ML20046A068

Application for Amend to License NPF-30,revising Tech Specs 3/4.8.1.1 & 3/4.8.1.2 Re Ac Sources,Operating & Shutdown

ML20046A068
Person / Time
Site:	Callaway
Issue date:	07/16/1993
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046A069	List: ML20046A068 ML20046A071
References
ULNRC-2824, NUDOCS 9307260086
Download: ML20046A068 (11)

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1901 Chouteau Avinue l , Post CHice B's1 9 l

St. Lou:s. Maouri 63156

• 31K554 2650 l-

""""'s ~ "c" Union l Etscrnic July 16, 1993 ff$((##

hb U.S. Nuclear Regulatory Commission Attn: Document Control Desk i j Mail Station P1-137 l Washington, D.C. 20555 ULNRC-2 824 Gentlemen:

i DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.8.1.1, 3/4.8.1.2

A.C. SOURCES, OPERATING AND SHUTDOWN Union Electric Company herewith transmits an l application for amendment to Facility Operating License No. NPF-30 for Callaway Plant ~ .

l This amendment application changes the minimum l required storage volume of the Emergency Fuel' Oil storage and day tanks from 85,300 gallons and 390 gallons to 80,400 gallons and 510 gallons. .These changes are the result of inconsistencies found by Union Electric in the ,

Technical Specification-Bases and calculations used to determine tank capacities while performing a self-imposed Electrical Distribution System Functional Assessment.

Attachments 1, 2, 3, and 4 contain the Safety Evaluation, the Significant Hazards Evaluation, the Environmental Evaluation, and the Proposed Technical '

Specification Changes in support of this amendment request.

Very truly yours,

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230041 e ~

Donald F. Schnell l-I

! JMC/ dis l

Attachments I\

j 9307260086 930716 'Fj Av p PDR ADOCK-05000403 P PDR S

STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

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 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.

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By # 6  !

Alan C. Passwater  !

l Manager, Licensing and Fuels l Nuclear TA' SUBSCRIBED and sworn to before me this Y day of /}htki , 1993, f l7 Abu wy 0./y9 4/4 py BARBARA J, PFAfF, NOTARY PUBUC-STATE OF MES0ljRl MY COMMISSION EXPIRES APRIL 22, 1937 SI, Louts COUNTX t

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cc- T. A. Baxter, Esq.

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

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

18225-A Flower Hill Way Gaithersburg, MD 20879-5334 L. Robert Greger.

Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission l Region III 799 Roosevelt Road -

Glen Ellyn, Illinois 60137 l

Bruce Bartlett Callaway Reside st Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 L. R. Wharton (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera l Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 l

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i bcc: D. Shafer/A160.761

/QA Record (CA-758)

Nuclear Date E210.01. 4 DFS/ Chrono D. F. Schnell 1 I

J. E. Birk J. V. Laux l M. A. Stiller G. L. Randolph j R. J. Irwin P. Barrett C. D. Naslund j W. R. Campbell i

A. C. Passwater D. E. Shafer W. E. Kahl-S. Wideman ( WCNOC)

M. D. Archdeacon'(Bechtel) l l S. E. Sampson q l NSRB (Sandra Dale) l l

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Attachments ULNRC-2824 l

( Attachment 1 - Safety Evaluation Attachment 2 - Significant Hazards Evaluation 3-- Environmental Evaluation Attachment Attachment 4 - Proposed Technical Specification Changes i

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Attachment 1 Page 1 of 3 ULNRC - 2824 SAFETY EVALUATION This amendment request revises Technical Specifications 3/4.8.1.1 and 3/4.8.1.2, A. C. Sources, Operating and Shutdown. The proposed revision changes the' minimum required storage volume of the Emergency Fuel Oil storage and day tanks from 85,300 gallons and 390 gallons to 80,400 gallons and 510 gallons. These changes are the result of inconsistencies found by Union Electric, in the calculations and T/S Bases for tank capacities, while performing a self-initiated Electrical Distribution System Functional Assessment (EDSFA). The just completed EDSFI performed by the NRC ,

re-examined this issue and it was determined that NUREG-1431 '

provided bases for the change to day tank level. This submittal is a T/S enhancement.

