ML20101F333

Application for Amend to License NPF-30,providing one-time Exemption to Tech Spec 4.6.1.2.a Re Containment Integrated Leakage Rate Test

ML20101F333
Person / Time
Site:	Callaway
Issue date:	06/16/1992
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101F336	List: ML20101F333 ML20101F337
References
ULNRC-2650, NUDOCS 9206240396
Download: ML20101F333 (10)

Text

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7 DonaldF Schnell Etscrmc .:

4,g June 16, 1992 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station 91-137 Washington, D.C. 20S55 Gentlemen: ULNRC -2650 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.6.1.2 CONTAINMENT LEAKAGE

References:

1) ULNRC- 2648, dated June 16, 1992

2) ULNRC-2378, dated March 15, 1991 Union Electric Company herewith transmits an application for amendment to Facility Operating License No.

NPF-30 for Callaway Plant.

This amendment application is a one-time schedular exemption to Technical Specification 4.6.1.2.a, that requires three Type A tests (Containment Integrated Leakage Rate Test or CILRT) be performed at 40 i 10 month intervals during each 10-year service period. This ene-time schedular exemption would allow the third test of the first 10-year service period to be performed during Refuel 7 at approximately a 53 month interval instead of the current maxitaum interval of 50 months and would oxceed the first 10- ~

year service period by approcinately 14 months.

Attachments 1, 2, 3 and 4 contain the Safety

, Evaluation, the Significant Hazart's Evaluation, the Environmental Evaluation, and 2.0 Proposed Technical Specification Changes '.n support of this amendment request.

This change request has been approved by the Callaway Onsite Review Committee and the Nuclear Safety Review Board.

We are requesting that the NRC Staff please

expedite their review of this submittal so that the

requested amendment will be issued by October 1992 to l facilitate our planning for future CILRTs. .

Very truly yours, 92062g PDR g h hPDR B3 y 4 g '

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4 r Donald F. Schnell f

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JMC/kea Attachments

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'l STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

Donald F. Schnell, of lawful age, being first duly sworn

,' upon oath says that he is Senior Vice President-Nuclear and an officer l of 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.wlth 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.

By ' 1 D~onald F. Schnell Senior Vice President Nuclear SUBSQRIBED and sworn to before me this /d' '

--day of () /ptc , 1992.

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N0fARY PU6LIC, STATE Of M:S300RI MY COMMISSION D?tES APR;L 22. 1993 ST, Louis COUNTY

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- cc: T.lA. .Baxter, Esq.

-Shaw, Pittman, Potts & Trowbridga '

2300 N.. Street,.N.W.

. Washington, D.C 2003'?

I Dr. J.-0. 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 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 Missol.ri Pubid c Service Cr>madssion .

P.O.. Box 360 /

Jefferson Cit.y, MO 65102 Ron'Kucera Department-of Natural Resources P.O.-Box-176

-Jefferson City, MO 65102

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E210.01 DFS/ Chrono D. ~ F. Schnell J. E. Birk J. V. Laux M. A. Stiller S G. L. Randolph R. J. Irwin P. Darrett C. D. Naslund A. C. Passwater D. E. Shafer W. E. Kahl S. Wideman (WCNOC)

R. C, Slovic (Bechtel)

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'. Attachment 1 Page 1 of 3 ULNRC-2650 SAFETY EVALUATION Proposed Change This amendment request is a one-time schedular exemption to Technical Specification (T/S) Surveillance Requirement 4.6.1.2.a and its associated Fases, that requires three Type A tests (Containment Integrated Leakage Rate Test or CILRT) be performed at-40 1 10 month intervals during each 20-year service period.

This one-time. schedular exemption would allow ~the third test of the first 10-year service period'to be performed during Refuel 7 at approximately a 53 month interval instead of the current-maximum interval of 50 months and would exceed the first 10-year .

service period by approximately 14 months.

Background

Type A tests are defined in Section II.F of 10 CFR 50, Appendix J L as those tests intended to measure the primary reactor containment

! overall integrated leakage rate at periodic intervals. The time required to perform the CILRTs necessitates that they be performed during refueling outages. The time interval between -_LRTs '

should_be about 40 months based _on performing three such tests at lapproximately equal intervals during each 10-year service period.  !

