ML20137N603

Application for Amend to License NPF-30,requesting Rev to TS Table 3.3-3 Re Engineered Safety Features Actuation Sys Instrumentation

ML20137N603
Person / Time
Site:	Callaway
Issue date:	04/01/1997
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137N608	List: ML20137N603 ML20137N611
References
ULNRC-3555, NUDOCS 9704090003
Download: ML20137N603 (12)

Text

. - - - - - _ _ - _ - -

1901 Ct:autelo Avenue

• Pod Othce Box 149

• . St. Louis, Masaun 63166

.314 SS42650 DonaldF. Schnell .

N. Senior Vice President C nusear 33 April 1, 1997 U. S. Nuclear Regulatory _ Commission Attn: Document Control Desk Mail' Station P1-137 Washington, DC 20555-0001 Gentlemen:

ULNRC-3555 DOCKET NUMBER 50-483 CALLAWAY PLANT l

REQUEST FOR EMERGENCY TECHNICAL SPECIFICATION CHANGE FOR TURBINE DRIVEN AUXILIARY FEEDWATER PUMP START LOGIC l

l

References:

1) ULNRC-1822 dated August 30, 1988 )

I

2) ULNRC-1862 dated November 18, 1988

3) ULNRC-1863 dated November 18, 1988

4) ULNRC-1884 dated December 28, 1988

5) ULNRC-1905 dated February 7, 1989

6) ULNRC-1911 dated February 10, 1989

7) ULNRC-1913 dated February 15, 1989 Union Electric Company (UE) herewith transmits an application for emergency amendment to Facility Operating y License NPF-30 for Callaway Plant. The chango proposes to /

l revise Technical Specification Table 3.3-3, runctional Unit /

l 6.d, for the start-logic of the Turbine Driven Auxiliary /

Feedwater Pump. Specifically, the " Channels to Trip" r column for Functional Unit 6.d.2.a and 6.d.2.b is modified

( to correct editorial errors associated with the start logic /j l of the Turbine Driven Auxiliary Feedwater Pump (TDAFP).

~ Currently, the TS indicate that 2 of 4 Steam Generator Low-Low Water Level channels of gny steam generator will actuate the TDAFP. The. actual plant design requires 2 of-4 in any two steam generators for automatic actuation of the TDAFP.

i 9704090003 970401 . ??

^ RuppRn.up L 5" cx o5oo = 3 y-

, m.

ULNRC-3555

., U.-S. Nuclear Regulatory Commission Page 2 By letter dated April 14, 1989, and corrected by letter dated May 11, 1989, NRC issued Amendment 43 to Facility Operating License NPF-30. This amendment revised the TS related to the steam-generator low-low level trip circuitry by adding an Environmental Allowance Modifier (EAM) and a Trip Time Delay (TTD). Prior to Amendment 43, TS Table 3.3-3 correctly described the steam generator low-low start logic for the TDAFP. Amendment 43 approved changes proposed in References 1 - 7. However, due to administrative oversight, the " Channels to Trip" column was inadvertently changed in the TS markup of Reference 1, thus introducing the error.

On March 31, 1997, Callaway Plant staff discovered the error and notified the NRC Senior Resident Inspector. At 1500, the TDAFP was declared inoperable and TS Limiting Condition for Operation 3.7.1.2, Action a was entered. This requires that the inoperable pump be l restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant be j shutdown to Mode 3 within the next six hours and in Mode 4 l in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

l l This situation could not be avoided because it

! involved an administrative oversight in a highly complex license amendment package. The specific wording in the

" Channels to Trip" column for the TDAFP was not intentionally changed.

Pursuant to 10 CFR 50. 91 (a) (5) , Union Electric hereby requests NRC emergency authorization and approval of this proposed amendment. The requested emergency

authorization is appropriate because this amendment involves no significant hazards consideration (Attachment 1). In addition, the present situation could

, not be foreseen and avoided. As indicated, Union Electric l has identified the issue and notified the NRC to pursue expeditious resolution of this matter. This TS change does 1 not impact any hardware at Callaway Plant and simply proposes to bring the TS into agreement with the plant design.