The Emergency Fuel Oil day tanks'are the suction sources for the

, engine driven fuel oil pumps on the diesel generators. They are l

sized to supply a minimum of one hour's worth of fuel for the diesel generators with the diesels running at their continuous rating plus a 10% margin :(sea ANSI N195-1976) . We believe this is equivalent to the NUREG-1431 bases which is full load plus 10% for the level surveillance value. The Emergency Fuel Oillstorage tanks are underground tanks which supply the day tanks with fuel oil for the diesel generators on demand. 'They are each sized to supply fuel oil to their day tanks for a minimum of seven days with their respective diesel engine running at the continuous rating plus an additional volume to be used for testing the diesel engine (see ANSI N195-1976). The transfer pumps located in the fuel oil storage tanks start on low level and stop on high level via level transmitters installed on the day tanks. However, if the diesel generators are running the transfer pumps will run continuously, thus the level increase in the day tanks is not an issue for long term diesel operability.

Bechtel calculation M-JE-321, which was used to calculate the minimum storage volume required for both the storage and day tanks, contained some inconsistent assumptions. The specific gravity used for the fuel oil was API 28 degrees where as Technical Specification (T/S) 4.8.1.1.2d.la allows a range between 27 and 39 degrees API. If a fuel oil specific gravity of 39 degrees-API were used in lieu of 28 degrees the density would be less thus requiring a larger minimum volume to attain the required running time for the diesel generators. This larger required minimum volume would be applicable to both the day tanks and storage tanks.

Another inconsistency was the method used to determine Net Positive Suction Head Available (NPSHA) for the transfer pump located in the fuel oil storage tanks. The original calculation did not account for the absolute pressure exerted on the fuel oil due to atmospheric pressure thus the NPSHA was calculated with a i static elevation of fuel oil above the pump centerline as being needed for proper pump operation. The results of this calculation determined that the tank contained a larger unusable volume of

Attachment 1 Page 2 of 3 ULNRC -2824 fuel oil which in turn required the minimum volume for 7 days running at continuous rating to be overly conservative. Union Electric engineering staff calculations indicate that the unusable volume of fuel oil in the tank to be considerably less than what was originally calculated. These calculations were made using the less dense specific gravity fuel oil, API 39 degrees, to allow for additional conservatism.

Union Electric's Addenda to Bechtel calculation M-JE-321 has determined that the minimum volume required for the day tank should be increased to 510 gallons to allow for the possibility that API 39 degrees specific gravity fuel oil may be used and to 3 correspond to latest T/S guidance. This minimum required is an f

increase of 120 gallons over the current T/S requirement and adds conservatism to the day tanks functionality. Union Electric currently has in place administrative controls to maintain the minimum volume in the day tanks at 510 gallons. This same addenda also has determined that the minimum volume required for the fuel oil storage tanks can be decreased to 80,400 gallons because of the differences used in fuel density and NPSHA for the transfer pumps. The more conservative fuel oil specific gravity of 39 degrees API, and the corrected NPSHA for the transfer pumps was used in the addenda calculation to determine the lower minimum required volume.

The proposed changes to Technical Specifications 3/4.8.1.1 and 3/4.8.1.2 do not involve an unreviewed safety question because operation of Callaway Plant with these changes would not:

1. Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report. These changes do not affect the operability requirements of the emergency diesel generators or the ability of the fuel oil system to perform its intended safety function. The increased minimum volume in the day tanks and the decreased minimum volume in the storage tanks was calculated using methods specified in ANSI N195-1976 which is endorsed in Regulatory Guide 1.137.

2. Create a possibility for an accident or malfunction of a different type than previously evaluated in the safety analysis report. There is no new type of accident or malfunction being created and the method and manner of plant operation remains unchanged. The changes correct the minimum required storage volumes using the.most conservative parameters for calculating these volumes.

3. Reduce the margin of safety as defined in the bases for any Technical Specification. This is based on the fact that no plant design changes are involved and the minimum required storage volumes are consistent with the requirements of ANSI N195-1976 and Regulatory Guide 1.137.

