ULNRC-05690, Application for License Amendment Revision to Technical Specification 3.3.2 Function 6.g Engineered Safety Feature Actuation System (ESFAS) Instrumentation: on Trip of All Main Feedwater Pumps (LDCN 10-0011)

Application for License Amendment Revision to Technical Specification 3.3.2 Function 6.g Engineered Safety Feature Actuation System (ESFAS) Instrumentation: on Trip of All Main Feedwater Pumps (LDCN 10-0011)

ML100890460
Person / Time
Site:	Callaway
Issue date:	03/29/2010
From:	Graessle L AmerenUE, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05690
Download: ML100890460 (4)

Text

AmerenUE PO Box 620 Callaway Plant Fulton, MO 65251 March 29,2010 ULNRC-05690 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop Pl-137 Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:

~~ DOCKET NUMBER 50-483 wAmeren CALLAWAY PLANT UNION ELECTRIC CO.

UE APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NPF-30 REVISION TO TECHNICAL SPECIFICATION 3.3.2 FUNCTION 6.g ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION:

AUXILIARY FEEDWATER ACTUATION ON TRIP OF ALL MAIN FEEDWATER PUMPS (LDCN 10-0011)

Reference:

ULNRC-05687 dated March 29,2010 In the above reference AmerenUE submitted an amendment application to request changes to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Action System (ESFAS) Instrumentation," for function 6.g in TS Table 3.3.2-l.

Function 6.g provides an auxiliary feedwater (AFW) start signal to the motor-driven AFW pumps in the event of a trip of both turbine-driven main feedwater (MFW) pumps. The changes would revise Condition J for ESFAS instrumentation function 6.g so that it addresses having one or more inoperable channel(s) on each turbine-driven MFW pump. Corresponding changes to Required Action J.1 and the Note above Required Actions J.1 and J.2 were also proposed for consistency with the revised Condition.

AmerenUE hereby requests that this amendment be approved on an exigent basis in accordance with 10 CFR 50.91(a)(6) due to the time critical nature of the amendment. The need for this amendment could not be foreseen or avoided.

Industry operating experience (OE) document, OE30225, "Main Feedwater Pump 'Reset' Design Feature Provides Incorrect Main Feedwater Pump Status to Emergency Feedwater Pump Initiation Circuitry Resulting in Missed Technical Specification Requirements," Oconee Nuclear Station, December 16,2009, identified a subsidiary of Ameren Corporation

ULNRC-05690 March 29,2010 Page 3 a concern in which the turbine-driven MFW pump oil pressure channels could provide an incorrect status indication that an idle (not yet fully in service) MFW pump is in service when that MFW pump's turbine is reset and the pump is not yet supplying water to the steam generators. If the running MFW pump were to trip, the motor-driven auxiliary feedwater pumps would not receive an auto-start signal as required by the Callaway TSs. On February 22,2010, AmerenUE determined that the TS issue described in the above referenced amendment request was applicable to Callaway Plant. Attachment 1 of the referenced letter (page 5 of 14) discussed the fact that, without this amendment, LCO 3.0.3 would be applicable during the process of placing the second turbine-driven MFW pump into service in MODE 1 at Callaway Plant.

Specifically, Callaway Plant will not be able to resume operation up to the plant's licensed power level following Refuel 17 without timely NRC approval of this amendment. AmerenUE has been developing this amendment request with Wolf Creek Generation Station, and processing it through our review procedures, since the OE document was determined to be applicable to our plants.

As stated in the above reference, AmerenUE requests approval of this proposed license amendment prior to MODE 2 entry during the restart from the upcoming Refuel 17 outage. Entry into MODE 2 is currently scheduled to occur on May 14,2010. AmerenUE further requests that the license amendment be made effective upon NRC issuance to be implemented within 30 days.

If you have any questions on this correspondence, please contact Mr. Tom Elwood at (314) 225-1905.

I declare under penalty of peIjury that the foregoing is true and correct.

Very truly yours, Executed on: 3,..J C? -;}. 0 I '0 Luke H. Graessle Director, Operations Support

ULNRC-05690 March 29,2010 Page 3 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Washington, DC 20555-0001 Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G14 Washington, DC 20555-2738

ULNRC-05690 March 29,2010 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

A. C. Heflin F. M. Diya L. S. Sandbothe C. O. Reasoner III S. A. Maglio S. L. Gallagher T. L. Woodward (NSRB)

T. B. Elwood G. G. Yates Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (PG&E)

Mr. Wayne Harrison (STPNOC)

Mr. John O'Neill (Pillsbury, Winthrop, Shaw, Pittman LLP)

Missouri Public Service Commission Mr. Floyd Gilzow (DNR)