Text

Completion Time Extensions for TS 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation Functions (LDCN 09-0039 Supplement)
	ML102730351
Person / Time
Site:	Callaway
Issue date:	09/29/2010
From:	Maglio S; AmerenUE, Union Electric Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	LDCN 09-0039, TAC ME2822, ULNRC-05731
	Download: ML102730351 (42)
	v • d • e

AmerenUE PO Box 620 Cal/away Plant Fulton, MO 65251 September 29, 2010 ULNRC-05731 u.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:

DOCKET NUMBER 50-483

~~ CALLAWAY PLANT UNION ELECTRIC CO.

wAmeren APPLICA TION FOR AMENDMENT TO U£ FACILITY OPERATING LICENSE NPF-30 COMPLETION TIME EXTENSIONS FOR TS 3.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION FUNCTIONS TAC NO. ME2822 (LDCN 09-0039 SUPPLEMENT)

References:

1. AmerenUE letter ULNRC-05665 dated November 25,2009

2. AmerenUE letter ULNRC-05694 dated April 22, 2010

3. AmerenUE letterULNRC-05704 dated May 14, 2010

4. NRC letter dated May 5, 2010, "Callaway Plant, Unit 1 - Issuance of Amendment RE: Revision of Technical Specification 3.3.2, "Engineered Safety Feature Actuation System Instrumentation,"

Function 6.G, Condition J (Exigent Circumstances) (TAC. NO.

ME3595)," ADAMS Accession No. MLI0II00665

5. AmerenUE letter ULNRC-05724 dated August 24,2010 AmerenUE submitted a license amendment request via Reference 1 that proposed changes to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," as contained in Facility Operating License Number NPF-30 for the Callaway Plant. AmerenUE responded to NRC requests for additional information (RAIs) in support of that amendment application via References 2 and 3.

The changes requested and described in Attachment 2 of Reference 1 included the revision of Condition J ofTS 3.3.2. Specifically, a new Note for limiting Separate Condition entry was proposed, along with the revision of the Completion Times of Required Actions J.l and J.2. However, after the issuance of License Amendment No. 196 in Reference 4, it was recognized in Reference 5 that the proposed Note on Separate Condition entry would not accomplish the intended a subsidiary of Ameren Corporation

DLNRC-05731 September 29, 2010 Page 2 function discussed in Reference 1 since Condition J had been revised to cover one or more inoperable channels, thereby covering the inoperability of one, two, three, or all four channels in Function 6.g, "Trip of All Main Feedwater Pumps," of TS Table 3.3.2-1. An amendment supplement is therefore required to revise the changes proposed in Reference 1.

Attachment 1 hereto responds to additional electronic RAIs issued on September 7 and 8, 2010, with respect to Reference 5. These RAI responses reflect the results of a teleconference held on September 21, 2010 between AmerenDE and NRC staff.

Attachment 2 describes the basis and justification for the changes to TS 3.3.2 Condition J and new TS 3.3.2 Condition M. Attachments 3 through 5 provide the Markup of Technical Specifications, Retyped Technical Specifications, and Proposed Technical Specification Bases Changes, respectively. Attachments 3 through 5 completely supersede Attachments 2 through 4 of Reference 1. Although the only new markups are those associated with TS 3.3.2 Condition J and new Condition M, the entire set of requested TS and Bases changes is contained in Attachments 3 through 5 for completeness and preventing confusion as to the final set of requested changes.

Attachment 5 hereto is provided for information only. Final TS Bases changes will be processed under the program described in TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment is implemented.

The risk basis for the 24-hour Completion Times is contained in Reference 1.

The TS changes and risk metrics contained in Reference 5 are entirely superseded and should not be cited in the NRC Safety Evaluation for this amendment.

The conclusions of the licensing evaluations submitted in Reference 1 (i.e., the no significant hazard consideration (NSHC) evaluation and the environmental consideration (EC) evaluation in Sections 5.1 and 6.0 of Attachment 1 to Reference 1, respectively) remain valid and unchanged.

In addition, it should be noted that, similar to the original amendment request, there are no commitments contained in this letter.

The Callaway Onsite Review Committee has reviewed and approved the submittal of the revised TS 3.3.2 Condition J and new Condition M markups.

ULNRC-05731 September 29, 2010 Page 3 AmerenUE continues to request approval of this license amendment request prior to November 20,2010. In addition, AmerenUE still requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.

In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Missouri State official. If you have any questions on this amendment application, please contact me at (573) 676-8719 or Mr. Tom Elwood at (314) 225-1905.

I declare under penalty of petjury that the foregoing is true and correct.

Very truly yours, Executed on: q, Lq /2b tD

~s::g:9 Regulatory Affairs Manager GGY/nls Attachments 1- RAI Responses 2- Basis and Justification for New Changes to TS 3.3.2 Conditions J and M 3- Markup of Technical Specifications 4- Retyped Technical Specifications 5- Proposed Technical Specification Bases Changes (for information only)

ULNRC-05731 September 29, 2010 Page 4 cc:

u.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Washington, DC 20555-0001 Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G14 Washington, DC 20555-2738 Mr. James Polickoski Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738

ULNRC-05731 September 29, 2010 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed).

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

A. C. Heflin F. M. Diya L. S. Sandbothe C. O. Reasoner III S. A. Maglio S. L. Gallagher T. L. Woodward (NSRB)

T. B. Elwood G. G. Yates Ms. Diane M. Hooper (WCNOC)

Mr. Tim Hope (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (PG&E)

Mr. Wayne Harrison (STPNOC)

Ms. Linda Conklin (SCE)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Mr. Dru Buntin (DNR)

ATTACHMENT 1 RAIRESPONSES Page 1 of3 REQUEST FOR ADDITIONAL INFORMATION CALLAWAY PLANT, UNION ELECTRIC COMPANY, LICENSE AMENDMENT SUPPLEMENT (LCDN 09-0039)

FOR COMPLETION TIME EXTENSIONS FOR TS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION FUNCTIONS TAC NUMBER ME2822 The NRC staff requests additional information to complete its review of the license amendment request for revision of Technical Specification (TS) 3.3.2, "Engineered Safety Feature System (ESF AS) Instrumentation" Function 6.g., "Trip of all Main Feedwater Pumps" and Action Statement J, for the Condition of "One or more main Feedwater Pumps trip channel(s) inoperable. "

By letter dated November 25,2009, Union Electric Company (licensee) proposed TS change to permit a 24-hour Completion Time (CT) for placing a single Main Feedwater (MFW) Pump separation group channel in trip. During this 24-hour period, with only one channel inoperable and prior to placing its separation group channel in a trip condition, the logic would still maintain the safety function of starting the Auxiliary Feedwater (AFW) Pumps if the unit experienced the loss of both Main Feedwater (MFW) Pumps due to the remaining separation group channels still being operable during that 24-hour period.

