Text

Issuance of Amendment No. 188, Revise TS 3.4.10, Pressurizer Safety Valves, to Adopt TSTF-247-A, TS 3.4.11, Pressurizer Power Operated Relief Valves, and TS 3.4.12 to Adopt TSTF-352-A
	ML082910895
Person / Time
Site:	Callaway
Issue date:	11/25/2008
From:	Donohew J; Plant Licensing Branch IV
To:	Heflin A; Union Electric Co
	Donohew J N, NRR/DORL/LPL4, 415-1307
References
	TAC MD7515, TAC MD7516
	Download: ML082910895 (20)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 November 25, 2008 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 -ISSUANCE OF AMENDMENT RE: ADOPTION OF INDUSTRY TRAVELERS TSTF-247-A AND TSTF-352-A (TAC NOS. MD7515 AND MD7516)

Dear Mr. Heflin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 188 to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1.

The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 29, 2007 (ULNRC-05459).

The amendment revises TS 3.4.10, "Pressurizer Safety Valves," TS 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)," and TS 3.4.12, "Cold Overpressure Mitigation System (COMS)," to adopt Nuclear Regulatory Commission (NRC)-approved TS Task Force (TSTF) travelers to the Standard TSs TSTF-247-A and TSTF-352-A.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

1. Amendment No. 188 to NPF-30

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 188 License No. NPF-30

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Union Electric Company (UE, the licensee),

dated November 29,2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regUlations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-30 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan*

The Technical Specifications contained in Appendix A, as revised through Amendment No. 188 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.

This amendment is effective as of its date of issuance, and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-30 and Technical Specifications Date of Issuance:

November 25, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 188 FACILITY OPERATING LICENSE NO. f\\lPF-30 DOCKET NO. 50-483 Replace the following pages of the Facility Operating License No. NPF-30 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License REMOVE INSERT

-3

-3 Technical Specifications REMOVE INSERT 3.4-19 3.4-21 3.4-23 3.4-27 3.4-19 3.4-21 3.4-23 3.4-27

- 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. 188 and the Environmental Protection Plan contained in Appendix 8, 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 188

Pressurizer Safety Valves 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Pressurizer Safety Valves LCO 3.4.10 Three pressurizer safety valves shall be OPERABLE with lift settings

~ 2411 psig and::; 2509 psig.

APPLICABILITY:

MODES 1, 2, and 3, MODE 4 with all RCS cold leg temperatures> 275°F.

NOTES -------------------------------------------

The lift settings are not required to be within the LCO limits during MODES 3 and 4 for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. This exception is allowed for 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months following entry into MODE 3 provided a preliminary cold setting was made prior to heatup.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One pressurizer safety valve inoperable.

A.1 Restore valve to OPERABLE status.

15 minutes B.

Required Action and associated Completion Time not met.

OR Two or more pressurizer safety valves inoperable.

B.1 AND B.2 Be in MODE 3.

Be in MODE 4 with any RCS cold leg temperature::; 275°F.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 24 hours CALLAWAY PLANT 3.4-19 Amendment No. 188

3.4.11 Pressurizer PORVs 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

NOTE -~---------------------------------------------------------

Separate Condition entry is allowed for each PORV and each block valve.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more PORVs inoperable solely due to excessive seat leakage.

A.1 Close and maintain power to associated block valve.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B.

One PORV inoperable for reasons other than excessive seat leakage.

B.1 AND B.2 AND B.3 Close associated block valve.

Remove power from associated block valve.

Restore PORV to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued)

CALLAWAY PLANT 3.4-21 Amendment No. 188

3.4.11 Pressurizer PORVs ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

More than one block valve inoperable.

NOTE ------------------

Required Action F.1 does not apply when block valve is inoperable solely as a result of complying with Required Action B.2 or E.2.

F.1 Restore one block valve to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months G

Required Action and associated Completion Time of Condition F not met.

8.1 Be in MODE 3.

AND 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 8.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CALLAWAY PLANT 3.4-23 Amendment No. 188

3.4.12 COMS ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and associated Completion Time of Condition C not met.

D.1 OR D.2 Increase all RCS cold leg temperatures to

> 275°F.

Depressurize affected accumulator to less than the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours E.

One required RCS relief valve inoperable in MODE4.

E.1 Restore required RCS relief valve to OPERABLE status.

7 days F.