The. plant On-Site Review Committee and Nuclear Safety Review Board have reviewed and approved this amendment request.

l

', ULNRC-3555

. U. S. Nuclear Regulatory Commission Page 3 1

I In'accordance with 10 CFR 50.91(b), Union Electric will promptly provide the State of Missouri with a copy of this proposed amendment to ensure their awareness ,

of this request, ]

l If there are any questions relating to this  !

information, please contact us. We appreciate your prompt J attention to this amendment. request.

i Very truly yours, l

. ad: Donald F. Schnell l

WBM/ l Attachments: 1 - Significant Hazard Evaluation ,

2 - Environmental Consideration l 3 - Technical Specifications Mark-up I

STATE OF MISSOURI )

) SS COUNTY OF CALLAWAY )

Ronald D. Affolter, oflawful age, being first duly sworn upon oath says that he, Plant Manager of the Callaway Nuclear Plant, Union Electric Company; 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, information and belief.

By [M N Ronald #dffolter Plant Manager Callaway Nuclear Plant i

i l

Subscribed and sworn to before me this 1st day of April,1997. i

% OU. l s Notary Public

.y b j NOMrMAUC i STATE OF MV5NC00NTY l NONV968 l My COMEWON EMES OCT08R 22,2000 I

1

1

,cc: M. .H.-Fletcher . ,

Professional Nuclear Consulting, Inc. I 19041 Raines Drive i Derwood, MD 20855-2432 I Regional Administrator  !

U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Irspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Kristine M. Thomas (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738  :

Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Xucera Department of Natural Resources  ;

P.O. Box 176 l Jefferson City, MO 65102 Don Woodlan TU Electric 1601 Bryan Street Dallas, TX 75201-3411 Pat Nugent Pacific Gas & Electric Regulatory Services P.O. Box 56 Avila Beach, CA 93424

i 1

i 1

1 I

1 l

'l l

5 t

SIGNIFICANT HAZARDS EVALUATION (3 Pages) ,

e n

F D

f e

i u

't I F4

ULNRC-3555 Attachment 1 Page 1 of 3 SIGNIFICANT HAZARDS EVALUATION

References:

1) NUREG-0830, Safety Evaluation Report related to Operation of Callaway Plant, Unit 1 4

2) Final Safety Analysis Report, Chapter

7.3.6.1.1 This amendment application revises the " Channels to Trip" column for Functional Units 6.d.2.a and 6.d.2.b of Technical Specifications (TS). Table 3.3-3 to correct an error in the i logic for starting of the Turbine Driven Auxiliary Feedwater Pump (TDAFP)on steam generator low-low level. The current TS indicate that 2 of 4 steam generator low-low level channels in any steam generator will actuate the TDAFP. The actual plant design requires 2 of 4 in any two steam

, generators for automatic actuation of the TDAFP. The TS l wording error was introduced in the Union Electric license amendment request associated with Amendment 43 to Facility Operating License NPF-30. This change is required to address compliance with the Callaway Technical Specifications.

]

BACKGROUND The logic the Auxiliary Feedwater Actuation Signal - Turbine Driven (AFAS-T) from a steam generator low-low level signal has remained the same since operation of the facility began in 1984. FSAR Section 7.3.6.1.1 states that an AFAS-T is generated on low-low level in any two steam generators.

This design was reviewed and accepted by NRC in Reference 1.

