ML20236D169

Responds to Re Replacement of Fuel Rods W/Filler Rods & Vantage-5 Fuel for Cycle 3 Operation at Facility.Encl Safety Evaluation Discusses Safety Considerations That Were Evaluated Before Approving Util Application

ML20236D169
Person / Time
Site:	Callaway
Issue date:	10/21/1987
From:	Alexion T Office of Nuclear Reactor Regulation
To:	Drey K AFFILIATION NOT ASSIGNED
References
NUDOCS 8710280053
Download: ML20236D169 (3)

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UNITED STATES NUCLEAR REGULATORY COMMISSION a

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'(..v October 21, 1987 Mrs. Kay Drey 515 West Point Avenue University City, Missouri 63130

Dear Mrs. Drey,

Your letter of June 9,1987 to the Public Affairs Officer, NRC Region III, was referred to n an September 24, 1987, for response.

Please accept my apologies for the delay in responding to your letter. The following expla-

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nations are offered to help resolve your concerns.

I Item 1, regarding replacement of fuel rods with filler rods or vacancies,

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was a) proved by the NRC staff in Amendment No. 24 to the operating license for tie Callaway Plant (see Enclosure 1). The safety evaluation, provided i

as an enclosure to the amendment, discusses the safety considerations, in not-too-technical terms, that were evaluated before approving the application.

Electric (UE)gh 6 of your letter concern the applications from Unionto switch to Vanta Items 2 throu and to operate the Callaway Plant at the higher power level of 3565 mega-l watts thermal. The staff currently has these issues under review. Upon completion of the reviews, the staff will issue safety evaluations either approving or disapproving the applications.

If the staff's evaluation approves the application and it involves changes to the license or tech-i

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nical specifications (which are part of the license), then a license amendment is issued.

In either case, you will receive a copy of the staff's correspondence since you are on our mailing list.

If you find that parts of the safety evaluations are too technical to understand, the staff can try to elaborate on any specific questions you may have.

Incidently, regarding Item 3 of your letter, the staff evaluated the spent fuel pool considerations of changing to the V-5 fuel in Amendment No. 23 (see Enclosure 2). However as discussed above, the staff's evaluation regarding Cycle 3 operation with V-5 fuel has not been completed.

Regarding the number of requests from (UE) to change the technical specifications, the staff does allow a certain amount of flexibility in the operation of the plant, as long as the changes are supported with the appro-priate safety analysis. The replacement of fuel rods with filler rods and the transition from LOPAR to 0FA fuel assemblies are good examples.

In some cases, the staff has identified where certain technical specifications can be improved, and UE has rrsponded to the staff's suggestions.

In other cases, UE has identified improvements to the technical specifications as they become more familiar with the operation of their plant.

Regarding your final comment, an example of staff denial to UE is provided in Enclosure 3.

However, denials are not common because most utilities have a fairly good understanding of what kinds of applications will be 8710200053 871021 ADOCK0500g3 DR i

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Mrs. Xcy Drey !

approved and which ones will-not be approved. This is due to their l

knowledge of what types and details of information were needed to get i

their license. Also, utilities review technical specification changes I

approved by the staff on other plants for appliceH lity to their plants.

1 I would like to note that'the starf review of the V-5 refueling applica-tion may be completed before this letter is issued. Also, when reading the safety evaluations, you will find that the safety significance of the change is always discussed, but the reason for the change is usually not i

discussed if the reason is for operational flexibility or economic consider-l ations.

I trust that you will find these responses to be helpful.

Sincerely,

/d Thomas W. Alexion, Project Manager Project Directorate III-3 Division of Reactor Projects

Enclosure:

As stated I

Distribution:

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NRC & Local PDRs PD111-3 r/f G. Holahan D. Wigginton P. Kreutzer T. Alexion R-III, PA Officer Office:

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Surname: ~PKreutzer Tale 'en,' 1 DWigginton ola an Date:

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ENCLOSURE 1

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June 8, 1987 Docket No. 50-483 Mr. Donald F. Schnell Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166

Dear Mr. Schnell:

The Comission has issued the enclosed Amendment No.24 to Facility Operating License Mo. NPF-30 for the Callaway Plant, Unit 1.

