Text

Application for Amendment to License No. NPF-030 (LDCN 12-0015), Revision to Technical Specification 3.7.9
	ML12349A321
Person / Time
Site:	Callaway
Issue date:	12/13/2012
From:	Maglio S; Ameren Missouri, Union Electric Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	ULNRC-05867
	Download: ML12349A321 (166)
	v • d • e

{{#Wiki_filter:~~ WAmeren Callaway Plant MISSOURI December 13, 2012 ULNRC-05867 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. APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NPF-30 (LDCN 12-0015) REVISION TO TECHNICAL SPECIFICATION 3.7.9 Pursuant to 10 CFR 50.90, "Application for Amendment of License or Construction Permit," Ameren Missowi (Union Electric Company) herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant. This amendment is requested in order to address a non-conservative Technical Specification as discussed in NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient To Assure Plant Safety." The proposed amendment would revise Technical Specification (TS) 3.7.9, "Ultimate Heat Sink (UHS)," to incorporate more restrictive UHS level and pond temperature limits which are specified in Surveillance Requirements (SRs) 3.7.9.1 and 3.7.9.2, respectively. In addition, new SR 3.7.9.4 would be added to verify that the UHS cooling tower fans respond appropriately to automatic start signals. The Enclosure to this letter provides an Evaluation of the proposed TS changes. Attachments 1 through 4 to the Enclosure provide the Technical Specification Page Markups, Technical Specification Bases Page Markups, Retyped Technical Specifications, and Proposed FSAR Changes, respectively, in support of this amendment request. Final TS Bases Changes will be processed under Callaway's program for updates per TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment is implemented. The FSAR will also be updated at the time this amendment is implemented. No commitments are contained in this amendment application.

************************************************************************************************************************       PO Box 620                  Fulton, MD 65251                    AmerenMissouri.com

ULNRC-05867 December I3, 20I2 Page2 It has been determined that this amendment application does not involve a significant hazard consideration, as determined per I 0 CFR 50.92, "Issuance of Amendment." In addition, pursuant to 10 CFR 51.22, "Criterion for Categorical Exclusion; Identification of Licensing and Regulatory Actions Eligible for Categorical Exclusion or Otherwise not Requiring Environmental Review," Section (b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment. The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the proposed changes, as well as the attached licensing evaluations, and have approved the submittal of this amendment application. Ameren Missouri requests approval of this license amendment request prior to December 13, 2013. As SR 3.7.9.4 is a new Surveillance Requirement, it is anticipated that the first required performance will come due during full power operation. In addition to revising procedures to reflect the new limits in SR 3.7.9.1 and SR 3.7.9.2, the testing imposed by the revised scope ofSR 3.7.8.2 and by new SR 3. 7. 9.4 will require new procedures and proper scheduling to assure each train is tested within the corresponding train work week. Therefore, Ameren Missouri also requests that the license amendment be made effective upon NRC issuance with implementation to occur within 120 days from the date of issuance. In accordance with 10 CFR 50.91, Notice for Public Comment; State Consultation," Section (b)( I), a copy of this amendment application 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 perjury that the foregoing is true and correct. Very truly yours, lL-f L~ /1-o I '- Executed on: xJtorf Scott Maglio y Regulatory Affairs Manager

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Enclosure:

Evaluation of the Proposed Change Attachments to the

Enclosure:

ULNRC-05867 December 13, 2012 Page 3 1- Technical Specification Page Markups 2- Technical Specification Bases Page Markups 3- Retyped Technical Specifications 4 - Proposed FSAR Changes 5- Use of GOTHIC 7.2b 6- Instrumentation and Controls Used to Implement Revised EOPs

ULNRC-05867 December 13, 2012 Page4 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy) Attn: Document Control Desk Washingtpn, DC 20555-0001 Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738

ULNRC-05867 December 13, 2012 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy: Certrec Corporation 4150 International Plaza Suite 820 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 C. 0. Reasoner III D. W. Neterer L. H. Graessle J. S. Geyer S. A. Maglio R. Holmes-Bobo NSRB Secretary T. B. Elwood G. G. Yates Mr. Mike Westman (WCNOC) Mr. Tim Hope (Luminant Power) Mr. Ron Barnes (APS) Mr. Tom Baldwin (PG&E) Mr. Mike Murray (STPNOC) Ms. Linda Conklin (SCE) Mr. John O'Neill (Pillsbury, Winthrop, Shaw, Pittman LLP) Missouri Public Service Commission Mr. Dru Buntin (DNR)

Enclosure Page 1 of25 EVALUATION OF THE PROPOSED CHANGE

1.

SUMMARY

DESCRIPTION Page 2

2. DETAILED DESCRIPTION Page 2 2.1 Proposed Changes Page 2 2.2 Background Page 3

3. TECHNICAL EVALUATION Page 8

4. REGULATORY SAFETY ANALYSIS Page 19 4.1 Applicable Regulatory Requirements/Criteria Page 19 4.2 No Significant Hazards Consideration Determination Page 21 4.3 Conclusions Page 24

5. ENVIRONMENTAL CONSIDERATION Page 24

6. REFERENCES Page 24

Enclosure Page 2 of25 EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION The proposed amendment would revise Technical Specification (TS) 3.7.9, "Ultimate Heat Sink (UHS)." More restrictive UHS level and pond temperature limits would be added to SR 3.7.9.1 and SR 3.7.9.2, respectively. In addition, new SR 3.7.9.4 would be added to verify that the UHS cooling tower fans respond appropriately to automatic start signals. 2.0 DETAILED DESCRIPTION 2.1 Proposed Changes The proposed amendment would revise TS 3.7.9, "Ultimate Heat Sink (UHS)," with more restrictive surveillance requirements. Specifically, SR 3.7.9.1 would be revised to increase the minimum initial UHS water level from 2: 831.25 feet mean sea level to 2: 834.0 feet mean sea level, and SR 3.7.9.2 would be revised to decrease the maximum initial average water temperature in the UHS pond from :::; 90°F to :::; 89°F. Further, new SR 3.7.9.4 would be added to verify that each UHS cooling tower fan starts automatically on an actual or simulated actuation signal. The Bases for new SR 3. 7.9 .4 would explain that this surveillance verifies proper auto-start capability and proper fan speed based on the temperatures sensed by the enabled temperature control loops. Since the credited mitigation functions performed by these temperature control loops (to auto-start the UHS cooling tower fans and change their speed from slow to fast depending upon the detected temperature) also include auto-closure of the UHS cooling tower bypass valves (EFHV0065, EFHV0066) in the essential service water (ESW) system, the Bases for SR 3.7.8.2 are being revised to identify these signals as being included within the set of actuation signals that must be tested within that Surveillance Requirement. The Frequency for new SR 3.7.9.4 is proposed to be in accordance with the Surveillance Frequency Control Program (SFCP) approved in Callaway License Amendment No. 202 (which, in turn, was based on TSTF-425-A, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," and NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies"). Those industry documents justified the relocation of all periodic Surveillance Frequencies from the Technical Specifications and placing the Frequencies under licensee control in accordance with a new program, the Surveillance Frequency Control Program. All Callaway Surveillance Frequencies were relocated except:

Enclosure Page 3 of25

Frequencies that reference other approved programs for the specific interval (such as the Inservice Testing Program or the Primary Containment Leakage Rate Testing Program);
Frequencies that are purely event-driven (e.g., "Each time the control rod is withdrawn to the 'full out' position");
Frequencies that are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours after thermal power reaching~ 95% RTP [Rated Thermal Power]"); and
Frequencies that are related to specific conditions (e.g., battery degradation, age, and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywell to suppression chamber differential pressure decrease" [for BWR plants]).

New SR 3.7.9.4 is of a recurring, periodic nature and does not satisfy any of the exclusion criteria above. Therefore, Ameren Missouri requests that the specified Frequency for new SR 3.7.9.4 be controlled in accordance with the Surveillance Frequency Control Program. The initial surveillance test interval (STI) for new SR 3.7.9.4 prior to the first application of the NEI 04-10 process will be 18 months. This request is consistent with the approvals given in Callaway License Amendment No. 202. The TS markups and retyped pages are provided in Attachments 1 and 3, respectively. Corresponding TS Bases changes and FSAR changes are provided in Attachments 2 and 4, respectively. 2.2 Background

System Description

The Ultimate Heat Sink (UHS) provides a heat sink during a transient or accident, as well as during normal operation, via the Essential Service Water (ESW) system. The two principal functions of the UHS are the dissipation of residual heat after reactor shutdown and dissipation of residual heat after an accident. The UHS consists of a 4-cell seismic Category I mechanical draft cooling tower and a seismic Category I source of makeup water (retention pond) for the cooling tower. Heat from the ESW system, as discussed in FSAR Section 9.2.5, is rejected to the UHS to permit a safe shutdown of the plant following an accident. The UHS enables the ESW system to supply approximately 15,000 gpm of cooling water per train at a maximum temperature of 92.3 op to remove the various component heat loads. The mechanical draft cooling tower is a safety-related, seismic Category I structure sized with 100-percent redundancy to provide heat dissipation for safe shutdown following an accident.

Enclosure Page 4 of25 ESW return flow from the power block is directed to the UHS cooling tower basin through normally open UHS cooling tower bypass valves (EFHV0065 in 'A' train, EFHV0066 in 'B' train). The position of the bypass valve in each train is normally controlled by ESW return water (UHS cooling tower inlet) temperature. This design provides freeze protection for the UHS cooling tower fill. ESW return flow from power block loads is normally directed through the open UHS cooling tower bypass valves to the cooling tower basin, thus bypassing the cooling tower fill. If the ES W return flow temperatures increase sufficiently, the UHS cooling tower bypass valves will automatically close. Original Licensing Basis During initial plant licensing (Callaway Safety Evaluation Report, NUREG-0830, Supplement 4, Section 2.4.4) a UHS level margin of 50% was accepted in lieu of a more restrictive minimum Technical Specification water level of 834 feet mean sea level (16 feet above the reference pond bottom) and a thermal and hydrologic analysis of the ESW and UHS. In this amendment request SR 3.7.9.1 is being changed to adopt the 834 feet mean sea level surveillance limit and the EF-123 analysis (discussed further below) addresses the thermal/hydrologic analysis issue. The SER Supplement 4 discussion (copied below), which describes the plant's original licensing basis with respect to the minimum UHS water depth, will no longer be applicable upon NRC approval of this license amendment request: 2.4.4 Ultimate Heat Sink In the SER the staff stated that an independent analysis of the thermal and hydrologic performance of the essential service water system was not made because of the significant margin available in the volume of the ultimate heat sink (UHS) retention pond over the requirements for one unit. To retain this margin, the staff established the UHS minimum water depth requirement in the final draft ("Technical Specifications for Callaway Unit No. 1") at 16ft above the pond bottom. The 1icensee, however, requested a lower minimum water depth in the pond so as to eliminate spillway discharges during tests and normal operation. Such spillway discharges would be in violation of the licensee's National Pollution Discharge Elimination System permit for one-unit operation. As an alternative to the 16-ft minimum depth established by the staff, the licensee proposed a minimum water depth of 13.25 ft (May 23, 1984). This depth would contain the water required for 30 days of losses under severe meteorological conditions plus a margin of 50% over the calculated loses. The staff reviewed the licensee's proposed water depth and found it acceptable. The UHS Technical Specification has been changed to reflect the licensee's proposed water level. Callaway's National Pollutant Discharge Elimination System (NPDES) Permit does not allow discharges from the UHS spillway (outfall #0 17). Included within the scope of

Enclosure Page 5 of25 Modification Package 11-0004 (discussed below) is a calculation of UHS freeboard which demonstrates that the risk of a UHS discharge is negligible as long as UHS level is maintained below the high alarm setpoint (835.83 feet mean sea level or 17 feet 10 inches above the reference pond bottom). Modification Package (MP) 11-0004 Plant modification package (MP) 11-0004 was implemented in the spring of 2012 to make the following changes:

Raise the required UHS level and associated annunciator alarm setpoints;
Lower the UHS cooling tower bypass valve and UHS cooling tower fan temperature control setpoints;
Add a new location in the ESW system flow path at each ESW pump discharge from which temperature control inputs can be derived from RTDs, new control circuits associated with those ESW pump discharge temperature elements (instrument loops EFT-0061 and EFT-0062); and new handswitches (EFHS0067, EFHS0068) to enable the new control circuitry; and
Revise the control room indication circuitry such that a determination can be made from main control room panel RLO 19 of each UHS cooling tower fan's speed (fast, slow, off). The plant operating staff can now verify the correct operation and position of the UHS cooling tower bypass valves and UHS cooling tower fans from the main control room.

These plant changes support the reanalysis described below with respect to assuring sufficient heat removal from ES W-supported loads and adequate UHS pond inventory for ESW pump net positive suction head (NPSH). The UHS cooling tower bypass valves will close at the required temperature and the cooling tower fans will operate at the required speed corresponding to the control temperature. The new ES W pump discharge control scheme ensures adequate 30-day UHS inventory. This modification also supports operator diagnostics from the main control room and the efficient implementation of the revised EOPs within credited manual operator action times. The plant design now supports the mitigation of a postulated design-basis large break loss of coolant accident (LOCA) via automatic temperature control of the UHS cooling tower bypass valves and UHS cooling tower fans that can be switched from a control scheme tied to ESW return flow temperature to one based on ESW pump discharge (ESW supply) temperature. This control scheme will be manually enabled by use of a control room handswitch (EFHS0067 for 'A' ESW train, EFHS0068 for 'B' ESW train) within 4 hours after a design-basis large break LOCA (LBLOCA), as discussed below under operator actions.

Enclosure Page 6 of25 EFHS0067 and EFHS0068 are installed on cabinet RP068, a safety-related local control BOP instrument rack in the back cabinet area of the main control room. As shown on drawing J-201-00037, the new switches are located approximately 32 inches above the floor. This location satisfies NUREG-0700, Guidelines for Control Room Design Reviews, published September 1981 (specifically, Section 6.1.2.2.d- Control Distance from the Front Edge of the Console). Taking into account items such as average male and female height and reach, a control switch height between 27 and 56 inches is needed for a flat stand-up console such used at the RP068 cabinet. A 32-inch height is, therefore, acceptable. The design of the temperature control setpoints prior to implementation of MP 11-0004 was based solely on providing freeze protection of the UHS cooling tower fill. The previous temperature control setpoints were, in ascending order, 91 op (bypass valves close), 104 op (cooling tower fans start in low speed), and 114 op (cooling tower fans switch to high speed). Following implementation ofMP 11-0004, the UHS cooling tower bypass valves will now automatically close when the ESW return water temperature is at or above 84 op to direct the water over the UHS cooling tower fill. If the ESW return water temperature increases to 95°F, the UHS cooling tower fans will automatically start in slow speed. IfESW return water temperature continues to rise, the UHS cooling tower fans will automatically shift to high speed at 105°F. The corresponding temperatures under the post-LOCA ESW pump discharge temperature control scheme in ascending order are 79°F (bypass valves close), 84.5°F (cooling tower fans start in low speed), and 89.5°F (cooling tower fans switch to high speed). ESW Pump Suction Design Protection and Preventive Maintenance The ESW intake apron extends 59 feet into the UHS pond. At each end of the apron, a concrete wing wall projects from the exterior comers of the ESW pumphouse originally designed for both Units 1 and 2. The resulting dimension between wing walls is 72 feet (drawings C-UC301 and C-UC303). The ESW intake apron includes a 3-foot wide by 6-inch high curb. The 6-inch curb acts as a barrier to resist any material resting on the bottom of the pond from accessing the intake apron. The curb does not restrict the flow of pond water above 6 inches above the pond bottom to the ESW pump intake. Additionally, the 72-foot length of the apron in the pond results in water flow over the curb at a very low velocity, substantially less than 1 foot per second. The flow velocity over the curb is insufficient to transport any settled debris or to result in scouring velocity that could erode the pond bottom across the face of the apron. The ESW pump intake structure is equipped with the necessary design features to permit UHS pond water supply to the ESW pumps at conditions of minimum pond level.

