ML20236R043

Forwards Request for Addl Info on Proposed Conversion to Improved Standard TSs for Comanche Peak Steam Electric Station,Units 1 & 2

ML20236R043
Person / Time
Site:	Comanche Peak
Issue date:	07/15/1998
From:	Polich T NRC (Affiliation Not Assigned)
To:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
TAC-M98778, TAC-M98779, NUDOCS 9807210211
Download: ML20236R043 (9)

Text

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l Mr. C. Lcnce Terry July 15,1998

.C.- TU Electric

. Senior Vice President & Principal Nuclear Officer

! ATTN: Regulatory Affairs Department P.O. Box 1002 Glen Rose, Texas 76043

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR COMANCHE PEAK STEAM ELECTRIC STATION, l (CPSES), UNITS 1 AND 2 (TAC NOS. M98778 AND M98779)

Dear Mr. Terry:

The Nuclear Regulatory Commission staff is reviewing TU Electric's proposed license amendment to convert the current technical specifications for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, to the improved Standard Technical Specifications.

TU Electric provided their proposed license amendment request by letter dated May 15,1997.

The staff has reviewed selected portions of the application. Based on its review, the staff has detem1ined that additionalinformation is needed in Section 5.0, Administrative Controls as discussed in the enclosure. S!nce you worked with three other utilities in preparing your submittal, the enclosure contains the request for additional information (RAl) questions for all four utilities. However, you need only reply to the RAI questions associated with Callaway Plant, Unit 1 as identified in the table within the enclosure.

To assist the staff in maintaining its review schedule, please respond to the questions pertaining to CPSES Units 1 and 2 within 30 days of the date of this letter. If you have any questions regarding the RAI, please contact me at (301) 415-1038. If all four utilities would like to have a common discussion, a single meeting, or phone call can be coordinated.

Sincerely, ORIGINAL SIGNED BY:

/

Timothy J. Polich, Project Manager ,

Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 , DISTRIBUTION: /

and 50-446 . .> ,Dochsta OGC PUBLIC ACRS

Enclosure:

Request for Additional PDIV-1 Reading PGwynn, RIV information EAdensam (EGA1) CHawes JHari on - WBeckner cc w/ encl: See next page TPolicii JLuehman

' Document Name: CPITS.RAI i

OFC PD4-1 PD4-2 TSB /, /b /2, NAME TPolich e::u EPeyto, WBeckner-DATE 7 /jf/ 98 7 /19 / 98 7 / I/98 OFFICIAL RECORD COPY

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• \*****/ July 15,1998 Mr. C. Lance Terry TU Electric Senior Vice President & Principal Nuclear Officer ATTN: Regulatoiy Affairs Department P.O. Box 1002 Glen Rose, Texas 76043

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED CONVERSION TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR COMANCHE PEAK STEAM ELECTRIC STATION, (CPSES), UNITS 1 AND 2 (TAC NOS. M98778 AND M98779)

Dear Mr. Terry:

The Nuclear Regulatory Commission staff is reviewing TU Electric's proposed license amendment to convert the current technical specifications for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, to the improved Standard Technical Specifications.

TU Electric provided their proposed license amendment request by letter dated May 15,1997.

The staff has reviewe:1 selected portions of the application. Based on its review, the staff has determined that additional information is needed in Section 5.0, Administrative Controls, as discussed in the enclosure. Since you worked with three other utilities in preparing your submittal, the enclosure contains the request for additional information (RAI) questions for all four utilities. However, you need only reply to the RAI questions associated with CPSES Units 1 and 2, as identified in the t'ble within the enclosure.

To assist the staff in maintaining its review schedule, please respond to the questions pertaining to CPSES Units 1 and 2 within 30 days of the date of this letter. If you have any questions regarding the RAI, please contact me at (301) 415-1038. If all four utilities would like to have a common discuss!on, a single meeting, or phone call can be coordinated.

Sincerely,

~d)fh Timothy J.Idich, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/lV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Request for Additional Information cc w/ encl: See next page l

Mr. C. Lance Terry TU Electric Company Comanche Peak, Units 1 and 2 cc:

Senior Resident inspector Honorable Dale McPherson U.S. Nuclear Regulatory Commission County Judge P. O. Box 2159 P. O. Box 851 Glen Rose, TX 76403-2159 Glen Rose, TX 76043 Regional Administrator, Region IV Office of the Govemor U.S. Nuclear Regulatory Commission ANN: John Howard, Director 611 Ryan Plaza Drive, Suite 400 Environmental and Natural Arlington,TX 76011 Resources Policy P. O. Box 12428 Mrs. Juanita Ellis, President Austin,TX 78711 Citizens Association for Sound Energy 1426 South Polk Arthur C. Tate, Director ,