This amendment is in response to your application dated March 27, 1987.

The amendment modifies section 5.3.1 of the Technical Specifications to allow for limited replacement of fuel rods with filler rods or vacancies if supported by a cycle-specific ceload analysis.

A copy of the Safety Evaluation is also enclosed. The-notice of issuance will be included in the Comission's next biweekly Federal Register notice.

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Sincerely,

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Thomas W. Alexion, Pro ect Manager Project Directorate III-3 Division of Reactor Projects

Enclosures:

1.

Amendment No. 24 to License No. NPF-30 l.

2.

Safety Evaluation cc w/ enclosures:

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AMENDMENT TO FACILITY OPERATING LICENSE

' Amendment No. 24 License No. NPF-30 1.

The Nuclear Regulatory Comission (the Comission) has found that:

~A.-

The application for amendment filed by Union Electric Company (the licensee) dated _ March 27, 1987, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act),

and the Comission's rules and regulations set forth in 10 CFR Chapter I;'

.B.

' The facility will operate in confomity with the application, the provisions of the Act,.and the rules and regulations of the Commission; C.

Thereisreasonableassurance(i)thattheactivitiesauthorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations; D.-

The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have j.

been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-30 is hereby amended to read as follows:

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(2) - Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as' revised through Amendment No.24, and the Environmental Protection Plan-~

contained in Appendix B, both of which are attached hereto, are hereby incorporated into the license.

UE shall operate the facility 1

in accordance with the Technical Specifications and the Environmental Protection Plan.

3.. This license amendment is effective as of the date of. its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 3

i David L.

igginton, Acting Project Director Project Directorate III-3

~ Division of Reactor Projects

Attachment:

Changes to the Technical Specifications Date of Issuance: June 8, 1987 1

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ATTACHMENT TO LICENSE AMENDMENT NO. 24 l

OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483-Revise ppendix A Technical Specifications by removing lthe page. identified i

- below and inserting the enclosed page. The revised page'is identified by

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-' the captioned amendment' number and contains marginal lines indicating the area

.of. change. The corresponding overleaf page is. included to maintain' document i

- completeness.

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DESIGN FEATURES 5.3 REACTOR CORE FUEL ASSEMBLIES 5.3.1 The core shall contain 193 fuel assemblies with each fuel assembly normally containing 264 fuel rods clad with Zircaloy-4 except that limited substitution of fuel rods by filler rods consisting of Zircaloy-4 or stainless steel or by vacancies may be made if justified by a cycle-specific reload analysis.

Each fuel rod shall have a nominal active fuel length of 144 inches and contain a maximum total weight of 1766 grams uranium.

Reload fuel shall be similar in physical design to the initial core loading and shall have a maximum enrichment of 4.25 weight percent U-235.

CONTROL ROD ASSEMBLIES 5.3.2 The core shall contain 53 full-length and no part-length control rod assemblies.

The full-length control rod assemblies shall contain a nominal 142 inches of absorber material. All control rods shall be hafnium, clad with stainless steel tubing.

5.4 REACTOR C00LAMT SYSTEM DESIGN PRESSURE AND TEMPERATURE 5.4.1 The Reactor Coolant System is designed and shall be maintained:

a.

In accordance with the Code requirements specified in Section 5.2 of the FSAR, with allowance for normal degradation pursuant to the applicable Surveillance Requirements.

b.

For a pressure of 2485 nsig, and c.

For a temperature of 650*F. except for the pressurizer which is 680*F.

VOLUME 5.4.2 The total volume of the Reactor Coolant System, including pressurizer and surge line, is 12,135 1 100 cubic feet at a nominal T,yg of 557'F.