Enclosure Page 7 of25 Preventive Maintenance task PM0825838 (Clean and Inspect UHS Pond) is performed with a nominal frequency of every 36 months. The PM task involves cleaning the pond bottom using a sludge pump and cleaning the concrete apron and rip rap of debris. Need for Change In Licensee Event Report (LER) 2010-004-00 (Reference 6.1 ), Union Electric Company reported a latent design issue regarding the essential service water (ES W) system and ultimate heat sink (UHS). The reporting basis in the LER was 10 CFR 50.73(a)(2)(ii)(B) for an unanalyzed condition that significantly degraded plant safety. Upon review of a calculation for UHS performance, it was determined that a limiting single failure had not been evaluated. The single failure identified in the above LER is a postulated failure of one UHS cooling tower bypass valve in the open position (i.e., failure to close) during a design- basis LBLOCA. After this failure, flow from one train of ESW would be cooled by the UHS cooling tower while flow from the other train of ES W would return directly to the UHS pond. This would lead to the UHS pond temperature increasing more quickly than previously analyzed, potentially exceeding the UHS pond temperature design basis limit in as little as 70 minutes with no operator actions. During an LBLOCA both ESW trains are currently assumed to operate for the first 8 hours of the accident per FSAR Standard Plant Section 9.2.5.2.2.1, "Nominal Heat Loads Following a LOCA," and FSAR Site Addendum Section 9.2.5.2.2, "Component Description, Retention Pond." After 8 hours one ESW train is assumed to be secured per the above FSAR discussions. For the purposes of analyzing the core response and containment pressure/temperature response after an LBLOCA, a single failure of one protection train (including the failure of the associated ESW train) is considered; however, that failure is not limiting with respect to UHS temperature and inventory performance. If both ESW trains are in operation after a LBLOCA and it is assumed that one UHS bypass valve fails to close, a greater demand is placed on the UHS function in terms of minimum heat transfer from the ESW-supported loads and maximum evaporative losses from the UHS. FSAR Site Addendum Sections 9.2.5.3, "Safety Evaluation One," and 9.2.5.5, "Instrument Applications," currently discuss proceduralized operator actions, in light of the pre-modification temperature control setpoints, to assure the UHS pond temperature was maintained below its 92.3°F limit. The guidance (originally contained in EDP-EF-UHSO 1 Revision 0) noted that the UHS cooling tower fans will return to slow speed after UHS temperatures decrease and the guidance called for periodic UHS temperature monitoring and running the UHS cooling towers in fast speed if cooling tower freezing was not a concern while experiencing elevated UHS water temperatures. That guidance has since been replaced with the operator actions discussed on page 13 of 25 in this Enclosure.

Enclosure Page 8 of25 The cause for this unanalyzed condition was identified in the LER as a failure tore-evaluate the UHS/ESW single-failure analysis when UHS cooling tower capacity was questioned during construction of the plant.

3.0 TECHNICAL EVALUATION

The justification for this amendment is based on an analysis of the UHS and ESW system with credit given to three operator actions. UHS I ESW Analysis Analysis Summary Calculation EF-123, "UHS Thermal Performance Analysis using GOTHIC 7.2(b)- CAR

20 1001813," analyzes the thermal performance and changes in UHS pond inventory after an LBLOCA and the postulated failure of the 'A' train EFHV0065 UHS cooling tower bypass valve to close. LBLOCA was selected as the limiting DBA because the 30-day large break LOCA imposes the largest heat load on the UHS. Other design basis accidents (DB As), such as steam generator tube rupture (SGTR) or main steamline break (MSLB), include mechanisms that remove heat from the reactor coolant system and transfer it to the environment via the steam generator atmospheric steam dump valves. Use of the atmospheric steam dump valves bypasses the UHS. All heat removal pathways available for LBLOCA mitigation transfer heat to the UHS. For this purpose, LBLOCA was chosen as the limiting UHS heat load accident.

Callaway contracted Westinghouse and Numerical Applications Inc. (NAI) to create a plant model built utilizing the existing GOTHIC containment model and integrating all of the heat transfer components throughout the entire ESW system including the UHS pond. This holistic GOTHIC model was created by Westinghouse and benchmarked to data supplied by Callaway using the most current temperature and flow data acquired through various surveillances performed at the plant. The GOTHIC model used in EF-123 essentially looks at two of the worst case scenarios affecting the UHS cooling tower and retention pond performance for limiting weather conditions. The first is a hot, humid summer day when evaporative cooling in the UHS cooling tower is minimal. This scenario preserves UHS pond inventory at the expense of higher temperatures. The second scenario is a hot, dry summer day where evaporative cooling is maximized in the UHS cooling tower. This scenario keeps the UHS pond temperature down but results in increased losses in pond inventory. The two critical values that must be met in this model are the maximum UHS pond temperature of 92.3 °F and the minimum pond level of 1 foot above the pond bottom which is 819 feet above mean sea level. (For zero reference purposes the UHS pond bottom is defined as 818 feet above mean sea level, plant elevation 1977 feet 6 inches as

Enclosure Page 9 of25 shown on FSAR Site Addendum Figure 3.8-2 in Attachment 4.) The ESW pump intakes are located at 811 feet mean sea level in protected pump wells. EF -123 Cases # 1 & #2 - Maximum Evaporation Model and Minimum Heat Transfer Model with Bypass Valve Failure The primary assumptions made in EF -123 are the following:

1. Homogenous and uniform mixing is assumed throughout the UHS pond and within the various modeled piping. With the relatively high flow velocities and water temperatures, the resulting high Reynolds number values make this a valid assumption for pipe flows.

2. UHS cooling tower performance is assumed to be equivalent to design performance.

3. Weather conditions are worst case summer conditions to assure conservatism.

The two cases examined both high and low humidity conditions. The worst case FSAR conditions from the 2012 summer were compared and the FSAR scenario from July to August of 1955 was determined to be more limiting.

4. Water flow through all the modeled piping is assumed to be turbulent and well mixed. Any conductive or convective energy losses or gains are assumed to be negligible.

5. The UHS pond is assumed to be perfectly mixed and homogenous. Numerical Applications Inc. has compared the results of a sub-divided model to a lumped sum model and concluded that this assumption is valid.

6. Leak-by past the UHS cooling tower bypass valves EFHV0065/66 is negligible and assumed to have little to no impact on the results of the model.

7. UHS cooling tower performance was conservatively degraded by eliminating the use of7.5% of the mist eliminator blades in each train. This is the maximum allowable loss that still allows the cooling tower to meet the design criteria for heat removal capability.

EF-123 Cases #3 & #4: Maximum Evaporation Model and Minimum Heat Transfer Models under Normal Plant Operation Assumptions for these models are the same as those made in Cases 1 and 2 above, along with the following:

1. One train ofESW will be secured after seven days. The intent of modeling this delay is to bound the inventory losses that would occur 7 days into the event should the operators not go to single-train operation after 70 minutes which was modeled in EF -123.

Enclosure Page 10 of25

2. The UHS cooling tower bypass valves EFHV0065/66 do not fail and operate as designed.

Variation in Total Integrated Heat Loads vs. Current FSAR For all four cases the decay heat load due to heavy elements and fission products is calculated using ANSI/ANS-5 .1-1979. In addition, as part of our fuel cycle design process, we calculate fuel cycle-specific decay heat load calculations to verify that the decay heat loads associated with the next fuel cycle are bounded by the decay heat loads used in the UHS analysis. Currently, FSAR SP Section 9.2.5.2.2.1 shows a total integrated heat load of 56.6E9 Btu being sent to the UHS over the 30-day LBLOCA event. The EF-123 calculation shows a total of 54.9E9 Btu being sent to the UHS for the minimum heat transfer case with a failure of one UHS cooling tower bypass valve to close on demand over the 30-day LBLOCA event. The new total integrated heat load value uses the trapezoidal rule and integrates using much smaller time differentials than the current FSAR, thus yielding a more accurate value. Results With credit given to the manual operator actions discussed on page 13 of this Evaluation, the results of EF -123 show that in the maximum evaporation case with the assumed single failure to close of one UHS cooling tower bypass valve, the final30-day pond level is 3.05 feet above the UHS reference pond bottom with a peak UHS pond temperature of91.74°F at 2.57 hours. With no UHS cooling tower bypass valve failure, i.e., if the UHS cooling tower bypass valves close as designed (and with credit given to completing the 4-hour and 7-day operator actions described on page 13), the peak UHS pond temperature is less and the final 30-day pond level is higher. For the minimum heat transfer case, the results show that, with the noted single failure and credit given to completing the noted operator actions on page 13, the final 30-day pond level is 7.51 feet above the UHS reference pond bottom with a peak UHS pond temperature of92.0°F at 40.14 hours. With no UHS cooling tower bypass valve failure, i.e., if the UHS cooling tower bypass valves close as designed (and with credit given to completing the 4-hour and 7-day operator actions described on page 13), the peak UHS pond temperature is less; however, the final30-day pond level is 7.20 feet above the UHS reference pond bottom. Both of these scenarios (maximum evaporation and minimum heat transfer) show that, under the worst summer conditions, the UHS pond is capable of performing its designed safety function.

Enclosure Page 11 of25 Analysis Results Summary Case* Maximum UHS Retention Time to Peak UHS Final UHS Level above Pond Temperature Pond Temperature Pond Bottom after 30 Days 1 91.74°F 2.57 hours 3.05 feet 2 92.00°F 40.14 hours 7.51 feet 3 89.23°F 410.85 seconds 3.16 feet 4 89.23°F 405.24 seconds 7.20 feet

LBLOCA Case Scenarios:

1 - Single active failure of one UHS cooling tower bypass valve to close, one ESW train secured within 70 minutes, maximum evaporation case 2 - Single active failure of one UHS cooling tower bypass valve to close, one ESW train secured within 70 minutes, minimum heat transfer case 3 -No single active failure ofUHS cooling tower bypass valve (valves close on demand), both ESW trains operating for first 7 days before one train is secured, maximum evaporation case 4- No single active failure ofUHS cooling tower bypass valve (valves close on demand), both ES W trains operating for first 7 days before one train is secured, minimum heat transfer case UHS Temperature and Level Uncertainties The UHS/ESW analysis accounts for temperature loop uncertainties in the modeling contained within Calculation EF -123. Therefore, the initial average water temperature, as reflected in the revision to SR 3.7.9.2, does not require the plant operators to factor in measurement uncertainty with each reading of the UHS pond temperature. They can directly compare the indicated values shown on recorder EFTR0113 in the 'A' ESW pump room to the value shown in SR 3.7.9.2 to assure compliance. The intent of the cases analyzed in EF -123 is to determine the scenarios and assumptions that will either minimize UHS pond level or maximize UHS pond temperature. For the Maximum Evaporation case, the intent is to keep the UHS pond water as cool as possible by maximizing evaporative cooling to the atmosphere. This case assumes a hot summer day with very low humidity, which optimizes heat removal from the returning ESW flow, thereby challenging pond inventory due to maximized evaporative losses to the atmosphere. In order to do this the UHS cooling tower fan setpoints used in the calculation are assumed to be at their nominal values minus a temperature uncertainty

Enclosure Page 12 of25 (2.5°F). This assumption keeps the UHS cooling tower fans running in high speed as long as possible over the 30 day event. For the Minimum Heat Transfer case, the intent is to keep the UHS pond water as warm as possible by minimizing evaporative cooling to the atmosphere. This case assumes a hot summer day with very high humidity, which minimizes heat removal from the returning ESW flow, thereby challenging UHS pond temperature due to minimized evaporative cooling. In order to do this the UHS cooling tower fan setpoints used in the calculation are assumed to be at their nominal values plus a temperature uncertainty (2.5°F). This assumption keeps the UHS cooling tower fans running in low speed, or turned off, as long as possible over the 30 day event. The 2.5°F uncertainty was derived in Calculation J-UEF03 using the methodology from ISA-S67 .04, dated September 1994, "Setpoints for Nuclear Safety-Related Instrumentation," and ISA-RP67.04, dated September 1994, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation." The UHS/ESW analysis in EF-123 also assumes that the initial UHS water level is at the proposed Technical Specification value (834.0 feet mean sea level, 16 feet above the UHS reference pond bottom) reflected in the revision to SR 3.7.9.1. The operators will verify that window 55D on control room annunciator panel RK020 is not alarming. The level indicating switch, EFLIS0027, which feeds the 55D UHS pond low level alarm has a setpoint that is 16 feet 8 inches above the UHS reference pond bottom. The derivation of that low alarm setpoint takes into account the switch tolerance of2 inches, wind-induced wave action of 1 inch, and includes an additional 5 inches for margin. If the low level alarm annunciates, the plant operators verify that the UHS water level is greater than 16 feet above the UHS reference pond bottom using local indications (at the ESW pumphouse building in the forebays associated with ESW pumps 'A' and 'B') available from EFLIS0027 and EFLIS0027 A. Those UHS level indicating switches are calibrated under Preventive Maintenance tasks (PM0808730 and PM0808725) with a nominal 18-month frequency to verify that the 2-inch switch tolerance is met. In addition to the 5-inch low UHS level annunciator setpoint margin above it should be noted that that the limiting UHS retention pond level after 30 days for Case 1 (maximum evaporation scenario with a failure to close of one of the UHS cooling tower bypass valves) is 3.05 feet above the UHS reference pond bottom. The ESW pumps require only one foot of UHS pond level above the UHS reference pond bottom in order to assure adequate NPSH (per drawing M-089-U0012). Therefore, the new specified level in revised SR 3. 7. 9.1 includes a conservative consideration of uncertainties, margins, and tolerances and will not require plant operators to factor in any additional uncertainty when readings of UHS pond level are taken. The above approach is consistent with Callaway's original licensing basis as discussed in SLNRC 84-0089 dated 5-31-84. The only Technical Specification values that factor in a measurement uncertainty between the safety analysis values and the corresponding

Enclosure Page 13 of25 indicated values read by the plant operators are pressurizer pressure and RCS average temperature addressed in the DNB TS 3.4.1. ESW Support of Normal RCS Cooldowns Although 10 CFR 50 Appendix R applies only to plants operating prior to 1/1179, the criteria contained in Appendix R are addressed in Callaway FSAR SP Appendix 9 .5B. One of the assumptions in FSAR SP Section 9 .5B.2 item (b) explicitly states that "A design basis accident occurring simultaneously with a fire hazard is not assumed." Therefore, an LBLOCA and a hazard, such as a fire, are not postulated to occur at the same time. The requirement from 10 CFR 50 Appendix R Paragraph III.L.5 is to be able to cool down the plant to Mode 5 (<200°F) within 72 hours if necessary. In addition, the Technical Specifications require the capability for a MODE 5 shutdown within 36 hours. At Callaway this would be done with a single train of RHR since the second train of RHR would be kept in a standby status for potential ECCS safety injection during MODE 4 per Technical Specification 3.5.3. Westinghouse re-analyzed the RHR cooldown rates described in FSAR SP Section 5.4.7 to show the RHR system would meet the above requirements using an initial UHS pond temperature at the analysis limit of 92.3 °F (since previous analyses assumed 95°F). The revised calculation resulted in a reduced cool down time with one train of RHR equipment in service in accordance with the plant Technical Specifications. For a normal cool down, a COLD SHUTDOWN to MODE 5 with a single train of RHR equipment in service can be achieved in 30.6 hours after reactor shutdown (a reduction by 3 hours). The markups in Attachment 4 include replacement Figures 5.4-9 and 5.4-10 along with all of the necessary FSAR text markups. GOTHIC Computer Code Version 7.2b GOTHIC (Generation of Thermal-Hydraulic Information for Containments) is a general-purpose thermal-hydraulics code for containment analysis developed for the Electric Power Research Institute (EPRI) by Numerical Applications, Inc. (NAI), for applications in the nuclear power industry. GOTHIC version 7.2b was used for the analysis discussed above. Attachment 5 contains a discussion demonstrating that GOTHIC 7 .2b is an approved analysis methodology that does not require further NRC review. Credited Manual Operator Actions The goal of EF -123 is to show that the UHS pond has adequate inventory and can stay below the maximum temperature of 92.3 °F under LBLOCA conditions. The GOTHIC model was used to verify that these two critical parameters are met. In the model the

Enclosure Page 14 of25 following critical assumptions are made which correspond to credited operator actions with defined completion times:

1. Verification of proper UHS Cooling Tower operation and securing affected ESW train within 70 minutes of the accident.

Verification ofUHS bypass valve position and operating status of the UHS cool-ing tower fans (on/off, fan speed) can be performed from the main control room.

2. UHS Cooling Tower Inlet temperature switchover within 4 hours to ESW Pump Discharge temperature.

During an LBLOCA event, the peak ESW temperatures entering the UHS cooling tower occur within the first few hours of the event. Temperatures then start to decrease but not at a rate that would allow the UHS cooling tower fans to switch to slow speed and thereby preserve UHS pond inventory. Protecting the amount of water available in the pond over the 30-day post-accident mission time requires the temperature monitoring point associated with the control scheme for the UHS cooling tower bypass valves and fans to be switched to a location indicative of a bulk average temperature after the ES W return water (UHS inlet) has had a chance to mix. In order to accomplish this objective the temperature is measured at the ESW pump discharge. The GOTHIC model used in EF-123 was modified to take this temperature switchover time and location into account. There is little sensitivity to the 4-hour timing of this action as long as it is done within a window of 70 minutes to 64 hours. Comparing the analyzed temperatures of the ESW system volume and the UHS pond to the chosen control setpoints, it can be demonstrated that either set of temperature setpoints (ESW return or ESW supply) will keep the fans in high speed for at least 64 hours past the initiation of the event. There will be some difference between the two setpoints for when the fans actuate at the beginning of the accident, but it will be fairly close to the initiation of the LBLOCA and will not approach the 4-hour mark. The 4-hour operator action switches over from the rapid-responding ESW return temperature sensor, which is only needed at the start of the accident, to the long-term inventory management control via the ESW pump discharge (ESW supply) temperature for bulk UHS pond temperature control. An earlier swapover would not matter as long as the plant is past the first 30 minutes or so of the accident and a later swapover would only result in a minimal loss ofUHS inventory. This is the basis for assigning the rather arbitrary time of 4 hours in order to be grouped with the separate 4-hour step to take action to assure spent fuel pool cooling.

