Text

Issuance of Amendment No. 197, Revise Technical Specification (TS) 3.7.2, Main Steam Isolation Valves (Msivs), and TS 3.3.2, ESFAS Instrumentation, and Add New TS 3.7.19, Secondary System Isolation Valves (Ssivs)
	ML101121025
Person / Time
Site:	Callaway
Issue date:	05/28/2010
From:	Thadani M; Plant Licensing Branch IV
To:	Heflin A; Union Electric Co
	Thadani, M C, NRR/DORL/LPL4, 415-1476
References
	TAC ME1324
	Download: ML101121025 (107)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 28, 2010 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: REVISION TO TECHNICAL SPECIFICATIONS 3.3.2 AND 3.7.2 AND ADDITION OF NEW TECHNICAL SPECIFICATION 3.7.19 (TAC NO. ME1324)

Dear Mr. Heflin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 197 to Facility Operating License No. I'JPF-30 for the Callaway Plant, Unit 1.

The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated May 4, 2009 (ULNRC-05566).

The proposed changes consist of the following:

Revise TS 3.7.2, "Main Steam Isolation Valves (MSIVs)," to add the main steam isolation valve bypass valves and main steam low point drain isolation valves to the scope of the TS and modify the title and page header of TS 3.7.2;

Revise footnotes (i) and (k) in TS Table 3.3.2-1, "Engineered Safety Feature Actuation Instrumentation," of TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," to make the Applicability of TS Table 3.3.2-1 consistent with the Applicability of TS 3.7.2 and delete footnote (I) which is no longer used in the Table; and

Add new TS 3.7.19, "Secondary System Isolation Valves (SSIVs)," Limiting Condition for Operation 3.7.19, and Surveillance Requirements (SRs) 3.7.19.1 and 3.7.19.2 for the following secondary system isolation valves: steam generator chemical injection isolation valves, steam generator blowdown isolation valves, and steam generator sample line isolation valves.

Correspondingly, the licensee proposed to add new Function 10, "Steam Generator Blowdown System and Sample Line Isolation Valve Actuation," and new exception footnote (t) for Function 10 in TS Table 3.3.2-1.

A. Heflin -2 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,

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Mohan C. Thadani, 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. 197 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. 197 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 May 4,2009, 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. 197 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 t~,tLJ- d I~J4j f-

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Ichael 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: May 28, 2010

ATIACHMENT TO LICENSE AMENDMENT NO. 197 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 - 3 (table of contents) 1 - 3 (table of contents) 3.3-32 3.3-32 3.3 3.3-74 3.3 3.3-76 3.7 3.7-43 3.7 3.7-46

-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. 197 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 No. 197

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 LIMITING 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 3.3-49 3.3.4 Remote Shutdown System 3.3-54 CALLAWAY PLANT Amendment 197

TABLE OF CONTENTS 3.3 INSTRUMENTATION (continued) 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation 3.3-57 3.3.6 Containment Purge Isolation Instrumentation 3.3-59 3.3.7 Control Room Emergency Ventilation System (CREVS)

Actuation Instrumentation 3.3-64 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation 3.3-69 3.3.9 Boron Dilution Mitigation System (BDMS) 3.3-74 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 3.4-1 0 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 Instru mentation 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 3.6.3 Containment Isolation Valves 3.6-7 CALLAWAY PLANT 2 Amendment 197

TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.4 Containment Pressure 3.6-16 3.6.5 Containment Air Temperature 3.6-17 3.6.6 Containment Spray and Cooling Systems 3.6-18 3.6.7 Recirculation Fluid pH Control (RFPC) System 3.6-21 3.6.8 Hydrogen Recombiners 3.6-22 3.7 PLANT SYSTEMS 3.7-1 3.7.1 Main Steam Safety Valves (MSSVs) 3.7-1 3.7.2 Main Steam Isolation Valves (MSIVs), Main Steam Isolation Valve Bypass Valves (MSIVBVs), and Main Steam Low Point Drain Isolation Valves (MSLPDIVs) 3.7-5 3.7.3 MFIVs and MFRVs and MFRV Bypass Valves 3.7-9 3.7.4 Atmospheric Steam Dump Valves (ASDs) 3.7-11 3.7.5 Auxiliary Feedwater (AFW) System 3.7-14 3.7.6 Condensate Storage Tank (CST) 3.7-18 3.7.7 Component Cooling Water (CCW) System 3.7-20 3.7.8 Essential Service Water System (ESW) 3.7-22 3.7.9 Ultimate Heat Sink (UHS) 3.7-25 3.7.10 Control Room Emergency Ventilation System (CREVS) 3.7-27 3.7.11 Control Room Air Conditioning System (CRACS) 3.7-31 3.7.12 Not Used 3.7-34 3.7.13 Emergency Exhaust System (EES) 3.7-35 3.7.14 Not Used 3.7-38 3.7.15 Fuel Storage Pool Water Level 3.7-39 3.7.16 Fuel Storage Pool Boron Concentration 3.7-40 3.7.17 Spent Fuel Assembly Storage 3.7-42 3.7.18 Secondary Specific Activity 3.7-44 3.7.19 Secondary System Isolation Valves (SSIVs) 3.7-45 3.8 ELECTRICAL POWER SYSTEMS 3.8-1 3.8.1 AC Sources - Operating 3.8-1 3.8.2 AC Sources - Shutdown 3.8-16 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8-20 3.8.4 DC Sources - Operating 3.8-23 3.8.5 DC Sources - Shutdown 3.8-26 3.8.6 Battery Cell Parameters 3.8-28 3.8.7 Inverters - Operating 3.8-32 3.8.8 Inverters - Shutdown 3.8-34 3.8.9 Distribution Systems - Operating 3.8-36 3.8.10 Distribution Systems - Shutdown 3.8-38 CALLAWAY PLANT 3 Amendment 197

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME P. One or more channel(s) P.1 Declare associated Immediately inoperable. auxiliary feedwater pump(s) inoperable.

AND P.2 Declare associated Immediately steam generator blowdown and sample line isolation valve(s) inoperable.

Q One train inoperable. ------------------- NOTE ------------------

One train may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other train is OPERABLE.

Q.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND Q.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months R. One or both train(s) R.1 Restore train(s) to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months inoperable. OPERABLE status.

OR R.2.1 Be in MODE 3. 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months AND R.2.2 Be in MODE 4. 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months (conti nued)

CALLAWAY PLANT 3.3-32 Amendment No. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 1 of 11)

Engineered Safety 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 3.3.28 NA Initiation

b. Automatic 1,2,3,4 2 trains C SR 3.3.2.2 NA Actuation SR 33.2.4 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 3.3.2.10

d. Pressurizer 1,2,3(b) 4 D SR 33.2.1 :2: 1834 psig Pressure SR 3.3.2.5 Low SR 3.3.2.9 SR 3.3.2.10

e. Steam Line 1,2,3(b) 3 per steam D SR 3.3.2.1 :2: 610 psig(c)(S)

Pressure line SR 3.3.2.5 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 3.3.28 NA Initiation 2 trains

b. 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)

(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 :2: 50 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. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 2 of 11)

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 SR 3.3.2.1 s 28.3 psig Pressure SR 3.3.2.5 High - 3 SR 3.3.2.9 SR 3.3.2.10

3. Containment Isolation

a. Phase A Isolation (1) Manual 1,2,3,4 2 B SR 3.3.2.8 NA Initiation (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 SR 3.32.13 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 3.3.2.8 NA Initiation 2 trains (2) Automatic 1,2,3,4 2 trains C SR 332.2 NA Actuation SR 3.3.24 Logic and SR 3.3.2.6 Actuation Relays (SSPS)

(3) Contain 1,2,3 4 E SR 3.3.2.1 s 28.3 psig ment SR 3.3.25 Pressure SR 3.3.29 High - 3 SR 3.3.2.10 (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. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 11)

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)(k), 3(i)(k) 2 F SR 3.3.2.8 NA

b. Automatic 1,2(i)(k), 3(i)(k) 2 trains G SR 3.3.. 2.2 NA Actuation Logic SR 33.2.4 and Actuation SR 3.3.2.6 Relays (SSPS)

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

d. Containment 1,2(i)(k), 3(i)(k) 3 D SR 3.3.2.1 ~ 18.3 psig Pressure - High 2 SR 3.3.2.5 SR 3.3.2.9 SR3.3.2.10 (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.

