ML20199A906

Confirms Results of Teleconference Between Union Electric & NRC in Which Union Electric Requested Enforcement Discretion from TS 3.8.1.1,Action D Requirements

ML20199A906
Person / Time
Site:	Callaway
Issue date:	01/22/1998
From:	Randolph G UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1600 ULNRC-3720, NUDOCS 9801280119
Download: ML20199A906 (10)

Text

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y Union riectrie l'OltoxC20 Catt.mer ha'd l'ulton. MO 65251 January 22,1998 U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop P1 137 Washington, DC 20555 j

, %m ULNRC-3720

/#8[S8 DOCKET NUMBER 50-483

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CALLAWAY PLANT UNION ELECTRIC CO.

REQUEST FOR NOTICE OF ENFORCEMENT DISCRETION (NOED)

Gentlemen:

This letter is to confirm the results of a teleconference between Union Electric and NRC Staff representatives in which Union Electric requested enforcement discretion from Technical Specifi;ation 3.8.1,1, Action d requirements.

On January 21,1998, at 1400 CST, Union Electric determined that a plant shutdown would be required in accordance with Technical Specification 3.8.1.1, Action d, dtief the 'B' train Emergency Exhaust System (EES) charcoal adsorber being determined j

inoperable while the ' A' Emergency Diesel Generator and 'A' Essential Service Watet train were inopercble. A further review of the test data for the charcoal and applicablg design bases accidents determined that the 'B' EES would still perform its safety function, Pursuant to NUREG 1600, " General Statement of Policy and Procedure for NRC Enforcement Action," Section Vil," Exercise of Discretion," Subsection 'C',

" Exercise of Discretion for an 0,nerating Facility," Union Electric requested a one time NOED to Technical Specitication (T/S) 3.8.1.1, Action d. Union Electric requested a 24-hour extension to the 2-hour allowance to satisfy the condition of Action d.l. The additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would allow restoration of the Emergency Diesel Generator and Essential Service Water train and preclude the need for a plant shutdown with its attendant risks.

This request for enforcement discretion was verbally discussed with the NRC Region IV Office and Oflice of Nuclear Reactor Regulation on January 21,1998 and subsequently verbally approved by the Deputy Regional Administrator, Mr. James E. Dyer. The writtenjustification for the NOED is contained in the attachment to this letter.

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ULNRC.3720 January 22,1998 Page 2

.,1f you should have any questions regarding thl request, please contact me at (573) 676 8245 or Mr. H. David Bono at (573) 676-4428.

Sincerely, G. L. Randolph Vice President and Chief Nuclear Omcer, Callaway Plant GLR /IIDB/tmw Attachment

ULNRC+3720 January 22,1998 Page 3

..cc: Mr. William D. Johnson Chief Branch B Division ofReactor Projects U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 8064 Mr. Ellis W. Merschoff 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 Mr. Barry C. Westreich (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 Washington, DC 20555 2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.

Washington, DC 20037 Plant Manager Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington,KS 66839

Attachment b ULNRC.3720 January 22,1998 Page I of 7 RIN)UEST TOR ENFORCEMENT DISCRETION REGARDING COMPLIANCE WITII TECilNICAL SPECIFICATION 3.8.1.1 "A. C. SOURCES", ACTION d.1 A.

Technical Specification (T/S) or other License Conditions that will 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 remaining 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 IlOT 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 SIIUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

H.

Circumstances Requiring the Request for Enforcement Discretion EES T/S Surveillance Requirement 4.7.7.b.2 requires on an 18 month frequency,

" Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide l

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 arwlysis 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 scheduled system outage.

On 1/21/98, laboratory analysis results for the charcoal samples submitted on 1/09/98 were r eceived. The results indicated that methyl iodide penetration was 2.45 %, which exceeded the T/S 2% limit and required declaring the 'B' EES train inoperable. This decision was made at 1400 CST. With a 'B' train component inoperable, the requirements of T/S 3.8.1.1, Action d.1 could not be met. Based on the status of the work on the 'A' train components, 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 met 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 results exceeding the 2% criteria is uncertain at this time. It should be noted that Operating License Amendment 118 issued 11/13/96 revised the charcoal sample test criteria. The 'B' train EES test results from the previous surveillance conducted 8/15/96 had indicated only a 0.05% penetration. Similarly, the ' A' train EES results from the surveillance conducted 10/10/96 indicated only a 0.02% penetration. The test results from all previous tests are trended in order to detect testing anomalies and to predict when the charcoal beds will degrade to the point 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 clange evidenced in the test results. Therefore the change may be more I

indicative of the change in test methodology or a non-representative sample.

