Text

Issuance of Amendment No. 189,Main Steam Isolation Valves and Main Feedwater Isolation System
	ML083300110
Person / Time
Site:	Callaway
Issue date:	12/18/2008
From:	Donohew J; Plant Licensing Branch IV
To:	Heflin A; Union Electric Co
	Donohew J N, NRR/DORL/LPL4, 415-1307
References
	TAC MD7786
	Download: ML083300110 (55)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 18, 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: MAIN STEAM ISOLATION VALVES AND MAIN FEEDWATER ISOLATION SYSTEM (TAC NO. MD7786)

Dear Mr. Heflin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 189 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 December 28, 2007 (ULNRC-05464).

The amendment revises TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," and TS Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation."

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 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.189 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. 189 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 December 28, 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.

Enclosure 1

-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. 189 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: December 18, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 189 FACILITY OPERATING LICENSE NO. NPF-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 1 (Table of Contents) 1 (Table of Contents) 2 (Table of Contents) 2 (Table of Contents) 3.3-38 to 3.3-73 3.3-38 to 3.3-74 3.7-7 3.7-7

-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. 189 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) 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 189

TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1-1 1.1 Definitions 1.1-1 1.2 Logical Connectors 1.2-1 1.3 Completion Times 1.3-1 1.4 Frequency 1.4-1 2.0 SAFETY LIMITS (SLs) 2.0-1 2.1 SLs 2.0-1 2.2 SL Violations 2.0-1 3.0 L1MITII\IG CONDITION FOR OPERATION (LCO) APPLICABILITY ..... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.0-4 3.1 REACTIVITY CONTROL SYSTEMS 3.1-1 3.1.1 SHUTDOWN MARGIN (SDM) 3.1-1 3.1.2 Core Reactivity 3.1-2 3.1.3 Moderator Temperature Coefficient (MTC) 3.1-4 3.1.4 Rod Group Alignment Limits 3.1-7 3.1.5 Shutdown Bank Insertion Limits 3.1-11 3.1.6 Control Bank Insertion Limits 3.1-13 3.1.7 Rod Position Indication 3.1-16 3.1.8 PHYSICS TESTS Exceptions - MODE 2 3.1-19 3.1.9 RCS Boron Limitations < 500°F 3.1-21 3.2 POWER DISTRIBUTION LIMITS 3.2-1 3.2.1 Heat Flux Hot Channel Factor (Fa(Z))

(Fa Methodology) 3.2-1 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor 3.2-6 3.2.3 AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC) Methodology) 3.2-9 3.2.4 QUADRANT POWER TILT RATIO (QPTR) 3.2-10 3.3 INSTRUMENTATION 3.3-1 3.3.1 Reactor Trip System (RTS) Instrumentation 3.3-1 3.3.2 Engineered Safety Feature Actuation System (ESFAS)

Instrumentation 3.3-25 3.3.3 Post Accident Monitoring (PAM) Instrumentation 3.3-47 CALLAWAY PLANT Amendment 189

TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.4 Remote Shutdown System 3.3-52 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation 3.3-55 3.3.6 Containment Purge Isolation Instrumentation 3.3-57 3.3.7 Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation 3.3-62 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation 3.3-67 3.3.9 Boron Dilution Mitigation System (BDMS) 3.3-72 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4-1 3.4.1 RCSPressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits 3.4-1 3.4.2 RCS Minimum Temperature for Criticality 3.4-3 3.4.3 RCS Pressure and Temperature (PIT) Limits 3.4-4 3.4.4 RCS Loops - MODES 1 and 2 3.4-6 3.4.5 RCS Loops - MODE 3 3.4-7 3.4.6 RCS Loops - MODE 4 3.4-10 3.4.7 RCS Loops - MODE 5, Loops Filled 3.4-12 3.4.8 RCS Loops - MODE 5, Loops Not Filled 3.4-15 3.4.9 Pressurizer 3.4-17 3.4.10 Pressurizer Safety Valves 3.4-19 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) 3.4-21 3.4.12 Cold Overpressure Mitigation System (COMS) 3.4-25 3.4.13 RCS Operational LEAKAGE 3.4-30 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage 3.4-32 3.4.15 RCS Leakage Detection Instrumentation 3.4-36 3.4.16 RCS Specific Activity 3.4-40 3.4.17 Steam Generator (SG) Tube Integrity 3.4-42 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) : 3.5-1 3.5.1 Accumulators 3.5-1 3.5.2 ECCS - Operating 3.5-3 3.5.3 ECCS - Shutdown 3.5-6 3.5.4 Refueling Water Storage Tank (RWST) 3.5-8 3.5.5 Seal Injection Flow 3.5-10 3.6 CONTAINMENT SYSTEMS 3.6-1 3.6.1 Containment 3.6-1 3.6.2 Containment Air Locks 3.6-3 CALLAWAY PLANT 2 Amendment 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 1 of 9)

Engineered Sofety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

1. Safety Injection

a. Manual 1,2,3,4 2 B SR 3.3.2.8 NA Initiation

b. Automatic 1,2,3,4 2 trains C SR 332.2 NA Actuation SR 332.4 Logic and SR 3.3.26 Actuation SR 3.3.2 13 Relays (SSPS)

c. Containment 1,2,3 3 D SR 3.3.2.1 -<: 4.5 psig Pressure SR 3.3.2.5 High 1 SR 3.3.2.9 SR 33.210

d. Pressurizer 1,2,3(b) 4 D SR 3.3.2.1 21834 psig Pressure SR 3.325 Low SR 3.3.2.9 SR 3.3.210

e. Steam Line 1,2,3(b) 3 per steam D SR 33.2.1 2610 psig(c)(s)

Pressure line SR 3325 Low SR 3.3.2.9 SR 3.3.2.10

2. Containment Spray

a. Manual 1,2,3,4 2 per train, B SR 3.3.2.8 NA Initiation 2 trains

b. Automatic 1,2,3,4 2 trains C SR 3.3.2.2 NA Actuation SR 33.2.4 Logic and SR 332.6 Actuation Relays (SSPS)

(a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

(b) Above the P-11 (Pressurizer Pressure) interlock and below P-11 unless the Function is blocked.

(c) Time constants used in the lead/lag controller are '1 250 seconds and '2 -<: 5 seconds.

(s) 1. If the as-found instrument channel setpoint is conservative with respect to the Allowable Value, but outside its as-found test acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2. The instrument channel setpoint shall be reset to a value that is within the as-left setpoint tolerance band on either side of the Nominal Trip Setpoint, or to a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoints and the methodology used to determine the as-found test acceptance criteria band and the as-left setpoint tolerance band shall be specified in the Bases.

