ULNRC-05087, Common Stars License Amendment Implementation of WCAP-14333 and WCAP-15376 RTS and ESFAS Test Times, Completion Times, and Surveillance Test Intervals
| ML043290421 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/16/2004 |
| From: | Keith Young AmerenUE |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-05087, WCAP-14333, WCAP-15376 | |
| Download: ML043290421 (12) | |
Text
AmarenUE PO Box 620 Callaway Plant Fulton, MO 65251 November 16, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC-05087 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 COMMON STARS LICENSE AMENDMENT UF IMPLEMENTATION OF WCAP-14333 AND WCAP-15376 RTS AND ESFAS TEST TIMES, COMPLETION TIMES, AND SURVEILLANCE TEST INTERVALS Reference 1: ULNRC-04929 dated December 17, 2003 In the letter referenced above, AmerenUE transmitted an application for amendment to Facility Operating License Number NPF-30 for Callaway Plant. The proposed amendment would revise Technical Specification (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," and TS 3.3.9, "Boron Dilution Mitigation System (BDMS)" to adopt Completion Time, test bypass time, and Surveillance Frequency changes approved by NRC in WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times," October 1998 and WCAP-15376-P-A, Revision 1, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," March 2003. As discussed in Reference 1 above, the requested changes were based on the following NRC-approved travelers: Industry/Technical Specification Task Force (TSTF) Standard TS (STS) Change Traveler 411, Revision 1, "Surveillance Test Interval Extensions for Components of the Reactor Protection System (WCAP-15376)"; and Industry/TSTF STS Change Traveler 418, Revision 2, "RPS and ESFAS Test Times and Completion Times (WCAP-14333)."
Reference I proposed to restructure TS 3.3.1 Condition D from what was approved in TSTF-418, Revision 2, to avoid confusion as to when a flux map for determining the Quadrant Power Tilt Ratio (QPTR) is required. Discussions with the NRC Project Manager and NRC Technical Specification Section personnel on July 13, 2004 and July 29, 2004 identified potential format concerns with the originally proposed Condition D. After further review, it was determined that the originally proposed Condition D should be revised. The proposed revision was again discussed with the NRC staff on September 1, 2004.
,4 t ()0 a subsidiary ofAmeren Corporation
ULNRC-05087 November 16, 2004 Page 2 contains the proposed revision to TS 3.3.1 Condition D and replaces the mark-ups to TS page 3.3-3 included in Attachment 2 of Reference 1. contains the revised TS Bases for Condition D (for information only).
This supplemental information does not impact the conclusions of the No Significant Hazards Consideration or the Environmental Consideration provided in Reference 1.
The proposed revision to TS 3.3.1 Condition D was reviewed by the Onsite Review Committee. There are no new commitments associated with this submittal.
If you have further questions on this amendment application, please contact us.
Very truly yours, Keith D. Young Manager, Regulatory Affairs Attachments
STATE OF MISSOURI
)
COUNTY OF CALLAWAY)
SS 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
)
)#,,06 Kith D. Yo J
Manager, Regulatory Affairs SUBSCRIBED and sworn to before me this /Itp TU day of NOCVEMBER
,2004.
LORI L. TWILLMAN Notary Public -Notary Seal STATE OF MISSOURI Callaway County My Commission Expires: Aug. 3,2007 beach d). OLLXa:IDJY0
i ULNRC-05087 November 16,2004 Page 3 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 7E1 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
ATTACHMENT 1 MARKUP OF TECHNICAL SPECIFICATION 3.3.1 CONDITION D
RTS Instrumentation A/1--4A9-3
>3
/, b3.3.1 One Power Range Neutron M ux - High channel I
NOTE-------------
The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing and setpoint adjustment of other channels.
D.1.1 Place channel in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND D.1.2 Reduce 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> s75% RTP.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Only requihd performed whi Power Range inoperable.
Perform SR 3.2.4.2.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR D.3 Be in MODE 3.
CALLAWAY PLANT 3.3-3 Amendment No. 133
INSERT 3.3.1.D CONDITION REQUIRED ACTION COMPLETION D. One Power Range Neutron Flux - High channel inoperable.
NOTE--------------
The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing and setpoint adjustment of other channels.
D.1.1
--- ----- -NOTE ---- ------
Only required when the Power Range Neutron Flux input to QPTR is inoperable.
Perform SR 3.2.4.2.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery of THERMAL POWER > 75%
RTP AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AND D.1.2 OR D.2 Place channel in trip.
Be in MODE 3.
1 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />
ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION 3.3.1 CONDITION D BASES CHANGES (for information only)
RTS Instrumentation B 3.3.1 BASES ACTIONS C.1, C.2.1, AND C.2.2 (continued)
Automatic Trip Logic.
This action addresses the train orientation of the RTS for these Functions.
