ML20216F373
| ML20216F373 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/09/1998 |
| From: | Passwater A UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20216F378 | List: |
| References | |
| ULNRC-3765, NUDOCS 9803180356 | |
| Download: ML20216F373 (12) | |
Text
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U i:n El:ctric One Amerea Ylaza 1001 Chouteau Awnue PO Box 66149 St louls, M0 03166-6149 31621.3227 March 9, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington D.C. 20555-0001 Gentlemen:
ULNRC-3 765 Mb DOCKET NUMBER 50-483 Tjgg CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.5.2 EMERGENCY CORE COOLING SYSTEM AmerenUE herewith transmits an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant.
This amendment application proposes revising Technical Specification Surveillance Requirement 3/4.5.2b.1) and its associated Bases to add clarification in regard to venting the Emergency Core Cooling System (ECCS) pump casings and accessible discharge piping high points.
The current surveillance requirement provides for verification that the ECCS piping is full of water by venting the ECCS pump casings, i.e. the Safety Injection Pumps, Residual Heat Removal Pumps and Centrifugal Charging Pumps, and accessible discharge piping high points every 31 days.
The Centrifugal Charging Pump (CCP) casings do not have installed casing vents.
Instead of an installed casing vent, the suction and discharge piping are installed as vertical runs of piping attached to the top-mounted suction and discharge nozzles of the pump.
Information provided by the pump manufacturer indicates that the vertical configuration of the piping is sufficient to prevent the accumulation of noncondensible gases that could cause gas binding.
Therefore, the CCP casings are effectively vented by vents on the discharge lines.
However, we are i
requesting this amendment to clarify the venting d A') {
-vr requirement.
We are currently meeting technical specification requirements by venting the discharge piping.
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9803180356 980309 l,lllllllllll5tBllErlllMi rllll eon aoocx 0300o4e3 p
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e subsiduary of Amoren Carperstoon L
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l U.S. Nuclear Regulatory Commission Page 2 Attachments 1, 2,
3, and 4 contain the Significant Hazards Evaluation, the Environmental Consideration, the Proposed Technical Specification Changes, and the Changes to ULNRC-3578 Attachment 20 in support of this amendment request.
This change request has been approved by the Callaway Onsite Review Committee and the Nuclear Safety Review Board.
If you have any questions concerning this matter, please contact me.
Very truly yours, lOw/
Alan C.
Passwater Manager, Licensing and Fuels JMC/
Attachments:
- 1) Significant Hazards Evaluation
- 2) Environmental Consideration
- 3) Proposed Technical Specification Changes
- 4) Change.
ULNRC-3578 Attachmnet 20
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STATE OF MISSOURI )
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Alan C. Passwater, of lawful age, being first duly l
sworn upon oath says that he is Manager, Licensing and Fuels (Nuclear) for 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.
By h
Alan C. Passwater Manager, Licensing and Fuels Nuclear
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SUBSCRIB an sworn to before me this b
day of 7
0* > ts 1998.
BARBARA EUNGWITZ g7x igwoh %c Notary Public - Notarf Seal 7
STATE OF MISSOURL City of St. Louis My Commission Expires September 2,1999 i
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cc:
M.
H.. Fletcher Professional Nuclear Consulting, Inc.
l 19041 Raines Drive L
Derwood, MD 20855-2432 l Regional Administrator U.S. Noclear 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 Barry C. Westreich (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission l' White' Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville,-MD 20852-2738
. Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 JeffersonLCity, MO 65102' Denny Buschbaum TU Electric P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent Pacific Gas-& Electric Regulatory Services P.O. Box 56 Avila Beach, CA 93424
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E210.01 J. V. Laux G. L. Randolph R.
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Irwin P. M. Barrett J. D. Blosser A. C.
Passwater D. E. Shafer W. E. Kahl S. Wideman (WCNOC)
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J. DiPerna, (Bechtel)
H. D. Bono NSRB (Patty Reynolds)
J. M. Chapman A14 0. 0001. 002 (1195) i
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ULNRC-3765
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ATTACHMENT ONE i
SIGNIFICANT HAZARDS EVALUATION I
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Page 1 of 4 l
SIGNIFICANT HAZARDS EVALUATION INTRODUCTION This amendment application proposes to revise Technical Specification (TS) 4.5.2b and associated Bases as they relate to the requirement to vent the Emergency Core Cooling System (ECCS) pump casings.
Surveillance Requirement 4.5.2b.1) would be revised to state:
"l) Verifying that the ECCS piping is full of water by venting the RHR and SI pump casings and accessible ECCS discharge piping high points, and..."
TS 4.5.2b.1) requires at least once per 31 days to verify that the ECCS piping is full of water by venting the ECCS pump casings and accessible discharge piping high points.
The proposed change to vent only the Residual Heat Removal (RHR) and Safety Injection (SI) pump casings is necessary to clarify that the Centrifugal Charging Pumps (CCPs) are not provided with a casing vent.