CALLAWAY PLANT 3.3-38 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 2 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

2. Containment Spray

c. Containment 1,2,3 4 E SR3,3,2,1 <:; 28.3 psig Pressure SR 3,3,2.5 High - 3 SR 3,3,29 SR 3,3,2.10

3. Containment Isolation

a. Phase A Isolation (1) Manual 1,2,3,4 2 B SR 3328 NA Initiation (2) Automatic 1,2,3,4 2 trains C SR 3,3,2.2 NA Actuation SR 3.:124 Logic and SR 3.3.2,6 Actuation SR 33213 Relays (SSPS)

(3) Safety Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

Injection

b. Phase B Isolation (1) Manual 1,2,3,4 2 per train, B SR 3.3.28 NA Initiation 2 trains (2) Automatic 1,2,3,4 2 trains C SR 3,3.2.2 NA Actuation SR 3.3,2.4 Logic and SR 3.3.2.6 Actuation Relays (SSPS)

(3) Contain 1,2,3 4 E SR3.32,1 <; 28.3 psig ment SR 3.3.2.5 Pressure SR 3329 High - 3 SR332,10 (a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

CALLAWAY PLANT 3.3-39 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

4. Steam Line Isolation

a. Manual Initiation 1,2(i),3(;) 2 F SR 3.3.2.8 NA

b. Automatic 1,2(i), 3(;) 2 trains G SR 3.3.2.2 NA Actuation Logic SR 3.3.2.4 and Actuation SR 3.3.2.6 Relays (SSPS)

c. Automatic 1,2(i),3(i) 2 trains(o) S SR 3.3.2.3 NA Actuation Logic and Actuation Relays (MSFIS)

d. Containment 1,2(i),3(;) 3 D SR332.1 s 183 psig Pressure - High 2 SR 3.32.5 SR 33.2.9 SR 332.10

e. Steam Line Pressure (1) Low 1,2 (;), 3(b)(i) 3 per steam D SR 3.3.2.1 e: 610 psig(c)(s) line SR 3.3.2.5 SR 3.329 SR 3.3.2.10 (2) Negative 3(g)(;) 3 per steam D SR 3.3.2.1 s 124 psi(h)

Rate - High line SR 33.25 SR 3.3.2.9 SR 3.32.10 (a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

(b) Above the P-11 (Pressurizer Pressure) Interlock and below P-11 unless the Function is blocked.

(c) Time constants used in the lead/lag controller are '1 e: 50 seconds and '2 s 5 seconds.

(g) Below the P-11 (Pressurizer Pressure) Interlock; however, may be blocked below P-11 when safety injection on low steam line pressure is not blocked.

(h) Time constant utilized in the rate/lag controller is e: 50 seconds.

(i) Except when all MSIVs are closed.

(0) Each train requires a minimum of two programmable logic controllers to be OPERABLE.

(s) 1. If the as-found instrument channel setpoint is conservative with respect to the Allowable Value, but outside its as-found test acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2. The instrument channel setpoint shall be reset to a value that is within the as-left setpoint tolerance band on either side of the Nominal Trip Setpoint, or to a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoints and the methodology used to determine the as-found test acceptance criteria band and the as-left setpoint tolerance band shall be specified in the Bases.

CALLAWAY PLANT 3.3-40 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 4 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

5. Turbine Trip and Feedwater Isolation

a. Automatic 2 trains G SR 3.3.2.2 NA Actuation Logic SR 3324 and Actuation SR 3.3.2.6 Relays (SSPS) SR 3.3.2.14

b. Automatic 2 trains(o) S SR 3.3.23 NA Actuation Logic and Actuation Relays (MSFIS)

c. SG Water Level - 4 per SG SR 3.3.2.1 $ 914%(5) of High High (P-14) SR 3325 Narrow Range SR 3329 Instrument SR 3.3.2.10 Span

d. Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

(a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

OJ Except when:

1. All MFIVs are closed and de-activated; AND

2. All MFRVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve; AND

3. All MFRVBVs are:

3.a Closed and de-activated, or 3.b Closed and isolated by a closed manual valve, or 3.c Isolated by two closed manual valves.

(0) Each train requires a minimum of two programmable logic controllers to be OPERABLE.

(s) 1. If the as-found instrument channel setpoint is conservative with respect to the Allowable Value, but outside Its as-found test acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2. The instrument channel setpoint shall be reset to a value that is within the as-left setpoint tolerance band on either side of the Nominal Trip Setpoint, or to a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoints and the methodology used to determine the as-found test acceptance criteria band and the as-left setpoint tolerance band shall be specified in the Bases.

CALLAWAY PLANT 3.3-41 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 5 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

5. Turbine Trip and Feedwater Isolation

e. Steam Generator Water Level Low-Low(q)

(1) Steam 1, 20), 30) 4 per SG D SR 3.3.2.1 ~ 20.6%(5) of Generator SR 3.3.2.5 Narrow Range Water Level SR 33.29 Low-Low Instrument SR 3.3210 Span (Adverse Containment Environment)

(2) Steam 1(r), 20,r), 30,r) 4 per SG D SR 3.3.2,1 ~ 16.6%(5) of Generator SR 3.3,25 Narrow Range Water Level SR 33.29 Instrument Low-Low SR 33.2,10 (Normal Span Containment Environment)

(a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

Except when:

1. All MFIVs are closed and de-activated; AND

2. All MFRVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve; AND 3 All MFRVBVs are:

3.a Closed and de-activated, or 3.b Closed and isolated by a closed manual valve, or 3.c Isolated by two closed manual valves.

(k) Not used.

(I) Not used.

(q) Feedwater isolation only.

(r) Except when the Containment Pressure - Environmental Allowance Modifier channels in the same prqtection sets are tripped.

(s) 1. If the as-found instrument channel setpoint is conservative with respect to the Allowable Value, but outside its as-found test acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2. The instrument channel setpoint shall be reset to a value that is within the as-left setpoint tolerance band on either side of the Nominal Trip Setpoint, or to a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoints and the methodology used to determine the as-found test acceptance criteria band and the as-left setpoint tolerance band shall be specified in the Bases, CALLAWAY PLANT 3.3-42 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 6 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

5. Turbine Trip and Feedwater Isolation

e. Steam Generator Water Level Low-Low(q)

(3) Not used.

(4) Containment 4 N SR 3.3.21 <; 2.0 psig Pressure SR 3.3.2.5 Environmental SR 3.3.2.9 Allowance SR 3.3.2.10 Modifier (a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

U) Except when:

1. All MFIVs are closed and de-activated; AND

2. All MFRVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve; AND

3. All MFRVBVs are:

3.a Closed and de-activated, or 3.b Closed and isolated by a closed manual valve, or 3.c Isolated by two closed manual valves.

(k) Not used.

(I) Not used.

(q) Feedwater Isolation only.

(s) 1. If the as-found instrument channel setpoint is conservative with respect to the Allowable Value, but outside Its as-found test acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2. The instrument channel setpoint shall be reset to a value that is within the as-left setpoint tolerance band on either side of the Nominal Trip Setpoint, or to a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoints and the methodology used to determine the as-found test acceptance criteria band and the as-left setpoint tolerance band shall be specified in the Bases.

