ML20086B408
| ML20086B408 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/15/1991 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-2515, NUDOCS 9111200175 | |
| Download: ML20086B408 (5) | |
Text
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- r. Jchn A. Zwolinski M
Assistant Director for Projects Office of Nuclear Reactor Regulation
-U.S.. Nuclear Regulatory Commission
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Washington, D.C.
20555 ULNRC-2515
Dear Mr. Zwolinski:
DOCKET NUMBER 50-483 CALLAWAy PLANT REQUEST FOR NRR TEMPORARY WAIVER OF COMPLIANCE AND EMERGENCY TECHNICAL SPECIFICATION 4.8.1.1.2.F(2) AMENDMEJJq
References:
1)
ULNRC-2516, dated 11/15/91 2)
Regulatory Guido 1.9, Rev. 1 3)
Pogulatory Guide 1.108. Rev. 1 This letter confirms tne results of a teleconference on 11/14/91 at 1620 CST between Union Electric and the NRC Staff in which Union Electric requested a
Temporary Waiver of Compliance and proposed an emergency j.
amendment to Technical Specification 4.8.1.1.2.f(2).
This is an 18-month shutdown surveillance which states:
" Verifying o
the dicsci generator capability to reject a load of greator than or equal to 1352 kW (ESW pump) while maintaining voltacc at 4000 1 320 volts and frequency at 60 1 5.4 Nr."
Although nurveillances had boon completed in accordance with the surveillance interval requirements of the Tochaical Specifications, the kW load value for the ESW pump motor was not measured during testing.
At' the time of the teleconference, Callaway Plant was in Modo 1 - Power Operations.
The Limiting Condition for Operation for l
Technical Specification 3.8.1.1 had not boon mot and i
Technical Specification 3.0.3 had been entered.
Union Electric requested that the requirement.to initiato action to L
shutdown-the plant por Technical Specification 3.0.3 bc waived until the emergency amendment to change the '352 kW requirement is approved.
The proposed amendment submitted via Reference _1 includes a revision to Technical Specification 4.8.1.1.2.f(2) to dc1cto the 1352 kW requirement.
Reference 1 includes a determination that this proposal does not involvo an.
unreviewed safety question nor a significant hazards i
consideration.
The proposed change does not adversely affect L
9111200170 911115 A MO[
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Mt. John A. Zwolinski page 2 or endanger the health or safety of the general public and-doca not involve irreversible environmental conscquences.
The basis for the Temporary Waiver of Compliance request is provided below 1
- 1..
Technical Specification Pacos 3/4.8.1 stato that d -
the surveillance requirements for demonstrating the i
operability of the diesel generators are in accordance with the recommendations of References 2
.and 3.
Reference 2 states:
"A dicsci-gonorator unit selected for use in an onsito electric power system should have the capability to....
sustain the loss of all or any part of such loads and maintain voltago and frequency within acceptabic linits."
It also states the following with regard to load rejection tests:
"During recovery from transients caused by stop load increases or resulting from the disconnection of tha largest singic load..."
Reference 3-testing recommendations include:
"Demonstrato proper operation during dicsc1 generator-load shodding, including a test of the loss of the largest single load..."
The motor rating of 1352 kW for an ESW pump specified in the Specification 4.8.1.1.2.f(2) was also-listed in the plant's Final Safety Analysis Report Figurc 8.3-2 as the.ESW pump motor load on the dicsc1 generator during a Loss of Coolant Accident (LOCA).
A measurement of the-actual kW rating of the ESW pump motor has not been
. performed during this surveillance test since roccipt of the Operating License but the value is known to be lors than 1352 kW.
The ESW pump system does not include installed instrumentation to-measure for a motor kW value.
L 2.
On 11/14/91, utility employees were informed by tc1cphone from-a similar plant that a potential concern existed with the ability to satisfy the 1352 kW requirement of Surveillance 4.8.1.1.2.f(2).
A review of applicability of the concern to the Callaway Plant was begun.
It was determined on 11/14/91_ that we have not been racasuring the ESW pump motor kW rating and comparing it to the 1352 kW surveillance requirement.
Additionally, engineering calculations show actual ESW pump motor rating during a LOCA is expected to be less than 1352 kW.
At 1515 CST, plant management determined the surveillance requirement has-ncycr been
. satisfied as specified.
Specification 3.0.3 was entered since the Limiting condition of operation for-Specification 3.8.1.1. was not satisfied.:
y
'Proparations were initiated to commence an orderly l'
plant shutdown.
At 1620, a verbal approval to
Mr. John A. Zwolinski Page 3 waive Specli. cation 3.0.3 was roccived and the plant exited-3.0.3.
3.
As added precaution, the operating crew verified the operability of the two offsite A.C. sources.
An emergency Technical Specification change was initiated and is included in reference 1.
An Emergency Notification System telephone call was made on 11/14/91 at approximately 1800.
4.
The surveillance testing performed to date has verified the ability of the dicscl goncrator to reject the largest single emergency load (ESW pump motor) and maintain rc' quired voltage and f requency.
The testing has been performed with the ESW system
~
.in the LOCA. lineup.
Additionally, the safety evaluation included in Reference'l concludes this condition is not an unroviewed safety question.
5.
The waiver duration is justified sinco a Specification 3.0.3 plant shutdown transient would be unnecessary._ The diesel generators would perform their safety function if required as demonstrated by survoillance.
6.
This request does not involve a significant hazards consideration as explained in Reference 1.
7.
This request does not involve irreversible environmental consequences as discussed in Reference 1.
B.
The:On-Site Review Committec approved this request for Temporary Waiver on 11/14/91 at approximately 1530.
Concurrently, they reviewed and approved the emergency snendment request in accordance with plant procedurcs.
Pursuant to 10CFR50.91(b)(1), a copy of'the Operating License amendment rcquest has boon forwarded to the designated State of Missouri Official.
Very truly yours,
~
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})~DonaldF.Schnell ACP/TPS/sid 1
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STATE OF MISSOURI )
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CITY ~OF ST. LOUIS )
Alan _C.
Pnsownter, of lawful age, being firnt duly sworn upon_ oath says that he in Manager, Licensing and Fueln (Nucioari for Union Electric Company; that he has read the foregoing document. and t
-itnows-the content thereof; that he has executed the nomo for and on behalf of said company with full power _and authority to de so; and
.l that the facts therein stated are true and correct to the bent of his Itnowledge, information and belief.
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gy Alan C.
Passwater Manager, Licensing and Fuela 4
Nuclear 1
SUBSCRIBED and sworn to before mn this 15th day af
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1991.
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G. L. WATm3 NOTARY PUUUC. MAR 00 fr%Dum f.1f COMMibSiON LXPiih 3 3n0?)3 St. Louis couN1y
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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. Ce rnak i
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 Bimee Bartlett Callaway Resident Office U.S. Nuclear Regulatory Commission RRill Steedman, Missouri 65077 J.
R. Hall (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 Department of Natural Resources P.O. Box 176 Jefferson: City, MO 65102 i
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