ML20198S636
| ML20198S636 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/22/1998 |
| From: | Randolph G UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3720, NUDOCS 9801260244 | |
| Download: ML20198S636 (11) | |
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FN 22 '98 02:23PM OLt.AWAY R. ANT OA P.2/A1 l #a*8 Ik*k PO Box $20
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Fulton,MO t5251 4
e January 22,199R U. S. Nuclear Regulatory Commissier Document Control Desk Mail Stop Pl-137 Washington, DC 20555 ULNRC-3720 DOCKET NUMBER 50-483
'y[ CAMWAYPLANT UNION ELECTRIC Co.
REQUESTFOR NOTICE OF ENFORCEMENT DISCRETION (NOED)
Gentlemen:
This letter is to conSrm the resuhs of a teleconference between Union Electric and NRC Staff representatives in which Union Electric requested enfoecement discretion from Technical Specification 3.8.1.1, Action d requirements.
On January 21,1998, a* 1400 CST, Union Electdc determined that a plant slutdown would be required in accordance with Technical Specification 3.8.1.1, Action d, due to the 'B' train Emergacy Exhaust Systers (EES) checoal adsorber being determined inoperable while the 'A' Emergency Die :1 Gewator ard 'A' Essential Service Water train were inoperable. A further reviev <>f that.t data for the charcoal and applies.ble design bases accidents determined that the 'B' EES wwld still perform its safet) function. Pursaut to NUREG 1600, " General Statement of Policy and Pmcedure for NRC Enforcement Action,"Section VII, " Exercise ofDiscretion," Subsection 'C', )f
" Exercise ofDiscretion for an Operating Facility," Union Electric requested a one jl time NOED to Technical Specification (T/S) 3.8.1.1, Antion d. Union Electric '
requested a 24-hour extension to the 2-hour allowance to satisfy th; :ondition of
' ' Action d.1. The additional 24-hours would allow restoration of the Er awcy Diesel Generator and Essential Service Water tmin and preclude the need for a plant 4
.} shutdown with its attendant dsks.
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This request for enforcement discretion was verbally disccssed with the NRC Region IV OfEce and Office ofNuclect Reactor Regulation on January 21,1998 and subsequently verbally approved by the Deputy Regiomt Administrator, Mr, James E. Dyer The writtenjustificati:,2 for the h OED is contained in the Mment to this letter.
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Wyou should have any questions regarding this request, phase contact me at
. . (573) 676-8245 or Mr. H. David Bono at (573) 676-4428.
Sincerely, G. L. Randolph Vice VWdent and ChiefNuclear Officer, Callaws Plant GLR /HDB/tmw .
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cc: Mr. William D. Johnson ChiefBranchB >
Division ofReactorProjects U.S. Nuclear Regulatory Commission P;gionIV 611 Ryan Plaza Drive, Suite 400 Mington, TX 76011-8064 Mr. Palis W. Marschoff '
Regional Administrator U.S.Nuchar Regulatory Commission RegionIV 611 Ryan Plaza Drive, Suca 400 .
Atlington, TX 76011 8064 Senior ResidentInspector Callaway Resident Office i U.S. Nuclear Regulstery Commission 8201 NRC Road Steedman,MO 65077 4
Mr. Barry C. Westreich(2 copies)
Licensing Project Manager, Callaway Plate.
Office ofNuclear Reactor Regulation
, U. S. Nuclear Regulatory Commission Mail Stop 13E16 Wa*Mayaa DC 20555-2738 Manager, Electric Department Missouri Peblic Service Ccmmission 4-PO Box 360 Jefferson City, MO 65102 Mr. Thomas A.Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.