Attaciuneet O ULNRC 3720 January 22,1998 Page 2 of 7 C. I Safety Evaluation Design Bases Function:

The standby power supply for each safety related load group consists of one diesel generator complete with its accessories and fbel storage and transfer systems. It is capable

- f supplying essential loads necessary to reliably and safely shutdown and cooldown the o

reactor. The diesel generators are electrically isolated firom each other. Power and control cables for the diesel generators and associated switchgear are routed to maintain physical

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separation. This is discussed in Final Safety Analysis Report (FSAR) Section 8.3.1.1.3.

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The Fuel Building heating, ventilation, and air conditioning (HVAC) system and the Auxiliary Building HVAC system are discussed in Callaway FS AR Sections 9.4.2 and 1

9.4.3. These sections describe the interrelationship of the EES for these two buildings.

The EES also collects and processes the Fuel Building atmosphere in the event of a Fuel l

Handling Accident. During operation of the EES, the nonessential Fuel Building HVAC l

air paths are isolated and the building exhausted to assure that fission products and particulate matter are collected and processed. The Fuel Building intake air system is provided with two motor-operated dampers in a series arrangement. Indication 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 the hydrogen purge system are processed. All ductwork which is not required for operation of the EES and penetrates the 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.nainSin a negative pressure 0.25 in. w.g. to assure that all leakage is into the Auxiliary Beilding.

Impact on Nuclear Safety:

Amendment i18 to Callaway Facility Operating License NPF 30 revised the testing standard for the EES charcoal adsorbers. The updated test standard applies to carbon samples obtained in accordance with Regulatory Guide Position C.6.b. of Regulatory Guide 1.52, Revision 2, March 1978 and 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 Amendments 96 and _1_06_. - Amendment % eliminated the containment spray additive system and replaced it with a passive Recirculation Fluid pH Control (RFPC) system.

Amendment 96 as supplemented by Amendment 105 revised the control room dose charcoal filter assumption from 90% to 95% efficiency.

Attaciunent O ULNRC.3720 January 22,1998 Page 3 of 7 The current analysis for the EES for the Fuel Handling Accident and LOCA assumes a 90% efficiency although the test methodology would support a 95% efficiency. Testing the charcoal using the newer methodology provides greater assurance that the charcoal filters will perform at an efficiency of at least 90%.

The laboratory test results obtained on January 21,1998 which indicated a methyl lodide penetration of 2.45% still supports an efliciency of the emergency exhaust train 'B' charcoal adsorber of greater than 90%. Based on this, the adsorber is fully functional to support the assumptions of our safety analysis and there is no increase in offsite or control room dose consequences for a fuel handing accident or LOCA. These are the only accidents that credit the EES.

Probabilistic Safety Assessment (PSA) Evaluation:

The efliciency of the EES charcoal adsorber has no impact on the calculated Callaway core damage frequency. In addition, there is no impact on any release frequency calculated for the Callaway Level 2 probabilistic safety analysis, including large, early release frequencies. Since the Callaway MAAP model does account for these charcoal adsorbers, there could be a small impact on certain IPE source terms for which the Auxiliary Building was credited to mitigate the release.

D.

Unreviewed Safety Question Determination and No Significant Hazards Consideration Evaluation Unreviewed Safety Question Determination:

Based on information provided in Item C, the proposed request for enforcement discretion does not involve:

1) an increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis 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 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 train 'B' charcoal adsorber is fully functional to meet the assumptions of the safety analysis. rhe enforcement discretion prevents an unnecessary unit shutdown whi ~

uld result in a reactor transient and an unwarranted challenge of safr i systems.

2) creation of the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.

The EES train 'B' adsorber will continue to perform in a manner consistent with the assumptions iri the FS AR and safety ant. lysis. No new scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced. There will be no

AtudmentO UL,NRC 3720 January 22,1998 Page 4 of 7 s'dverse effects or challenges imposed on any safety-related system as a result of this

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request. Therefore, the possibility of a new or different kind of accident is not created.

3) a decrease in the margin of safety as defined in the basis for any T/S.

The EES train 'B' adsorber will continue to perform in a manner consistent with the assumptions in the FSAR and safety analysis. The proposed changes will not affect or-change a safety limit or affect plant operations. These changes wi;l not reduce the margin of safety assumed in the accident analysis nor reduce any margin of safety as -

defined h 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 system response time will not be affected,

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Conclusion:==

Based upon the preceding information, it has been determined that the proposed request does not involve any undue risk to the health and safety of the public nor involve en unreviewed safety question per the requirements of 10 CFR 50.59.

No Significant Hazards Consideration Evaluation:

In accordance with 10 CFR 50.92(c), UE's evaluation of the proposed enforcement discretion for no significant hazards consideration is as follows:

1.

