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| ULNRC-05226 November 03, 2005 Page 3 cc: U.S. Nuclear Regulatory Commission (Original and I copy) | | ULNRC-05226 November 03, 2005 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) | | 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) |
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| application of the Code-required reference value and acceptance range for each MFIV will ensure that valve degradation is detected or investigated. This would be true for any test pressure since, as explained in the response to the next question, for a deviation seen at one particular test pressure a deviation would also be seen at any other test pressure (in relation to the characteristic stroke-time curve established for the MFIVs). | | application of the Code-required reference value and acceptance range for each MFIV will ensure that valve degradation is detected or investigated. This would be true for any test pressure since, as explained in the response to the next question, for a deviation seen at one particular test pressure a deviation would also be seen at any other test pressure (in relation to the characteristic stroke-time curve established for the MFIVs). |
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| Attachment 1 ULNRC-05226 Page 3 | | Attachment 1 ULNRC-05226 Page 3 |
| : 2. What are the conditions that the MFIVs would be tested at to be in accordance with the proposed SR 3.7.3.3, andwhat is the basis that testing an MFIV at those conditions ensures that the valve closure times at other conditions would meet the proposedFigure3.7.3-1? | | : 2. What are the conditions that the MFIVs would be tested at to be in accordance with the proposed SR 3.7.3.3, andwhat is the basis that testing an MFIV at those conditions ensures that the valve closure times at other conditions would meet the proposedFigure3.7.3-1? |
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| As described in the amendment request, the proposed TS acceptance curve for SR 3.7.3.3 is based on the MFIV performance curve (provided as Attachment 6 to the September 9 amendment request). The shape of the performance curve reflects the operating characteristics of the MFIVs (with respect to how fast the valves may be expected to close at any pressure throughout the expected pressure range of operation). This curve was supported by testing done at the valve manufacturer, as well as field tests done at Callaway. In addition, and as also noted in the amendment request, the shape of the acceptance/performance curve(s) will be verified by baseline testing to be done during restart from the current refueling outage. [For the baseline testing, each MFIV will be stroked to close at five different pressures throughout the applicable pressure range. The measured stroke times will then be compared and evaluated to verify the shape of the performance/acceptance curve(s).] Since the acceptance curve is based on the characteristic curve for the valves, a deviation from the stroke time at one point on the acceptance curve would be expected to yield a proportional deviation from the stroke time at any other point on the curve. | | As described in the amendment request, the proposed TS acceptance curve for SR 3.7.3.3 is based on the MFIV performance curve (provided as Attachment 6 to the September 9 amendment request). The shape of the performance curve reflects the operating characteristics of the MFIVs (with respect to how fast the valves may be expected to close at any pressure throughout the expected pressure range of operation). This curve was supported by testing done at the valve manufacturer, as well as field tests done at Callaway. In addition, and as also noted in the amendment request, the shape of the acceptance/performance curve(s) will be verified by baseline testing to be done during restart from the current refueling outage. [For the baseline testing, each MFIV will be stroked to close at five different pressures throughout the applicable pressure range. The measured stroke times will then be compared and evaluated to verify the shape of the performance/acceptance curve(s).] Since the acceptance curve is based on the characteristic curve for the valves, a deviation from the stroke time at one point on the acceptance curve would be expected to yield a proportional deviation from the stroke time at any other point on the curve. |
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| ULNRC-05226 ATTACHMENT 2 MFIV PERFORMANCE CURVE | | ULNRC-05226 ATTACHMENT 2 MFIV PERFORMANCE CURVE |
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MONTHYEARULNRC-05206, License Amendment Request OL 1258 Revision to Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfiv'S)2005-09-0909 September 2005 License Amendment Request OL 1258 Revision to Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfiv'S) Project stage: Request ML0524905382005-09-12012 September 2005 9/12/05, Callaway, Individual Federal Register Notice for License Amendment Request Related to Main Feedwater Isolation Valve (Mfiv) Stroke Time Limits Project stage: Other ULNRC-05224, Supplement/Revision to License Amendment Request OL-1258 for Revision of Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfivs).2005-10-24024 October 2005 Supplement/Revision to License Amendment Request OL-1258 for Revision of Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfivs). Project stage: Supplement ULNRC-05226, Responses to Requests for Additional Information Concerning License Amendment Request (LAR) OL-1258 for Revision of Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfivs).2005-11-0303 November 2005 Responses to Requests for Additional Information Concerning License Amendment Request (LAR) OL-1258 for Revision of Technical Specification 3.7.3, Main Feedwater Isolation Valves (Mfivs). Project stage: Response to RAI ML0529702652005-11-17017 November 2005 Issuance of License Amendment 170 Regarding Main Feedwater Isolation Valves Closure Time in Technical Specification 3.7.3 Project stage: Approval ML0532700072005-11-17017 November 2005 Tech Spec Pages for Amendment 170 Regarding Main Feedwater Isolation Valves Closure Time in Technical Specification 3.7.3 Project stage: Other 2005-11-03