3. Securing one train of ESW within 7 days.

In order to preserve the UHS pond inventory over the required 30 days, it is

Enclosure Page 15 of25 necessary to have one train of ES W and associated UHS cooling tower fans secured within 7 days into the LBLOCA event (assuming that both ESW trains are actuated and are operating in response to the LBLOCA). The reason for this is that with two trains ofESW and UHS cooling tower fans running, the evaporative losses incurred due to the second train running would remove inventory and reduce the margin needed to meet the 30-day requirement. To address this issue, Technical Support Center procedure EIP-ZZ-00240 Addendum B, "Technical Assessment Coordinator (TAC) Checklist," requires a review of EDP-EF-UHS01, "UHS Cooling Tower Operational Guidance Following a LOCA," to assure that one train of ESW is secured within 7 days after initiation of an LBLOCA to protect UHS pond inventory. One operating train (with two UHS cooling tower fans to a train) is adequate to dissipate the remaining heat load resulting from the accident. In addition, although not a credited operator action with a defined completion time, Step 5 ofEOP Addendum 40 (discussed further below) is a continuous action step to check UHS cooling tower fan speeds vs. the ESW pump discharge (ESW supply) temperature so that any equipment failures involving the temperature control handswitches (EFHS0067, EFHS0068) or ESW supply temperature loops (EFT-0061, EFT-0062) would be recognized and addressed in time (e.g., by securing the affected ESW train, if necessary) to support maintaining the necessary UHS pond inventory. It is expected that any operator action required to diagnose and respond to a failed temperature control switch (EFHS0067 or EFHS0068) or an ESW supply temperature loop circuit failure would be performed within 24 hours after event initiation. Emergency Operating Procedures CEOPs) Since the time when the single failure issue addressed in LER 201 0-004-00 was initially raised in March 2010, EOP E-1, "Loss of Reactor or Secondary Coolant," has been revised to add two new steps. New step 11 was added in May 2010 to assure operator action is taken to diagnose and mitigate a postulated single failure of a UHS cooling tower bypass valve to close. The time requirement for the completion of these actions is 70 minutes per the current UHS I ESW analysis described above. New step 19 was added in June 2012 to assure operator action is taken within 4 hours to switch the automatic temperature control scheme governing the operation of the UHS cooling tower bypass valves and cooling tower fans from one based on ESW return (UHS inlet) water temperature to one based on ESW pump discharge temperature. Step 11 ofEOP E-1 (mentioned above) is a continuous action step such that it remains in effect for the entire time E-1 is performed. Step 11 directs the plant operators to use indications from NG07 and NG08 load center voltage annunciators (E-1 step 11.a) to verify power supply to the UHS cooling tower fans, and to check the ESW return (UHS inlet) water temperature (E-1 step 11. b) in order to verify proper UHS cooling tower

Enclosure Page 16 of25 bypass valve position and UHS cooling tower fan operation I speed. If the load center voltage annunciator alarms due to an undervoltage condition, the affected ESW train is secured using EOP Addendum 17, "Securing ESW Train due to UHS Cooling Tower Trouble." If the UHS cooling tower bypass valves are not in the correct position for the prevailing ESW return water temperature (E-1 step 11.c), based on main control room indication for each valve, the following actions are taken:

If radiological conditions permit, equipment operators are dispatched to locally ensure the bypass valves are in the correct position for the prevailing ESW return water temperature (bypass valves should automatically close on high temperature).
If radiological conditions after a design-basis LBLOCA do not permit local valve manipulation, the affected ESW train is secured using EOP Addendum 17.

If the UHS cooling tower fans are not in the correct operating status (on/off, fan speed) for the prevailing ESW return water temperature (E-1 step 11.d), UHS cooling tower fans should automatically start in slow speed on high temperature, switch to fast speed on high-high temperature, and reset appropriately as temperature decreases), the following actions are taken:

The affected ESW train's loads are cooled by the normal service water system if available (via cross-connect valves EFHV0023 and EFHV0025 for 'A' train and via EFHV0024 and EFHV0026 for 'B' train, which automatically close after a safety injection signal or loss of offsite power); however, the design-basis LBLOCA also assumes a loss of offsite power during which the non-safety related normal service water pumps would not be powered.
If normal service water is not available, the affected ESW train is secured using EOP Addendum 17.

EOP Addendum 17 directs the plant operators to verify that one train ofESW remains in operation and the operating ESW train's supported equipment is operating. For the ESW train being secured from service, EOP Addendum 17 directs the plant operators to secure the affected ESW train's supported loads by placing their control switches in "pull-to-lock," secure the affected train's ESW pump by placing its control switch in pull-to-lock, and stop that train's emergency diesel generator. Step 19 ofEOP E-1 directs a transfer to EOP Addendum 40, "UHS Cooling Tower Fan Speed and Bypass Valve Control," within 4 hours after accident initiation. Assuming that load centers NG07 and NG08 are providing power to the UHS cooling tower fans (as already verified at step 11), EOP Addendum 40 requires the control room operating

Enclosure Page 17 of25 staff to manually transfer the temperature control scheme for the UHS cooling tower bypass valves and fans using handswitches EFHS0067 and EFHS0068. After that transfer is manually enabled, the ES W pump discharge temperature will automatically control the UHS cooling tower bypass valves and cooling tower fans with lower temperature switch settings as discussed in the Background section above. From this point EOP Addendum 40 verifies proper operation of the UHS bypass valves and cooling tower fans with similar "Response Not Obtained" actions as discussed under E-1 step 11 if improper responses are observed. Step 5 of EOP Addendum 40 is a continuous action step to check UHS cooling tower fan speeds vs. the ESW pump discharge (ESW supply) temperature so that any equipment failures involving the temperature control handswitches (EFHS0067, EFHS0068) or ESW supply temperature loops (EFT-0061, EFT-0062) would be recognized and addressed in time (securing the affected ESW train if necessary) to support maintaining the necessary UHS pond inventory. provides additional information regarding the instrumentation and controls used by the plant operators to implement the above EOP revisions. Simulator Verifications On May 5, 2010 two 4-man crews were observed for their responses to the following simulator scenario:

Loss of offsite power
Large break LOCA
Swapover to cold leg recirculation per EOP ES-1.3, "Transfer to Cold Leg Recirculation" (required by the EOP E-1 foldout page ifRWST level decreases to less than 36% of span)

   *    'A' train UHS cooling tower bypass valve EFHV0065 fails to close as required, alarmed via annunciator 54E (response procedure OTO-RK.-00020 Addendum 54E, "UHS Cooling Tower Trouble")
   *    'A' train UHS cooling tower fans lose power from load center NG07, alarmed via annunciator 30E (response procedure OTO-RK.-00016 Addendum 30E)

The scenario termination point was when the affected ES W train was secured. One crew took 41 minutes to secure the affected ESW train and the other crew took 45 minutes. On 5/7/10 one 4-man crew was observed for their response to the following simulator scenario:

Large break LOCA
Swapover to cold leg recirculation per EOP ES-1.3, "Transfer to Cold Leg Recirculation" (required by the EOP E-1 foldout page ifRWST level decreases to less than 36% of span)

Enclosure Page 18 of25

   *     'A' train UHS cooling tower fans lose power from load center NG07, alarmed via annunciator 30E (response procedure OTO-RK-00016 Addendum 30E)

The scenario termination point was when the affected ES W train was secured. The crew took 44 minutes to secure the affected ESW train. On 5/12/10 one 3-man crew was observed for their response to the following simulator scenario:

Large break LOCA Loss of plant computer (this requires an equipment operator to be dispatched to the 1974-foot elevation ofthe control building (room 3101) for step 1l.b to locally determine ES W return water temperatures since computer points were not available)
Swapover to cold leg recirculation per EOP ES-1.3, "Transfer to Cold Leg Recirculation" (required by the EOP E-1 foldout page ifRWST level decreases to less than 36% of span)

   *    'A' train UHS cooling tower fan CEF01B fails to run The scenario termination point was when the affected ES W train was secured. This crew took 65 minutes 6 seconds to secure the affected ESW train. However, 15 minutes of that time were set aside in the simulator scenario prior to the exercise for E-1 step 11.d to send an equipment operator to the UHS cooling tower electrical rooms to verify fan operating status and speed (four separate time studies were performed for E-1 Step 11.d that varied between 8 minutes 6 seconds to 9 minutes 29 seconds). Since that time a plant modification has been completed (MP 11-0004, as previously described) allowing the control room staff to verify UHS cooling tower fan operating status and speed using safety-related control board indications.

On 2/9/12 one 6-man crew (with a Shift Technical Advisor and extra Reactor Operator) was observed for their response to the following simulator scenario:

Large break LOCA
Swapover to cold leg recirculation per EOP ES-1.3, "Transfer to Cold Leg Recirculation" (required by the EOP E-1 foldout page ifRWST level decreases to less than 36% of span)
No failures of the UHS cooling tower bypass valves or fans
Simulation run to step 19 and Addendum 40 to verify 4-hour action to transfer temperature control scheme The crew completed the required steps in E-0 ("Reactor Trip or Safety Injection"),

transitioned to E-1, transitioned to ES-1.3 for cold leg recirculation, transitioned back to E-1, and completed step 11 of E-1 in a total time of 46 minutes. This included an extra 5 minutes for a training timeout for discussion; therefore the actual simulation time for comparison against the required 70-minute credited operator action was effectively 41

Enclosure Page 19 of25 minutes. After the simulation was restarted the crew took an additional 19 minutes to proceed from E-1 step 12 to E-1 step 19 and then complete EOP Addendum 40 to transfer the temperature control to ESW pump discharge temperature. Based on the above results, credited operator actions (70 minutes to diagnose and remedy failures of the UHS cooling tower bypass valve or the UHS cooling tower fans by securing the affected ESW train and 4 hours to manually transfer the temperature control scheme for the UHS cooling tower bypass valves and fans to the ESW pump discharge temperature) have been demonstrated to be credible analysis assumptions. No simulator demonstration of the operator action to diagnose a failed temperature control switch (EFHS0067 or EFHS0068) or the 7-day operator action to secure one train ofESW was deemed necessary given the continuous staffing of the Technical Support Center after a large break LOCA. 4.0 REGULATORY SAFETY ANALYSIS 4.1 Applicable Regulatory Requirements I Criteria Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include Technical Specifications (TSs) as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The U.S. Nuclear Regulatory Commission's (NRC's) requirements related to the content of the TSs are contained in Section 50.36 ofTitle 10 ofthe Code ofFederal Regulations (10 CFR 50.36) which requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements per 10 CFR 50.36(c)(3); (4) design features; and (5) administrative controls. This amendment application is mainly related to the third category above and represents a more restrictive change since a new Surveillance Requirement (SR) 3.7.9.4, revised scope for existing SR 3.7.8.2, and more restrictive SR limits for UHS level and temperature are being incorporated into the Callaway Technical Specifications. The following regulatory requirements and guidance documents also apply to the UHS cooling tower bypass valves, UHS cooling tower fans, and the ESW system:

GDC 2 requires that structures, systems, and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

Enclosure Page 20 of25

GDC 4 requires that structures, systems, and components important to safety be designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with the normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, discharging fluids that may result from equipment failures, and from events and conditions outside the nuclear power unit. However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.
GDC 44 - Cooling Water "A system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions. Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure."
GDC 45 - Inspection Of Cooling Water System "The cooling water system shall be designed to permit appropriate periodic inspection of important components, such as heat exchangers and piping, to assure the integrity and capability of the system."
GDC 46- Testing Of Cooling Water System "The cooling water system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and the performance of the active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation for reactor shutdown and for loss-of-coolant accidents, including operation of applicable portions of the protection system and the transfer between normal and emergency power sources."
Regulatory Guide 1.27 describes requirements to be met by the Ultimate Heat Sink. This Regulatory Guide requires Callaway Plant to have a reliable source of

Enclosure Page 21 of25 cooling water that can assure the safe shutdown of the plant during a Design Basis Accident over a 30-day time frame. There are no changes proposed in this license amendment application that would be in conflict with any of the above regulatory requirements as the intent of the changes is to assure continued compliance, particularly with respect to GDC 44 and GDC 46. 4.2 No Significant Hazards Consideration (NSHC) Determination This section addresses the standards of 10 CFR 50.92 as well as the applicable regulatory requirements and acceptance criteria. The proposed amendment would revise Technical Specification (TS) 3.7.9, "Ultimate Heat Sink (UHS)." More restrictive UHS level and pond temperature limits would be added to SR 3.7.9.1 and SR 3.7.9.2, respectively. In addition, new SR 3.7.9.4 would be added to verify that the UHS cooling tower fans respond appropriately to automatic start signals. Ameren Missouri has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," Part 50.92( c), as discussed below:

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

Response: No There are no design changes associated with the proposed amendment. All design, material, and construction standards that were applicable prior to this amendment request will continue to be applicable. The proposed change will not adversely affect accident initiators or precursors or adversely alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained with respect to such initiators or precursors. The proposed changes do not affect the way in which safety-related systems perform their functions. All accident analysis acceptance criteria will continue to be met with the proposed changes. The proposed changes will not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. The proposed changes will not alter any assumptions or change any mitigation actions in the radiological consequence evaluations in the FSAR.

Enclosure Page 22 of25 The applicable radiological dose acceptance criteria will continue to be met. The intent of the modified UHS water level and temperature limits for TS 3. 7. 9, as proposed, is to ensure that the UHS can perform its specified safety function for accident mitigation, including consideration of its 30-day mission time. The proposed surveillance limits are more restrictive and are based on an analysis that includes credit given to specific operator actions (with assumed completion times) not previously assumed. However, the operator actions are reasonable and have been established in accordance with NRC-approved guidance. Further, they have been simulator verified and proven to be capable of being met by plant operators under applicable accident scenarios. The crediting of these operator actions is consistent with the plant's current licensing basis which already credits operator action to provide long-term protection of the UHS following an accident. These actions, in conjunction with the more restrictive proposed UHS water temperature and level surveillance limits, support the plant's existing accident analysis such that there is no change in analyzed consequences. In light of these considerations, there is no significant increase in the consequences of any accident previously evaluated with regard to the assumed operator actions and revised UHS water level and temperature limits, as proposed. The proposed change adds additional controls to the Technical Specifications but does not physically alter safety-related systems or affect the way in which safety-related systems perform their functions per the intended plant design. As such, the proposed change will not alter or prevent the capability of structures, systems, and components (SSCs) to perform their intended functions for mitigating the consequences of an accident and meeting applicable acceptance limits. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No With respect to any new or different kind of accident, there are no proposed design changes nor are there any changes in the method by which any safety-related plant sse performs its specified safety function. The proposed change will not affect the normal method of plant operation. No new transient precursors will be introduced as a result of this amendment. The reanalysis discussed herein addresses new large break LOCA scenarios with assumptions, including single failures, aimed at maximizing the UHS temperature and minimizing the UHS inventory. The proposed change adds requirements to the Technical Specifications. The change does not involve a physical modification of the plant. The UHS level and temperature

Enclosure Page 23 of25 limits within which the plant is normally operated are being changed in the conservative direction. Appropriate changes have been made to the emergency operating procedures relied upon to mitigate a design basis event. The change does not have a detrimental impact on the manner in which plant equipment operates or responds to an actuation signal. The changes to the ultimate heat sink (UHS) surveillance limits are in the conservative direction. The proposed change does not, therefore, create the possibility of a new or different accident from any accident previously evaluated.

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

Response: No There will be no effect on those plant systems necessary to assure the accomplishment of protection functions associated with reactor operation or the reactor coolant system. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, heat flux hot channel factor (Fo), nuclear enthalpy rise hot channel factor (F ~H), loss of coolant accident peak cladding temperature (LOCA PCT), peak local power density, or any other limit and associated margin of safety. Required shutdown margins in the COLR will not be changed. The proposed change does not eliminate any surveillances or alter the frequency of surveillances required by the Technical Specifications. The proposed change would add Technical Specification Surveillance Requirements for assuring the automatic closure of the UHS cooling tower bypass valves when required and the automatic start of the UHS cooling tower fans and their transition from slow speed to fast speed when required. The extent of Callaway's conformance to NRC Regulatory Guide (RG) 1.27 is discussed in FSAR Site Addendum Table 9.2-5 (see Attachment 4 to this Enclosure). RG 1.27 requires that the UHS be sized for 30 day post-LOCA operation; however, it does not specify a margin value above that 30-day requirement. During initial plant licensing (Callaway Safety Evaluation Report, NUREG-0830, Supplement 4, Section 2.4.4) a UHS level margin of 50% was accepted in lieu of a more restrictive minimum Technical Specification water level of 834 feet mean sea level (16 feet above the reference pond bottom) and a thermal and hydrologic analysis of the ESW and UHS. In this amendment request SR 3.7.9.1 is being changed to adopt the former and the supporting EF-123 analysis addresses the latter. The SER Supplement 4 discussion, copied in Section 2.2 of this Evaluation, will no longer be applicable upon NRC approval of this license amendment request. As such, the proposed change does not involve a significant reduction in a margin of safety as defined in any regulatory requirement or guidance document.