CALLAWAY PLANT 3.3-43 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 7 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS' CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

6. Auxiliary Feedwater

a. Manual Initiation 1,2,3 1/pump P SR 3.3.28 NA

b. Automatic 1,2,3 2 trains G SR 3.3.2.2 NA Actuation Logic SR 3.3.24 and Actuation SR 332.6 Relays (SSPS)

c. Automatic 1,2,3 2 trains Q SR 332.3 NA Actuation Logic and Actuation Relays (BOP ESFAS)

d. SG Water Level Low-Low (1) Steam 1,2,3 4 per SG D SR 33.2.1 ~ 20.6%(5) of Generator SR 3.3.2.5 Narrow Range Water Level SR 3329 Instrument Low-Low SR 33.210 Span (Adverse Containment Environment)

(2) Steam 4 per SG D SR 3.3.2.1 ~ 16.6%(5) of Generator SR 3325 Narrow Range Water Level SR 3329 Instrument Low-Low SR 3.3.2.10 Span (Normal Containment Environment)

(a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

(r) Except when the Containment Pressure - Environmental Allowance Modifier channels in the same protection sets are tripped.

(s) 1. If the as-found instrument channel setpoint is conservative with respect to the Allowable Value, but outside its as-found test acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2. The instrument channel setpoint shaH be reset to a value that is within the as-left setpoint tolerance band on either side of the Nominal Trip Setpoint, or to a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoints and the methodology used to determine the as-found test acceptance criteria band and the as-left setpoint tolerance band shall be specified in the Bases.

CALLAWAY PLANT 3.3-44 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 8 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

6. Auxiliary Feedwater

d. SG Water Level Low-Low (3) Not used.

(4) Containment 1,2,3 4 N SR3.3.2.1 ~ 2.0 psig Pressure - SR 3.3.2.5 Environmental SR 3.3.2.9 Allowance SR 33210 Modifier

e. Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

f. Loss of Offsite 1,2,3 2 trains R SR 3.3.2.7 NA Power SR 3.3.2.10

g. Trip of all Main 1,2(n) 2 per pump J SR 3.3.2.8 NA Feedwater Pumps

h. Auxiliary 1,2,3 3 0 SR 3.321 ~ 20.64 psia Feedwater Pump SR 3.3.2.9 Suction Transfer SR3.3.2.10 on Suction SR 3.3.2.12 Pressure - Low (a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

(k) Not used.

(I) Not used.

(n) Trip function may be blocked just before shutdown of the last operating main feedwater pump and restored just after the first main feedwater pump is put into service following performance of its startup trip test.

CALLAWAY PLANT 3.3-45 Amendment No. 189

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 9 of 9)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

7. Automatic Switchover to Containment Sump

a. Automatic 1,2,3,4 2 trains C SR 332.2 NA Actuation Logic SR 3324 and Actuation SR 3.3.2.13 Relays (SSPS)

b. Refueling Water 1,2,3,4 4 K SR 3.3.2.1 ;;, 35.2%

Storage Tank SR 33.2.5 (RWST) Level SR 3.32.9 Low Low SR33210 Coincident with Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

Safety Injection

8. ESFAS Interlocks

a. Reactor Trip, P-4 1,2,3 2 per train, F SR33211 NA 2 trains

b. Pressurizer 1,2,3 3 L SR 3.325 5 1981 psig Pressure, P-11 SR 332.9

9. Automatic Pressurizer PORV Actuation

a. Automatic 1,2,3 2 trains H SR 3.3.2.2 NA Actuation Logic SR 3324 and Actuation SR 3.3.2.14 Relays (SSPS)

b. Pressurizer 1,2,3 4 D SR 3.3.21 52350 psig Pressure - High SR 332.5 SR 3329 (a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1), 5.c, 5.e.(1), 5.e.(2),

6.d.(1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal Trip Setpoints.

CALLAWAY PLANT 3.3-46 Amendment No. 189

PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTIONS

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

Separate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A, One or more Functions with A,1 Restore required 30 days one required channel channel to OPERABLE inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A not Specification 5.6.8.

met.

(continued)

CALLAWAY PLANT 3.3-47 Amendment No. 189 I

PAM Instrumentation 3.3.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. ------------- NOTE ------------ C.1 Restore all but one 7 days Not applicable to hydrogen channel to OPERABLE analyzer channels. status.

One or more Functions with two or more required channels inoperable.

D. Two hydrogen analyzer 0.1 Restore one hydrogen 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months channels inoperable. analyzer channel to OPERABLE status.

E. Required Action and E.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C or 0 Table 3.3.3-1 for the not met. channel.

F. As required by Required F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action E.1 and referenced in Table 3.3.3-1. AND F.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months G As required by Required G1 Initiate action in Immediately Action E.1 and referenced accordance with in Table 3.3.3-1. Specification 5.6.8.

CALLAWAY PLANT 3.3-48 Amendment No. 189 I

PAM Instrumentation 3.3.3 SURVEILLANCE REQUIREMENTS

N()TE ----------------------------------------------------------

SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 --------------------------------- N()TE ---------------------------

Neutron detectors are excluded from CHANNEL CALIBRATI()N.

Perform CHANNEL CALIBRATI()N. 18 months CALLAWAY PLANT 3.3-49 Amendment No. 189 I

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 2)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED REQUIRED FUNCTION CHANNELS ACTION E.1 2 F

1. Neutron Flux

2. Reactor Coolant System (ReS) Hot Leg 2 F Temperature (Wide Range)

3. RCS Cold Leg Temperature (Wide Range) 2 F

4. RCS Pressure (Wide Range) 2 F

5. Reactor Vessel Level Indicating System 2 G (RVLlS)

6. Containment Normal Sump Water Level 2 F

7. Containment Pressure (Normal Range) 2 F

8. Steam Line Pressure 2 per steam F generator

9. Containment Radiation Level (High Range) 2 G

10. Containment Hydrogen Analyzers 2 F

11. Pressurizer Water Level 2 F

12. Steam Generator Water Level (Wide Range) 4 F

13. Steam Generator Water Level (Narrow Range) 2 per steam F generator (continued)

CALLAWAY PLANT 3.3-50 Amendment No. 189 I

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 2 of 2)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED REQUIRED FUNCTION CHANNELS ACTION E.1

14. Core Exit Temperature - Quadrant 1 2(a) F

15. Core Exit Temperature - Quadrant 2 2(a) F

16. Core Exit Temperature - Quadrant 3 2(a) F

17. Core Exit Temperature - Quadrant 4 2(a) F

18. Auxiliary Feedwater Flow Rate 4 F

19. Refueling Water Storage Tank Level 2 F (a) A channel consists of two core exit thermocouples (CETs).

CALLAWAY PLANT 3.3-51 Amendment No. 189 I

Remote Shutdown System 3.3.4 3.3 INSTRUMENTATION 3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions in Table 3.3.4-1 and the required auxiliary shutdown panel (ASP) controls shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each Function and required ASP control.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more required A.1 Restore required 30 days Functions inoperable. Function and required ASP controls to OR OPERABLE status.

One or more required ASP controls inoperable.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. I 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CALLAWAY PLANT 3.3-52 Amendment No. 189 I

Remote Shutdown System 3.3.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.4.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.4.2 -------------------------------- N()TE ---------------------------

()nly required to be performed in M()DES 1 and 2 for the turbine-driven AFW pump.