Subsequent to the November 25,2009 amendment request, the NRC staff issued exigent amendment (ML101100665, ME3595 dated May 5,2010) which permits placing multiple ("one or more") inoperable MFW Pump separation group channels in trip for the existing I-hour CT period, even if a loss of safety function condition exists. This loss of safety function can exist for either of two reasons: (1) separate condition entries are allowed for each MFW Pump trip function (as per an initial note in TS 3.3.2); or, (2) a subsequent trip of the running MFW pump during the I-hour CT prior to the affected,"Reset" MFW pump, requiring LCO entry, having its separation group channels placed in trip. In its review of the exigent amendment, the NRC staff recognized that if a certain combination of channels were inoperable, then the loss of safety function condition would exist. Based on the limited time of I-hour, the regulatory consistency of TS actions required following loss of important equipment, and the significance of the safety function, the NRC staff approved the I-hour CT.

The August 24, 2010 supplemental submittal, which incorporates the initial amendment with the exigent amendment changes, proposes that the Condition J. CT be increased to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This change would permit unavailability of the specified safety function of starting the AFW Pumps on loss of all MFW Pumps for the same two reasons as stated above, but now for a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CT.

Based on the above NRC staffreview, the NRC staffhas following four additional questions:

Page 2 of3 Question (1):

What additional justification can be provided to clarify the industry's regulatory consistency by increasing the unavailability for the TS safety function from 1 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ?

Response

First, a minor clarification is offered regarding the 2nd paragraph of the above RAI introduction, repeated below with changes tracked to assure the Callaway design and original license amendment request are fully understood.

By letter dated November 25,2009, Union Electric Company (licensee) proposed TS change to permit a 24-hour Completion Time (CT) for placing a single Main Feedwater (MFW) Pump separation group channel in trip. During this 24-hour period, with only one channel per MFW pump inoperable in the same separation group and prior to placing those same separation group channels in a tripped condition, the logic would still maintain the safety function of starting the Auxiliary Feedwater (AFW) Pumps if the unit experienced the loss of both Main Feedwater (MFW) Pumps due to the remaining separation group channels still being operable during that 24-hour period.

Preservation of the ESFAS 6.g function (Auxiliary Feedwater - Trip of All Main Feedwater Pumps) will be addressed by the revised changes to TS 3.3.2 Condition J and new TS 3.3.2 Condition M as discussed in further detail in Attachment 2. Attachment 3 contains the complete set of TS changes being requested.

Question (2):

The NRC staff noted that the 24-hour CT may be used for operational andlor maintenance convenience, while the controls of a MFW Pump are in "Reset." Since the stated intent for exigent amendment request discussed MFW pump operations during plant start-up and shutdown with one MFW pump in "Reset," the increased CT would expose the plant to a potential loss of the AFW actuation safety function for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months should the separation group channels for the "Reset" MFW Pump not be placed in a trip condition and the running MFW Pump fail.

What additional justification can you provide to justify the operational intent in employment of the proposed Condition J?

Response

See the response to Question (1) above.

Page 3 of3 Question (3):

The original November 2009 license amendment request was noticed to the public in the Federal Register on April 29, 2010. The August 2010 supplemental submittal expanded the scope of the original license amendment request by extending the loss of safety function duration from 1 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , but a "No Significant Hazards Determination" was not provided to address this change.

Please describe what changes are needed to the "No Significant Hazards Determination" in order to complete the supplemental submittal.

Response

There are no changes needed to the NSHC determination provided in Section 5.1 of Attachment 1 to ULNRC-05665 dated November 25,2009 due to this reconciling of the LDCN 09-0039 amendment request with TS 3.3.2 Condition J as revised by License Amendment 196. The responses to the three questions of 10 CFR 50.92 are unaffected. The Basis for proposed no significant hazards consideration determination posted in 75 FR 27833 dated May 18,2010 is unaffected. That FR Notice reflects the submitted NSHC determination. The amendment request description in the Federal Register Notice would be affected as discussed in ; however, that does not affect the answers to the 50.92 questions. The impact and effect of all requested TS changes are covered by the NSHC determination in ULNRC-05665 (Reference 1).

Question (4):

Callaway Amendment 197 added a new ESFAS function (#10) for SG blowdown and sample isolation, and this uses condition Q of the proposed TS change we are reviewing for an extension to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Should your supplement address how the proposed change to the BOP ESFAS logic CT has been considered for this new function, and address this new function as well as AFW auto start and switchover logic?

Response

Amendment 197 has no impact on the LDCN 09-0039 amendment request. The deterministic and risk evaluations presented in ULNRC-05665 already include the effects on new ESFAS Function 10.b which has always been one of the design functions actuated by BOP ESFAS. The effects on steam generator (SG) blowdown and sample line isolation were discussed in ULNRC-05665 (Attachment 1, pages 4, 16,21,22; Attachment 6, Table 2, FlO SC-4). The risk results reported in ULNRC-05665 already reflect the impact of BOP ESFAS Completion Time extensions on all risk-significant functions initiated from the BOP ESFAS cabinets, including SG blowdown and sample line isolation.

