ML102980369

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Request for Additional Information, Round 4, License Amendment Request, Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, for Extension of Completion Times
ML102980369
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/25/2010
From: Polickoski J
Plant Licensing Branch IV
To: Elwood T, Maglio S
Union Electric Co
Polickoski J, NRR/DORL/LPL4, 415-5430
Shared Package
ML102980368 List:
References
TAC ME2822
Download: ML102980369 (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.

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]] (ML093290318) and supplemented on August 24, 2010 (ML102371010) and September 29, 2010 (ML102730351), Union Electric Company (licensee) proposed changes to TS 3.3.2 function 6.c. Automatic Actuation Logic and Actuation Relays (BOP ESFAS) and related Condition Q; function 6.g. Trip of all Main Feedwater Pumps and related Condition J; and function 6.h. Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low and related Condition O. In section 4.1.2 of in the licensees original November 2009 submittal, the licensee provided an internal fire risk evaluation in support of the technical evaluation for this proposed amendment.

Following NRC staff review of Attachment 1, the NRC staff has two additional questions:

Section 4.1.2 of Attachment 1 describes how the risk from internal fires is calculated to account for the proposed 24-hour Completion Time (CT) for a single Balance of Plant (BOP) ESFAS logic channel train. In this calculation as described, the initiating event frequency for each fire area is multiplied by a probability factor. This probability factor is the difference in Auxiliary Feedwater (AFW) system unavailability for the case where one Auxiliary Feedwater Actuation Signal (AFAS) train is unavailable and the case where no components in the AFW or actuation system are unavailable. The staff assessment agrees that this method of calculating the increase in core damage frequency (CDF) would be a conservative estimate if there is no fire damage to any AFW or supporting system component. However, this implicit assumption of no fire damage is not addressed in the submittal. Instead, a sensitivity study is provided which identifies a doubling of the calculated CDF when it is assumed that both motor-driven AFW pumps are unavailable, and only the turbine-driven AFW pump is free from fire damage. In addition, this submittal does not validate this assumption of the turbine-driven AFW pump remaining free from fire damage.

In addition, the staff notes on page 26 of 41 of Attachment 1 that the probability PAFWAFAS1 is used in the calculation of the CCDP. The probability value of 4.862E-04 is applied to PAFWAFAS1 on page 26, but this value is actually the value for PAFWAFAS4 on page 28 of 41. PAFWAFAS1 is identified as having a value of 4.909E-04 on page 29 of 41.

Therefore, the staff requests:

(1) Identify which analysis areas have fire scenarios which can cause damage to one or more AFW trains and/or their supporting systems. Then, either provide a more rigorous calculation which accounts for this fire damage, or validate the assumption in the sensitivity study that the turbine-driven AFW pump is not also impacted by the same fire scenario.

(2) Clarify which probabilities are intended for the fire risk evaluation per the discussion above, and provide corrected risk metrics, if necessary.