ML20116L009

Proposed Tech Specs Consisting of Proposed Change,Revising TS 3/4.9.7,to Allow Fuel Pool Transfer Gates to Travel Over Fuel Assemblies in SFP for Refueling Activities,Fuel Handling Sys Maintenance & Transfer Gate Seal Replacement

ML20116L009
Person / Time
Site:	Callaway
Issue date:	11/10/1992
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20116K991	List: ML20116K987 ML20116L009
References
NUDOCS 9211180132
Download: ML20116L009 (16)

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Attachment 1 l

-l L4arksd-up Technical Specification Pages ,

Page 3/4 9-8 Page B 3/4 92 i

9211180132'921110 '

PDR AD'CK d 05000403 P PDR

R(rULLINO OPfRATIONS u.y CW 3'" REVISlay j .

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3/,4.9./ CHANI TRAVLL * $PLNI IUEL $10RACF F ACILITY dhlilNC CONDl110N F0u OPFRATION __

3.9.7 Loads in escess of 22$0 pounds shall be ptthibited from travel over f uel assemblies in the spent fuel storage !ccility y excegf f,,. j.ke rpnY APPLICABILITY: With fuel asseAblies in the spent fuel storage f4cility.

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a. Wiih the requirements of the above specification not satisfied, place the crane load in a safe condition.

h. lhe provicions of Specifications 3.0.3 and 3.0.4 are not ap icable.

NllRVE 1Lt ANCE RE0thWEMENTS ,

4.9./ CrAnv interlocks and physical stops which pre nt rane travel With fy? 104:15 in excess of 2250 pounds over fuel assembli shall be detsonstrated s jl, . OPLRABLL within / days prior to crane use and' least once per 7 days '. /

thereafLer cluring crane operation.

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A L') CAIIAWAY - UNIi 1 3/4 9-B . >-

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4 REFUELING OTEUTIONS ELSES 3/a.9.6 REFUELING MACHINE

- The OPERABILITY recuirements for the refueling machine and auxiliary hoist ensure that: (1) manipulator cranes will be used for movement of drive rods and fuel assemblies. (2) each crane has sufficient load capacity to lift a drive rod or fuel assembly, and (3) the core internals and reactor vessel are protected from excessive lif ting force in the event they are inadvertently engaged during lifting operations.

3/4.9.7 CRANE T UVEL - SPENT FUEL STO UGE FACILI~Y The restriction on movemen*, of loads in excess of the nom 4nal weight of a fuel and control rod assembly and associated handling tool over other fuel assemblies in the storage pool areas ensures that in the event this lead is

. dropped: (1) the activity release will be limited to that contained in a single fuel assembly, and (2) any possible distortion of fuel in the storage racks will not result in a critical array. This assumption is consistent with the activity release assumed in the safety analyses.

~h.r$Teer 3/a.9.8 RESIDUAL A HEAT REMOVAL AND C001. ANT CIRCULATION, The requirement that at least one re'sidual haat removal (RHR) loop be in operation ensures that: (1) sufficient cooling capacity is available to remove

, ,.) decay heat and maintain the water in the reactor vessel below 140'F as required during ti e REFUELIN3 MODE, and (2) sufficient coolant circulation is maintainee through the core to minimice the effect of a boron dilution incident anc prevent bron stratification.

The requirement to maintain a 1000 gpm flowrate ensures that there is

• adequate flow to prevent boron stratification. The RHR flow to the RCS will provide adecuate cooling to prevent exceeding 140*F and to allew flowrates whic. provice adcitional margin against vertaxing at the RHR pump suction while in partial drain operation.

The requirement to have two RHR locos OPERABLE when there is less than 23 feet of water noove the reactor vessei flange ensures that a single f ailure of the operating RHR loop will not result in a complete less of resicual heat removal capability. With the reactor vessel head removed and at 1ctst 23 feet of water above the reactor vessel flange, a large heat sink is available for core cooline. Thus, in tne event of a failure of the operating RHR loop, adequate tioe is provided to initiate emergency procedures to cool the core. .

