ML20082S770
| ML20082S770 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/26/1995 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20082S772 | List: |
| References | |
| ULNRC-3205, NUDOCS 9505030212 | |
| Download: ML20082S770 (16) | |
Text
1901 Chowcau Avenue Post Offte Box 149 St laws. Masoun 63166
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314-554-2C50 Donald F. Schnell W
Etscruic Senior L' ice President nusc.,
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April 26, 1995 U.S. Nuclear Regulatory Commission ATTN: Document. Control Desk Mail Station P1-137 WaFhington, D.C. 20555 Gentlemen:
ULNRC-3205 DOCKET NUMBER 50-483 CALLAWAY PLANT CONTROL ROOM EMERGENCY VENTILATION SYSTEM
References:
- 1. ULNRC-3050 dated August 4, 1994
- 2. ULNRC-3165 dated March 14, 1995
- 3. ULNRC-3180 dated March 28, 1995
- 4. OL Amendment No. 96 dated March 30, 1995 Union Electric Company herewith transmits an application for amendment to Facility Operating License No. NPF-30 for the Callaway Plant.
This amendment application includes changes to the Surveillance Requirements of Technical Specification 3/4.7.6 that would reduce the upper limit on the flow rate through the control room filtration subsystem (flow not to exceed 2200 cfm) and would adopt ASTM D-3803-1989 as the laboratory testing standard for control room filtration and control building pressurization charcoal adsorber. The Bases are revised accordingly. Laboratory testing of the charcoal adsorber will be performed at 30 C and 70% relative humidity for a methyl iodide penetration not to exceed 2%. Reference 1 submitted an amendment application to replace the Containment Spray Additive System with a passive Recirculation Fluid pH Control System consisting of stainless steel baskets in the containment recirculation sumps containing trisodium phosphate dodecahydrate (TSP-C). References 2 and 3 submitted supplementary information on the Containment Spray Additive System retirement application to support the issuance of Reference 4, including the flow rate and testing changes that are the subject of this amendment i
application.
9505030212 950426 PDR ADOCK 0a000483 p
PDR l
t U. S. Nucle r Regulatory Commiccion Page 2 The Callaway Plant Onsite Review Committee and the Nuclear Safety Review Board have reviewed this amendment application. Attachments 1 through 4 provide the Safety Evaluation, Significant Hazards Evaluacion, Environmental Consideration, and proposed Technical Specification revisions, respectively, in scoport of this request. It has been determined that this amendment application does not involve an unreviewed safety question as detenmined per 10CFR50.59 nor a significant hazard consideration as determined per 10CFR50.92. Pursuant to 10CFR51.22(b), no environmental assessment need be prepared in connection with the issuance of this amendment.
If you have any questions on the attachments, please contact us.
Very truly yours, 9
4* Donald F. Schnell GGY/sid Safety Evaluation Attachments:
1 2 - Significant Hazards Evaluation 3 - Environmental Consideration 4 - Proposed Technical Specification Revisions
c_,-
. STATE OF MISSOURI
)
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SS COUNTY OF CALLAWAY )
Garry L. Randolph, oflawful age, being first duly sworn upon oath says that he is Vice President, Nuclear Operations, 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.
d By '
f 4+
darry L. Randolp'h Vice President Nuclear Operations SUBSCRIBED and sworn to before me this Alv day of Mor//
,1995.
Mua RQaA v
LANAR.JACOBS,NotwyPubre STATE OF MISSOURl, COUNTY OF CALLAWAY MYCOMMISSION EXP!RES:11613?3
a cc:
T. A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.
Washington, D.C.
20037 M. H. Fletcher Professional Nuclear Consulting, Inc.
19041 Raines Dr Derwood, MD 20855-2432 M. J. Farber r
Chief, Reactor ProjectsSection III A U.S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 60532-4351 Bruce Bartlett Callaway Resident Office U.S. Regulatory Commission RR#1 Steedman, MO 65077 l
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 20852-2738 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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ULNRC-3 205 ATTACHMENT ONE SAFETY EVALUATION l
Page 1 of 5 SAFETY EVALUATION INTRODUCTION This amendment application includes changes to the Surveillance Requirements of Technical Specification 3/4.7.6 that would reduce the upper limit on the flow rate through the control room filtration subsystem (flow not to exceed 2200 cfm) and would adopt ASTM D-3803-1989 as the laboratory testing standard for control room filtration and control building pressurization charcoal adsorber. The Base are revised accordingly. Laboratory testing of the charcoal adsorber will be performed at 30 C and 70% relative humidity for a methyl iodide penetration not to exceed 2%. ULNRC-3050 dated August 4, 1994 submitted an amendment application to replace the Containment Spray Additive System with a passive Recirculation Fluid pH Control System consisting of stainless steel baskets in the containment recirculation sumps containing trisodium phosphate dodecahydrate (TSP-C).
