ML083100134

Correction to Amendment No. 186 Approving One-Time Extension of Completion Time for Inoperable Essential Service Water System and Emergency Diesel Generators

ML083100134
Person / Time
Site:	Callaway
Issue date:	11/06/2008
From:	Thadani M Plant Licensing Branch IV
To:	Heflin A Union Electric Co
Thadani, M C, NRR/DORL/LP4, 415-1476
References
TAC MD7252
Download: ML083100134 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 6, 2008 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - CORRECTION TO AMENDMENT NO. 186 APPROVING ONE-TIME EXTENSION OF COMPLETION TIME FOR INOPERABLE ESSENTIAL SERVICE WATER SYSTEM AND EMERGENCY DIESEL GENERATORS (TAC NO. MD7252)

Dear Mr. Heflin:

By application dated October 31, 2007, as supplemented by letters dated February 21, March 7, May 6, July 10, and August 13, 2008, Union Electric Company requested the U.S. Nuclear Regulatory Commission (NRC) staff for approval of changes to the Technical Specifications (TS) for its Callaway Plant, Unit 1.

On October 31, 2008, the NRC staff responded to your application and issued Amendment No. 186, dated October 31 , 2008, to the Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1. The amendment revised the TS to permit a one-time extension of Completion Time for essential service water and emergency diesel generators from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days.

By emaiisdatedNovember1and3.2008.Mr. Thomas Elwood of your staff informed the NRC staff of errors in the license and safety evaluation and missing revision bars on the TS pages accompanying Amendment No. 186 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML082810643).

The NRC staff has reviewed the information provided by Mr. Elwood, and agrees with the comments. Our evaluation indicates that the missing revision bars were caused by the scanning process being used by the NRC staff in connection with the new electronic distribution system adopted by the NRC staff. That problem has been corrected, and the amendment has been rescanned and replaced in ADAMS Accession No. ML082810643. In addition, the rescanned amendment was sent bye-mail to the distribution list on November 5, 2008. The errors in the license page and safety evaluation were inadvertently caused and have been corrected in the enclosed revised license page 3 and safety evaluation pages 6, 8, 27, and 28 supporting Amendment No. 186.

These errors do not change any of the NRC staffs conclusions regarding Amendment No. 186.

A. Heflin -2 We regret any inconvenience caused by these errors.

Sincerely, Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

As stated cc w/encls: See next page

Callaway Plant, Unit 1 (9/19/2008) cc:

Missouri Public Service Commission Governor Office Building 200 Madison Street P.O. Box 360 Jefferson City, MO 65102-0360 Certrec Corporation 4200 S. Hulen, Suite 422 Fort Worth, TX 76109 Technical Services Branch Chief FEMA Region VII 2323 Grand Blvd., Suite 900 Kansas City, MO 64108-2670 Additional Distribution via Listserv

ENCLOSURES License page 3 Safety Evaluation pages 6, 8, 27, and 28

-3 (4) UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source of special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level UE is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100% power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan*

The Technical Specifications contained in Appendix A, as revised through Amendment No. 186 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Environmental Qualification (Section 3.11, SSER #3)**

Deleted per Amendment No. 169

• Amendments 133, 134, & 135 were effective as of April 30, 2000 however these amendments were implemented on April 1, 2000.

• • The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 186

-6 3.1 Evaluation of Extension of CTs for ESW and EDGs The offsite and onsite power system at the Callaway Plant is designed to comply with the requirements of GDC-17 and GDC-18, respectively. As described in the licensee's Final Safety Analyses Report (FSAR), the plant is supplied power from the offsite system through two independent and redundant sources in accordance with GDC-17. With respect to the safety related (Class 1E) power supply configuration, one preferred circuit from the switchyard supplies power to a multi-winding startup transformer, one winding of which feeds a 13.8/4.16 kiloVolt (kV) engineered safety feature (ESF) transformer (also equipped with an automatic load tap changer and its associated capacitor bank). Each ESF transformer supplies power to an associated Class 1E 4.16 kV bus. For each safety-related bus normally fed by its associated transformer, the capability exists for either bus to be ultimately supplied by the other preferred source connection.

The onsite standby power system includes Class 1E AC and direct current (DC) power supply capability for equipment used to achieve and maintain a cold shutdown of the plant and to mitigate the consequences of a design-basis accident. With respect to Class 1E AC power, each of the two Class 1E load groups at the 4.16 kV bus level is capable of being powered from an independent EDG (one per load group) that functions to provide power in the event of a loss of the preferred power source. Undervoltage relays are provided for each 4.16 kV bus to detect an undervoltage condition and automatically start the EDG in response to such a condition. The Class 1E DC system includes four separate 125 Volt (V) DC batteries that supply power for Class 1E controls, instrumentation, and inverters.

