ML20151F593
| ML20151F593 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/12/1988 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20151F594 | List: |
| References | |
| ULNRC-1805, NUDOCS 8807270163 | |
| Download: ML20151F593 (10) | |
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1 1622' 1901 Gratiot Street St. Louis Donald F. Schteell Vea PreWent July 12, 1988 U.S.
Nuclear Regulatory Commission A*tn: Document Control Desk k
. Station F1-137
.shington, D.C.
20555 Gentlemen:
ULNRC-1805 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.5.1 REACTOR COOLANT SYSTEM ACCUMULATORS Union Electric Company is transmitting an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant.
This amendment application request revises Technical Specification 3/4.5.1 and its associated bases to: change Action Statement a..and b.
to allow the unit to remain in Hot Standby (Mode 3) with Reactor Coolant System (RCS) pressure less than 1000 psig and with one accumulator inoperable in lieu'of going to Hot Shutdown (Mode 4); and to add a note to Action Statement b.
to allow closing one accumulator isolation valve for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform leakage testing of system check valves.
The change to allow the unit to remain in Hot Standby at a reduced RCS pressure is a previously approved change that the Commission $ssued as Amendment No. 11 to Facility Operating Licens6 No. NPF-42 for Wolf Creek Generating Station on November 2, 1987.
The other change is an administrative change to clarify the Action Statement associated with a closed isolation valve.
Currently in Mode 3, when testing system check valves for leakage as required by Technical Specification 4.0.5, the isolation valve must be closed.
The closure of the isolation valve causes the accumulator to be inoperable and the required Action is to open the valve immediately or be in at least Mode 3 within the nent 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Technically, this can be interpreted as a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period of time in which these isolation valves can be closed before further Action is required, since the testing is being done in Mode 3.
The intent and interpretation of this Action Statement has resulted in discussions between the NRC Resident Inspectors and the Callaway Plant Staff as to whether or not the-Action Statement has or is being met during check valve testing.
The addition of the requested note to the technical specification would. clarify the specification for all personnel involved.
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$ 3k Maihng Ackfress: P.O. Box 149 Lo, MO 63166
' Attachments 1, 2,
and 3 contain the Safety Evaluation, the
'Significant Hazard Evaluation, and the Proposed Technical ~
Spacification Changes in support of this amendment. request.
-The-prcposed changes will.become effective for Union Electric implementation upon NRC approval.
Enclosed is a' check for the
$150.00 application fee (Attachment 4) as required by 10CER170.21.
Very truly yours, Donald F.
Schnell JMC/ dis q
Attachments:
1.
Safety Evaluation 4
2.
Significant Hazard Evaluation
- 3. Proposed Technical Specification Changes 4.
Application Fee 1
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STATE OF MISSOURI )
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Donald F.
Schnell, of lawful age, being first duly-sworn upon oath says that he is Senior Vice President-Nuclear.and an
-officer 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 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~
Donald F.
Schnell Senior.Vice President Nuclear SUBSCRIBED and sworn to before me this / d day of.
198[-
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. BARBARA AF -
NOTARY PUBUC, STATE OF MISSOURI-MY COMMISSION EXPIRES APRIL 22,1989 ST. LOUIS COUNTY. _
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bcci D. Shafer/A160.761
/QA-Record (CA-758)
Nuclear Date DFS/ Chrono D.
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Schnell J. E. Birk.
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J. F._McLaughlin A. P. Neuhalfen R. J. Schukai-M. A. Stiller G. L. Randolph R. J.
Irwin H. Wuertenbaecher-W. R. Campbell A. C. Passwater R.
P. Wendling D.
E.
Shafer D.
- i. Walker 0.' Maynard (WCNOC)
R. C. Slovic (Bechtel)
G56.37 (CA-460)
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Sharkey NSRB (Sandra Auston)
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cc i. Gerald Charnoff, Esq.