The proposed request for enforcement discretion does not involve a significant increase in the probability or consequences of an accident or malfunction previously ev.luated, 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 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 train 'B' charcoat adsorber is fully functional to meet the assumptions of the safety analysis. The enforcement discretion prevents an.

unnecessary unit shutdown which could result in a reactor transient 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 evaluated.

2.

The proposed request for enforcement discretion does not create %.a possibility af a new or different kind of accident from any accident previously evaluated.

The EES train 'B' adsorber will continue to perform in a manner consistent with the assumptions in the FSAR and safety analysis. No new scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced. There will be no adverse effects or challenges imposed on any safety-related system as a result of this

Atudment t)

ULNRC+3720 January 22,199 Pase s a(7 a -

lequest. Therefore, the possibility of a new or different kind of accident is not created.

3.

The proposed request for enforcement discretion does not involve a significant

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reduction in the margin of safety.

i The EES train 'B' adsorber will continue to perform in a manner consistent with the assumptions in the FSAR and safety analysis. The proposed changes will not affect or change a safety limit or affect plant operations. These changes will not reduce the -

margin of safety assumed in the accident analysis nor reduce any margin of safety as defined 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 system response i-time will not be affected, i

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Conclusion:==

Based upon the preceding information, it las beet Jetermined that the proposed request 3

meets the requirements of 10 CFR 50.92 (c) and does not involve a significant hazards consideration.

1 E.

Environsneetal Evaluation i

This request for enforcement discretion meets the eligibility criteria for categorical exclusion met forth in 10 CFR $1.22(c)(9) as specified below:

I 1.

Involves no significant hazards consideration An demonstrated in Section D "Unreviewed Safety Question Deterniination and No Signiticant Hazards Consideration Evaluation" of this attachment, the request does not involve any significant hazards consideration; 1

2.

J.ere is no significant change in the types or significant increase in the amounts of i

any emuents that may be released offsite i

The equest does not involve a change to the facility or operating procedures that

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would cawe an increase in the amounts of effluents or create new types of emuents.

j' The request for enforcement discretion does not involve changes to any normal emuent pathway. The request only involves the EES emuent pathv/ay. Therefore, i

there is no change in the types or increase in the amounts of any routine emuents that may be released offsite.

i 3.

There is no significant increase in individual or cumulative occupational radiation exposure The request would not adversely affect the operation of the reactor, and would not affect any system that would affect occupational radiation exposure. The proposed change does not create additional exposure to utility personn:1 nor affect levels of

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Attaciunent O ULNRC.3720 January 22,1998 Page 6 of 7 radiation present. The enforcement discretion request will not result in any increase in utility personnel individual or cumulative occupational radiation exposure.

Based on the above, it is concluded that there will be no impact on the environment resulting from the request, and that the request meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from ihe requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment '.he Commission.

F.

Compensatory Actions i

The following compensatory measures will be performed-Restoration of the 'A' EDG and ' A' ESW System is currently being conducted.

e Load Dispatch was contacted to ensure no intentional perturbations would be made to the system that would result in a loss ofoff site power, 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 Duration Requested It is requested that enforcement discretion t.c given to extend the T/S 3.8.1.1,2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time limit to satisfy the condition of Action d.1 an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This would extend the allowed out of service time for the ' A' EDO from 1600 CST on 1/21/98 to 1600 CST on 1/22/98 in order to restore the ' A' EDG and ' A' ESW System from a maintenance outage.

The extension would allow sufficient time for restoration, performance of the required surveillance tests, and contingency for unforeseen pwblems resulting from the shortened outage. Without the NOED, a plant shutdown would be required.

II.

C1-Site Review Committee reviewed and approval Callaway Plant's On-Site Review Committee approved the NOED request at 1515 CST on l

1/21/98.

I.

Justification for Submitting a Request for Enforcement Discretion In Accordance with NUREG 1600, " General Statement of Policy and Procedures for NRC Enforcement Actions,"Section VII, " Exercise of Discretion," Subsection "C," Exercise of Discretion for an Operating Facility;"

"For an operating plant, this exercise of enforcement discretion is intendM to minimize the potential safety consequences of unnecessary plant transients with accompanying risks and impacts."

The surveillance requirements of T/S 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 function during the period j

one of the EDG is inoperable. For the current situation the 'B' EES train is considered i

Attachmem t)

ULNRC 3720 January 22,1998 Page 7 of 7 inopNable from a T/S standpoint, but still capable of performing its safety function. The charcoal test results support the conclusion that the unit would still provide the 90%

removal efficiency assumed in the design basis accident analyses. Therefore the potential safety consequences 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.

- J.

Need for Lleense Amendment and Impact of T/S Line-Item Improvements on Request This is intended to be a one-time request and no OL amendments are necessary. Callaway i

has submitted Improved Technical Specifications for review by the NRC A review of our submittal confirmed that adoption would not have obylated the need for this request for j

enforcement discretion.

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