(i) Except when:

1. All MSIVBVs are:

1.a Closed and de-activated, or 1.b Closed and isolated by a closed manual valve, or 1.c Isolated by two closed manual valves.

AND

2. All MSLPDIVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve, or 2.c Isolated by two closed manual valves.

(k) Except when all MSIVs are closed and de-activated.

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

CALLAWAY PLANT 3.3-40 Amendment 1\10. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 4 of 11)

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

e. Steam Line Pressure (1) Low 1,2 (i)(k), 3(b)(i)(k) 3 per steam D SR 3.3.21 ~ 610 psig(c)(s) line SR 3.3.2.5 SR 3.3.2.9 SR 3.3.2.10 (2) Negative 3(g)(i)(k) 3 per steam D SR 3.3.2.1 s; 124 psi(h)

Rate - High line SR 3.3.2.5 SR 3.3.2.9 SR 3.3.2.10 (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 ~ 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 ~ 50 seconds.

(i) Except when:

1. All MSIVBVs are:

1.a Closed and de-activated, or 1.b Closed and isolated by a closed manual valve, or 1.c Isolated by two closed manual valves.

AND

2. All MSLPDIVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve, or 2.c Isolated by two closed manual valves.

(k) Except when all MSIVs are closed and de-activated.

(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. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 5 of 11)

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 3.3.24 and Actuation SR 3.3.2.6 Relays (SSPS) SR 3.3.2.14

b. Automatic 2 trains(o) S SR 3.3.2.3 NA Actuation Logic and Actuation Relays (MSFIS)

c. SG Water Level - 4 per SG SR 3.3.2.1 .,:; 91.4%(5) of High High (P-14) SR 3.3.2.5 Narrow Range SR 3.3.2.9 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.

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 3.3-42 Amendment No. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 6 of 11)

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 3.3.2.9 Low-Low Instrument SR 3.3.2.10 Span (Adverse Containment Environment)

(2) Steam 1(r), 20)(r), 3U)(r) 4 perSG D SR 3.3.2.1 ::: 16.6%(5) of Generator SR 3.3.2.5 Narrow Range Water Level SR 3.3.29 Low-Low Instrument SR 3.3.2.10 Span (Normal Containment Environment)

(a) The Allowable Value defines the limiting safety system setting except for Functions i.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.

(q) Feedwater isolation only.

(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 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. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 7 of 11)

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 3.3.2.1 ~ 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.

(q) Feedwater isolation only.

CALLAWAY PLANT 3.3-44 Amendment No. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 8 of 11)

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 3.3.2.8 NA

b. Automatic 1,2,3 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 1,2,3 2 trains Q SR 3.3.2.3 NA Actuation Logic and Actuation Relays (BOP ESFAS)

d. SG Water Level Low-Low (1) Steam 1,2,3 4 perSG D SR 3.3.2.1 ~ 20.6%(5) of Generator SR 3.3.25 Narrow Range Water Level SR 3.3.2.9 Instrument Low-Low SR 3.3.2.10 Span (Adverse Containment Environment)

(2) Steam 4 per SG D SR 3.3.2.1 ~ 16.6%(5) of Generator SR 3.3.2.5 Narrow Range Water Level SR 3.3.2.9 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 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 3.3-45 Amendment No. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 9 of 11)

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 SR 3.3.2.1 s; 2.0 psig Pressure SR 3.3.2.5 Environmental SR 3.3.2.9 Allowance SR3.3.210 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 3.3.2.1 220.64 psia Feedwater Pump SR 3.3.2.9 Suction Transfer SR 3.3.2.10 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.

(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 3.3-46 Amendment 1\10. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 10 of 11)

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

7. Automatic Switehover to Containment Sump

a. Automatic 1,2,3,4 2 trains C SR 3,3,2,2 NA Actuation Logic SR 3,3.2.4 and Actuation SR 3,3.213 Relays (SSPS)

b. Refueling Water 1,2,3,4 4 K SR 3,3,2,1 235.2%

Storage Tank SR 33.2.5 (RWST) Level SR 3,3.2.9 Low Low SR 3.3.2,10 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 SR 33.211 NA 2 trains

b. Pressurizer 1,2,3 3 L SR 3,3.2,5 $ 1981 psig Pressure, P-11 SR 3.3,2,9

9. Automatic Pressurizer PORV Actuation

a. Automatic 1,2,3 2 trains H SR 3.3.2.2 NA Actuation Logic SR 3.3.2.4 and Actuation SR 3.3,2.14 Relays (SSPS)

b. Pressurizer 1,2,3 4 D SR 3,3.2,1 $2350 psig Pressure - High SR 3,3,2.5 SR 33,2.9 (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 3.3-47 Amendment No. 197

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 11 of 11)

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

10. Steam Generator Blowdown and Sample Line Isolation

a. Manual Initiation 1(1),2(1),3(1) 2 trains P SR 3.3.2() NA (1 perMDAFW pump)