3.1.1 Proposed TS Changes The proposed change to TS 3.7.8, "Essential Service Water System," will add a note to the CT of Required Action A.1 that would require the restoration of an inoperable ESW train to OPERABLE status. This new note would allow a one-time CT extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days per ESW train to be used prior to December 31, 2008, for replacing underground ESW piping. The new note would read: "A one-time Completion Time of 14 days per ESW train is allowed to support planned replacement of ESW piping prior to December 31,2008."

Currently, TS 3.8.1.8 requires that two separate and independent EDGs be operable in MODES 1 through 4. In the event that one of the required EDGs becomes inoperable, the LCO requires the inoperable EDG to be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or the plant must be in Hot Standby (MODE 3) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and be placed in Cold Shutdown (MODE 5) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Additionally, if two of the required EDGs become inoperable, TS 3.8.1 Action E requires that at least one of the inoperable EDGs be returned to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or the plant must be brought to Hot Standby conditions within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to Cold Shutdown conditions within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The licensee has proposed adding a note to TS 3.8.1.B.4 for a one-time CT extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. The new note would read "A one-time Completion Time of 14 days per DG

[diesel generator] is allowed to support planned replacement of ESW piping prior to December 31,2008."

-8 (1) programmatic activities, such as protecting the other (operable) train of safety equipment by deferring, to the extent possible, the performance of any maintenance or testing related to the operable train of equipment; providing operator training in certain areas that are impacted; and (2) establishing enhanced monitoring to address flooding considerations. Based on this being a one-time change of limited duration, the NRC staff concludes the programmatic activities to be appropriate and necessary for maintaining defense-in-depth.

3.1.2.2 Emergency Diesel Generator Outage The purpose of the proposed change to TS 3.8.1 is to extend the EDG system CT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days to allow the licensee to perform major modifications to the ESW system associated piping. The licensee stated that the proposed modification will require more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to implement while the plant is operating in MODES 1 through 4. The ESW system provides cooling water for the EDG system during emergency conditions. The ESW system outage will render the corresponding EDG inoperable.

The NRC staff evaluated the licensee's request to extend the CT for EDGs to determine whether the station blackout requirement in 10 CFR 50.63 would be eroded by the proposed changes and whether the overall availability of the EDGs would be reduced significantly as a result of increased on-line maintenance activities. In light of the recent experiences in offsite power system outages, it has been the NRC staff's position that the availability of an additional power source is a condition for approval of an extended EDG CT.

The licensee has proposed compensatory actions to reduce the risk of loss of redundant AC power required for safe shutdown during the implementation stages of the modifications. The licensee stated that the following compensatory measures will be implemented to enhance plant safety during each 14-day outage period:

1. A temporary alternate AC power source consisting of DGs, with combined capacity equal to or greater than the capacity of either one of the installed EDGs will be available as a backup power source. This temporary alternate AC source could power protected train loads in the unlikely event a LOOP event occurred and the protected train's EDG failed to start and run. Prior to applying the extended CT, these temporary DGs will be load tested to demonstrate their capability of supporting a load equal to the continuous rating of the inoperable EDG. After entering the extended CT, this source will be verified available every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and treated as protected equipment. The licensee plans to stage four temporary DGs in the switchyard such that they can be connected to the safeguard transformer ring bus and have dedicated manning such that Callaway Plant's 4-hour station blackout coping duration will not be exceeded.

2. Access to the switchyard will be limited to personnel with a demonstrable need (e.g., operator rounds involving no equipment manipulation and staff associated with the temporary DGs) and no work will be allowed in the switchyard that could cause a LOOP event during the one-time extended CT.

3. The one-time extended CT will not be entered if inclement weather conditions are forecasted (i.e., work under the extended CT will not be started if severe

- 27 LIST OF REGULATORY COMMITMENTS MADE BY THE LICENSEE ATIACHMENT 2 TO SUPPLEMENTAL LETTER DATED JULY 10, 2008 COMMITMENT DUE DATE/EVENT

1. For no more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during the 'A' ESW train LCO Administrative controls in outage, and no more than 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> during the 'B' ESW train place at the time the LCO outage, normal service water will not be available to the amendment is implemented.

out-of-service ESW train. During these time limits, no PRA- This is a Tier 2 commitment.

modeled equipment, other than the out-of-service ESW train and supported systems rendered inoperable by that ESW train being out-of-service, will be voluntarily taken out-of-service during the one-time extended Completion Time taken on each train. This applies only to PRA-modeled equipment in the protected ESF train (ESF train not served by the inoperable ESW train) during these time limits that normal service water is unavailable. No work will be allowed on the protected (operable) ESW train. The preceding was credited in the risk metric calculations supporting this license amendment request. No work will be allowed in the area of equipment in the protected [Engineered Safety Features]

ESF train (within 20 feet unless there is an intervening barrier) except for yard piping work and work in control building room 3101 where the underground piping enters the control building.

