ML20214D597
| ML20214D597 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/18/1986 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-1410, NUDOCS 8611240161 | |
| Download: ML20214D597 (5) | |
Text
.
UNION Etscraic n
1901 Gratiot Street, St. Louis Donald F. Schnell Vice Presnient a
November 18, 1986 Mr. Harold R.
Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
ULNRC-1410 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATIONS CONCERNING MAIN STEAM AND MAIN FEEDWATER ISOLATION VALVES
Reference:
ULNRC-1377 dated 9-29-86, same subject The referenced letter transmitted a Technical Specification amendment request to withdraw previous change requests related to Type C test extensions and editorial changes to valve descriptions, to clarify Technical Specification Tables 3.3-5 and 3.6-1 regarding Main Steam and Main Feedwater Isolation valve operability and closure time requirements, and to add a new Specification 3/4.7.1.7 to define requirements for the Main Feedwater Isolation Valves.
Provided herewith is an expanded evaluation of significant hazards associated with the above changes.
The attachment replaces Enclosure 4 of the referenced letter in its entirety.
If there are any questions, please contact us.
Very truly yours, U
h Don ld F Schnell GGY/ tar 8611240161 861118 PDR ADOCK 05000483 P
PDR Ok I k
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Mailing Address: P.O. Box 149, St. Louis, MO 63166
i STATE OF MISSOURI )
)
i Robert J.
Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) for 1
Union Electric Company; that he has read the foregoing document and i
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.
i By
(
Robe J. TRihukai Gener anager-Engineering Nuclear SUBSCRIBED and sworn to before me this /[1 day of hthdo/198 b.
4 ANf-
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BARBARA U. PFAFF NOTARY PUBUC, STATE OF MISSOURI MY COMMISSION EXPtRES APRIL 22, 1989 j
ST. LOUIS COUNTY l
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. - ~ _., _ _ -. _.. - _ -
cc:
Gerald Charnoff, Esq.
Shaw, Pittman, Potts & T rowbridge 1800 M. Street, N.W.
Washington, D.C.
20036
. Nicholas A. Petrick Executive Director SNUPPS S Choke Cherry Road Rockville, Maryland 20850 I
C. W. Hehl Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission
-Region III 4
799 Roosevelt Road Glen Ellyn, Illinois 60137 i
Bruce Little Callaway Resident Of fice U.S.
Nuclear Regulatory Commission RR$1 Steedman, Missouri 65077 Paul O'Connor (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 Jefferson City, MO 65102 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 i
I
Attachment to ULNRC- /f/O SIGNIFICANT HAZARD EVALUATION This amendment request consists of three categories of changes to Table 3.3-5, Table 3.6-1 and proposed Specification 3/4.7.1.7 as discussed in the Safety Evaluation (Enclosure 3 of ULNRC-1377).
The following discussions address these changes and their corresponding significant hazard evaluations in the same order as discussed in the Safety Evaluation.
1.
The changes to Table 3.3-5, Engineered Safety Features Response Times, are requested such that only the sensor and associated electronic loop response times are included in this table.
The valve closure times are given in Specification 3/4.7.1.5 and proposed Specification 3/4.7.1.7.
a)
These changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
These changes delineate the electronic and mechanical portions of the closure times associated with the main steam isolation valves (MSIVs) and main feedwater isolation valves (MFIVs).
The 2 second signal processing time is appropriate for inclusion in the instrumentation section of the Technical Specifications (Table 3. 3-5) whereas the 5 second valve closure time is appropriate for inclusion in the plant systems section of the Technical Specifications (4.7.1.5 and proposed 4.7.1.7).
No changes to the total closure times are proposed.
These changes are a logical rearrangement of the electronic and mechanical portions of the total closure times, consistent with the treatment of Phase "A" isolation response times in Table 3.3-5.
b)
These changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
This is based on the fact that the method and manner of plant operation is unchanged and the changes involve clarifications between the electronic and mechanical portions of unchanged total valve closure times.
c)
These changes do not involve a significant reduction in a margin of safety.
