ML20198P408
| ML20198P408 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/31/1997 |
| From: | Passwater A UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20198P411 | List: |
| References | |
| ULNRC-3674, NUDOCS 9711070146 | |
| Download: ML20198P408 (13) | |
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October 31, 1997 Eu(6Nk:
E3 U.S. Nuclear Regulatory Conunission Attn: Document Control Desk Mail Station PI 137 Washington, DC 20555 ULNRC.3674 Gentlemen:
DOCKET NUMHER 50-483 l
CALLAWAY PLANT CllANGES TO ESFAS FUNCTIONAL UNIT 6.f
Reference:
- 1) ULNRC-3578 dated May 15, 1997 I
Union Electric Company herewith transmits an application for amendment to Facility Operating Licer.se No. NFF-30 for the Callaway Plant.
This amendment reoplication would revise ESPAS Functional Unit 6.f, less of Offsite Powt.. Start Turbine-Driven Pump, in Technical Specification Tables 3.3 3,3.3-4, and 4.3 2 as follows:
(1) Table 3.3-3 is reviw.I to create separate Functional Units for the analog and digital portions of the ESFAS function associated with staning the turbine-driven auxiliary feedwater pump (TDAFP) upon a loss of offsite power. This separation is required to correct the present inconsistency between the operability requirements imposed in Table 3.3-3, written only for the digital circuitry, and the surveillance requirements imposed in Table 4.3 2 which have meanies only for the analog circuitry, (2) Table 3.3-4 is also revised to create separk Fimetional Units for the analog and digital portions of the ESFAS function associated with he staning the TDAFP upon a loss of offsite power. This is necessary s
since the current 'N.A."setpoint listings apply only to the digital I\\
ponion. Trie analog ponion has a Trip Setpoint and Allowable Value, as specified under Functional Unit 8.a.
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U.S. Nuclear Regul: tory Conunission Page 2 UUIRC-3674 (3) Table 4.3-2 is likewise revised to create separate Functional Units for the analog and digital portions of the ESFAS function associated with staning the TDAFP upon a loss of offsite power. This is necessary since only the analog ponion of this function is subject to a CilANNEL CALIBRATION and a monthly TADOT can reasonably be perfonned only on the analog ponion, since the performance of a TADOT on the digital ponion at power is not post.ible without the use of jumpers and lifted leads. It is proposed that the digital portion only be tested during refueling outages, similar to Functional Unit 6.g, while noting that all of the BOP ESPAS actuation logic is tested monthly under Functional Unit 6.c.
The Callaway Plant Onsite Review Committee and the Nuclear Safety Review Boani have reviewed this amendment application. Attachments i thmugh 3 provide the Significant Hazards Evaluation, Environmental Consideration, and progesed Technical Specincation revisions, respectively, in suppon of this amendment request. In addition, Attachments 4 and 5 provide changes to Attachments 19 and 20 of the license amendment application submitted in Reference 1. It has been detennined that this amendment application does not involve a significant hazard consideration as detennined per 10CFR50.92. Pursuant to 10CFR51.22(b), no environmental impact statement or envimnmental assessment need be prepared in connection with the issuance of this amendment.
If you have any questions on this amendment application, please contact us.
j Very imly yours, I
Alan C. Passwater Manager-Licensing and Fuels GGY/std Attachments: 1 - Significant Hazards Evaluation 2 - Environmental Consideration 3 - Pmposed Technical Specincation Revisions 4 - Changes to ULNRC-3578 Attachment 19 l
5 - Changes to ULNRC-3578 Attachment 20 l
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STATE OF MISSOURI )
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Alan C. Passweter, of lawful age, being first duly sworn upon oath says that he is Manager, Licensing and Fuels (Nuclear) for Union Electric Company; that he has read the foregoing document and knows the content thereofi that he has executed the same for and on behalf of said company with full power and cuthority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
^+H By Alan C. Passwater Manager, Licensing and Fuels Nuclear SUBrCRI ED and sworn to before me this day of C+
N1 1997.
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. dis.....h PATRICWL REYNOLDS NOTAM PUBUC--4TAft 0FiANOMIB sT. LOUIS COUNTY MV000mm0640NEXPlfM 05. E W
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M. H. Fletcher Professional Nuclear Consulting, Inc.
