Text

Notice of Meeting with Union Electric Company to Discuss Licensee'S Planned Responses to Staff Requests for Additional Information Related to Callaway Plant'S Request to Revise TS 3.3.2, ESFAS Instrumentation Functions
	ML103020279
Person / Time
Site:	Callaway
Issue date:	11/05/2010
From:	Thadani M; Plant Licensing Branch IV
To:	Markley M; Plant Licensing Branch IV
	Polickoski J, NRR/DORL/LPL4, 415-5430
References
	TAC ME2822
	Download: ML103020279 (20)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 November 5, 2010 MEMORANDUM TO: Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation SUB~IECT: FORTHCOMING MEETING WITH REPRESENTATIVES OF UNION ELECTRIC COMPANY (TAC NO. ME2822)

DATE & TIME: Thursday, November 18, 2010 9:30 a.m. to 11 :00 a.m. EST LOCATION: U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike, Room 0-8B02 Rockville, Maryland PURPOSE: To discuss Union Electric Company's (the licensee's) planned response to the U.S. Nuclear Regulatory Commission (NRC) staff's requests for additional information dated October 20 and 25, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML102930673 and ML102980368, respectively), regarding Callaway Plant, Unit 1's license amendment request to revise Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation Functions," dated November 25,2009 (ADAMS Accession No. ML093290318).

CATEGORY 1:

This is a Category 1 public meeting. The public is invited to observe this meeting and will have one or more opportunities to communicate with the NRC after the business portion, but before the meeting is adjourned.

PARTICIPANTS: Participants from the NRC include members of the Office of Nuclear Reactor Regulation (NRR).

NRC Union Electric Company M. Thadani K. Bucholtz S. Maglio J. Polickoski A. Howe T. Ellwood M. Markley G. Casto B. Yates S. Gardocki et al.

Commission's Policy Statement on "Enhancing Public Participation in NRC Meetings" (67 FR 36920), May 28, 2002.

M. Markley -2 Interested members of the public can participate in this meeting via a toll-free audio teleconference. Please call one of the meeting contacts listed below November 17, 2010, 3:00 p.m.

(Eastern Standard Time) to get the telephone number and the pass code.

MEETING CONTACTS: Mohan Thadani, NRR James T. Polickoski, NRR 301-415-1476 301-415-5430 mohan.thadani@nrc.gov james. polickoski@nrc.gov The NRC provides reasonable accommodation to individuals with disabilities where appropriate.

If you need a reasonable accommodation to participate in a meeting, or need a meeting notice or a transcript or other information from a meeting in another format (e.g., Braille, large print),

please notify the NRC's meeting contact. Determinations on requests for reasonable accommodation will be made on a case-by-case basis.

To receive a summary of this meeting and begin receiving other plant-specific e-mail distributions, you must subscribe to the Operating Reactor Correspondence electronic distribution for this plant via http://www.nrc.gov/public-involvellistserver/plants-by-region.html.

Once subscribed, if you wish to discontinue receiving electronic distribution, you may unsubscribe at any time by visiting the same web address above.

Docket No 50-483

Enclosure:

Agenda cc w/encl: Distribution via Listserv

AGENDA FORTHCOMING MEETING WITH UNION ELECTRIC COMPANY U.S. NUCLEAR REGULATORY COMMISSION Thursday. November 18, 2010 9:30 a.m. - 11 :00 a.m. EST

1. Introductions

2. Preliminary responses to requests for additional information (RAls) responses (Union Electric Company) a) Responses to specific RAl's dated October 20 and 25, 2010 b) Discussions of proposed modifications to TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation Functions" (see Attachment)

3. Questions (NRC staff)

4. Public participation

5. Closing remarks Enclosure

ATTACHMENT Proposed modifications to TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation Functions"

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME I. One channel inoperable. ------------------ NOTE .-.---------------

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 QB.

1.2 Be in MODE 3. 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months e or more Main ------------------ NOTE -----------------

Fee Pumps trip One inoperable channel may be channel(s) ina Ie. bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months f surveillance testing of r eels.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months J.2 Be in MODE 3.

rNS£/((" AI CALLAWAY PLANT 3.3-29 Amendment No. 196

INSERT A1 CONDITION REQUIRED ACTION COMPLETION TIME J. Two trains inoperable. ----------------NO"rE--------------

One inoperable channel 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 of other channels.

J.1.1 Restore one train to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OPERABLE status.

OR J.1.2 Place inoperable 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months channels in trip.

OR J.2 Be in MODE 3. 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months

ESFAS Instrumentation 3.3.2 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME M. +Jot t1eed. :I:NSt=/(f 13/

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 MODE4. 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 Rel:J~::l.4- ku.r.r-AND 0.2 Restore channel to During OPERABLE status. performance of the next required COT (Contmued)

CALLAWAY PLANT 3.3-31 Amendment No. 168

INSERT B1 CONDITION REQUIRED ACTION COMPLETION TIME M. One train inoperable. ----------------NOTE--------------

One inoperable channel 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 of other channels.