Enclosure Page 24 of25 Based on the above evaluation, Ameren Missouri concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of"no significant hazards consideration" is justified. 4.3 Conclusions In conclusion, based on the considerations discussed above, ( 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Ameren Missouri has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 AmerenUE letter ULNRC-05701 dated April30, 2010, Licensee Event Report 2010-004 Unanalyzed Single Failure Component for Ultimate Heat Sink I Essential Service Water. 6.2 Callaway License Amendment 168, Issuance of Amendment Regarding the Steam Generator Replacement Project (TAC NO. MC4437), dated September 29, 2005, ADAMS Accession Nos.: ML052570054, Package ML052570086, TS ML052730083. 6.3 George, TL, et al., GOTHIC Containment Analysis Package User Manual, Version 7.2b(QA), NAI 8907-02, Rev. 18, Numerical Applications, Inc., Richland, WA, March 2009. 6.4 George, TL, et al., GOTHIC Containment Analysis Package Technical Manual, Version 7.2b(QA), NAI 8907-06, Rev. 17, Numerical Applications, Inc., Richland, WA, March 2009.

Enclosure Page 25 of25 6.5 George, TL, et al., GOTHIC Containment Analysis Package Qualification Report, Version 7.2b(QA), NAI 8907-09, Rev. 10, Numerical Applications, Inc., Richland, WA, March 2009.

ATTACHMENT 1 TECHNICAL SPECIFICATION PAGE MARKUPS

UHS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of UHS is ~..ga1.2~ft mean sea In accordance level. with the

                                                ?31:()             Surveillance Frequency Control Program SR 3.7.9.2   Verify average water temperature of UHS is   ~?F. In accordance with the f1       Surveillance Frequency Control Program SR 3.7.9.3   Operate each cooling tower fan for   ~ 15 minutes in  In accordance both the fast and slow speed.                        with the Surveillance Frequency Control Program CALLAWAY PLANT                         3.7-27                      Amendment No. 202

UHS 3.7.9 INSERT 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.4 Verify each cooling tower fan starts automatically In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program CALLAWAY PLANT 3.7-27 Amendment No.

ATTACHMENT 2 TECHNICAL SPECIFICATION BASES PAGE MARKUPS

ESW 8 3.7.8 B 3. 7 PLANT SYSTEMS B 3.7.8 Essential Service Water (ESW) System BASES BACKGROUND The ESW system provides a heat sink for the removal of process and operating heat from safety-related components during a Design Basis Accident (DBA) or transient. During normal operation, and a normal shutdown, the ESW system also provides this function for various safety-related and non-safety related components and receives coolant flow from the non-safety related Service Water system. The safety-related function associated with the mitigation of DBAs and transients analyzed in FSAR Chapters 6 and 15 is covered by this LCO. The ESW system consists of two separate, 100% capacity, safety-related, cooling water trains. Each train consists of a self cleaning strainer, prelube tank, one 100% capacity pump, piping, valving, and instrumentation. The pumps and valves are remote and manually aligned, except in the unlikely event of a loss of coolant accident (LOCA). The pumps are automatically started upon receipt of a safety injection signal, low suction pressure to the auxiliary feedwater pumps coincident with an auxiliary feedwater actuation signal (AFAS), or loss of offsite power. Upon receipt of one of these signals, the automatically actuated essential valves are aligned to their post-accident positions as required. The ESW system also provides emergency makeup to the spent fuel pool and CCW system and is the backup water supply to the Auxiliary Feedwater system. Each ESW train also services a non-safety related air compressor and associated aftercooler via non-safety related, non-seismic lines downstream of safety-related, air-operated isolation valves (EFHV0043 in

                    'P\ train and EFHV0044 in 'B' train). In the event of a hazard that could compromise the integrity of the non-safety, non-seismic piping to the air compressors and aftercoolers, such as a seismically induced pipe break or crack or a non-mechanistic malfunction in the moderate energy piping, isolation of the non-safety piping would occur by one of several means, depending on the size of the leak or break and the availability of offsite power. The non-safety related piping would be automatically isolated by signals from the ESW differential pressure channels (EFPDT0043 and EFPDSH0043 in 'A' train; EFPDT0044 and EFPDSH0044 in 'B' train) which send automatic isolation signals in response to a high differential pressure (high flow) between the safety-related ESW piping and the non-safety related piping associated with the air compressors and aftercoolers, or by operator action for smaller leaks prior to impacting the available UHS inventory, or by a loss of air supply to the isolation valve solenoids.

(continued) CALLAWAY PLANT 8 3.7.8-1 Revision 10

ESW B 3.7.8 BASES BACKGROUND However, hazard event mitigation functions do not satisfy any of the 10 {continued) CFR 50.36{c){2){ii) criteria for inclusion within the scope of the Technical Specifications. Functionality of the ESW differential pressure channels is, therefore, addressed in Reference 5. Additional information about the design and operation of the ESW system, along with a list of the components served, is presented in the FSAR, Section 9.2.1.2 {Ref. 1). The principal safety-related function of the ESW system is the removal of decay heat from the reactor via the CCW system and removal of containment heat loads via the containment coolers. APPLICABLE The design basis of the ESW system is for one ESW train, in conjunction SAFETY with the CCW system and a 100% capacity containment cooling system, ANALYSES to remove accident generated and core decay heat following a design basis LOCA as discussed in the FSAR, Section 6.2 (Ref. 2). This prevents the containment sump fluid from increasing in temperature during the recirculation phase following a LOCA and provides for a gradual reduction in the temperature of this fluid as it is supplied to the Reactor Coolant system by the ECCS pumps. The ESW system is designed to perform its function with a single failure of any active component, assuming the loss of offsite power. LCO Two ESW system trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to remove post-accident heat loads, assuming that the worst case single active failure occurs coincident with the loss of offsite power. {continued) CALLAWAY PLANT 8 3.7.8-2 Revision 10

ESW B 3.7.8 BASES LCO An ESW system train is considered OPERABLE during MODES 1, 2, 3, (continued) and 4 when:

a. The pump is OPERABLE;

b. The required piping, valves, and instrumentation and controls needed to perform safety-related functions necessary to mitigate DBAs and transients analyzed in FSAR Chapters 6 and 15 are OPERABLE (Ref. 4); and

c. The pump room supply fan is OPERABLE.

The prelube storage tanks, TEF01A and TEF01 B, are not required for OPERABILITY of the ESW pumps. The ESW pumps will start and run satisfactorily with dry bearings in an emergency should prelube water supply from the prelube storage tank not be present. Once the pump starts, lube water will be supplied by the pump. The isolation of ESW flow to the Service Air (KA) system air compressors may render them non-functional, but does not affect the OPERABILITY of the ESW system. Further, non-functionality of the ESW differential pressure channel in either (or both) ESW train (driven by transmitters EFPDT0043 and EFPDT0044) does not affect OPERABILITY of the ESW system. APPLICABILITY In MODES 1, 2, 3, and 4, the ESW system is a standby system that is required to support the OPERABILITY of the equipment serviced by the ESW system and required to be OPERABLE in these MODES. In MODES 5 and 6, requirements for the ESW system are determined by the systems it supports. ACTIONS If one ESW train is inoperable, action must be taken to restore OPERABLE status within 72 hours. In this Condition, the remaining OPERABLE ESW system train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE ESW system train could result in loss of ESW function. Required Action A.1 is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, "AC (continued) CALLAWAY PLANT B 3.7.8-3 Revision 10

ESW B 3.7.8 BASES ACTIONS A.1 (continued) Sources- Operating," shall be entered if an inoperable ESW train results in an inoperable emergency diesel generator. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," shall be entered if an inoperable ESW system train results in an inoperable residual heat removal train. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. The 72 hour Completion Time is reasonable based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period. The Completion Time is modified by a Note that allows a one-time Completion Time of 14 days to support the planned replacement of ESW 'B' train piping prior to April30, 2009. B.1 and B.2 If the ESW system train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. The allowed Completion 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 systems. SURVEILLANCE SR 3.7.8.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of ESW flow to individual components or systems may render those components inoperable or non-functional, but does not affect the OPERABILITY of the ESWsystem. Verifying the correct alignment for manual, power operated, and automatic valves in the ESW system flow path servicing safety-related components provides assurance that the proper flow paths exist for ESW system operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve will (continued) CALLAWAY PLANT B 3.7.8-4 Revision 10

ESW 8 3.7.8 BASES SURVEILLANCE SR 3.7.8.1 (continued) REQUIREMENTS automatically reposition within the proper stroke time. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown (which may include the use of local or remote indicators), that those valves capable of being mispositioned are in the correct position. When either of the series isolation valves in the supply or return lines to/from the normal service water system is closed with power removed, this Surveillance no longer applies to the affected isolation valves since the valves would no longer be in the flow path. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves and relief valves. Additionally, vent and drain valves are not within the scope of this SR. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. SR 3.7.8.2 SR 3.7.8.3 This SR verifies proper automatic operation of the ESW system pumps on an actual or simulated actuation signal. These actuation signals include SIS, Low AFW Suction Pressure coincident with an AFAS, and Loss of Power. The ESW system is a standby emergency system that cannot be fully actuated as part of normal testing during normal operation. The ESW pump start on low AFW Suction Pressure Surveillance is performed under the conditions that apply during a unit outage and has the potential for (continued) CALLAWAY PLANT 8 3.7.8-5 Revision 10

INSERT2 This SR verifies proper automatic operation of the ESW system valves servicing safety-related components or isolating the non-safety related components on an actual or simulated actuation signal. These actuation signals include Loss of Power, SIS, Low AFW Suction Pressure coincident with an AF AS, and the temperature signals that automatically close the UHS cooling tower bypass valves (EFHV0065 and EFHV0066). The last set of automatic actuation signals includes ESW return temperature (UHS inlet) signals from EFTSL0067A (EFTSL0068A), and ESW pump discharge (ESW supply) temperature signals from EFTSL0061 (EFTSL0062) enabled by hand switches EFHS0067 (EFHS0068), to close UHS cooling tower bypass valves EFHV0065 (EFHV0066) which direct ESW return flow over the UHS cooling tower fill. The ESW system is a standby emergency system that cannot be fully actuated as part of normal testing. When either of the series isolation valves in the supply or return lines to/from the normal service water system is closed with power removed, this Surveillance no longer applies to the affected isolation valves since the valves would no longer be in the flow path. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

ESW 8 3.7.8 BASES SURVEILLANCE SR 3.7.8.3 (continued) REQUIREMENTS an unplanned transient if the Surveillance were performed with the reactor at power. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. REFERENCES 1. FSAR, Section 9.2.1.2, Essential Service Water System.

2. FSAR, Section 6.2, Containment Systems.

3. FSAR, Section 5.4.7, Residual Heat Removal System.

4. TSTF-GG-05-01, "Writer's Guide for Plant-Specific Improved Technical Specifications," June 2005, Sections 4.1.3.b and 4.1.6.e.

5. FSAR, Section 16.7.6, ESW System.

CALLAWAY PLANT 8 3.7.8-6 Revision 10

UHS B 3.7.9 B 3. 7 PLANT SYSTEMS B 3.7.9 Ultimate Heat Sink (UHS) BASES BACKGROUND The U S provides a heat sink for processing and operating heat from safety related components during a transient or accident, as well as durin normal operation. This is done by utilizing the Essential Service Wate ~stem.fES'J~. The two principal functions of the UHS are the dissipation of residual heat after reactor shutdown, and dissipation of residual h~at aft~r1 an accideat. ~ enahle..r --17\e. ~wSY..s ~ I The UHS consists of a 4-cell seismic C tegory I mechanical draft cooling'fa o/IJ. tower and a seismic Category I source f makeup water (retention pond) for the tower. Heat from the ESW sys m as discussed in FSAR Section 9.2.5, is rejected to the UHS t permit a safe shutdown of the plant following an accident. The UH

approximately 15,000 gpm of cooling wate
to remove the heat loads of the co ponents listed in the Standard Plant FSAR Section 9.2.5. fer-- +r-~ in The mechanical draft cooling tower is a safety related, seismic Category I structure sized with 100 percent redundancy to provide heat dissipation for safe shutdown following an accident. The cooling tower is protected from horizontal and vertical tornad~m* 'les. The supply headers and spray pipes for each train of the E separated by interior walls. A pass1

                                                              'I'!    em from the Power Block are 1lure of the spray pipe for one train will not affect the opposite train.

The approximate dimensions of the UHS retention pond are 330 by 680 feet and the sides slopes are 3 horizontal to 1 vertical. The side slopes are protected by riprap from the surrounding grade elevation. Two submerged, reinforced concrete discharge structures discharge water into the pond from the mechanical draft cooling tower. A reinforced concrete outlet structure is provided for outflow from the pond. Additional information on the design and operation of the system, along with a list of components served, can be found in Reference 1. APPLICABLE The UHS is sized to dissipate the maximum heat loads listed in Standard SAFETY Plant FSAR Section 9.2.5,wl:lile jiF9'JieiA6 e eelet ooete1 te1 11p01 ett11 e less ANALYSES ti'l&A er 9Elti81 ~s ego~. It is assumed that the design basis accident occurs at the time that the most adverse meteorological conditions for tower (continued) CALLAWAY PLANT B 3.7.9-1 Revision 10

UHS B 3.7.9 BASES APPLICABLE ormance prevail. UHS pond temperature r~ched under these SAFETY co ditions will not exce 92.3°F. 'XNSclll IS ANALYSES 1/,.o (continued) minimum required I vel is ~eet from the bottom of the UHS acre-feet). acre-feet is needed to provide a 30 day supply of cooling and makeup water post LOCA u

7 .. :3 evaporation condition for this period. The al pond water volume remaining after 30 days is ere-feet. The useable portion of this volume is acre-feet, which is the volume of water above the minimum lev I needed to maintain the NPSH for the ESW pumps. The remaining olume provides a margin that is ~~....t~lltftrr-t;tm" of the total water volu requirement. The UHS was analyz for the design basis LOCA in ccordance with NRC Regulatory Gui e 1.27 (Ref. 2). +. 17 /:1.%

The UHS satisfies Criterion 3 of 10 CFR 50.36 (c)(2)(ii). LCO The UHS is required to be OPERABLE and is considered OPERABLE if it contains a sufficient volume of water at or below the maximum fC1 IF temperature that would allow the ESW system to operate ~ at least 30 days following the design basis LOCA without the los of net positive suction head (NPSH), and without exceeding the maxi m design temperature of the equipment served by the ESW sy t m. To meet this condition, the UHS temperature should not exceed should not fall below~ feet from the bottom of the UHS

                                            ,,,0 mean sea level) during rmal unit operation.

(uft and the level {~A. 0 D~ In addition, two UHS cooling tower trains (2 cells per train) are required to dissipate the heat contained in the ESW system. An inoperable UHS cooling tower electrical room supply fan renders its UHS cooling tower train inoperable. The UHS is not inoperable if a UHS sump heater is inoperable unless ice formation blocks the return line to the UHS pond. APPLICABILITY In MODES 1, 2, 3, and 4, the UHS is required to support the OPERABILITY of the ESW system and required to be OPERABLE in these MODES. ACTIONS If one cooling tower train is inoperable, action must be taken to restore the inoperable cooling tower train to OPERABLE status within 72 hours. (continued) CALLAWAY PLANT B 3.7.9-2 Revision 10

INSERT B The design-basis maximum ESW supply temperature from the UHS retention pond is 95°F. That value was used in the design of the UHS cooling tower cells (FSAR Site Addendum Table 9.2-4 of Reference 1) and is the assumed ESW inlet temperature to all loads served by ESW except for the electrical penetration room coolers. However, the maximum ESW supply and UHS retention pond temperature of92.3°F establishes the upper acceptance criterion in the minimum heat transfer and maximum evaporation cases in the analysis supporting the 30-day UHS inventory requirement per RG 1.27 (Ref. 2). In addition, an ESW inlet temperature of92.3°F is also assumed in the analysis of the electrical penetration room temperatures (room coolers supplied by ESW). The 92.3 °F value is the maximum temperature allowed in these analyses to support UHS OPERABILITY assuming an initial maximum temperature of 89°F.

