ULNRC-04969, Supporting Information and Follow-Up Request Regarding License Amendment Request OL-1228 for Revision to Technical Specifications 3.8.1, AC Sources - Operating, and 3.8.4, DC Sources - Operating.

Supporting Information and Follow-Up Request Regarding License Amendment Request OL-1228 for Revision to Technical Specifications 3.8.1, AC Sources - Operating, and 3.8.4, DC Sources - Operating.

ML041170353
Person / Time
Site:	Callaway
Issue date:	04/14/2004
From:	Keith Young AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-04969
Download: ML041170353 (8)

Text

AmerenUE PO Box 620 Callaway Plant Fulton, MIO 65251 April 14, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen: ULNRC-04969 wAmeren DOCKET NUMBER 50-483 UE CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

SUPPORTING INFORMATION AND FOLLOW-UP REQUEST REGARDING LICENSE AMENDMENT REQUEST OL-1228 FOR REVISION TO TECHNICAL SPECIFICATIONS 3.8.1, "AC SOURCES - OPERATING," AND 3.8.4, "DC SOURCES - OPERATING"

Reference:

I) AmerenUE Letter ULNRC-04837, "License Amendment Request OL-1228 - Revision to Technical Specification Surveillance Requirements 3.8.1 and 3.8.4," from D. Shafer (AmerenUE) to USNRC, dated June 6, 2003

2) USNRC Letter, "Request for Additional Information re: Technical Specifications 3.8.1 and 3.8.4 for Callaway, Diablo Canyon, Palo Verde, and Wolf Creek Plants," from J. Donohew (USNRC) to G. Randolph, AmerenUE; G. Rueger, Pacific Gas and Electric; G.

Overbeck, Arizona Public Service Company, and R. Muench, Wolf Creek Nuclear Operating Corporation; dated September 25, 2003.

3) AmerenUE Letter ULNRC-04909, "Response to Request for Additional Information Regarding License Amendment Request OL-1228 (Revision to Technical Specification Surveillance Requirements 3.8.1 and 3.8.4)," from K. Young (AmerenUE) to USNRC, dated December 19, 2003 Per Reference 1, Union Electric Company (AmerenUE) transmitted an application for amendment of Facility Operating License No. NPF-30 for the Callaway Plant. In that request AmerenUE proposed changes to Technical Specifications (TS) 3.8.1, "AC Sources - Operating," and TS 3.8.4, "DC Sources -

\oO a subsidiary ofAmeren Corporation

ULNRC-04969 April 14, 2004 Page 2 Operating," to allow surveillance testing of the emergency diesel generators (DGs) during MODES in which it is currently prohibited and to incorporate changes based on Industry/Technical Specification Task Force (TSTF) Standard Technical Specification change TSTF-283, Revision 3.

AmerenUE's application for amendment, along with similar applications from Wolf Creek Nuclear Operating Corporation, Arizona Public Service Company, and Pacific Gas and Electric Company, is currently under review by the NRC staff. Per Reference 2, the NRC transmitted a request for additional information regarding the proposed TS Changes, to which AmerenUE responded via Reference 3.

Subsequently, on February 4, 2004, two additional questions related to DG testing in MODES I and 2 with the DG connected to the offsite power supply were provided by electronic mail from the NRC Project Manager. Responses to those questions were provided electronically on February 24, 2004, wherein it was identified that the information requested was previously provided by References 1 and 3. Through further discussions with the NRC Project Manager it was requested by the NRC Electrical Engineering Section that Ameren UE provide, in the Bases of the Callaway Technical Specifications, administrative controls for DG testing in MODES I and 2 with the DG connected to the offsite power supply.

Based on these discussions, AmerenUE is providing in the Enclosure additional changes to the TS Bases for Surveillance Requirement (SR) 3.8.1.14 (i.e.,

the 24-hour DG endurance run) to include the requested administrative controls. The enclosed additional TS Bases changes are provided (for information only) to assist the staff in its review of the proposed changes. (The enclosed marked-up TS Bases page reflects the NRC-requested changes as well as those originally indicated in Reference I for the affected page.) As noted in Reference 1, revision of the TS Bases will be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of the license amendment.