ATTACHMENT 2 BASIS AND JUSTIFICATION FOR NEW CHANGES TO TS 3.3.2 CONDITIONS J AND M Page 1 of5 BASIS AND JUSTIFICATION FOR NEW CHANGES TO TS 3.3.2 CONDITIONS J AND M Original Amendment Request In AmerenUE's original amendment request (Reference 1, ULNRC-05665 dated November 25,2009), the following discussion of the proposed change to Technical Specification (TS) 3.3.2 Condition J was provided in Section 2.0 of Attachment 1:

"Since the risk impact associated with the loss of one train of BOP ESFAS actuation logic and actuation relays is greater than the loss of individual analog channel input(s) into that BOP ESFAS train, it is also proposed that the Completion Times for TS 3.3.2 Required Action J.l (for TS Table 3.3.2-1 Function 6.g, Auxiliary Feedwater - Trip of All Main Feedwater Pumps) and Required Action 0.1 (for TS Table 3.3.2-1 Function 6.h, Auxiliary Feedwater-Pump Suction Transfer on Suction Pressure - Low) be changed from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The Completion Time for Required Action J.2 (shutdown to MODE 3 if Required Action J.l is not met within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) would be extended to 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (24 + 6). The Completion Time for Required Action 0.2 would be unchanged.

An additional restriction would be added to TS 3.3.2 Condition J in the form of a new Note limiting the application of separate Condition entry. Since the Required Channels for Function 6.g are specified in TS Table 3.3.2-1 as 2 per pump, Condition J may be entered separately for each main feedwater pump. However, as shown on the J-I04-00176 logic block diagram provided in Attachment 5, satisfying the trip logic requires the presence of a low oil pressure signal in the same separation group on each main feedwater pump. An inoperable separation group 1 channel on one pump coincident with an inoperable separation group 4 channel on the other pump would lead to the loss of this actuation function.

Therefore, a new Note would be added to Condition J that would read:

'Separate Condition entry is restricted to one inoperable channel per pump in the same separation group.'

This would assure that the AFW start signal after the loss of both main feedwater pumps would be generated by the operable inputs from the other separation group to both motor-driven AFW pumps (cross train actuations are provided as shown in Attachment 5)."

Effect of License Amendment 196 Prior to the Reference 1 submittal and the subsequent issuance of Reference 4 (License Amendment 196), Condition J addressed only one inoperable channel. Separate Condition entry was allowed for one inoperable channel per main feedwater pump (MFP)

Page 2 of5 since the Required Channels in TS Table 3.3.2-1 were specified on a "per pump" basis.

Separate Condition entry allows individual time tracking of the inoperable MFP channels such that the following postulated example would have been accommodated prior to License Amendment 196 using the equipment identification tag numbers identified in to Reference 1 (example for demonstration purposes):

Separation group 1 channel (isolated output from FCPSL0025 on MFP 'A' or isolated output from FCPSL0125 on MFP 'B') is declared inoperable at time = 0 and TS 3.3.2 Condition J entered.

Time tracking for Required Action J.1 to trip the channel in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months starts at time = o.

Prior to time = 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , separation group 4 channel (isolated output from FCPSLO 126 on MFP 'B' or isolated output from FCPSL0026 on MFP 'A') is declared inoperable at time < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . TS 3.3.2 Condition J would be separately entered if the new inoperability affects the opposite MFP as allowed by Separate Condition entry per MFP.

Separate time tracking for Required Action J.1 to trip the second channel in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months starts at the second Condition J entry.

The total time that the LCO is not met could have approached 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to License Amendment 196; however, a loss of function could exist for no more than one hour.

Reference 4 changed TS 3.3.2 Condition J to address one or more inoperable channels.

Given the implementation of Reference 4, the above scenario in which there are two inoperable ESFAS Function 6.g channels in different separation groups (involving a loss of function) could be entered when one MFP turbine is reset during the process of placing the pump in service (as discussed in Reference 4). Therefore, the above loss-of-function scenario would not necessarily require Separate Condition entry for an inoperable channel on each MFP. Since TS 3.3.2 Condition J now covers more than one inoperable MFP channel after Amendment 196, Separate Condition entry could theoretically involve the following scenario (for demonstration purposes):

Separation group 1 and 4 channels (isolated outputs from FCPSL0025 and FCPSL0026 on MFP 'A') declared inoperable at time = 0 and TS 3.3.2 Condition J entered.

Time tracking for Required Action J.1 to trip both channels in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months starts at time = o.

Prior to time = 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , separation group 1 and 4 channels (isolated outputs from FCPSL0125 and FCPSL0126 on MFP 'B') declared inoperable at time < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

TS 3.3.2 Condition J would be separately entered since the new channel Page 3 of5 inoperabilities (one or more inoperable channels allowed by Condition J) affect the opposite MFP as allowed by Separate Condition entry per MFP. However, this is a theoretical exercise since the plant would not remain in MODES 1 or 2 with a total loss of normal feedwater.

Separate time tracking for Required Action J.l to trip the second set of channels in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months starts at the second Condition J entry.

The total time that the LCO is not met could approach 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and the loss of function could also exist for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months since Condition J now covers one or more inoperable channels.

Deletion of Original Amendment Request's Separate Condition J Entry Note As discussed above, a new Note was proposed in Reference 1 to restrict Separate Condition entry in conjunction with extending the Completion Time of Required Action J.l from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The additional limitation contained in the Separate Condition entry Note of Reference 1 will not accomplish the intended purpose described above (preservation of the ESFAS 6.g actuation function) during the allowed Completion Time prior to placing the inoperable channels in a tripped condition per Required Action J.l. The originally proposed Separate Condition entry Note would, in fact, offer no restriction to the inoperability of multiple channels in which case the actuation signal from ESFAS Function 6.g may not be available.

Therefore, in order to reconcile the Reference 1 amendment request against the current wording ofTS 3.3.2 Condition J, additional restrictions are proposed in Attachment 3 to differentiate between situations when the actuation function is available from one train and when the actuation function is lost. The former (new Condition M) will be allowed a 24-hour Completion Time supported by the risk results reported in Reference 1. When the actuation function is lost, a revised Condition J will limit the Completion Time to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in accordance with the current (Amendment 196) licensing basis.

New Proposed TS Changes The changes to TS 3.3.2 Conditions 0 and Q remain the same as submitted in Reference

1. Those changes are included in the Attachment 3 markups on the current TS pages for completeness.

The new changes, prompted by a teleconference between AmerenUE and NRC staff on September 21,2010, include the following:

TS 3.3.2 Condition J currently reads:

"One or more Main Feedwater Pumps trip channel(s) inoperable."