UHS B 3.7.9 BASES ACTIONS A.1 (continued) The 72 hour Completion Time is reasonable based on the low probability of an accident ociurring du.sl_ng the 72 hours that one cooling tower trair'\ \

                                  '/'       '/_'                       1'             ( c..lo.!"&

is ino1rable, the number of availabt systemt and !lie time :tuired to lA f

reasonably complete the Required Action. 8.1 and 8.2 If the cooling tower train cannot be restored to OPERABLE status within the associated Completion Time, or if the UHS is inoperable for reasons other than Condition A, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 5 within 36 hours. The allowed Completion 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 systems. SURVEILLANCE SR 3.7.9.1 REQUIREMENTS This SR verifies that adequate long term (30 day) cooling can be maintained. The specified level also ensures that sufficient NPSH is available to operate the ESW system pumps. This SR verifies that the UHS water level is ~ ~feet from the bottom of the UHS or ~ft mean sea level. 'C //, . O C f'31-,() The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. SR 3.7.9.2 This SR verifies that the UHS is available to cool the ESW System to at least its maximum design temperature with the maximum accident or normal design heat loads for 30 days following a Design Basis Accident. This SR verifies that the average water temperature of the UHS is :$ ~

                                                                                       ?e/'F:

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. (continued) CALLAWAY PLANT B 3.7.9-3 Revision 10

UHS 8 3.7.9 BASES SURVEILLANCE SR 3.7.9.3 REQUIREMENTS (continued) Operating each cooling tower fan in both the fast and slow speeds for

                  ~ 15 minutes ensures that all fans are OPERABLE and that all associated controls are functioning properly. It also ensures that fan or motor failure, can be detected for corrective action.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program. REFERENCES 1. FSAR, ection 9.2.5, Ultimate Heat Sink.

2. Regu tory Guide 1.27, Ultimate Heat Sink.

CALLAWAY PLANT 8 3.7.9-4 Revision 10

INSERT 3 SURVEILLANCE SR 3.7.9.4 REQUIREMENTS This SR verifies that each cooling tower fan starts and operates in slow speed on an actual or simulated actuation signal from its train-associated high ESW return (UHS inlet) temperature signal (EFTSH0067A and EFTSH0068A) and automatically shifts to fast speed on an actual or simulated signal from its train-associated high-high ESW return (UHS inlet) temperature signal (EFTSHH0067A and EFTSHH0068A). During the course of post-LOCA recovery, the cooling tower fans are manually transferred from a control scheme based on ESW return temperature to one based on ESW pump discharge temperature via hand switches EFHS0067 and EFHS0068. This SR also verifies that each cooling tower fan starts and operates in slow speed on an actual or simulated actuation signal from its train-associated high ESW pump discharge temperature signal (EFTSH0061 and EFTSH0062) and automatically shifts to fast speed on an actual or simulated signal from its train-associated high-high ESW pump discharge temperature signal (EFTSHH0061 and EFTSHH0062A). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. REFERENCES 1. FSAR Standard Plant and Site Addendum, Section 9.2.5, Ultimate Heat Sink.

2. Regulatory Guide 1.27, Ultimate Heat Sink.

CALLAWAY PLANT 8 3.7.9-4 Revision

ATTACHMENT 3 RETYPED TECHNICAL SPECIFICATION PAGES

UHS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of UHS is~ 834.0 ft mean sea level. In accordance with the Surveillance Frequency Control Program SR 3.7.9.2 Verify average water temperature of UHS is::::; 89°F. In accordance with the Surveillance Frequency Control Program SR 3.7.9.3 Operate each cooling tower fan for~ 15 minutes in In accordance both the fast and slow speed. with the Surveillance Frequency Control Program SR 3.7.9.4 Verify each cooling tower fan starts automatically on In accordance an actual or simulated actuation signal. with the Surveillance Frequency Control Program CALLAWAY PLANT 3.7-27 Amendment No.###

ATTACHMENT 4 PROPOSED FSAR CHANGES

FSAR STANDARD PLANT CALLAWAY- SP 5.4.7 RESIDUAL HEAT REMOVAL SYSTEM 5.4.7.1 Design Bases The residual heat removal system (RHRS) functions to remove heat from the RCS when RCS pressure and temperature are below approximately 400 psig and 350°F, respectively. Heat is transferred from the RHRS to the component cooling water system. Portions of the RHRS also serve as portions of the ECCS during the injection and recirculation phases of a LOCA (see Section 6.3). The RHRS also is used to transfer refueling water between the refueling cavity and the refueling water storage tank at the beginning and end of the refueling operations. The RHRS is designed to be isolated from the RCS whenever the RCS pressure exceeds the RHRS design pressure. 5.4.7.2 Design Description 5.4.7.2.1 Functional Design RHRS design parameters are listed in able 5.4-7. Nuclear plants employing the same RHRS design as the SNUPPS units a e given in Section 1.3. During normal approaches to cold sh tdown, the RHRS is placed in operation /4-, q approximately 4 hours after reactor sh tdown when the temperature and press e of the RCS are below approximately 350°F nd 400 psig, respectively. Assuming th t two heat exchangers and two pumps are in se ice and that each heat exchanger is s pplied with component cooling water at design flo and temperature, the RHRS is desi ed to reduce the temperature of the reactor oolant from 350°F to 140°F within . hours (See Figure 5.4-9). The time required under these conditions, to reduce reactor coolant temperature from 350°F to 212°F is . hours based on a 50°F/hr cooldown rate. The heat load handled by the RHRS during the cooldown transient includes residual and decay heat from the core and reactor coolant puntJrheat. The design heat load is based on the decay heat fraction that exists at 20 hour~following reactor shutdown from an extended run at full power. Tl'le eJiHerer~ee be~oeer~ tl=lo RCS teffipere~ture Bt 20 ~'lours prigr te cp1 ati11g (1 a49°F) a Rei tl=le RCS teffipeFBtttre at 20 hoblr:s after: tl=le RSG 2 - r+loditieatieR (142.7 F) is i11sig11ifica1,t. Tl"'erefore,"e design heat load used here and in Section 9.2.5 (UHS) will ee-j>ased o,.n the 29 l'lettr eeelelewfl tiffie afld-decay heat generationA.of 78.9 X 106 Btu/hr.A. IS ri.ffe_ l .=eNS~ /) Assuming that only one heat exchanger and pump are in service and that the heat exchanger is supplied with component cooling water at design flow and temperature, the RHRS is capable of reducing the temperature of the reactor coolant from 350°F at-46-/;2. hours after shutdown to 200°F at~ours after shutdown (See Figure 5.4-10). The time required under these condition to reduce reactor coolant temperature from 350°F to 212°F is approximately..:~frhours. 3o-t,

                       /fJ*__;

5.4-26 Rev. OL-18 12/10

INSERTD Based on the MODE 4 ECCS standby alignment requirements of Technical Specification 3.5.3 imposed on one RHR train, as well as procedural requirements related to preventing void formation associated with exceeding saturation conditions in the RHR suction lines from the RWST, the assumption of a two-train cooldown starting at the RHR cut-in conditions does not reflect plant operating practice.

CALLAWAY- SP The RHRS is isolated from the RCS on the suction side by two motor-operated valves in series on each suction line. Each motor-operated valve is interlocked to prevent its opening if RCS pressure is greater than 360 psig. A control room alarm will actuate if an RHR suction isolation valve is not fully closed and RCS pressure is greater than the design pressures for RHR system operation. The RHRS is isolated from the RCS on the discharge side by two check valves in each return line. Also provided on the discharge side is a normally open, motor-operated valve downstream of each RHRS heat exchanger. (These check valves and motor-operated valves are not considered part of the RHRS. They are shown as part of the ECCS, see Figure 6.3-1.) Each inlet line to the RHRS is equipped with a pressure relief valve designed to relieve the combined flow of all the charging pumps at the relief valve set pressure. These relief valves also protect the system from inadvertent overpressurization during plant cooldown or startup and provide LTOP for the RCS during low temperature water solid operation. Each discharge line from the RHRS to the RCS is equipped with a pressure relief valve designed to relieve the maximum possible backleakage through the valves isolating the RHRS from the RCS. The RHRS is provided for a single nuclear power unit, and is not shared among nuclear power units. The RHRS is designed to be fully operable from the control room for normal operation. Manual operations required of the operator are: opening the suction isolation valves, positioning the flow control valves downstream of the RHRS heat exchangers, and starting the residual heat removal pumps. By nature of its redundant two-train design, the RHRS is designed to accept all major component single failures with the only effect being an extension in the required cooldown time. For two low probability electrical system single failures, i.e., failure in the suction isolation valve interlock circuitry or diesel generator failure in conjunction with loss of offsite power, operator action outside the control room is required to open the suction isolation valves. Manual actions are discussed in further detail in Sections 5.4.7.2.7 and 5.4.7.2.8. Spurious operation of a single motor-operated valve can be accepted without loss of function, as a result of the redundant two-train design. Missile protection, protection against dynamic effects associated with the postulated rupture of piping, and seismic design are discussed in Sections 3.5, 3.6, and 3.7(8), and

3. 7(N) respectively.

5.4.7.2.2 Piping and Instrumentation Diagrams The RHRS, as shown in Figures 5.4-7 (piping and instrumentation diagram) and 5.4-8 (process flow diagram), consists of two residual heat exchangers, two residual heat removal pumps, and the associated piping, valves, and instrumentation necessary for operational control. The inlet lines to the RHRS are connected to the hot legs of two reactor coolant loops, while the return lines are connected to the cold leg of each of the reactor coolant loops. These return lines are also the ECCS low head injection lines 5.4-27 Rev. OL-18 12/10

CALLAWAY- SP use of two separate RHR trains assures that cooling capacity is only partially lost should one pump become inoperative. The RHR pumps are protected from overheating and loss of discharge flow by miniflow bypass lines. A valve located in each miniflow line is regulated by a signal from the flow indicating switch located in each pump discharge header. The control valves open when the RHR pump discharge flow is less than approximately 816 gpm at 300°F (783 gpm at 68°F) and close when the flow exceeds approximately 1650 gpm at 300°F (1582 gpm at 68°F). A pressure sensor in each pump discharge header provides a signal for an indicator in the control room. A high pressure alarm is also actuated by the pressure sensor. The two pumps are vertical, centrifugal units with mechanical seals on the shafts. All pump surfaces in contact with reactor coolant are austenitic stainless steel or equivalent corrosion resistant material. The RHR pumps also function as the low head safety injection pumps in the ECCS (see Section 6.3 for further information and for the residual heat removal pump performance curves). Residual Heat Exchangers Two residual heat exchangers are installed in the system. The heat exchanger design is based on heat load and temperature differences between reactor coolant and component cooling water existing 20 hours after reactor shutdown when the temperature difference between the two systems is small. RefeF elso to Seetio11 5.4.7.2.1 for a .....QisetJssiefl efl tl=le effects ef r;>lant l:JflFatiAg. The installation of two heat exchangers in separate and independent residual heat removal trains assures that the heat removal capacity of the system is only partially lost if one train becomes inoperative. The residual heat exchangers are of the shell and U-tube type. Reactor coolant circulates through the tubes, while component cooling water circulates through the shell. The tubes are welded to the tube sheet to prevent leakage of reactor coolant. The residual heat exchangers also function as part of the ECCS (see Section 6.3). Residual Heat Removal System Valves Valves that perform a modulating function are equipped with two sets of packings and an intermediate leakoff connection that discharges to the drain header. 5.4-30 Rev. OL-18 12/10

CALLAWAY-SP '1/o ~ the "prevent-open" interlock through corrective action at the solid state protection system cabinet or at the individual affected motor control centers. The other type of failure which can prevent opening the residual heat removal suction isolation valves from the control room is a failure of an electrical power train. Such a failure is extremely unlikely to occur during the few minutes out of a year's operating time during which it can have any consequence. If such an unlikely event should occur, several alternatives are available. The most realistic approach would be to obtain restoration of offsite power, which can be expected to occur in less than 1/2 hour. Other alternatives are to restore the emergency diesel generator to operation or to bring in an alternative power source. The only impact of either of the above types of failures is some delay in initiating residual heat removal operation, while action is taken to open the residual heat removal suction isolation valves. This delay has no adverse safety impact because of the capability of the auxiliary feedwater system and steam generator power-operated relief valves to continue to remove residual heat, and, in fact, to continue plant cooldown. A failure mode and effects analysis of the RHRS for normal plant cooldown is provided as Table 5.4-9. 5.4.7.2.8 Manual Actions The RHRS is designed to be fully operable from the control room for normal operation. Manual operations required of the operator are: opening the suction isolation valves, positioning the flow control valves downstream of the RHRS heat exchangers, and starting the residual heat removal pumps. Manual actions required outside the control room, under conditions of single failure, are discussed in Section 5.4.7.2.7. 5.4.7.3 Performance Evaluation The performance of the RHRS in reducing reactor coolant temperature is evaluated through the use of heat balance calculations on the RCS, and the component cooling water system at stepwise intervals following the initiation of RHR operation. Heat removal through the RHR and component cooling water heat exchangers is calculated at each interval by use of standard water-to-water heat exchanger performance correlations. The resultant fluid temperatures for the RHRS and component cooling water system are calculated and used as input to the next interval's heat balance calculation. Assumptions utilized in the series of the heat balance calculations describing plant RHR cooldown are as follows: 5.4-36 Rev. OL-18 12/10

CALLAWAY- SP A :;l.

a. RHR operation is initiated 4 hours after reactor shutdown~ hou;s after shutdown for single train cooldown).as f)OF 'IICAP 10140, Callevve~

            --=Replaso~oAt 8tee11, Ge1,e1 etor Pre~raffi ~~888 EA~iAeeriA~ Report.

b. RHR operation begins at a reactor coolant temperature of 350°F.

c. Thermal equilibrium is maintained throughout the RCS during the cooldown.

d. Component cooling water temperature at the CCW heat exchanger outlet during cooldown is limited to a maximum of 120°F.

e. Expected cooldown rates of 50°F per hour are not exceeded.

Cooldown curves calculated using this method are provided for the case of all residual heat removal components operable (Figure 5.4-9) and for the case of a single train residual heat removal cooldown (Figure 5.4-1 0). 5.4.7.4 Preoperational Testing Preoperational testing of the RHRS is addressed in Chapter 14.0. 5.4.8 REACTOR WATER CLEANUP SYSTEM This section is not applicable to SNUPPS. 5.4.9 MAIN STEAM LINE AND FEED WATER PIPING Discussion pertaining to the main steam line and feedwater piping are contained in the following sections:

a. Main Steam Line Piping - Section 10.3.

b. Main Feedwater Piping - Section 10.4. 7.

c. Auxiliary Feedwater Piping - Section 10.4.9.

d. lnservice Inspection of a, b, and c- Section 6.6.

5.4.1 0 PRESSURIZER 5.4.1 0.1 Design Bases The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for control of pressure of the RCS during steady state operations and transients. 5.4-37 Rev. OL-18 12/10

CALLAWAY- SP TABLE 5.4-7 DESIGN BASES FOR RESIDUAL HEAT REMOVAL SYSTEM OPERATION Residual heat removal system startup, hours after reactor shutdown -4 3 Reactor coolant system initial pressure, psig -400 Reactor coolant system initial temperature, oF -350 Component cooling water design temperature, oF 105 1 3 Cooldown time, hours after initiation of residual heat removal system operation -48.~ 3 /4-,Cj Reactor coolant system temperature at end of cooldown,°F 140 3 Decay heat generation at 20 hours after reactor shutdown, Btu/hr 78.9 X 106 2 (1) Maximum temperature at the CCW heat exchanger outlet at~ hours after plant shutdown. (2) Refer to Section 5.4.7.2.1. I?, '1 (3) (200°F) within 36 hours after shutdown (actual value is L Refer to Section 5.4.7.2.1 and Figure 5.4-10 for single train cooldown which will take the plant to cold shutdown hours after shutdown).

                                                                 ~.6 Rev. OL-15 5/06

CALLAWAY- SP TABLE 5.4-8 RESIDUAL HEAT REMOVAL SYSTEM COMPONENT DATA Residual Heat Removal Pumps Number 2 Design pressure, psig 600 Design temperature, oF 400 Design flow, gpm 3,800 Design head, ft 350 NPSH required at 3,800 gpm, ft 17 Power, hp 500 Residual Heat Exchangers Number 2 Design heat removal capacity, Btu/hr 39.1 X 106 Estimated UA, Btu/hr FLMTD 2.3 X 106 Tube Side Shell Side Design pressure, psig 600 150 Design temperature, F 400 200 Design flow, lb/hr 1.9 X 106 3.8 X 106 Inlet temperature, F* 140 105 Outlet temperature, F* 120 116 Material Austenitic stainless Carbon steel steel Fluid Reactor coolant Component cooling water RHR Isolation Valve Encapsulation Tank (TEJ01A & B) Manufacturer Richmond Eng. Quantity 2 Height ft-in. 12-6 Diameter ft-in. 5-6 Design Pressure, psig 75 Design Temperature, oF 400 Material Austenitic stainless steel Codes and Standards ASME Section Ill, Class 2 Seismic Category I

Maximum temperatures at~hours after plant shutdown.