5.5 METEOROLOGICAL TOWER LOCATION 5.5.1 The meteorological tower shall be located as shown on Figure 5.1-1.

CALLAWAY - UNIT 1 5-6 Amendment No. J2, 23. 24

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SAFETY EVALUATION'BY THE OFFICE OF NUCLEAR REACTOP REGULATION RELATED-TO AMENDMENT NO. 24 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY. PLANT, UNIT 1 DOCKET NO. STN 50-483

1.0 INTRODUCTION

By letter dated March.27,1987, Union Electric Company (the licensee) requested changes. to. Facility Operating License No. NPF-30 for the Callaway Plant. The proposed changes are to Technical Specification i

5.3.1, Design Features-Fuel Assemblies.. The first sentence of Technical.

Specification 5.3.1 currently states, "The core shall contain 193 fuel assemblies. with each fuel assembly containing 264 fuel rods clad with Zircaloy-4." The proposed revision would remove the period at the end of this sentence and add ".. except that limited substitution of fuel rods by filler rods consisting of Zircaloy-4. or stainless steel, or by vacancies may be made if justified by a cycle-specific reload analysis."

2.0 EVALUATION The. intent of the proposed change to the Callaway Technical Specifications is to allow for the reduction in the number of fuel rods per assembly in i

cases where leaking fuel rods. can be identified and replaced with Zircaloy-4 or stainless steel rods or vacancies. Replacement of leaking fuel rods with other fuel rods involves handling of additional fuel assemblies and i

has not been used in Westinghouse reactors 'to date.

Replacement of leaking l

. fuel rods will permit utilization of the energy remaining in fuel assemblies I

containing defective fuel rods.

In general,. substitution of a limited number of' fuel rods with filler 1

rods or water holer has a negligible effect on core physics parameter

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and consequently on the safety analysis. The licensee states that in j

each reload core the reconstituted assemblies will be evaluated using standard reload analysis methods. The reload analysis will ensure that the safety criteria and design limits, including peaking factors and core averaga linear heat rate effects, are not exceeded. Thes,the final safety evaluation of implementation of substitutions allowed by this change will be made as part of the reload analysis performed for the affected cycle.

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2-The. staff had-earlier approved a similar request for.a change to 1

Technical? Specification'5.3.1 with slightly diffe' rent wording than j

proposed by the' licensee which the staff prefers and wishes to I

standardize

.This wording'is,."The reactor core shall contain U 3 fuel 1

assemblies'with each fuel. assembly normally containing 264 fuel rolu clad withLZircaloy-4,:except that limited' substitution of fuel rods by filler

. rods" consisting of Zircaloy-4 or stainless steel or by vacancies may be j

made if justified by a cycle-specific reload analysis." This wording.was j

. discussed ~with the Union Electric staff and they orally agreed.on April 3, 71987.

With this modification,.which only inserts.the word "normally" into..the wording proposed by the licensee, the staff finds the proposed change-acceptable.

'Because the limited substitution of Zircaloy-4 or stainless steel rods or vacancies for fuel rods is'not expected to have a significant impact on plant safety, and.because a cycle-specific evaluation will be performed

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to; justify any.such substitutions, the staff finds the proposed. Technical i

Specification change for Callaway, with the modification as discussed j

above, acceptable.-

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change to a requirement with respect to the insta11atirm or'use of a facility component located within the 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 Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.

Accordingly, this. amendment meets the eligibility criterie for cate-gorical 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.

4.0. CONCLUSION The staff har 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 Commission'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:

ft. Dunenfeld, SRXE l

T. Alexion, PDIII-3 Dated: June 8, 1987 C^~~.: ~:..? " -

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May 22, 1987 Docket No. 50-483 Mr. Donald F. Schnell Vice President - Nuclear Union Electric Company Post' Office Box 149 St. Louis, Missouri 63166

Dear Mr. Schnell:

The Comission has issued the enclosed Amendment No. 23 to Facility Operatino License No. NPF-30 for the Callaway Plant, Unit 1.

This amendment is in response to your application dated December 19, 1986.

The amendment revises Technical Specification Figure 3.9-1 with correct curves for Westinghouse optimized fuel (0FA) and standard fuel (SFA).

Figure 3.9-1

.now also incorporates a curve for Westinghouse Ventage Fuel (V5) which~

overlays the OFA curve. TS sections 5.3.1 and 5.6.1.1 are also revised to reflect a maximum enrichment of 4.25 w/o U-235 for fuel storage.