Page 4 of5 TS 3.3.2 Condition J would be revised to read:

"More than one Main Feedwater Pumps trip channel inoperable with inoperable channels not in the same separation group."

Since the risk impact associated with the loss of one train of BOP ESFAS actuation logic and actuation relays is greater than the loss of individual analog channel input(s) into that BOP ESFAS train as long as the 6.g function is available, it is also proposed that new TS 3.3.2 Condition M be added to read:

"One Main Feedwater Pumps trip channel inoperable.

Two Main Feedwater Pumps trip channels inoperable with inoperable channels limited to the same separation group."

A Note above new Condition M would be a reminder to limit its use to only those situations in which the actuation function is not lost.

New Required Actions M.1 (Place channel(s) in trip) and M.2 (Be in MODE 3) would have 24-hour and 30-hour Completion Times, respectively. New Required Actions M.1 and M.2 would have the same bypass testing Note as Required Actions J.1 and J.2.

New Condition M would assure that the AFW start signal after the loss of both main feedwater pumps (ESFAS Function 6.g) would be generated by the operable inputs from the other separation group to both motor-driven AFW pumps via cross train actuations.

The proposed format of TS 3.3.2 Conditions J and M is similar to the split Condition approach used in TS 3.7.2 for the MSIV actuator trains; however, the Completion Times in TS 3.7.2 reflect the impact on actuated end devices (more limiting if a potential single failure could cause two MSIV s to fail to close) rather than the impact on inputs to the BOP ESFAS actuation logic (more limiting if different separation groups are affected resulting in a loss of actuation function).

Approval Basis for TS 3.3.2 Conditions J and M TS 3.3.2 Condition J retains the current licensing basis (Callaway Amendment 196) in that the Completion Time for a potential loss of actuation function would be limited to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

TS 3.3.2 Condition M relaxes the Completion Time for ESFAS Function 6.g when there is no loss of actuation function to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with Reference 1.

Page 5 of5 The TS markups in Attachment 3 to this submittal retain the Separate Condition entry allowances in the current licensing basis.

Effect on NSHC Determination of Reference 1 There is no change to the responses to the three questions of 10 CFR 50.92 in Reference

1. The change introduction in Section 5.0 of Attachment 1 to Reference 1 would be affected as follows with revisions indicated (which would also affect the Description of amendment request in 75 FR 27833 dated May 18,2010):

"This section addresses the standards of 10 CFR 50.92 as well as the applicable regulatory requirements and acceptance criteria.

This amendment application submits a proposed change to Technical Specification (TS) 3.3.2, "Engineered Safety Feature Action System (ESFAS)

Instrumentation," that would add a new Required Action Q.l to require restoration of an inoperable Balance of Plant ESFAS (BOP ESFAS) train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Currently, Condition Q ofTS 3.3.2 for Function 6.c ofTS Table 3.3.2-1 requires the plant to enter a shutdown track to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with no allowed outage time provided for restoration. In addition, the Completion Time for TS 3.3.2 Required Action 0.1 to trip an inoperable channel that provides an input to BOP ESFAS would also be extended to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Shutdown track Completion Times in Condition Q to be in MODES 3 and 4 would be increased to reflect the longer restoration time. TS 3.3.2 Condition J would be revised to assure that the actuation function of Function 6.g in TS Table 3.3.2-1 is not lost for more than the time allowed under the current licensing basis and new TS 3.3.2 Condition M would be added to relax the Completion Time if the actuation function can still be performed. This is a risk-informed amendment request following the guidance of NRC Regulatory Guides (RGs) 1.174, 1.1 77, and 1.200 Revision 1."

ATTACHMENT 3 MARKUP OF TECHNICAL SPECIFICATIONS

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME I. One channel inoperable. ------------------- NOT E -------------------

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

1.1 Place channel in trip. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR 1.2 Be in MODE 3. 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months J. 9Re SF FflSFe Meill ------------------- NOT E -------------------

~99QUla~9F j;!1::n~f:lS ~Fif:l One inoperable channel may be sRaARel(s) illo~el able. bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for

/Y1DH!.. *fJvJn Dne surveillance testing of other channels.

!YI41n Fee)wn-/-e,.. -------------------------------------------------

/Uhll-S Il)o/eN:fj

-f.-z.e NiH, cAanroe I J.1 Plac~RaAAel(s)-in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

~/'\IA'I1\ e Is r7e~"'e c.Aanne/s OR hI) r"..fI.e SamE'- J.2 Be in MODE 3. 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months

.rejJArrhih 1J-4l(~,.

, r V (contlnueOJ CALLAWAY PLANT 3.3-29 Amendment No. 196

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME M. ~~et tJ~ed. INSRIA N. One or more Containment N.1 Place channel(s) in trip. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Pressure - Environmental Allowance Modifier OR channel(s) inoperable.

N.2.1 Be in MODE 3. 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months AND N.2.2 Be in MODE 4. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months O. One channel inoperable. 0.1 Place channel in trip. 1 A8~ f .:24- AIJUI"S-AND 0.2 Restore channel to During OPERABLE status. performance of the next required COT (continued)

CALLAWAY PLANT 3.3-31 Amendment No. 168

INSERT A CONDITION REQUIRED ACTION COMPLETION TIME M. -----------NOTE------------ ----------------NOTE---------------

Entry into Condition M One inoperable channel may is allowed only if there be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is no loss of the for surveillance testing of actuation function. other channels.

One Main Feedwater M.1 Place channel(s) in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Pumps trip channel trip.

inoperable.

OR OR M.2 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months Two Main Feedwater Pumps trip channels inoperable with inoperable channels limited to the same separation group.

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

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

AND P.2 Declare associated Immediately steam generator blowdown and sam pie line isolation valve(s) inoperab Ie.

a One train inoperab Ie. ------------------- 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.

rNsE/trg- '.

~ours

~

~,Q.. -:2, I Be in MOD E 3.

AN~

Q.2 .. ':t A

Be in MODE 4. '?t hours 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 inoperab Ie. 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 (continued)

CALLAWAY PLANT 3.3-32 Amendment No. 197

INSERT B REQUIRED ACTION COMPLETION TIME Q.1 Restore train to OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months status.