The CCPs have top-mounted suction and discharge nozzles which allow noncondensible gases in the pump to escape through the nozzles and are effectively vented at a location on the discharge piping.
The ECCS is designed to supply core cooling and negative reactivity to ensure the reactor is cooled and shutdown following a postulated accident.
The ECCS pumps include the high head safety injection pumps or CCPs, the intermediate 3
head safety injection pumps or SI pumps, and the low head safety injection pumps or RHR pumps.
The SI and RHR pumps are designed with installed pump casing vents.
The CCPs are an 11 stage, multi-diffuser type pump r.anufactured by j
Pacific Pumps with no installed pump casing vent.
In order to verify that the pump casing was properly vented, the discharge piping from the pump was vented using a 2 inch diameter flushing connection off of the side of the 4 inch diameter discharge piping.
Only the discharge side of the piping was vented since the suction side of the pump is vented back to the suction line of the normally running Normal Charging Pump.
The venting was done using valve BGV0357 for "A" CCP and valve BGV0358 for "B" CCP.
Based on calculations performed the top 0.8755" of the inside
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j Page 2 of 4 diameter of the horizontal discharge piping could not be vented.
This equates to a maximum void solume of (0.589 gallons) for the "A" pump horizontal discharge line and (0.531 gallons) for the "B" pump horizontal discharge line.
Although the volume discussed above could not be vented by the 2" flushing connection, using the flushing connection assured that the pump casing was not air bound or hydrogen locked.
According to Pacific Pump Drawing 300-B49739, the internal volume of the CCPs is 14 gallons.
The possible maximum void volume in the piping is less than 0.6 gallons which is insignificant (<5%) when compared to the total internal volume of the pump.
Pecause of the larger total volume of water in the discharge piping the possibility of a 0.6 gallon void producing a water hammer event is deemed insignificant.
A design modification has added a new vent on the CCPs discharge piping to facilitate the required venting.
This modification installed a vent assembly to the high point of the discharge piping above each of the discharge nozzles of the CCPs.
The vent assembly was installed on the "A" pump on 11/20/97 and on the "B" pump on 12/04/97.
Venting at these new locations ensures that the CCP casing will continue to be properly vented.
50.92 EVALUATION 4
The proposed change to the Technical Specifications does not involve a significant hazards consideration as discussed below:
1.
Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change will align the surveillance requirements with the installed system design and normal operating conditions.
The performance of surveillances required by Technical Specifications is not postulated to initiate an accident.
The intent of the surveillance ensures OPERABILITY of the ECCS by l
Verifying that the ECCS piping is full of water and not i
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Page 3 of 4 subjected to gas binding or water hammer.
The design of the CCPs is such that significant noncondensible gases do not collect in the pumps, whether they are running or_not.
Therefore, it is unnecessary to require periodic pump casing venting to ensure the CCPs will remain OPERABLE.
In addition, operating j
experience has shown that no significant voiding has occurred in the affected piping which will continue to be vented at a high point every 31 days per Surveillance Requirement 4.5.2b.1).
Therefore, no increase in the probability or consequences of an accident will occur as a result of this change.
3.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change will not result in new failure modes because there are no hardware changes nor are there any changes in the method by which any safety-related plant system performs its safety function.
The design of the CCPs is such that significant i
noncondensible gases do not collect in the pumps, whether they are running or not.
Therefore, it is not
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necessary to require periodic pump casing venting to ensure the equipment will remain OPERABLE.
Manual venting operations will be performed to minimize the potential for voids in system piping.
Accordingly, this change will not cr.eate the possibility of a new or different kind of ace.1 dent.
3.
Does this change. involve significant reduction in a margin of safety?
l The proposed change does not affect the acceptance criteria for any snalyzed event.
There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure l
the accomplishment of protective functions.
There will be no impact on any margin of safety.
l CONCLUSION l
Based upon the preceding information, it has been determined that the proposed changes to the Technical Specifications do not involve a significant increase in the probability or i
I Page 4 of 4 consequences of any accident previously evaluated, create the possib.4.lity of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Therefore, it is concluded that the proposed changes meet the requirements of 10 CFR
- 50. 92 (c) and do not involve a significant hazards consideration.
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s-ULNRC-3765 4
ATTACHMENT TWO ENVIRONMENTAL CONSIDERATION l
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Page lof 1 ENVIRONMENTAL CONSIDERATION This amendment application revises the requirements of Technical Specification Surveillance Requirement 4.5.2b and its associated Bases as they relate to the requirement to vent the Emergency Core Cooling System pump casings.
The proposed amendment involves changes with respect to the use of facility components located within the restricted area, as defined in 10 CFR 20 and revises surveillance requirements.
AmerenUE has determined that the proposed amendment does not involve:
1)
A significant hazards consideration, as discussed in of this amendment application; 2)
A significant change in the types or significant increase in the amounts c ' any ef fluents that may be released offsite; 3)
A significant increase in individual or cumulative occupational radiation exposure.
t Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9).
Pursuant to 10 CFR 51.22 (b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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