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Category:Letter type:ULNRC
MONTHYEARULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024 Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717 ULNRC-06847, Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)2023-12-21021 December 2023 Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01) ULNRC-06849, License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds2023-12-20020 December 2023 License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification2023-12-0707 December 2023 Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification ULNRC-06827, Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2023-11-20020 November 2023 Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A2023-08-17017 August 2023 Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A ULNRC-06830, Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak2023-08-15015 August 2023 Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak ULNRC-06223, Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004)2023-07-25025 July 2023 Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004) ULNRC-06799, Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications2023-07-13013 July 2023 Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023 Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301) ULNRC-06822, Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a2023-06-14014 June 2023 Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a ULNRC-06815, Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a2023-06-0505 June 2023 Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a ULNRC-06818, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate .2023-06-0505 June 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate . ULNRC-06816, Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015)2023-05-0909 May 2023 Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06812, Submittal of 2022 Annual Radiological Environmental Operating Report2023-04-27027 April 2023 Submittal of 2022 Annual Radiological Environmental Operating Report ULNRC-06806, Submittal of Radiological Emergency Response Plan, Revision 552023-04-12012 April 2023 Submittal of Radiological Emergency Response Plan, Revision 55 ULNRC-06807, Submittal of Single Positive Test Forms2023-04-0303 April 2023 Submittal of Single Positive Test Forms ULNRC-06798, Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan2023-03-30030 March 2023 Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan ULNRC-06801, CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions2023-03-30030 March 2023 CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions ULNRC-06804, Submittal of Nuclear Property Insurance Reporting2023-03-29029 March 2023 Submittal of Nuclear Property Insurance Reporting ULNRC-06751, Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control2023-03-29029 March 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control ULNRC-06803, Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection2023-03-29029 March 2023 Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection ULNRC-06805, Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days2023-03-21021 March 2023 Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days ULNRC-06802, Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument2023-03-0909 March 2023 Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument ULNRC-06795, Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms2023-01-24024 January 2023 Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms ULNRC-06794, Submittal of Fitness for Duty Program Data for 20222023-01-24024 January 2023 Submittal of Fitness for Duty Program Data for 2022 ULNRC-06787, Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015)2022-12-0808 December 2022 Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06781, License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2022-12-0101 December 2022 License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06780, Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-0072022-11-30030 November 2022 Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-007 ULNRC-06772, 10 CFR 50.59 and 10 CFR 72.48 Summary Report2022-11-23023 November 2022 10 CFR 50.59 and 10 CFR 72.48 Summary Report ULNRC-06777, Operating Quality Assurance Manual (Oqam) Revision 362022-11-16016 November 2022 Operating Quality Assurance Manual (Oqam) Revision 36 ULNRC-06779, ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves2022-11-14014 November 2022 ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves ULNRC-06765, License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004)2022-11-0303 November 2022 License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004) ULNRC-06773, Results of Steam Generator Tube In-Service Inspection2022-11-0101 November 2022 Results of Steam Generator Tube In-Service Inspection ULNRC-06775, Submittal of Non-Functionality of Loose-Part Detection System Channel for Greater than 30 Days2022-10-27027 October 2022 Submittal of Non-Functionality of Loose-Part Detection System Channel for Greater than 30 Days ULNRC-06771, Correction to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections (LDCN 21-0013)2022-10-25025 October 2022 Correction to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections (LDCN 21-0013) ULNRC-06770, Cycle 25 Commitment Change Summary Report2022-10-19019 October 2022 Cycle 25 Commitment Change Summary Report ULNRC-06766, Correction of Text Contained in