ML020160333

Issuance of Amendment Reactor Seal Injection Flow, TAC No. MB3744

ML020160333
Person / Time
Site:	Callaway
Issue date:	05/02/2002
From:	Donohew J NRC/NRR/DLPM/LPD4
To:	Randolph G Union Electric Co
Donohew J N, NRR/DLPM,415-1307
References
Download: ML020160333 (10)

Text

May 2, 2002 Mr. Garry L. Randolph Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

Callahan PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: REACTOR PUMP SEAL INJECTION FLOW (TAC NO. MB3744)

Dear Mr. Randolph:

The Commission has issued the enclosed Amendment No. 150 to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated December 13, 2001 (ULNRC-04583), as supplemented by letter dated April 8, 2002 (ULNRC-04635).

The amendment revises Limiting Condition for Operation (LCO) 3.5.5, Required Action A.1 for the LCO, and Surveillance Requirement 3.5.5.1 in TS 3.5.5, "Seal Injection Flow." The revision replaces the flow and differential pressure limits that were stated for the reactor coolant pump seal injection flow by limits provided in Figure 3.5.5-1, which has been added to the TSs.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

1. Amendment No. 150 to NPF-30

2. Safety Evaluation cc w/encls: See next page

May 2, 2002 Mr. Garry L. Randolph Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: REACTOR PUMP SEAL INJECTION FLOW (TAC NO. MB3744)

Dear Mr. Randolph:

The Commission has issued the enclosed Amendment No. 150 to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated December 13, 2001 (ULNRC-04583), as supplemented by letter dated April 8, 2002 (ULNRC-04635).

The amendment revises Limiting Condition for Operation (LCO) 3.5.5, Required Action A.1 for the LCO, and Surveillance Requirement 3.5.5.1 in TS 3.5.5, "Seal Injection Flow." The revision replaces the flow and differential pressure limits that were stated for the reactor coolant pump seal injection flow by limits provided in Figure 3.5.5-1, which has been added to the TSs.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-483 DISTRIBUTION:

PUBLIC GHill (2)

Enclosures:

1. Amendment No. to NPF-30 PDIV-2 Reading WBeckner

2. Safety Evaluation RidsNrrDlpmLpdiv (SRichards)DBujol, RIV RidsNrrPMJDonohew LHurley, RIV cc w/encls: See next page RidsNrrLAEPeyton WJohnson, RIV RidsOgcRp RidsAcrsAcnwMailCenter JWermiel Tech Spec Pages: ML021260007 Package: ML021260615 ACCESSION NO.: ML020160333 OFFICE PDIV-2/PM PDIV-2/LA SXRB/BC OGC PDIV-2/SC NAME JDonohew:lf EPeyton JWermiel JHeck SDembek DATE 4/17/2002 4/17/02 4/17/02 4/19/02 5/2/02 OFFICIAL RECORD COPY

UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 150 License No. NPF-30

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Union Electric Company (UE, the licensee) dated December 13, 2001, as supplemented by letter dated April 8, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-30 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 150 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This amendment is effective as of its date of issuance and shall be implemented prior to entering Mode 3 ascending during the restart from Refueling Outage 12, which is scheduled for the Fall of 2002, subject to the note above Surveillance Requirement 3.5.5.1.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Stephen Dembek, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 2, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 150 FACILITY OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

REMOVE INSERT 3.5-10 3.5-10 3.5-11 3.5-11

--- 3.5-12

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 150 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

By application dated December 13, 2001, as supplemented by letter dated April 8, 2002, Union Electric Company (the licensee) requested changes to the Technical Specifications (TSs, Appendix A to Facility Operating License No. NPF-30) for the Callaway Plant, Unit 1 (Callaway).

The proposed amendment would revise Limiting Condition for Operation (LCO) 3.5.5, Required Action A.1 for the LCO, and Surveillance Requirement 3.5.5.1 in Technical Specification (TS) 3.5.5, "Seal Injection Flow." The revision would replace the flow and differential pressure limits stated for the reactor coolant pump (RCP) seal injection flow in TS 3.5.5 by limits in Figure 3.5.5-1 that would be added to TS 3.5.5.

The additional information in the supplemental letter of April 8, 2002, does not expand the scope of the application as noticed, clarifies the proposed changes given in the application, and does not change the staffs original proposed no significant hazards consideration determination published in the Federal Register on February 5, 2002 (67 FR 5341).

2.0 EVALUATION Seal injection flow to the four RCPs is provided by the two safety-related centrifugal charging pumps (CCPs) from the charging header through the seal injection flow path, which is composed of piping and valves, including the charging pump header and the seal injection throttle valves. The CCPs provide high pressure water to the charging header, which is for safety injection into the reactor coolant system (RCS) and the RCP seal injection flow. The seal injection flow is to protect the integrity of the RCP seals and prevent the seal from becoming a break in the RCS. The seal injection flow is an assumption in the loss-of-coolant accident (LOCA) analyses because it is CCP water that is assumed not to enter the RCS and provide water makeup to the RCS in a LOCA.

The charging flow control valve controls the difference in pressure between the RCS and the charging header. The manual seal injection throttle valves in TS 3.5.5 are adjusted to vary the seal injection flow from the charging header to the RCP seals. The seal injection flow limit is met by adjusting the throttle valves which change the seal flow line resistance from the header to the RCP seals for the pressure difference between the RCS and the header.

The current requirements for the RCP seal injection flow specify that the flow to each pump shall be 7.5 + 0.5 gpm with a 105 (+5, -2) psi differential pressure between the charging header and the RCS pressure. The intent of TS 3.5.5 is to control the seal flow line resistance by properly positioning the throttle valves.