This is based on the fact that no change in design or operation is involved.
The Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain examples (4 8FR14 870).
This change request is similar to the example of a change involving no significant hazards consideration which relates to a change that is administrative in nature.
The changes provide consistency between the Technical Specifications and FSAR.
Attachm:nt to ULNRC- /g/O 2.
The changes to Table 3.6-1 delete the MSIV and MFIV isolation time requirements and reference Specification 3/4.7.1.5 and proposed Specification 3/4.7.1.7 for these valves' operability requirements and closure times.
a)
These changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
As discussed in the FSAR (Figure 6.2.4-1 pages 1-8 and safety evaluation 7 of Section 6.2.4.3), the MSIVs and MFIVs are not containment isolation valves.
They were included in Technical Specification Table 3.6-1 per NRC direction for table completeness.
Since these valves are not required for containment isolation, operability in mode 4 should not be a requirement.
Containment integrity is maintained by the steam generator tubes, the snell of the secondary side of the steam generators, and the lines emanating f rom the steam generator secondary shells.
Based on a vendor recommendation to test these valves under operating conditions (i.e. mode 3) and the fact that these valves are not necessary for containment isolation, the mode applicability and closure time requirements specified in 3/4.7.1.5 and proposed 3/4.7.1.7 are appropriate and reflect design requirements.
b)
These changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
This is based on the fact that the method and manner of plant operation is unchanged.
The changes in mode applicabilities are consistent with current Technical Specification Table 3.3-3 and 3/4.7.1.5 (applicable modes are 1,2, and 3) and Table 3.6-1 of NUREG-1104 (Appendix A to NPF-32, Technical Specifications for Wolf Creek Generating Station).
No changes in valve closure times are proposed; they remain the same as stated in Technical Specifications 4.7.1.5 and proposed 4.7.1.7.
MSIV and MFIV closure times should not be listed in Table 3.6-1 since these valves are not required for containment isolation.
c)
These changes do not invlove a significant reduction in a margin of safety.
This is based on the fact that no design change is involved, MSIV and MFIV closure times remain the same, and mode applicabilities are consistent with the design requirements for steam and feedwater isolation rather than for containment isolation.
The Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain examples (4 8FR14 870).
This change request is similar to the example of an action involving no significant hazard consideration which relates to a change that is administrative in na ture.
The change provides consistency
Attachment to ULNRC- /f/O between the Technical Specifications and FSAR as to the purpose for valve closure and the closure time requirement.
3.
The addition of Specification 3/4.7.1.7 provides specific actions to be taken when MFIVs are inoperable.
a)
This change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed Technical Specification 3/4.7.1.7 adds operability and surveillance requirements for the MFIVs heretofore not included in the Technical Specifications.
b)
This change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
This is based on the f act that the method and manner of plant operation is unchanged.
- Further, the valve operability and closure time requirements are consistent with, or more conservative than, Technical Specification Table 3.3-3 (which requires feedwater isolation capability in modes 1 and 2) and current Tables 3.3-5 and 3.6-1 (i.e.,
2 second signal time and S second valve closure time).
c)
This change does not involve a significant reduction in a margin of safety.
This is based on the fact that no design change is involved, MFIV closure times remain the same, and mode applicabilities are consistent with the design requirements for feedwater isolation.
The Commission has provided guidance c'oncerning the application of the standards in 10CFR50.92 by providing certain examples (4 8FR14 87 0).
This change request is similar to the example of a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications.
Based on the above discussions, the amendment request does not involve a signi ficant increase in the probability or consequences of an accident previously evaluated; nor create the possibility of a new or different kind of accident from any accident previously evaluated; nor involve a reduction in the required margin of safety.
Based on the foregoing, the requested amendment does not present a significant hazard.