3/a.9.9 CONTAINY.ENT VENTILATION SYSTEM The OPEPABILITY of this system ensures that the containment ourge cenetra-tions will be automat'.cally isolated upon detection of high radiation levels within the ccntainment. The OPERABILITY of th'.s sys tem is required to restrict the release of radioactive material from the containment at.ncspnere to tne environment.

CALLAWAY - UNIT 1 5 3/4 g-2 Amencment No. 42 j I

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4 IllSERT A The spent fuel pool transfer gates are excluded from this restriction becauso with a limited gate lift height, the spent fuol pool racks will absorb the impact of a dropped gate without damage to fuel assemblies. In addition, redundant trolleys and supports are used when moving the gatos to preclude dropping a gato on the spent fuel racks, the time and distance the gates are moved over fuel is minimized as much as practical, and gate travel over fuel assemblies containing RCCAs is prohibited. The spent fuel pool transfer gates are o@r moved for refueling activities, fuel han('.irg system maintenance, and to change gate seals.

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-- Attachment 2 Eg typed Technica?. Specification Pages w Paga 3/4 9-8 Page B 3/4 9-2 Page B 3/4 9-3 sQ 4'

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EEEUEUNG3fEBATl0JiS 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE-. FACILITY >

LIMITING CONDITION FOR OPERATION t

3.9.7 Loads in excess of 2250 pounds shall be prohibited from travel over feel i assemblies in the spent fuel storage f acility, except for the spent fuel pool transfer gates which may be moved over fuel assemblies in the spent fuel pool fcr refueling. ,

activities, fuel handling system maintenance, and transfer gate seal replacement.

APPLICABlLLIX: With fuel assernblies in the spent fuel storage f acility.

A.CITION:

a. V. th the requitements of the aoove specification not satisfied, place the crane load in a safe condition,

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b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

I SURVEILLANCE REQUIREMENTS

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e.9.7 Crane nterlo%s and physical stops which prevent crane travel with loads in excess of 2250 pounds over fuel assemblies shall be demonstrated OPERA 5LE within 7 days prior to crane use and at least once per 7 days thereaf ter during crane operation.

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_' CALLAWAY - UNIT 1 3/4 9-8

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• FEEURINEOPERATIONS-BASES MAQ,J1EFUELING MACHINE The OPERABILITY requirements for the refueling machino and auxiliary hoist 1 onsure that: (1) manipulator cranos will be used for movement of drive rods and fuel-

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assemt/nes, (2) each crane has sefficient load capacity to lift a drive rod or fuel -!

assembly, and (3) the core internals and reactor vessel are protected from excessive -

lif ting force in the event they are inadvertendy~en_ aged during lif tir ,perations. '

MJ1 CRANE TRAVEL - SPENT FUEL STORAGE FACILITY The restra uon on movement of loads in excess of the nominal weight of a fuel .

and control rod assembly and associated handling tool over other furt assemblies in the storage pool areas ensures that in the ovent this load is dropped: (1) the activity - '

release will be limited to that contained in a angle fuel assembly, and (2) any possible -

distortion of fuel in the storage racks will not result in a cr!tical array. This a :sumption-is consistent with the activity release assumed in the safety analyses.

a spent fuel pool transfer gates are excluded from this restriction because with a tmNd gato lif t height, the spent fuel pool racks will absorb the impact of a dropped gate without damage to fuel assemblies, in addition, redundant trolleys and supports .

are used when moving the gatos to preclude dropping a gate on the spent fuel racks, the time and distan;e tha gates are moved over fuelis minimized as much as practical, and gate travel over fuel assemblies containing RCCA- is pruhibited. The spent fuel L poi transfer gates are only moved for refueling activities, fuel hand e ig system meintenance, and to changs nato seals.

