ML20086B063

Application for Amend to License NPF-30,changing TS Surveillance Requirement 4.8.1.1.2.f.(2) to Remove Value of 1352 Kw for Largest Single Load Required to Be Rejected for EDG Testing & State That ESW Pump Is Largest Emergency Load

ML20086B063
Person / Time
Site:	Callaway
Issue date:	11/15/1991
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086B065	List: ML20086B063 ML20086B072
References
ULNRC-2516, NUDOCS 9111200040
Download: ML20086B063 (9)

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, 11;l %1 ,t D ry Donaldi Sthtwil 2992 Etict Titic "ovo=bar 25- t C

P3 U.S. Nuclear Regulatory Commission Attnt Document Control Desk

' Mail Station P1-237 Washington, D.C. 20555 U LNRC-2516 Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT EMERGENCY TECl!NICAL SPECIFICATION Cl!ANGE REQUEST TO SURVEILLANCE REOUIREMENT 4.8.L L 2.f.(2)

Referenco ULNRC-2515 dated November 15, 1991 Union Electric Company (UE) herowlth transmits an application for omorgency amendment to Facility Operating Licenso No. NPF-30 for Callaway Plant. The chango proposes to reviso Technical Specification Survoillanco Requiremont 4.0.1.1.2.f.(2) to removo tho value of 1352 kW for the largest single load required to be rejected for Emergency Diosol Generator Testing. The change would stato that the Essential Servico Water (ESW) pump is the largest single omorgency load.

Reference 1 transmitted a Temporary Waivor of Compliance which was discussed with the NRC and for which verbal approval was granted on November 14, 1991.

On November 14, 1991, UE was informed by another utility that a potential concern existed with the ability to saticfy the 1352 kW requirement of Surveillanco Requirement 4.0.1.1.2.f.(2) since the as installed ESW load is less than 1352 kW. A review of the applicability of the concern to callaway Plant was begun immediately. It was datormined that we had never boon in litoral compliance with this surveillance requiremont although the surveillance has boon conducted por the Toch Spoc .survoillance interval. Specification 3.0.3 was entered upon making that datormination.

Relief in the form of an omorgency technical specification change is necessary to provent the required shutdown of-the plant which is operating at near 100% power.

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U.S. Nuclear Regulatory Commicolon Pago 2 of 2 November 15, 1991 This situation could not reasonably have boon identiflod sooner in that UE took prompt action to determino the applicability of the issuo when it was informed of the concern.

Pursuant to 10CFR50.91(a) (S) , UE hereby requests NRC omorgency authorization and approval of this proposed amendment to Facility Operating License No. NPP-30. The requested omorgency authorization is appropriate because this amendment request involves no significant hazards consideration (Attachmont 2). In addition, the present situation could not be avoided.

As indicated above, UE promptly notified the NRC of this situation and has pursued an expeditious resolution of this matter. The results of the Safety Evaluation (Attachment 1) show that the intent of the surveillanco requirements as defined in regulatory guidanco has boon and will continue to be not with the propoand change.

No unroviewed safety question exists and thoro is no adverso affect on the health and safety of the general public.

The callaway Plant on-Sito Review Committoo and Nuclear Safety Review Board have reviewed and approved thin amendment request.

In accordance with 10CFR50.91(b), UE will promptly provide the Stato of Missouri with a copy of this proposed amendment to ensure their awareness of this request. We appreciato your prompt attention to this amendment request.

Very truly yours,

()p(dalmtw

[

a J Schnell

.//Y^DonaldF.

DS/ dis Attachments: 1 - Safety Evaluation 2 - Significant llazard Evaluation 3 - Environmental Consideration 4 - Proposed Technical Specification Chango

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STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

1 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 ftill power cnd authority to do so; and ,

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

// l l By ## # I M C#W5'"

Alan C. Passwater Manager, Licensing and Fuels Nticle ar SUBSCRIBED and sworn to before me this (5+h day ,

of Nogember ,

1991, Y (N1J G. L WATERS f 40TARY PUCUC, STATE Of f/ISSOURI MY COMM;$310N LXPlHES 3/16195 ST. LOUIS COUN1Y -

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l cc T. A. Baxter, Esq. l Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