The licensee stated that due to errors in the documentation for License Amendment No. 68, on the maximum and minimum emergency core cooling system (ECCS) flow rates during accidents, which was issued by NRC letter dated March 24, 1992, new seal injection line resistance criteria are required. The errors affect only the seal injection line resistance which determines the seal injection flow for the pressure differential pressure between the charging pump header and the RCS. The errors have the non-conservative effect of increasing the seal injection flow which is not credited for core cooling.

To correct the non-conservative effect of the errors, the licensee has proposed Figure 3.5.5-1 which provides the acceptable region of total seal injection line flow to the four RCPs for a given charging header/RCS differential pressure. The licensee stated that the proposed figure meets the LOCA safety analysis for the maximum flow to the RCP seals, minimum ECCS flow, and avoidance of CCP runout conditions during the LOCA.

The current requirement in TS 3.5.5 and the proposed Figure 3.5.5-1 are equivalent methods to specify the acceptance criteria for RCP seal injection flow. Both specify an acceptance area of seal injection flow for given pressure differential between the charging pump header and the RCS. The licensee stated that specifying a figure for acceptable total injection flow will facilitate the performance of the surveillance test required by SR 3.5.5.1. This is because the proposed figure provides a larger region of acceptable seal injection flow for charging pump header/RCS differential pressures.

Based on the proposed Figure 3.5.5-1 correcting errors in the previous analysis of the seal injection line resistance and meeting the LOCA safety analysis for the maximum flow to the RCP seals, minimum ECCS flow, and avoidance of CCP runout conditions during the LOCA, the staff concludes that the proposed Figure 3.5.5-1 is acceptable for specifying the acceptable limits for the RCP seal injection flow, and the licensees proposed change to LCO 3.5.5 to replace the current acceptance criteria by TS 3.5.5-1 is acceptable.

With the proposed TS Figure 3.5.5-1 specifying the limits on the seal injection flow, the reference to the current acceptance criteria for seal injection flow in Required Action A.1 and SR 3.5.5.1 must also be replaced by a reference to the proposed TS Figure 3.5.5-1. Therefore, the staff also concludes that the licensees proposed changes to replace the current seal injection flow criteria in Required Action A.1 and SR 3.5.5.1 are acceptable.

In its supplemental letter, the licensee stated that they and their vendor Westinghouse, have reload design processes in place to assure that (1) the input values for the LOCA analysis that are sensitive for peak cladding temperature bound the as-operated plant values, and (2) the uncertainties in the parameters are accounted for. Therefore, based on this and the above evaluation, the staff concludes that the proposed amendment to TS 3.5.5 is acceptable.

The staff has also reviewed the licensees changes to the Bases of TS 3.5.5 and to the Final Safety Analysis Report for Callaway that were provided in Attachments 4 and 5 of the application for information purposes. The staff has no disagreement with the changes to these documents.

The licensee stated in its application that the amendment will be implemented during the restart from Refueling Outage 12 which is scheduled for the Fall of 2002. Because LCO 3.5.5 is applicable in Modes 1 through 3, the amendment should be implemented before entry into Mode 3; however, the Note for SR 3.5.5.1 states that the surveillance is "Not required to be performed until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the Reactor Coolant System pressure stabilizes at > 2215 psig and < 2255 psig." This condition will occur during the restart of the plant, but may happen after entry into Mode 3. Based on the Note for SR 3.5.5.1, the amendment must be implemented before the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the RCS pressure stabilizes at > 2215 psig and < 2255 psig during the restart from Refueling Outage 12. (i.e., the amendment must be implemented before SR 3.5.5.1 is required to be performed during the restart from the outage).

3.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Missouri State official was notified of the proposed issuance of the amendment. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes a surveillance requirement. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (67 FR 5341). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Jack Donohew Date: May 2, 2002

Callaway Plant, Unit 1 cc:

Professional Nuclear Mr. Otto L. Maynard Consulting, Inc. President and Chief Executive Officer 19041 Raines Drive Wolf Creek Nuclear Operating Corporation Derwood, MD 20855 Post Office Box 411 Burlington, KA 66839 John ONeill, Esq.

Shaw, Pittman, Potts & Trowbridge Mr. Dan I. Bolef, President 2300 N. Street, N.W. Kay Drey, Representative Washington, D.C. 20037 Board of Directors Coalition for the Environment Mr. Mark A. Reidmeyer, Regional 6267 Delmar Boulevard Regulatory Affairs Supervisor University City, MO 63130 Regulatory Affairs AmerenUE Mr. Lee Fritz Post Office Box 620 Presiding Commissioner Fulton, MO 65251 Callaway County Court House 10 East Fifth Street U.S. Nuclear Regulatory Commission Fulton, MO 65151 Resident Inspector Office 8201 NRC Road Mr. David E. Shafer Steedman, MO 65077-1302 Superintendent Licensing Regulatory Affairs Mr. J. V. Laux, Manager AmerenUE Quality Assurance Post Office Box 66149, MC 470 AmerenUE St. Louis, MO 63166-6149 Post Office Box 620 Fulton, MO 65251 Mr. John D. Blosser, Manager Regulatory Affairs Manager - Electric Department AmerenUE Missouri Public Service Commission P.O. Box 620 301 W. High Fulton, MO 65251 Post Office Box 360 Jefferson City, MO 65102 Mr. Gary McNutt, Director Section for Environmental Public Health Regional Administrator, Region IV P. O. Box 570 U.S. Nuclear Regulatory Commission Jefferson City, Missouri 65102-0570 Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Ronald A. Kucera, Deputy Director for Public Policy Department of Natural Resources 205 Jefferson Street Jefferson City, MO 65101