Verify each required auxiliary shutdown panel control 18 months circuit and transfer switch is capable of performing the intended function.

~LJ I l: ---------------------------

SR 3.3.4.3 1. Neutron detectors are excluded from CHANNEL CALIBRATI()N.

2. Reactor trip breaker and RCP breaker position indications are excluded from CHANNEL CALIBRATI()N.

Perform CHANNEL CALIBRATI()N for each required 18 months instrumentation channel.

CALLAWAY PLANT 3.3-53 Amendment No. 189 I

Remote Shutdown System 3.3.4 Table 3.3.4-1 (page 1 of 1)

Remote Shutdown System Functions FUNCTION REQUIRED CHANNELS

1. Source Range Neutron Flux(a) 1

2. Reactor Trip Breaker Position 1 per trip breaker

3. Pressurizer Pressure 1

4. RCS Wide Range Pressure 1

5. RCS Hot Leg Temperature 1

6. RCS Cold Leg Temperature 1

7. SG Pressure 1 per SG

8. SG Level 1 per SG

9. AFW Flow Rate 1

10. RCP Breaker Position 1 per pump

11. AFW Suction Pressure 1

12. Pressurizer Level 1 (a) Not required OPERABLE in MODE 1 or in MODE 2 above the P-6 setpoint.

CALLAWAY PLANT 3.3-54 Amendment No. 189 I

LOP DG Start Instrumentation 3.3.5 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation LCO 3.3.5 Four channels per 4.16-kV NB bus of the loss of voltage Function and four channels per 4.16-kV NB bus of the degraded voltage Function shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.2, "AC Sources - Shutdown."

ACTIONS

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

Separate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more Functions with A.1 ------------ NOTE ----------

one channel per bus The inoperable channel inoperable. may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

Place channel in trip. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. One or more Functions with B.1 Declare associated load Immediately two or more channels per shedder and emergency bus inoperable. load sequencer (LSELS) inoperable.

OR Required Action and associated Completion Time of Condition A not met.

CALLAWAY PLANT 3.3-55 Amendment No. 189 I

LOP DG Start Instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 Tie breakers between 480 Vac buses NG01 and 7 days NG03 and between 480 Vac buses NG02 and NG04 shall be verified open.

SR 3.3.5.2 --------------------------------- NOTE ---------------------------

Verification of time delays is not required.

Perform TADOr. 31 days SR 3.3.5.3 Perform CHANNEL CALIBRATION with nominal Trip 18 months Setpoint and Allowable Value as follows:

a. Loss of voltage Allowable Value 83 +0, -8.3V (120V Bus) with a time delay of 1.0 + 0.2,

-0.5 sec.

Loss of voltage nominal Trip Setpoint 83V (120V Bus) with a time delay of 1.0 sec.

b. Degraded voltage Allowable Value 107.47 +/- 0.38V (120V Bus) with a time delay of 119 +/- 11.6 sec.

Degraded voltage nominal Trip Setpoint 107.47V (120V Bus) with a time delay of 119 sec.

SR 3.3.5.4 Verify LOP DG Start ESF RESPONSE TIMES are 18 months on a within limits. STAGGERED TEST BASIS CALLAWAY PLANT 3.3-56 Amendment No. 189 I

Containment Purge Isolation Instrumentation 3.3.6 3.3 INSTRUMENTATION 3.3.6 Containment Purge Isolation Instrumentation LCO 3.3.6 The Containment Purge Isolation instrumentation for each Function in Table 3.3.6-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.6-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A. One radiation monitoring A.1 Restore the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months channel inoperable. channel to OPERABLE status.

(continued)

CALLAWAY PLANT 3.3-57 Amendment No. 189 I

Containment Purge Isolation Instrumentation 3.3.6 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. ------------- NOTE ------------ B.1 Place and maintain Immediately Only applicable in MODE 1, containment purge 2,3, or 4. supply and exhaust valves in closed position.

One or more Functions with one or more manual channels or automatic actuation trains inoperable.

Both radiation monitoring channels inoperable.

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

(continued)

CALLAWAY PLANT 3.3-58 Amendment No. 189 I

Containment Purge Isolation Instrumentation 3.3.6 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION r TIME C. ------------- NOTE ------------ C.1 Place and maintain Immediately Only applicable during I containment purge CORE ALTERATIONS or supply and exhaust movement of irradiated fuel valves in closed position.

assemblies within containment. OR C.2 Enter applicable Immediately One or more manual Conditions and Required channels inoperable. Actions of LCO 3.9.4, "Containment Penetrations," for containment purge supply and exhaust valves made inoperable by isolation instrumentation.

CALLAWAY PLANT 3.3-59 Amendment No. 189 I

Containment Purge Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS

N()TE ----------------------------------------------------------

Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Purge Isolation Function.

SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.6.2 -------------------------------- N()-rE ---------------------------

The continuity check may be excluded.

Perform ACTUATI()N L()GIC TEST. 31 days on a STAGGERED TEST BASIS SR 3.3.6.3 Perform C()T. 92 days SR 3.3.6.4 --------------------------------- N()TE ---------------------------

Verification of setpoint is not required.

~--------------------------------------------------

Perform TAD()T. 18 months SR 3.3.6.5 Perform CHANNEL CALIBRATI()N. 18 months SR 3.3.6.6 Verify Containment Purge Isolation ESF RESP()NSE 18 months on a TIMES are within limits. STAGGERED TEST BASIS CALLAWAY PLANT 3.3-60 Amendment No. 189 I

Containment Purge Isolation Instrumentation 3.3.6 TABLE 3.3.6-1 (PAGE 1 OF 1)

Containment Purge Isolation Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE NOMINAL FUNCTION CONDITIONS CHANNELS REQUIREMENTS TRIP SETPOINT

1. Manual 1,2,3,4, 2 SR 3.3.6.4 NA Initiation (a), (b)

2. Automatic 1,2,3,4 2 trains SR 3.3.6.2 NA Actuation SR 33.66 Logic and Actuation Relays (BOP ESFAS)

3. Containment 1,2,3,4 2 SR 3361 (c)

Purge SR 3.3.6.3 Exhaust SR 3.3.6.5 Radiation Gaseous

4. Containment Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a, for all initiation functions and Isolation requirements.

Phase A (a) During CORE ALTERATIONS.

(b) During movement of irradiated fuel assemblies within containment.

(c) Set to ensure ODCM limits are not exceeded.

CALLAWAY PLANT 3.3-61 Amendment No. 189 I

CREVS Actuation Instrumentation 3.3.7 3.3 INSTRUMENTATION 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation LCO 3.3.7 The CREVS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.7-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more Functions with A.1 Place one CREVS train 7 days one channel or train in Control Room inoperable. Ventilation Isolation Signal (CRVIS) mode.

(continued)

CALLAWAY PLANT 3.3-62 Amendment No. 189 I

CREVS Actuation Instrumentation 3.3.7 COMPLETION CONDITION I REQUIRED ACTION TIME 1

6. ------------- NOTE -------------- I 6.1.1 Place one CREVS train Immediately Not applicable to I in CRVIS mode.