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

18225-A Flower Hill Way Gaithersburg, MD 20879-5334 R. C. Knop Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission '

Region III 799 Roosevelt Road Glen Ellyn,--Illinois 60137--  ;

- Bruce Bartlett callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 J. R. Hall (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-L Ron Kucera Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 t

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Attachment 1 ULNRC-2516 Page 1 of 2 SAFETY EVALUATIQB This amendment application revises the 18 month surveillance requirements for Specification 3/4.8.1, A.C. Sources, to replace the phrase "a load of greater than or equal to 1352 kW (ESW pump)" in Technical Specification 4. 8.1.1.2. f . (2) with the phrase "the ESW pump motor load (the largest single emergency load)".

The Bases are also revised to more explicitly discuss this surveillance . This amendment is needed to address literal compliance with the Callaway Technical Specifications.

The proposed change does not involve an unreviewed safety question because operation of Callaway Plant in accordance with this change would not:

(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.

The requested change is administrative in nature and does not involve any design changes or hardware modifications.

The load rejection surveillance test in question is taken from Regulatory Guides 1.9, Revision 1, Position C.5 and Regulatory Guide 1.108, Revision 1, Position C.2.a. (4) which call for a test of the loss of the largest single load. This surveillance test is performed at Callaway by disconnecting an ESW pump motor with the ESW and AC power systems aligned in their emergency operation modes. This meets the requirements of the regulatory guides and represents the worst case loss of a single load. Since there is no installed plant equipment which would allow the measurement of the rejected load in this surveillance, there is no direct way to assure that this load equals the 1352 kW listed in the Technical Specifications. However, the actual kW load associated with the ESW pump motors is less than 1352 kW and can vary slightly depending on plant conditions and motor efficiency. This variance is insignificant as assured by the preventive maintenance program that monitors pump / driver performance. Therefore, there should be no listed value for this load in the Technical Specifications nor is one needed to satisfy the regulatory guide requirements. The intended requirement is to assure that the diesel meets the specified acceptance criteria given the rejection of the ESW pump motor load when the plant is in a lineup representative of emergency conditions at Callaway.

No new design requirements are being imposed on any plant systems or components. There is no change to the 12 second diesel start time assumed in the accident analyses and verified by Technical Specification 4.8.1.1.2.a. (4) nor is there a change to the acceptance criteria for any of the diesel generator surveillance tests, including the startup, rated load, and load rejection tests. There will be no

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l Attachment 1 ULNRC-2516 .

Page 2 of 2 effect on the capability of the diesel generators to supply the loads assumed in the mitigation of the accidents analyzed in FSAR Chapter 15. Since there are no design or performance changes, there will be no increase in the-probability of any accident or equipment malfunction.  ;

Likewise, there will be no effect on the inputs to the dose analyses in the FSAR; therefore, there will be no increase in the consequences of an accident or equipment malfunction.

(2) Create the possibility for an accident or malfunction of a different type than any previously evaluated in che FSAR.

As stated above, the proposed change does not involve any design changes or hardware modifications nor will there be any changes to the intended manner of plant operation or in the method by which any safety-related plant system  !

performs its safety function. No new accident-initiators, transient precursors, failure mechanisms, or limiting ,

single failures are introduced as a result of this change.

(3) Involve a reduction in the margin of safety as defined in the-basis for-any Technical Specification. The Bases for Technical Specification 3/4.8.1 refer to Regulatory Guides 1.9 and.1.108 with regard to the surveillance requirements.

As discussed above, the requirement to test for the loss of the single largest load will continue to be satisfied given the approval of this. amendment application. The proposed t change does not alter the manner in which safety limits or -

limiting safety system settings are determined. The proposed change will have no effect on those plant eystems necessary to assure the accomplishment of protection functions and meet the accident analysis acceptance criteria in FSAR Chapter 15. There will be no impact on DNBR limits, F , F delta-H, LOCA PCT, or any other defined safety margin.Q Based on-the above discussion, the proposed change does not involve an-unreviewed safety question and will not adversely

. affect or endanger the health or safety of the general public.