3/4.9.8 RESIDU/LL_H_ FAT REMOVAL ANL C_OOLANT CIRCULATION The requirement that at least one resictal heat removal (RHR) loop be in operation- .

ensures that: (1) sufficient cooling capacitt is available to removo decay heat and

_ maintain the water in the reactor vessel bdow 140 F as required during.the REFUELING MODE, and (2) sufficient coolant circulation is maintained through the core to minimize the effect of a baron dilution incident and prevent boron stratification. 1 l- _ _

i L The requirement to maintain a 1000 gpm flov, sta ensures that there is adequate-l flow to prevent boron stratification. The RHR flow to the RCS will' provide acequate coolHg to prevent exceeding 140 F and +, allow flowrates which provido additional margin against vortexing at the RHR pump ouction while in partial drain operation.

J The requirement to have two RHR loops OPERABLE when there is less than 23:

feet of water above the react.or vessel flange en >ures that a single faa ure.of the : '

operating RHRloop 'will not result in a complete loss of residual heat removal capabili_ty. With the reactor vessel head removed ar j at least 23 feet of water above

- the reactor vessel flange, a large heat sink is available for core cooling; Thus,--in the event of a failure of the operating RHR loop, adequate time is provided to-initiate emergency procedures to cool the core.

-CAli AWAY - UNIT 1. _. B 3/4 9-2 Amendment No. 42 T

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. BEFUElitROEERATlONS:

BASES'

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' 314.9.9' CONTAINMENT VENTILATION SYSTEM T The OPERABILITY of this system ensures that the containment purge penetrations will be botomatically isolated upon detection of high radiation levt.!s within the i containment. The OPERABILITY of this system is required tolrestnct the release of radioactive material from the containment atmosphere to the environment.

3/4.9.14 and. 314.9.11- WATER LEVEL REACTOR VESSFJ. and STORAGE POOL The restrictions on minimum water level ensure that sufficient water depth is

,. available to remove 99% of the assumed 10% iodine gap activity released from the rupture of an irradiated fuel assembly. The minirnum water depth is consistent ' wit -

the_ assumptions of the safety analysis.

3 /4.9 u 1_2 SPENT FUEL ASSEMBLY STORAGE Thu restrictions placed on spent fuol assemblies stored in Region 2 of the spent fuel pool ensure inadvertent criticality will not occur.

, 3/4.9.13 EMERGENCY EXHAU.S_T_S1SIF,M -y Th9 limitations on tha Emergency Exhaust System ensure that all radioactive -

materials released from an irradiated fuel assembly will be filtered through the HEPA fUters and charcoal adsorber prior to discharge to the atmospherei Operation of tho . '

system with the heaters operating to maintain low humidity using automatic contiol for at least 10 cmtinuous hours in a 31-day period _is sufficient to reduce the bui: dup of moisture on the adsorbers and HEPA filters. The OPERABILITY of this system and' the resulting iodine removal capacity are consistent-with the assumptions of the safety ,

analyses. ANSI N510-1975 will be used as a crocedural guide for surveillance ;esting.'- .

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.i Attachment 3 ,

Nuclear Safety Evaluation

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i Page l.of:3 SAFETY EVALUATION ThisLamendment application requests a change to-Technical Specifications (T/S).3/4.9.7 on erane-Travel-Spenc Fuel Storage Facility and its associated Bases. This specification is revised to allow-for movement of_the transfer gates over i fuel assemblies in the spent fuel pool for plant refueling,_

fuel transfer system maintenance, and for transfer-gate' seal replacement.

Background

The spent fuel storage facility is located within the fuel building and provides onsite' storage for spent fuel elements.

