ML20012B757

Application for Amend to License NPF-30,revising Tech Specs 4.0.3 & 4.0.4 & Associated Bases to Incorporate Changes Provided in Generic Ltr 87-09,dtd 870604

ML20012B757
Person / Time
Site:	Callaway
Issue date:	03/08/1990
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20012B758	List: ML20012B757 ML20012B763
References
GL-87-09, GL-87-9, ULNRC-2172, NUDOCS 9003160231
Download: ML20012B757 (6)

Text

.1901 Granot Street

"'4 Post O' tee Bs 149 L r St. itwi.t M:s.soun C3166 314$542650 i'

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DonaldF. Schnell N March 8, 1990 E C sena y,ce nescent tvua w

[63 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-137

Washington, D.C. 20555

[ Gentlemen: ULNRC- 2172 L

DOCKET NUMBER 50-483 CALLAWAY PLANT i

REVISION TO TECHNICAL SPECIFICATION 3/4.0 SURVEILLANCE INTERVALS Union Electric Company herewith transmits an application for amendment to Facility Operating License No.

NPF-30 for Callaway Plant. l This. amendment application revises Technical l Specifications 4.0.3, 4.0.4 and their associated bases to incorporate the changes provided in Generic Letter 87-09, dated June 4, 1987.

Attachments 1, 2, and 3 contain the Safety Evaluation, the Significant Hazards Evaluation, and the Proposed Technical Specification Changes in support of this '

amendment request. The proposed changes will become effective for Union Electric implementation upon NRC approval.

Very truly yours, 7 NMI'Y D

g onald F. Schnell ,

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STATE OF MISSOURI )

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l Alan C. Passwater, of lawful age, being first duly sworn upon oath says that he is Manager, Licensing and Fuels (Nuclear) for Union Electric Company; that he has read the foregoing document and knows the. content thereof; that he has executed the same for and on g behalf of said company with full power and authority to do so; and

that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By ( ' L Alan C. Passwater Manager, Licensing and Fuels Nuclear SL'BS D nd sworn to bef e me this -

-day A A.4. o 0: h/A

- r u ao BARBARA J. PFAFF NOTARY PUBLIC, STATE OF MISSOURI WY COMMIS$10N EXPIRES APRIL 22. 1993 ST. LOUIS COUNTY l

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i b ce s . Gerald Charnoff, Esq.

!: Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C. 20037 Dr. J. O. Cermak CFA, Inc.

p al Professiona.1 Drive (Suite 110) l' Gaithersburg, MD 20879 p

g R. C. Knop

[. Chief, Reactor Project Branch 1 F U.S. Nuclear Regulatory Commission L Region III p .99 Roosevelt Road

'i Glen Ellyn, Illinois 60137 l- Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission l' RR#1 Steedman, Missouri 65077 S. V. Athavale (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 l 11555 Rockville Pike Rockville, MD 20852

> Manager, Electric Department

! Missouri Public Service Commission P.O. Box 360 Jefferson City, MO~65102 Ron Kucera Department of Natural Resources P.O.' Box 176 Jefferson City, MO 65102

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Att: chm:nt 1 PCO3 1 of 2

# ULNRC - 2172 >

Safety Evaluation ,

I- This amendment request revises Technical Specification 3/4.0 and l'

[ its associated Bases to incorporate the changes provided in Generic Letter (GL) 87-09, dated June 4, 1987, which offers guidance on  :

short-term Technical Specification improvements. These changes and

.their respective safety evaluation are discussed hereinafter. ,

1. Technical Specification 4.0.3 states that the failure to perform a surveillance within the specified time interval t shall constitute a failure to meet the LCO's operability l' Requirements. Therefore,.if a Surveillance Requirement is not met as a result of the failure to schedule the  ;

performance of the surveillance, the LCO would not be met.

Consequently, the LCO's Action Requirements must be met as l when a surveillance verifies that a system or component is inoperable.