A copy of the Safety Evaluation is also enclosed. The notice of issuance will be included in the Comission's next biweekly Federal Register notice.

Sincerely, MaM Thomas W. Alexion, roject Manager Project Directorate III-3 Division of Reactor Projects

Enclosures:

1.

Amendment No. 23 to License No. NPF-30 2.

Safety Evaluation cc w/ enclosures:

See next page s

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CALLAWAY PLANT, UNIT 1 DOCKET NO.'STN 50-483 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.23 License No. NPF-30 1.

The Nuclear Regulatory Comission (the Comission) has found that:

A.

The application for amendment filed by Union Electric Company (the licensee) dated Decemt er 19, 1986 complies with the standards and requirementsoftheAtomicEner'gyAct.of1954,asamended(theAct),

1 ana the Comission's rules and regulations set forth in 10 CFR 1

Chapter I; B.

The facility will ortrate in conformity with the application, the provisions of the Act, and the rules and regulations of the Comission; C.

Thereisreasonableassurance~(i)thattheactivitiesauthorized by this amendment can be conh eted without endangering the health and safety of the public, and-(ii) that such activities will be conducted in compliance with the Comission's regulations; D.

The issuance of this amendment will not be inimical to the comon

~ defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Comission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment,andparagraph2.C.(2)ofFacilityOperatingLicense No, NPF-30 is hereby amended to read as follows:

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' '(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised-through_ Amendment No. 23, and the Environmental Protection Plan

' contained in Appendix B both of which are attached hereto, are hereby incorporated into the license. UE shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

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David L. Wigg nton, Acting Project Director Project Directorate III-3 Division of Reactor Projects

Attachment:

Changes to the Technical Specifications Date of Issuance: May 22, 1987 h-_____

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' ATTACHMENT TO LICENSE AMENDMENT NO.23 l'

OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483 I

Revise Appendix A Technical Specifications by removing the pages identified below and inserting the enclosed pages. The revised pages are identified by

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.the captioned amendment number and.contain marginal lines. indicating the area of change.. The corresponding ~ overleaf'pages are included to maintain document completeness.

REMOVE INSERT 3/4 9 3/4 9-16 5-6 5-6 5-7 5-7 p

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REFUELING OPERATIONS 3/4.'9.12 SPENT FUEL ASSEMBLY STORAGE

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LIMITING CONDITION FOR OPERATION 3.9.12. Spent fuel assemblies stored in Region.2 shall be' subject to the following conditions:

a.

The combination of initial enrichment and cumulative exposure shall be v: thin the acceptable domain of Figure 3.9-1, and-b..

No spent fuel assemblies shall be placed in Region 2, nor shall any storage location be changed in designation from being in Region 1 to j

being in Region 2. While refueling operations are in progress.

APPLICABILITY: Whenever irradiated fuel assemblies are in the spent fuel pool.

ACTION:

a.

With the requirements of the above specification not satisfied, suspend all other movement of fuel assemblies and crane operations with loads in the fuel storage areas and move the non-complying fuel assemblies to Region 1.

Until these requirements of the above.

specification are satisfied, boron concentration of the spent fuel pool shall be verified to be greater than or equal to 2000 ppm at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.12 The burnup of each spent fuel assembly stored in Region 2 shall be ascertained by analysis of its burnup history and independently verified, prior to storage in Region 2.

A complete record of such analysis shall be kept for the time period that the spent fuel assembly remains in Region 2 of the spent

-fuel pool.

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1.6 2.0 8.0 4.0 FUEL ASSEMBLY INITIAL ENRICHMENT, W/O U-235 FIGURE 3.9-1 MINIMUM REQUIRED FUEL ASSEMBLY BURNUP AS A FUNCTION OF INITIAL ENRICHMENT TO PERMIT STORAGE IN REGION 2 i

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'5.3 REACTOR CORE FUEL ASSEMBLIES-5.3.1 The core shall contain 193 fuci as:cmblics with each fuel assembly containing 264 fuel rods clad with Zircaloy-4.

