ML20133F900

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Safety Evaluation Supporting Amend 8 to License NPF-30
ML20133F900
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/03/1985
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20133F898 List:
References
NUDOCS 8510150026
Download: ML20133F900 (4)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGUL'ATION SUPPORTING AMENDMENT NO. 8 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. STN 50-483

1.0 INTRODUCTION

By letter dated July 10, 1985, as supplemented by letter dated August 9, 1985 Union Electric Company (the licensee) requested an amendment to Facility Operating License No. NPF-30 for operation of the Callaway Plant in Callaway County, Missouri.

The amendrent approves modifications to Pages 3/4 3-10, 3-12, 3-33, 3-34, 3-37, 5-5, 6-13, 6-17, 7-11, 7-12, 8-4, and 8-10 of the Callaway Technical Specifications (TS). The amendment extends the initial 18-month surveillance interval for various surveillance tests until prior to startup following the first refueling outage or June 1,1986, which-ever occurs first. The first refueling outage is the next scheduled shutdown and is currently scheduled to begin in April 1986. This request entails an approximate six-month extension in the most limiting case. The affected surveillance intervals include manual initiations of the reactor trip system and engineered safety features actuation system (ESFAS), portions of diesel generator testing, ESFAS actuations on safety injection and loss of offsite power, containment spray actu-ation testing, Phase A and B containment isolations, and a Class 1E battery service test.

Normally, since refueling outages occur about every 18-months, extensions beyond the 18-month surveillance interval required by the technical spec-ifications for these items are usually rot necessary. However, due to the extended length of the plant startup program and Cycle 1, the licensee must either request an extension or be forced to shutdown prior to the first refueling outage.

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. 2.0 EVALUATION A.

Manual Initiations of the Reactor Trip System and Enginehred Safety Features Actuation System (E5FAS), E5FA5 Actuations on Safety Injection and Loss of Offsite Power, Containment Spray Actuation Testino, and Phase A and B Containment Isolations General Design Criterion (GDC)-21 of Appendix A to 10 CFR Part 50,

" Protection System Reliability and Testability," requires that pro-tection systems be designed to permit periodic testing during reactor operation. The licensing basis for Callaway Unit I related to GDC-21, as described in Section 7 of the plant's Final Safety Analysis Report (FSAR), is a method of periodic, overlapping tests of individual por-tions of the protection systems. These tests, incorporated into the plant's TS, encompass in a piecemeal fashion all equipment and inter-faces from sensors through final actuated equipment for each of the plant's protective systems.

In addition, inservice testing based on ASME Code Section XI, requires periodic operability testing of valves and pumps. The only protection system equipment not period-ically tested by these two means are those (identified in Section 7 of the plant's FSAR) which would cause plant upset or equipment damage.

The specific tests for which the licensee has requested surveillance interval extensions are whole system operational tests conducted every 18-months during plant shutdown. Since operability of most cf the individual components in those systems (for which the extensions are requested) is proven on a periodic basis (monthly or quarterly), the staff believes, based on the overlapping test method utilized, that sufficient proof of system functional capability is provided by the individual component tests to allow the requested surveillance interval extensions.

Further, system design features such as redundancy and diversity, including manual initiation of the systems and their individual components, provide alternate means to ensure protection system

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operability should an undetectable failure occur during the extended surveillance intervals. Accordingly, the staff fint's that the one-time extension of the surveillance intervals fo-the above tests are acceptable and that the provisions of TS 4.0.2 are reset from performance of the next surveillance.

B.

Portions of Diesel Generator Testing and a Class IE Battery Service Test Each diesel generator is tested (at least once a month) at ir,tervals determined by the number of failures in the last 100 valid tests as required by the TS. In addition, each diesel generator is tested every 18 months during shutdown. The diesel generator unit design and other operational features are extenalsely tested to ensure h

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3 their operability by timely failure detection and subsequent repair.

This, includes one of the design features which requires the diesel generator to make fast starts and automatically load from ambient conditions in the case of a large loss of coolant accident (LOCA) with loss of offsite power (LOOP).

Considering the following facts:

1.

Each diesel generator is tested at least monthly to demonstrate its operability and capability to assume load; 2.

The current test frequency of Callaway is once a month as there have been no diesel generator failures; 3.

The unit is more susceptible to transients when changing the operational modes (such as would be required to perform the subject testing) than while operating in a steady state condition; 4.

Unless there is a large break LOCA with LOOP, fast starting 6

of a diesel generator is not actually necessary to prevent severe core damage since emergency AC power is not needed for many minutes after initial event, thus manual actuation is possible; 5.

The chance of occurrence of an automatic diesel generator tfon as a result of an acc actug/RY)followedbyLOOP(10'jdent,i.e.,largeLOCA), for the duration of the (10-six-month period proposed is insignificant (f x 10 /RY).

The staff finds that the one-time extension of the surveillance inter-val for portions of diesel generator testing is acceptable and that the provisions of TS 4.0.2 are reset from performance of the next surveil.

2 lance.

The battery service test in question is a specific battery capacity, test which demonstrates if the battery will meet the design requirements of the DC system. It is performed as part of the preoperational and periodic DC system tests every 18 months or whenever there is any DC system change. Although it is possible to perform this test during plant operation, it would take the battery out of service much longer than the two hours which is permitted under the existing TS (during plant operation) and is therefore, undesirable.

It is for this reason that such tests as the service test and performance discharge tests should be perfonned during shutdown. The licensee stated that those two tests were performed in conjunction with the preoperational test on February 9, 1984 They found that the battery capacities were approximately 10% above the acceptance criteria. In view of the fact that their batteries are relatively new, no substantial loads have been added to the batteries, and each battery has been tested weekly and quarherly for electrolyte level, float voltage, specific gravity, terminal voltage and terminal corrosion, the licensee contends that the performance of the above surveillance provides a means of identifying i

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potential failures such as no output or inadequate output due to sudden i

degradation. Therefore, they conclude that the probability of an un.

detected inoperable battery is considered minimal for the duration of I

the extended surveillance interval. The staff concurs with the licensee

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and finds that the one-time extension of the surveillance interval for i

this battery service test is acceptable and that the provisions of TS r

i 4.0.2 are reset from performance of the next surveillance, f

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change in the installation or use of a facility 2

component located within the restricted area as defined in 10 CFR Part 20.

The staff has determined that the amendment involves no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Counission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment l

on such finding. Accordingly, this amendment meets the eligibilit crf-teria for categorical exclusion set forth in 10 CFR Section 51.22(y)(9).

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Pursuant to 10 CFR 51.22(b), no environmental impact statement or environ-nental assessment need be prepared in connection with the issuance of i

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this amendment.

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4.0 CONCLUSION

We have concluded, based on the considerations discuswo above, that:

(1) there is reasonable assurance that the health and safety of the j

public will not be endangered by operation in the proposed manner; and (2) such activities will be conducted in compliance with the Connis-4 i

Sion's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and 2

safety of the public, i

Principal Contributors:

i F. H. Burrows, ICSB P. Kang, PSB

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T. W. Alexion, LB#1 i

j Dated:

OCT 3 1985 l

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