ML20248B404
| ML20248B404 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/02/1989 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20248B408 | List: |
| References | |
| ULNRC-2054, NUDOCS 8908090227 | |
| Download: ML20248B404 (8) | |
Text
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190I Gratiot Street Post Offee Box 149 St Loui.t Missoun bJ1GG l
314-554 2650 1
hrION August 2, 1989 aanald r. schnell
.p semo,v,cc n essent 6LECTRIC U. S. Nuclear Regulatory Commission Nudear Sh3 Attn:
Document Control Desk Mail Station Pl-137 Washington, DC 20555 Gentlemen:
ULNRC-2054 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/4.3.3 RADIATION MONITORING FOR PLANT OPERATION Union Electric Company herewith transmits an appli-cation for amendment to Facility Operating License No.
NPF-30 for Callaway Plant.
This amendment application revises Technical Speci-fication 3/4.3.3, Radiation Monitoring for Plant Operation.
The proposed revision would increase from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the permitted period of inoperability for one channel of the control room air intake monitors and the fuel building atmosphere monitors.
This request is similar to an amendment recently approved by the NRC for the Wolf Creek Generating Station.
Attachments 1, 2, and 3 contain the Safety Evaluation, the Significant Hazards Evaluation, and the Proposed Tech-nical Specification Changes in support of this amendment request.
The proposed changes will become effective for Union Electric implementation upon NRC approval.
Very truly yours r
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Donald F.
Schnell JMC/bjs Attachments fool 8908090227 890802 I
{DR ADOCK 05000483
/
STATE OF MISSOURI )
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Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Senior Vice President-Nuclear and an of ficer 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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l By Donald F.
Schnell Senior Vice President l
Nuclear l
SUBSCRIBED and sworn to before me this A day of 4.
, 198 9 l
/k /(-end..
E.M.DONAHUE NOTARY putu,;. STATE OF f,:is3ygg EY C0f4M!SS10N EXPir:s ; <jv. j3,19 9 ST. LOUIS COUN1y I
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1 cc:'. Gerald Charnoff, Esq.
- Shaw, Pittman, Potts & Trowbridge 2300 N.
Street, N.W.
Washington, D.C.
20037 Dr. J. O. Cermak CFA, Inc.
4 Professional Drive (Suite 110)
Gaithersburg, MD 20879 R.
C. Knop Chief, Reactor Project Branch 1 U.S.
Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S.
Nuclear Regulatory Commission RRil Steedman, Missouri 65077 Tom Alexion (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 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 Jefferson City, MO 65102 l
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Birk-J. V.
Laux M. A. Stiller i
G. L. Randolph R. J.
Irwin-H. Wuertenbaecher W.
R. Campbell A. C. Passwater R. P. Wendling D. E.'Shafer j
D. J.~ Walker I
-O. Maynard (WCNOC)
N. P. Goel (Bechtel) l T. P.
Sharkey NSRB (Sandra'Auston) 1 i
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__ __ _____, Page 1 of 3 ULNRC -20 54 S_AFETY EVALUATION This amendment request revises Technical Specification 3/4.3.3, Radiation Monitoring for Plant Operation. The proposed revision would increase from I hour to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the permitted period of inoperability for one channel of the control room air intake monitors and the fuel building atmosphere monitors.
'This request is similar to an. amendment recently approved by the Nuclear Regulatory Commission for the Wolf Creak Generating Station.
As described in the Callaway Final Safety Analysis Report (FSAR) the control room ventilation radioactivity monitors continuously nonitor the supply air of the norma heating; ventilation, and air conditioning system for particulate, fodine, and gaseous radioactivity to provide protection for the control room operators in the event of high airborne radioactivity in the control room HVAC supply duct. Upon detection of high radiation IcVels in the system the monitors automatically place the control room ventilation system in the emergency mode of operation. The Standard Technical Specifications permit the system to continue to operate in the normal mode with one operable monitor.
Technical Specification 3/4.3.3 currer.tly permits only one hour of normal operation when only 1 monitor is operable.
The fuel building ventilation exhaust radioactivity y monitors continuously monitor for particulate, iodine, and gaseous radioactivity in the fuel building ventilation exhaust system for the protection of the workers in the fuel building.
In the event of a fuel handling accident, the monitors initiate isolation of the fuel building and operation of the emergency exhaust system. The Standard Technical Specifications requires operation of the emergency exhaust system if fuel movement is to continue with one monitor inoperable.
Technical Specification 3/4.3.3 currently requires both monitors to be operable and provides only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in which to actuate the emergency exhaust system if either monitor becomes inoperable.
Anytime either of the systems is placed in its emergency mode, a pressure gradient is created across the doors to these areas. This results in two areas of concern; a personnel hazard to people who have to open and pass through these doors, and added wear and tear on these doors which may cause premature failure. Additionally, unnecessary running of the ventilation systems may cause premature wear.
Increasing the time thnt these radiation monitors can be out of service w.111 allow radiation monitor repair or service to be completed and have the monitors placed back in service without unnecessarily starting emergency ventilation equipment.