b. Automatic 1(1),2(1),3(t) 2 trains Q Sf.? :l3,;: ~~10% RTP.~~

Verify each AFW manual, power operated, and 31 days automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.5.2 --------------------------------- N()TE ---------------------------
Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after ~ 900 psig in the steam generator.
Verify the developed head of each AFW pump at the In accordance with flow test point is greater than or equal to the required the Inservice Test developed head. Program SR 3.7.5.3 Verify each AFW automatic valve that is not locked, 18 months sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
- - - - - - - - - - - - - - - - - - - - - - - - - - - *----*-*--l----(r=lc-=-o=ntZTIIn,,-,-u*ea)
CALLAWAY PLANT 3.7-16 Amendment No. 197 I
AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.5.4 --------------------------------- N()TE ---------------------------
Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 2': 900 psig in the steam generator.
Verify each AFW pump starts automatically on an 18 months actual or simulated actuation signal.
SR 3.7.5.5 Verify proper alignment of the required AFW flow Prior to entering paths by verifying flow from the condensate storage M()OE 2 tank to each steam generator. whenever unit has been in M()OE 5 or 6 for> 30 days CALLAWAY PLANT 3.7-17 Amendment No. 197 I
CST 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST)
LCO 3.7.6 The CST contained water volume shall be ~ 281,000 gal.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. CST contained water A.1 Verify by administrative 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months volume not within limit. means OPERABILITY of backup water supply. AND AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter A.2 Restore CST contained 7 days water volume to within limit.
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. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CALLAWAY PLANT 3.7-18 Amendment No. 197 I
CST 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify the CST contained water volume is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 
~~2: 281,000 gal.~~
CALLAWAY PLANT 3.7-19 Amendment No. 197 I
CCW System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One CCW train inoperable. A.1 ------------ NOTE ----------
Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"
for residual heat removal loops made inoperable by CCW.
Restore CCW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.
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 of Condition A not AND met.
B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months CALLAWAY PLANT 3.7-20 Amendment No. 197 I
CCW System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 --------------------------------- N()-rE ---------------------------
Isolation of CCW flow to individual components does not render the CCW System inoperable.
Verify each CCW manual, power operated, and 31 days automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.7.2 Verify each CCW automatic valve in the flow path that 18 months is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.7.7.3 Verify each CCW pump starts automatically on an 18 months actual or simulated actuation signal.
CALLAWAY PLANT 3.7-21 Amendment No. 197 I
ESW 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Essential Service Water System (ESW)
LCO 3.7.8 Two ESW trains shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One ESW train inoperable. A.1 ------------ NOTE ----------
~~1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sou rces-Operati ng,"~~
~~for emergency diesel generator made inoperable by ESW.~~
~~2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," for residual heat removal loops made inoperable by ESW.~~
(continued)
CALLAWAY PLANT 3.7-22 Amendment No. 197 I
ESW 3.7.8 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One ESW train inoperable. A.1 (continued) --------NOTE-------
A one-time Restore ESW train to Completion Time of OPERABLE status. 14 days is allowed to support planned replacement of ESW 'B' train piping prior to April 30, 2009.
72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 of Condition A not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months CALLAWAY PLANT 3.7-23 Amendment 197 I
ESW 3.7.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 --------------------------------- NOTE ---------------------------
Isolation of ESW flow to individual components does not render the ESW inoperable.
Verify each ESW manual, power operated, and 31 days automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.8.2 Verify each ESW automatic valve in the flow path that 18 months is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
SR 3.7.8.3 Verify each ESW pump starts automatically on an 18 months actual or simulated actuation signal.
CALLAWAY PLANT 3.7-24 Amendment No. 197 I
UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)
LCO 3.7.9 The UHS shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One cooling tower train A.1 Restore cooling tower 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. train to OPERABLE status.
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 lime of Condition A not AND met.
OR B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months UHS inoperable for reasons other than Condition A.
CALLAWAY PLANT 3.7-25 Amendment No. 197 I
UHS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of UHS is ~ 831.25 ft mean sea 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months level.
SR 3.7.9.2 Verify average water temperature of UHS is ~ 90°F. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.7.9.3 Operate each cooling tower fan for ~ 15 minutes in 31 days both the fast and slow speed.
CALLAWAY PLANT 3.7-26 Amendment No. 197 I
CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS)
LCO 3.7.10 Two CREVS trains shall be OPERABLE.

