ML102930674

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Request for Additional Information, Round 3, License Amendment Request, Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, for Extension of Completion Times
ML102930674
Person / Time
Site: Callaway 
Issue date: 10/20/2010
From: Polickoski J
Plant Licensing Branch IV
To: Elwood S, Maglio S
Union Electric Co, AmerenUE
Polickoski J, NRR/DORL/LPL4, 415-5430
References
TAC ME2822
Download: ML102930674 (1)


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 (MFW) Pumps, Action Statement J for the Condition of One or more Main Feedwater Pumps trip channel(s) inoperable, and the unused Condition M.

On September 7, 2010, the NRC staff requested additional information (ML102510275) to inquire on the justification for the increase in Auxiliary Feedwater (AFW) unavailability from 1 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the operational intent behind this increase, and the potential changes to the No Significant Hazards Determination. In response to this request, the licensee submitted an additional amendment request supplement dated September 29, 2010 (ML102730351). This supplement modified TS 3.3.2 Condition J and utilized unused Condition M in order to preserve the ESFAS 6.g. AFW safety function following the 1-hour CT. This supplement also asserted that no changes are required for the No Significant Hazards Determination stating that the licensees original responses remain unaffected.

Based on continued NRC staff review of the additional supplement submittal, the NRC staff has two additional questions:

NRC staff analysis of the licensees proposed modifications to TS 3.3.2 Conditions J and M revealed MFW pump trip channel inoperability combinations that are not addressed by either of the proposed conditions. This inoperability of certain combinations of MFW pump trip channels results in the unavailability of the safety function to start the AFW pumps on loss of both MFW pumps. Without a prescribed condition entry, the licensee would have to enter TS 3.0.3.

In addition, the staffs assessment of the licensees application of separate condition entry to be allowed per channel and per multiple MFW pumps in the proposed condition wording is inconsistent with the TS 3.3.2 ESFAS 6.g. function principle configuration of separate condition entry per pump.

Therefore, the staff requests:

(1) Provide justification for allowing inoperability combinations that are not addressed by either of the proposed Conditions J and M and therefore leading to TS 3.0.3 entry.

(2) Provide justification for allowing the use of separate condition entry on a per channel level and per multiple MFW pumps when the TS 3.3.2 ESFAS 6.g. function principle configuration of separate condition entry is per pump.