Etch fuel rod shall have a nominal active fuel length of 144 inches and contain a maximum total weight of 1766 crams uranium. The! initial core loading shall have a maximum enrichment of 3.10 weight percent U-235.

Reload fuel shall be similar in physical. design to the initial core loading and shall have a maximum enrichment of 4.25 weight' l

percent:U-235.

CONTROL R0D ASSEMBLIES 5.3.2 The core shall contain 53 full-length and no part-length control rod assemblies. The full-length control rod assemblies shall contain a nominal

.142-inches of absorber material. All control rods shall be hafnium, clad with stainless steel. tubing.-

5.4 REACTOR C00LAliT SYSTEM DESIGN PRESSURE AND TEMPERATURE 5.4.1 The Reactor Coolant System is designed and shall be maintained:

a.

In accordance with the Code requirements specified in Section 5.2 of the FSAR, with allowance for normal degradation pursuant to the applicable Surveillance Requirements, b.

For a pressure of 2485 psig, and

'For a temperature of 650 F, except for the pressurizer which is c.

680*F.

VOLUME' 5.4.2 The total volume of the Reactor Coolant System, including pressurizer and surge line, is 12,135 1 100 cubic feet at a nominal T,yg of 557*F.

i 5.5 METEOROLOGICAL TOWER LOCATION 5.5.1 The meteorological tower shall be located as shown on Figure 5.1-1.

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5. 6 FUEL STORAGE CRITICALITY-L 5.6.1.1 The spent fuel. storage racks are designed and shall be maintained with:

l A k,ff equivalent to less than or equal to 0.95 when flooded with

.a.

unborated water, which' includes a conservative allowance of 2.6%

l Ak/k for uncertainties as described in Section 4.3 of the FSAR.

This is based on new fuel with an enrichment of 4.25 weight percent l

U-235 in Region 1 and on spent fuel with combination of initial i

enrichment and. discharge exposures, shown in Figure 3.9-1, in-Region 2,.and b.

A nominal 9.24 inch center-to-center distance between fuel assemblies l

placed in the storage racks.

5.6.1.2 The k f r new fuel for the first core loading stored dry in the l

eff spent fuel storage racks shall not exceed 0.98 when aqueous foam moderation is-assumed.

DRAINAGE 5.6.2 The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the. pool below elevatien 2040 feet.

CAPACITY 5.6.3 The spent fuel storage pool is designed and shall be maintained with a j

storage capacity limited to no more than 1344 fuel assemblies.

5.7 COMP 0NENT CYCLIC OR TRANSIENT LIMIT 5.7.1 The components identified in Table 5.7-1 are designed and shall be maintained within the cyclic or transient limits of Table 5.7-1.

CALLAWAY - UNIT 1 5-7 Amendment No.12, 23

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.23 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY l

CALLAWAY PLANT, UNIT 1 DOCKET NO. STN 50-483

1.0 INTRODUCTION

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By letter dated December 19, 1986, Union Electric Company submitted a request for changes to the Technical Specifications (TS) to revise Figure 3.9-1, regarding required burnup as a function of initial enrichment for l

Region 2 of the spent fuel pool, with correct curves for Westinghouse optimized fuel (OFA) and standard fuel (SFA). The letter also requested that Figure 3.9-1 incorporate a curve for We:tinghouse Vantage Fuel (V5) which overlays the OFA curve with an extension to 4.25 w/o U-235. Finally, the letter requested that TS sections 5.3.1 and 5.6.1.1 be revised to reflect a maximum enrichment of 4.25 w/o U-235 for fuel storage.

2.0 DISCUSSION Callaway's first reload core (Cycle 2) contains both SFA and 0FA. The next reload core (Cycle 3) will introduce the V5 option as a mix with the SFA and 0FA designs. Use of the V5 design requires increasing the maximum enrichment limit for stored fuel from 4.2 w/o to 4.25 w/o.

Supplemental criticality analyses were performed to support storage of 4.25 w/o fuel, and additional assessments were made to determine the impact of using the VS option on spent fuel pool design criteria.

