ML20127J987
| ML20127J987 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/17/1985 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20127J992 | List: |
| References | |
| ULNRC-1097, NUDOCS 8505220006 | |
| Download: ML20127J987 (7) | |
Text
Ia UNION RECTRIC COMPANY 1901 Grotlot Street, St. Louis May 17, 1985 Donald F. Schnell Vice President Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 ULNRC-1097
Dear Mr. Denton:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 REVISION TO TECHNICAL SPECIFICATION 3.8.4.1 Union Electric Company herewith transmits three (3) original and forty (40) conformed copies of an application for Amendment to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1.
This change modifies Technical Specification 3.8.4.1 by deletion of the requirement for resistance checking of fuses.
Resistance checking of fuses is performed by the vendor to confirm the correct internal construction such as correct amount of fuse elements, correct thickness of elements and detection of poor or no solder joints.
Periodic non-destructive testing (resistance testing) of fuses only generates data and is not indicative of performance.
This change also deletes Table 3.8-1 from the Technical Specifications and imposes the requirement for administratively controlling the table similarly to that of snubbers as described in Generic Letter 84-13 dated May 3, 1984.
Compliance with Technical Specification 3.8.4.1 shall Q
in no way be degraded by maintaining the list of containment Nv5 penetration conductor overcurrent protective devices in E8' appropriate plant procedures but provides additional
@8 flexibility for making changes based on 10 CFR 50.59 mo evaluations.
It is also consistent with the NRC and og industry effort to simplify the Technical Specifications.
Union Electric also suggests that the changes indicated on Q
the attached page B 3/4 8-3 be incorporated to make the g
bases consistent with the revised specifications.
OE This change will also meet the commitment of voluntary LER 85-017-00 submitted via ULNRC-1082 dated 4/22/85.
The changes described therein will be incorporated i to the EE administrative 1y controlled program.
7 jg7 OIO N
,0 Moiling Address PO Box 149, St. Louis MO 63166
g 1Mr. Harold-R.:Denton
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- May 17, 1985 a..
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The' proposed' changes would become effective.for. Union-Electric implementation'30idays following NRC. approval.
j' Enclosed is a-check-for the $150'.00 applicati'on fee as required by~10:CFR 170.21.
.Very:truly yours, b
q Donald Schnell 1
_ WRR/drs-
Enclosures:
1)
Safety' Evaluation.
2). Significant Hazards Consideration
- 3). Proposed: Technical Specification Changes h
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cc:
Gerald Charnoff,1Esq.
-Shaw, Pittman,-Potts-& Trowbridge
'1800 M. Street, N.W.'
Washington, D.C.
.20036 Nicholas A. Petrick.
Executive Director.
.SNUPPS
'S Choke Cherry Road Rockville, Maryland -20850 John H. Neisler
-Callaway Resident Office U. S. Nuclear Regulatory Commission
-RRf1-Steedman,: Missouri 65077 Geoffrey'C. Wright Division of: Projects and
' Resident Programs, Chief. Section 1A U..S.~ Nuclear Regulatory Commission Region III
?799 Roosevelt Road
~ Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U. S. Nuclear Regulatory Commission cRR#1 Steedman, Missouri 65077 Tom Alexion b
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail-Stop P-316 7920 Norfolk Avenue Bethesda, Maryland 20014 Ron Kucera, Deputy Director Department of Natural'Resourcos P. O. Box 176 Jefferson City, Missouri 65102
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STATE OF MISSOURI )
).
- CITY OF. ST. LOUIS )
' Rober t J. Schukai, of lawful age, being first duly sworn
- upon oath says'that he is General Manager-Engineering (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 sc; and that the facts therein stated.are true and correct to the best of his knowledge,.information and belief.
r By L
Robert 7E chukai
> Genera
'ager-Engineering Nuclear SUBSCRIBED and sworn to before me this
/7 day of OM/
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Page 1 of 2 ULNRC-1097
- ~,-
SAFETY EVALUATION
^
1This amendmentJrequest modifies Technical Specification 3.8.4.17 by deletion of.the requirement for resistance e.