One required RCS relief valve inoperable in MODE 5 or6.

F.1 Restore required RCS relief valve to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months G

Two required RCS relief valves inoperable.

OR Required Action and associated Completion Time of Condition A, B, D, E, or F not met.

OR COMS inoperable for any reason other than Condition A, B, C, D, E, or F.

G1 Depressurize RCS and establish RCS vent of

~ 2.0 square inches.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CALLAWAY PLANT 3.4-27 Amendment No. 188

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 188 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

By application dated November 29, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073460060), Union Electric Company (the licensee) requested changes to the Technical Specifications (TSs) for Facility Operating License No.

NPF-30 for the Callaway Plant, Unit 1 (Callaway). The licensee is proposing to revise TS 3.4.10, "Pressurizer Safety Valves," TS 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)," and TS 3.4.12, "Cold Overpressure Mitigation System (COMS)" to modify the completion times (CTs) for default conditions in these TSs, allow separate condition entry for PORV block valves in TS 3.4.11, and delete a required action to place the associated PORVs in manual control.

The licensee stated in its application that it is adopting the following two Nuclear Regulatory Commission (NRC)-approved TS Task Force (TSTF) travelers to the Improved Standard TSs (ISTS): TSTF-247-A, "Provide Separate Condition Entry for each PORV and Block Valve," and TSTF-352-A, "Provide Consistent Completion Time to Reach Mode 4." The ISTS for Westinghouse plants (WISTS), like Callaway, is NUREG-1431, "Standard Technical Specifications for Westinghouse Plants," Revision 3.1. The Callaway TSs are based on NUREG-1431.

The purpose of the license amendment request (LAR) is the following:

(1)

Extend the CT to perform a safe and orderly shutdown, for when a pressurizer safety valve has been inoperable for more than 15 minutes or more than one pressurizer safety valve is inoperable, in TS 3.4.10.

(2)

Allow separate condition entry for PORV block valves in TS 3.4.11 to provide more flexibility to the licensee when operating with more than one inoperable block valve.

When there is more than one inoperable valve, this allows each inoperable valve to have the CT from the time the valve becomes inoperable instead of requiring that all the valves together have the CT from the time the first valve became inoperable.

- 2 (3)

Extend the CT to plan and execute the activity to depressurize the reactor coolant system (RCS) and establish an RCS vent, for multiple conditions whereby the COMS is inoperable, in TS 3.4.12.

The design of the pressurizer safety valves and PORV block valves, and the COMS are not being changed by the LAR; however, the CTs for required actions to address inoperability of these systems and components are being extended. Also, separate condition entry for the PORV block valves and the deletion of an unnecessary required action are being proposed.

The licensee provided its TS Bases changes for the proposed changes to the TSs. These changes were presented for information only because these changes are controlled through TS 5.5.14, "Technical Specification (TS) Bases Change Program." Although the NRC staff does not approve these changes, the staff reviews the changes to ascertain whether the changes are technically correct or not.

2.0 REGULATORY EVALUATION

In Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36), the Commission established its regulatory requirements related to the content of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs);

(4) design features; and (5) administrative controls. The rule does not specify specific requirements for items (1) through (5) in a plant's TSs.

As stated in 10 CFR 50.36(c)(2)(i), LCOs are "the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications..." The remedial actions in the TSs are specified in terms of LCO conditions, required actions, and CTs, or allowed outage times (AOTs), to complete the required actions. When an LCO is not being met, the CTs specified in the TSs are the time allowed in the TSs for completing the specified required actions. The conditions and required actions specified in the TSs must be acceptable remedial actions for the LCO not being met, and the CTs must be a reasonable time for completing the required actions while maintaining the safe operation of the plant.

Since the pressurizer safety valves, PORVs and PORV block valves, and the COMS are not being changed by the proposed amendment and only the remedial actions for inoperable systems or components are being changed, none of the General Design Criteria for nuclear power plants in Appendix A to 10 CFR Part 50 apply to the proposed amendment.

3.0 BACKGROUND

The LAR involves the pressurizer safety valves, the pressurizer PORV block valves, and the COMS. The licensee addressed the safety function and design of these valves and the COMS in its application.

- 3 The safety function of these valves and the COMS is pressure relief for the RCS to prevent overpressurization of the RCS. Overpressurization protection is required in Modes 1 through 6 with the reactor vessel head on the vessel.