In the course of performing supplemental calculations to verify criticality limits for V5 fuel storage, discrepancies were identified between the current work and that provided in 1985. The discrepancies were reviewed and the source of errors was identified. The errors rendered incorrect both the SFA and 0FA curves currently presented in Figure 3.9-1 of the Callaway TS.

The discrepancy in the OFA curve was traced to the use of an incorrect multiplier on the fission product absorption cross section.

Further investigation showed that the original (FSAR) analysis had been correctly done. The error produces non-conservative values for the burnup required for storage in Region 2 of the spent fuel pool. The error was of the order of 2000 mwd /MT in burnup for the OFA fuel.

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. The discrepancy in the SFA curve was traced to an incorrect transcription of data from.the original SFA' calculated curves. _This transcription error resulted in a similar non-conservative error for the SFA as the OFA.

At the' time of the discovery of the error there was no fuel stored in

'RegionL2 (RegionL2 is designed to safely store irradiated fuel assemblies in large numbers). The error did not impact the analyses.for Region 1 (Region.1Lis designed to safely store a number of fresh unirradiated fuel assembliesanda' full'coreunloadingifthatshouldprovenecessary). Of.

the spent fuel. stored in Region-1, only four assemblies'oualify for. storage

'in Region 2 if the' incorrect.burnup versus initial enrichment curve is used. Each of these assemblies would also qualify for storage if the correct curve were used. Thus, no violation of the design bases of the racks resulted from the error.

3.0 EVALUATION The licensee, in the December 19, 1986 submittal,' presented ~evised r

l curves for the standard and 0FA fuel assemblies for enrichments up to 4.20 weight percent U-235. Also presented were. analyses to support the,

storage of V5 and 0FA fuel having enrichments up to 4.25 weight percent U-235..The analyses'show that the same curve of required burnup as a function of initial enrichment may be used for both the V5'and 0FA assemblies.

The same methodology that was used to perform the FSAR Spent Fuel Pool Jb analysis was used to obtain the TS curves. Acceptable methods that have I

been verified against experiments were approved by the NRC staff for use

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in the FSAR analysis and continue to be acceptable for the present

analyses, q

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Analyses were performed for Region 1 to confirm that storage of fuel having an enrichment up to 4.25 weight percent U-235 results in a k-effective value, including uncertainties, of less than our acceptance criterion of 0.95 for this quantity. The revised curves of required j'i burnup as a function of initial' enrichment were extended to an enrichment

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of 4.25 weight percent U-235 using the previously approved methods.

Particular attention was paid to quality assurance during the analysis.

We conclude that the revised curves are acceptable.

The changes to the TS include replacement of Figure 3.9-1 with the revised curve and changing the maximum enrichment value in Specifications 1

5.3.1 and 5.6.1.1 to 4.25 weight percent U-235. These revisions are consistent with the safety analyses provided and are, therefore, acceptable.

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4.0 ENVIRONMENTAL C0FSIDERATION This amendment involves a change to a requirement with respect to the installation or.use of a facility component located within the 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 L

radiation exposure..The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and' there has been no public comment on such finding.c Accordingly, this amendment t

meets the eligibility. criteria for categorical exclusion set forth in'10 t

CFR51.22(c)(9).'Pursuantto10.CFR51.22(b),noenvironmentalimpact i

statement or environmental assessment need be prepared in connection with' the. issuance of this amendment..

5.0 CONCLUSION

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.The staff has. concluded, based'en 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; 1

and (2) such activities will be conducted in compliance with the Commission's regulations'and the issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public.

Principal Contributors:' W. Brooks, SRXB T. Alexion, PDIII-3 Dated:

May 22,~1987 1

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t ENCLOSURE 3 t

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• 4 ro UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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WASHINGTON, D. C. 20$$5 e

July 23, 1986

' Docket No.:

50-483.

Mr.-Donald F. Schnell Vice President - Nuclear i

L Union Electric Company Post Office Box.149 St. Louis Missouri 63166

SUBJECT:

PROPOSED REVISION TO TECHNICAL SPECIFICATION 4.6.1.2 REGARDING

- CONTAINMENT LEAKAGE SURVEILLANCE REQUIREMENTS FOR VALVES PRESSUR

'WITH FLUID FROM SEAL SYSTEM

-i The NRC staff has completed its review of your-requests dated July 17, 1984'-

and October 3,1984, for a revision to Technical Specification 4.6.1.2 regarding,

containment leakage surveillance requirements for valves pressurized with fluid from a seal system.- Specifically the proposed change would permit local leak rate testing of certain containment isolation valves using water, in lieu of air as required by Appendix J to 10 CFR 50.