                                /~,'1 Rev. OL-15 5/06

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 ~        I i A.

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      ,~I 100 4                              12                   \. 16 20        24      REV. OL-15 Time IIIIer Read or Shutdo                       5/06 CALLAWAY PLANT FIGURE 5.4-9 te,lace   kf(/-A  1'/141 lf;IAre-                         NORMAL RESIDUAL HEAT REMOVAL COOLDOWN U.re ..J~~  -/-r-1-!e 6/(Jck.

Figure 5.4-9 Normal Residual Heat Removal Cooldown ......_. 350 LL. 0

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~ 150 100+-----~----~------------~------~T---.-----------~------------.-----------~ 4 10 16 28 34 40 REV. OL-15 5/06 CALLAWAY PLANT FIGURE 5.4-10

                 ~e_~/4c..e w/../-J., Ae-W -h;;'-f'"TZ -             SINGLE RESIDUAL HEAT REMOVAL Use    J'~ frlfe it~                               TRAIN COOLDOWN

Figure 5.4-10 Single Residual Heat Removal Train Cool down ~ 350 L&. 0

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CALLAWAY- SP TABLE 5.4A-1 DESIGN COMPARISON TO REGULATORY POSITIONS OF REGULATORY GUIDE 1.139 REV 1, DRAFT 2 DATED FEBRUARY 25, 1980 TITLED "GUIDANCE FOR RESIDUAL HEAT REMOVAL TO ACHIEVE AND MAINTAIN COLD SHUTDOWN: A complete discussion of the SNUPPS plant cold shutdown capability is provided in Appendix 5.4A. REGULATORY POSITION UNION ELECTRIC

1. FUNCTIONAL The method yti!ized to take the reactor from normal operating conditions to cold shutdown should satisfy the functional guidance presented below. *

a. The design should be such that the reactor can be taken from normal operating 1a. The reactor coolant system, in conjunction with several supporting systems, can conditions to cold shutdown using only safetv-related systems that satisfy General be brought to a cold shutdown condition following any given hazard (GDCs 2, 3, Design Criteria 1 through 5. and 4) using safety-related systems (design in compliance with GDC 1).

b. These safety-related systems should have suitable redundancy in components 1b. Complies. Section 3.1.2 provides the single failure criteria thatis used, including and features and suitable interconnection, leak detection and containment, and the bases for operator action outside the control room. Table 5.4A-3 provides a isolation capabilities to ensure that, for onsite electric power system operation safety related cold shutdown (CSD) FMEA.

(assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available), the system safety function can be accomplished assuming a single failure. In demonstrating that the ~ can be ytilized to perform its function assuming a single failure, limited operator action outside the control room would be acceptable if suitably justified. Necessary operator actjons to majntajn hot shu1down or proceed from that plant condition to cold shutdown should be planned no sooner than one hour from the time when shy1down is commenced. This limited ooerator action should not result in an exposure beyond the allowed limits assuming high radio- activitv in the reactor coolant or containment building environment.

c. The method should be capable of bringing the reactor to a .1121 shutdown condition, 1c. Complies. See. ~e.e--/fiJn S: f;7,..~/,

where RHR cooling may be initiated, within approximately 36 hours following shutdown with only offsite power or onsite power available, assuming the most limiting single failure.

   .!1. Instrumentation and controls including protective measures and interlocks associatd   1d. Except for the boric acid transfer system controls and the pressurizer heaters, the with the safety-related systems reqyjred to achjeve or majntajn cold shutdown             instrumentation and controls are designed in accordance with applicable should meet the requirements of IEEE Standards 279-1971 323 384 and 344                    Regulatory Guides and IEEE standards. The highly reliable design of the and the guidance provided in Regulatorv Guides 1.89 1. 75 and 1.100                        pressurizer heaters and the BAT system (both of which are capable of being manually loaded on the diesels) are described in Sections 5.4, 7.4, 8.3, and 9.3.4.
   ~     The safety-related systems should be classjfied as Seismjc Category I and meet        1e. Except as discussed in 1d, all components and systems comply.

the guidance provided in Regulatorv Guide 1.29. Rev. OL-19 5/12

CALLAWAY- SP LIST OF TABLES (Continued) Number Title ~;/v.re /h,de.r c,,.J £f.'+ec-/-s 9.2-5 Essential Service Water SystemASi~~le;:cQceti oe Feil~1 eVAn alysis attl tillS Coo Irf)!J. -rdtv~~- 9.2-6 Essential Service Water Sys,lndicating and 51\larm Devices 9.2-7 Component Cooling Water System Requirements Normal Operation 9.2-8 Component Cooling Water System Requirements Shutdown (@ 4 Hours) Operations 9.2-9 Component Cooling Water System Requirements Post-LOCA 9.2-10 Component Cooling Water System Component Data 9.2-11 Water Chemistry Specifications for Component Cooling Water System and Closed Cooling Water System 9.2-12 Component Cooling Water System Single Active Failure Analysis 9.2-13 Component Cooling Water System, Indicating and Alarm Devices 9.2-14 Major Components supplied With Water From Demineralized Water Storage and Transfer System 9.2-15 Plant Water Chemistry Specifications 9.2-16 ESW/UHS Cooling Water Chemistry Analysis 9.2-17 Heat Loads from Station Auxiliaries Post LOCA 9.2-18 ' Heat Loads from Station Auxiliaries Normal Shutdown Using UHS Cooldown to Cold Shutdown 9.2-19 Components and Systems Served by Condensate Storage and Transfer System 9.2-20 Summary of Reactor Makeup Water Req~irements 9.2-21 Components Cooled by the Closed Cooling Water System 9.2-22 Condensate Storage and Transfer System Component Data 9.3-1 Component Description Compressed Air System 9.0-xiii Rev. OL-14 12/04

CALLAWAY- SP LIST OF FIGURES (Continued) Number Title 9.1A-25 Plot of Gap Between Racks 13 and 14 at Spring No. 496 in Full SFP Model 9.1 A-26 Plot of Gap Between Racks 14 and 15 at Spring No. 504 in Full SFP Model 9.1A-27 Plot of Gap Between Racks 14 and the wall at Spring No. 501 in Full SFP Model 9.2-1 Service Water System (Sheets 1 & 2) 9.2-2 Essential Service Water System (Sheets 1, 2 & 3) 9.2-3 Component Cooling Water System (Sheets 1, 2 & 3) 9.2-4 Demineralized Water Storage and Transfer System 9.2-5 Domestic Water System (Sheets 1 & 2) ->~ :INSEl<lllJC 9~~ ~::r~/(ES

  -8.2-B              ~eFAinal  l-loat Rejeetien Rate tg ' 'ltir.:Rat& H&at SiRk bOCA s.z-7             P4omiRel  l"te~reteeJ l-leet RejeeteeJ te Ultimete lleet Si"k LOCA 9.2-8             Heat Rejection Rate to Ultimate Heat Sink- Normal Shutdown 9.2-9             Integrated Heat Rejected to Ultimate Heat Sink - Normal Shutdown 9.2-10            Emergency Makeup Water Requirement- LOCA 9.2-11             Integrated Emergency Makeup Water Requirement 9.2-12             Condensate Storage and Transfer System 9.2-13             Reactor Makeup Water System 9.2-14             Closed Cooling Water System 9.0-xx                              Rev. OL-17 4/09

INSERT TOC 9.2 FIGURES Number 9.2-6(a) 'A' Train Heat Loads to UHS for LBLOCA (Max Evaporation Model with UHS Cooling Tower Bypass Valve Failure to Close) 9.2-6(b) 'B' Train Heat Loads to UHS for LBLOCA (Max Evaporation Model with UHS Cooling Tower Bypass Valve Failure to Close) 9.2-6(c) 'A' Train Heat Loads to UHS for LBLOCA (Min Heat Transfer Model with UHS Cooling Tower Bypass Valve Failure to Close) 9.2-6(d) 'B' Train Heat Loads to UHS for LBLOCA (Min Heat Transfer Model with UHS Cooling Tower Bypass Valve Failure to Close) 9.2-6(e) Total Heat Rejection Rate to UHS for LBLOCA (Max Evaporation Model with UHS Cooling Tower Bypass Valve Failure to Close) 9.2-6(f) Total Heat Rejection Rate to UHS for LBLOCA (Min Heat Transfer Model with UHS Cooling Tower Bypass Valve Failure to Close) 9.2-7(a) 30 Day Total Integrated Heat to UHS for LBLOCA (Min Heat Transfer Model with UHS Cooling Tower Bypass Valve Failure to Close) 9.2-7(b) 30 Day Total Integrated Heat to UHS for LBLOCA (Max Evaporation Model with UHS Cooling Tower Bypass Valve Failure to Close)

CALLAWAY- SP 9.2.1.1.2.2 Component Description The SWS piping and valves are carbon steel and are designed to meet the requirements of ANSI B31.1. Valves EAV0001, EAV0004, EAV0006, EAV0008, EAV0043, EAV0184, EAV0185, EAV0186 and EAV0187 are stainless steel and meet ANSI B31.1. The design ratings of the SWS supply lines are 200 psig and 150°F, and discharge lines to the circulating water system are 85 psig and 150°F. 9.2.1.1.2.3 System Operation Refer to the Site Addendum for operation of the pumps. Upon loss of offsite power or the receipt of an SIS, the system is isolated from the ESWS, as described in Section 9.2.1.2. 9.2.1.1.3 Safety Evaluation The SWS has no safety-related functions. 9.2.1.1.4 Test and Inspection Preoperational testing is described in Chapter 14.0. The performance and structural and leaktight integrity of all cooling water system components is demonstrated by continuous operation. 9.2.1.1.5 Instrumentation Applications The SWS instrumentation is designed to facilitate automatic operation, remote control, and continuous indication of system parameters. Local pressure and temperature indicators are provided at various components which are served by the SWS. Control valves are provided to control water flow where necessary. 9.2.1.2 Essential Service Water System T The ESWS removes heat from plant components which require cooling for safe shutdown of the reactor or following a DBA. The ESWS also provides emergency makeup to the spent fuel pool and component cooling water systems, and is the backup water supply to the auxiliary feedwater system. The ESWS consists of two redundant cooling water trains. 9.2.1.2.1 Design Bases 9.2.1.2.1.1 Safety Design Basis The ESWS is safety related, is required to function following a DBA, and is required to achieve and maintain the plant in a safe shutdown condition. 9.2-2 Rev. OL-19 5/12

CALLAWAY- SP SAFETY DESIGN BASIS ONE -The ESWS is protected from the effects of natural phenomena, such as earthquakes, tornadoes, hurricanes, floods, and external missiles (GDC-2). SAFETY DESIGN BASIS TWO - The ESWS is designed to remain functional after an SSE and to perform its intended function following the postulated hazards of fire, internal missile, or pipe break (GDC-3 and 4). SAFETY DESIGN BASIS THREE- Safety functions can be performed, assuming a single active component failure coincident with the loss of offsite power (GDC-44). Components of this system are not shared with other units (GDC-5). SAFETY DESIGN BASIS FOUR -The active components are capable of being tested during plant operation. Provisions are made to allow for inservice inspection of components at appropriate times specified in the ASME Boiler and Pressure Vessel Code, Section XI (GDC-45 and 46). SAFETY DESIGN BASIS FIVE -The ESWS is designed and fabricated to codes consistent with the quality group classification assigned by Regulatory Guide 1.26 and the seismic category assigned by Regulatory Guide 1.29. The power supply and control functions are in accordance with Regulatory Guide 1.32. SAFETY DESIGN BASIS SIX - The capability to isolate components or piping is provided so that the ESWS's safety function will not be compromised. This includes isolation of components to deal with leakage or malfunctions and to isolate non safety-related portions of the ESWS (GDC-44). SAFETY DESIGN BASIS SEVEN - The containment isolation valves in the system are selected, tested, and located in accordance with the requirements of GDC-54 and 56 and 10 CFR 50, Appendix J, Type C testing. SAFETY DESIGN BASIS EIGHT - The ESWS is designed to remove heat from components important to mitigating the consequences of a LOCA or MSLB and to transfer the heat to the ultimate heat sink (GDC-44). SAFETY DESIGN BASIS NINE- The ESWS operates in conjunction with the component cooling water and other reactor auxiliary components and the ultimate heat sink to provide a means to cool the reactor core and RCS to achieve and maintain a safe shutdown. SAFETY DESIGN BASIS TEN - The ESWS provides emergency makeup to the spent fuel pool and component cooling water systems, and is the backup water supply to the auxiliary feedwater system. 9.2-3 Rev. OL-19 5/12

CALLAWAY- SP 9.2.1.2.1.2 Power Generation Design Basis POWER GENERATION DESIGN BASIS ONE- The ESWS provides sufficient cooling water for removing heat from essential plant equipment over the full range of the normal reactor operation. 9.2.1.2.2 System Description 9.2.1.2.2.1 General Description ( 0 0 ,_. L::i.<l.l 'h a-I-M q;;, "31F SQ.e. v~+e, i} ~"""'~ n The ESWS is shown in Figure 9.2-2 and consi s of two separate 100-percent capacity<f f'h-. trains of piping, valves, and instrumentation. he essential service water pumps, which S_;c are discussed in Section 9.2.1 of the Site Ad endum, draw water from the ultimate heat -,,.:2, ,:2,.

                                                                                                                 /n .]1J sink at a maximum ae&i!t)l'l'"temperature of          and a minimum design temperature of 32°F. ~Rii ~o~EiFFibJI+l 1 1HS water temperatl':lre reael:leel eltte tea DBA 'Will Rot exceed "Q~.~or.- Each train of the ESWS serves through the associated train of safety-related components. Each train of the ESWS is interconnected with the SWS. Two motor-operated isolation valves are provided in each crosstie header where it connects to the SWS. In addition, cooling water flow is maintained following a DBA to a nonsafety-related air compressor and associated after-cooler in each train. The air compressor is automatically isolated on high flow (indicative of leakage) or it can be remote manually isolated.

The water chemistry of the ESWS fluid is given in Table 9.2-16. The metallic piping in the ESWS is designed with a corrosion tolerance to assure that there is no long-term degradation of the system. The components cooled by or supplied with makeup water from the ESWS and their respective heat loads and flow rates are given in Tables 9.2-2 through 9.2-4. The basis for the heat loads and flow rates is given in the referenced sections in Tables 9.2-2 through 9.2-4. The minimum required flow to components served by the ESW system is controlled by plant procedures. The minimum flow rate is based on the following parameters:

1) The maximum ESW supply temperature

2) The heat load of the component or room

3) The process fluid flow rate

4) The effective surface area of the heat exchanger

5) The design fouling factors as defined by the heat exchanger data sheet or as provided by the heat exchanger manufacturer.