Since refueling outages do not necessarily occur coincident with a 40-month interval, a permissible variation of 10 months (i.e.,

a 25 percent variation) is authorized in the T/S to permit g flexibility in scheduling the CILRTs.

.The first-and second CILRTs, of the set of three tests for the first 10-year _ service period for Callaway Plant, were conducted in April 1987 and October 1990, respectively. This represents testing _ intervals of 40 and 41 months from the initial preoperational CILRT performed in January 1984. This would indicate that the third of the first! set of three CILRTs be performed _at. Refuel 6_ scheduled for September 1993 which will be 1 35 months after the preceding test and within the first 10-year j service-period. The result of this testing sequence would cause an-extra CILRT to be performed over the course of the next 10-y?ar. service period based on the 40- 1 10 month testing H interval-coincident _with the 18-month fuel-cycle utilized at Callaway m ant._ In order to. prevent performing this fourth CILRT in the e ,ond 10-year service period, we are proposing that-the third v. .ZP for the first 10-year service period be performed during Refuel '/ scheduled for March 1995. Therefore, the one time scredular exemption is needed-to allow this test interval to exceed the 40 10 month requirement and the three tests within z _ __ the f '.rst _10-year service period requ i ement.

An exemption to exceed the 10-year interval of 10CFL Appendix J, Section o II7.0.1(a) is being submittM L

• ace 1. This request is ccasist ent . with the changes requested to T/S 3/4.6.1.2 under Reference 2.

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i Attachment 1 Page 2 of 3 U LNRC-2650 A benefit of this one-time exemption is to elluinate the need to perform an extra CILRT over the next 10-year service period, thus a reduction in personnel radiation exposure is realized. The elimination of setup and restoration of 1 CILRT during the first 20-year period provides a dose savings from the elimination of contamination, the reduction of exposure for venting and draining '

and from setup and restoration of the instrumentation during and after the test.

Evaluation Data from past tests at Callaway Plant and from NUMARC indicates that the majority of the leakage that is maasured during the  ;

CILRT is from the containment penetrations - and not from the containment barrier itself. Since the Type B and C tests (Local ,

Leakage Rate Test or LLRT) program, which measures penetration '

and valve leakage, is not altered, assurance that containment integrity is maintained can also be verifind by the performance of the LLRTs. In addition to the LLRTs indication of containment integrity the~ data from the first and second CILRT illustrates that the "as-left" leakage rate was well below the limit established for acceptance in 10 CFR 50, Appendix J and Technical Specifications. The allowable leakage rate, La is 0.2 wt.%/ day, I

however Appendix J and T/S requires that the leakage rate be less than 75% of this value-to allow for ceter,iorat=en in leakage paths between tests. Therefore, the acceptance limit is 0.15 wt.%/ day and the "as-left" leakage rates for the first two CILRTs were 0.083 and .0505 wt.%/ day which is well below the acceptance limit.

The proposed one-time schecular exemption to T/S 4.6.1.2.a that would allow the third test of the first 10-year service period to be performed beyond the_10-year service period and past the 50 month maximum interval does not involve an unreviewed safety question because operation of Callaway Plant with this change would not:

a. 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.

'This_one-time exemption to extend the CILRT interval 3 months beyond the maximum T/S allowance and into the 2nd 10-year service period will not adversely impact plant

safety. The schedule for performing the Type B and C LLRTs is not af fected and the majority of leakage from the containment is through penetrations and isolation valves.