Dallas, TX 75224 Division of Compliance & Inspection Bureau of Radiation Control Mr. Roger D. Walker Texas Department of Health TU Electric 1100 West 49th Street Regulatory Affairs Manager Austin, TX 78756-3189 i P. O. Box 1002 Glen Rose, TX 76043 Jim Calloway Public Utility Commission of Texas George L. Edgar, Esq. Electric Industry Analysis Morgan, Lewis & Bocklus P. O. Box 13326 1800 M Street, N.W. Austin, TX 78711-3326 Wr hington, DC 20036-5869 i

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, FOUR LOOP GROUP (FLOG) IMPROVED TS REVIEW COMMENTS  !

! , SECTION 5.0 - ADMINISTRATIVE CONTROLS

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5.1-1 CTS 6.1.1, ITS 5.1.1, Change 0101 A and Difference 5.1-2 (Callaway) )

. Comment: Difference 5.1-2 states that the STS is revised to " maintain CTS." However, given

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that Change 01-01-A Insert 1 includes new language into the CTS it is unclear how the CTS is being maintained. This addition of new language into the CTS and deviation from the STS is notjustified. ProvideJustification.

FLOG Response: .

' 5.2-1 STS 5.2.2 b and Difference 5.2-2

, Comment: TSTF-121 has been withdrawn for modification, combination and resubmission. j i- Use current ITS.

FLOG Response: j 5.3-1 ITS 5.3.1 (Wolf Creek, Callaway and Diablo Canyon)

Comment: Part 55 of Title 10 of the Code of Federal Regulations was revised in March 1987 to establish upgraded requirements for licensed reactor operators. NRC Regulatory Guide (RG) 1.8, Revision 2, April 1987, describes methods acceptable to the staff for complying with the

. revised rule. The Statements of Consideration for the Part 55 rule change state that, "Those facility licensees that have made a commitment that is less than that required by the new rules must conform to the new rules automatically." The staff is concemed some facilities continue to have technical specifications that reference older industry standards that may not fully meet the revised requirements of 10 CFR Part 55.

The staff previously considered that the standards applied through the industry's accreditation process were equivalent to the guidance contained in RG 1.8, Revision 2. However, the staff has recently found that current ENPO guidance in this area is very general; only advising licensees to follow regulatory requirements. In RG 1.8, Revision 2, the NRC staff endorses, with conditions, certain parts of industry standard ANSI /ANS-3.1-1981 as an acceptable approach for complying with the qualification and training requirements of 10 CFR Parts 50 and

55. This endorsement applies to the positions identified as shift supervisor, senior operator, licensed operator, shift technical advisor, and radiation protection manager. For positions other than those identified, the RG finds acceptable the approach provided in ANSI N18.1-1971.

- For Callaway, the ITS proposes to adopt the CTS which adopts ANSI /ANS 3.1-1978 for the unit staff (besides SROs, Ros and STAS) and RG 1.8, September 1975 for the radiation protection manager. For Wolf Creek, the ITS proposes to adopt the CTS which adopts ANSI /ANS 3.1-1978 for the unit staff (besides SROs and ROs) and RG 1.8, September 1975 for the radiation L

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. l l protection manager. For Diablo Canyon, the ITS proposes to adopt the CTS which adopts l

ANSl/ANS 3.1-1978 for the unit staff (besides the radiation protection manager) though it does makes a reference to Ros and SROs having to meet the minimum qualifications of Part 55.

Please describe how your commitment to an ANSI standard other than that endorsed by NRC RG 1.8, Revision 2 currently meets the requirements of 10 CFR Part 55, as discussed in the Statements of Consideration for the rule change and would meet those requirements with the j ITS as proposed.

FLOG Response:

1' 5.5-1 Change 217 LS1 (Callaway, Diablo Canyon) l Comment: WOG-85 has not yet become a TSTF. Use current ITS.

j FLOG Response:

i 5.5-2 Difference 5.5-14 l Comment: WOG-85 has not yet become a TSTF. Use current ITS.

l FLOG Response:

l l 5.5-3 ITS 5.5.4 b&g and Difference 5.51 i l

L Comment: Changes are based on a y'et unnumbered traveler. Use current ITS.

L FLOG Response: ,

i 5.5-4 ITS 5.5.4 e and Difference 5.513 Comment: WOG-72 has not yet become a TSTF. Use current ITS.

l FLOG Response:

• j l 5.5-5 ITS 5.5.12 c, CTS 6.8.5 a.3 and Difference 5.5 7 (Callaway)

Comment: The CTS Just refers to 10 CFR Part 20 Appendix B. More information is needed to  !

determine which table govems the current requirements.