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

The control room envelope (CRE) and control building envelope (CBE) boundaries may be opened intermittently under administrative control.
APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CREVS train A.1 Restore CREVS train to 7 days inoperable for reasons other OPERABLE status.
than Condition B.
(continued)
CALLAWAY PLANT 3.7-27 Amendment No. 197 I
CREVS 3.7.10 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. One or more CREVS trains B.1 Initiate action to Immediately inoperable due to an implement mitigating inoperable CRE boundary or actions.
an inoperable CBE boundary in MODE 1, 2, 3, or 4. AND B.2 Verify mitigating actions to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant radiological exposure will not exceed limits and CRE occupants are protected from chemical and smoke hazards.
AND B.3 Restore the CRE 90 days boundary and CBE boundary to OPERABLE status.
C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or 4. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (contlnueo)
CALLAWAY PLANT 3.7-28 Amendment No. 197 I
CREVS 3.7.10 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREVS train in CRVIS Time of Condition A not met mode.
during movement of irradiated fuel assemblies.
OR D.2.1 Suspend CORE Immediately ALTERATIONS.
AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.
E. Two CREVS trains E.1 Suspend CORE Immediately inoperable during movement ALTERATIONS.
of irradiated fuel assemblies.
AND OR E.2 Suspend movement of Immediately One or more CREVS trains irradiated fuel assemblies.
inoperable due to an inoperable CRE boundary or an inoperable CBE boundary during movement of irradiated fuel assemblies.
F. Two CREVS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
CALLAWAY PLANT 3.7-29 Amendment No. 197 I
CREVS 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train pressurization filter unit 31 days for ~ 10 continuous hours with the heaters operating and each CREVS train filtration filter unit for
~ 15 minutes.

~~~~------.---~-----------___ t-------~- -~~

SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.10.3 Verify each CREVS train actuates on an actual or 18 months simulated actuation signal.
SR 3.7.10.4 Perform required unfiltered air inleakage testing of the In accordance with CRE and CBE boundaries in accordance with the the Control Room Control Room Envelope Habitability Program. Envelope Habitability Program CALLAWAY PLANT 3.7-30 Amendment 1\10. 197 I
CRACS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Air Conditioning System (CRACS)
LCO 3.7.11 Two CRACS trains shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One CRACS train A.1 Restore CRACS train to 30 days inoperable. OPERABLE status.
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 of Condition A not met AND in MODE 1,2,3, or4.
B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)
CALLAWAY PLANT 3.7-31 Amendment No. 197 I
CRACS 3.7.11 ACTIONS (continued)
COMPLETION CONDITION REQUIRED ACTION TIME C. Required Action and C.1 Place OPERABLE Immediately associated Completion CRACS train in Time of Condition A not met operation.
in MODE 5 or 6, or during movement of irradiated fuel OR assemblies.
C.2.1 Suspend CORE ALTERATIONS. Immediately AND C.2.2 Suspend movement of Immediately irradiated fuel assemblies.
D. Two CRACS trains 0.1 Suspend CORE Immediately inoperable in MODE 5 or 6, ALTERATIONS.
or during movement of irradiated fuel assemblies.
AND 0.2 Suspend movement of Immediately irradiated fuel assemblies.
E. Two CRACS trains E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or4.
CALLAWAY PLANT 3.7-32 Amendment No. 197 I
CRACS 3.7.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify each CRACS train has the capability to remove 18 months the assumed heat load.
CALLAWAY PLANT 3.7-33 Amendment No. 197 I
3.7.12 3.7 PLANT SYSTEMS 3.7.12 Not Used.
CALLAWAY PLANT 3.7-34 Amendment No. 197 I
Emergency Exhaust System 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Emergency Exhaust System (EES)
LCO 3.7.13 Two EES trains shall be OPERABLE.

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

The auxiliary or fuel building boundary may be opened intermittently under administrative control.
APPLICABI LlTY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies in the fuel building.

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

The SIS mode of operation is required only in MODES 1, 2, 3 and 4. The FBVIS mode of operation is required only during movement of irradiated fuel assemblies in the fuel building.
ACTIONS

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

LCO 3.0.3 is not applicable to the FBVIS mode of operation.
COMPLETION CONDITION REQUIRED ACTION TIME A. One EES train inoperable. A.1 Restore EES train to 7 days OPERABLE status.
B. Two EES trains inoperable B.1 Restore auxiliary building 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to inoperable auxiliary boundary to OPERABLE building boundary in status.
MODE 1,2,3 or4.
(continued)
CALLAWAY PLANT 3.7-35 Amendment No. 197 I
Emergency Exhaust System 3.7.13 ACTIONS (continued)
COMPLETION CONDITION REQUIRED ACTION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B not AND met in MODE 1, 2, 3, or 4.
C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two EES trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
D. Required Action and D.1 Place OPERABLE EES Immediately associated Completion Time train in the FBVIS mode.
of Condition A not met during movement of irradiated fuel assemblies in the fuel building.
OR D.2 Suspend movement of Immediately irradiated fuel assemblies in the fuel building.
E. Two EES trains inoperable E.1 Suspend movement of Immediately during movement of irradiated fuel irradiated fuel assemblies in assemblies in the fuel the fuel building. building.
CALLAWAY PLANT 3.7-36 Amendment No. 197 I
Emergency Exhaust System 3.7.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each EES train for ~ 10 continuous hours 31 days with the heaters operating.
SR 3.7.13.2 Perform required EES filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.13.3 Verify each EES train actuates on an actual or 18 months simulated actuation signal.
SR 3.7.13.4 Verify one EES train can maintain a negative pressure 18 months on a
~ 0.25 inches water gauge with respect to STAGGERED atmospheric pressure in the auxiliary building during TEST BASIS the SIS mode of operation.
SR 3.7.13.5 Verify one EES train can maintain a negative pressure 18 months on a
~ 0.25 inches water gauge with respect to STAGGERED atmospheric pressure in the fuel building during the TEST BASIS FBVIS mode of operation.
CALLAWAY PLANT 3.7-37 Amendment No. 197 I
3.7.14 3.7 PLANT SYSTEMS 3.7.14 Not Used.
CALLAWAY PLANT 3.7-38 Amendment No. 197 I
Fuel Storage Pool Water Level 3.7.15 3.7 PLANT SYSTEMS 3.7.15 Fuel Storage Pool Water Level LCO 3.7.15 The fuel storage pool water level shall be ~ 23 ft over the top of the storage racks.
APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Fuel storage pool water A.1 ----------- NOTE ----------
level not within limit. LCO 3.0.3 is not applicable.
Suspend movement of Immediately irradiated fuel assemblies in the fuel storage pool.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15.1 Verify the fuel storage pool water level is ~ 23 ft 7 days above the storage racks.
CALLAWAY PLANT 3.7-39 Amendment No. 197 I
Fuel Storage Pool Boron Concentration 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Fuel Storage Pool Boron Concentration LCO 3.7.16 The fuel storage pool boron concentration shall be ~ 2165 ppm.
APPLICABILITY: When fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Fuel storage pool boron ------------------- NOTE ------------------
concentration not within LCO 3.0.3 is not applicable.
limit.
A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.
AND A.2.1 Initiate action to restore Immediately fuel storage pool boron concentration to within limit.
A.2.2 Verify by administrative Immediately means that a non-Region 1 fuel storage pool verification has been performed since the last movement of fuel assemblies in the fuel storage pool.
CALLAWAY PLANT 3.7-40 Amendment No. 197 I
Fuel Storage Pool Boron Concentration 3.7.16 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 Verify the fuel storage pool boron concentration is 7 days within limit.
CALLAWAY PLANT 3.7-41 Amendment No. 197 I
Spent Fuel Assembly Storage 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Spent Fuel Assembly Storage LCO 3.7.17 The combination of initial enrichment and burnup of each spent fuel assembly stored in Region 2 or 3 shall be within the Acceptable Domain of Figu re 3.7.17-1 or in accordance with Specification 4.3.1.1.
APPLICABILITY: Whenever any fuel assembly is stored in the fuel storage pool.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Requirements of the LCO A.1 ------------ NOTE ----------
not met. LCO 3.0.3 is not applicable.
Initiate action to move Immediately the noncomplying fuel assembly to Region 1.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.17.1 Verify by administrative means the initial enrichment Prior to storing the and burnup of the fuel assembly is in accordance with fuel assembly in Figure 3.7.17-1 or Specification 4.3.1.1. Region 2 or 3 CALLAWAY PLANT 3.7-42 Amendment No. 197 I
Spent Fuel Assembly Storage 3.7.17 55000 50000
/
~~> - AC( 'EPTAB _E BUR NUP D~MAIN I -- FOR REGIO~ 2 AN D 3 S ~ORAGE~~
