL POWER RATIO (ABCPR)
L3.2.2 DOC CHANGE / DIFFERENCE COMMENT '
1 M.1 CTS 4.12.C.1.a requwes venfying the MCPR once per Justdicabon based on system design,
,' j day when :t 25% RTP. ITS SR 3.2.2.1 requwes once plant operabons, etc.
,j ' within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after :t 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I j thereafter.
!! 2' R.1 CTS SR 4.12.C.1.b requires venfying the MCPR is idenbfy plant procedures and method of
- ! greater than or equal to the limsts folkwng any control.
sigr#, cord change in power level or distribubon. ITS 3.2.2 does not address the MCPR limits and the ;
requwement is moved to plant procedures. !
3 M.2 ITS SR 3.2.2.2 adds a requwement to determine the Provide )_h regarding cunent .!
MCPR limits once within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each operabng pr.ct;ce and its impact on plant i
., ceiv@M of ITS SR 3.1.4.1. This requirement is not operabons and design. ;
{ included in CTS 4.12.C. j l ,
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