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Attachment 2 ULNRC-2516 Page 1 of 2 SIGNIFICANT HAKARDS EVALUATION This amendment application revises the 18 month surveillance requirements for Specification 3/4.8.1, A.C. Sources, to replace the phrase "a load of greater than or equal to 1352 kW (ESW pump) " in Technical Specification 4. 8.1.1.2. f . (2) with the phrase "the ESW pump motor load (the largest single emergency load)".

The Bases are also revised to more explicitly discuss this surveillance. This amendment is needed to address literal compliance-with the Callaway Technical Specifications.

The proposed change does not involve a significant hazards consideration because operation of Callaway Plant in accordance with=this change would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The load rejection surveillance test in question is taken frc- Regulatory Guides-1.9, Revision 1, Position C.5 and Regulatory Guide 1.108, Revision 1, Position C.2.a. (4) which call for a test of the loss of the largest single load. This surveillance test is performed at Callaway by disconnecting an ESW pump motor with the ESW and AC power systems aligned in their emergency operation modes.

Currently there is no direct way to assure that this rejected load equals the 1352 kW~ listed in the Technical Specifications. However, the actual kW load associated with the ESW pump motors is less than 1352 kW and can vary slightly. depending on plant conditions and motor efficiency. This variance is insignificant as assured by the preventive maintenance program that monitors pump / driver performance. Therefore, there should be no '

-listed value for this load in the Technical Specifications nor is one needed to satisfy the regulatory guide requirements. The intended requirement is to assure that the diesel meets the specified acceptance criteria given the_ rejection of the ESW pump motor load when the plant is in-a lineup representative of emergency conditions at

'Callaway.

No-new design requirements are being imposed on any plant systems.or components. There is no change to the 12 second l diesel start time assumed in the accident analyses and l verified by Technical Specification 4.8.1.1.2.a. (4) nor is there a change to the acceptance criteria for any of the dieael generator surveillance tests, including the startup, ,

rated load, and load rejection tests. There_will be no effect on the capability of the diesel generators to supply the. loads assumed in tb- mitigation of the accidents analyzed in FSAR Chapuer 15.

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(2) Create the possibility of a new or different kind of accident from any previously evaluated.

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4 t Attachment 2 ULNRC-2516 Page 2 of 2 i The proposed change does not invo3ve any design changes or hardware modifications nor will there be any changes to the

. intended manner of plant operation or in the method by which any safety-related plant system performs its safety function. No new accident initiators, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this change.

(3)- Involve a significant reduction in a margin of safety.

The requirement to test for the loss of the single largest load will continue to be satisfied given the approval of this amendment application. The proposed change does not alter the_ manner in which safety limits or limiting safety system settings are determined. The proposed change will have no effect_on those plant systems necessary to assure the. accomplishment of protection functions and meet the accident analysis acceptance criteria in FSAR Chapter 15.

There will be no impact on DNBR limits. F LOCA PCT, or any other defined safety margin. Q, F-delta-H, Based _upon the preceding information, it has been determined that the proposed change to the Technical Specifications does not involve an 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 change meets the requirements of 10CFR50.92 (c) and does not involve a significant hazards consideration.  ;

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Attachment 3

. ULNRC 2516 i Page 1 of 1 ENVIRONMENTAL CONSIDERATI0B $

This amendment application revises the 18 month surveillance ,

requirements for Specification 3/4.8.1, A.C. Sources, to replace the phrase "a load of greater than or equal to 1352 kW (ESW pump)" in Technical Specification / . 8.1.1.2. f . (2) with the phrase "the ESW pump motor load (the largest single emergency load) " .

The Bases are also revised to more etplicitly discuss this surveillance. This amendment is needed to address literal ,

compliance with the Callaway Technical Specifications. .,

f

-The proposed amendment involves a change with respect to the

• surveillance requirements of facility components within the restricted area; as defined in 10CFR20. 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; or  !

(3) .A significant increase in individual or cumulative occupational radiation exposure.

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- 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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Attachment 4 ULNRC-2516 i

DRAFT TECHNICAL SPECIFICATION MARKUPS Page Section Description 3/4 8 4 . 8.1.1. 2. f . (2 ) - Revised wording for single B3/4 8-1 B 3/4.8.1 largest load rejection Insert 1 surveillance test.

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