Shaw, Pittman,-Potts & Trowbridge'
-2300 N.. Street,'N.W.
Washington,.D.C.
'20037 Dr. J. O. Cermak CFA, Inc.
4 Professional Drive 1-(Suite 110)
Gaithersburg, MD-20879 R.
C.' Knop Chief,, Reactor Project Branch 1 U.S.' Nuclear Regulatory Commission Region III 799-Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077 Tom Alexion (2)
Office of Nuclear Reactor Regulation-U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box-360 Jefferson City, MO 65102 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
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Attachm:nt 1, pags 1 of 2 ULNRC 1805 SAFETY EVALUATION This amendment request revises Technical Specification 3/4.5.1 and its associated bases to: Change Action Statement a. and b. to allow the unit to remain in Hot Standby with Reactor Coolant System pressure less than 1000 psig and with one accumulator inoperable in lieu of going to Hot Shutdown; and add a note to Action i
Statement b to allow closing one accumulator valve for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform leakage testing por Technical Specification 4.0.5 or 4.4.6.2.2.
These changes and their respective safety evaluations are discuased hereinafter.
l 1)
The first proposed change would allow the plant to remair. in Hot Standby l
(Mode 3) with Reactor Coolant System pressure less than 1,000 psig with one l
accumulator inoperable in lieu of going to Hot Shutdown (Mode 4).
Technical Specification 3 5-1 is applicabic in modes 1, 2 and 3, and when (pressurizer) pressure is above 1,000 psig; i.e., when all accumulators are operable.
(The accumulator nitrogen cover-pressure at Callaway Plant is between 602 and 648 psig). Normal operation procedures require the control room operators to close the accumulator discharge valves whenever the RCS l
pressure is reduced below 1,000 psig.
The present Technical Specification 3 5-1 Action Statements require the plant to be in Hot Standby (mode 3) within seven hours from the moment the accumulator has been declared inoperable and in Hot Shutdown (mode 4) within the following 6 houra. The proposed amendment would revise the Action statements to require the plant to be in mode 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and require a reduction of the RCS pressure to less than or equal to 1,000 psig within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Justification for this change is that it is an administrative change to the technical specification to clarify the intent of the Action Statements when an accumulator is declared inoperable. As currently stated the Action Statements apply in modes 1, 2 and 3, and mode 3 is applicable only if the pressurizer pressure is above 1000 psig. The requirement to enter into mode 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if an inoperable accumulator cannot be restored to operable status while in mode 3 is an unnecessary requirement that imposes thermal cycling on the RCS containment and reactor internals.
Since the accumulators are not required to be operable with the RCS pressure below 1000 psig and the plant in mode 3 or a lower mode the Action Statements need to be revised to reflect this condition. Therefore, the proposed change is simply an administrative change to clarify the intent of the Action Statements.
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- Attachmsnt 1,; pass 2 of 2 ULNRC 1805-1 2)
The -second. proposed change woulb allow an accumulator. isolation valve
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to be closed for a specified period'of up' to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, with the reactor in mode 3 and with RCS pressure greater than 1000 psig, for testing of system check valves. 'This.would require.Ta delibrate action to close the valve'for testing and not' require immediate action.to bes taken to reopen the valve as -
currently stated in-Technical' Specification 3' 5 1 Action Staterent b.
Justification for this change is that it(is. an ' administrative change' to clarify. the Action Statement associatedf with a. closed isolation valve.. The current Action Statement requires a closed isolation valve to be opened
.immediately.or to be in mode 3 within the'next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. 'This proposed-s change is to allow'the isolation valve to be closed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.in mode 3 for testing purposes. Since this~2 hour period is less~than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, allowed by the Action Statement, the proposed change is simply-an added note to clarify the Action Statement.
Pursuant to the 'above information, this amendment request does not adversely affect or endanger the health or safety.of the general public-and does not' involve an unreviewed safety question.