19041 T aines Drive Derwood, MD 20855-2432 Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Barry C. Westreich (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 Missourd Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 Jef ferson City, MO 65102 Don Woodlan TU Electric P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent Pacific Gas & Electric Regulatory Services P.O. Box 56 Avila Beach, CA 93424 i
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ATTACIIMENT ONE SIGNIFICANT IIAZARDS EVALUATION
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Page 1 of 5 i
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SIGNIFICANT HAZARDS EVALUATION
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INTRODUCTION This amendment application would revise ESFAS Functional Unit 6.f, Imss of Offsite Power-f Start Turbine-Driven Pump, in Technical Specification Tables 3.3 3, 3.3-4, and 4.3-2 as 1
follows:
(1) Table 3.3 3 is revised to create sepante Functional Units for the analog and digital podions of the ESFAS function associated with staning the turbine-driven auxiliary feedwater pump (TDAFP) upon a loss of offsite power. This separation is trquired to correct the present inconsistency between the operability requirements imposed in Table 3.3-3, written only for the digital circuitry, and the surveillance trquirements imposed in Table 4.3 2 which have meaning only for the analog circuitry.
j The analog ponion, labeled new Functional Unit 6 f.1), consists of the same 4kV bus (NB01 and NB02) undervoltage relays specified in Functional Unit 8.a; t
however, differing MODE Applicabilities trquire a separate line item be added to Table 3.3 3. The ACTION Statement for new Functional Unit 6.f.1) is the same as r
that for Functional Unit 8 a, i.e. ACTION 19, and the same 3.0.4 exception footnote is applied. The current ACTION Statement 22 for Functional Unit 6 f, with its 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed outage time (AOT), and the currently specified Total Number of Channels (2), Channels to Trip (1), and Minimum Channels OPERABLE (2) do not apply to the analog ponion with its four channels in a two-out-of four logic, for which continued operation should be allowed with an inoperable channel as long as it is tripped within I hour.
The digital podion, labeled new Functional Unit 6.f.2), consists of the output relays from the load shedder and emergency load sequencer (LSELS) cabinets and that portion of the BOP-ESI AS separation gruup 1 and 4 circuitry associated with the stan of the TDAFP upon a loss of offsite power. A new ACTION Statement 39 has been added which recognizes that this digital circuitry is only associated with the TDAFP As sch, the inoperability of one logic train would be given a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> AOT after which the TDAFP would be declared inopemble and ACTION would be taken as required by Technical Specification 3.7.1.2. The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> AOT is a reasonable restoration time considering the nature of this Functional Unit, the available redundancy, and the low probability of an event occr g during this interval. Tne 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> AOT is also consistent with that allowet g she current i
ACTION Siatement 22 for Functional Unit 6.f, as well as the AGT allowed by ACTION Statements for other automatically initiated functions, e.g., ACTION Statements 5.a (RTS Functional Umt 6.b) and 26 (ESFAS Functional Unit 9). If
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AttTlunent 1 Page 2 of 5 both logic trains were inoperable, new ACTION Statement 39 would require that the TDAFP be immediately declared inopemble. There should be no requirement to enter Specincation 3.0.3 for loss of both logic trains since the only affected end device is the TDAFP and ACTIONS already exist under Specification 3.7.1.2 to address TDAFP inoperability. Similar approaches addressing end device opembility are also used for ESPAS Functional Units 3.c (ACTION Statement 17),
6.a (ACTION Statement 24), and 10 (ACTION Statement 25).
(2) Table 3.3-4 is also revised to create separate Functional Un;ts for the analog and digital ponions of the ESPAS function associated with staning the TDAFP upon a loss of offsite power. This is necessary since the current H.A.'setpoint listings apply only to the digital ponlon. The analog ponion has a Trip Setpoint and Allowable Value, as speelned under Functional Unit 8.a.
(3) Tahle 4.3-2 is likewise revised to create separate Functional Units for the analog and digital ponions of the ESFAS function associated with staning the TDAFP upon a loss of offsite power. 'lhis is necessary since only the analog ponion of this function is subject to a CHANNEL CALIBRATION and a monthly TADOT can reasonably be perfonned only on the analog portion, since the perfonnance of a TADOT on the digital ponion at power is not possible without the use of jumpers and lifted leads. It is proposed that the digital ponion only be tested during refueling outages, similar to Functional Unit 6.g, while noting that all of the BOP-ESPAS actuation logic is tested monthly under Functional Unit 6.c.
