ML20033F068
| ML20033F068 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/06/1990 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20033F069 | List: |
| References | |
| ULNRC-2167, NUDOCS 9003150396 | |
| Download: ML20033F068 (6) | |
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c g March 6, 1990 U.S. Nuclear Regulatory Commission i
Attn: Document Control Desk t
Mail Station Pl-137 t
Washington, D.C.
20555 ULNRC-2167
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Gentlemen DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.7.1.2 AUXILIARY __FEEDWATER SYSTEM Union Electric Company herewith transmits an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant.
This_ amendment application adds additional conditions to the Limiting Conditions for Operation to address flowpath requirements for the motor-driven and steam turbine-driven auxiliary feedwater pumps.
It also imposes additional requirements to the ACTION Statements if any of the Essential Service Water (ESW) system valves to the steam turbine-driven auxiliary feedwater pump are inoperable or if one ESW loop is inoperable.
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, 5000
$ w<x5-i Donald F.
Schnell JMC/ dis ph Attachments
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I' STATE OF MISSOURI )
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CITY OF ST. LOUIS )
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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 L
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, M
M By_
Alan C.
Passwater Manager, Licensing and Fuels Nuclear SUBSCRIBED and sworn to before me this 44 day of
'7)UML 1990.
l l dAK YLYW DARBARA PFAFF NOTARY PUDUC, STAit OF MISSOURI My COMMISSION EXPIRES APRIL 22, 1993 i
ST. LOUIS COUNTY
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ces.. Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 H. Street, N.W.
Washington, D.C.
20037 Dr. J. O. Cermak CFA, Inc.
b 4 Professional Drive (Suite 110)
Gaithersburg, MD 20879 R. C.
Knop p
Chief, Reactor Project Branch 1 L
U.S.-Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
' Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 L
Steedman, Missouri 65077 S. V. Athavale (2) l Office of Nuclear Reactor Regulation U.S.' Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20052 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 i-
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Attcchment 1 P:gs 1 cf 2 ULNRC-2167 SAFETY EVALUATION This amendment.equest revises Technical Specification 3/4.7.1.2 Auxiliary l
Feedwater (AFW) System. The proposed revision adds additional conditions to the Limiting Conditions for Operation to address flowpath requirements 4
for the motor-driven and steam turbine-driven auxiliary feedwater pumps.
l It also imposes additional requirements to the ACTION Statements to clarify the action to be taken in the event any of the Essential Service Water (ESW) system valves to the steam turbine-driven auxiliary feedwater pump are inoperable or if one ESW loop is inoperable.
Union Electric's l
compliance with the current technical specification has been consistent with the proposed additions to the ACTION Statements. These additional requirements provide clarity and consistency to assure proper compliance is being maintained.
The proposed additions to the ACTION Statements provide direction in the event that any one of the ESW supply valves to the steam turbine-driven auxiliary feedwater pump (AL-HV-32, AL-HV-33, AL-V-11, and AL-V-14 as shown on FSAR Figure 10.4-9) is inoperabic.
It also clariffes the required action to be taken in the event that one ESW loop is inoperable.
This clarification is needed to provide a balance between single failure, seismic design, and pipe break criteria for Callaway Plant.
From a singic failure perspective, AL-HV-32, AL-HV-33. AL-V-11, or AL-V-14, could be inoperable indefinitely since the turbine-driven AFW pump would still have two suction sources availabic, i.e. via the unaffected ESV train as well as from the Condensate f,torage Tank -(CST) through AL-HV-36.
The latter is the normal and preferred source.
However, our seismic design commitment to Regulatory Guide 1.29 in FSAR Table 3.2-3 requires that all plant items needed to cope with a secondary side pipe break inside containment be seismically designed.
Further, the secondary systems break r
criteria discussed in FSAR Tabic 3.6-4 (Table Note D.4) states that no non-safety related equipment is required for safe shutdown after a secondary side pipe brosk.
Since the CST is non-ceismic and has no safety design basis, it can not be assumed to mitigate this pipe break.
If the CST suction source is non-rechanistically assumed to be unavailable due to these licensing commitments, then both ESW trains must be available to satisfy single failure criteria in support of AFW functional requirements i
in the mitigation of a secondary side pipe break. We consider the CST unavailability in this scenario to be non-mechanistic since, as discussed in FSAR Section 10.4.9.3 (Safety Evaluation Two), breaks in seismic Category I piping (e.g. secondary side pipe breaks inside containment) are not postulated during a seismic event.