M.1.1 Restore channel(s) to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR M.1.2 Place inoperable 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months channel(s) in trip.

OR M.2 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months

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 - SR3.3.2.5 Environmental SR3.3.2.9 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 SR3.3.2.7 NA Power SR 3.3.2.10

g. Trip of all Main 1,2(0) .2 p'ir "~M" J)M SR 3.3.2.8 NA Feedwater Pumps

~ +n;.iY1 SO) ~,. 1\

h. Auxiliary 1,2,3 -:2. e "']eJ~fe.'" 31 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 Selpolnts.

(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

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

SAFETY ANALYSES, g.

LCO, AND APPLICABILITY A Trip of all MFW pumps (PAE01A and PAE01 ) is an indication of a loss of MFW and the subsequen need for some method of decay heat and sensible heat moval to bring the reactor back to no load temperature an pressure.

Each furbin-;ttdriven MFW pump is equipped wi two pressure switches (one in separation group 1 a d one in separation group 4) on the oil line for the speed ontrol system. A low pressure signal from either of th e pressure switches indicates a trip of that pump.~N&-

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'1&F!8F8tiBA fjFBt:lF! eFl BetA fiJt:lftlfiJ6 FeEjt:liFe8 fer sigi lal

...tliiitie~ A trip of all MFW pumps (PAE01A and PAE01 B) starts the moto:roriven AFW pumps to ensure that the intact SGs are availa Ie 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. J I JI renaer.r bD...,.-rl a One cause of multiple channel inoperability which~equires 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 89

INSERT 3.3.2.6.g There are two actuation trains for this function with two channels per actuation train. The separation group 1 channels (driven from FCPSL0025 and FCPSL0125) make up one actuation train and the separation group 4 channels (driven from FCPSL0026 and FCPSL0126) make up the second actuation train.

Signal actuation requires that both channels in a given train be OPERABLE. If one or both channels in an actuation train are inoperable, then that train is inoperable.

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE g. Auxiliarv 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 turbine-driven MFW pump experience the high oil pressures indicative of an operating pump prior to that turbine-driven MFW 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 MF~WUp turbine in reset, Condition J must be entered fo 0 inoperable oil pressure channels on that turbine-drive FW pum~ This Condition re ire..r Or- imposes a partial AFW actu on status (or partial trip) on the plant. L _ J.. L L .... ,.. I~"A I WI t:I C7'LfPrf14 /" (rift,.... ' IV This ESFAS fu nction is an anticipatory start signal for which no credit is taken in any accident or transient analysis. The safety analyses credit actuation of the~drivenAFW pumps upon a low-low steam generator ater level signal in any steam generator and after a saf y injection signal.

frlr-frJr

h. Auxiliarv 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 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.

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J 1 BRa d.2-;T: I.IJ ::T:.I.;L, IV >>

ahd.::r:;:;. (s.fq~ !lew f~~o/'¥lr Condition J applies to the AFW pump start on t 'p of all MFW pumps (PAE01A and PAE01B).

This action addresses the train orientation of the B P ESFAS for the auto start function of the AFW System on loss of all MFW umps (PAE01A and PAE01 B). The OPERABILITY of the AFW System m st be assured by providing automatic start of the AFW System pumps.JI+.o~~~ef'8'"

CbaQQ91(Si) are iAs~sra~le, 1 Astir is ellovoed to "Ieee tRe iAe~el'8Ble cbiRRel(s) iR ~Ae ~ri""ed eeAaitisR, If ~Ae sheARsls saRRst ~e tFi~l3ee! iR 1 Aal:lF, S Be!elitieR81 Ael:lFS BFa alle'Nee! ~s "Ieee the cliit iI i MODE a. 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.

K.1. K.2.1. and K.2.2 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.J1 Condition J applies if both actuation trains are inoperable. In this Condition the actuation function has been lost, Le., more than one channel is inoperable and the inoperable channels are not within the same separation group whether on separate MFW pumps or on the same MFW pump. 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 restore one actuation train to OPERABLE status or to place the inoperable channels in the tripped condition.

If one channel per MFW pump is inoperable within different separation groups or if both channels on the same MFW pump are inoperable, the actuation function is not available since neither actuation train is OPERABLE. 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 MFW 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 inoperabilityof both actuation trains and the loss of the actuation function.

Similarly, the loss of both channels on the same MFW pump would also 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.

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

If Required Action J.1.1 or J.1.2 can not be met within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time. 6 additional hours are allowed to place the unit in MODE 3.