~
'o- 45000
-- ~'V
~
n ..
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1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 FUEL ASSEMBLY INITIAL ENRICHMENT (w/o U-235)
Figure 3.7.17-1 (page 1 of1)
MINIMUM REQUIRED FUEL ASSEMBLY BURNUP AS A FUNCTION OF INITIAL ENRICHMENT TO PERMIT STORAGE IN REGIONS 2 AND 3 CALLAWAY PLANT 3.7-43 Amendment No. 197 I
Secondary Specific Activity 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Secondary Specific Activity LCO 3.7.18 The specific activity of the secondary coolant shall be s; 0.10 IlCilgm DOSE EQUIVALENT 1-131. .
APPLICABILITY: MODES 1,2,3, and 4.
ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. Specific activity not within A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months limit.
AND A.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify the specific activity of the secondary coolant is 31 days
.:s;0.10 IlCilgm DOSE EQUIVALENT 1-131.
CALLAWAY PLANT 3.7-44 Amendment No. 197
SSIVs 3.7.19 3.7 PLANT SYSTEMS 3."1.19 Secondary System Isolation Valves (SSIVs)
LCO 3.7.19 The SSIVs shall be OPERABLE.

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

Locked closed manual SSIVs may be opened under administrative controls.
APPLICABILITY: MODES 1, 2, and 3 except for each secondary system flow path when:
~~a. At least one of the two associated SSIVs is closed and de-activated; or~~
~~b. At least one of the two associated SSIVs is closed and isolated by a closed manual valve; or~~
~~c. The SSIV flow path is isolated by two closed manual valves, or two closed de-activated automatic valves, or a combination of a closed manual valve and a closed de-activated automatic valve.~~
~~ACTIONS~~

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

Separate Condition entry is allowed for each secondary system flow path.
COMPLETION CONDITION REQUIRED ACTION TIME A. One or more SSIVs ------------------ NOTE ------------------
inoperable. Closed or isolated automatic SSIVs may be opened or unisolated under administrative controls.
A.1 Close or isolate SSIV. 7 days AND A.2 Verify SSIV is closed or Once per 7 days isolated.
CALLAWAY PLANT 3.7-45 Amendment No. 197
SSIVs 3.7.19 ACTIONS (continued)
COMPLETION CONDITION REQUIRED ACTION TIME (contlnuedl 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. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.19.1 Verify the isolation time of each automatic SSIV is In accordance with within limits. the Inservice Testing Program SR 3.7.19.2 Verify each automatic SSIV in the flow path actuates 18 months to the isolation position on an actual or simulated actuation signal.
CALLAWAY PLANT 3.7-46 Amendment No. 197
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 197 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483
~~1.0 INTRODUCTION~~
By letter dated May 4, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091310167), Union Electric Company, the licensee for the Callaway Plant, Unit 1, requested an amendment to Facility Operating License No. NPF-30. In its application, the licensee proposed the following changes:
Revise Technical Specification (TS) 3.7.2, "Main Steam Isolation Valves (MSIVs)," to add the main steam isolation valve bypass valves (MSIVBVs) and main steam low point drain isolation valves (MSLPDIVs) to the scope of the TS and modify the title and page header of TS 3.7.2;
Revise footnotes (i) and (k) in TS Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation," of TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," to make the Applicability of TS Table 3.3.2-1 consistent with the Applicability of TS 3.7.2 and delete footnote (I) which is no longer used in the Table; and
Add new TS 3.7.19, "Secondary System Isolation Valves (SSIVs)," Limiting Condition for Operation (LCO) 3.7.19, and Surveillance Requirements (SRs) 3.7.19.1 and 3.7.19.2 for the following secondary system isolation valves:
steam generator chemical injection isolation valves, steam generator blowdown isolation valves, and steam generator sample line isolation valves.
Correspondingly, the licensee proposed to add new Function 10, "Steam Generator Blowdown and Sample Line Isolation," and new exception footnote (t) for Function 10 in TS Table 3.3.2-1.
Enclosure 2
-2
~~2.0 REGULATORY EVALUATION~~
2.1. Regulatory Requirements Section 182a of the Atomic Energy Act of 1954, as amended, requires applicants for licenses to operate nuclear power plants to include TSs as part of the license application. These TSs become part of any license issued and are derived from the plant safety analyses.
The regulations in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications," contain the requirements for the content of 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) LCOs; (3) SRs; (4) design features; and (5) administrative controls.
The regulations in 10 CFR 50.36(c)(2)(ii) list four criteria used to determine whether or not LCOs must be established in the TSs for items related to plant operation. If the item meets one or more of the four criteria listed below, an LCO must be established in the TSs to ensure the lowest functional capability or performance level of equipment required for safe operation of the facility will be met. The four criteria are:
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 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.
The regulations in 10 CFR 50.36 do not specify each particular requirement to be included in a plant's TSs, nor do they specify the format of a plant's TSs. Rather, the U.S. Nuclear Regulatory Commission (NRC) publishes generic guidance on TS format and content. The NRC published a set of Standard Technical Specifications (STS) in NUREG-1431, Revision 3, "Standard Technical Specifications, Westinghouse Plants," dated March 2004. The STS are a guide to what a plant's TS should contain with regard to format and content. The STS are not requirements in a regulatory sense, but licensees adopting portions of the improved STS to eXisting TSs should adopt all related requirements, as applicable, to achieve a high degree of standardization and consistency.
-3 Licensees may propose revisions to the TSs to adopt improved STS format and content provided that the plant-specific review supports a determination 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. The NRC staff reviews the proposed revision and determines whether or not the proposed revision is acceptable. If the staff determines that the proposed revision is acceptable, the staff changes the licensee's TSs. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0, "Technical Evaluation," in the context of specific proposed changes.
2.2 System Description Section 15.1.5 of Revision 14 to the Callaway Final Safety Analysis Report (FSAR) presented results for the design basis main steam line break accident. The major rupture of a steam line was the most limiting cooldown transient and was analyzed at zero power with no decay heat.
Effects of minor secondary system pipe breaks were bounded by this analysis. The main steam isolation valves, the associated bypass valves, and the steam line drain valves isolate the steam generators and the main steam lines upon a signal initiated by the engineered safety features actuation system under the conditions of high negative steam line pressure rates, low steamline pressure, or high containment pressures. Callaway FSAR Table 15.1-2, "Equipment Required Following a Rupture of a Main Steam Line," included the following required equipment: the main steam isolation valves (trip closed feature), the main steam isolation bypass valves (trip closed feature), the steam generator blowdown isolation valves (automatic closure feature), and the auxiliary feedwater system, (including pumps, water supplies, piping and valves). Isolation of the chemical injection lines in the feedwater system supports operation of the auxiliary feedwater system.
Section 10.4.7.3 of Revision 14 to the Callaway FSAR described that, for a main feedwater line break inside the containment or a main steam line break, the main feedwater isolation valves located in the auxiliary building and the main feedwater control valves located in the turbine building automatically close upon receipt of a feedwater isolation signal or low-low steam generator level signal. For each intact feedwater loop, the main feedwater isolation valve, main feedwater control valve, and associated redundant isolation of the chemical addition line would close, forming a pressure boundary to permit auxiliary feedwater addition. Callaway FSAR Table 10.4-7, "Feedwater Isolation Single Failure Analysis," described that, should the chemical addition isolation valve fail to close upon receipt of an automatic signal, the associated check valve would close, providing adequate isolation.
The licensee provided information regarding the function and operation of the various steam isolation valves in the May 4, 2009, letter. The attachment included the following information about the steam isolation valves:
The Main Steam System functions to (1) contain and transport saturated steam from the steam generator to the main turbine and other loads, (2) serve as the main heat sink for the primary system, preventing fuel overheating during transients and accidents, and (3) supply a source of power to the turbine-driven
