ML20137Q993

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Safety Evaluation Supporting Amend 119 to License NPF-30
ML20137Q993
Person / Time
Site: Callaway Ameren icon.png
Issue date: 04/02/1997
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20137Q984 List:
References
NUDOCS 9704110193
Download: ML20137Q993 (4)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 119 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT. UNIT 1 QQCKET NO. 50-483

1.0 INTRODUCTION

i By letter dated April 1,1997, Union Electric Company (UE), requested changes to the Technical Specifications (Appendix A to Facility Operating License No.

NPF-30) for the Callaway Plant, Unit 1.

The proposed amendment would revise Technical Specification (TS) Table 3.3-3 to correct administrative errorr associatei with the start logic of the turbine driven auxiliary feedwater pump (TDAFP).

2.0 EVALUATION By letter dated August 30, 1988, the licensee requested an amendment to the Callaway Plant TS related to the steam generator low-low level trip circuitry to add an environmental allowance modifier (EAM) and a trip time delay.

In the request, the licensee inadvertently requested a change to the steam generator low-low start logic on Table 3.3-3 for the TDAFP to change the logic from 2 channels per steam generator in any 2 steam generators to 2 channels per steam generator in any steam generator.

By letter dated April 14, 1989, the NRC issued Amendatat 43 to Facility Operating License NPF-30, approving the request.

On March 31, 1997, the licensee informed the NRC of the error. The logic for the automatic start of the TDAFP, as described in the Final Safety Analysis Report (FSAR), has remained the same (2 channels per steam generator in any 2 steam generators) since the Callaway Plant began operation in 1984.

The staff has reviewed the information contained in the licensee's August 30, 1988, amendment request and has concluded that the change was an administrative error as described in the licensee's April 1, 1997, amendment request. On this basis, the staff concludes that the change is acceptable.

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'3.0 DESCRIFTION OF EMERGENCY CIRCUMSTANCES l

On March 31, 1997, when the Callaway Plant staff discovered the error, the j

TDAFP was declared inoperable and TS Limiting Condition for Operation 3.7.1.2, i

i Action a. was entered. Action a. requires that the inoperable pump be 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 shut down to Mode 3 within the next six hours and in Mode 4 in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Therefore, without the change, the licensee would be required to shut down the plant.

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j Within one day of discovery of the error, the licensee submitted the emergency TS amendment request. The licensee stated in its application that the i

situation could not be avoided because it involved an administrative oversight 1

in a highly complex license amendment package.

The Commission finds that an emergency situation exists in that failure to act in a timely way would result in shutdown of the plant.

Further, the staff has j

determined that the licensee did not abuse the emergency provisions by failing i

to make a timely application and did not itself create the emergency.

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4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION 4

The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations, if operation of the facility, in accordance with the amendment would not:

i (1)

Involve a significant increase in the probability or consequences of any accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any previously evaluated; or

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(3)

Involve a significant reduction in a margin of safety.

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This amendment has been evaluated against the standards in 10 CFR 50.92.

It does not involve a significant hazards consideration because the changes would 1

not:

1 1.

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

i All accident analyses of record are based on the actual plant design of i

the turbine driven auxiliary feedwater actuation system. The wording in the current technical specifications does not accurately reflect 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 i

consequences of the accidents previously evaluated in the FSAR are unchanged.

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

This change does not impact any plant hardware and does not represent a j

change in design. This change brings the TS into conformance with the plant design which was evaluated and accepted in Section 7.3.1.10 of the callaway Plant Safety Evaluation Report (NUREG-0830). No new accident initiators er transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this change.

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Involve a significant reduction in a margin of safety.

The safety margins of the technical specifications are based on the actual plant design and are unaffected by this change. The plant design has been evaluated and accepted by NRC.

This change simply corrects an administrative error associated with a previous license amendment request i

and brings the TS into conformance with actual plant design.

Accordingly, the Commission has determined that the amendment involves no significant hazards considerations.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment.

The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final no significant hazards consideration finding with respect to this amendment.

Accordingly, the 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 the issuance of the amendment.

7.0 CONCLUSION

The Cosmiission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be andangered by operation in the proposed manner, (2) such

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activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

K. Thomas Date:

April 2, 1997 i

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