Function 3.

AND One or more Functions with 6.1.2 Enter applicable Immediately two channels or two trains Conditions and Required inoperable. Actions of LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)", for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

OR 6.2 Place both trains in Immediately CRVIS mode.

CALLAWAY PLANT 3.3-63 Amendment No. 189 I

CREVS Actuation Instrumentation 3.3.7 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. Both radiation monitoring C.1.1 Enter applicable Immediately channels inoperable. Conditions and Required Actions of LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)," for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

AND C.1.2 Place one CREVS train 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in CRVIS mode.

l OR Place both trains in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C2 CRVIS mode.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Conditions A, B, AND or C not met in MODE 1,2, 3, or 4. D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Required Action and E.1 Suspend CORE Immediately associated Completion ALTERATIONS.

Time for Conditions A, B, or C not met in MODE 5 or 6, AND or during CORE ALTERATIONS, or during E.2 Suspend movement of Immediately movement of irradiated fuel irradiated fuel assemblies. assemblies.

CALLAWAY PLANT 3.3-64 Amendment No. 189 I

CREVS Actuation Instrumentation 3.3.7 SURVEILLANCE REQUIREMENTS

N()TE ----------------------------------------------------------

Refer to Table 3.3.7-1 to determine which SRs apply for each CREVS Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.7.2 Perform C()T. 92 days SR 3.3.7.3 -------------------------------- N()TE ---------------------------

The continuity check may be excluded.

Perform ACTUATI()N L()GIC TEST. 31 days on a STAGGERED TEST BASIS SR 3.3.7.4 --------------------------------- N()TE ---------------------------

Verification of setpoint is not required.

Perform TAD()T. 18 months SR 3.3.7.5 Perform CHANNEL CALIBRATI()N. 18 months SR 3.3.7.6 --------------------------------- N()-rE ---------------------------

Radiation monitor detectors are excluded from response time testing.

Verify Control Room Ventilation Isolation ESF 18 months on a RESP()NSE TIMES are within limits STAGGERED TEST BASIS CALLAWAY PLANT 3.3-65 Amendment No. 189 I

CREVS Actuation Instrumentation 3.3.7 Table 3.3.7-1 (page 1 of 1)

CREVS Actuation Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE TRIP FUNCTION CONDITIONS CHANNELS REQUIREMENTS SETPOINT

1. Manual 1, 2, 3, 4, 5, 6, 2 SR 3.3.7.4 NA Initiation (a), and (c)

2. Automatic 1,2,3,4,5,6, 2 trains SR 3.3.7.3 NA Actuation (a), and (c)

Logic and Actuation (a) 2 trains SR 3.3.7.6 NA Relays (BOP ESFAS)

3. Control Room 1, 2, 3, 4, 5, 6, 2 SR 3.3.7.1 (b)

Radiation - and (a) SR 3.3.7.2 Control Room SR 3.3.7.5 Air Intakes (a) 2 SR 3.3.7.6 (b)

4. Containment Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a, for all initiation functions and Isolation requ irements.

Phase A

5. Fuel Building Refer to LCO 3.3.8, "EES Actuation Instrumentation," for all initiation functions and Exhaust requirements.

Radiation, Gaseous (a) During CORE ALTERATIONS or during movement of irradiated fuel assemblies within containment.

(b) Nominal Trip Setpoint concentration value (~Cilcm3) shall be established such that the actual submersion dose rate would not exceed 2 mRlhr in the control room.

(c) During movement of irradiated fuel assemblies in the fuel building CALLAWAY PLANT 3.3-66 Amendment No. 189 I

EES Actuation Instrumentation 3.3.8 3.3 INSTRUMENTATION 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation LCO 3.3.8 The EES actuation instrumentation for each Function in Table 3.3.8-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.8-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more Functions A.1 Place one EES train in 7 days with one channel or train the Fuel Building inoperable. Ventilation Isolation Signal (FBVIS) mode.

A.2 Place one CREVS train 7 days in Control Room Ventilation Isolation Signal (CRVIS) mode.

~contlnuea)

CALLAWAY PLANT 3.3-67 Amendment No. 189 I

EES Actuation Instrumentation 3.3.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME B. ------------- NOTE ------------ B.1.1 Place one EES train in Immediately Not applicable to the FBVIS mode and Function 3. one CREVS train in the CRVIS mode.

One or more Functions AND with two channels or two trains inoperable. B.1.2 Enter applicable Immediately Conditions and Required Actions of LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)," for one CREVS train made inoperable and enter applicable Conditions and Required Actions of LeO 3.7.13, "Emergency Exhaust System (EES),"

for one EES train made inoperable by inoperable EES actuation instrumentation.

B.2 Place both EES trains in Immediately the FBVIS mode and both CREVS trains in the CRVIS mode.

(contlnueo)

CALLAWAY PLANT 3.3-68 Amendment No. 189 I

EES Actuation Instrumentation 3.3.8 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. Both radiation monitoring C.1.1 Enter applicable Immediately channels inoperable. Conditions and Required Actions of LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)," for one CREVS train made inoperable and enter applicable Conditions and Required Actions of LCO 3.7.13, "Emergency Exhaust System (EES),"

for one EES train made inoperable by inoperable EES actuation instrumentation.

AND C.1.2 Place one EES train in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the FBVIS mode and one CREVS train in the CRVIS mode.

OR C.2 Place both EES trains in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the FBVIS mode and both CREVS trains in the CRVIS mode.

D. Required Action and 0.1 Suspend movement of Immediately associated Completion irradiated fuel Time for Conditions A, B, assemblies in the fuel or C not met during building.

movement of irradiated fuel assemblies in the fuel building.

CALLAWAY PLANT 3.3-69 Amendment No. 189 I

EES Actuation Instrumentation 3.3.8 SURVEILLANCE REQUIREMENTS

N()TE ----------------------------------------------------------

Refer to Table 3.3.8-1 to determine which SRs apply for each EES Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.8.2 Perform C()T. 92 days SR 3.3.8.3 -------------------------------- N()TE ---------------------------

The continuity check may be excluded.

Perform ACTUATI()N L()GIC TEST. 31 days on a STAGGERED TEST BASIS SR 3.3.8.4 -------------------------------- I\J () TE ---------------------------

Verification of setpoint is not required.

Perform TAD()T. 18 months SR 3.3.8.5 Perform CHANNEL CALIBRATI()N. 18 months CALLAWAY PLANT 3.3-70 Amendment No. 189 I

EES Actuation Instrumentation 3.3.8 Table 3.3.8-1 (page 1 of 1)

EES Actuation Instrumentation APPLICABLE MODES OR SPECIFIED REQUIRED SURVEILLANCE NOMINAL TRIP FUNCTION CONDITIONS CHANNELS REQUIREMENTS SETPOINT

1. Manual (a) 2 SR 3384 NA Initiation

2. Automatic (a) 2 trains SR 3.3.8.3 NA Actuation Logic and Actuation Relays (BOP ESFAS)

3. Fuel (a) 2 SR 33.81 (b)

Building SR 3382 Exhaust SR 3.3.8.5 Radiation

- Gaseous (a) During movement of irradiated fuel assemblies in the fuel building.