The ESWS normally supplies water at a higher pressure than the cooled safety-related component. Therefore, if leakage occurs it will be into the system being cooled or, in the 9.2-4 Rev. OL-19 5/12

CALLAWAY- SP case of ESW piping and valves, in the floor drain system described in Section 9.3.3. Once a significant leak is found, an affected item will be isolated and repaired. 9.2.1.2.2.2 Component Description Codes and standards applicable to the ESWS are listed in Table 3.2-1. The ESWS is designed and constructed in accordance with the following quality group requirements: Containment penetrations are quality group B, the separate and redundant cooling loops for safety-related equipment are quality group C, and lines to other nonessential equipment are quality group D. The quality group 8 and C portions are seismic Category I. ESSENTIAL SERVICE WATER PUMPS -The two essential service water pumps each have a capacity of 100 percent of the flowrate required during normal operation. These designs exceed the required accident condition flowrate. Pumps are sized to include an additional wear margin on the flow at the design head to accommodate normal degradation of performance due to impeller wear. The ESW pumps, supporting systems, NPSH available, and flood protection are described in Section 9.2.1 of the Site Addendum. AUXILIARY HEAT EXCHANGERS- Tables 9.2-2 through 9.2-4 list the various components in the ESWS and their nominal heat loads and flow requirements. In general, essential service water flows through the tube side, and the cooled fluid flows through the shell side. Further description of these items is included in the referenced sections. PIPING AND VALVES- Piping within the standard power block to and from the ultimate heat sink is carbon steel, stainless steel, or polyethylene. The maximum design condition for supply water is 200 psig and 100°F, and the maximum design condition for the return line is 200 psig and 200°F. Certain piping segments have lower design pressures and temperatures based on maximum calculated operating conditions for these segments. Two entirely separate redundant lines are provided and designed to ASME Section Ill, Class 3, except for containment penetrations which are designed to ASME Section Ill, Class 2. Nonsafety-related portions of the system are designed to ANSI 831.1. For the components located inside the containment, supply and return lines are provided with containment isolation valves, as described in Section 6.2.4. Power-operated valves are provided to permit isolation of nonsafety-related or nonessential service following a DBA. For a description of the yard piping outside of the standard power block, see Section 9.2.1 of the Site Addendum. 9.2-5 Rev. OL-19 5/12

CALLAWAY- SP 9.2.1.2.2.3 System Operation POWER GENERATION OPERATION - During normal plant operations, the ESW within the standard power block receives water from the SWS and supplies water to the safety-related components and air compressors. After cooling the equipment, the heated water is returned to the SWS. Manual bypass valves are provided around the motor operated valves on the ESW return line from the component cooling water heat exchangers. During normal operation, these valves are adjusted for proper flow for safety functions and locked into position, and the motor operated valves remain open. Motor-operated bypass isolation valves are also provided in outlet lines from the containment air coolers outside the containment. During normal plant operation, these bypass isolation valves remain open, and the main outlet isolation valves outside the containment remain closed. The ESWS does not directly interface with radioactive systems. The only credible in leakage path of potentially contaminated water into the ESW system is contamination from the CCW heat exchanger if simultaneous leaks occurred between CCW and interfacing systems and in the CCW/ESW Heat Exchangers. The other components served by ESW system are room coolers, the diesel generator coolers and the Control Room and Class~E r frigerant coolers. The CCW system is a clean system which cools otentially radioact e systems and components. This system has radioactivity monitors EG-RE-09 and EG-RE-1 0 to detect, indicate and alarm any in leakage into this ystem. To detect in leakage into the SW/ESW system periodic samples of the SW/ESW system will be analy~z. nalysis oiJS~ESW fa~* ity will be pe o med weekly when the Component Coolin Water and e Steam Ge rator Blowdow activity is less than the alarm setpoint o G-RE-09, G-RE-1 0, J-RE-02 and - M-RE-25. The ~~~g will be performed more frequently if radiation monitor - G-RE-09,~G-RE- ~J-RE-02 ~M-RE-25 reach the alarm setpoint. )J The normal makeup water to the spent fuel pool and component cooling water system is from other plant sources, and the ESWS is only used if the other systems are unable to supply water. PLANT COOLDOWN AND SHUTDOWN- No changes to the valving arrangement are required from the normal operation to initiate cooldown of the plant. During the cold shutdown condition, various components may be isolated if no heat loads are generated. The source of water is normally from the SWS; however, if offsite power is not available the Class 1E ESW pumps will provide the water source. EMERGENCY OPERATION- Following a DBA or loss of offsite power, the safety-related signals will isolate the ESWS from the SWS by closing the associated motor-operated isolation valves. Also, the essential service water pumps will automatically start receiving power from the preferred power supply or the emergency diesel generators and supply water from the ultimate heat sink to the safety-related components and air compressors. The motor operated valves on the ESW return lines for the component 9.2-6 Rev. OL-19 5/12

CALLAWAY- SP cooling water heat exchangers, and the main isolation valves for the containment air coolers are automatically positioned, to decrease and increase, respectively, the cooling water flow rate as dictated by the service requirements. After cooling the equipment, the heated water is returned to the ultimate heat sink. Motor-operated valves in the UHS cooling tower will open to allow flow to return to the UHS cooling pond. Following the loss of only one Class-1 E 4160-V bus (not a design basis event), the ESWS will isolate from the service water system and the ESW pumps will automatically start as described above. The ESW pump and valves in the train of the lost bus will perform as though a complete loss of offsite power has occurred. The other ESW pump will start following signals which indicate both undervoltage on the opposite train bus and loss of flow to the containment coolers. Signals will also be given to open the inlet valve to the CCW heat exchanger and the return valve to the UHS in the train opposite that of the lost bus. The signal to start the opposite train ESW pump is isolated following a DBA or complete loss of offsite power. These signals preclude the need for operator action should only one Class-1 E 4160-V bus be lost. As described in Section 10.4.9, the ESWS, which is credited for accident mitigation, will automatically supply water to the auxiliary feedwater system in the event nonsafety-related condensate storage tank water is unavailable. In addition to the SIS and loss of offsite power signals, the ESW pump start logic includes the open signal to the ESW supply valve to the auxiliary feedwater system (AFS) on low suction pressure (LSP). The auxiliary feedwater LSP signal also closes the ESW/SW system isolation valves located at the power block inlet. This assures ESW supply to the AFS following an SSE without an accompanying accident or loss of offsite power. During this event, the 26 J9CreeAt FRaF~iA eA ultimate heat sink volume allows operator alignment of the ESW system to the UHS. 9.2.1.2.3 Safety Evaluation Safety evaluations are numbered to correspond to the safety design bases. SAFETY EVALUATION ONE - Except for the buried piping between the ESWS pumphouse, UHS Cooling Tower, ESW Supply Lines Yard Vault and the power block, the safety-related portions of the ESWS are located in the reactor, auxiliary, control, diesel, UHS Cooling Tower, ESW Supply Lines Yard Vault and essential service water pumphouse buildings. These buildings are designed to withstand the effects of earthquakes, tornadoes, hurricanes, floods, external missiles, and other appropriate natural phenomena. Sections 3.3, 3.4, 3.5, 3. 7(8), and 3.8 provide the bases for the adequacy of the structural design of these buildings. The buried piping is also designed to withstand these natural phenomena, as described in Section 9.2.1.2 of the Site Addendum. SAFETY EVALUATION TWO -The safety-related portions of the ESWS are designed to remain functional after a SSE. Sections 3.7(8).2 and 3.9(8) provide the design loading conditions that were considered. Sections 3.5, 3.6, and 9.5.1 provide the hazards 9.2-7 Rev. OL-19 5/12

CALLAWAY- SP analyses to assure that safe shutdown, as outlined in Section 7.4, can be achieved and maintained. Cl c-l-Ive esws SAFETY EVALUATION ~EE -The ESWS is completely r dundant and, as indicated by Table 9.2-Stno single~~~ure will compromise the ' safety functions. All vital power can be upplied from either onsite or offsite power systems, as described in 0~ ) Chapter 8. 0. LIV h;"ch o./.f1 Po dJ re..r.re~ /) HS ~" Ir ":J. .fo we..- sr, 1IlL 1"""1;I tA>-e r ') 3 SAFETY EVALUATION FOUR -The ESWS is initially tested with the program given in Chapter 14.0. Periodic inservice functional testing is done in accordance with Section 9.2.1.2.4. Section 6.6 provides the ASME Boiler and Pressure Vessel Code, Section XI requirements that are appropriate for the ESWS. SAFETY EVALUATION FIVE - Section 3.2 delineates the quality group classification and seismic category applicable to the safety-related portion of this system and supporting systems. Section 9.2.1.2.2.2 shows that the components meet the design and fabrication codes given in Section 3.2. All the power supplies and the control function necessary for safe function of the ESWS are Class 1E, as described in Chapters 7.0 and 8.0. SAFETY EVALUATION SIX - Section 9.2.1.2.2.1 describes provisions made to identify and isolate leakage or malfunction and to isolate the non safety-related portions of the system. SAFETY EVALUATION SEVEN - Sections 6.2.4 and 6.2.6 provide the safety evaluation for the system containment isolation arrangement and testability. SAFETY EVALUATION EIGHT- The nominal flow rates required to remove heat from the containment and necessary safety-related components from a postulated LOCA or MSLB and dissipate it to the ultimate heat sink are listed in Table 9.2-3. DeteFffiiAatioA of these 'Rew& i& BQ&QQ SA QA blltiFRate !=teet !iFIIE eJesi~A teFRf>8Fatur=e ef Q§°F, 83 eleter1 I Iii 1ed ~1:"1 aeetiofl 9.2.5. The ESWS design assures that the flow requirements are met by operation of an ESWS pump and proper realignment of the valves to the accident configuration. :::cN'S£/rr (!.. Each train of the ESWS and each train of the safety-related systems served by the ESWS are 100 percent redundant. This arrangement ensures that the full-heat dissipating capacity is available following an accident and an assumed single failure. SAFETY EVALUATION NINE- The nominal ESWS flow rate required to remove decay heat from the RCS and other necessary components to achieve and maintain a safe shutdown under normal conditions is listed in Table 9.2-4. ~l1e How 1ates ere 19eseeJ OFI 9.2-8 Rev. OL-19 5/12

INSERT C The design-basis maximum ESW supply temperature from the UHS retention pond is 95°F. That value was used in the design of the UHS cooling tower cells (FSAR Site Addendum Table 9.2-4 of Reference 1) and is the assumed ESW inlet temperature to all loads served by ESW except for the electrical penetration room coolers. However, the maximum ESW supply and UHS retention pond temperature of92.3°F establishes the upper acceptance criterion in the minimum heat transfer and maximum evaporation cases in the analysis supporting the 30-day UHS inventory requirement per RG 1.27 (Ref. 2). In addition, an ESW inlet temperature of92.3°F is also assumed in the analysis of the electrical penetration room temperatures (room coolers supplied by ESW). The 92.3°F value is the maximum temperature allowed in these analyses to support UHS operability assuming an initial maximum temperature of 89°F.

SaFe-~ Ev.-lu~-1-r;, f JrJ:i'.r~.'*;::viJ! ESW /<<HS Jesran 6~~.Jrr aR III=(~~~~FRJil~lllre gf QlioFJThe ESWS design assures that the flow requirements are met by operation of an ESWS pump and proper realignment of the valves to the accident configuration. SAFETY EVALUATION TEN - The minimum ESWS flow rate required to provide emergency makeup to the spent fuel pool and component cooling water systems and the backup water to the auxiliary feedwater system is listed in Table 9.2-3. The ESWS design assures that the flow requirements are met by operation of an ESWS pump in each train and proper realignment of the associated valves. 9.2.1.2.4 Tests and Inspections Preoperational testing is described in Chapter 14.0. The performance and structural and leaktight integrity of all cooling water system components is demonstrated by continuous operation. The ESWS is testable through the full operational sequence that brings the system into operation for reactor shutdown and for LOCAs, including operation of applicable portions of the protection system and the transfer between normal and standby power sources. The safety-related components of the ESWS, i.e., pumps, valves, heat exchangers, and piping (to the extent practicable), are designed and located to permit preservice and inservice inspections. 9.2.1.2.5 Instrumentation Applications The ESWS instrumentation, as described on Table 9.2-6, is designed to facilitate automatic operation and remote control of the system and to provide continuous indication of system parameters. Redundant controls are provided to initiate the start of the ESWS and to isolate it from the SWS upon receipt of an SIS and/or loss of offsite power. Redundant and independent power supplies for pump controls and instrumentation are provided from Class 1E busses. Refer to Chapter 8.0. Thermowells and pressure indicator connections are provided where required for testing and balancing the system. Portable ultrasonic flow indicators (and permanently installed flow indicators) are utilized for balancing of the flows in the system and for verifying flows during plant operation. 9.2.2 COOLING SYSTEM FOR REACTOR AUXILIARIES The cooling system for the reactor auxiliaries is the component cooling water system (CCWS). The CCWS provides cooling water to selected auxiliary components during normal plant operation, including shutdown, and also provides cooling water to several engineered safety feature systems (ESFS) during a LOCA or MSLB. This system is a closed loop system which serves as an intermediate barrier between the SWS or ESWS 9.2-9 Rev. OL-19 5/12

CALLAWAY- SP Protection against pollution from any equipment which takes water from the DoWS but uses this water for purposes other than drinking, cooking, or washing is provided by passing the flow supplying such equipment through air gaps or a backflow prevention device of the reduced-pressure zone type. Section 3.6 provides an evaluation demonstrating that pipe routing of the DoWS is physically separate from essential systems, to the maximum extent practicable. In addition, the floor drain system described in Section 9.3.3 provides leakage detection capabilities to assure that any abnormal leakage is detected and repaired. 9.2.4.2.2 Deleted 9.2.4.2.3 System Operation The domestic water system is supplied by a pressurized, chlorinated potable water source, as described in Section 9.2.4 of the Site Addendum. The DoWS will automatically supply water when an intermittent demand is created at an outlet. 9.2.4.3 Deleted 9.2.4.4 Tests and Inspections Preoperational testing is discussed in Chapter 14.0. Proper operation of the various components is verified by satisfactory use. 9.2.4.5 Deleted ---rs-2.5 ULTIMATE HEAT SINK A description of the ultimate heat sink (UHS), including drawings for the site, is given in Section 9.2.5 of the Site Addendum. Evaluations of the UHSpincludiRg a single faih:IFC analy&i&, are presented in the Site Addendum. ,h 9.2.5.1 Design Bases 9.2.5.1.1 Safety Design Basis SAFETY DESIGN BASIS ONE- The UHS provides a reliable source of cooling water to achieve and maintain a safe shutdown of the reactor following a DBA (GDC-44). SAFETY DESIGN BASIS TWO- The UHS supplies emergency makeup water to the spent fuel pool and component cooling water systems, and is the backup water supply for the auxiliary feedwater system. 9.2-22 Rev. OL-19 5/12

CALLAWAY- SP 9.2.5.1.2 Power Generation Design Basis The UHS is not required for power generation. 9.2.5.2 System Description 9.2.5.2.1 General Description The UHS consists of one seismic Category I mechanical draft cooling tower with redundant cells and a seismic Category I excavated retention pond1 siz:eel for tl=lo origiAel -two tu li tr. 9.2.5.2.2 Nominal Heat Loads f UHS cooling water chemistry analysis is provided for information in Table 9.2-16. q,::l-I (t~o)) q.:l.-l(b)~)___ Integrated heat rejected to the UHS for u to 30 days after and normal shutdown using the UHS are provided in Figures . - and 9.2-9 1ch are compiled by summing contributions from the following sources: L.ocA-f!kx;,...urn L!JCA-/11rn/lhUtn

a. Containment air coolers /3.Vt:tfon. frtJn. 6..s-~ HePrf- "'II?Ai\S~r &re.

(I~' t+ujAr) (14' t+u/"t")

b. Residual heat removal system 4-1-'6 5()~

c. Station auxiliary systems 11~ Jq~

10~ IP~

d. Spent fuel pool '(/1'3 ttl .. ~

Tabulated below are the nominal heat rejection rates or the ~c'ted time inteNals, 57.+ taken from Figures~and 9.2-8. 4!5:-~ 4-5::J. tJ~-t{e)~ q,2-t{+) I.L..---- 1

J / Normal Shutdown Using UHS -bOO!< I (1 06 Btu/hr) (1 Q6 Qt~/AF~

0 to 1 hour 24 -iOO 1 to 10 hours 265 583 10 hours to 1 day 152 ~ 1 day to 3 days 94 -49%:- 3 days to 15 days 67 -- 15 days to 30 days 36 60 ' 9.2-23 Rev. OL-19 5/12

otal integrated heat load for the 30-day period is conservatively calculated to be

   ~.-A-v-:+tt""--Mf-H-. Based upon this value, the average heat load per unit during the 30 days following a LOCA is -7&:9-x 106 Btu/hr.

7/r;,3 Section 6.2.1 provides a detailed analysis of heat released to the containment following an accident. This analysis considers the heat rejection due to the stored thermal energy ~ of the reactor coolant system and due to the heavy elements and fission ~roducts decay heat. ~:q,_:l-t,{P) -Anu;JA 'J,:J-t{+)) Cj;2-l{t?.j) arv:f t/f,:J-/(J, Figures' ~ depict the heat loads utilized to determine the thermal response of the UHS to heat loads following a LOC~ These figures conservatively represent heat rejection from all sources, including heat fr m the stored thermal energy of the reactor coolant system, fission product and heavy lement decay, heat from the station auxiliary systems, and heat due to pump work. Th heat rates and total integrated heat load shown in these figures are in accordance ith Regulatory Guide 1.27 and provide additional conservatism over the heat reje ted to containment as described in Section 6.2.1. These heat loads are based upon e following operational assumption~ ; --->~- I/VS~£(< ,r6

           ~         ~~~~~~~~~~~~~~~~~~

The decay heat due to the heavy elemen sand fission products is calculated using ~NSI/ _f\ . ANS-5.1-1979. w r.J.A /Ae_ t),JrtAI1-tel -fq;I~.~~ -ff ~/,J,.re. lJF~"'e

u. H.f CIJI/111$.,-/tJv~ey JvJJttr.S.r valve.!'