Attachment 1 Page 3 of 3, ULNRC 2824 Given the above discussions as well as those presented in the  ;

Significant Hazards Evaluation, the proposed changes do not l adversely affect or endanger the health,or safety of theLgeneral public or involve a significant safety hazard. The proposal- i corrects an inconsistency in the plant technical specifications that causes a compliance problem. .j j

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I Attachment 2

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SIGNIFICANT HAZARDS EVAL 0ATION This amendment application requests a change to Technical Specifications (T/S) 3/4.8.1.1 and 3/4.8.1.2, A. C. Sources, Operating and Shutdown, to change the minimum required storage volume of the Emergency Fuel Oil storage and day tanks from 85,300 f gallons and 390 gallons to 80,400 gallons and 510-gallons. These changes are the result of inconsistencies found by Union Electric, in the calculations and T/S Bases for tank capacities, while-performing a self-initiated Electrical Distribution System .

Functional Assessment (EDSFA). The just completed EDSFI performed r by the NRC re-examined this issue and it was determined'that NUREG-1431 provided bases for the change to day tank level. This submittal is a T/S enhancement.

The proposed changes to Technical Specifications 3/4.8.1.1 and 3/4.8.1.2 do not involve a significant hazards consideration because operation of Callaway Plant with-these changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated. . The current minimum required volume of the day tanks as given in T/S 3.8.1.1b.1 and 3.8.1.2b.1 is based on fuel oil with a specific gravity value in the upper range of values allowed by T/S. Calculations made using fuel oil with a specific gravity of 39 degrees API, which is the minimum allowed specific gravity, indicate a larger minimum required volume is needed in the day tanks. The increased minimum required i volume provides additional conservatism for the day tanks to I

perform their intended safety function based on the possibility of using different specific gravity fuel oil.

The current minimum required volume of the storage tanks as given in T/S 3.8.1.lb.2 and 3.8.1.2b.2 was calculated by using an overly conservative het Positive-Suction Head (NPSH) available calculation. The original calculation. assumed a static head was needed in order for the NPSH available to exceed the NPSH required and assure proper operation of the fuel oil transfer pumps. Union Electric calculations have l determined that the NPSH required for the transfer pumps is j maintained as long as the pump suction is submerged. Based l on this calculation the minimum required volume of the storage tanks can be reduced and the diesel generators can still achieve their required seven days of operation at continuous' rating plus an additional volume available to be used for testing.

2. Create the possibility of a new or different kind of accident from any previously evaluated. There is no new type of-accident or malfunction being created and the method and L iner of plant operation remains unchanged. The safety

( tign bases in the FSAR have not been altered, the re3a'cament for continuous operation remains unchanged.

l Attachment 2 Page 2 of 2 ULNRC -2824

3. Involve a significant reduction in a margin of safety. There are no plant design changes involved and no changes are being made to the safety limits or safety system settings that would adversely impact plant safety. The minimum required storage volumes of the day and storage tanks are being changed based on calculations using conservative data.

Based on the above discussions, it has been determined that the requested Technical Specification revisions do not involve a ,

significant increase in the probability or consequences of an j 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 i reduction in a margin of safety. Therefore, the requested' license l amendment does not involve a significant hazards consideration.

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Attachment 3 Page 1 of 1 ULNRC- 2 82 4 -

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, ENVIRONMENTAL CONSIDERATION i

This amendment application revises the requirements of Technical Specification 3/4.8.1.1 and 3/4.8.1.2 for the minimum required storage volume of the Emergency Fuel Oil storage and day tanks from 85,300 gallons.and 390 gallons to 80,400 gallons and 510 gallons.

The proposed amendment involves changes with respect to the use of facility components located within the restricted

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area, as defined in 10 CFR 20 and revises a limiting condition for operation. Union Electric has determined that the proposed amendment does not involve:

(1) A significant hazard consideration, as discussed in Attachment 2 of this amendment application; (2) A significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (3) A significant increase in individual or cumulative occupational radiation exposure. ,

Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth'in 10 CFR 51.22 (c) (9) . Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment. '

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