ML20207S514

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Safety Evaluation Supporting Amend 18 to License NPF-30
ML20207S514
Person / Time
Site: Callaway 
Issue date: 03/10/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20207S513 List:
References
NUDOCS 8703190590
Download: ML20207S514 (5)


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UNITED STATES

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 18 TO OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 INTRODUCTION By letter dated September 29, 1986, and supplement thereto dated February 26, 1987, Union Electric Company (the licensee) submitted an amendment request for changes to the Technical Specifications for the Callaway Plant. The changes pertain to the main steam isolation valves (MSIVs) and to the main feedwater isolation valves (MFIVs). The principal effect of the proposed changes would be to clarify the Technical Specifications pertaining to the MSIVs and to the 4

MFIVs in particular. We have reviewed the proposed changes and find them to be acceptable as discussed below.

DISCUSSION AND EVALUATION The licensee sumarizes their amendment request by stating that the request provides clarification and restructures the Technical Specifications asso-ciated with the MSIVs and MFIVs.

Further, no changes are being made to the valves or their response times, and therefore the original design bases are met.

For the Engineered Safety Features Response Times (Table 3.3-5), the licensee proposes to' separate the response times for the MSIVs and the MFIVs into two parts. The response time for the sensor, associated electronics and actuation relays would be indicated in Table 3.3-5, whereas the valve closure tine, for the valve to be considered operable, would be given in a separate specification.

Thus, the MSIV and MFIV response times in Table 3.3-5 would be changed from the present < 7 seconds to < 2 seconds, with a footnote added that the response l

time does not include valve closure time. A separate specification would re-quire valve closure time within five seconds for the valve to be OPERABLE. As i

a result, there would be no effective change in the overall response times.

We therefore find this proposed change to be acceptable.

i The Containment Isolation Valves (Table 3.6-1) include a list of the MSIVs and MFIVs under the table notation "Other Automatic Valves." The maximum iso-lation time for these valves is presently indicated as 5 seconds. The licensee proposes to replace the 5 seconds with N.A. (not applicable). The 5 seconds requirement would then appear in other technical specifications as discussed previously.

The licensee partially justifies the changes in Table 3.6-1 on the basis that the MSIVs and MFIVs are not containment isolation valves because the valves are not required to meet containment isolation criteria since the containment 0703190590 870310 PDR ADOCK 05000483 P

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secondary side of the steam generator, and the lines emanating from the steam generator secondary shells. We find that the licensee's contention that the MSIVs and MFIVs are not containment isolation valves conflicts with General Design Criterion 57 which states in part:

Each line that penetrates primary reactor containment and is neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere shall have at least one containment isolation valve which shall be either automatic, or locked closed, or capable of remote manual operation.

Although we disagree with the licensee's contention that the MSIVs and MFIVs are not containment isolation valves, we find the changes to Table 3.6-1 are acceptable because the specifications for the MSIVs and MFIVs appear elsewhere in the Technical Specifications and there is no effective change in the over-all response time of the valve closures. Also the licensee states and the staff finds that the licensee's proposed change in Table 3.6-1 for the Callaway plant is similar to the existing Table 3.6-1 for the Wolf Creek plant.

A footnote pertaining to the MSIVs and MFIVs would also be added stating:

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      • These valves are included only for table completeness. The require-ments of Specification 3.6.3 do not apply; instead, the requirements of Specification 3.7.1.5 and 3.7.1.6 apply to the Main Steam Isolation Valves and Main Feedwater Isolation Valves, respectively.

I Specification 3.6.3 pertains to containment isolation valves other than the MSIVs and MFIVs and is applicable for Modes 1, 2, 3 and 4.

Specifications 3.7.1.5 and 3.7.1.6 pertain to the MSIVs and MFIVs, respectively; apply to i

Modes 1, 2 and 3; and have different action statements than 3.6.3.

Thus, the effect of the licensee's proposed changed is to clarify the appropriate limiting conditions for operation and associated action statements for the i

MSIVs and MFIVs. We find this clarification note acceptable and observe that i

a similar note appears in the Wolf Creek Technical Specifications.