ESFAS Instrumentation B 3.3.2 BASES ACTIONS (continued)

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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 cannot be placed in the tripped condition within the specified Completion Time, the unit must be placed in a MODE 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 4-1,001. ~ J..olAr..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.M1 (page 1 of 2)

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 PAE01B).

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

Condition M applies if one actuation train is inoperable. In this Condition the actuation function has not been lost, Le., only one channel out of the four total channels is inoperable or two channels out of the four total channels are inoperable but are in the same separation group. If Condition M is entered, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to restore inoperable channel(s) to OPERABLE status or place the inoperable channel(s) in the tripped condition. If the cause of the train inoperability is a single channel inoperable, that channel may either be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or placed in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If the cause of the train inoperability is the inoperability of both channels in that actuation train, the following must occur:

Both inoperable channels must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or

One inoperable channel must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the other inoperable channel tripped within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or

Both inoperable channels must be placed in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . However, this will result in the generation of an auxiliary feedwater (AFW) actuation signal to the motor-driven AFW pumps.

If a single channel out of the total of four channels is inoperable, or if one channel per MFW pump is inoperable but the Condition is limited to the same separation group, one actuation train is inoperable; however, the actuation function remains available via the OPERABLE actuation train. 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 MFW 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 M covers any of the following situations:

INSERT 3.3.2.M1 (page 2 of 2)

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 restored or 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.

BASES SURVEILLANCE SR 3.3.2.6 (continued) n..nfl#';

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REQUIREMENTS verified by a continuity check of the circuit containing the slave relay. This test is performed every 92 days. The SR is modified by a Note that excludes slave relays K602, K620, K622, K624 , K630, K740, K741 , and K750 which are included in testing required by SR 3.3.2.13 and SR 3.3.2.14. The Frequency is adequate, based on industry operating experience, considering instrument reliability and operating history data.

S8 3.3.2.7 SR 3.3.2.7 is the performance of a TADOT every 18 months. This test is a check of the AFW pump start on Loss of Offsite Power trip Function and the Steam Generator Blowdown and Sample Line Isolation Valve Actuation Function 10.d. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The trip actuating devices tested within the scope of SR 3.3.2.7 are the LSELS output relays and BOP ESFAS separation groups 1 and 4 logic associated with the automatic start of the turbine driven auxiliary feedwater pump and closure of the steam generator blowdown isolation valves and sample line isolation valves on an ESF bus undervoltage condition The Frequency is adequate. It is based on industry operating experience and is consistent with the typical refueling cycle.

The SR is modified by a Note that excludes verification of setpoints for relays. The trip actuating devices tested have no associated setpoint.

S8 3.3.2.8 SR 3.3.2.8 is the performance of a TADOT. This test is a check of the Manual Actuation Functions, AFW pump start on trip of all MFW pumps (PAE01A and PAE01 B), and manual generation of an SGBSIS (Function 10.a). The Manual Safety Injection TADOT shall independently verify OPERABILITY of the undervoltage and shunt trip handswitch contacts for both the Reactor Trip Breakers and Reactor Trip Bypass Breakers as well as the contacts for safety injection actuation. It is performed every 18 months. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay.

This is acceptable because all of the other required contacts of the relay (continued)

CALLAWAY PLANT B 3.3.2-62 Revision 8g

ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.8 (continued)

REQUIREMENTS are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The Frequency is adequate, based on industry operating experience and is consistent with the typical refueling cycle. The SR is modified by a Note that excludes verification of setpoints during the TADOT for manual initiation Functions. The manual initiation Functions have no associated setpoints. The Note exclusion does not explicitly apply to the AFW pump start on trip of both turbine-driven MFW pumps; however. the TADOT test procedures for that Function do not require the verification of a nominal trip setpoint or allowable value since none have ever been specified in the Technical Specifications for that anticipatory actuation signal which is not credited in any accident or transient analysis.

SR 3.3.2.9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.

A CHANNEL CALIBRATION is performed every 18 months, or approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.CHANNEL CALIBRATIONS must be performed consistent with the assumptions of Reference 6.

The Frequency of 18 months is based on the assumed calibration interval in the determination of the magnitude of equipment drift in the setpoint methodology..

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. This does not include verification of time delay relays.

These are verified via response time testing per SR 3.3.2.10.

The portion of the automatic PORV actuation circuitry required for COMS is calibrated in accordance with SR 3.4.12.9.

SR 3.3.2.10 This SR verifies the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

(continued)

CALLAWAY PLANT B 3.3.2-63 Revision 8g

ML103020279 OFFICE DORLlLPL4/PM DORLlLPL4/PM DORLlLPL4/LA DORLlLPL4/BC DORLlLPL4/PM II NAME JPolickoski MThadani JBurkhardt MMarkley MThadani 1,1, DATE 11/3/10 11/4/10 11/3/10 11/5/10 11/5/10 II

v t e Letter Sequence RAI
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]

ML103020279

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