-4 auxiliary feedwater pump (TDAFP) turbine. The Main Steam System starts at the four steam generators and includes the components on each of the four main steam lines. Leaving the steam generator, each main steam line contains an atmospheric steam dump valve and five main steam safety valves. Downstream of the main steam safety valves, are steam supplies to the TDAFP via two of the four steam headers.
Main steam then flows through the main steam isolation valves (MSIVs) or MSIV Bypass valves (MSIVBVs) to the turbine bUilding. The MSIVs and MSIVBVs provide steam generator isolation for steam line break protection. Upstream of the MSIVs, the steam generators act independently of each other when the MSIVs are closed. Normally the MSIVs are open and the MSIVBVs are closed.
When the MSIVs are open, the individual main steam flows from the steam generators tie together in a parallel confjguration which is then distributed to loads in the turbine building. The crosstie header equalizes the pressure in all four steam generators which maintains equal flow on all the generators. On each steam header upstream of the MSIVs is a 12-inch diameter drain standpipe.
Attached to the 12-inch line is a 1-inch diameter line back to the condenser. One air-operated low point drain isolation valve (MSLPDIV) is installed in each 1-inch drain line. The MSLPDIV is normally open to allow a steam trap to pass moisture to the main condenser. FSAR Section 10.3 describes the Main Steam Supply system.
MSIV Bypass Valves (MSIVBVs)
The MSIVBVs are air-operated, two-inch bypass valves around the MSIVs. They are provided for warming of downstream steam lines and equalizing the steam pressure across the MSIVs. The MSIVBVs have two redundant solenoid valves which, when deenergized, result in valve closure. Both of the solenoid valves are de-energized on a steamline isolation signal. The MSIVs and bypass valves are controlled from the main control board panel. The bypass valves also have manual handwheels that are normally locked in the neutral position.
Main Steam Low Point Drain Isolation Valves (MSLPDlVs)
On each of the four main steam lines, upstream of the main steam isolation valves, is a 12-inch diameter low point drain line. Each drain line has a level detection system that consists of a level switch that annunciates on a high level.
One air-operated low point drain valve (IVISLPDIV) is installed in each drain line.
The MSLPDIVs are normally open to allow a steam trap to pass moisture to the main condenser. The MSLPDIVs close upon receipt of a steam line isolation signal (SLlS) and function to isolate the plant's secondary side. The MSLPDIVs fail in the closed position.
Steam Generator Blowdown Isolation Valves (SGBSlVs)
The SGBSIVs are air-operated globe valves which fail closed. For emergency closure, either of two safety-related solenoid valves is de-energized to dump air
-5 supplied to the valve actuator. The electrical solenoid valves are energized from separate Class 1E sources and are tripped upon receipt of a steam generator blowdown isolation signal.
Steam Generator Blowdown Sample Isolation Valves (SGBSSIVs)
Three SGBSSIVs are installed in each of the sample line flow paths for each steam generator. Two valves are located inside the containment (one from each sample point), and one valve is located outside containment. The SGBSSIVs prevent uncontrolled blowdown from more than one steam generator and isolate the non-safety related portions from the safety-related portions of the system.
The SGBSSIVs are solenoid-operated globe valves which fail closed. The inside containment solenoid valves are energized from separate Class 1E sources from the outside containment solenoid valves. These valves are also closed upon receipt of a steam generator blowdown isolation signal.
Steam Generator Chemical Injection Isolation Valves (SGCIIVs)
The SGCllVs are air-operated globe valves, which fail closed on loss of air. The valves automatically close upon receipt of a feedwater isolation signal. When the valves are closed or isolated they function to isolate the plant's secondary side.
Containment Isolation Licensing Basis As noted in FSAR Sections 6.2.4.3,6.2.6.3, and on Figure 6.2.4-1 and Figure 6.2.4-2, the containment penetrations associated with steam generators are not subject to the 10 CFR 50 Appendix A General Design Criteria that address containment isolation provisions, since the containment barrier integrity is not breached. At Callaway, the boundary or barrier against fission product leakage to the environment is the inside of the steam generator tubes and the outside of the lines emanating from the steam generator shells. The piping itself is an extension of containment and thus treated as the containment barrier. Therefore, the purpose of the main steam line and feed line isolation valves is to isolate the plant secondary side, to control steam generator blow down, and to ensure the delivery of required auxiliary feedwater flow during a design basis accident.
~~3.0 TECHNICAL EVALUATION~~
The NRC staff reviewed the proposed changes for compliance with 10 CFR 50.36 and agreement with the STS. In general, licensees cannot justify technical specification changes solely on the basis of adopting the model STS. To ensure this, the NRC staff makes a determination that proposed changes maintain adequate safety. Changes that result in relaxation (Le., a less restrictive condition) of current TS requirements require detailed justification. The following is the NRC staff's detailed evaluation of the licensee's proposed changes to the TSs.
-6 3.1 TS 3.7.2, "Main Steam Isolation Valves (MSIVs)"
The proposed changes to TS 3.7.2 are as follows:
Currently, TS 3.7.2 is entitled "Main Steam Isolation Valves (MSIVs)." Revised TS 3.7.2 will be entitled "Main Steam Isolation Valves (MSIVs), Main Steam Isolation Valve Bypass Valves (MSIVBVs), and Main Steam Low Point Drain Isolation Valves (MSLPDIVs)." In addition, the current page header for TS 3.7.2, "MSIVs," will be changed to "MSIVs, MSIVBVs, and MSLPDIVs."
Currently, LCO 3.7.2 states, "Four MSIVs and their associated actuator trains shall be OPERABLE." Revised LCO 3.7.2 will state, "The MSIV and its associated actuator trains, the MSIVBV, and the MSLPDIV in each of the four main steam lines shall be OPERABLE."
Currently, the Applicability statement for TS 3.7.2 states "MODES 1,2, and 3." The revised Applicability statement for TS 3.7.2 will state:
For the MSIV and its associated actuator trains in each main steam line:
MODE 1, MODES 2 and 3 except when the MSIV is closed and de-activated.
For the MSIVBV in each main steam line:
MODES 1, 2, and 3 except when:
~~a. MSIVBV is closed and de-activated, or~~
~~b. MSIVBV is closed and isolated by a closed manual valve, or~~
~~c. MSIVBV is isolated by two closed manual valves.~~
For the MSLPDIV in each main steam line:
MODES 1, 2, and 3 except when:
~~a. MSLPDIV is closed and de-activated, or~~
~~b. MSLPDIV is closed and isolated by a closed manual valve, or~~
~~c. MSLPDIV is isolated by two closed manual valves.~~
~~Currently, Condition E of TS 3.7.2 states, in part "Three or more actuator trains inoperable." Revised Condition E of TS 3.7.2 will state, in part "Three or more MSIV actuator trains inoperable."~~
-7
~~New TS 3.7.2 Conditions H and I will state the following:~~
COMPLETION CONDITION REQUIRED ACTION TIME H. ----------NO-rE----------- H.1 Close or isolate 7 days Separate Condition MSIVBV.
entry is allowed for each main steam line.

~~AND One or more MSIVBVs H.2 Verify MSIVBV is Once per 7 days inoperable. closed or isolated.~~

I. ----------NOTE----------- 1.1 Close or isolate 7 days Separate Condition MSLPDIV.
entry is allowed for each main steam line.

~~AND One or more 1.2 Verify MSLPDIV is Once per 7 days MSLPDIVs inoperable. I closed or isolated.~~

The current TS 3.7.2 Condition H will be re-Iabeled as Condition J; current Required Actions H.1 and H.2 will be re-Iabeled as Required Actions J.1 and J.2, respectively, and the current Note which states "Separate Condition entry is allowed for each MSIV," will be revised to state "Separate Condition entry is allowed for each main steam line."
The current TS 3.7.2 Condition I, which states "Required Action and associated Completion Time of Condition H not met," will be re-Iabeled as Condition K and revised to state "Required Action and associated Completion Time of Conditions H, I, or J not met." Also, current Required Actions 1.1 and 1.2 will be re-Iabeled as Required Actions K.1 and K.2, respectively.
Currently, SR 3.7.2.2 states "Verify each MSIV actuates to the isolation position on an actual or simulated actuation signaL" Revised SR 3.7.2.2 will state "Verify each MSIV, each MSIVBV, and each MSLPDIV actuates to the isolation position on an actual or simulated actuation signaL"
~~New SR 3.7.2.3 will state:~~
SURVEILLANCE FREQUENCY SR 3.7.2.3 Verify isolation time of each MSIVBV In accordance with the and MSLPDIV is within limits. Inservice Testing Program.
-8
The proposed changes to the TS Table of Contents result from the revisions as discussed above; therefore, the licensee is renumbering the pages for TS 3.7.3 through TS 3.7.18. This is the only change for TS 3.7.3 through TS 3.7.18.
