ML20090E237

Application to Amend License NPF-25,revising Tech Specs Re Containment Leakage Surveillance Requirement & Associated Bases to Clarify Leak Rate Testing of Seal Sys Fluid Pressurized Valves.Safety Evaluation Encl.Fee Encl

ML20090E237
Person / Time
Site:	Callaway
Issue date:	07/17/1984
From:	Schnell D UNION ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20090E240	List: ML20090E237 ML20090E242
References
ULNRC-875, NUDOCS 8407190361
Download: ML20090E237 (7)

Text

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e UNION ELECTRIC COM PANY 1908 GRATIOT STREET ST. Louis, MISSOURI

7. d. .*.."~,'" July 17, 1984 .r.tou . . . .

Mr. Harold R. Denton Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

ULNRC-875 DOCKET NUMBER 50-483 CALLAWAY PLANT, UNIT 1 REVISIONS TO TECHNICAL SPECIFICATIONS 3. 4.9. 3, 4.6.1.2, AND 3/4.6.1.2 BASES Union Electric Company is transmitting three (3) original and forty (40) conformed copies of an application for knendment to Facility Operating License No. NPF-25 for the Callaway Plant, Unit 1.

This application requests that Callaway Technical Specifications 3.4.9.3, 4.6.1.2, and 3/4.6.1.2 bases be revised to reflect the following changes. The Technical Specification 4.6.1.2, containment leakage surveillance requirement, and its associated bases 3/4.6.1.2 have been revised to provide clarifications on the leak rate testing of valves pressurized with fluid from a seal system. The clarifications are provided by the incorporation of Standard Technical Specifications 4.6.1.2.d.3 and 4.6.1.2.g (NUREG-0452, Revision 4) into Callaway Specifications 4.6.1.2.d.3 and 4.6.1.2.h and by an addition to bases 3/4.6.1.2 to include callaway Plant specific requirements that are consistent with 10CFR50, Appendix J, Paragraph III.C. 3.

In addition the Callaway FSAR Section 6.2.6.3, Containment Isolation Valve Leakage Rate Tests (Type C tests), will be revised as attached and will be incorporated into the next revision of the FSAR.

The overpressure protection systems Technical Specification, limiting condition for operation (LCO), 3.4.9.3.a is being changed to set the allowable tolerance on the RHR suction relief valves at + 3% rather than + 1%. This change makes the SpecificatTon consistent with the requirements of the ASME Boiler and Pressure Vessel Code,Section III, Article NB 7513.1, as long as the maximum pressure allowed is less than the lowest pressure setting of the power operated relief valves (PORVs). In addition, Action item (a) for this Specification is being changed as indicated in the enclosure to make the Action item consistent {g (3 with the LCO. \

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Mr. Harold R. Danton July 17, 1984 Page 2:

The proposed changes would become effective for Union Electric implementation upon NRC approval. Attachment 1 to this letter describes all enclosures transmitted herewith.

Enclosed is a check for the $150.00 application fee as requested by 10CFR170.21.

Very truly yours, D. F. Schnell DJW/lw Attachments l

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5 STATE OF MISSOURI )

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Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an of ficer of 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 Donald F. Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this / day of , 198d BARDARA a w, PFAFF NOTARY PUBLIC, STATE OF MISSOURI MY C0tlMISSION EXPIRES APRIL 22,1985 ST. LOUIS COUNTY

cc: Gerald Charnoft, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C. 20036 Nicholas A. Petrick Executive Director SNUPPS

'S Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resident Office U.S. Nuclear Regulatory Commission RRil-Steedman, Missouri- 65077 William Forney Division of Projects and Resident Programs, Chief, Section LA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077 Joseph J. Holonich, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop P-316 Washington, D.C. 20555 Ron Kucera, Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65012

ULMRC-875 7/17/84 Attachment 1 Enclosure A Safety Evaluation Enclosure B Significant Hazards Consideration Enclosure C Marked Technical Specifications and Bases Enclosure D Marked FSAR Section 6.2.6.3

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ENCLOSURE A ULNRC-875 7/17/84 SAFETY EVALUATION This amendment request revises Technical Specification  !