The pressurizer safety valves are designed to prevent the RCS pressure from exceeding the pressure safety limit of 2735 psig (pounds per square inch guage), which is 110 percent of the design pressure for the RCS including the reactor pressure vessel. They are required to be operable in Modes 1 through 3 and in Mode 4 where the RCS cold leg temperatures are above 275 degrees Fahrenheit (F).

The pressurizer also has PORVs for pressure relief of the RCS. Although the safety valves operate only automatically to the pressure setpoints of the valves, the PORVs can be manually controlled from the control room. The block valves are used to isolate the PORVs. This is done to stop excessive through a PORV seat or stuck open PORV to stop RCS depressurization and coolant loss.

The COMS provides RCS overpressure protection at low reactor temperatures so the RCS meets the pressure and temperature safety limits in Appendix G, "Fracture Toughness Requirements," of 10 CFR Part 50, which are based on the RCS pressure boundary material have less toughness and provide less resistant to pressure stress at low temperatures.

The design of the pressurizer safety valves and PORV block valves, and the COMS are not being changed by the LAR; however, the CTs for required actions to address inoperability of these systems and components are proposed to be extended.

4.0 TECHNICAL EVALUATION

4.1 Proposed Changes to the TSs In its application, the licensee proposed the following changes to TS 3.4.10, TS 3.4.11, and TS 3.4.12:

1.

The CT for Required Action B.2 in TS 3.4.10, to place the plant in Mode 4 with any RCS cold leg temperature less than or equal to 275 degrees F, is extended from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The required action is not changed.

2.

The !'Jote for the Actions in TS 3.4.11 is extended to also allow separate condition entry for each PORV block valve.

3.

Required Action F.1 in TS 3.4.11, to place the associated PORVs in manual control for more than one PORV block valve inoperable, and its associated CT are deleted. The Note for this required action is corrected to account for the deletion of Required Action F.1, and Required Action F.2 is re-numbered.

4.

The CT for Required Action G.1 in TS 3.4.12, to depressurize the RCS and establish an RCS vent, is extended from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The required action is not changed.

- 4 4.2 Extend CT for Required Action B.2 in TS 3.4.10 The licensee stated in the application that the pressurizer safety valves, in conjunction with the reactor trip system, provide overpressure protection for the reactor coolant system (RCS) and overpressure protection is required in reactor Modes 1 through 6 when the reactor vessel head is on the vessel. For Modes 1 through 4 down to an RCS cold-leg temperature above 275 degrees F, overpressure protection is provided by the pressurizer safety valves in TS 3.4.10.

For Mode 4 at or below an RCS cold-leg temperature of 275 degrees F, and Mode 5 and 6 with the vessel head on, overpressure protection is provided by operating procedures and the CaMS in TS 3.4.12.

In TS 3.4.10, for the required action and CT of Condition A (one pressurizer safety valve inoperable) or two or more pressurizer safety valves inoperable, the required actions are the following:

B.1: Be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and B.2: Be in Mode 4 with any RCS cold leg temperature less than or equal to 275 degrees F within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The current CT of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Required Action B.2 is for a normal shutdown from Mode 1 to Mode 4 << 350 degrees F); however, for TS 3.4.10, the plant is required to in Mode 4 at or below the CaMS arming temperature of 275 degrees F.

The 275 degrees F is 75 degrees below the temperature for entry into Mode 4. The licensee stated that the additional time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is needed to reduce the temperature to no more than 275 degrees F in a safe and controlled manner.

The times for a normal orderly shutdown of a plant are given in LCO 3.0.3 in the TSs.

LCO 3.0.3 applies to when an LCO is not met and the associated LCO actions are not met, and a further action is not provided, or if directed by the associated required actions, the unit shall be placed in a mode or other specified condition in which the LCO is not applicable. In this case, the licensee is directed to initiate actions within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, and then place the unit (1) in Mode 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months , (2) in Mode 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , and in Mode 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . Removing the 1-hour period for the licensee to start actions to shut down the unit, entry into Mode 3 is required to be within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; into Mode 4, in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; and into Mode 5, in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . On this basis, there is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the unit to be taken from entering Mode 4 to entering Mode 5. Since Mode 4 is an average RCS temperature between 200 and 350 degrees F and Mode 5 is 200 degrees F or below, the orderly and safe shutdown in LCO 3.0.3 allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to go from 350 degrees F (entry into Mode 4) to 200 degrees F (entry into Mode 5).