Enclosures Provided with Supplements to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014)2022-09-0808 September 2022 Correction of Text Contained in Enclosures Provided with Supplements to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014) ULNRC-06767, Presentation Information for Pre-Application Meeting Regarding New License Amendment Request for Use of Framatome Fuel Assemblies2022-09-0606 September 2022 Presentation Information for Pre-Application Meeting Regarding New License Amendment Request for Use of Framatome Fuel Assemblies ULNRC-06764, Revised Response to Request for Additional Information Regarding License Amendment Request for Adoption Off Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015)2022-09-0101 September 2022 Revised Response to Request for Additional Information Regarding License Amendment Request for Adoption Off Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06763, Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspection (LDCN 21-0013)2022-09-0101 September 2022 Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspection (LDCN 21-0013) ULNRC-06762, Submittal of Owner'S Activity Reports (OAR-1 Forms) for Cycle/Refuel 252022-08-25025 August 2022 Submittal of Owner'S Activity Reports (OAR-1 Forms) for Cycle/Refuel 25 ULNRC-06758, Union Electric Co. - Renewed Facility Operating License NPF-30, Withdrawal of License Amendment Request and Exemption Request Regarding Transition to Framatome Fuel (LDCN 22-0002)2022-08-0404 August 2022 Union Electric Co. - Renewed Facility Operating License NPF-30, Withdrawal of License Amendment Request and Exemption Request Regarding Transition to Framatome Fuel (LDCN 22-0002) ULNRC-06755, Response to Requests for Additional Information for Proposed Revision to Radiological Emergency Response Plan Regarding Response and Notification Goals2022-07-13013 July 2022 Response to Requests for Additional Information for Proposed Revision to Radiological Emergency Response Plan Regarding Response and Notification Goals ULNRC-06754, Response to Request for Additional Information Regarding Licensee Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications2022-07-0505 July 2022 Response to Request for Additional Information Regarding Licensee Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications ULNRC-06739, Post-Audit Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505 (LDCN 20-0007)2022-06-30030 June 2022 Post-Audit Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505 (LDCN 20-0007) ULNRC-06752, Evacuation Time Estimates Report2022-06-27027 June 2022 Evacuation Time Estimates Report ULNRC-06753, Presentation Information for Pre-Submittal Meeting Regarding Updated Spent Fuel Criticality Safety Analysis2022-06-23023 June 2022 Presentation Information for Pre-Submittal Meeting Regarding Updated Spent Fuel Criticality Safety Analysis ULNRC-06750, Submittal of Cycle 26 Core Operating Limits Report (COLR)2022-06-13013 June 2022 Submittal of Cycle 26 Core Operating Limits Report (COLR) ULNRC-06735, Response to Request for Additional Information Regarding Request for License Amendment and Regulatory Exemptions for Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004-02 (LDCN 19-0014).2022-05-27027 May 2022 Response to Request for Additional Information Regarding Request for License Amendment and Regulatory Exemptions for Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004-02 (LDCN 19-0014). 2024-01-29
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AmerenUE PO Box 620 Callaway Plant Fulton, MtO 65251 November 03, 2005 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.C. 20555-0001 Ladies and Gentlemen: ULNRC-05226 DOCKET NUMBER 50483 CALLAWAY PLANT WAmeren UNION ELECTRIC COMPANY RESPONSES TO REQUESTS FOR UE ADDITIONAL INFORMATION CONCERNING LICENSE AMENDMENT REQUEST (LAR) OL-1258 FOR REVISION OF TECHNICAL SPECIFICATION 3.7.3, "MAIN FEEDWATER ISOLATION VALVES (MFIVsr'
References:
1)ULNRC-05206, dated September 9, 2005
- 2) ULNRC-05224, dated October 24, 2005 Reference 1 (ULNRC-05206) transmitted to the NRC AmerenUE's (Union Electric) requested amendment of the Facility Operating License for the Callaway Plant (License No. NPF-30) to revise Technical Specification (TS) 3.7.3, "Main Feedwater Isolation Valves (MFIVs)." The primary change proposed per the amendment request (which is still under review by the NRC) is to revise the stroke time test requirement for the MFIVs such that the single-value 15-second stroke time limit currently specified in TS 3.7.3 for the MFIVs would be replaced with a reference to a figure that specifies the stroke time limit as a function of steam generator steam pressure.
Reference 2 (ULNRC-05224) transmitted a supplement to the original amendment request in order to partially modify the changes that were originally proposed, and to provide additional information in response to questions/requests for additional information from the NRC. Subsequent to the Reference 2 submittal, AmerenUE received additional questions from the NRC.
This letter provides AmerenUE's responses to the additional NRC questions. Specifically, Attachment I to this letter provides statements of the questions and the AmerenUE responses. In addition, Attachment 2 to this letter provides a color version of the MFIV Performance Curve that was originally provided to the NRC as Attachment 6 to Reference I (ULNRC-05206).
a subsidiary olAmeren Corporation
ULNRC-05226 November 03, 2005 Page 2 In providing this additional information, the determination pursuant to 10 CFR 50.92 that the proposed license amendment request and its supplement does not involve a significant hazard consideration, including the basis for that determination, remains unchanged.
Please contact us for any questions you may have regarding this transmittal of additional information.
I declare under penalty of perjury that the foregoing is true and correct.