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t 3-FLOG Response:

5.54 CTS 3.7.6 and Changes 10-15 LG and 10-17-A (Callaway)

Comment: Please provide a better explanation of the deletion of Pressurization System 2200 CFM +800, -200.

- FLOG Response: ,

5.5 7 CTS 3.7.6 and Changes 10-15-LG and 1017 A (Wolf Creek)

Comment: The CTS markup is inconsistent with the comments as nothing is lined out.

Further, the deletions (at least as they are reflected in ITS 5.5.11) need a better explanation.

Provide explanation.

FLOG Response:

5.5-8 CTS 3.7.6 (3.7.5.1 and 3.7.6.1 DCPP and 3.7.7.1 and 3.7.8 CPSES) and Change 10 08 A l

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- Comment: it should be speciCcally noted as to which CTS requirements were carried over to the VFTP and which were deleted (as well as which section of what standard justified the duplication deletions). Provide explanation and justification, i i FLOG Response:

l 5.5 9 CTS 3.9.13 (3.9.12 - DCPP) and Change 12 04 A (Wolf Creek, Callaway and Diablo Canyon) l L

Comment: it appears that some of the CTS requirements covered by this change were deleted rather than transferred to ITS 5.5.11 as stated. Justify the individual deletions.

FLOG Response:

--5.510 ITS 5.5.11.b (Callaway and Wolf Creek)

, Comment: The smooth copy of the ITS still has the [] around the plant specific bypass value

- FLOG Response:

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Y E _ _ _ _-_----------------: 1 ----- i ----_------- - - - - - - - - - - - - - - - - - - - - - - - - - - --

. -4 5.5-11 ITS 5.5.9 d, ITS 5.5.11 b, and 5.5.13 (Diablo Canyon)

Comment: The smooth copy of the ITS contains a number of administrative errors. Page 5.0 1g of the smooth copy of the ITS has two errors. First, the VFTP section title and the (continued) appear before ITS 5.5.11.b when they should appear at the top of Page 5.0-20.

Second, in 5.5.11 b it should not be "10%at". To be consistent with the rest of the section, Page 5.0-15 should have SG Tube (continued) at the top of the page. Similarly, Page 5.0-23 should have a Diesel Fuel (continued) at the top of the page. 1 FLOG Response:

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5.512 ITS 5.5.11 and CTS 4.7.6.c.2 (Wolf Creek)

Comment: The value of relative humidity is 70% in the ITS,78% in the CTS markup, and 70%

in the CTS. Is it correct to assume the CTS markup value is wrong?

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' FLOG Response:  !

l 5.5-13 Difference 5.5-9 (Diablo Canyon)

Comment: Unlike Comanche Peak, the ITS/ CTS cross reference table does not include any l reference to CTS 3/4.11. Therefore, the difference as written is not detailed enough. Either  !

make the tie in the difference discussion or update the cross reference.

FLOG Response:  !

l 5.5-14 ITS 5.5.11.e and CTS 4.7,8.d.3 (Comanche Peak)  ;

1 Comment: The value for the ESF filtration unit is 100 plus or minus 5 kW in the CTS and 100 i

plus 5 kW in the ITS. Provide correction orjustify change.

! FLOG Response; 4

l 5.5-1 ITS 5.8.5 a.7&8, Changes 0314&15 M

! Comment: it is true that the additions would make the COLR more restrictive however, the removal of the specific values from the TS is a less restrictive change that needs to be justifed.

Provide justification.

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5.6-2 Difference 5.6-2 (Diablo Canyon) I l Comment: TSTF-37 has not yet been approved by the NRC. Use current ITS.

FLOG Response:

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! 5.71 ITS 5.7.2 and Difference 5.7-2 l i l l Comment: TSTF-167 has been rejected by the NRC. Use current ITS.  ;

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e FLOG RAI APPLICABILITY TABLE FOR ITS SECTION 5.0 RAI Number Callaway Comanche Peak Diablo Canyon Wolf Creek 5.1-1 X 5.2-1 X X X X 5.3-1 X X X 5.5-1 X X 5.5-2 X X X X 5.5-3 X X X X 5.5-4 X X X X l 5.5-5 X 5.5-6 X 5.5-7 X 5.5-8 X X X X 5.5-9 X X X l 5.5-10 X X 5.5-11 X 5.5-12 X 5.5-13 X 5.5-14 X 5.6-1 X X X X 5.6-2 X 5.7-1 X X X X l

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