Based upon its review the staff has concluded that the proposed passive seal system could not perfonn the needed function of a seal system as called for by Appendix J.

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' Accordingly, we find the proposed technical specification change unacceptable.

5.

Our detailed Safety Evaluation is contained in Enclosure 1.

' Sincerely, cuA.k.,0.

np Paul W. O'Connor, Project Manager PWR. Project Directorate #4 Division of PWR Licensing-A

Enclosure:

As stated I

cc:

See next page J

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l Engineering Branch Division of PWR Licensing-A Safety Evaluation Report for Callaway Plant. Unit 1 Docket No. 50-483 A.

Introduction By a lette" dated July 17, 1984, Union Electric Company requested in part that the bases of Callaway Technical Specifications 4.6.1.2 and 3/4.6.1.2 be revised to allow local leak rate testing of certain l

containment isolation valves using water as test medium, in lieu of air l

as required by Appendix J to 10 CFR 50.

The affected containment isolation valves and penetrations are associated with the essentici service water,

l system (ESWS)toandfromcontainmentaircoolers.

The licensee's basis l

for the request is that the piping volume of the ESWS will form a passive seal water system. The passive seal water system will then keep the concerned containment isolation valves water sealed following accidencs so that there is little potential for contaminated air to leak out through these penetrations. A previous staff review indicated that although the proposed concept of a passive seal system had sone merits, the water inventory of the proposed seal system could not be clearly defined and the amount of seal water available following certain accident scenarios could not be assured.

In responding to the staff review, the' licensee t-submitted additional infonnation in a letter dated October 3,1984, p

on its proposed passive seal water system.

The staff's evaluation of the additional infonnation is provided below.

B.. Evaluation Section III.C.2 of Appendix J requires that containment isolation valves be Type C tested using air or nitrogen at a pressure of Pa with 3

one exception. The exception is that tests for valves sealed with fluid

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from a seal system may be conducted with that fluid at a pressure not less than 1.1 Pa. The function of a seal system is to provide sufficient fluid to the affected penetrations and valves to prevent contaminated air g

.from leaking out the containment.

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The licensee requests that the containment isolation valves EF-HV-33,-34, -45, and -46 be tested with water, in lieu of air, because a passive seal water system may be defined to provide sealing water to these valves. As indicated by the system design, the primary function of.these containment isolation valves is to stay open following accidents and to provide cooling water.to containment air coolers. These valves will only be called upon to perform their function of containment isolation, when the containment air coolers are required to be shut down due to failures or similar reasons.

The valves will then be closed by operators via remote manual control.

Icllowing the closure of these valves, the piping volume from the air coolers to the containment isolation valves may still be filled with water, which is counted.on by the licensee to provide the sealing function for these affected valves.

In a previous review, the staff felt that the concept of a passive seal I

water system might be found acceptable if the amount of sealing water from the piping volume could be defined and a,ssured. However, a close i

review of the events and scenarios of LOCAs indicates that one would not know for sure at what point these valves would be closed following the t

shut down or failure of the ESWS. Therefore, one would not know for sure how much water still remained in the piping volume after the valves were completely closed.

Even though we agree that the piping volume is large enough to hold the required amount of sealing water, the problem is that there is no way to verify and assure that an adequate amount of' sealing water will remain in the piping volume following certain accidents.

Since the water inventory of the proposed passive seal water system could not be assured and could not be monitored and replenished following accidents,

'we find that the proposed passive seal system could not perform the needed function of a seal system as called for by Appendix J.

C.

Conclusion 4

Based on the above discussion, we find the proposed T.S. Change to allow water testing of certain containment isolation valves unacceptable because these valves could not be assured to be water sealed as required 1

by Appendix J.

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