The licensee stated that the proposed CT was taken from TSTF-352-A. In this TSTF, it is stated that the following CTs present the allowed times for attaining various shutdown conditions from Mode 1 at normal operating temperature and pressure: Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , which is consistent with what is stated in the previous paragraph. It is

- 5 further stated that many required actions in the TSs specify entry into conditions which take longer to achieve than Mode 4, but allow only the normal 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to enter the those conditions.

Required Action B.2 is such a required action. Other required actions allow 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months for similar circumstances. This 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months leaves insufficient time to reach the required condition that is at lower temperature than entry into Mode 4. Therefore, for those conditions, the CT is revised to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (midway between the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to entry Mode 4 and the 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to enter Mode 5) to provide a consistent adequate CT. TSTF-352-A identifies the same Required Action B.2 that the licensee has proposed to extend the CT. In a conference call on October 16, 2008, the licensee stated that this basis in TSTF-352-A for the proposed CT of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is the same basis that it used to propose the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Based on this evaluation, the NRC staff concludes that the proposed extension of the CT for Required Action B.2 is reasonable since the condition to be reached by the required action is 225 degrees F (Le., 500 - 275 = 225) below the temperature for entry into Mode 4. The licensee can meet the current requirement because it had not proposed to change the CT until the current application. However, the NRC staff concludes that it is reasonable to provide the additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to allow for the fact that the condition to be reached in Required Action B.2 is a significant temperature less than the temperature for entry into Mode 4. Based on this, the NRC staff further concludes that the proposed CT of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the Required Action B.2 is acceptable and meets 10 CFR 50.36.

4.3 Extend TS 3.4.11 Note to Allow Separate Condition Entry for PORV Block Valves Currently, the note in TS 3.4.11 allows separate condition entry for each PORV, where LCO 3.4.11 requires each PORV and associated block valve is operable. This allows each PORV to be treated separately with there being a separate CT for each inoperable PORV.

The proposed change to add the PORV block valves to the note will allow the PORV block valves to be treated as separate entities with a separate CT for each inoperable PORV block valve. This is consistent with the note in TS 3.4.11 on PORVs in the WISTS.

The revised note would allow each inoperable PORV block valve to have a separate CT from the time the PORV block valve was discovered to be inoperable. Therefore, the action condition for an inoperable PORV block valve would be entered separately for each inoperable valve, and the CTs would be tracked on a per valve basis. When a PORV block valve is declared inoperable, TS 3.4.11 Condition C is entered and the CT for that valve starts. If subsequent valves are declared inoperable, Condition F is entered for each valve and separate CTs start and are tracked for each valve. If the CT associated with a valve in Condition C expires without meeting the required action, Condition 0 is entered for that valve. If the CTs associated with subsequent valves in Condition C expire, Condition 0 is entered separately for each valve and separate CTs start and are tracked for each valve. If a valve that caused entry into Condition 0 is restored to operable status, Condition 0 is exited for that valve. Since the proposed note in WISTS 3.4.11 would allow multiple condition entry and tracking of separate CTs, CT extensions in accordance with SR 3.0.2 do not apply.

The proposed change to the note in TS 3.4.11 is simply extending the separate condition entry for the PORVs in the current TSs to the PORV block valves. This is treating the PORV block valves in the same manner as the PORVs. Since the PORV block valves are being credited as

- 6 backup valves to the PORVs, the NRC staff concludes that this proposed change is acceptable and meets 10 CFR 50.36.

4.4 Delete Required Action F.1 in TS 3.4.11 In its application, the licensee proposed to delete Required Action F.1 in TS 3.4.11. This required action is for the condition of more than one block valve inoperable and requires that the associated PORVs for the inoperable block valves is placed in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

The licensee stated that this deletion will remove an unnecessary, redundant requirement since separate condition entry for each block valve means that Required Action C.1 would apply to each inoperable block valve at the time of condition entry and would require its corresponding PORV be placed in manual control.