The licensee proposed to add LCOs requiring operability of the MSIVBV and the MSLPDIV to TS 3.7.2. The existing TS 3.7.2 LCO requires operability of the MSIV and its associated actuator trains in each of the four main steam lines. In Section 4.1 of its letter dated May 4, 2009, the licensee stated that the MSIVBVs are normally closed during plant operation, while the MSIVs are open. However, the MSIVBVs are open for warming of the steam lines and equalizing steam pressure across the MSIVs, and they may also be opened to support maintenance and testing. The licensee also described that the MSLPDIVs are normally open during plant operation. Similarly, the MSIVs are also normally open.
The licensee identified that, although less significant in terms of potential accident consequences, either an open MSIVBV or an open MSLPDIV constitutes a flow path similar to the MSIVs and should be subject to the same or similar requirements. The proposed TS change would add the MSIVBVs and the MSLPDIVs to the TSs, and more clearly convey that each valve's isolation function is required for its respective steam line. The proposed LCO would ensure the MSIV, MSIVBV, and MSLPDIV in each steam line would isolate steam flow from the secondary side following a high-energy line break. Therefore, the NRC staff concludes that addition of the MSIVBVs and MSLPDIVs to TS LCO 3.7.2 is consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii), and is, therefore, acceptable.
The licensee proposed a change in the TS applicability for the MSIVs and addition of specific applicability for the MSIVBVs and MSLPDIVs. The MSIVs and the associated actuator trains would be required to be operable at all times in MODE 1. In MODES 2 and 3, the MSIVs and the associated actuator trains are required to be operable except when the MSIV is closed and deactivated. This proposed MSIV applicability is consistent with the Westinghouse improved STS, and the exception for a closed and de-activated MSIV in MODES 2 and 3 provides assurance that the valve would perform its safety function. Similar to the MSIVs, the MSIVBVs and the MSLPDIVs would be required to be operable in MODES 1, 2, and 3, except when the affected valve is in one of the following conditions:
~~a. closed and de-activated, or~~
~~b. closed and isolated by a closed manual valve, or~~
~~c. isolated by two closed manual valves.~~
Anyone of these conditions assures, assuming a single failure, that the required safety function of isolating steam flow from the secondary side following a high-energy line break would be accomplished. Therefore, the NRC staff concludes that the proposed Applicability of revised TS 3.7.2 is acceptable.
The licensee proposed revised Conditions, Required Actions, and Completion Times for TS 3.7.2. Conditions A through G, which relate to the MSIVs, would be unchanged with the exception of an editorial change to Condition E clarifying that the Condition applies to the MSIV actuator. The licensee proposed adding new Conditions H and I, which would allow for a separate Condition entry for each steam line for one or more inoperable MSIVBVs and one or
- 9 more inoperable MSLPDIVs, respectively. The associated Actions and Completion Times for new Conditions H and I would be to close or isolate the affected valve within 7 days and to verify the affected valve is closed or isolated once every 7 days thereafter. The licensee also proposed making editorial changes to existing Condition H that would re-Iabel it Condition J and specify a separate Condition entry for each main steam line (rather than for each MSIV).
Finally, existing Condition I would be re-Iabeled as Condition K and changed so it would apply when the Required Action and associated Completion Time are not satisfied for new Conditions H or I (one or more inoperable MSIVBVs or MSLPDIVs, respectively). Condition K would continue to apply when the Required Action and associated Completion Time are not satisfied for Condition J (one or more inoperable MSIVs in MODES 2 or 3). The Required Actions and Completion Times for Condition K would be unchanged. Therefore, the overall effect of the proposed changes would be to expand the scope to include inoperable MSIVBVs and MSLPDIVs and specify Required Actions and Completion Times for these added Conditions, and the NRC staff concludes that this change is acceptable because the changes provide additional safety.
The proposed Completion Times for closure of the MSIVBVs and MSLPDIVs under Conditions H and I, respectively, are significantly longer than the existing Completion Time for closure of an inoperable MSIV in MODE 2 or 3. However, the longer Completion Time would be justified by the low probability of a high-energy line break requiring isolation of the specific MSIVBV or MSLPDIV line and the significantly lower consequences associated with failure to isolate the associated small diameter lines. Therefore, the NRC staff concludes that the specification of a 7-day Completion Time for initial closure of one or more inoperable MSIVBVs and/or MSLPDIVs is acceptable.
The licensee also proposed to revise SR 3.7.2.2 and add new SR 3.7.2.3 to demonstrate that the MSIVBVs and MSLPDIVs would actuate to the isolation position on an actual or simulated actuation signal (modified SR 3.7.2.2) and would isolate within the required time (new SR 3.7.2.3). These changes to the SRs would be consistent with the additional LCOs.
Therefore, the NRC staff concludes that the changes to the SRs are acceptable.
3.2 TS 3.7.19, "Secondary System Isolation Valves (SSIVs)"
In its application dated May 4,2009, the licensee proposed to add new TS 3.7.19 which states:
3.7.19 Secondary System Isolation Valves (SSIVs)
LCO 3.7.19 The SSIVs shall be OPERABLE.

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

Locked closed manual SSIVs may be opened under administrative controls.
APPLICABILITY: MODES 1, 2, and 3 except for each secondary system flow path when:
~~a. At least one of the two associated SSIVs is closed and de-activated; or~~
~~- 10~~
~~b. At least one of the two associated SSIVs is closed and isolated by a closed manual valve; or~~
~~c. The SSIV flow path is isolated by two closed manual valves, or two closed de-activated automatic valves, or a combination of a closed manual valve and a closed de-activated automatic valve.~~
~~ACTIONS~~

~~NO"rE:-----------------------------------------------------~~

Separate Condition entry is allowed for each secondary system flow path.
COMPLE:TION CONDITION RE:QUIRE:D ACTION TIME:
A. One or more SSIVs --------------------NOTE:-----------------
inoperable. Closed or isolated automatic SSIVs may be opened or unisolated under administrative controls.
A.1 Close or isolate MSIVBV. 7 days AND A.2 Verify SSIV is closed or Once per 7 days isolated.
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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.2 Be in MODE: 4.
SURVE:ILLANCE: RE:QUIRE:ME:NTS SURVE:ILLANCE: FRE:QUE:NCY SR 3.7.19.1 Verify isolation time of each automatic SS IV is In accordance with within limits. the Inservice Testing Program.
SR 3.7.19.2 Verify each automatic SSIV in the flow path 18 months actuates to the isolation position on an actual or simulated actuation signal.
~~The proposed changes to the TS Table of Contents result from the addition of newTS 3.7.19.~~
The licensee proposed the addition of new TS 3.7.19, "Secondary System Isolation Valves (SSIVs)." The TS 3.7.19 would apply to the normally locked-closed manual steam generator chemical injection isolation valves, the automatically isolated steam generator blowdown isolation valves and the steam generator sample line isolation valves. The licensee provided
- 11 Bases for the proposed new TS that more specifically identified the SSIVs. The proposed LCO simply states that "SSIVs shall be OPERABLE." This LCO is modified by a note stating that locked closed manual SSIVs may be opened under administrative controls. In its letter dated May 4, 2009, the licensee states that the administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way, the valve can be rapidly isolated when a need for isolation is indicated.
The licensee proposed an LCO applicability that would require the SSIVs to be operable in MODES 1, 2, and 3, which is when there is significant mass and energy in the reactor coolant system and steam generators. The licensee proposed exceptions to the applicability where performance of the safety function of the SSIV in a particular secondary system flow path is assured by one of the following conditions:
~~a. at least one of the two associated SSIVs in the line is closed and de-activated; or~~
~~b. at least one of the two associated SSIVs is closed and isolated by a closed manual valve; or~~
~~c. the SSIV flow path is isolated by two closed manual valves, or two closed de-activated automatic valves, or a combination of a closed manual valve and a closed de-activated automatic valve.~~
Anyone of these conditions assures, assuming a single failure, that the safety function of the SSIV would be performed consistent with the analyses for the main steam line break accident and mitigation by the auxiliary feedwater system. Therefore, the LCO and the proposed Applicability are consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii). The NRC staff concludes that the proposed changes are acceptable.