ULNRC-3165 dated March 14, 1995 and ULNRC-3180 dated March 28, 1995 submitted supplementary information on the Containment Spray Additive System retirement application to support the issuance of OL Amendment No. 96 dated March 30, 1995, including the flow rate and testing changes that are the subject of this amendment application.
BACKGROUND The Control Room Emergency Ventilation System (CREVS) includes the Control Room Air Conditioning Units (SGK04A,B),
the Control Room Filtration Units (FGK01A,B), and the Control Building Pressurization Units (FGK02A,B), as depicted in FSAR Figure 9.4-1 sheets 1 and 3 and discussed in FSAR Section 9.4.1. The CREVS is designed to maintain the habitability of the control room during a design basis LOCA by creating a positive pressure envelope within the control room, by filtering the supply air to remove particulates, and by providing charcoal adsorber to remove iodines. This will ensure that the doses to control room personnel will be within the limits of GDC 19.
A sufficiently positive pressure envelope is created by the Control Building Pressurization Units supplying 500 cfm
(+500, -50) of filtered air to the control building of which 400 cfm (+140, -40) is directed to the control room for maintaining the required +1/8 inch water gauge (IWG) positive pressure and the remaining 100 cfm (+360, -10) is I
divided among the 2000', 2016', 2032' and 2073' elevations of the control building to produce a positive pressure to limit unfiltered inleakage, as discussed in FSAR Section 9.4.1.2.3.
Filter adsorber units FGK01A,B and FGK02A,B are periodically tested to ensure the design flow rate is
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maintained under both clean and dirty filter conditions. The control room is periodically tested to ensure at least a
+1/8 IWG pressure can be maintained during a Control Room Ventilation Isolation Signal. Charcoal samples are routinely tested based upon total run time hours (720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />) or installation time (18 months) or following an event such as painting, welding, or fire. The charcoal sample is analyzed by a testing laboratory to specified conditions representative of service during a design basis accident.
CONTROL ROOM DOSE CONSIDERATIONS OL Amendment No. 96 approved the retirement of the Containment Spray Additive System. One of the key accident analysis assumptions approved in that amendment was a change in the filter decontamination efficiency from 90% to 95% for the calculation of doses to the control room personnel. NRC approval of that change was contingent on the assurance of a 0.25 sec average atmosphere residence time in the control room filtration and control building pressurization filter adsorber units, per position C.3.1 of RG 1.52, as well as a change in the testing protocol for the charcoal adsorber san.ples to reflect testing per ASTM D-3803-1989 at 30 C and 70% relative humidity (RH) for a methyl iodide penetration not to exceed 2%. This amendment application will ensure that the above criteria are met.
The 30 C/70% RH test to be performed on FGK01A,B and FGK02A,B is representative of the postulated conditions for the control room after a design basis LOCA. FGK02A,B have heaters that are designed to control the humidity of incoming outside air. The current Specification 3/4.7.6 penetration limit of 1% for testing at 80 C/'/0% RH per test standard RDT M-16-1T is less conservative thun a 2%
penetration limit for testing at 30 C and 70% RH due to the more stringent tolerances placed upon temperature and humidity in ASTM D-3803-1989 as well as the test being performed at the lower temperature of 30 C. The new flow rate tolerances for the control room filtration units supersede the changes approved in OL Amendment No. 47, reverting back to the originally licensed flow rate tolerances.
DETERMINATION OF NO UNREVIEWED SAFETY OUESTION The proposed changes to the Technical Specifications do not involve an unreviewed safety question because the operation of Callaway Plant in accordance with these proposed changes would not:
Attachm:nt 1 4
Page 3 of 5 (1)
Involve an increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR.
Overall protection system performance will remain within the bounds of the accident analyses documented in FSAR Chapter 15, WCAP-10961-P, and WCAP-11883 since no hardware changes are proposed.
The CREVS will continue to function in a manner consistent with the above analysis assumptions and the plant design basis. There will be no degradation in the performance of or an increase in the number of challenges to equipment assumed to function during an accident situation.