When a PORV block valve is declared inoperable, there is entry into Condition C, one block valve inoperable. The required actions are (1) to place the associated PORV in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and (2) restore the block valve to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . These required actions and CTs are not being changed in this amendment. Therefore, for separate condition entry for PORV block valves, there would be separate entry into Condition C for each block valve and separately, for each inoperable block valve, the associated PORV would be required to be in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Therefore, the NRC staff agrees with the license that with separate condition entry for PORV block valves, Required Action F.1 is redundant to Required Action C.1, and unnecessary. Based on this and the conclusion in Section 3.3 of this safety evaluation that separate condition entry for the PORV block valves is acceptable, the NRC staff further concludes that the proposed deletion of Required Action F.1 is acceptable and meets 10 CFR 50.36.

With the deletion of Required Action F.1, Required Action F.2 has to be re-numbered and the reference to more than one required action for Condition F has to be changed. The licensee has proposed to do that by making Required Action F.2 be Required Action F and by having the note state the phrase "Required action does not apply" instead of the current phrase "Required actions do not apply." The proposed changes reflect the fact that with the deletion of Required Action F.1, there is only one required action left for Condition F. Based on this, the NRC staff concludes that these proposed changes are acceptable and meet 10 CFR 50.36.

4.5 Extend CT for Required Action G.1 in TS 3.4.12 In its application, the licensee proposed to extend the CT for Required Action G.1 from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This required action is for two required RCS relief valves inoperable, or the required actions and associated CTs for Conditions A, B, D, E, or F are not met, or COMS is inoperable for any reason other than Condition A, B, C, D, E, or F. This requires the licensee to depressurize the RCS and establish an RCS vent area of not less than 2.0 in2 (inches square).

The licensee stated that the current CT of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is too short a time to plan a mode change, cool the plant following the plant cooldown limits, plan and execute the maintenance activity of opening a vent, and cool down the RCS sufficiently to safely open a vent. The licensee further stated that 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is insufficient to do this and the additional 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the CT will maintain plant safety by allowing the operators more time to plan the shutdown and prevent challenges to

- 7 plant systems which may initiate an overpressure event that the shutdown intends to prevent.

The CT in the ISTS, which is the proposed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , is a more appropriate time period.

Based on the licensee's statement above that the current CT of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is insufficient for the actions to be taken by the control room operators and the proposed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , which is in the ISTS, is more appropriate, the NRC staff has considered the longer CT for Required Action G.1.

Based on engineering judgment, the NRC staff agrees with the licensee that the CT of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is more appropriate for the Required Action G.1. Based on this, the NRC staff concludes that the proposed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Required Action G.1 is acceptable and meets 10 CFR 50.36.

4.6 Conclusion In Sections 3.2 through 3.5 of this safety evaluation, the NRC staff has evaluated the proposed changes to TSs 3.4.10, 3.4.11, and 3.4.12 in the licensee's application dated November 29, 2007, in which the licensee proposed changes that are consistent with remedial actions specified in the ISTS that is applicable to Callaway. Based on these evaluations, the NRC staff concludes that the proposed changes in this amendment are acceptable and meet 10 CFR 50.36. Based on the proposed changes meeting 10 CFR 50.36, the NRC staff further concludes that the proposed amendment to the TSs is acceptable 4.7 Final No Significant Hazards Consideration In the Federal Register notice published on March 3, 2008 (73 FR 15791), for the application, the NRC staff inadvertently did not address the proposed change to TS 3.4.12 to extend the completion time for Condition G. This additional proposed change and the proposed changes to TSs 3.4.10 and 3.4.11 in the application were addressed in the notice of consideration that was published in the Federal Register on October 22, 2008 (73 FR 63025).

The Commission may issue the license amendment before the expiration of the 60-day period provided that its final determination is that the amendment involves no significant hazards consideration. This amendment is being issued prior to the expiration of the 60-day period.

Therefore, a final finding of no significant hazards consideration follows.

The Commission has made a final determination that the amendment request involves no significant hazards consideration. Under the Commission's regulations in 10 CFR 50.92, this means that operation of the facility in accordance with the proposed amendment does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. As required by 10 CFR 50.91(a), the licensee has provided its analysis of the issue of no significant hazards consideration which is presented below.

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

- 8 Overall protection system performance will remain within the bounds of the previously performed accident analyses since there are no design changes. All design, material, and construction standards that were applicable prior to this amendment request will be maintained. There will be no changes to the design and operating temperature and pressure limits placed on the reactor coolant system.

The proposed changes will not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes will not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended functions to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed changes do not physically alter safety-related systems nor affect the way in which safety-related systems perform their functions.