(b) Nominal Trip Setpoint concentration vtllue U.lCi/cm 3 ) shall be established such that the actual submersion dose rate would not exceed 4 mR/hr in the fuel building.

CALLAWAY PLANT 3.3-71 Amendment No. 189 I

BDMS 3.3.9 3.3 INSTRUMENTATION 3.3.9 Boron Dilution Mitigation System (BDMS)

LCO 3.3.9 Two trains of the BDMS shall be OPERABLE and one RCS loop shall be in operation.

APPLICABILITY: MODES 2 (below P-6 (Intermediate Range Neutron Flux) interlock), 3, 4, and 5.

NO-rE -------------------------------------------

The boron dilution flux multiplication signal may be blocked in MODES 2 (below P-6 (Intermediate Range Neutron Flux) interlock) and 3 during reactor startup.

ACTIONS

____ C_O_N_D_r_r1_0_N + R_E_Q_L_"_RE_D_A_CT_I_O_N I COMPLETION TIME A. One train inoperable. . A.1 Restore train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

B. Two trains inoperable. B.1 ----------- NOTE -----------

Plant temperature changes are allowed provided the temperature Required Action and change is accounted for associated Completion Time in the calculated SDM.

of Condition A not met.

Suspend operations Immediately involving positive reactivity additions.

(continued)

CALLAWAY PLANT 3.3-72 Amendment No. 189 \

BDMS 3.3.9 ACTIONS CONDITION r REQUIRED ACTION COMPLETION TIME

1 I B. (continued) I B.2 Perform SR 3.1.1.1. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months I

i I

I Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I thereafter B.3.1 Close and secure 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months unborated water source isolation valves.

8.3.2 Verify unborated water Once per 31 days source isolation valves are closed and secured.

C. No RCS loop in operation. C.1 Close and secure 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months unborated water source isolation valves.

AND C.2 CALLAWAY PLANT 3.3-73 Amendment 189 I

BDMS 3.3.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.3.9.2 --------------------------------- N()TE ---------------------------

()nly required to be performed in M()DE 5.

Verify BGV0178 is secured in the closed position. 31 days SR 3.3.9.3 --------------------------------- N()TE ---------------------------

Not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after reducing power below P-6 interlock.

Perform C()T and verify nominal flux multiplication 184 days setpoint of 1.7.

SR 3.3.9.4 --------------------------------- N()TE ---------------------------

Neutron detectors are excluded from CHANNEL CALIBRATI()N.

Perform CHANNEL CALIBRATI()N. 18 months SR 3.3.9.5 Verify the centrifugal charging pump suction valves 18 months from the RWST open and the CVCS volume control tank discharge valves close in less than or equal to 30 seconds on 3 simulated or actual actuation signal.

SR 3.3.9.6 Verify one RCS lOOp is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CALLAWAY PLANT 3.3-74 Amendment No. 189 I

MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 Verify isolation time of each MSIV is within limits. In accordance with the Inservice I Testing Program

1 SR 3.7.2.2 Verify each MSIV actuates to the isolation position on 18 months an actual or simulated actuation signal.

CALLAWAY PLANT 3.7-7 Amendment No. 189

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 189 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

By application dated December 28, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML080150528), 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 Table 3.3.2-1, "Engineered Safety Feature Actuation System [(ESFAS)] Instrumentation," and TS 3.7.2, "Main Steam Isolation Valves (MSIVs)."

The proposed amendment would (1) revise the exception in TS Table 3.3.2-1 for the main feedwater isolation system to be consistent with the modes of applicability for that same system in TS 3.7.3, "Main Feedwater Isolation Valves (MFIVs) and Main Feedwater Regulating Valves (MFRVs) and Main Feedwater Regulating Valve Bypass Valves (MFRVBVs)," and (2) delete the same note in Surveillance Requirements (SRs) 3.7.2.1 and 3.7.2.2 on the MSIVs because the note is no longer needed or appropriate for the two SRs.

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 stationoperation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls.

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 completion times (CTs), or allowed outage times (AOTs), to complete the required actions. When an LCO is not being met, the Enclosure 2

-2 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.

As required by 10 CFR 50.36(c)(2)(ii), an LCO must be included in TS for any item meeting one of the following four criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Those items that do not fall within or satisfy any of the above criteria are not required to be included in the TSs.

As required by 10 CFR 50.36(c)(3), SRs are the requirements related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

As required by 10 CFR 50.36(c)(5), administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

The licensee is not changing the design of the MSIVs, MFIVs, MFRVs, or MFRVBVs, and not changing the design of the ESFAS instrumentation for these valves or the main steam isolation system, the main feedwater isolation system, or the turbine trip system. Therefore, there are no general design criteria in Appendix A tc 10 CFR Part 50 that need to be addressed for this amendment.

In general, there are two classes of changes to TSs: (1) changes needed to reflect modifications to the plant design basis (TSs are derived from the design basis), and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TSs over time. This amendment deals with the second class of changes.

Licensees may revise the TSs to adopt the current format and content of NUREG-1431, Vol. 1, Revision 3.0, "Standard Technical Specifications, Westinghouse Plants," provided that a

-3 plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial administrative,or provides clarification (i.e., no requirements are materially altered),

(2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. This amendment application meets the second test above.

3.0 BACKGROUND

The proposed change in TS Table 3.3.2-1 is to the ESFAS Function 5 for the turbine trip and main feedwater isolation (TT&MFI). The licensee stated that the primary functions of the TT&MFI signals are to prevent damage to the turbine from water in the steam lines and to stop excessive flow of feedwater into the steam generators (SGs) and are necessary to mitigate the effects of a postulated high-water level in the SGs, which could result in carryover of water into the steam lines, and excessive cooldown of the primary system and could be caused by excessive feedwater flow. The licensee further stated that to address this condition, the TT&MFI function is actuated when the water level in any SG exceeds the high-high setpoint and this actuated function performs the following:

Trips the main turbine;

Trips the main feedwater pumps, closing the pump discharge valves (neither of which is credited in the accident analyses); and

Initiates feedwater isolation, closing the MFIVs, MFRVs, and MFRVBVs.

While the above discussion applies to both turbine trip and feedwater isolation in response to excessive feedwater in Modes 1 and 2, feedwater isolation on SG low-low level is required for events in Modes 1, 2, and 3 where the assurance of auxiliary feedwater (AFW) delivery to the intact SGs paramount in the accident analyses. The analyses for the Loss of Non-Emergency AC Power, Loss of Normal Feedwater, and Feedwater System Pipe Break events credit feedwater isolation on SG low-low level.

The licensee explained that, with the location of the feedwater check valves inside containment downstream of where the piping connects to the main feedwater piping, closure of the MFIVs, MFRVs, and MFRVBVs is required to assure that the AFW flow to the SGs is not diverted.