With one channel or train inoperable, the inoperable channel or train must be restored to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the affected Function(s) cannot be restored to OPERABLE status within the allowed 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time, the unit must be placed in a MODE in which the requirement does not apply. To achieve this status, action must be initiated within the same 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to fully insert all rods and the Rod Control System must be rendered incapable of rod withdrawal within the next hour (e.g., by de-energizing all CRDMs, by opening the RTBs, or de-energizing the motor generator (MG) sets). The additional hour for the latter provides sufficient time to accomplish the action in an orderly manner. With the rods fully inserted and the Rod Control System incapable of rod withdrawal, these Functions are no longer required.
The Completion lime is reasonable considering that in this Condition, the remaining OPERABLE train is adequate to perform the safety function, and given the low probability of an event occurring during this interval.
Condition C is modified by a Note stating that while this LCO is not met for Function 19, 20, or 21 in MODE 5, making the Rod Control System capable of rod withdrawal is not permitted. This Note specifies an exception to LCO 3.0.4 for this MODE 5 transition and avoids placing the plant in a condition where control rods can be withdrawn or not fully inserted while the reactor trip system is degraded.
D.1.1, D.1.2, D.2.4, D.2.2, and D.3 Body b.Q2 Condition D applies to the Power Range Neutron Flux - High trip Function.
The NIS power range detectors provide input to the Rod Control System and the SG Water Level Control System and, therefore, have a two-out-of-four trip logic. A known inoperable channel must be placed in the tripped condition. This results in a partial trip condition requiring only one-out-of-three logic for actuation. The ~hours allowed to place the inoperable channel in the tripped isndio isustified in Referencef aI to placin inopera channel he tripp condition T
MAL P0WDR must be uced to
% RTPjhin 12 h rs.
Reducingth ower level events op tion of thgore with dial p9ge distribts beyond t design limi at a power evel whe DNB /
(continued)
CALLAWAY PLANT B 3.3.1-34 Revision 4c
INSERT 1 With one of the NIS power range detectors inoperable, 1/4 of the radial power distribution monitoring capability is lost. Therefore, SR 3.2.4.2 must be performed (Required Action D. 1.1) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of THERMAL POWER exceeding 75% RTP and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. If reactor power decreases to < 75% RTP, the measurement of both Completion Times for Required Action D.1.1 stops and SR 3.2.4.2 is no longer required. Completion Time tracking recommences upon reactor power exceeding 75% RTP. Calculating QPTR every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> compensates for the lost monitoring capability due to the inoperable NIS power range channel and allows continued plant operation at power levels > 75% RTP. At power levels < 75% RTP, operation of the core with radial power distributions beyond the design limits, at a power level where DNB conditions may exist, is prevented. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is consistent with the SR 3.2.4.2 Frequency in LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)."
Required Action D.1.1 has been modified by a Note which only requires SR 3.2.4.2 to be performed if the Power Range Neutron Flux input to QPTR becomes inoperable. Failure of a component in the Power Range Neutron Flux Channel which renders the High Flux Trip Function inoperable may not affect the capability to monitor QPTR. As such, determining QPTR using the movable incore detectors once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> may not be necessary.
RTS Instrumentation B 3.3.1 ara' b.2 BASES ACTIONS D.1.1, D.1.2,'1, D.2., and D.Z (continued) c ditions may exist. With one of the NIS power range detectors iope
, 1/4 of the radial power distribution monitoring c ity is lost.
As an altermatv e above actions, the re channel can be placed in the tripped co withi rs and the QPTR monitored once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as per S 2 (including the SR 3.2.4.2 Note),
QPTR verification. Cagn QP R1 or opnsates for the lost montpaiity due toteipeb S pwr range chane fo sontinued unit oprto>a oe 75%
RTP.
The 6or Completion Time and the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency arco ent As an alternative to the above Actions, the plant must be placed in a MODE where this Function is no longer required OPERABLE. 4welve-Se ven4-k~e,' (i) hours are allowed to place the plant in MODE 3 This is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plan systems. If Required Actions cannot be completed within their allow s
Completion limes, LCO 3.0.3 must be entered.
L IJ\\/J 7 -
,/3 The Required Actions have been modified by a Note that allows placing the inoperable channel in the bypassed condition for up to ours while performing routine surveillance testing of other channels.
e Note also allows placing the inoperable channel in the bypassed co ition to allow setpoint adjustments of other channels when required to rduce the setpoint in accordance with other Technical Specification>. Th hour time limit is justified in References /7, Ion D..2 nas been mo ied by a Note which on S R 3.2.4.2 toit ihte Power Range Neutronto QPTR becomes inoperable.
aco n the Power Range Neutron Flux Channel which rendFiction inoperable may not acapability to monitor QPTV I
determinin glusing the movable incore detectors once per 12 E.1 and E.2 Condition E applies to the following reactor trip Functions:
Power Range Neutron Flux - Low; Overtemperature AT; (continued)
CALLAWAY PLANT B 3.3.1-35 Revision 4c
INSERT 1 B The 78-hour Completion Time includes 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for channel corrective maintenance, and an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the MODE reduction as required by Required Action D.2.