1, Page 1 of 2 ULNRC-18 05 SIGNIFICANT HAZARD EVALUATION This amendment'is requested to-revise. Technical Specification 3/4.5.'1 to
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-modify the Action Statemer.ta associated'with accumulator inoperabilitysas a.
result of isolation 'velve closure.and to, allow the plant to remain. in mode '3 with a reduction in RCS pressure in lieu of going to mode 4 if accumulator operability cannot be restored. The following discussions address these changes and their corresponding significant hazard evaluation.
1.
The proposed change to allow'the plant to remain in mode'3 with a reduction in RCS pressure in lieu of going to mode 4 if. accumulator operability cannot be restored would not:
a.
Involve a significant increase in the probability or conse-quences of an accident previously evaluated. The change to the.
Action Statement is merely to allow'the plant-to remain in hat' Standby (mode 3) for a longer period of time af ter an accunnla-tor has been declared inoperable, in lieu of going'.to Hot Shutdown (mode 4).
This additional time allowance in mode 3 at a reduction of the RCS pressure to less than 1000 psig would-reduce thermal cycling on.the.RCS and reactor internals; conform with the current version of the Westinghouse Standard Technical Specifications, NUREG-0452, Rev. 5; and would not affect the scope of the technical specification.
b.
Create the possibility of a new or different. kind of' accident from any accident previously evaluated. There-is no change to the system or components to create any new failure or accident sequences. The change allows the plant'to remain in mode 3 for
- a. longer time period upon entry-into an Action Statement and is consistent with NUREG-0452, Rev. 5.
This change also does not-affect the scope or intent of the original technical-specifica -
tion Action Statement.
Involve a significant reduction in a margin of safety.
The c.
change to allow the plant to remain in mode 3 fat a reduced RCS pressure does not impact the margin of safety.
Since this change is only effective upon entry into an: Action Statement due to an inoperable accumulator, the margin of safety.has been already reduced to 3 out of 4 accumulators available if needed and, therefore, this change does not impact the margin of safety that currently exists.
- a 1,
Attacilment 2, Page -2 of 2-ULNRC-IBoS 2.
The second proposed change would allow an accumulator' isolation.
valve to be~ closed for a specified period of up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,.with the
, reactor in mode 3 and with RCS pressure greater than'1000 psig, for testing of system check valves.
a.
The change would not involve.a.significant increase in the probability or consequences of an accident previously evaluated. The proposed change would allow a time. period of up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in which an accumulator isolation valve can~be closed while the plant is-in mode 3 and RCS pressure is greater than 1000 psig to perform surveillance leakage testing of system check valves. This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time period would only be applicable in mode 3 and would not affect accident evaluations since the current Action Statement allows up to 6. hours to achieve mode 3 status with en accumulator isolation valve:
closed. Also the valve could be;immediately opened if needed since the accumulator otherwise meets operability requirements.
b.
The change would not create the possibility of a new or different kind of accident from any-accident previously evaluated. There is no change to the system or components to create any new failure or accident sequences.
The change is merely a closely monitored period of time in which an accumulator isolation valve is closed on an otherwise operable accumulator to allow for system check valve testing required by.
technical specifications.
c.
The change would not involve a significant reduction'in a margin of safety. While the shutdown margin following a LOCA nay be reduced if a'LOCA were'to occur with one accumulator isolated, the increase in allowed time before the accumulator' isolation valve could be. opened does:not significantly affect the margin of-safety since;the accumulator could be returned to service if needed.
)
Based on the above discussions, the amendment ~ request does not involve a j
significant' increase in the probability ar consequences of an accident previ-l ously evaluated, nor create the possibility of a new or different kind of accident from any accident previously evaluated, nor involve a reduction in the required margin of safety.
Based on the foregoing, the requested amend-ment does^not present a'significant hazard.
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ULNRC IBo5 1
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PROPOSED TECHNICAL SPECIFICATION CHANGES 1
1 Specification 3/4.5.1 t
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