Lengthening the allowed outage time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for radiation monitors GK RE-04 or 05 and for GG RE-27 or 28, is appropriate.
GK RE-04 and 05 provide an isolation signal to the Control Room Emergency Ventilation System, when incoming outside air increases to a specified radiation 1cvel. Either monitor will send an isolation signal to both safety trains of the Control Room Emergency Ventilation System. Technical Specification 3.7.6, which concerns I
l the Control Room Emergency Ventilation System, allows one of its two safety l
trains to be out of service for seven days.
Technical Specifications l
presently require that, if either GK RE-04 or 05 becomes inoperable for more
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.. Page 2 of 3 ULNRC -2054 than one hour, the. Control Room is isolated from the outside by placing the Control Room Emergency Ventilation System in service.
If the ventilation system is left in its normal line-up after taking one radiation monitor out of servico,.the redundant radiation monitor remains OPERABLE and capable of supplying an isolation signal should radiation levels in the incoming air increase to the specified setpoint.
GG RE-27 and 28 present a similar situation. These monitors provide a Fuel Building Isolation Signal to the Fuel Building Ventilation System and start the Emergency Exhaust System. The Emergency Exhaust Systcm creates a small negative pressure in the Fuel Building, by directing all exhausting air through two sets of redundant HEPA and charcoal filters. Technical Specifications presently require that the Emergency Exhaust System be started and the normal ventilation system secured if one of these two redundant radiation monitors becomes inoperable for more than one hour.
During normal oper a t,J on, one safety train of the Emergency Exhaust System may be out of service for up to seven days. During fuel movement healt.h physics personnel are present with portable radiation monitors.
If the Fuel Building Ventilation System is left in its normal line-up after either GG RE-27 or 28 becomes inoperable, the remaining OPERABLE redundant radiation monit.or will be available to provide the required Fuel Building isolation Signal when radiation levels in the Fuel Building increase to a specified setpoint.
The proposed changes will not. affect probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety-analysis repott.
In both proposed changes, when a radiation monitor is allowed to be taken out. of service, redundant OPERABLE radiation monitors are still in service. The monitors that remain in service, provide the same signal to the same equipment and at the same setpoint as the monitor that is removed from service. The additional allowed outage time associated with this change is insignificant when compared to the probability of an event which requires actuation, coincident with a failure of the remaining operable detector.
In addition this change will reduce the use of the emergency mode of system operation for both the control room ventilation system and the fuel building emergency exhaust, system, thus increasing the probability of them serving their intended purpose in an emergency.
The proposed change would not create the possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report. This proposed change does not involve changing any setpoints or involve changing how existing equipment is operated. These changes reduce the burden on the control room staf f, by allowing suf ficient time for mon.itor repair without unnecessarily actuating the emergency ventilation systems.
The proposed changes will not affect the margin of safety as defined in the basis for any technical specification. The proposed changes do not alter the manner in which safety limits and limiting safety system setpoints are f
determined. Redundant monitors remain OPERABLE during the extended allowed outage time and under the revit,ed minimum OPERABhE channels requirements.
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ULNRC -2054 Based on the above discussions and the considerations presented in Attachment
'2, the proposed revisions to Technical Specifications 3/4.3.3 do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report; or create a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report; or reduce the margin of safety as defined in the basis for any technical specificataan.
Therefore, the proposed revisions do not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.
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., page 1 of 1 UhNRC - 2054 1
SIGNIFICANT HAZARDS CONSII) ERAT 10N This amendment request revises Technical Specification 3/4.3.3, Radiation Monitoring.for Plant Operation. The proposed revision would increase from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the permitted period of inoperability for one channel of both the control room air intake monitors and the fuel building atmcaphere monitors.
1.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Increasing the-allowed outage time associated with an inoperable monitor is acceptable, since the safety function of the monitors remain unaffected. 1he proposed change does not affect the ability of the monitors to perform their intended safety function, it will however reduce the use of the emergency mode of system operation for 3
both the control room ventilation system and the fuel buildin;-
emergency exhaust system thus increasing the probability of t'em serving their intended purpose in an emergency.
2.
The proposed change does not create the possibility of a new or different kind of accident from any previonsly evaluated. There are i
no new failure modes or mechanisms associated with the proposed change. This change does not involve any modification in the operational limits or physical design of the involved systems. The change merely allows an extended time period for the diagnosis and repair rf radiation monitoring systems, thus reducing the excessive use of the emergency exhaust systems for the control room and fuel building.
3.
The proposed change does not involve a significant reduction in a margin of safety. This change does not affect any technical specification margk of safety.
This change allows appropriate ACTIONS commensurate with the significance of the monitor i
l-malfunction, provided the malfunction does not affect the capability of the monitors to perform t. heir safety function.
Based on the above discussions and those presented in Attachment 1, it has l
been determined that the requested Technical Specification revisions do not involve a significant increase in the probability or consequences of an accident or other adverse condition over previous evaluations; or create the possibility of a new or dif ferent. kind of accident or condition over previous evaluations; or involve _ a signi ficant. reduction in a margin of safety.
Ther9 fore, the requested license amendment. does not involve a significant hazards consideration.
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