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The licensee proposes the addition of the following to the Bases section of the Technical Specifications:

3/4.7.1.6 Feedwater Isolation Valves The OPERABILITY of the feedwater isolation valves functions to: 1) provide a pressure boundary to permit auxiliary feedwater addition in the event of a main steam or feedwater line break inside contain-ment; and 2) ensure that no more than one steam generator will blow down in the event of a steam line rupture which a) minimizes the positive reactivity effects of the Reactor Coolant System cooldown associated with the blowdown, and b) limits the pressure rise within containment. The MSIVs and FWIVs are not considered to be contain-ment isolation valves. The containment boundary is the steam generator secondary side and tubes. The OPERABILITY of the feed-water isolation valves within the closure times of the Surveillance Requirements are consistent with the assumptions used in the safety analysis.

  • As discussed previously, the staff disagrees that the MSIVs and MFIVs are not considered to be containment isolation valves. Therefore, the staff recomended that the following statements should be removed from the Bases section:

"The MSIVs and FWIVs are not considered to be containment isolation valves. The containment boundary is the steam generator secondary side and tubes" By letter dated February 26, 1987 the licensee supplemented its amendment re-quest by removing the above statement as requested by the staff.

The licensee also proposes the following LC0 and Surveillance Requirement for the Main Feedwater System:

Plant Systems Main Feedwater System Limiting Condition For Operation 3.7.1.6 Each main feedwater isolation valve (MFIV) shall be OPERABLE.

Aeolicability: Modes 1, 2, and 3.

Action:

Modes 1 and 2 With one MFIV inoperable but open, operation may continue qi provided the inoperable valve is restored to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; otherwise be in HOT STANDBY within i

the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, f

Mode 3:

With one MFIV inoperable, subsequent operation in Mode 3 may proceed provided the isolation valve is maintained i

closed. Otherwise, be in HOT SHUTDOWN within the next l

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Surveillance Requirements 4.7.1.6 Each MFIV shall be demonstrated OPERABLE by verifying full t

closure within 5 seconds when tested pursuant to Stucification 4.0.5.

The provisions of specification 4.0.4 are not applicable for entry into MODE 3.

Staff notes that the above proposed additional LC0 and Surveillance Requirement for the MFIVs is consistent with the present 3.7.1.5 LCO and 4.7.2.5 Surveil-lance Requirement for the MSIVs. Also, we note that the present 3.7.1.5 LC0 and 4.7.1.5 Surveillance Requirement is consistent with the latest proposed revision 5 of the Westinghouse Standard Technical Specification.

Finally, we find a definite functional relationship between the MSIVs and MFIVs, and would there-fore expect the LCOs and Surveillance Requirements to be similar. We therefore find the proposed Technical Specification to be acceptable.

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SUMMARY

The licensee for the Callaway Plant has submitted proposed Technical Specifi-cation changes pertaining to the main steam isolation valves (MSIVs) and to the main feedwater isolation valves (MFIVs). The proposed changes restructure the Technical Specifications, primarily toward the objective of clarification.

No changes are being made to the valves or to their response times. We have reviewed the proposed Technical Specification changes and find them to be acceptable, except for the changes proposed in the Bases section.

In two places in the Bases section, the words "The OPERABILITY" appear. We would suggest adding the words:

"of the main steam isolation valves and" after the word OPERABILITY in each place. Also the following statements should be removed from the Bases section.

"The MSIVs and FWIVs are not considered to be containment isolation valves. The containment b^undary is the steam i

generator secondary side and tubes."

ENVIRONMENTAL CONSIDERATION This amendment involves changes in the use of a facility component located within tho restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Comission has previously published a proposed finding that the amendment involves no significant hazards con-sideration and there has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forthin10CFR651.22(c)(9). Pursuant to 10 CFR 551.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

CONCLUSION The Commission made a proposed detennination that the amendment involves no significant hazards consideration which was published in the Federal Register (51 FR 45215) on December 17, 1986, and consulted with the state of Missouri.

No public comments were received, and the state of Missouri did not have any comments.

We have concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Paul O'Connor, PWR#4/DPWR-A A. Toalston, EICSB/DPWR-A Date: March 10, 1987

March 10, 1987 AMENDMENT N0.18 TO FACILITY OPERATING LICENSE NPF CALLAWAY PLANT, UNIT 1 1

DISTRIBUTION:

Doctet F11e
502483j

'NRC^PDR" ~ " ~'"~~

Local PDR PRC System PWR#4 Rdg M. Duncan P. O'Connor T. Novak B. J. Youngblood R. Diggs T. Barnhart (4)

W. Jones OPA F0B J. Partlow B. Grimes E. Jordan ACRS (10)

OGC-Bethesda L. Harmon A. Toalston