Washington,DC 20037 PlantManager
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Wolf Creek Nuclear Operating Corpontion PO Box 411 Burlington, KS 66839 - ,
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ULNRC 3720 -
faamary 22,1s98
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Pass 1 d7 REQUEST FOR ENFORCEMENT DISCRETION RECARDING COMPLIANCE WITH TECENICAL SPECIFICATION 3.8.L1 "A. C. SOURCES", ACTION d.1 A Tochancal specificaties (T/S) er other License Ceeditions that wiE be violated Technical Specification 3.8.1.1, Action d.1 requires that, with one diesel generator inoperable, all required systems, subsystems, trains, components and devices that depend on the mmaining OPERABLE diesel generator as a source of emergency power are also OPERABLE. If these conditions are not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOriN within the fbliowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
B, Circuanstamees Requiring the Request for Enforceenest Discretion EES T/S Surveillance Requirement 4.7.7.b.2 requires on an 18 month frequer .y,
" Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b ofRegulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D-3803-1989 when tested at 30' C and 70% relative humidity, for methyl iodide penetration ofless than 2%."
On 1/09/98 a charcoal test sample was removed from the 'B' Train of the EES and submitted for laboratory analysis in accordance with T/S Surveillance Requirement 4.7.7.b.2.
On 1/21/98, at 0739 CST, the 'A' Emergency Diesel Generator (EDG) and the 'A' train of Essential Service Water (ESW) were removed from service for a schedded system outage.
On 1/21/98, .hboratory analysis results for the charcoal samples submitted on 1/09/98 were received. The results indicated that methyl iodide pcz hmion was 2.45 %, which exceeded the T/S 2% limit and oquired declaring the 'B' EES train inoperable. This decision was made at 1400 CST. With a 'B' train component inoperable, the requii, s of T/S 3.8.1.1, Actioc :.1 could not be met. Based on the status of the work on the 'A' train ccmi.cres, and the time it would take to replace the charcoal in the 'B' train EES, it was apparent that the requirement to satisfy the condition of Action d.1 could not be m-t within the allowed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and enforcement discretion would be needed to continue operation.
The reason for the charcoal test resuhs exceeding the 2% critana is uncertain at this time. It should be noted that Operating License Amendment 118 issued 11113/96 re"ised the chancel sample test criteria. The 'B' train EES test resuhs fiom the previous nuvalH*m conducted 8/15/96 had indicated only a 0.05% pmetrption. Similarly, the 'A' train EES
, , reauke from the surveillance caahd 10/10/96 indicated ordy a 0.02% penetration. The test results from all previous tests are trended in order to detect testing anomahs and to predict when the charcoal beds will degrade to the po'mt they need replaced. While neither EES train has had its charcoal bed replaced since initial plant operation, trending did not predict the degradation. In addition, no known events occurred since the last test that could have caused the change evidenceo in the test resuhs. Therefore the change may be more indicative of the chance in test methodology or a non-representative sample.
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, C. Safety Evaluation Design Bases Punction:
Tbc standby power supply for each sefety-related load group manista of one diesel generator complete with its acessories ar.d fuel storage and transfer systems. It is capable
- of suppiving essential loads necessary to reliably and safely shutdown and cooldown the reactor. The diesel generators are electrica'ly isolated from each other. Power and control cables for the diesel generators and associated switchgear are routed to maintain physical separation. This is discus, sed in Final Safety Analysis Report (FSAR) Section 8.3.1.1.3.
rhe Puel Building heating, ventilation, and air conditioning (HVAC) system and the Auxiliary Building HVAC system are discussed in Callaway FSAR, Sections 9.4.2 and i 9.4.3. These sections deswibe the interrektionship of the EES for these two buildings.
The EES also collects and processes the Fuel Building atmosphere in the event of a Fuel Handling Accidant. During operation of the EES, the nonessential FuelBuilding HVAC
, air paths are isolated and the building exhausted to assure that fission products and particulate matter are collected and pr~~~l The Fuel Building intake air system is provided with two motor-operated dampers in a series arrangenvsnt. Indicatian of high
- radiation levels in the Fuel Building will initiate automatic transfer to the EES. In this lineup, the EES will maintain the Fuel Building at a negative pressure of 0.25 in, w.g.,
relative to the outside atmosphere.
