ML20137F757

Application for Amend to License NPF-30,revising Tech Specs Re Operability & Surveillance Requirements for Reactor Trip Sys Instrumentation,Per Generic Ltr 83-28.Fee Paid

ML20137F757
Person / Time
Site:	Callaway
Issue date:	01/09/1986
From:	Schnell D UNION ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20137F764	List: ML20137F757 ML20137F822
References
GL-83-28, ULNRC-1240, NUDOCS 8601170575
Download: ML20137F757 (6)

Text

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• r UNION ELECTRIC COMPANY 1901 Gratiot Street, St. Louis January 9, 1986 Donald E Schnell Vice President Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation t U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

ULNRC 1240 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISIONS TO TECHNICAL SPECIPICATION TABLES 3.3-1 AND 4.3-1

References:

1. Generic Letter 85-09 dated 5-23-85, Technical Specifications for Generic Letter 83-28, Item 4.3

2. ULNRC-1031 dated 1-29-85, Revisions to Technical Specification Table 4.3-1

3. ULNRC-763 dated 3-12-84, Additional Responses to Generic Letter 83-28 Union Electric Company is transmitting three original and 40 conformed copies of an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant. This application supercedes the previous application transmitted in Reference 2.

This amendment application requests that the operability and surveillance requirements given in Technical Specification Tables 3.3-1 and 4.3-1 be revised. These revisions are as follows:

1. Action Statement 12 is being added to Table 3.3-1 to provide fcr a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> restoration time after one of the diverse reactor trip features (Undervoltage or Shunt Trip Attachment) has been declared inoperable in either Mode 1 or 2. If the inoperable trip feature is not restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, Action Statement 9 would be applied. This change, being made pursuant to the Staff positions given in Reference 1, recognizes the increased diversity associated with the addition of the automatic actuation of the Shunt Trip Attachment.

2. Note 14 of Table 4.3-1 is being added to explicitly require independent testing of the control room manual reactor trip switch contacts during each refueling outage. Attachment 2 of Reference 3, in responding to the NRC SER on the generic Westinghouse automatic shunt B601170575 860109 1 HSE' PDR P

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trip design, discussed our commitment to test all.

p control room manual reactor trip switch contacts and E . wiring prior to restart after each refueling outage.

i. This will test the circuitry up to the reactor trip l- breakers and bypass breakers. Reference 2 noted that

, no Technical Specification changes were needed as this testing is presently covered by Functional Unit 1 of Table 4.3-1. However, in deference to the Staff's concerns expressed in Reference 1, this commitment is now being incorporated into the Callaway Technical Specifications.

3. Notes 7 and 11 of Table 4.3-1 are being revised to indicate that the on-line Trip Actuating Device Operational Tests of the reactor trip breakers shall include-independent verification of the operability of the Undervoltage and Shunt Trip Attachments. These changes were previously requested in Reference 2; however, they are being resubmitted at this time to be more consistent'with the format provided in ,

Reference 1.

Bypass breaker testing is addressed in Attachment 4 to this le tter .- Union Electric plans to administratively control this testing outside of the Technical Specifications.

Attachments 1 and 2 provide the Safety Evaluation and Significant Hazards Considerations associated with the changes discussed ut. der items 1, 2, and 3 above. Although a portion of these are common to the original amendment request transmitted by Reference 2, they are contained herein for completeness of this amendment request. The Proposed Technical Specification changes (Attachment 3) have been reformatted from those contained in Reference 2 and have also been included in their entirety. This proposed amendment would become effective for Union Electric implementation 30 days following NRC approval. The application fee for these changes was tendered with Reference 2.

Very truly yours, s_

km Don i Schnell d

DS/lw Attachments: 1 - Safety Evaluation 2~- Significant Hazards Considerations 3 - Proposed Technical Specification Changes 4 - Bypass Breaker Testing

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STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

Robert J. Schukai, of lawful age, being first duly sworn

.upon oath - says that he is General Manager-Engineering (Nuclear) for i

. 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 1 information and belief 9

By '" A R6ber J. chukai Gene al ager-Engineering Nuclear SUBSCRIBED and sworn to before me this M day of , 198f

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BARBARA J. PFAFF NOTARY FU3UC, STATE OF MISSOURI NY COMMISSION EXPlRES APRIL 22,100 ST. LOUIS COUNTY.