HMKGROUND less of Offsite Pour Instmmentation and lead Skdder and Emergency Imad Sequencer The diesel generators (DGs) provide a source of emergency power when offsite power is either unavailable or is insufficiently stable to allow safe unit opemtion. If a loss of voltage or degnaled voltage condition occurs at the 4.16 kV ESF buses, undervoltage protection will:
a) Trip the 4.16 kV preferred nonnal and alternate bus feeder breakers to remove the deficient power source to pmtect the Class lE equipment fmm damage; b) Shed all loads from the bus except the Class IE 480 Vac load centers and centrifugal charging pumps to prepart the buses for re-energization by the load shedder and eraergency load sequencer (LSELS); and c) Generate a DG start signal.
i Att chment !
Page 3 of 5 There are two sets of undervoltage protection cirruhs, one for each 4.16 kV NB system bus.
Each set consists of a loss of voltage and degraded voltage function. Four potential tmnsfonners on each bus pmvide the necessary input voltages to the protective devices used to perfonn these functions. The undervoltage protection circuits are described in FSAR Section 8.3.1.1.3.
Four instantaneous undervoltage relays with an associated time delay am pmvided for each 4.16 kV Class lE system bus for detectinc a loss of bus voltage. The outputs are combined in a two-out-of-four logic to generate an undervoltage signal if the voltage is below appmximately 70% for a short time.
Four degraded voltage b! stables with associated time delays are provided for each 4.16 kV Class IE system bus for detecting a sustained degraded voltage condition. The four bistable outputs are combined in a two-out-of-four logic to (;enemte a degmded voltage signal if the voltage is below appmximately 90% far a long tiuc.
Rilance of Plant (ILOP) ESFAS The BOP luPAS processes signals fmm SSPS, signal processing equipment, and plant radiation monitors to actuate certain ESF equipment. There are two redundan trains clBOP ESFAS, and a third sepamtion group to actuate the turbine-driven auxiliary feedwater pump and reposition automatic valves (turbine steam supply valves, turbine trip and throttle valve, ESW supply valves, CST supply valve) as required. The redundant trains provide actuation for the motor-driven auxiliary feedwater pumps (and reposition automatic valves as required, i.e., steam generator blowdown and sample line isolation valves, ESW supply valves, CST supply valves), containment purge isolation, control room emergency ventilation, and emergency exhaust actuation functions.
Turbine-Driven Auxiliary Fmiwater Pumo Start on less of Offsite Power A loss of offsite power (LOP) is indicated by the undervoltage irlays detecting a loss of voltage on each ESF bus, as discussed above. Upon satisfying the two-out-of-four loss of voltage logic in the LSELS cabinets, LSELS output relays feed the redundant separation groups 1 and 4 BOP-ESFAS cabincts as show in the attached Figure 1. The separation groups I and 4 BOP-ESFAS cabinets perfonn several functions, as discussed above, but on a LOP signal these cabinets perfonn only two functions, i.e., the steam generator blowdown and sample lines are isolated and electrically isolated outputs are provided to the separation group 2 BOP-ESPAS cabinet. The sepamtion gmup 2 BOP-ESFAS cabinet is only associated with the TDAFP and is considered to be part of that end device, i.e., the TDAFP, in the Technical Specifications. On a LOP signal, the turbine steam supply valves (ABlIV0005 and ABilV0006) and the turbine trip and throttle valve (FCIIV0312) are opened for the start of the
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- 50.92 EVALUATION 1
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'Ihe proposed change to the Technical Specincation does not involve a significant hazards-j consideration as discussed below.
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- t.. Does the change involve a significant increase in the pmbability or consequences of an accident previously evaluated?
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Overall pmtection system perfonnance will remain within the bounds of the previously perfonned accident analyses since no hardware changes are proposed.
l The recognition that different operability and surveillance requirements apply to analog vs. digital circuitry does not impact any previoucly analyzed accidents. The proposed change will not affect any of the analysis assumptions for any of the accidents previously evaluated. The proposed change does not alter the current method or procedures for meeting the surveillance requirements in Table 4.3-2.