4.6.1.2, and its associated bases, and FSAR Section 6.2.6.3 to provide claritications on the leak rate testing of valves pressurized with fluid from a seal system. These clarifications i

are consistent with 10CFR50, Appendix J, Paragraph III.C.3 and

-Standard Technical Specifications 4.6.1.2.d.3 and 4.6.1.2.g (NUREG-0452, Revision 4) . In addition, a specific example of the applicability of these clarifications is cited regarding containment penetrations P-28, P-29, P-71, and P-73 (essential 1 service water to/from containment coolers as depicted on FSAR Fig. 6.2.4-1). For these penetrations the water volume contained in the piping inside containment (from the cooler to the inboard

' isolation valve) provides a passive water seal on the affected valves (EF-HV-33,34,45, and 46 as shown on FSAR Fig. 9.2-2, sheet

2) . The water inventory insido containment is sufficient to assure the sealing function for at least 30-days at a pressure of 1.10 Pa (53 psig) when the leakage for each of these penetrations is less than or equal to 7500 cc/hr as stated in the revised bases for Technical Specification 3/4.6.1.2. This leakage acceptance criterion is being added to the. bases per 10CFR50,

' Appendix J, Paragraph II.C.3. (a) and Standard Review Plan 6.2.6 and is based upon the as-built piping configuration. The water volume from the air. cooler to the nearest containment isolation valve would be depleted in 30 days if the leakage rate were greater than 7641 cc/hr.

In addition this amendment request revises Technical Specification 3.4.9.3 limit ing condition for operation LCO (a) and Action' item (a). For LCO (a) the allowable tolerance on the RHR suction relief valves is being changed to + 3% rather than

+ 14. The + 1% tolerance was selected based on the tolerances t Tor the pressurizer code safety valves. To be consistent with the requirements of ASME Boiler and Pressure Vessel Code,Section III, Article NB 7513.1, a tolerance of + 3% is acceptable, as long as the maximum pressure allowed is less than the lowest pressure setting of the power operated relief valves (PORVs).

Also, Action item (a) as written is not consistent with the LCO as specified. The intent of the Specification is to give credit for the availability of the RHR suction relief valves for cold overpressure protection. In the Standard Technical Specifications (NUREG-0452) , Revision 4) , when relying on PORVs for cold overpressure protection, if one PORV becomes inoperable, seven days are allowed for restoring it or an action would be

required forJCallaway to open a two square inch vent. Regardless of the status of the PORVs, this same action should be applicable

~if Callaway loses one RHR suction relief valve while relying on RHR suction relief for cold overpressure protection.

Pursuant to the above information, this amendment request

'does not adversely affect or endanger the health of the general public and does not involve an unreviewed safety question.

ENCLOSURE B ULNRC-875 7/17/84 SIGNIFICANT HAZARDS CONSIDERATION This amendment request. revises Technical Specification 4.6.1.2,Iand its associated bases, and FSAR Section 6.2.6.3 to provide clarifications on the leak rate testing of valves pressurized with fluid from a seal system. These clarifications are. consistent with 10CFR50,' Appendix J, Paragraph III.C.3 and

, Standard Techrtical Specifications 4.6.1.2.d.3 and 4.6.1.2.g i ~(NUREG-0452, Revision 4) . Containment penetrations for essential service water supply to and return from the containment coolers satisty the sealed system exclusion allowed by 10CFR50, Appendix J,. Paragraph III.C 3..

In addition this amendment request revises Technical Specification 3.4.9.3 limiting condition for operation, LCO (a) and Action item (a) . The LCO is revised to make the allowable

-tolerance on'the RER suction relief valves consistent with ASME Boiler and Pressure Vessel Code,Section III, Article NB 7513.1.

DFurther,-Action item (a) is being modified slightly to make it consistent with the LCO as specified and consistent with the

' intent as given in the Standard Technical Specifications (NUREG-0452, Revision 4) .

'The Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain

' examples (48FR14870). This amendment request is similar to the example of an action involving no significant hazards consideration which relates to a change to make the license

. conform to regulations, where the license amendment results in

~

1 changes to facility operations clearly in keeping with the regulations.

This amendment request does not involve a significant increase-in.the probability or consequences of an accident or other adverse condition over previous evaluations; nor create the possibility of a new or different kind of accident or condition over previous _ evaluations; nor involve a significant reduction in a margin of safety.. Based on the foregoing, the requested amendment does not present a significant hazard.

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