All accident analysis acceptance criteria will continue to be met with the proposed changes. The proposed changes will not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. The proposed changes will not alter any assumptions or change any mitigation actions in the radiological consequence evaluations in the FSAR. The applicable radiological dose acceptance criteria will continue to be met.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No There are no proposed design changes nor are there any changes in the method by which any safety-related plant SSC performs its safety function. The proposed changes will not affect the normal method of plant operation or change any operating parameters. No equipment performance requirements will be affected. The proposed changes will not alter any assumptions made in the safety analyses.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this amendment.

There will be no adverse effect or challenges imposed on any safety related system as a result of this amendment.

- 9 The proposed amendment will not alter the design or performance of the 7300 Process Protection System, Nuclear Instrumentation System, or Solid State Protection System used in the plant protection systems.

Therefore, the proposed changes do not create the possibility of a new or different accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No There will be no effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, heat flux hot channel factor (FQ), nuclear enthalpy rise hot channel factor (FAH), loss of coolant accident peak cladding temperature (LOCA PCT),

peak local power density, or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met.

The proposed changes do not eliminate any surveillances or alter the frequency of surveillances required by the Technical Specifications.

None of the acceptance criteria for any accident analysis will be changed.

The proposed changes will have no impact on the radiological consequences of a design-basis accident.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

The NRC staff has reviewed the licensee's analysis and based on this review, determined that the three standards of 10 CFR 50.92 are satisfied. Therefore, the NRC staff has determined that the amendment involves no significant hazards consideration.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no

- 10 significant hazards consideration and there has been no public comment on such finding published in the Federal Register (October 22, 2008, 73 FR 63025). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) the amendment does not (a) involve a significant increase in the probability or consequences of an accident previously evaluated, or (b) create the possibility of a new or different kind of accident from any accident previously evaluated, or (c) involve a significant reduction in a margin of safety; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (3) such activities will be conducted in compliance with the Commission's regulations, and (4) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Jack Donohew Date: November 25, 2008

November 25, 2008 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: ADOPTION OF INDUSTRY TRAVELERS TSTF-247-A AND TSTF-352-A (TAC NOS. MD7515 AND MD7516)

Dear Mr. Heflin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 188 to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1.

The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 29, 2007 (ULNRC-05459).

The amendment revises TS 3.4.10, "Pressurizer Safety Valves," TS 3.4.11, "Pressurizer Power Operated Relief Valves (PORVs)," and TS 3.4.12, "Cold Overpressure Mitigation System (COMS)," to adopt Nuclear Regulatory Commission (NRC)-approved TS Task Force (TSTF) travelers to the Standard TSs TSTF-247-A and TSTF-352-A.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRAI Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

1. Amendment No. 188 to NPF-30

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDssSbpb Resource LPLIV Reading RidsNrrPMMThadani Resource RidsAcrsAcnw_MailCTR Resource RidsNrrLA,IBurkhardt Resource RidsNrrDirsltsb Resource RidsOgcRp Resource RidsNrrDorlDpr Resource RidsRgn4MailCenter Resource RidsNrrDorlLpl4 Resource ADAMS Accession No. ML082910895 OFFICE NRRlLPL4/PM NRRlLPL4/LA DIRS/ITSB/BC DSS/SBPB/BC(A)

OGC NRRlLPL4/BC NRRlLPL4/PM NAME JDonohew JBurkhardt RElliott MRahimi AJones MMarkley JDonohew\\.n"t DATE 11/20/08 10/28/08 11/07/08 11/05/08 11/18/08 11/25/08 11/25/08 c.\\

!r" OFFICIAL RECORD COpy

v t e Letter Sequence Approval
TAC:MD7515, Provide Consistent Completion Time to Reach Mode 4, Provide Separate Condition Entry for Each PORV and Block Valve (Approved, Closed) TAC:MD7516, Provide Consistent Completion Time to Reach Mode 4, Provide Separate Condition Entry for Each PORV and Block Valve (Approved, Closed)
Initiation Acceptance... Administration Questions Answers Results Approval Other: ML082840670, ML082840682
MONTHYEAR2008-10-14 [Table View]

ML082910895

Text

SUBJECT:

Dear Mr. Heflin:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 BACKGROUND

4.0 TECHNICAL EVALUATION

5.0 STATE CONSULTATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

SUBJECT:

Dear Mr. Heflin:

Enclosures:

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