OR

ESFAS Instrumentation No c.A~nge.s - tJ-lVi7;!e./ *1" &Jrr+ex+ on'd- 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 Actuation Logic and Actuation Relays (BOP ESFAS) 1,2,3 2 trains Q SR 3.3.2.3 NA

}

d. SG Water Level Low-Low (1) Steam 1,2,3 4 per SG D SR 3.3.2.1 ;?: 20.6%(8) 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 (Adverse Containment Environment)

(2) Steam 1(r), 2(r), 3(r) 4 per SG D SR 3.3.2.1 ;?: 16.6%(8) 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. Ifthe 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 ~ 2.0 psig Pressure - SR 3.3.2.5 Environmental SR 3.3.2.9 Allowance SR 3.3.2.10 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 Feedwater Pumps 1,2(n) 2 per pump J) JL1 SR 3.3.2.8 NA A

h. Auxiliary 1,2,3 3 0 SR 3.3.2.1 ~ 20.64 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 No. 197

ATTACHMENT 4 RETYPED TECHNICAL SPECIFICATIONS

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME I. One channel inoperable. ------------------- NOT E -------------------

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

1.1 Place channel in trip. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR 1.2 Be in MODE 3. 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months J. More than one Main ------------------- NOT E -------------------

Feedwater Pumps trip One inoperable channel may be channel inoperable with bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for inoperable channels not in surveillance testing of other the same separation group. channels.

J.1 Place channels in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR J.2 Be in MODE 3. 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months (continued)

CALLAWAY PLANT 3.3-29 Amendment No. ###

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME M. ------------- NOTE ------------- ------------------- NOT E -------------------

Entry into Condition M is One inoperable channel may be allowed only if there is no bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for loss of the actuation surveillance testing of other function. channels.

One Main Feedwater M.1 Place channel(s) in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Pumps trip channel inoperable. OR OR M.2 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months Two Main Feedwater Pumps trip channels inoperable with inoperable channels limited to the same separation group.

N. One or more Containment N.1 Place channel(s) in trip. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Pressure - Environmental Allowance Modifier OR channel(s) inoperable.

N.2.1 Be in MODE 3. 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months AND N.2.2 Be in MODE 4. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months

o. One channel inoperable. 0.1 Place channel in trip. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND 0.2 Restore channel to During OPERABLE status. performance of the next required COT (continued)

CALLAWAY PLANT 3.3-31 Amendment No. ###

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 1m med iately steam generator blowdown and sample line isolation valve( s) inoperable.

Q One train inoperable. ------------------- NOT E -------------------

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 Restore train to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR Q.2.1 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months AND Q.2.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

CALLAWAY PLANT 3.3-32 Amendment No. ###

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME 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

s. One train inoperable ------------------- NOT E -------------------

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

S.1 Restore train to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OPERABLE status.

OR S.2.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND S.2.2 Be in MODE 4. 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months CALLAWAY PLANT 3.3-33 Amendment No. ### I

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 ::; 2.0 psig Pressure - SR 3.3.2.5 Envi ron mental SR 3.3.2.9 Allowance SR 3.3.2.10 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, M SR 3.3.2.8 NA Feedwater Pumps

h. Auxiliary 1,2,3 3 0 SR 3.3.2.1 ;?: 20.64 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 No. ###

ATTACHMENT 5 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (for information only)

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE d. Auxiliary Feedwater - Steam Generator Water Level -

SAFETY Low Low (continued)

ANALYSES, LCO, AND EAM function is used to monitor the presence of adverse APPLICABILITY containment conditions (elevated pressure) and enables the Steam Generator Water Level - Low Low (Adverse) trip setpoint to reflect the increased transmitter uncertainties due to this harsh environ ment. The EAM enables a lower Steam Generator Water Level - Low Low (Normal) trip setpoint when these conditions are not present, thus allowing more margin to trip for normal operating conditions. If the EAM trip function has inoperable required channels, it is acceptable to place the inoperable channels in the tripped condition and continue operation. Placing the inoperable channels in the trip mode enables the Steam Generator Water Level-Low Low (Adverse) Function, for the EAM. If the Steam Generator Water Level - Low Low (Normal) trip Function has an inoperable requ ired channel, the inoperable channel must be tripped, subject to the LCO Applicabi lity footnote.

The Trip Setpoint reflects the inclusion of both steady state and adverse environment instrument uncertainties. The Trip Setpoints for the SG Water Level - Low Low (Adverse Containment Environment) and (Normal Containment Environment) bistables are ~ 21.0% and ~ 17.0% of narrow range span, respectively. The Trip Setpoint for the Containment Pressure - Environmental Allowance Modifier bistables is ::;; 1.5 psig.

e. Auxiliary Feedwater - Safety Injection An SI signal starts the motor driven AFW pumps. The AFW initiation functions are the same as the requirements for their SI function. Therefore, the requirements are not repeated in Table 3.3.2-1. Instead, Function 1, SI, is referenced for all initiating functions and requirements.

f. Auxiliary Feedwater - Loss of Offsite Power The loss of offsite power (LOP) is detected by a voltage drop on each ESF bus. The LOP is sensed and processed by the circuitry for LOP DG Start (Load Shedde rand (continued)

CALLAWAY PLANT B 3.3.2-33 Revision 8g

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE f. Auxiliary Feedwater - Loss of Offsite Power (continued)

SAFETY ANALYSES, Emergency Load Sequencer) and fed to BOP ESFAS by LCO, AND relay actuation. Loss of power to either ES F bus will start APPLICABILITY the turbine - driven AFW pump, to ensure tRat at I&ast eRe eO geRt8iR~ enough water to serve as the heat sink for reactor dec y heat and sensible heat removal following the reactor trip, and automatically isolate the SG blowdown and sample lin s. In addition, once the diesel generators are started an up to speed, the motor - driven AFW pumps will be seque tially' loaded onto the diesel generator buses.