Spent fuel storage racks are located in the spent fuel pool, ahich is constructed of reinforced concrete with a' stainless. ,

steel lining and is an integral part of the tuel building. ,

7 The spent fuel pool provides a cooling and shielding medium-for the spent fuel. The facility provides protection for spent fuel assembl.4as'under conditions such as tornadoes,.  ;

earthquakes,_and-flooding and provides an efficient method-for safe and reliable 'uel handling operat:.ons within the spent  ;

fueltpool.  :

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Adjacent to the, spent fuel pool are tao small-pools and a warhdown pit. One pool is the fuel transfer canal-which is=

connected to the refuelinb pool by.the_ fuel transfer tube. A leaktight gate is provided to separate the spent fuel pool and the fuel transfer canal. This allows the fuel transfer canal ~

to be drained for maintenance of the fuel transfer system ,

mechanism.

The-second pool is the spent fuel-~ shipping cask loading pit.

It is: designed for loading spent-fuel; assemblies'intoispent .*

fue; _shippingicasks-and provideuLafmeans'for moviuq newffuel into the spent _ fuel pool. A-l'eaktight-gate is;prcvided to _

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~ '"J separate the spent fuel pool (from the_ cask loading pit infthet

-event.that the cask loading pitais drained.' ,;

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Both transfer gates'must be moved forJfuel1 handling operati.ons:

associated with the. plant: refuel to take' place ~,Jfor maintenance on the fuel handling system, and forigate:seall

replacement. .However, these gates-each weighJapproximately ,

5200 pou.nds'and a strict interpretation of'T/S 3/4.9.7E(whichi prohibits'trasel_of loadslin excess of 2250 pounds over fueli  !

Lassemblies)-~.wodd not-permit.these gates to be1 moved. This.

Lcould cause a technical specificatior compliance. situation Mue 3' to_a:poter.tiallinability;to meetLT/S 3/4.9.7.

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-Proposed ~ Change l 1ThisMamendmentiapplication-requests'a. revision to Technical; ~ M

-Specification-LCO 3.9.7 to allow the'spentLfuel: pool transfer-

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- gates to-be moved over fuel essemblies in the. spent ruel' pool.

Bases 3/4.9.7 is revised to include discussion:which. details 1the controls used when moving transfer gates.

SaLety_Analysia

- Revising T/S 3.9.7 to permit' movement of1the-transfer gates.

R over fuel assemblies-in-the spent fuel pool does not impact- >

plant safety because:

1) Testing and analysis of the racks shows they_can-absorb l energy equivalent to dropping a gate from a height of 15 inches with no fuel damage occurring. Since administrative controls are used at Callaway to limit gat.

lift height to less than 12 inches and redundant slings are used hen moving the transfer gates, a gate drop is L enveloped by the fuel handling accident as discussed in L Chapter.15 of'the Callaway FSAR. ,

2) The distance from the installed-location of the transfer.

gates to their storage locations is approximately 6 feet.

The storage locations are located adjacent to the in .alled locations so the time a gate may be' suspended over fuel is very short.-

3) , Gate seal' replacement only occurs every 5 to 6 years.

When the gates are .vvedifor seal replacement, redundant slings are utilized and lift height is limited to 12.

inches. ,

4) Any items stored in fuel assemblies-which may stick up above the fuel racks, such as RCCAs, are avoided.

. 5) NRR reviewed and approved the-Callaway positi'on on use of the spent fuel pool-bridge crane in Callaway. Safety -

Evalmation-Report, Appenoix H (NUREG-0830, Supplement No. 3). As discussed.:in thisl document,.Callaway'uses;a

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redundant support (sling) -when moving the gatescto;

-preclude _ dropping:a1 gate on the spent fuel racks. This position was found to' satisfy-the criteria of NUREG 0612 by NRC. ,

, . Evaluation

-The proposed change to Technical Specification'3/4.9.7.does not-involve an unreviewed safety. question because operation'of the Callaway Plantcwith-this change 1would not:

1. Increate the probability:of occurrence or_the_ consequences of an accident or. malfunction =of equipment ^importaut to .

safety previously evaluated in the safety analysis report.

