ULNRC-05056, Technical Specification Revisions Associated with Steam Generator Replacement Project

Technical Specification Revisions Associated with Steam Generator Replacement Project

ML042870364
Person / Time
Site:	Callaway
Issue date:	09/17/2004
From:	Keith Young AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05056
Download: ML042870364 (6)

Text

AmerenUE PO Box 620 CallawayPlant Fulton, MIO 65251

-~ September 17, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-137 Washington, D.C. 20555 ULNRC-05056 Ladies and Gentlemen:

DOCKET NUMBER 50-483 UNION ELECTRIC COMPANY 41 FCALLAWAY PLANT a I TECHNICAL SPECIFICATION REVISIONS ASSOCIATED WITH THE waffoeref STEAM GENERATOR REPLACMENT PROJECT UF AmerenUE herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant in support of replacement steam generators to be installed during Refuel 14 (fall 2005).

The proposed amendment would revise the following Technical Specifications (TS):

• TS 2.1. 1, "Reactor Core Safety Limits";

• TS 3.3.1, "Reactor Trip System (RTS) Instrumentation";

• TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation";

• TS 3.4.1, "RCS Pressure, Temperature, and Flow DNB Limits";

• TS 3.4.5, "RCS Loops - MODE 3";

• TS 3.4.6, "RCS Loops - MODE 4";

• TS 3.4.7, "RCS Loops - MODE 5, Loops Filled";

• TS 3.4.13, "RCS Operational Leakage";

• TS 3.7.1, "Main Steam Safety Valves";

• TS 5.5.9, "Steam Generator (SG) Tube Surveillance Program";

• TS 5.5.16, "Containment Leakage Rate Testing Program"; and

• TS 5.6.10, "Steam Generator Tube Inspection Report."

In addition, the proposed amendment would add new TS 3.4.17, "Steam Generator Tube Integrity," pursuant to Technical Specification Task Force (TSTF)

Improved Standard Technical Specifications Change Traveler TSTF-449 Revision 2.

a subsidiary ofAmeren Corporation

ULNRC-05056 September 17, 2004 Page 2 Attachments 1 through 5 provide the Evaluation, Markup of Technical Specifications, Retyped Technical Specifications, Proposed Technical Specification Bases Changes, and Summary of Regulatory Commitments, respectively, in support of this amendment request. Attachment 4 is provided for information only. Final Bases changes will be implemented pursuant to TS 5.5.14, Technical Specifications Bases Control Program, at the time the amendment is implemented. Appendix A provides the Westinghouse licensing report in support of the replacement steam generators.

Sections 5.5.2.2 and 6.5.2.3 of Appendix A discuss the application of leak-before-break (LBB) criteria to the pressurizer surge line and take credit for WCAP-15983-P which was not approved by NRC in Callaway License Amendment 161 dated April 12, 2004. Prior to November 30, 2004, AmerenUE will submit the documentation requested by NRC regarding effective mitigation measures to be applied at the Alloy 82/182 pressurizer nozzle safe end weld at the base of the pressurizer. A description of the mitigation measures and a commitment to apply those measures at this weld should allow us to pursue the application of LBB for the entire pressurizer surge line and approval of WCAP- 15983-P to support modifications related to the replacement steam generators to be installed during Refuel 14.

Section 6.6.1.2.2 of Appendix A discusses the credit taken for the main feedwater control (flow regulating) valves in the analysis of steam line break mass and energy releases inside containment. Credit is taken for these valves if the postulated single failure is a main feedwater isolation valve that fails in the open position. Therefore, a separate amendment application will be submitted based on Technical Specification 3.7.3 of STS NUREG- 1431, Revision 3, adding the main feedwater control and bypass valves to LCO 3.7.3 with 72-hour Completion Times in Conditions A, B, and C.

Westinghouse has determined that information contained in Appendix A is proprietary, and is thereby supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390. Accordingly, it is respectfully requested that the information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390. This letter transmits proprietary and non-proprietary copies of Appendix A. Also enclosed are Westinghouse authorization letter CAW-04-1868, its accompanying affidavit, Proprietary Information Notice, and Copyright Notice. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-04-1868 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company, LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

ULNRC-05056 September 17, 2004 Page 3 It has been determined that this amendment application does not involve a significant hazard consideration as determined per I OCFR50.92. Pursuant to IOCFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment. The Callaway Onsite Review Committee and Nuclear Safety Review Board have reviewed and approved these licensing evaluations and have approved the submittal of this amendment application.

Approval of this amendment application is requested by August 15, 2005 to support final Refuel 14 outage preparations. This amendment will be implemented prior to MODE 5 entry ascending during startup from the Refuel 14 outage when the replacement steam generators will be installed. In accordance with IOCFR50.91, a copy of this amendment application is being provided to the designated Missouri State official.

If you have any questions on this amendment application, please contact us.

Very truly yours, Keith D. Young Manager-Regulatory Affairs GGY/

Attachments:

I Evaluation 2 Markup of Technical Specifications 3 Retyped Technical Specifications 4 Proposed Technical Specification Bases Changes (for information only) 5 Summary of Regulatory Commitments Appendix A WCAP-16265-P Callaway Replacement Steam Generator Program NSSS Licensing Report (proprietary and non-proprietary versions)

ULNRC-05056 September 17, 2004 Page 4 cc: U.S. Nuclear Regulatory Commission (Original and I 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 7EI Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102

ULNRC-05056 September 17, 2004 Page 5 bcc: G. L. Randolph C. D. Naslund K. D. Young G. A. Hughes D. E. Shafer (470) (2 copies)

S. L. Gallagher (100)

S. L. Klang (NSRB)

M. A. Reidmeyer J. E. Ready G. G. Yates E210.0001 A 160.0761 Diane Ilooper STARS Projects Manager Supervisor, Licensing c/o Rodney Wilferd WCNOC Palo Verde NGS P.O. Box 411 P.O. Box 52034 Burlington, KS 66839 Phoenix, AZ 85072-2034 Mr. Scott Bauer Mr. Dennis Buschbaum Regulatory Affairs Comanche Peak SES Palo Verde NGS P.O. Box 1002 P.O. Box 52034, Glen Rose, TX 76043 Mail Station 7636 Phoenix, AZ 85072-2034 Mr. Scott Head Mr. Stan Ketelsen Supervisor, Licensing Manager, Regulatory Services South Texas Project NOC Pacific Gas & Electric Mail Code N5014 Mail Stop 104/5/536 P.O. Box 289 P.O. Box 56 Wadsworth, TX 77483 Avila Beach, CA 93424 Mr. John O'Neill Certrec Corporation Shaw, Pittman 4200 South Hulen, Suite 630 2300 N. Street N.W. Fort Worth, TX 76109 Washington, DC 20037

STATE OF MISSOURI )SEA

)S S NOTAR~Y COUNTY OF CALLAWAY )PXBLI 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 _____

Kih D. Young Manager, Regulatory Affairs SUBSCRIBED and sworn to before me this J day of -ea p 6e, , 2004.