+J..,e ;~d-SGs- ~~In Functions 6.a through 6.f must be OPERABLE in MODES 1,2, and 3 to ensure that the SGs remain the heat sink for the reactor. SG Water Level - Low Low in any operating SG will cause the motor - driven AFW pumps to start. The system is aligned so that upon a start of the pump, water immediately begins to flow to the SGs. SG Water Level - Low Low in any two operating SGs will cause the turbine - driven pum p to start. The SG Water Level - Low Low (Normal Containment Environment) channels do not provide protection when the Containment Pressure - Environmental Allowance Modifier (EAM) channels in the sam e protection sets are tripped since th at enables the SG Water Level - Low Low (Adverse Containment Environment) channels with a higher water level trip setpoint. As such, the SG Water Level - Low Low (Normal Containment Environment) channels need not be OPERABLE when the Containment Pressure - EAM channels in the sam e protection sets are tripped, as discussed in a footnote to Table 3.3.2-1. These Functions do not have to be OPERABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink. In MODE 4, AFW actuation does not need to be OPE RABLE because either AFW or residual heat removal (RHR) will be available to remove decay heat or sufficient time is available to manually place either system in operation.

(continued)

CALLAWAY PLANT B 3.3.2-34 Revision 8g

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE 6. Auxiliary Feedwater (continued)

SAFETY ANALYSES, g. Auxiliary Feedwater - Trip of All Main Feedwater Pumps LCO, AND APPLICABILITY A Trip of all MFW pumps (PAE01A and PAE01 B) is an indication of a loss of MFW and the subsequent need for some method of decay heat and sensible heat removal to bring the reactor back to no load temperature and pressure.

Each turbine driven MFW pump is equipped with two pressure switches (one in separation group 1 and one in separation group 4) on the oil line for the speed control system. A low pressure signal from either of these pressure switches indicates a trip of that pump. Two OPERABLE channels per pump satisfy redundancy requirements with one-out-of-two logic in the same separation group on both pumps required for signal actuation. A trip of all MFW pumps (PAE01A and PAE01 B) starts the moto~driven AFW pumps to ensure that the intact SGs are availa e with water to act as the heat sink for the reactor. -

Function 6.g must be OPERABLE in MODES 1 and 2. This ensures that the intact SGs are provided with water to serve as the heat sink to remove reactor decay heat and sensible heat in the event of an accident. In MODES 3, 4, and 5, the turbine-driven MFW pumps may be normally shut down, and thus pump trip is not indicative of a condition requiring automatic AFW initiation. Note (n) of Table 3.3.2-1 allows the blocking of this ESFAS function in MODE 2 just before shutdown of the last operating turbine-driven main feedwater pump and the restoration of this trip function just after the first turbine-driven main feedwater pump is put into service following its startup trip test. This limits the potential for inadvertent AFW actuations during normal startups and shutdowns.

A turbine-driven MFW pump is in service when the pump's stop valves are open, the governor control valves are either in manual or automatic control, and feedwater is being supplied to the steam generators.

One cause of multiple channel inoperability which requires entry into Condition J occurs routinely during normal plant operation. A single turbine-driven MFW pump may be in service in MODE 1 at reduced power levels if the other (continued)

CALLAWAY PLANT B 3.3.2-35 Revision 8g

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE g. Auxiliary Feedwater - Trip of All Main Feedwater Pumps SAFETY (Continued)

ANALYSES, LCO, AND turbine-driven MFW pump has not yet been placed into APPLICABILITY service during power ascension or has been removed from service for maintenance. Prior to placing a turbine-driven MFW pump into service, the status of its turbine control circuitry is changed from "tripped" to "reset" via its TripI Reset handswitch (FCHIS0018 or FCHIS0118) such that the two oil pressure switch channels on that tu rbine-driven MFW pump experience the high oil pressures indicative of an operating pum p prior to that turbine-driven M FW pump providing feedwater flow to the steam generators. In this status, the turbine-driven MFW pump that is not yet in service would not satisfy the AFW start function actuation logic if the operating turbine-driven MFW pump were to trip at this time since it takes one tripped channel on each turbine-driven MFW pump in the same separation group to initiate an auxiliary feedwater actuation signal. Therefore, with one turbine-driven MFW pump turbine in reset, Condition J must be entered for two inoperable oil pressure channels on that turbine-driven MFW pump. This Condition imposes a partial AFW actuation status (or partial trip) on the plant.

This ESFAS function is an anticipatory start signal for which no credit is taken in any accident or transient analysis. The safety analyses credit actuation of the driven AFW pumps upon a low-low steam generator ater level signal in any steam generator and after a sat ty injection signal.

rh#-hr-

h. Auxiliary Feedwater - Pump Suction Transfer on Suction Pressure - Low A low pressure signal in the AFW pump suction line protects the AFW pumps against a loss of the normal supply of water for the pumps, the CST. Three pressure switches are located on the AFW pump suction line from the CST. A low pressure signal sensed by any two of the (continued)

CALLAWAY PLANT B 3.3.2-36 Revision 8g

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE h. Auxiliary Feedwater - Pump Suction Transfer on Suction SAFETY Pressure - Low (continued)

ANALYSES, LCO, AND three switches coincident with an auxiliary feedwater APPLICABILITY actuation signal will cause the emergency supply of water for the pumps to be aligned. ESW (safety grade) is automatically lined up to supply the AFW pumps to ensure an adequate su pply of water for the AFW System to maintai as the heat sink for reactor ecay heat and sensible heat removal.

-Me. ;~c+ SG..s-Since the detectors are located in an area not affected by HELBs or high radiation, they will not experience any adverse environmental conditions and the Trip Setpoint reflects only steady state instrument uncertainties. The Trip Setpoint is;::: 21.71 psia.

This Function must be OPERABLE in MODES 1,2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the SGs as the heat sink for the reactor. This Function does not have to be OPE RABLE in MODES 5 and 6 because there is not enough heat being generated in the reactor to require the SGs as a heat sink.

In MODE 4, AFW automatic suction transfer does not need to be OPE RABLE because RHR w ill already be in operation, or sufficient time is available to place RHR in operation, to remove decay heat.

7. Automatic Switchover to Containment Sump At the end of the injection phase of a LOCA, the RWST will be nearly empty. Continued cooling must be provided by the ECCS to remove decay heat. The source of water for the RHR pum ps is automatically switched to the containment recirculation sum ps.