There is no increase in.the probability'of. occurrence:or-

the consequences of-an accident.previouslyoevaluatediini  ;

theisafety analysis report. -The' fuel racks.are'ablesto-O n Y en e -n r 4 --e - ,e 4 1

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.j withstand a'transfet' gate drop'from-15 inches above the' racks with no damage.to stored ruel. ]  :

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2. - Create a possibility _ for an accident Ror raalfunction of a1 different type than any previously evaluated 11n the safety _

analysis report. .This change revises the Technical Specifications to allow for transfer gate movement-to

-support plant refueling activities,-fuel handling system maintenance, and- replacement of gate seals.. The Technical' Specifications and adm.nistrative controls will assure that the transfer gates will not be dropped-on the'racke in a manner which car damage _ fuel. Therefore, there is ao new type of accident or malfunction created.

3. Reduce the margin of safety as defined in theLbasis_for ,

any Technical Specification. Technical Specificaticns and  :

administrative controls will assure that the gatas'will not be dropped on the racks in a manner which can _ dartige ' .

fuel. Therefore, no margin of cafety as defined in the basis for any technical specification has been reduced.

Given the above discussions as well as those presented in_the Significant Hazards Evaluation, the proposed. change does not adversely af fect or endanger the health ore Lafety of the general public or involve a significant safety hazard.

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SIGNIFICANT HAZARDS ~NVALUATION

'This amendment application requests a-revision-to Technical" Specification 3/4.9.7 and its assodiated Bases. 'This E _

specification-is revised to allow movement-ofLthe transfer gates over fuel acsemblies in the spent fuel _ pool for plant refueling. activities, for fuel handlirg system maintenance, and for replacement of the transfer gate seals.

The proposed change does not involve a significant nazards consideration because operation of Callaway ?lant with this change would not:

1. Involve a significant increase in the probability or consequcnces of an accident previously evaluated. The

Callaway Safety-Analysis Report has been reviewed anc beenn E found to be unaffected by this proposed change. The-O design of tha plant assumed gate movement to support. plant-refuel and fuel; handling system maintenance. Allowing _-

gate movementLover the spent fuel pool will not increase the consequences of any accident or malfunction of "

equipment since the fuel racks have been sh wn tc ' e able-L to withstand a transfer gate drop from 15 inches above the- q racks.with-no damage to1 stored fuel.

2 ' eate-the possibility of a_new or different kind of ident from-any previoucly evaluated. Technical-p c1 cifications.and administrative controls.will assure 1 L that'the transfer gates will not be dropped-on the racks L in a manner which ca. damage fuel. Therefore,,there is no.

new type of accident or malfunction created.

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3. Involve a significant reduction Lin a margin 'of safety.-

The margin of_ safety remains unaffected eince'the Technical Specifications!and-administrative controla will1 assure _that the__ gates;will not:be dropped on:the racksfi n a manner which:can damage fuel.

Asfdiscussad above, the-proposed change does not involvela significant increase in.the probability or consequences of:an-accident previously evaluatedcor-create the possibilityfof al 0 new or_ dif ferent kind of 1 accident: fronianyLpreviously evaluated. 'This. change:does.not resultfin ajsignificant reduction in'a margin of safety. Therefore,.it has been-

-determined that the.proposedichange does'not' involve ~a- ~

- - .significant hazardt . ons'idera tion . ' q M

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Environmental Consideration t

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. Page 1-of 1 ElBLM01MENTAh COtMIDERATlf1N

- This amendment application requests a revision to Technical c

Specification (T/S) 3/4.9.7 and associated Bases to allo" for movement of the spent fuel pool transfer gates over fuel assemblies in the spent fuel pool The proposed amendment involves changes with respect to the use of facility components located within the restrictea areas as defined in 10 CFR Fart 20. Union Electric has determined ,

that the prop ned amendment i; M ves no significant increase in the amounts, and no eignificant change in the types, of any ,

effluents that may be released offsite and that there is no ~

significant increase in individual ce cumulat9ve occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria fur categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Pursuant to 10 CFR 51.22 (b) no "

environmental impact statement or environiaental assessment need be prepared in connection with the issuance of this ameadment.

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