These Technical Specification revisions do not involve any hardware changes nor do they affect the probability of any event initiators.
The change to the control room filtration flow rate is consistent with the original licensing basis and will ensure an average atmosphere residence time of greater than or equal to 0.25 sec. There will be no change to ESF actuation setpoints or accident mitigation capabilities. The laboratory testing will demonstrate the required adsorber performance after a design basis LOCA.
The control room dose analyses assume a single failure of one control room filtration fan which is isolated by operator action after 30 minutes.
Prior to isolation, an unfiltered flow from the control building is assumed to enter the control room at a rate of 540 cfm via the failed train. Filtered flow via the operable train consists of 540 cfm from the control building and 1440 cfm of filtered recirculation flow, for a total flow rate through the operable control room filtration unit of 1980 cfm as stated in FSAR Table 15A-1. This total flow rate is within the proposed upper limit. As such, there will be no changes required to the control room dose analyses.
Based on the above, these Technical Specification changes will not increase the probability or consequences of an accident or malfunction.
(2)
Create the possibility for an accident or malfunction of a different type than any previously evaluated in the FSAR.
As discussed above, there are no hardware changes associated with these Technical Specification revisions nor are there any changes in the method by which any
Page 4 of 5 safety-related plant system performs its safety function.
Revisions to the Surveillance Requirements for the CREVS will ensure that the control room dose analysis assumptions made in support of OL Amendment No. 96 are valid. Changes to the control room filtration unit flow rate are more limiting than that currently specified and have already been implemented by resetting the open limit switches on the respective units' outlet dampers, GK-HZ-0019B and -0030B. This flow rate is consistent with the design basis for the filtration units as originally licensed.
No new accident scenarios, trausient precursors, failure mechanisnm, or limiting single failures are introduced as a result of these changes. There will be no adverse effect or challenges imposed on any safety-related system as a result of these changes. Therefore, the possibility of a new or different kind of accident is not created.
There are no changes which would cause the malfunction of safety-related equipment, assumed to be operable in the accident analyses, as a result of the proposed Technical Specification changes. No new mode of failure has been created and no new equipment performance burdens are imposed.
Therefore, the possibility of a new or different malfunction of safety-related equipment is not created.
(3)
A reduction in the margin of safety as defined in the basis for any Technical Specification.
There will be no margin reduction since these changes are in the conservative direction and have already been approved by NRC via the approval of OL Amendment No.
- 96. The reduced upper bound flow rate for the control room filtration units is consistent with their design basis and will maintain an average atmosphere residence time greater than or equal to 0.25 sec under both clean and dirty filter conditions. The new charcoal adsorber sample laboratory testing protocol is more stringent than the current testing practice and more accurately demonstrates the required performance after a design basis LOCA.
There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. There will no impact on the overpower limit, DNBR limits, Fg, FAH, LOCA PCT, peak
Page 5 of 5 local power density, or any other margin of safety.
These changes will ensure that the criteria of GDC 19 are met.
Based on the information presented above, the proposed amendment does not involve an unreviewed safety question and wi'll not adversely affect or endanger the health or safety of the general public.
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1 ULNRC-3205 ATTACHMENT TWO SIGNIFICANT HAZARDS EVALUATION r
a Page 1 of 3 SIGNIFICANT HAZARDS EVALUATION This amendment application includes changes to the Surveillance Requirements of Technical Specification 3/4.7.6 that would reduce the upper limit on the flow rate through the control room filtration subsystem (flow not to exceed 2200 cfm) and would adopt ASTM D-3803-1989 as the laboratory testing standard for control room filtration and control building pressurization charcoal adsorber. The Bases are revised accordingly. Laboratory testing of the charcoal adsorber will be performed at 30 C and 70% relative humidity for a methyl iodide penetration not to exceed 2%. ULNRC-3050 dated August 4, 1994 submitted an amendment application to replace the Containment Spray Additive System with a passive l
Recirculation Fluid pH Control System consisting of stainless steel baskets in the containment recirculation sumps containing trisodium phosphate dodecahydrate (TSP-C).
ULNRC-3165 dated March 14, 1995 and ULNRC-3180 dated March 28, 1995 submitted supplementary information on the Containment Spray Additive System retirement application to support the issuance of OL Amendment No. 96 dated March 30, 1995, including the flow rate and testing changes that are the subject of this amendment application.