It is overly conservative to assume that systens or components are inoperable when a surveillance requirement has not been performed. The opposite is in fact the case; the vast inajority of surveillances demonstrate that systems ,

or components in fact are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of the required i surveillance. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the Technical Specifications should

• include a time limit that would allow a delay of the required actions to permit the performance of the missed ,,

surveillance.

This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as ..'

the safety significance of the delay in . completion of the surveillance. 'The 24-hour time limit provided in GL 87-09 '

would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown ,

Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action Requirements before the surveillance can be completed.

1 Attcchm:nt 1 i Pcg3 2 of 2 i

< ULNRC - 2172 e  !

2. Specification 4.0.4 prohibits entry into an operational mode  !

or other specified condition when Surveillance Requirements j have not been performed within the specified surveillance .

interval. A conflict with this Technical Specification )

exists when a mode change is required as a consequence of i

> shutdown Action Requirements and when the Surveillance  !

Requirements that become applicable have not been performed within the specified surveillance interval. For instance, ,

the plant could previously have been in a mode for which the Surveillance Requirements were not applicable and, ,

therefore, the surveillance may not have been performed i within the specified' time interval. Consequently, the l Action Requirements of the LCO associated with these Surveillance Requirements apply and the unit may have to be placed in a lower mode of operation than that required by ,

the original shutdown Action Requirements, or other remedial j actions may have to be taken, if the surveillence cannot be I completed within the time limits for these actions, i The first problem arises because conformance with '

Specification 4.0.4 would require the performance of these surveillances before entering a mode for which they apply.

Source and intermediate range nuclear instrumentat$on and cold overpressure protection systems are examples of systems for which Surveillance Requirements may become applicable at, t a consequence of mode changes to comply with shutdown Action ,

Requirements. The second problem has been mitigated by the i change in Specification 4.0.3 to permit a delay of up to 24

• hours in the applicability of the Action Requirements, -

thereby placing an appropriate time limit on the completion of Surveillance Requirements that become applicable as a consequence of mode changes to comply with Action Requirements. However, the first problem can be further resolved by a change to Specification 4.0.4, thus lowering the potential for a plant upset and challenge to safety systems if surveillances are performed during a shutdown to '

comply with Action Requirements. It is not the intent of Specification 4.0.4 to prevent passage through or to  :

operational modes to comply with-Action Requirements and it I should not apply when mode changes are imposed by Action Requirements. Accordingly, Specification 4.0.4 should be modified per GL 87-09 to note that its provisions shall not prevent passage through or to operational modes as required to comply with Action Requirements.

Pursuant to the above information, as provided per GL 87-09, this amendment request does not adversely affect and does not involve an unreviewed safety question, k

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[: s' PSCO 1 of 1 g d ULNRC - 2172 L Significant Hazard Evaluation l

This amendment request consists of changes to Technical Specification 3/4.0 and its associated Bases. These changes have been made using the. guidance provided in Generic Letter (GL) 87-09, dated June 4, 1987, and are being jointly considered in this evaluation for significant haRards.

This change does not involve a significant increase in the 1 probability or consequences of an accident previously evaluated. The

- change merely is an effort to clarify, simplify, and streamline the

[ specifications in accordance with the guidance a part of the implementation of the Commission'provided s PolicyinStatement GL 87-09onaus l

Technical Specification Improvements.

This change does not create the possibility of a new or different The proposed:

p kind of accident from any accident previously evaluated.

change does not alter the requirements and the method and manner of plant operation are unchangod. Its intent is to resolve the problems regarding the general requirements of Section 4.0 of the Technical f Specifications on the applicability of Surveillance Requirements.

l This is accomplished by providing alternatives to these sections-using L the guidance provided in GL 87-09.

This change does not involve a significant reduction in a margin of safety. This is based on the fact that no design change is involved, but the intent of the Technical Specifications is clarified to-enhance the overall safety to the plant and general public.

Based on the above discussions, the amendment request does not

~ involve a significant increase in the probability or consequences of-an accident previously evaluated; nor create the posalbility of a.new or different kind of accident from any accident _previously evaluated; nor involve a reduction in the required margin of safety. Based on the foregoing, the requested amendment does not pretent a significant.

hazard, i

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