The pmposed change will not affect the probability of any event initiators nor will l
~ the pmposed change affect the ability of any safety-related equipment to perfonn its lien <ted function. There will be no degradation in the perfonnance of nor an increase in the number of challenges imposed on safety-related equipment assumed j
tc, function during an accident situation. Therefore, the proposed change does not j
involve a significant increase in the probability or consequences of an accident previously evah.ated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
There are no hardware changes nor are there any changes in the method by which any safety related plant ;ystem performs its safety function. The separation of analog and digital pomons of Functional Unit 6.f will not impact the nonnal inethod of plant operation.
The operability requiremems, ACTION Statement, and surveillance requirements for the analog portion, new Functional Unit 6.f.1), are identical to those of Functional Unit 8.a, while the requirements for the digital portion, new Functional
- Unit.6.f 2), are consistent with the current Technical Specifications, other than the new ACTION Statement 39 provisions that defer to the TDAFP Specification 3.7.1.2 requirements and the perfonnance of a TADOT durinc appropriate plant l
. conditions. These changes do not change any ESFAS design standards and are 1
L appmpriate for digital functions s%h as this. No new accident scenarios, transient y
L precursors, failun; ncchanisms; or limiting single failures are introduced as a result of this change. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
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- 3. Does this change involve significant reduction in a margin of safety?.
i The progesed change does not affect the acceptance criteria for any analyzed event.
There will be no effect on the manner in which safety limits or limiting safety i
system settings are detennined nor will there be any effect un those plant systems necessary to assure the accomplishment of protes tion functions. There will be no impact on any margin of safety.
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CONCLUSION Hased upon the preceding information, it has been detennined that the proposed changes to the Technical Specifications do not invol"; a significant increase in the probability or j
consequences of any accident prev'ausly evaluated, create the possibility of a new or different
- kind of accident from any accider. previously evaluated, o * "olve a significant reduction in a
- margin of safety. Therefore, it is concluded that the proposed changes meet the requirements of 10CFR50.92(c) and do not involve a significant hazards consioeration.
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1 ULNRC-3674 ATTACIL%fENT TWO ENVIRONMENTAL CONSIDERATION
Page1 ofI liNVIRONMENTAL CONSIDERATION This amendment application would revise ESFAS Functional Unit 6.f, Ioss of Offsite Power-Stan Turbine-Driven Pump, in Technical Specification Tables 3.3-3, 3.3-4, and 4.3-2 as follows:
(1) Table 3.3-3 is revised to create sepamte Functional Units for the analog and digital ponions of the ESFAS function associated with staning the turbine-driven auxiliary feedwater pump (TDAFP) upon a loss of offsite power. This separation is requinxl to correct the present inc< insistency between the operability requirements imposed in Table 3.3-3, written only for the digital circuitry, and the surveillance requirements imposed in Table 4.3 2 which have meaning only for the analg circuitry.
(2) Table 3.3-4 is also revised to create sepamte Functional Units for the analog and digital ponions of the ESFAS function anociated with staning the TDAFP upon a loss of offsite,:awer. This is necessary since the curn:nt 'N. A."setpoint listings apply only to the digital ponion. The analog ponion has a Trip Setpoint and Allowable Value, as specified under Functional Uni: 8.a.
(3) Table 4.-3-2 is likewise n: vised to create separate Functional Units for the analog and digital ponions of the ESFAS function associated with stading the TDAFP upon a loss of offsite power. This is necessary since only the analog ponion of this function is subject to a CIIANNEL CALIBRATION and a monthly TADOT can reasonably be perfonned only on the analog ponion, since the perfonnance of a TADOT on the digital ponion at power is not possible without the use of jumpers and lifted leads. It is proposed that the digital portion only be tested during refueFng outages, similar to Functional Unit 6.g, while noting that all o the BOP-r ESFAS actuation logic is tested monthly under Functional Unit 6.c.
The proposed amendment involves changes with respect to the use of facility components located within the restricted area, as defined in 10CFR20. Union Electric has determined that the proposed amendment does not involve:
(1) A significant hazaris consideration, as discussed !.i Attachment 1 of this amendment application; (2) A significant change in th typ:s or significant increase in the amounts of any effluents that may be released offsite; (3) A significant increase in individuct or cumulative occupational radiation exposure.
Acconting, the pmposed amendment meets the eligibility criteria for categorical exclusion su fonh in 10CFR51.22(c)(9). Pursuant to 10CFR51.22(b), no environmental impact statement or envimnmental assessment need be prepared in connection with the issuance of this amendment.