As such, we would not declare the turbine-driven AFW pump inoperable due to the failure of one ESW supply valve since the other ESW train and the CST source are available after a secondary side break, absent a seismic event.
Therefore, this additional ACTION Statement is needed to satisfy our licensing commitments, clarify operability requirements, and to provide a comparable level of plant protection as given by Technical Specification 3.7.1.2 and 3.7.4.
This same logic can be used in the event that the steam turbine-driven AFW l'
pump and one motor-driven ArW pump have an associated ESW train inoperable.
The steam turbine-driven AW pump would still be operable since the other ESW train and the CST source are available, however the affected motor-driven AFW pump would be declared inoperable and the associated ACTION Statement for one AFW pump being inoperable would be entered.
Even though the inoperability of one ESV train to the steam turbine-driven A W
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ULNRC-2167 Pap 2 cf 2 O'*
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- pump'would not actually-render the pump inoperable, since the other ESW suction path and the CST source are available after a secondary sidebreak absent a seismic event, a clarification of the existing ACTION Staterent is needed to insure consistency with the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time for the
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ESW System.
Since a single failure does not have to be postulated during a technical specification allowed outage time, the additional ACTION Statements do not adversely affect the steam turbine-driven APW pump's I
ability to perform as designed. Therefore the loss of one train of ESW would result in the declaration of only one APW pump inoperable, and that one would be the inoperable train's associated motor-driven AFW pump.
Based on the above. discussions and the considerations presented in
,, the proposed revisions to Technical Specification 3/4.7.1.2 do not increase the probability of occurrence or the consequences of an l
accident or malfunction of equipment important to saft.ty previously i
t evaluated fn the safety equipment important to_aafety previously evaluated in the safety analysis report; or create a possibility for an accident or r
malfunction of_a different type than any previously evaluated in the safety analysis report; or reduce the margin of safety an defined in the basis for any technical specification.
Therefore, the proposed revisions do not adversely af fect or endanger the health or safety of the general public or involve a significant safety hazard.
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ULNRC-2167 i
SIGNIfICANT_ljAZARDS CONSIDERATION This amendment request revises Technical Specification 3/4.7.1.2 Auxiliary
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reedwater ( AW) System. The proposed revision adds additional conditions to the Limiting Conditions for Operation to address flowpath requirements for the motor-driven and steam turbine-driven auxiliary feedwater pumps.
It.also imposes additional requirements to the ACTION Statements to clarify i
the action to be taken in the event any of the Essential Service Water j
(ESW) system valves to the steam turbine-driven auxiliary feodwater pump are inoperable or if one ESW loop is inoperable. Union Electric's l
compliance with the current technical specification has been consistent i
-with the proposed additions to the ACTION Statements. These additional requirements provide clarity and consistency to assure proper compliance is being maintained.
1.
The proposed additional ACTION Statements do not involve a significant increase in the probability or consequences of an l
accident previously evaluated.
This change constitutes an additional Ifmitation, rnstriction, or control not presently included in the technical specifications which is consistent with operability requirements of the AW and ESW systems. The change provides a balance between single failure, noismic design, and pipe break criteria while satisfying our licensing commitments.
The credit given to the non-seismic condensato storage tank is 5
appropriately restricted.
It does not affect the ability of the AW System to perform its intended safety function. The change clarifles the operability determination for the existing ACTION Statements, and provides additional conditions for the Limiting Conditions for Operation.
2.
The proposed additional ACTION Statements do not create the possibility of a new or different kind of accident from any previously evaluated. This is based on the fact that the method and manner of plant operation remains unchanged. The allowable outage time for an inoperablo ESW supply valve to the turbinn-driven AW pump is consistent with that of Technical Specifications 3.7.1.2 and 3.7.4.
There are no now failure modos or mechanisms associated with the proposed change..The change clarifles the operability determination for the existing ACTION Statements to remove confusion when an ACTION Statement is entered, and adds additional conditions to the existing Limiting Conditions for Operation.
3.
The proposed additional ACTION Statements do not involve a significant reduction in a margin of safety. This is based on the fact that no plant design chcnges are involved. The change i
provides clarification for operability determination to the existing ACTION Statements, and adds additional conditions to the Limiting Conditions for Operation.
Based on the above discussions it has been determined that the requested Technical Specification revisions-do not involvo a significant increase in v
-the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of a new or different kind of accident or condition over previous evaluations; or involve a significant. reduction in a margin of safety. Therefore, the requested
- 11 cense' amendment does not involve a significant hazards consideration.