Specifically, the information to be added to the TS Bases will state:

Administrative controls for performing this Surveillance in MODES 1 or 2 with the DG connected to an offsite circuit ensure or require that:

a. Weather conditions are conducive for performing the Surveillance.

b. The offsite power supply and switchyard conditions are conducive for performing the Surveillance, which includes ensuring that switchyard access is restricted and no elective maintenance within the switchyard is performed.

c. No equipment or systems assumed to be available for supporting the performance of the Surveillance are removed from service.

ULNRC-04969 April 14, 2004 Page 3 In its license amendment application (Reference 1), AmerenUE proposed changes to the mode-restriction Notes associated with the applicable SRs under TS 3.8.1, as well as the applicable SRs under TS 3.8.4, i.e., SR 3.8.4.7 and SR 3.8.4.8.

The proposed changes to the Notes provide the flexibility for a partial performance of the surveillance during plant operation to reestablish OPERABILITY following corrective maintenance. Although application of the proposed changes in the Notes to SR 3.8.4.7 and SR 3.8.4.8 (in addition to the SRs of TS 3.8.1) is consistent with NRC-approved TSTF-283, NRC reviewers of AmerenUE's amendment application expressed some concerns regarding the changes proposed for SR 3.8.4.7 and SR 3.8.4.8. As a result, in Reference 3, AmerenUE indicated that the changes to those SRs should be processed separately (from the TS 3.8.1 SRs) based on the potentially additional time to resolve the concerns both generically and for AmerenUE. After further consideration, AmerenUE has decided to withdraw the proposed changes to SR 3.8.4.7 and SR 3.8.4.8. AmerenUE will consider pursuing additional changes depending on the generic resolution of the concerns associated with the changes to those SRs.

It should be noted that the supplemental information and changes provided by this letter do not impact the conclusions of the No Significant Hazards Consideration provided in Reference 1. In addition, there are no commitments associated with this submittal.

Please contact me or Dave Shafer at (314) 554-3104 for any questions you may have regarding this application.

Very truly yours, Keith D. Young Manager, Regulatory Affairs TBE/mlo Enclosure

ULNRC-04969 April 14, 2004 Page 4 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360

STATE OF MISSOURI )

) SS COUNTY OF CALLAWAY)

Keith D. Young, of lawful age, being first duly sworn upon oath says that he is Manager, Regulatory Affairs, 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 4 W40" K D.Y g Manager, Regulatory Affairs SUBSCRIBED and sworn to before me this JŽ day of f)A2 j '2004.

TERRA E. COOK Notary Public - Notary Seal STATE OF MISSOURI Callaway County My Commission Expires May 13, 2006

ULNRC-04969 April 14, 2004 Enclosure

AC Sources - Operating B 3.8.1 BASES SURVEILLA!' ICE SR 3.8.1.14 REQUIREME !NTS (continued) Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

If the auto-connected design loads have increased above the continuous duty rating the load shall be increased to 110% of the continuous duty rating for 2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2. and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

In order to ensure that the DG is tested under load conditions thatare as close to design conditions as possible, testing must be performed using a power factor of 2 0.8 and < 0.9. This power factor is chosen to be representative of the actual design basis inductive loading that the DG would experience. The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequentteardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The generator voltage and frequency is maintained within 4160 + 160 - 420 volts and 60 +/- 1.2 Hz during this test.

INSERT 6 The 18 month Frequency is consistent with the recommendations of

_Q RgulaorL~ide .10 upragah 2.a ( ,

si erain no n requiredSurveillance, nd is ctw This Surveillance is modified by`hFeeNotes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary powe factor tran ients above the row r factor ii vl p ot invalidate he tes u n a~o ea~ornIc, performance of this Surveilnecud cause perturbations to the electrical distribution systems thacol challenge co d sags at da s ours in the overloaded conditio eed not be performed, provided the auto-connected loads remain below he 6201 KVW continuous rating of the DG.

SR 3.8.1.15 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal (continued)

CALLAWAY PLANT B 3.8.1-22 Revision 0

ULNRC-04969 April 14, 2004 TS Bases Insert 6 (new)

Administrative controls for performing this Surveillance in MODES 1 or 2 with the DG connected to the offsite power supply ensure or require that:

a. Weather conditions are conducive for performing the Surveillance.

b. The offsite power supply and switchyard conditions are conducive for performing the Surveillance, which includes ensuring that switchyard access is restricted and no elective maintenance within the switchyard is performed.

c. No equipment or systems assumed to be available for supporting the performance of the Surveillance are removed from service.