Very truly yours, Executed on: November 03, 2005 Michael S. Evans Manager, Business Operations DJW/jdg Attachments: 1) Responses to NRC Questions Regarding LAR OL-1258
- 2) MFIV Performance Curve
ULNRC-05226 November 03, 2005 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
ULNRC-05226 ATTACHMENT 1 RESPONSES TO NRC QUESTIONS REGARDING LAR OL-1258
Responses to NRC Questions Regarding LAR OL-1258
- 1. The 15 seconds in the currentSR 3.7.3.1 is basedon the premise that any higher closure time would be an indication of degradationofthe valve. Therefore, the NRC staff needs to know that higher closure times below 500psig SG pressure (SGP) in the proposedFigure3.7.3-1 ivould not be showing that the MFIV being tested has degraded
Response
The main feedwater isolation valves (MFIVs) are tested under the Inservice Testing (IST)
Program. Valves tested under the IST Program are governed by the testing requirements of the ASME OM Code. The ASME OM Code requires that stroke time test results shall be compared to the initial reference values or new reference values established for subject valves. Although the stroke-time limits for the MFIVs are being changed (pursuant to the license amendment request), the ASME OM Code test requirements will not change for the main feedwater isolation valves.
When comparing the stroke time test results to the initial reference values, the ASME OM Code specifies, for each type of valve (based on actuator type), the exact stroke time ranges to be used for stroke time acceptance criteria. If a valve fails to meet the stroke time acceptance criteria range, the valve shall be immediately retested or declared inoperable. If the valve is retested and the second set of data also does not meet the stroke time acceptance criteria range, the data shall be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to verify that the new stroke time represents acceptable valve operation, or the valve shall be declared inoperable. If the second set of data meets the acceptance criteria, the cause of the initial deviation shall be analyzed and the results documented in the record of tests.
Valves declared inoperable may be repaired or replaced, or the data may be analyzed to determine the cause of the deviation. The latter may yield a determination, in some cases, that the valve is operating acceptably. [ASME OM Code 1988 Part 10 Paragraphs 4.2.1.8 and 4.2.1.9]
When new reference values are established, the ASME OM Code specifies that reference values shall only be established when the valve is known to be operating acceptably.
Deviations between the previous and new reference values shall be identified and analyzed. Verification that the new values represent acceptable operation shall be documented in the record of test. [ASME OM Code 1988 Part 10 Paragraph 3.3 and 3.4]
Therefore, although longer stroke times would be noted for the MFIVs at lower pressures (consistent with the characteristics of the system-medium actuators for these valves),
application of the Code-required reference value and acceptance range for each MFIV will ensure that valve degradation is detected or investigated. This would be true for any test pressure since, as explained in the response to the next question, for a deviation seen at one particular test pressure a deviation would also be seen at any other test pressure (in relation to the characteristic stroke-time curve established for the MFIVs).
Attachment 1 ULNRC-05226 Page 3
- 2. What are the conditions that the MFIVs would be tested at to be in accordance with the proposed SR 3.7.3.3, andwhat is the basis that testing an MFIV at those conditions ensures that the valve closure times at other conditions would meet the proposedFigure3.7.3-1?
Response
Per the proposed surveillance test procedure to be used for implementing SR 3.7.3.3, the MFIVs will be tested at a nominal system pressure (steam generator steam pressure) of approximately 100 psig (during Mode 4, prior to entry into Mode 3). As described in the response to Question 1 above, testing at this point will provide a reference stroke time value that will be used to establish the test acceptance criteria for each MFIV under the IST program.
As described in the amendment request, the proposed TS acceptance curve for SR 3.7.3.3 is based on the MFIV performance curve (provided as Attachment 6 to the September 9 amendment request). The shape of the performance curve reflects the operating characteristics of the MFIVs (with respect to how fast the valves may be expected to close at any pressure throughout the expected pressure range of operation). This curve was supported by testing done at the valve manufacturer, as well as field tests done at Callaway. In addition, and as also noted in the amendment request, the shape of the acceptance/performance curve(s) will be verified by baseline testing to be done during restart from the current refueling outage. [For the baseline testing, each MFIV will be stroked to close at five different pressures throughout the applicable pressure range. The measured stroke times will then be compared and evaluated to verify the shape of the performance/acceptance curve(s).] Since the acceptance curve is based on the characteristic curve for the valves, a deviation from the stroke time at one point on the acceptance curve would be expected to yield a proportional deviation from the stroke time at any other point on the curve.
ULNRC-05226 ATTACHMENT 2 MFIV PERFORMANCE CURVE
)f MFIV Stroke Time Curves 12 0--0 115 __- -Calculated Dual Train Stroke Time 115 _
110 _ __ -Calculated Single Train Stroke Time 105 -- Measured Dual Train Stroke Time 100 _ .
95 -_- Safety Analysis Limits 90 -_ -Sample TS Curve 85 -
Mode 3 Entry Steam Generator 80 Pressure 75 _ __
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0 oo o to O LO LO O LO S e n e raOt rO PeO ( L o Lo N N M WD: W1)t1) (O CD I-- I- CD GO a) 0) O O N-Steam Generator Pressure (psig)
C9/