2. For the rest of the 'A' ESW train and 'B' ESW train LCO outages Administrative controls in (the one-time 14-day Completion Times per ESW train minus place at the time the the time limits noted above), the out-of-service ESW train loads amendment is implemented.

will be cooled by normal service water. Credit has been taken in This is a Tier 2 commitment.

the risk metric calculations for the ESF equipment serviced by the protected ESW train (and for normal service water supplying the protected train loads if the protected ESW pump were to fail) and for the ESF equipment that can be serviced by normal service water associated with the out-of-service ESW train.

None of the PRA-modeled equipment in either train will be voluntarily taken out of service during the time that normal service water is available to supply the out-of-service ESW train loads. This commitment applies as long as the one-time 14-day Completion Time extension of TS 3.7.8 Condition A and TS 3.8.1 Condition B is in use; this commitment expires when these TS Conditions are exited.

3. Access to the switchyard will be limited to personnel with a Administrative controls in demonstrable need (operator rounds involving no equipment place at the time the manipulation and staff associated with performing the 8-hour amendment is implemented.

readiness checks on the temporary DGs) and no pre-planned This is a Tier 2 commitment.

work or testing or preventive maintenance will be allowed in the switchyard, or other areas of the plant, that could cause a loss of offsite power (LOOP) event during the one-time 14-day extended Completion Time. Credit was taken for this commitment in the risk metric calculations supporting this license amendment request. The only other access to the sWitchyard that would be considered would be for corrective maintenance that would address an emergent condition before it led to a LOOP event.

- 28 COMMITMENT DUE DATE/EVENT

4. The one-time 14-day extended Completion Time will not be Administrative controls in entered if, prior to entry, inclement weather conditions are place at the time the forecasted, i.e., work under the extended Completion Time will amendment is implemented.

not be started if Severe Weather as defined in OTO-ZZ-00012 is This is a Tier 2 commitment.

forecasted to occur within 140 miles of the plant. National Weather Service reports will be monitored prior to and throughout each ESW train LCO outage.

5. From EDP-ZZ-01129 Appendix 2 for a DG or ESW outage and Administrative controls in TS 3.7.5, the following Tier 2 commitments are also added to the place at the time the scope of this amendment request: amendment is implemented.

This is a Tier 2 commitment.

• The turbine-driven auxiliary feedwater pump (TDAFP) will remain Operable. If the TDAFP were to become inoperable during the 14-day LCO outage, TS 3.7.5 Condition D would require a plant shutdown to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> since one MDAFW train is already inoperable at the beginning of the LCO outage.

• The TDAFP pump room and associated valve rooms will be posted as restricted access.

• The protected train motor-driven auxiliary feedwater pump (MDAFP) pump room and associated valve rooms will be posted as restricted access.

• The condensate storage tank (CST) will be posted as restricted access.

• No work will be allowed on the Security Diesel.

6. For the time limits (14 days minus 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> on ESW train 'A' and Administrative controls in 14 days minus 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> on ESW train 'B') noted above in place at the time the commitment 2, the piping tie-in (new underground PE amendment is implemented.

[polyethylene] ESW piping to the rest of the system) will be This is a Tier 2 commitment.

performed with the normal service water system cooling the out of-service ESW train heat loads. During the portion of the extended Completion Time that normal service water is supplying the ESW loads, the normal service water to ESW supply and return cross-connect valves will be opened and power removed from the operators. Credit was taken for the preceding in the risk metric calculations supporting this license amendment request. The ESW return to UHS valves will be closed and power removed from the operators during this portion of the extended 14-day Completion Time as well.

November 6, 2008 A. Heflin -2 We regret any inconvenience caused by these errors.

Sincerely, IRAI Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

As stated cc w/encls: See next page DISTRIBUTION:

PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDirsltsb Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrPMMThadani Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource G. Mathuru, NRRlDE/EEEB M. McConnell, NRRlDE/EEEB A. Howe, NRRlDRNAPLA R. Young, NRRlDSS/SBPB GHill, OIS (2)

ADAMS Accession No. ML083100134 OFFICE NRR//DORLlLPL4/LA NRRIDORLlLPL4/BC NAME MThadani JBurkhardt DATE 11/5/08