The licensee provided Conditions, Required Actions, and Completion Times for the new TS. The Conditions and Required Actions would be modified by a Note indicating that separate condition entry is allowed for each secondary system flow path. For Condition A, which involves one or more inoperable SSIVs, the associated Required Actions and Completion Times for this condition would be to close or isolate the affected valve within 7 days and to verify the affected valve is closed or isolated once every 7 days thereafter. The Required Action would be modified by a Note stating that closed or isolated automatic SSIVs may be opened or unisolated under administrative controls. When the SSIV is closed or isolated, it is performing its specified safety function. The 7-day Completion Time takes into account the low probability of an event occurring during this period that would require isolation of the plant's secondary side. The licensee considered the 7-day Completion Time reasonable based on operating experience and the amount of flow through each SSIV. Callaway Plant's Final Safety Analysis Report Table 10.4-7 identifies that a check valve performs the isolation function if the chemical injection isolation valve fails to close. In Section 4.4 of its letter dated May 4, 2009, the licensee described that the flow area for the blowdown isolation valves was insignificant because the flow would be through 3lB-inch tubing. The NRC staff determined that the allowance for operation of the valves under administrative controls, the 7-day Completion Time, and the 7-day period for verification was consistent with the safety significance of the valve operation. If the Required Action and associated Completion Time of Condition A is not met, the unit must be placed in a mode in which the LCO does not apply. To achieve this status, Action B would require placing the unit in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are
- 12 reasonable, based on operating experience, for reaching the required unit conditions in an orderly manner and without challenging unit systems. Therefore, the NRC staff concludes that the proposed Conditions, Required Actions, and Completion Times for new TS 3.7.19 are acceptable.
Finally, the licensee proposed SRs for proposed new TS 3.7.19. The proposed SR 3.7.19.1 verifies that the isolation time of each automatic SSIV is within limits when tested pursuant to the Inservice Testing Program. The licensee clarified that this SR would be performed only for automatic SSIVs. This surveillance does not include verifying a closure time for the steam generator chemical addition injection isolation valves because these valves are normally locked closed and only opened under administrative controls. The frequency for this SR is in accordance with the Inservice Testing Program. The proposed SR 3.7.19.2 verifies that each automatic SSIV in the flow path is capable of closure on an actual or simulated actuation signal.
The proposed frequency for this SR is 18 months. This interval is consistent with that of the MSIVs. The proposed SRs are consistent with SRs for other steam isolation valves with greater safety significance. Therefore, the NRC staff concludes that proposed SRs are acceptable.
3.3 TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation" In its application dated May 4, 2009, the licensee proposed changes to TS 3.3.2 as follows:
~~New Required Action P.2 will state:~~
~~REQUIRED ACTION COMPLETION TIME P.2 Declare associated steam generator blowdown Immediately and sample line isolation valve(s) inoperable.~~
~~TS Table 3.3.2-1, current footnote (i), which states "Except when all MSIVs are closed," will be revised to state:~~
~~(i) Except when:~~
~~1. All MSIVBVs are:~~
1.a Closed and de-activated, or 1.b Closed and isolated by a closed manual valve, or 1.c Isolated by two closed manual valves.
AND
~~2. All MSLPDIVs are:~~
~~2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve, or 2.c Isolated by two closed manual valves.~~
~~TS Table 3.3.2-1, Function 4, "Steam Line Isolation," revises current footnote (k) "Not used" to state:~~
(k) Except when all MSIVs are closed and de-activated.
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T8 Table 3.3.2-1, current footnote (I) "Not used" in Function 5, "Turbine Trip and Feedwater Isolation," and Function 6, "Auxiliary Feedwater," will be deleted because the footnote designation is no longer used in the Table.
~~T8 Table 3.3.2-1, new Function 10 and new exception footnote (t) will state:~~
APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALLIE (a)
~~10. Steam Generator Blowdown and Sample Line Isolation~~
~~a. Manual Initiation 2 trains P SR 3.3.2.8 NA (1 per MDAFW pump)~~
~~b. Automatic 2 trains Q SR 3.3.2.3 NA Actuation Logic and Actuation Relays (BOP ESFAS)~~
~~c. Safety Injection Refer to Function 1 (Safety Injection) for initiation functions and requirements.~~
~~d. Loss of Offsite 2 trains R SR 3.3.2.7 NA Power (t) Except when all Steam Generator Blowdown and Sample Line Isolation Valves are:~~
~~1. Closed and de-activated, or~~
~~2. Closed and isolated by a closed manual valve, or~~
~~3. Isolated by a combination of closed manual valve(s) and closed de-activated automatic valve(s).~~
~~- 14~~
The proposed changes to pages 1 and 2 of the TS Table of Contents result from the revisions as discussed above; therefore, the licensee is renumbering the pages for TS 3.3.4 through TS 3.3.9. This is the only change for TS 3.3.4 through TS 3.3.9.
The licensee determined that the addition of the MSIVBVs and MSLPDIVs to the scope of TS 3.7.2 (along with the clarifications being made to the Applicability of that TS), as well as the incorporation of new TS 3.7.19 for the SSIVs, requires appropriate supporting changes to be made to TS 3.3.2. The TS 3.7.2 changes and the new TS 3.7.19 both require the revision or addition of footnotes associated with TS Table 3.3.2-1. New TS 3.7.19 requires the addition into Table 3.3.2-1 of new Function 10, "Steam Generator Blowdown and Sample Line Isolation," and new Required Action P.2 for an inoperable auxiliary feedwater manual initiation channel.
The proposed footnotes for TS 3.3.2 modify the Applicability of operability requirements for specific engineered safety feature initiation functions. The licensee proposed to modify an existing footnote and add a new footnote. These footnotes would exclude certain actuation instrumentation functions from operability requirements when all valves initiated by the channel are not required to be operable because the valves are closed and deactivated or isolated such that the safety function is satisfied. Use of this type of footnote is consistent with the improved STS in NUREG-1431. Therefore, the NRC staff concludes that the proposed changes are acceptable.
The licensee proposed adding the new Function 10 for steam generator blowdown and sample line isolation because the steam generator blowdown isolation valves and the steam generator sample line isolation valves automatically close on a steam generator blowdown system isolation signal. For conditions where one or more channels for manual initiation of this signal are inoperable, the licensee proposed the addition of Required Action P.2, which requires operators to immediately declare the associated steam generator blowdown and sample isolation valves inoperable. The licensee deleted footnote (I) which was not used and proposed new exception footnote (t) to the Table 3.3.2-1. These actions are consistent with the reduced capability to promptly close the affected valves. Based on the above, the NRC staff concludes that the proposed changes are acceptable.
~~3.4 NRC Staff Conclusion~~
Based on the above review of the licensee's analysis and the conservative nature of the changes, the NRC staff concludes that the proposed changes to TSs 3.7.2 and 3.3.2 that add the MSIVBVs and MSLPDIVs to the TS scope are consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii) and, therefore, are acceptable. The staff also concludes that the addition of TS 3.7.19 is conservative, consistent with Criterion 3 of 10 CFR 50.36(c)(2)(ii) and, therefore, the associated changes are acceptable.
~~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.
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~~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 published in the Federal Register on August 25,2009 (74 FR 42933). 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.
Principal Contributors: S. Jones M. Hamm Date: May 28, 2010
A. Heflin -2 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, IRA!
Mohan C. Thadani, 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. 197 to NPF-30~~
~~2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:~~
PUBLIC RidsNrrPMCallaway Resource LPLIV Reading RidsNrrLAJBurkhardt Resource RidsAcrsAcnw_MailCTR Resource RidsOgcRp Resource RidsNrrDirsltsb Resource RidsRgn4MailCenter Resource RidsNrrDorlDpr Resource MHamm, NRR/DIRS/ITSB RidsNrrDorlLpl4 Resource SJones, NRR/DSS/SBPB RidsNrrDssSbpb Resource ADAMS Accession No. ML101121025 *SE memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LA NRRIDIRSIITSB/BC NRRIDSS/SBPB/BC OGC NRR/LPL4/BC NRR/LPL4/PM MMarkleyJR NAME MThadani JBurkhardt RElliott* GCasto* CKanatas Hall for MThadani DATE 5/24/10 5/24/10 3/2110 2/16/10 5/24/10 5/28/10 5/28/10 OFFICIAL RECORD COpy

v t e Letter Sequence Approval
TAC:ME1324, (Approved, Closed)
Initiation Acceptance Administration Questions Answers Results Approval, Approval Other: ML101940108, ML101940117
MONTHYEAR2010-05-28 [Table View]

ML101121025

Text

SUBJECT:

Dear Mr. Heflin:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

3.4 NRC Staff Conclusion

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

Enclosures:

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