In the application, the licensee also addressed the MSIVs in TS 3.7.2. The MSIVs isolate steam flow from the SG secondary side following a high-energy line break and the MSIV closure terminates flow from the unaffected (or intact) SGs. There is one MSIV located in each main steam line outside, but close to, containment. The MSIVs are located downstream from the main steam safety valves (MSSVs) and AFW pump turbine steam supply to prevent MSSV and AFW isolation from the SGs by MSIV closure. Closing the MSIVs isolates each SG from the other SGs, and isolates the turbine, condenser steam dump system, and other auxiliary steam supplies from the SGs.

-4

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes In its application, the licensee proposed the following changes to TS Table 3.3.2-1 and TS 3.7.2:

1. For Functions 5.a through 5.e, turbine and feedwater isolation, in TS Table 3.3.2-1, the footnote (j) is revised from the current statement, "Except when all MFIVs are closed," to the following statements:

Except when:

1. All MFIVs are closed and de-activated; AND

2. All MFRVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve; AND

3. All MFRVBVs are:

3.a Closed and de-activated, or 3.b Closed a.nd isolated by a closed manual valve, or 3.c Isolated by two closed manual valves.

2. The note that states "Only Required to be Performed in MODES 1 and 2" in SR-3.7.2.1 and SR-3.7.2.2 is deleted in both SRs. There are no other changes to TS 3.7.2 or to SRs-3.7.2.1 and 3.7.2.2.

In addition, the licensee proposed changes to pages 1 and 2 of the Table of Contents for the TSs. These changes result from the addition of a page to TS Table 3.3.2-1 because of the revised footnotes, discussed in item 1 above, to two pages of the table. The increased text for footnote U) would add the additional page and the licensee is re-numbering the pages for TSs 3.3.3 through 3.3.9. This is the only change for TSs 3.3.3 through 3.3.9.

The proposed changes above to footnote U) in TS Table 3.3.2-1 are the same changes that the NRC staff approved for the Wolf Creek Generating Station in Amendment No. 177 issued by letter dated April 3, 2008 (ADAMS Accession No. ML080370117).

-5 3.2 Revised Footnote U) in TS Table 3.3.2-1 The licensee stated that the proposed footnote j in TS Table 3.3.2-1 modifies the applicability of the Function 5 instrumentation listed inthe table. The instrumentation is for the following ESFAS functions:

1. Function 5.a, Automatic Actuation Logic and Actuation Relays (Solid State Protection System, SSPS)

2. Function 5.b, Automatic Actuation Logic and Actuation Relays (Main Steam Feedwater Isolation System, MSFIS)

3. Function 5.c, SG Water Level - High High (P-14)

4. Function 5.e(1), SG Water Level Low-Low (Adverse Containment Environment)

5. Function 5.e(2), SG Water Level Low-Low (l\Jormal Containment Environment)

6. Function 5.e(4), Containment Pressure - Environmental Allowance Modifier The applicable modes for the above ESFAS functions are Modes 1,2, and 3, except for Function 5.c, which are Modes 1 and 2. These are the modes where the function instrumentation is required to be operable (i.e., capable of performing their safety function). The Modes 2 and 3 have the footnote j as an exponent that currently states the following: "except when all MFIVs are closed." This footnote means that the function instrumentation, although normally required to be operable in Modes 2 and 3, is not required to be operable in Modes 2 and 3 when all the MFIVs are closed. The point would be that when all the MFIVs are closed, the ESFAS instrumentation is not needed to be operable for the safety of the plant.

The licensee stated in its application that closure of the MFIVs, MFRVs, and MFRVBVs is required to assure that AFW flow is not diverted. The MFRVs and MFRVBVs are arranged in parallel and provide backup isolation of the main feedwater line. The licensee stated that the steam line break analysis cases that were examined to support the replacement SG project at Callaway included a set of cases at different power levels in which a failed open MFIV was assumed. Further, the accident analyses may consider postulated component failures as well as mechanistic failures in order to determine the impact on the plant.

In Amendment 167 (Reference 1), in which the MFRVs and MFRVBVs were added to TS 3.7.3, it is stated that closure of the MFIVs, or the MFRVs and associated MFRVBVs, terminates flow to the SGs, thus terminating the feedwater line break event occurring upstream of the MFIVs or MFRVs. The consequences of events occurring in the main steam lines or in the main feedwater lines downstream from the MFIVs will be also mitigated by their closure since closure of the MFIVs, or the MFRVs and MFRVBVs, effectively terminates the addition of feedwater to an affected SG.

The licensee stated that the ESFAS instrumentation in TS Table 3.3.2-1 must be operable in case any of the MFIVs, MFRVs, and MFRVBVs would require an automatic closure signal.

Thus, the licensee concluded in its application for the amendment that all three sets of valves

-6 must be in a condition satisfying the accident analysis to permit an exception to the operability requirements on the ESFAS functions. The NRC staff reviewed this proposed change and found it to be acceptable.

The MFIVs, MFRVs, and MFRVBVs would require an automatic closure signal if the valves are required to be operable and are not closed or de-activated or isolated by a closed manual valve or valves. In TS 3.7.3, the modes of applicability for all the MFIVs, MFRVs, and MFRVBVs are the following:

Modes 1, 2, and 3, except when:

a. The MFRV is closed and de-activated; or

b. The MFRV is closed and de-activated, or closed and isolated by a closed manual valve; or

c. The MFRVBV is closed and de-activated, or closed and isolated by a closed manual valve, or isolated by two closed manual valves.

Given that the modes of applicability for the associated ESFAS function for the main feedwater isolation function are either Modes 1, 2, and 3 or Modes 1 and 2, there is no need to revise the modes; however, footnote U) must be revised because it limits Modes 2 and 3 to only when the MFIVs are not closed. In including the MFRVs and MFRVBVs, the licensee has proposed to extend footnote U) to the following:

Except when:

1. All MFIVs are closed ar,d de-activated; AND

2. All MFRVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve; AND

3. All MFRVBVs are:

3.a Closed and de-activated, or 3.b Closed and isolated by a closed manual valve, or 3.c Isolated by two closed manual valves.

-7 The licensee has proposed to incorporate the modes of applicability in TS 3.7.3 for when the MFIVs, MFRVs, and MFRVBVs are required to be operable into footnote U) because footnote U) defines when the ESFAS instrumentation is required to be operable. The proposed footnote U) requires the instrumentation to be operable unless all the MFIVs and MFRVs, and MFRVBVs are not required to be operable. Based on this, the I\IRC staff concludes that the proposed footnote (j) is acceptable and meets 10 CFR 50.36.

3.3 Deletion of Notes in TS 3.7.2 The licensee also proposed to delete the same note in SRs 3.7.2.1 and 3.7.2.2. The requirements in these SRs are to (1) verify the isolation time of each MSIV is within limits (SR 3.7.2.1) and (2) verify that each MSIV actuates to the isolation position on an actual or simulated signal (SR 3.7.2.2). In the TS 3.7.2 Bases, it is explained that the note is to allow entry and operation in Modes 1,2, and 3 prior to performing the two SRs. In accordance with SR 3.0.1, unless an exception is stated by a note in the SR, a plant can not enter a mode where a component is required to be operable unless that component has met the SA. The MSIVs are required to be operable in Modes 1, 2, and 3, and the two SRs could only be performed in Modes 1 and 2.