The leakage rates assumed by accident analyses are unchanged and past CILRTs have produced leakage rates well below the maximum allowed by T/S and Appendix J.

b. Create the possibility for an accident or malfunction of equipment of a different type than any previously evaluated in the Safety Analysis Report. There are no design changes being made that would create the possibility for an accident a ,. .- - , , . ,. -.:- ..- .. . .- - . -

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Attachment 1 Page 3 of 3 U LNRC- 2650 or malfunction of equipment. The change is a one-time exemption to exceed the T/s maximum interval for performing a CILRT. The purpose of the CILRT is to provide periodic verification by tests af the leak-tight integrity of the primary reactor containment, and systems and components which penetrate containment. The tests assure that leakage j through the containment, and systems and components penetrating contain.-unt shall not exceed allowable leakage rate values associated with the conditions resulting from any loss of-coolant accident. The additional 3-month period added to the interval since the last CILRT was performed would not aJuersely af fect the containment integrity in the event of a - ss-of- coolant accident. _

c. Reduce the margin of safety as defined in the basis for any 5 technical specification. The change is a one-time request -

to extend a surveillance interval and does not reduce the margin of safety assumed in accident analysis for release of radioactive materials from the containment atmosphere into the environment.

Conclusion Give' the above discussions as well as-those presented in the Significant Hazards Consideration, the proposed change does not adversely affect or endanger the health or safety of the general public or involve a sign 3ficant safety hazard.

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, Attachment 2 Page 1 of 2

, ULNRC-2650 SIGNIFICANT Hb2ARDS CONSIDERATION This amendment request is a one-time schedular exemption to Technical Specification (T/S) Surveillance Requirement 4.6.1.2.a and its associated Bases, that requires three Type A tests

-(Containment Integrated Leakage Rate Test or CILRT) be performed during each 10-year service period at 40 1 10 month interv.ls.

This one-time exemption would. allow the third CILRT to be performed during Refuel 7 at approximately 53 months elapsed time since the-previous one was performed. This would exceed the 50 i

month ' maximum -interval in the current T/S and would also extend

! the third test approximately 14 months past the first 10-year service period. This exemption would prevent the need to perform a fourth CILRT in the second 10-year service period, thus a reduction in personnel exposure is realized.

The proposed exemption to Technical Specification Surveillance Requirement 4.6.1.2.a does not involve a significant hazards consideration because operation of Callaway Plant with this exemption would not:

1. . Involve a significant increase in the probability or consequence; of ar. accident previously evaluated. This exemption applies to the integrated leak rate test and does not affect the local leak rate testing of containment penetrations and isolation valves '.,here the majority of the leakage occurs. The allowable containment leakage used in accident analysis for offsit Joses, La is 0.2 wt.%/ day and for conservatism the leakage 's limited to 75%.La to account for possible degradation of the containment leakage barriers between tests. Based on the "as-left" leakage data from the past two CILRTs, the additional time period added to the testing interval would not adversely impact the containment

. lcakage barriers .tx) where degradation would cause leakage to i exceed that assumed in accident analysis.

2, Create the possibility of a new or different kind of accident from any accident previously evaluated. There are no design changes being made that would create a new type of accident or malfunction and the method and manner of plant operation remain unchanged. The change to the Surveillance Requirement is a one-time exemption to extend.the surveillance interval for performance of the third CILRT.

3. Involve a significant reduction in a margin of safety.

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There are no-changes being made to the safety limits or safety system settings that would adversely impact plant safety. The change is a one-time exemption to extend the time interval for performing a CILRT approximately 3 months beyond the current maximum interval. This change does not reduce any technical specification margin of safety.

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, Attachment 2 i Page 2 of 2  !

. ULNRC -~ 2 650 l l

Based on the above discussions, it has been determined that the requested Technical Specification change does not involve a significant increase in 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 license amendment does not involve a significant hazards consideration, r

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. Attachment 3

', Page 1 of 1 ULNRC- 2650 ENVIRONMENTAL CONSIDERATION This amendment application is a one-time schedular exemption to .

_Techin cal Speci ficati on Surveillance Requirement 4.6.1.2.a and its associated Bases, that-would allow the third test of the first 10-year service period to be performed at approximately a 53 month interval instead of the current maximum interval of 50 months.

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

Accordingly, the propos_d amendment meets the eligibility criteria for categorical exclusion set f orth in 20CFR51.22 (c) (9 ) .

Pursuant to 10CFR51.22(b), no environmental impact statemant or environmental assessment need be prepared in connection with the

-issuance of this amendment.

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