The low head residual heat removal (RHR) pum ps and containment spray pumps draw the water from the containment recirculation sumps, the RHR pumps pump the water through the RHR heat exchanger, inject the water back into the RCS, and supply the cooled water to the other ECCS pumps. Switchover from the RWST to the containment sumps must occur before the RWST empties to prevent damage to the RHR pumps and a loss of core cooling capability. For similar reasons, switchover must not occur before there is sufficient water in the containment sumps to support ESF pump suction.

(continued)

CALLAWAY PLANT B 3.3.2-37 Revision 8g

ESFAS Instrumentation B 3.3.2 BASES ACTIONS 1.1 and 1.2 (continued)

The Required Actions are modified by a Note that allows the inoperable channel to be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed to place the inoperable channel in the tripped condition, and the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowed for an inoperable channel to be in the bypassed condition for testing, are justified in Reference 18.

=z=N.rc/("l$.3~:2;:r \

J.1 and J.2 (~-Jqr+l1ew la~3ntA.J Condition J applies to the AFW pump start 0 (PAE01A and PAE01 B).

This action addresses the train orientation of the OP ESFAS for the auto start function of the AFW System on loss of all MF pumps (PAE01A and PAE01 B). The OPERABILITY of the AFW System st be assured by providing automatic start of the AFW System pumps.~~w..u'"""'-l~~

QRaRRel~s) are iRe~eFeble, 1 IIOUi is alloooed to j3leee t1ge ifl6fjeFeBIe cbaRRel~9) ill tile li i~j3ed eOI.ditioll. If the channels cannot be tripped in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 6 additional hours are allo d to place the unit in MODE 3. The allowed Completion Time of 6 hou is reasonable, based on operating experience, to reach MODE 3 fro full power conditions in an orderly manner and without ch lIenging unit systems. In MODE 3, the unit does not have any analyzed ransients or conditions that require the explicit use of the protection fun ion noted above. The Required Actions are modified by a Note that allo s one inoperable channel to be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillanc testing of other channels.

K.1. K.2.1, and K.2.2

{s-h.,..+ hew ftAr-a~rt).f~J Condition K applies to:

RWST Level - Low Low Coincident with Safety Injection.

RWST Level - Low Low Coincident With SI provides actuation of switchover to the containment recirculation sumps. Note that this Function requires the bistables to energize to perform their required action. The failure of up to two channels will not prevent the operation of this Function. This Action Statement limits the duration that an RWST level channel could be inoperable in the tripped condition in order to limit the probability for automatic switchover to an empty containment sump upon receipt of an inadvertent safety injection signal (SIS), coincident with a single failure of another RWST level channel, or for premature (continued)

CALLAWAY PLANT B 3.3.2-55 Revision 8g

INSERT 3.3.2.J Condition J applies if the actuation function has been lost, i.e., if more than one channel is inoperable and the inoperable channels are not in the same separation group. If Condition J is entered, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to place the inoperable channels in the tripped condition. Since the Required Channels for Function 6.g are specified in Technical Specification Table 3.3.2-1 as 2 per main feedwater pump, Condition J may be entered separately, on a per pump basis, for the inoperability of more than one channel. If one or both channel(s) per main feedwater pump are inoperable in different separation groups, the actuation function is not available. As shown on FSAR Figure 7.3-1, sheet 2 (Ref. 2),

satisfying the trip logic requires the presence of a low oil pressure signal in the same separation group on each main feedwater pump. For example, an inoperable separation group 1 channel on one pump coincident with an inoperable separation group 4 channel on the other pump would lead to the loss of the actuation function. Similarly, the loss of both channels on the same MFP would lead to the loss of the actuation function. Therefore, Condition J covers any of the following situations:

Channels FCP-0025 and FCP-0026 inoperable;

Channels FCP-0125 and FCP-0126 inoperable;

Channels FCP-0025 and FCP-0126 inoperable;

Channels FCP-0026 and FCP-0125 inoperable;

Channels FCP-0025, FCP-0026, and FCP-0125 inoperable;

Channels FCP-0025, FCP-0026, and FCP-0126 inoperable;

Channels FCP-0125, FCP-0126, and FCP-0025 inoperable;

Channels FCP-0125, FCP-0126, and FCP-0026 inoperable;

Channels FCP-0025, FCP-0026, FCP-0125, and FCP-0126 inoperable.

The wording of Condition J limits the duration of the loss of function consistent with Reference 23.

ESFAS Instrumentation B 3.3.2 BASES ACTIONS M.1 and M.2 (continued)

N.1. N.2.1. and N.2.2 Condition N applies to the Environmental Allowance Modifier (EAM) circuitry for the SG Water Level - Low Low trip Functions in MODES 1, 2, and 3. With one or more EAM channel(s) inoperable, they must be placed in the tripped condition within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Placing an EAM channel in trip automatically enables the SG Water Level - Low Low (Adverse Containment Environment) bistable for that protection channel, with its higher SG level Trip Setpoint (a higher trip setpoint means a feedwater isolation or an AFW actuation would occur sooner). The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is based on Reference 18. If the inoperable channel cann ot be placed in the tripped condition within the specified Completion Time, the unit must be placed in a MO DE where this Function is not required to be OPERABLE. The unit must be placed in MODE 3 within an additional six hours and in MODE 4 within the following six hours.

0.1 and 0.2 Condition 0 applies to the Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low trip Function. The Condensate Storage Tank is the highly reliable and preferred suction source for the AFW pumps. This function has a two-out-of-three trip logic. Therefore, continued operation is allowed with one inoperable channel until the performance of the next monthly COT on one of the other channels, as long as the inoperable channel is placed in trip within -4 R8t1F. :2+ Aour-.s""

P.1 and P.2 Condition P applies to the Auxiliary Feedwater Manual Initiation trip Function and the Steam Generator Blowdown and Sample Line Isolation Valve Actuation Function 10.a. The associated auxiliary feedwater pump(s) and the associated steam generator blowdown and sample line isolation valve(s) must be declared inoperable immediately when one or more channel(s) or train(s) is inoperable. Refer to LCO 3.7.5, "Auxiliary Feedwater (AFW) System," and to LCO 3.7.19, "Secondary Side Isolation Valves."