The EES serves the Auxiliary Building only following a Loss of Coolant Accident (LOCA) to assure that all Emergency Core Cooling System (ECCS) leakage to the Auxiliary Building atmosphere and the containment air purged via tie hydrogen purge system are processsd. All ductwork which is not required for operation of the EES and penetrates the i Auxiliary Building boundary is automatically isolated. These nonessential systems are provided with two motor-operated dampers in a series arrangement at the boundary penetrations. These will close automatically following receipt of a Safety Injection Signal (SIS). In this lineup, the EES will raaintain a negative pressure 0.25 in w.g. to assure that
. all leakage is into the Auxiliary Building.
Impact on Nuclear Safety:
Amendment 118 to Callaway Facility Operating License NPF-30 revised the testing L
standcrd for the EES charcoal adsorbers. The nM test standard applies to carbon samples obtained in accordance with Regulatory Guide Position C.6.b. of Rapals:ory Guide 1.52, Revision 2, March 1973 mi meets the laboratory testing criteria of ASTM D-3803-1989 when tested at 30*C and 70% relative humidity for a methyl iodide penetration ofless than 2%. This test methodology is consistent with that which was approved in
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Amandmenr2 96 and 106. Amendment 96 eliminc.ed the containment spray additive system and replaced it with a passive Recirculation Fluid pH Control (RFPC) system.
Amendmc.t 96 as supplemented by Amendment 106 revised the controi room dose
, charcoal filter assumption from 90% to 95% efficiency.-
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- Jasmary 22,1998 Pap 3 es7 The current analysis for the EES for the Fuel Handling Accident and LOCA assumes a T 90% ef5ciency although the test methodology would support a 95% of5ciency. Testing the charcoal using the newer mee.hodology provides greater assurance that the charcoal filters will perform at an efficiency of at least 90%.
Tne laboratory test resuhs WaH on January 21,1998 which indicated a methyl lodide panetration of 2A5% still supports an efficiency of the emergency avhans train 'B' charcoal adsorber of greater than 90%. Based on this, the adsorber is fully fbactional to support the assumptions ofour safety analysis and there is no incruase in ofEnte or control room dose consequences for a fuel handing accident or LOCA. These are the only mecida=*c est credit the EES.
Probabilistic Safety Assessment (PSA) Evaluation:
The Officiency of the EES charcoal adsorber has no impact on the calmistad Callaway core damage frequency. In addition, there is no impact on any release firequency calculated for the Callsway Level 2 probabilistic safety analysis, including large, early release frequencies. Since the Callaway MAAP model does account for these charcoal adsorbers, b
there could be a small impact on certain IPE source terms for whick lia Auxiliary Building was credited to mitigate the release.
D. Unreviewed Safety Qaesties Determination and No Signincaat Hazards Consideration Evaluaties UnreviW Safety Question Determination:
Based on information provided in Item C, the proposed request for enfuroement discretion does notinvolve:
- 1) an increase in the probability of occurrence or the consequences of an ace'. dent or malfunction of equipment important to safety previously evaluated in the safety analysi6 report, The requested 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> increase in the allowed outage, time associated with Technical Specification Action Statement 3.8.1.1.d is still within the allowed outage time of Action Statement 3.8.1.1.b for one diesel Sensrator inoperable, which is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> The emergency exhaust train 'B' charcoal adsorber is fully functional to meet the assumptions of the safety snalysis. The enforcement discret i on pia an unnecessary unit shutdown which could result in a reactor transient and an unwarranted challenge of safsty-related systems.
- 2) - creation of the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report
'Ihe EES train 'B' adsorber wG continue to pennm in a manner conalemt with the
- !-= nations in the FSAR and safety analysis. No new scenarios, transient precursors, falhue mechanisms, orlimiting single failures are introduced. There will be no s-
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. January 21,1998 Page 4 et7 adverse effects or challenges heposed on any safety-related system as a resuk of this request. Therefore, the possibility of a new or diffemnt kind of accident is not created.
