ML102510275

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Request for Additional Information, Round 2, License Amendment Request, Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System Instrumentation, for Extension of Completion Times
ML102510275
Person / Time
Site: Callaway 
Issue date: 09/07/2010
From: Thadani M
Plant Licensing Branch IV
To: Elwood T, Maglio S
Union Electric Co
Thadani, M C, NRR/DORL/LP4, 415-1476
References
TAC ME2822
Download: ML102510275 (2)


Text

REQUEST FOR ADDITIONAL INFORMATION CALLAWAY PLANT, UNION ELECTRIC COMPANY, LICENSE AMENDMENT SUPPLEMENT (LCDN 09-0039) FOR COMPLETION TIME EXTENSIONS FOR TS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION FUNCTIONS TAC Number ME2822 The NRC staff requests additional information to complete its review of the license amendment request for revision of Technical Specification (TS) 3.3.2, Engineered Safety Feature System (ESFAS)

Instrumentation Function 6.g., Trip of all Main Feedwater Pumps and Action Statement J, for the Condition of One or more main Feedwater Pumps trip channel(s) inoperable.

By [[letter::ULNRC-05665, Application for Amendment to Facility Operating License NPF-30 (LDCN 09-0039) Completion Time Extensions for TS 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation Functions|letter dated November 25, 2009]], Union Electric Company (licensee) proposed TS change to permit a 24-hour Completion Time (CT) for placing a single Main Feedwater (MFW) Pump separation group channel in trip. During this 24-hour period, with only one channel inoperable and prior to placing its separation group channel in a trip condition, the logic would still maintain the safety function of starting the Auxiliary Feedwater (AFW) Pumps if the unit experienced the loss of both Main Feedwater (MFW) Pumps due to the remaining separation group channels still being operable during that 24-hour period.

Subsequent to the November 25, 2009 amendment request, the NRC staff issued exigent amendment (ML101100665, ME3595 dated May 5, 2010) which permits placing multiple (one or more) inoperable MFW Pump separation group channels in trip for the existing 1-hour CT period, even if a loss of safety function condition exists. This loss of safety function can exist for either of two reasons: (1) separate condition entries are allowed for each MFW Pump trip function (as per an initial note in TS 3.3.2); or, (2) a subsequent trip of the running MFW pump during the 1-hour CT prior to the affected,Reset MFW pump, requiring LCO entry, having its separation group channels placed in trip. In its review of the exigent amendment, the NRC staff recognized that if a certain combination of channels were inoperable, then the loss of safety function condition would exist.

Based on the limited time of 1-hour, the regulatory consistency of TS actions required following loss of important equipment, and the significance of the safety function, the NRC staff approved the 1-hour CT.

The August 24, 2010 supplemental submittal, which incorporates the initial amendment with the exigent amendment changes, proposes that the Condition J. CT be increased to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This change would permit unavailability of the specified safety function of starting the AFW Pumps on loss of all MFW Pumps for the same two reasons as stated above, but now for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CT.

Based on the above NRC staff review, the NRC staff has following three additional questions:

(a) What additional justification can be provided to clarify the industrys regulatory consistency by increasing the unavailability for the TS safety function from 1 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?

(b) The NRC staff noted that the 24-hour CT may be used for operational and/or maintenance convenience, while the controls of a MFW Pump are in Reset. Since the stated intent for exigent amendment request discussed MFW pump operations during plant start-up and shutdown with one MFW pump in Reset, the increased CT would expose the plant to a

potential loss of the AFW actuation safety function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> should the separation group channels for the Reset MFW Pump not be placed in a trip condition and the running MFW Pump fail. What additional justification can you provide to justify the operational intent in employment of the proposed Condition J?

(c) The original November 2009 license amendment request was noticed to the public in the Federal Register on April 29, 2010. The August 2010 supplemental submittal expanded the scope of the original license amendment request by extending the loss of safety function duration from 1 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, but a No Significant Hazards Determination was not provided to address this change. Please describe what changes are needed to the No Significant Hazards Determination in order to complete the supplemental submittal.