ML20205R375
| ML20205R375 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/30/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20205R377 | List: |
| References | |
| GL-85-19, ULNRC-1480, NUDOCS 8704060328 | |
| Download: ML20205R375 (7) | |
Text
3 Umon
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1901 Gratiot Street, St. Louis Donald F. Schnell Vice President March 30, 1987 U.S.
Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
ULNRC-1480 CALLAWAY PLANT DOCKET NO. 50-483 REVISION TO TECHNICAL SPECIFICATION 3.4.8 ACTIONS, BASES SECTICN 3/4.4.8 AND ADMINISTRATIVE CONTROLS SECTION 6.9.1.5
Reference:
Generic Letter 85-19, dated September 27, 1985 Union Electric herewith transmits one original and one conformed copy of an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant.
This amendment request revises the requirentents for reporting iodine spiking and eliminates the requirement to shut down the plant af ter 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of operation with a dose equivalent I-131 value of 1 pci/gm or greater.
The referenced Generic Letter 85-19 provides justifications for the proposed changes.
Per the Generic Letter, iodine spiking need no longer be a Special Report or Licensee Event Report but should be included in an Annual Report.
The information to be included in the Annual Report is similar to that previously required but more clearly designates the results to be included from a primary coolant specific activity analysis.
In addition, the information regarding fuel burnup by core region is deleted.
Since there has been improvement throughout the industry in the quality of nuclear fuel and since operational history has demonstrated the result that normal coolant iodine activity (in the absence of iodine spiking) is well below the Technical Specification limit, existing requirements to shut down a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a twelve month period can be eliminated.
In addition, regulations require the NRC to be immediately notified of fuel cladding failures that exceed expected values or that are caused by unexpected factors.
Thus through proper fuel management and existing reporting requirements, our operation of Callaway should preclude ever approaching the previous shutdown limit.
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- o Callaway has experienced indicated' fuel fa'ilures higher than anticipated during its second cycle of operation.
Under the.
existing reporting requirements, Callaway has issued two Special Reports concerning iodine spiking.. These~incidences did not-occur at power, and, at power, coolant iodine : activity levels remain ~significantly-below the limit.
Wefexpect'to. remove
' leaking fuel assemblies _during Refuel -:2, which will maintain-Callaway's coolant; iodine. activity at a reasonably low level.
Union Electric' requests. implementation of this. amendment request concurrent with the startup of Cycle 3 which is planned for October, 1987.
NRC review and approval.of'this amendment request consistent ~ with this schedule would be appreciated.
Enclosed is a check for the $150 application fee required by1 10CFR170.21.
Very truly yours,
. Donald F. Schnell DJW/ dis
Enclosures:
1 - Safety Evaluation 2 - Significant Hazards Considerations-3 --Marked Technical Specification Pages 4 - Application Fee q
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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 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.
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By i'
D6nald F.
Schnell Vice President Nuclear SUBSCRIBEDandsworntobeforemethis]8 day of
,198[
W}Wl BARBARA J. PFAFF NOTARY PUCUC STATE OF MISS00R1 MY COMMISS10't EXPlRES APRIL 22, 1983 ST. LOUIS COUNTY L
i cc:. Gerald L Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W. -
Washington,_D.C.
20037 J. O. Cermak CFA Inc.
3356 Tanterra circle Brookville, MD 20833 W. L. Forney Division of' Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 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 Ron Kucera, Deputy Director Department of Natural Resources P.O.
Box 176 4
Jefferson City, MO 65102 Manager, Electric Department Missouri Public Service Commission P.O.
Box 360 Jefferson City, MO 65102 2
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Encloruro 1 ULNRC-14 80
.Page'l of.l' Safety Evaluation This amendment request revises the requirements for reporting iodine spiking and eliminates the requirement to shut down the plant after 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of operation with a dose equivalent I-131 value of 1 yci/gm or greater.
The request complies with the Generic Letter 85-19, dated September 27, 1985, which reduces this reportability.
l In the Generic Letter it was determined that the existing requirements to shut down a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12 month period can be eliminated.
The quality of nuclear fuel has been greatly improved over the past decade with the result that normal coolant iodine activity (i.e. in the absence of iodine. spiking) is well below the limit.
Appropriate actions would beLinitiated long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the iodine activity limit.
In addition, 10 CFR 50.72(b)(1)(ii) requires the NRC t.o be immediately notified of fuel cladding failures that exceed expected values or that are caused by unexpected factors.
Therefore, this Technical Specification limit is no longer considered necessary on the basis that proper fuel management and existing reporting requirements-should preclude ~ever approaching the limit.
Reporting requirements have no effect on the severity or the consequences of an accident.
It also has no effect on the probability of an accident occuring or a different accident than one already evaluated.
Based on the above discussion, the proposed Techincal Specification changes do not adversely effect or endanger the health or the safety of the general public and do not involve an unreviewed safety question.
i
m Enclorura 2:
ULNRC-1480
~.
-Page-1 of 1, Significant Hazards Considerations This amendment request revisesfthe; req'irements for u
reporting iodine spiking and eliminates the requirement to shut
-down'the plant after 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of operation with a dose equivalent I-131 value of l'pci/gm or greater., _ This' request complies with the Generic Letter.85-19, dated September 174 1985, which reduces this reportability.-
This amendment request-does not represent a significant hazard jln that the revisions in
. reporting requirements do not involve a significant increase.in
~
the probability or consequence.of an accident or other-adverse:
condition over previous evaluations; nor do the revisions in reporting requirements create the possibility'of a new'or different kind of accident or condition over. previous evaluation;-
nor involve a significant reduction in a margin of safety.
With the proposed revisions under existing reporting requirements and with the proper fuel. management Callaway should not approach the above mentioned limits.
4
1 Enclo;ura 3 ULNRC-14 80 l
MARKED TECHNICAL SPECIFICATION PAGES' (a) 3/4.4.8 SPECIFIC ACTIVITY pages 3/4 4-25 to 4-26 (b) SPECIFIC ACTIVITY (continued) page B'3/4 4-6 (c) ANNUAL REPORTS (continued) 6.9.1.5 page 6-18 i