- 3) a decrease in the margin of safety as de6ned in the basis for any T/S The EES train 'B' adsorber will continue to perform in a asaaner annale== whh the ,
assumptions in the FSAR, and safety analysis. The proposed changes will not effect or change a safety limit or affect plant operations. These changes will not reduce the margin of safety assumed in the accident analysis nor reduos any margin of safety as denned in the basis for any T/S. The proposed changes do not affect the acceptance criteria for any analyzed event. No setpoints are revised and the .ystem response time willnot be affected.
Conchision:
r Based upon the preceding information, it has been determ;ned tht the proposed request does not involve any undue risk to the health and safety of the public imr involve an unreviewed safety question per the requirements of 10 CFR 50.59. *
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No Significant Hazards Consideration Evaluation:
- In accordance with 10 CFR 50.92(c), UE's evaluation of the proposed endbrcement discretion for no significant hazards consideration is as fbliows
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- 1. b proposed request for enforcement discretion does acrJmvolve a significant increase in the probability or consequences of an accident or malfunction previously evaluated N requested 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> increase in ine allowed outage time associated with Technical Spd.cstion Actices S'.atenent 3.8.;.l.d is still within the allowed outage time of Action Statement 3.8.1.1.b fot one desel generator inoperable, which is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The emergency exhaust trair. 'B'. charcoal adsorber is ibily &artlanal to meet the assumptions of the safety analysis. The enforcement discretion pmvents an unnecessary unit shutdown v hich co 11d result in a reactor tunsicct and an unwarranted challenge of safety-related systems Therefore the request for enforcement discretion will not result in an increase in the probability or consequences of an accident or malfunction previously evahi=*ad
~ 2. . h proposed request for wiv.w.w.t discretion does not create the possibility of a new or different kind of accident from any accident previously evakumed
& EES train 'B' adsorber will continue to perform in a manner canaistaat with the assumptions in the FSAR and safety analysis. No new scenarios, transiest precursors, 1- failure mechanisms, or limiting single failures are introduced. There will be no adverse effects or challenges imposed on any safety related system as a resuh of this 4
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request. Therefore, the possibilkv of a new or different kind of accident is not created.
- 3. The proposed request for enforcement discretion does not involve a signiBeant reduction in the margin of safety.
N EES train 'B' adsorber will continue to perform in a manner consistant with the assumptions in the FSAR and safety analysis. The proposed changes wili not afect or change a safety limit or afect plant operations. These changes will not reduce the margin of safety assumed in the accident analysis nor reduos any magin of safiry as denn3d in the basis for any T/S. The proposed changes do not asset the acosptance
, criteria for any analyzed event. No setpoints are revised and the systen response time will not be affected.
Conclusion:
Based upon the preceding information, it has been determined that the proposed request masts the requirements of 10 CFR 50.92 (:) and does not involve a signincent hazards .
consideration.
E. Enviremesental Evaluaties This request for enforcement disembs: me. cts the eligibility criteria fbr categorical exclusion set forth in 10 CFR 511:(c.X9) as specified below:
- 1. Involves no significant hazards consideration 4
As demonstrated in Section D "Unreviewed Safety Question Detamination and No Significant Hazards Consideration Evaluation" of this machmaat, the request does not involve any significant hazards consideration.
- 2. There is no significant change ia the types or significant increase in the amounts of any effluents that may be released offsite
. The request does not involve a change to the facility or operating procedures that would cause an increase in the amounts of efBueats or create new types of shames.
The request for enforcement discretion does not involve chmages to any normal
. . efBuent pathway. The request only involves the EES efBuent pathway. Therefore, there is no change in the types or increase in the amounts of any routine effluents that may be released offsite.