-testing.of fuses.
It also deletes Table 3.8-1, Contain-
- ment Penetration Conductor Overcurrent Protective Devices,
?and imposes?the requirement for administrative 1y controlling theLtable throughiappropriate plant procedures-.
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Periodic' resistance measurement is not practical for 7
containment. penetration conductor overcurrent protection
_ fuses.
Resistance verification is performed as one of the
' final > steps in the manufacturing process, assuring proper Lconstruction and rating.
Manufacturers do not publish this
~ baseline data since construction changes are made based on
' design.and material' improvements.
Because of this, nci
. baseline data would-be available if^ periodic resistance
~
-measurements were. performed.
Routine. removal of fuses for 3
+3 testing is.not prudent according to the manufacturer.
Routine removal can result in damaging of the fuse holder SV 4
.and; contact points.
Fuse. manufacturers have^also stated E
that fuses do not deteriorate with service life.
Service 1pj'etemperatures above:the rated temperature, current surges, H
.and unusual cycling _ conditions all reduce the fuse's service life,_i.e., the fuse becomes more protective.
Under no JU
+
' conditions will a fuse become less protective during its s
-service life.
In lieu.of field testing by resistance, we
'willfestablish a fuse inspection and maintenance program-that will ensure:
(1) that the proper size. fuse is s
- installed,' '(2) that the fuse shows no sign of ~ deterioration, and~(3).that the fuse connections are tight and clean.
(See
^
-IEEE Std 242 1975 Recommended Practice'for Protectionfand 7
e tcs.
~ Coordination of. Industrial and Commercial. Power Systems)..
Should a problem arise-with a specific brand or model of~
(fuse, necessary corrective action would be initiated through
.the plant's incident = reporting program.
. b.-)
- The. list of containment penetration cor ;ctor Lovercurrent protective devices shall bc :aintained in :
~
Tappropriate' plant procedures in accordance with 10 CFR 50.71(c).'(Maintenance of records, making of reports).
Changes to theLlist shall be reviewed for unreviewed (safety; questions-in;accordance with-10-CFR 50.59 l(Changes, tests. and experiments).
Compliance with T/S
' "[
~3.8.4.1 shall"be: ensured by the appropriate procedures
- presently.being. utilized... Compliance with T/S 3.8.4.1 shalliin no;way>be" degraded by maintaining the list'of s '
containment'penet' ration conductor overcurrent protective-devices in'the appropriate plant procedures and
.not in the Technical Specifications and provides the needed cflexibility_fo'r changes without requiring a License Lamendment as:was-done in the case of snubbers.
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. Enclosure 1 1,
Page.2 of 2.
ULNRC-1097, p.
Pursuan't'to=the above information,.this amendment request
- does-:not-adversely affect or endanger the health of the 7,
general public and does:not involve an unreviewed safety
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' Enclosure.2 ULNRC-1097 SIGNIFICANT' HAZARDS CONSIDERATION This amendment request modifies Technical Specification -3.8.4.1:by deletion of the requirement for resistance checking of fuses and deletion of Table 3.8-1.
(The Comm'ission has provided guidance concerning the application of the standards in 10 CFR 50.92 by providing certain examples (48 FR 14870).
This amendment request.is similar'to the' example of.an action involving a purely
. administrative change to Technical Specifications.. The amendment-request provides for the. list of containment l electrical penetration protective devices to be administratively maintained at the plant ~rather than in.the Technical ~ Specifications.
The deletion of the requirement
-for' resistance checking.of fuses is considered
- administrative in that the resistance testing of fuses only-
. generates data that is not-indicative of performance.
.This: amendment request does not involve a significant increase-in the probability'or consequences of an accident or other adverse condition over previous evaluations; nor create the possibility'of a new or different kind of
~
accident or condition over previous evaluations; nor involve-a significant_ reduction in a margin of safety.. Based on the foregoing, the requested amendment does not present a significant hazard.
-