(continued)

CALLAWAY PLANT B 3.3.2-57 Revision 8g

INSERT 3.3.2.M Condition M applies to the AFW pump start on trip of all MFW pumps (PAE01A and PAE01 B).

This action addresses the train orientation of the BOP ESFAS for the auto start function of the AFW System on loss of all MFW pumps (PAE01A and PAE01 B).

The OPERABILITY of the AFW System must be assured by providing automatic start of the AFW System pumps.

Condition M applies if the actuation function has not been lost, i.e., if only one channel out of the four total channels is inoperable or if two channels out of the four total channels are inoperable but are in the same separation group. The Condition is modified by a Note that limits Condition entry to situations in which there has been no loss of the actuation function. If Condition M is entered, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to place the inoperable channel(s) in the tripped condition.

Since the Required Channels for Function 6.g are specified in Technical Specification Table 3.3.2-1 as 2 per main feedwater pump, Condition M may be entered separately, on a per pump basis, for the inoperability of one channel per pump in the same separation group. If a single channel out of the total of four channels is inoperable or if one channel per main feedwater pump is inoperable but the Condition is limited to the same separation group, the actuation function remains available. As shown on FSAR Figure 7.3-1, sheet 2 (Ref. 2), satisfying the trip logic requires the presence of a low oil pressure signal in the same separation group on each main feedwater pump. For example, an inoperable separation group 1 channel on one pump coincident with an inoperable separation group 1 channel on the other pump would leave the separation group 4 channels available to perform the actuation function. Therefore, Condition J covers any of the following situations:

A single channel out of four inoperable;

Channels FCP-0025 and FCP-0125 inoperable;

Channels FCP-0026 and FCP-0126 inoperable; The wording of Condition M limits the Completion Time duration consistent with Reference 23.

If the channel(s) can not be tripped in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 6 additional hours are allowed to place the unit in MODE 3. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging unit systems. In MODE 3, the unit does not have any analyzed transients or conditions that require the explicit use of the protection function noted above. The Required Actions are modified by a Note that allows one inoperable channel to 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 of other channels.

ESFAS Instrumentation BASES C &.1, IJ. ;;)./. tWi 1).:::2.:2 B 3.3.2 ACTIONS (continued)

Condition Q applies to the Auxiliary Feedwater and Steam Generator Blowdown and Sample Li e Isolation Valve Actuation Function 1D.b Balance of Plant ESFAS utomatic actuation logic and actuation relays.

. ,the un it must be brought to MODE 3 within 30-&hours and MODE 4 Within~hours (Example 1.3-1 explains the independence of these Comp tion Times). The Required Actions are modified by a Note that allo one train to 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 provo ed the other train is OPERABLE.

3~

R.1. R.2.1. and R.2.2 Condition R applies to the Auxiliary Feedwater Loss of Offsite Power trip Function and the Steam Generator Blowdown and Sam pie Line Isolation Valve Actuation Function 1D.d. With the inoperability of one or both train(s), 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months are allowed to return the train(s) to OPERABLE status.

The specified Completion Time is reasonable considering this Function is associated with the turbine driven auxiliary feedwater pump (TDAFP) and the ESFAS Function 1D valves, the available redunda ncy provided by the motor driven auxiliary feedwater pumps and other isolation valves, and the low probability of an event occurring during this interval. If the Function cannot be returned to OPERABLE status, the unit must be placed 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 (Example 1.3-1 explains the independence of these Completion Times). The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit sy stems. In MODE 4, the unit does not h ave any analyzed transients or conditions that require this equipment for mitigation.

S.1. S.2.1. and S.2.2 Condition S appli es to the MSFIS automatic logic and actuation relays.

The action addresses the tra in orientation of the actuation logic for these functions. If one train is inoperable, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months are allowed to restore the train to OPE RABLE status. The Completion Time for restoring a train to OPERABLE status is reasonable considering that ther e is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be returned to OPE RABLE status, the unit must be brought to MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Com pletion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit (continued)

CALLAWAY PLANT B 3.3.2-58 Revision 8g

INSERT 3.3.2.Q If one train is inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to restore the train to OPERABLE status. The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed for restoring the inoperable train to OPERABLE status is justified in Reference 23. The specified Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the inoperable train cannot be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,

ESFAS Instrumentation B 3.3.2 BASES REFERENCES 10. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor (continued) Response Time Testing Requirements," January 1996.

11. Callaway OL Amendment No. 43 dated April 14, 1989.

12. SLNRC 84-0038 dated February 27, 1984.

13. Callaway OL Amendment No. 117 dated October 1, 1996.

14. WCAP-14036-P-A, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," October 1998.

15. FSAR, Section 15.5.1 .

16. FSAR, Section 15.6.1 .

17. Letter from Mel Gray (NRC) to Garry L. Randolph (UE), "Revision 20 of the Inservice Testing Program for Callaway Plant, Unit 1 (TAC No. MA4469)," dated March 19, 1999.

18. WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times," October 1998.

19. WCAP-15376-P-A, Revision 1, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Rea ctor Trip Breaker Test and Completion Times," March 2003.

20. Westinghouse letter SCP-04-90 dated August 27, 2004.

21. ULNRC-03748 dated February 27, 1998.

22. IDP-ZZ-00017.

~~ 6.YIIA way Li<!ense Ahtendlhen+ Xxx t1~ ,qf;1.bb)Yy.

7 CALLAWAY PLANT B 3.3.2-68 Revision 8g

v t e Letter Sequence Supplement
TAC:ME2822, (Approved, Closed)
Initiation Request, Request, Request Acceptance Supplement, Supplement, Supplement Administration Questions 23 April 2010 7 September 2010 7 September 2010 20 October 2010 20 October 2010 25 October 2010 25 October 2010 5 November 2010 16 December 2010 12 January 2011 22 February 2011 Answers Results Approval Other:
MONTHYEAR2010-04-23 [Table View]

ULNRC-05731, Completion Time Extensions for TS 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation Functions (LDCN 09-0039 Supplement)

Text

References:

Response

Response

Response

Response

Navigation menu

ULNRC-05731, Completion Time Extensions for TS 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation Functions (LDCN 09-0039 Supplement)

Text

References:

Response

Response

Response

Response

Navigation menu

Search