- 3. There is no signific. ant increase in individual or cumulative occupational radiation exposure The request would not adversely affect the operation of the reactor, and would not aNect any system that would affect occupational radiation exposure.' The pmposed change does not create additional exposure to utility personnel nor afEset levels of
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ULNRC 3730 l , 'Jesmary 22,1998 hge 6 ef 7 radiation present. The enforcement discretion request will not resuk in any increase in utilky personnel individual or cunnlative m=a4nal radiation exposure.
Based on the above, it is concluded that there will be no impact on the environment resuking from the request, and that the request meets the criteria specified in 10 CPR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission.
F. Compensatory Actions ne following compensatory maamres will be pesformed-e Restoration of the 'A' EDG and 'A' ESW System is currently being WM e Load Dispatch was contacted to ensure no intentional perturbations wou'd be made to the system that would result in a loss of off-site power, e No discretionary work will be authorized which would could cause a plant transient or affect operability of other systems.
. No fuel handling will occur.
Once the ' A' EDG and ' A' ESW train is restored to service the NOED will be exited.
G. Justification for Duraties Requested e
It is requested that enforcement discretion be given to extend the T/S 3.3.1.1,2-hour time link to satisfy the condition of Action d.1 an additional 24-hours his would extend the allowed out of service time for the 'A' EDG from 1600 CST on 1/21/98 to 1600 CST on 1/22/98 in crder to restore the 'A' EDG and ' A' ESW System from a ma'mtenance outage.
Tb.xtension would allow sufficient time for restoration, performance of the required surveillance tests, and contingency for unforeseen problems r==#ng from the shortened outage. Without the NOED, a plant shutdown would be required.
H. On-Site Review Committee reviewed and approval Callaway Plant's On-Site Review Committee approved the NOED request at 1515 CST on 1/21/98.
I. Justificaties for Subsmitting a Request for Enforcement Discretion In Ag&d-ise with NUREG 1600, " General Statement of Policy and Procedures for NRC Enforcement Actions," Section VH, " Exercise of Discretion," Subsection "C," Exercise of Ducretion for an Operating Facility;" ,
"For an operating plant, this exercise of enforcement discretion is imended to minimize the potential afety consequences of unnecessary plant transients with accompanying risks and imriacts "
%e surveillance requirements ofliS 3.8.1.1, Action d.1 are intended to ensure that a loss-of-offsite power event will not result in a complete loss of safety fbnetion during the period one of the EDG is inoperable. For the current situation the 'B' EES train is considered 1
Jm ;p '90 Q 31PM CA_L M Y FLmT % P.11/11 Uuotc-3720 Jemmy 22,199s Page 7 ef 7 inoperable from a T/S standpoint, but still capable of performing its safety function. The chercoal test resuhs support the conclusion that the unit would still provide the 90%
removal efficiency assumed in the design basis accident analyses. Therefore the potential safety consepences associated with the requested extension are less than the potential risks and consequences associated with a plant shutdown while one EDG and ESW train are inoperable.
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Need for License Amendment and Impact of T/S Line-Item Improvements en Request This is intended to be a one-time request and no OL amendments are necessary. Callaway has submitted Improved Technical Specifications for review by the NRC. A review of our submittal confirmed that adoption would not have obviated the need for this request for enforcement discretion.
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. AmerenUE CALLAWAYNUCLEAR PLANT Message Transmittod By:
P. O. Box 620 Fulton,MO 65251 2
FAX No. (573) 676- 4202 __
Date: / .JJ-ff A.M.
VerificationNo. (573) 676- 4341 Time: 8,'/2 ' P.M.
DO NOT USE RED INK OR PENCIL TOTALPAGES: 16 To: Do;ument control Desk From: H. Dave Bono Company: U.s. Nuclear Regulatory comm. Extension: sus Receiving FAX 301-415-7010
. VerificationNo.
Discard O MailtoReceivingParty Return to Sender (Please provide address)
Instructions to Receiving Operator: Please deliver to Document Control Desk.
Document' Control Desk - an : original letter is being mailed today.
.. u U d 1 b)
M21 01/21/93 N/A 1
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