The proposed changes to the Technical Specifications do not involve a significant hazards consideration because operation of Callaway Plant in accordance with these changes would not:
(1)
Involve a significant increase in the probability or consequences of an accident previously evaluated.
Overall protection system performance will remain within the bounds of the accident analyses documented in FSAR Chapter 15, WCAP-10961-P, and WCAP-11883 since no hardware changes are proposed.
The Control Room Emergency Ventilation System (CREVS) will continue to function in a manner consistent with the above analysis assumptions and the plant design basis. There will be no degradation in the performance of or an increase in the number of challenges to equipment assumed to function during an accident situation.
These Technical Specification revisions do not involve any hardware changes nor do they affect the probability of any event initiators. The change to the control room filtration flow rate is consistent with the original licensing basis and will ensure an average atmosphere residence time of greater than or equal to 0.25 sec.
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_Page 2 of 3 There will be no change to ESF actuation setpoints or accident mitigation capabilities. The laboratory testing will demonstrate the required adsorber performance after a design basis LOCA.
The control room dose analyses assume a total flow rate through the control room filtration units that is less than the proposed upper limit. As such, there will be no changes required to the control room dose analyses.
Based on the above, these Technical Specification changes will not increase the probability or consequences of an accident or malfunction.
(2)
Create the possibility of a new or different kind of accident from any accident previously evaluated.
As discussed above, there are no hardware changes associated with these Technical Specification revisions nor are there any changes in the method by which any safety-related plant system performs its safety function.
Revisions to the Surveillance Requirements for the CREVS will ensure that the control room dose analysis assumptions made in support of OL Amendment No. 96 are valid. Char.ges to the control room filtration unit flow rate are more limiting than that currently specified and have already been implemented by resetting the open limit switches on the respective units' outlet dampers.
This flow rate is consistent with the design basis for the filtration units as originally licensed.
No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of these changes. There will be no adverse effect or challenges imposed on any safety-related system as a result of these changes.
Therefore, the possibility of a new or different kind of accident is not created.
(3)
Involve a significant reduction in a margin of safety.
There will be no margin reduction since these changes are in the conservative direction and have already been approved by NRC via the approval of OL Amendment No.
- 96. The reduced upper bound flow rate for the control room filtration units is consistent with their design basis and will maintain an average atmosphere residence time greater than or equal to 0.25 sec under both clean and dirty filter conditions. The new charcoal adsorber sample laboratory testing protocol is more stringent than the current testing practice and more accurately l
Attachm:nt 2 Page 3 of 3 demonstrates the required performance after a design basis LOCA.
There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions. There will no impact on the overpower limit, DNBR limits, Fg, FAH, LOCA PCT, peak local power density, or any other margin of safety.
These changes will ensure that the criteria of GDC 19 are met.
Based upon the preceding information, it has been determined that the proposed changes to the Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, it is concluded that the proposed changes meet the requirements of 10CFR50.92(c) and do not involve a significant hazards consideration.
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.4 ULNRC-3205 4
I ATTACHMENT THREE ENVIRONMENTAL CONSIDERATION i
Page 1 of 1 ENVIRONMENTAL CONSIDERATION This amendment application includes changes to the Surveillance Requirements of Technical Specification 3/4.7.6 that would reduce the upper limit on the flow rate through the control room filtration subsystem (flow not to exceed 2200 cfm) and would adopt ASTM D-3803-1989 as the laboratory testing standard for control room filtration and control building pressurization charcoal adsorber. The Bases are revised accordingly. Laboratory testing of the charcoal adsorber will be performed at 30 C and 70% relative humidity for a methyl iodide penetration not to exceed 2%. ULNRC-3050 dated August 4, 1994 submitted an amendment application to replace the Containment Spray Additive System with a passive Recirculation Fluid pH Control System consisting of stainless steel baskets in the containment recirculation sumps containing trisodium phosphate dodecahydrate (TSP-C).
ULNRC-3165 dated March 14, 1995 and ULNRC-3180 dated March 28, 1995 submitted supplementary information on the Containment Spray Additive System retirement application to support the issuance of OL Amendment No. 96 dated March 30, 1995, including the flow rate and testing changes that are the subject of this amendment application.
The propesed amendment involves changes with respect to the use of facility components located within the restricted area, as defined in 10CFR20, and changes surveillance requirements. Union Electric has determined that the proposed amendment does not involve:
(1)
A significant hazards consideration, as discussed in 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 10CFR51.22 (c) (9). Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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