The correct design of the logic was reflected in the Technical Specifications until April 14, 1989, when

, Amendment 43 was issued. Amendment 43 approved changes to the TS associated with the addition of an Environmental Allowance Modifier (EAM) and Trip Time Delay (TTD) to the steam generator low-low level circuitry. The hardware modification did not impact the start logic (i.e., number of steam generators with low-low level) of the TDAFP. However, when translating the information in the " Channels to Trip" column for Functional Item 6.d.2.a and .b of Table 3.3-3, the number "2" was inadvertently omitted such that the new TS indicated that low-low- level in any steam generator would result in an AFAS-T. The surveillance testing associated with this TDAFP start logic has remained unchanged since initial startup and verifies the logic is correct per-the plant design.

~

,. . ULNRC-3555' Attachment 1 Page 2 of 3

-It should be noted that the information contained in the "

" Channels to Trip" column in Table 3.3-3 of the current TS is not included in NUREG-1431, Rev. 1, Standard Technical Specifications - Westinghouse Plants. Union Electric plans to submit an amendment request in May, 1997 to convert to the improved TS format. Through the conversion, information from the " Channels to Trip" column will be moved to the TS Bases. This error was discovered on March 31, 1997 during a review by Union Electric personnel while .onducting. reviews in support of NEI Initiative 96-05.

4 3

EVALUATION The proposed change does not involve a significant hazards consideration because operation of Callaway Plant in

accordance with these changes would not

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

All accident analyses of record are based on the actual plant. design of.the Turbine Driven Auxiliary Feedwater Actuation System. The wording in the current Technical Specifications does not accurately reflect plant design. Surveillance testing has and continues to verify actual plant design. This change will simply correct an administrative error associated with a previous amendment request and no new requirements are being imposed on any plant systems or components. The probability and consequences of the accidents previously evaluated in the Final Safety Analysis Report (FSAR) are unchanged.

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

4 This change does not impact any plant hardware and does not represent a change in design. This change brings the TS into conformance with the piant design which was i evaluated and accepted in Section 7.3.1.10 of the l Callaway Plant Safety Evaluation Report (Reference 1).

No new accident initiators or transient precursors, J failure mechanisms, or limiting single failures are introduced as a result of this change. I 1

'l

~

ULMRC-3555 Attachment 1 Page 3 of 3 (3) Involve a significant reduction in a margin of safety.

The safety margins of the Technical Specifications are l based on the actual plant design and are unaffected by l this change. . The plant design has been evaluated and i accepted by NRC via Reference 1. This change simply corrects an administrative error associated with a '

previous license amendment request and brings the TS into conformance with actual plant design.

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 i 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 10 CFR 50.92(c) and does not involve a significett hazards consideration.

l 2

d

ULNRC-3555 e

. 4 i

l 1

i 4

8 d

i i

ENVIRONMENTAL CONSIDERATION (1 Page)

A d

4 L

f b

--* ULNRC-3555 Attachment 2 Page 1 of 1 ENVIRONMENTAL CONSIDERATION This amendment application revises the " Channels to Trip" column for Functional Units 6.d.2.a and 6.d.2.b of Technical Specifications (TS) Table 3.3-3 to correct an error in the logic for starting of the Turbine Driven Auxiliary Feedwater Pump (TDAFP) on steam generator low-low level. The current TS indicate-that two-out-of-four steam generator low-low level channels in any steam generator will actuate the TDAFP. The actual plant design requires two-out-of-four in any two steam generators for automatic actuation of the TDAFP. The TS wording error was introduced in the Union Electric license amendment request associated with Amendment 43 to Facility Operating License NPF-30. This change is required to address compliance with the Callaway Technical {

Specifications. l The proposed amendment involves changes with respect to the use of facility components located within the restricted area, as defined in 10 CFR 20. Union Electric has determined that the proposed amendment does not involve:

(1) A significant hazard consideration, as discussed in Attachment 1 of this amendment application.

(2) A significant change in the types or significant increase in the amounts of any effluents that may be related offsite.

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

Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need'be prepared in connection with issuance of this amendment.

1

ULNRC-3555 t

t 6

TECHNICAL SPECIFICATIONS MARKUP (Page 3/4 3-16)

\

I I

O