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3 o r Attachm nt 1 ULNRC- 124 0 SAFETY EVALUATION This-amendment request revises the operability and surveillance. requirements given in Technical Specification. Tables 3.3-1 and 4.3-1-in order to comply with Staff guidance contained

.in' Reference-1. Per Reference 1 Union Electric must submit proposed-Technical 1 Specification changes-that address the

.following:

a. Revised reactor trip breaker operability requirements that~ reflect the addition of automatically actuated-

~ Shunt Trip Attachments,

b. _ Explicit surveillance requirements associated with the Manual Reactor _ Trip function.

c. Independent testing of the Undervoltage and Shunt Trip Attachments on the reactor trip breakers during power operation.

d. Periodic testing of the Undervoltage and Shunt Trip Attachments on the bypass breakers.

Items a, b, and c are addressed in the following safety <

. evalua tion ~. Item d is discussed in Attachment 4.

Item a .

With the addition of the automatic actuation of the Shunt Trip-Attachment, diverse features exist to effect a reactor trip for each breaker. If one of these diverse trip features is inoperable, a decision would have to be made with rega2d to the operability status of the reactor trip breaker. The definition of OPERABLE-OPERABILITY in Technical Specification 1,18 states that a component shall be operable or have operabil 'y when it is capable of performing its specified function. Since either trip teature being operable would initiate a' reactor trip on demand, it would be overly conservative to treat a breaker as inoperable if one of these diverse trip features were inoperable. The callaway reactor trip breaker surveillance test independently verifies the operability of'the Undervoltage and Shunt Trip Attachments of the reactor. trip breakers as part of a single, sequential-test procedure (Operations Surveillance Procedure OSP-SB-00001). Therefore, the surveillance test which identifies a failure of one diverse' trip feature also confirms the operability of the other trip feature. As a consequence, there is a. high degree of confidence that the operable trip feature would be capable of initiating a reactor trip in the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Accordingly, Action' Statement 12 is being added to Table 3.3-1 to permit continued plant operation for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> with one of the diverse trip features inoperable before further action needs to be taken-(i.e., Action Statement 9).

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y, Attachmsnt 1 ULNRC-1240 Item b In the evaluation of the generic Westinghouse automatic shunt trip design, the Staff noted that the procedures for

. testing the breakers did not include verification of the operability of:the control room reactor trip switch contacts and wiring'in the manual trip circuits. Given the importance of this circuitry in.the termination of the Salem ATWS events, the Staff has concluded.in Reference 1 that licensees should propose Technica1' Specification changes that explicitly provide for independent testing of the control room manual reactor trip switch contacts during each refueling outage. Therefore, ACTION 14 has been added to Item l'of Table 4.3-1.

Item c In Generic Letter 83-28, Item 4.5.1 and in Generic Letter 85-09 (Reference 1) the Staff has addressed the need for independent, online testing of the Undervoltage and Shunt Trip Attachments. Table 4.3-1, Item 18 and its associated notes have been revised to clarify that online testing or testing following maintenance or adjustment of the trip breakers includes independent verification of these diverse features. The addition of these surveillances results in greater confidence that the respective Undervoltage and Shunt Trip Attachments will perform as designed.

i . Pursuant to the above information, this amendment request does not adversely affect or endanger the health of the general public and does not involve an unreviewed safety question.

p I Attachment 2

' ULNRC 1240

- SIGNIFICANT HAZARDS CONSIDERATIONS The. Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain

. examples '(48FR14870). This amendment request is similar to the example.of an action involving no significant hazards consideration which relates to a change that. constitutes an additional limitation, restriction, or control not presently included.in the: Technical Specifications.

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 La. margin of safety. Based on the foregoing, the requested amendment does not present-a significant hazard.

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