In its application, the licensee stated that it replaced the original hydraulic valve actuators for the MFIVs and, later, the MSIVs with actuators that use system pressure. In Amendment 170 (Reference 2), the NRC approved the use of an MFIV closure time acceptance criteria curve based on SG pressure and the deletion of the same note, which allowed closure time testing only when the plant had entered Mode 1 or 2, for the MFIVs. The note was retained for the MFRVs and MFRVBVs because it is necessary for these valves since the testing can not be done before entry into Mode 3 where these valves are required to be operable.

The deletion of the note for the MFIVs was acceptable because the closure time acceptance criteria curve provided acceptance criteria valid for the entire range of operating conditions where TS 3.7.3 applied. Subsequently, the NRC approved Amendment 176 (Reference 3) which permitted the relocation of the stroke time limits for the MSIVs previously contained in TS 3.7.2 to the TS Bases, a licensee-controlled document. After the MSIV actuators were modified, the licensee developed new variable closure time acceptance criteria based on SG pressure that was similar to that approved for the MFIVs, and implemented the revised acceptance criteria pursuant to 10 CFR 50.59 (i.e., the change did not require NRC review and approval). The licensee stated that it has since identified that the notes above SR 3.7.2.1 and SR 3.7.2.2 for the MSIVs should be deleted because the variable MSIV closure time acceptance criteria can be applied in all operational modes that TS 3.7.2 applies and the notes are, thus, no longer needed. Therefore, the licensee proposed to delete the notes in SR 3.7.2.1 and SR 3.7.2.2.

The deletion of the notes in SR 3.7.2.1 and SR 3.7.2.2 is possible because the revised MSIV closure time acceptance criteria covers a broader range of operating conditions and allows testing of the valves prior to entry into Mode 3. The broader range of applicability of SR 3.7.2.1 and SR 3.7.2.2 is a conservative change. Therefore, the NRC staff concludes that the proposed change is acceptable and, thus, meets 10 CFR 50.36 since the MSIVs can be tested before entry into Mode 3.

-8 3.4 Conclusions In its application, the licensee has proposed to (1) revise footnote U) in TS Table 3.3.2-1 to add the MFRVs and MFRVBVs to the footnote and (2) delete the same note in SR 3.7.2.1 and SR 3.7.2.2 for MSIVs.

Based on the evaluations in Sections 3.2 (footnote U) in TS 3.3.2) and Section 3.3 (SRs 3.7.2.1 and 3.7.2.2) of this safety evaluation, the NRC staff concludes that the proposed changes to TS 3.3.2 are conservative because the change expands the conditions for applicability to encompass all three sets of valves performing the main feedwater isolation function (MFIVs, MFRVs, and MFRVBVs) and the deletion of the notes in SR 3.7.3.1 and SR 3.7.3.2 is also conservative because the notes are no longer needed. The deletion broadens the range of applicability of SR 3.7.2.1 and SR 3.7.2.2 because the valves are now required to be demonstrated to be operable before entry into Mode 3. Therefore, the NRC staff concludes that the proposed changes are acceptable and satisfy the requirements of 10 CFR 50.36. Based on this, the NRC staff further concludes that the amendment is acceptable.

Regarding the licensee proposed changes to pages 1 and 2 of the Table of Contents (TOC) for the TSs, these changes result from the addition of a page. to TS Table 3.3.2-1 because of the revised footnotes, discussed in item 1 above, to two pages of the table. The increased text for footnote U) would add the additional page and the licensee is re-numbering the pages for TSs 3.3.3 through 3.3.9. This is the only change for TSs 3.3.3 through 3.3.9. The NRC staff concludes that these changes are administrative and have no effect on the requirements in the TSs. Based on the above, the NRC staff concludes that these changes satisfy 10 CFR 50.36 and are, therefore, acceptable.

The changes to TS table 3.3.2-1 also include a change to the parenthetical phrase "(page x of 8)" that is to the right of "Table 3.3.2-1" near the top of each page of the table. The change is to acknowledge that there are now a total of 9 pages in the table since an additional page was added to the table because of the revised footnote j. This is described in the previous paragraph. The NRC staff concludes that this change is administrative and has no effect on the requirements in the table. Based on this, the NRC staff also concludes that this change satisfies 10 CFR 50.36 and is, therefore, acceptable.

The licensee also identified changes to the TS Bases, for TS 3.3.2 on ESFAS instrumentation and TS 3.7.2 on SR 3.7.2.1 and SR 3.7.2.2, in Attachment 4 to its application. Changes to the TS Bases are controlled by TS 5.5.14, "Technical Specifications (TS) Bases Control Program,"

and, therefore, do not require approval by the NRC staff. However, the NRC staff reviews these changes for technical accuracy with respect to the proposed amendment and, based on that review, the NRC staff has no disagreement with what the licensee presented in Attachment 4 to its application.

There are no regulatory commitments submitted in the licensee's application.

4.0 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.

-9

5.0 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 significant hazards consideration and there has been no public comment on such 'finding as published in the Federal Register on March 25, 2008 (73 FR 15790). 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.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Letter from Brian Benney, U.S. Nuclear Regulatory Commission, to Charles Naslund, Union Electric Company, "Callaway Plant, Unit 1 - Issuance of Amendment Re: Revision to Technical Specification 3.7.3, "Main Feedwater Isolation Valves," to Add Main Feedwater Regulating Valves and MFRV Bypass Valves and to Extend the Allowed Outage Time," Amendment No. 167, dated May 31,2005 (ADAMS Accession No. ML051190334).

2. Letter from Jack Donohew, U.S. Nuclear Regulatory Commission, to Charles Naslund, Union Electric Company, "Callaway Plant, Unit 1 - Issuance of Amendment Re: Main Feedwater Isolation Valves Closure Time in Technical Specification 3.7.3," Amendment No. 170, dated November 17, 2005 (ADAMS Accession No. ML052970265).

3. Letter from Jack Donohew, U.S. Nuclear Regulatory Commission, to Charles Naslund, Union Electric Company, "Callaway Plant, Unit 1 - Issuance of Amendment Re: Removal of Valve Closure Times from the Technical Specifications to the Technical Specification Bases," Amendment No. 176, dated November 15, 2006 (ADAMS Accession No. ML062760093).

Principal Contributors: Ogbonna Hopkins Jack Donohew Date: December 18, 2008

ML083300110 OFFICE NRR/LPL4/P~ NRR/LPL4/LA DSS/SBPB(A) OGC NRRlLPL4/BC NRR/LPL4/PM NAME JDonohe\'{ VJlt1' JBurkhardt MRahimi' AJones MMarkley~ JDonohew ~\

DATE I/dj/~~ .D 12/5/08 11/13/08 12/05/08 lz.Y.~~ I 210ft JaR I '/

v t e Letter Sequence Approval
TAC:MD7786, (Approved, Closed)
Initiation Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2008-12-18 [Table View]

ML083300110

Text

SUBJECT:

Dear Mr. Heflin:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 BACKGROUND

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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