The average nominal heat rejection rate of the stat1on auxiliary ~stems listed in Table 9.2-17 following a LOCA is 17.86 x 106 Btu/hr. The total integrated heat released by the station auxiliaries for 30 days is conservatively calculated to be 1.29 x 1010 Btu. Section 9.1.3 describes the heat load from the spent fuel pool cooling system. 9.2.5.2.2.2 Nominal Heat Loads Following Normal Shutdown Using UHS Figures 9.2-8 and 9.2-9 provide the heat loads as a function of time for a normal plant cooldown. The average heat load per unit during the 30 days following a normal plant cooldown is 55.7 x 106 Btu/hr. The total integrated heat load for the 30-day ~eriod is 1 L .. l:!' 9 ( tl #.t! CA 'L II ~~*4~11! 40.1 x 10 Btu. ~1 F'-7?.1><://I.ffo/lw Heat rejected to the UHS following a normal shutdown is based on tFelfl RI-IR

  -of)eFatioA feF tl':le iflitial 20 hours~ whieh time the Uflit is ifl eelel sl'lutelowfl eeflelitiofF.=

Refer to Section 5.4. 7.2 .1 for~~ itional discussion, eR tl:l& effeete ef stea111 gene* at01 F911laeeA'teAts. (_ _

                                           -{; 1/,w'?J rea e:kr sA 1-f-IJIJI.V;,

9.2-24 Rev. OL-19 5/12

INSERT4

a. Operator action is taken within 70 minutes of large break LOCA initiation to diagnose and mitigate a postulated single failure of a UHS cooling tower bypass valve to close based on indications from NG07 and NG08 bus voltage annunciators and proper equipment status (bypass valve position, UHS cooling tower fan speed) for the prevailing ESW return (UHS inlet) temperature.

b. Operator action is taken within 4 hours of large break LOCA initiation to use EFHS0067 ('A' train) and EFHS0068 (' B' train) to switch the temperature control circuitry for the automatic positioning of the UHS cooling tower bypass valves and UHS cooling tower fans (fans transition from off to slow speed then to high speed as temperature increases) from the ES W return temperature loops (UHS inlet) to the ESW pump discharge (ESW supply) temperature loops.

c. Two ESW trains may be in operation for up to 7 days after large break LOCA initiation. Within 7 days one ESW train is secured by operator action.

d. One ESW train is in operation for the remainder of the 30 days.

Table 9.2-5 (items 10 and 11) also identifies operator action that may be required to mitigate a postulated failure in the circuitry used to control the UHS cooling tower bypass valves and cooling tower fans based on ESW pump discharge (ESW supply) temperature.

CALLAWAY- SP The heat rejection rate of the station auxiliary systems listed in Table 9.2-18 is 15.09 x 106 Btu/hr. The total integrated heat released by the station auxiliaries for 30 days is 2. 7 9 X 10 Btu. The heat load from the spent fuel pool cooling system is described in Section 9.1.3. As indicated by the above heat load valu~~tdown heat loads are bounded by the LOCA heat loads. \:£7 (.!;! 9.2.5.2.3 Emergency Makeup Water Requirement Power block emergency makeup water requirements are given in Figures 9.2-10 and f -= 9.2-11. w~e T keup no ter fr the ESWS is required to supply the auxiliary feedwater system fel}i elated condensate storage tank is unavailable or exhausted, as described in Section 10.4.9. Makeup water from the ESWS is required to replace evaporative losses from the spent fuel pool, as described in Section 9.1.3. Makeup water may also be required to replace evaporative losses or minor leakage from the component cooling water system. Normal makeup is provided from other sources.

9.2.5.2.4 Component Description Refer to Section 9.2.5.2 of the Site Addendum. 9.2.5.2.5 System Operation Refer to Section 9.2.5 of the Site Addendum. 9.2.5.3 Safety Evaluation SAFETY EVALUATION ONE- The UHS is capable of providing enough cooling water for a safe shutdown and for continued cooling of the reactor for 30 days following an accident. q ~, 3 an £SW The design ba s heat load for the UHS is tabulated in SectioEn.2.5.2.2. Section 9.2.5 of the Site Ad endum provides a safety evaluation which dem nstrates that the UHS capacity is su 1cient for a 30-day supply of cooling water with supply temperature no greater then °F, assuming maximum engineered safety feature operation with minimum heat transfer conditions, as described in Section 9.2.5 of the Site Addendum. The maximum UHS temperature reached in the DBA during these conditions is 92.3°F. This is bas d on maximum heat load and the most severe meteorological conditions, as des ibed in Section 9.2.5 of the Site Addendum. :Z:A/ SIE/(1" C.. re.-1-err/-(m ford 9.2-25 Rev. OL-19 5/12

INSERT C The design-basis maximum ESW supply temperature from the UHS retention pond is 95°F. That value was used in the design of the UHS cooling tower cells (FSAR Site Addendum Table 9.2-4 of Reference 1) and is the assumed ESW inlet temperature to all loads served by ESW except for the electrical penetration room coolers. However, the maximum ESW supply and UHS retention pond temperature of 92.3 °F establishes the upper acceptance criterion in the minimum heat transfer and maximum evaporation cases in the analysis supporting the 30-day UHS inventory requirement per RG 1.27 (Ref. 2). In addition, an ESW inlet temperature of92.3°F is also assumed in the analysis of the electrical penetration room temperatures (room coolers supplied by ESW). The 92.3°F value is the maximum temperature allowed in these analyses to support UHS operability assuming an initial maximum temperature of 89°F.

CALLAWAY- SP SAFETY EVALUATION TWO -The minimum UHS reserve requirement to provide emergency makeup water to the spent fuel pool and component cooling water systems and backup water to the auxiliary feedwater system is provided in Figures 9.2-10 and 9.2-11. Section 9.2.5 of the Site Addendum provides the safety evaluation which demonstrates that the UHS has an adequate capacity to meet these needs. 9.2.5.4 Tests and Inspections Refer to Section 9.2.5 of the Site Addendum. 9.2.5.5 Instrument Application Refer to Section 9.2.5 of the Site Addendum. _1__ 9.2.6 CONDENSATE STORAGE AND TRANSFER SYSTEM The condensate storage and transfer system (CSTS) consists of one 450,000-gallon condensate storage tank (CST), non-safety auxiliary feedwater pump, and associated valves and piping. The CST serves as a reservoir to supply or receive condensate, as required by the condenser hotwelllevel control system. The tank is also a nonseismically designed source of water to the auxiliary feedwater system and is not credited for accident mitigation. 9.2.6.1 Design Bases 9.2.6.1.1 Safety Design Bases The CSTS serves no safety function and has no safety design basis. 9.2.6.1.2 Power Generation Design Bases POWER GENERATION DESIGN BASIS ONE- The minimum usable volume of the CST provides sufficient water to the suction of the auxiliary feedwater pumps for decay heat removal during a 4 hour Station Blackout event, as discussed in Table 8.3A-1, item II I.A. POWER GENERATION DESIGN BASIS TWO - CSTS permits periodic testing of the auxiliary feedwater pumps. POWER GENERATION DESIGN BASIS THREE -The gross capacity of the CST is sufficient to fill the condensate system, feedwater system, and the steam generators. POWER GENERATION DESIGN BASIS FOUR -The CSTS is designed to limit the dissolved oxygen in the CST to less than 0.1 ppm. 9.2-26 Rev. OL-19 5/12

CALLAWAY- SP

                                                        ~()       J~r-TABLE 9.2-3 ESSENTIAL SERVICE WATER SYSTEM FLOW REQUIREMENTS POST-LOCA OPERATION<8 )
                                           'A' Train      'B' Train        Total Flow (gpm)/    Flow (gpm)/       Duty Equipment             Section   Number/   Duty (x 106    Duty (x 106      (x 106 Description           Number     In Use    Btu/hr)< 3)    Btu/hr)< 3)   Btu/hr)<2)

Component cooling 9.2.2 2/2 7,350/195 7,350/195 390 water heat exchanger <1) Containment air 6.2.2 4/4 4,000/204.65 4,000/204.65 409.3 cooler (2,000/141.4) (2,000/141.4) (282.8) Diesel generator 9.5.5 2/2 1,200/14.2 1,200/14.2 28.4 cooler Component cooling 9.4.3 2/2 128/0.16 128/0.16 0.32 water pump room cooler Centrifugal charging 9.4.3 2/2 128/0.16 128/0.16 0.32 pump room cooler Auxiliary feedwater 9.4.3 2/2 128/0.32 128/0.32 0.64 pump room cooler (?) Safety injection pump 9.4.3 2/2 88/0.135 88/0.135 0.27 room cooler RHR pump room 9.4.3 2/2 88/0.16 88/0.16 0.32 cooler Containment spray 9.4.3 2/2 88/0.13 88/0.13 0.26 pump room cooler Penetration room 9.4.3 2/2 100/0.16 100/0.16 0.32 cooler (electrical) Fuel pool cooling 9.4.2 2/2 29/0.072 29/0.072 0.144 pump room cooler Control room ale unit 9.4.1 2/2 140/0.663 140/0.663 1.326 condenser Class 1E switchgear 9.4.1 2/2 66/0.485 66/0.485 0.970 ale condenser Rev. OL-19 5/12

CALLAWAY- SP TABLE 9.2-3 (Sheet 2)

                                                      'A' Train         'B' Train          Total Flow (gpm)/       Flow (gpm)/         Duty Equipment                   Section    Number/       Duty (x 106        Duty (x 106       (x 106 Description                 Number      In Use        Btu/hr)< 3)        Btu/hr)< 3)    Btu/hr)<2)

Air compressor and 9.3.1 2/2 61/0.763 61/0.763 1.526 after cooler <4 ) Maximum flow to 10.4.9 1,120/NA 1, 120/NA auxiliary feedwater system (S& 6) Makeup to spent fuel 9.1.3 25/NA 25/NA pool cooling & cleanup systems <6) Maximum makeup to 9.2.2 100/NA 100/NA component cooling water system <6) NOTE: (1) Load does not occur until post-LOCA recirculation mode is initiated. This load is a conservative bound determined in the plant uprating report. For the purposes of determining system response to post LOCA heat loads, minor CCW heat loads such as the Safety injection and Centrifugal Charging Pump Oil coolers, and the Residual Heat Removal Pump Seal Cooler are considered to be encompassed by this bounding value. (2) If single failure occurs in either train, the load shown in the opposite train will be the total. (3) Peak duty is shown for each component. Actual duty is less and will reduce long term, as described in Section 9.2.5. (4) Values may vary with plant conditions. (5) Auxiliary feedwater system may be used to maintain steam generator water level post-LOCA. (6) Flow shown would be maximum intermittent value expected. (7) Heat load shown would be maximum intermittent value expected. (8) The values specified in this table are nominal values based upon-#le-tl R=taxiA=tttm UHS/ESW temperature of 95°~ The minimum required ESW (See ) J,jC/ASSitJt1 rn sec-+r4n ~";:), J,;!, 3)

                                    .s-"'+e+y      £v.,./ 111111 k'" Erd). +)         Rev. oL-19 5/12

CALLAWAY- SP TABLE 9.2-3 (Sheet 3) flow rates are dependent on a number of factors including the number of tubes plugged on a heat exchanger, the fouling of the heat exchanger, heat loads of the components or room, process fluid flow rates, maximum calculated ESW temperature, and ESW flow rate through its associated cooling tower. The minimum acceptable ESW flow rates to these plant components are controlled by plant procedures. Rev. OL-19 5/12

CALLAWAY- SP ~del~ TABLE 9.2-4 ESSENTIAL SERVICE WATER SYSTEM FLOW REQUIREMENTS NORMAL SHUTDOWN OPERATION(4 )

                                          'A' Train     'B' Train      Total Flow (gpm)/   Flow (gpm)/    Duty<2)

Equipment Section Number/ Duty (x 106 Duty (x 106 (x 106 Description Number In Use Btu/hr) Btu/hr) Btu/hr) Component cooling 9.2.2 2/2 13,500/140.35 13,500/118.11 258.46 water heat exchanger <1) Containment air 6.2.2 4/4 2,200/4.62 2,200/4.62 9.25 cooler Diesel generator 9.5.5 2/0 1,200/0 1,200/0 0.0 cooler Component cooling 9.4.3 2/2 128/0.32 128/0.32 0.64 water pump room cooler Centrifugal charging 9.4.3 2/0 128/0 128/0 0 pump room cooler Auxiliary feedwater 9.4.3 2/0 128/0 128/0 0 pump room cooler Safety injection pump 9.4.3 2/0 88/0 88/0 0.0 room cooler RHR pump room 9.4.3 2/2 88/0.22 88/0.22 0.44 cooler Containment spray 9.4.3 2/0 88/0 88/0 0.0 pump room cooler Penetration room 9.4.3 2/2 100/0.10 100/0.10 0.20 cooler Fuel pool cooling 9.4.2 2/2 29/.072 29/.072 0.144 pump room cooler Control room ale unit 9.4.1 2/2 140/0.663 140/0.663 1.326 condenser Class 1E switchgear 9.4.1 2/2 66/0.485 66/0.485 0.97 ale condenser Rev. OL-19 5/12

CALLAWAY- SP TABLE 9.2-4 (Sheet 2)

                                                   'A' Train            'B' Train            Total Flow (gpm)/          Flow (gpm)/         Duty(2)

Equipment Section Number/ Duty (x 106 Duty (x 106 (x 106 Description Number In Use Btu/hr) Btu/hr) Btu/hr) Air compressor and 9.3.1 2/2 61/0.763 61/0.763 0.526 after cooler (3 ) Flow to auxiliary 10.4.9 0 feedwater system Makeup to spent fuel 9.1.3 0 pool cooling and cleanup system Makeup to 9.2.2 0 component cooling water system NOTE: (1) Maximum duty from CCW occurs 4 hours after initiation of shutdown when the RHR system is brought into service, as described in Section 9.2.2. Flowrate listed represents the nominal flow with the CCW heat exchanger outlet flow control valves fully open. Actual flows will be less. (2) Peak duty is shown for each component. Total duty to UHS is actually less and will reduce long term. (3) Values may vary with plant conditions; both are assumed to be operating. (4) The values specified in this table are nominal values based upon4Ae-A rTiaxiR:n:Jm UHS/ESW temperature of 95°F The minimum required ESW flow rates are dependent on a number of actors including the number of tubes plugged on a heat exchanger, the f uling of the heat exchanger, heat loads of the components or room, proce s fluid flow rates, maximum calculated ESW temperature, and ES flow rate through its associated cooling tower. The minimum accepta e ESW flow rates to these plant components are controlled by plant p ocedures. {_see j l.lcVtS.SitJY"\ 'ir. Jec-H'dn a-, ,~, I , :l ,-'3 J S~e-lu I £vt:.i/~~to.frtJn N r,... J Rev. OL-19 5/12

CALLAWAY- SP AN~/t!WE~ TABLE 9.2-5 ESSENTIAL SERVICE WATER SYSTEMV. FA:rL#Mt=(YWF:£:r /tNb EFFEC!-"IS ANALYSIS Component Failure Comments

1. ESW pump and associated Fails to start on Two pumps are provided.

supporting items automatic signal. One is sufficient for post-LOCA heat removal.

2. Supply isolation valve Fails to close on Second valve in series between SW and ESW automatic signal. will provide isolation.

system

3. Main outlet valve for Fails to open on Partial cooling still containment air cooler automatic signal. provided in addition to 1OOo/o cooling removal by redundant train.

4. Supply valve to air Fails to close upon Continued use of the compressor small break. system will result in minimal loss of water.

100 percent of the heat load is removed by the redundant train.

5. CCW heat exchanger inlet Fails to open on Two CCWheat valve automatic signal. exchangers and two paths are provided. One loop provides 1OOo/o cooling capacity.

6. CCW heat exchanger main Fails to reposition on Results in lower flows to outlet valve automatic signal. other components (i.e.

containment air cooler), hence reducing their efficiency. 100 percent of the heat load is removed by the redundant train.

7. Return isolation valve Fails to close on Second valve in series between SW and ESW automatic signal. will provide isolation.

system

8. Return isolation valve to Fails to open on 100 percent of the heat ultimate heat sink automatic signal. load is removed by the redundant train.

> ::LNS~~~ s-Rev. OL-13 5/03

INSERT 5 (page 1 of2) ComQonent Failure Comments

9. UHS cooling tower Fails to close on The cooling function of one safety train of essential service water is lost bypass valve (EFHV0065, automatic signal. with the potential of overheating the UHS retention pond or not retaining EFHV0066) sufficient 30-day inventory. Control room operators will be able to evaluate the situation and isolate the degraded train of essential service water within 70 minutes per plant procedures. Essential plant cooling requirements are met thereafter by the remaining operable essential service water and UHS safety train.

10. Temperature control Fails to transfer Given no other ESW/UHS equipment failures, one ESW train must be transfer handswitch automatic control of secured within 7 days of the initiation of a large break LOCA initiation (EFHS0067, EFHS0068) UHS cooling tower as discussed in Section 9.2.5.2.2.1. In order to mitigate a postulated bypass valves and failure of the temperature control handswitch, an emergency operating cooling tower fans from procedure step will continuously monitor the expected cooling tower fan ESW return (UHS inlet) performance and secure the failed ES W train if the control scheme is not temperature loops to performing as anticipated. Given the continuous monitoring required by ESW pump discharge the emergency operating procedure, this condition will be resolved (ESW supply) within 24 hours of large break LOCA initiation.

temperature loops (Item 11).

11. ESW supply temperature Fails to properly control The ESW supply (ESW pump discharge) temperature loops, up to the control loops (EFT-0061, UHS cooling tower temperature control transfer hands witches (Item 10), are identical in EFT-0062) bypass valves and function to the UHS cooling tower inlet temperature loops. Any failure cooling tower fans. in the ESW supply temperature loop circuitry would be bounded by the discussion under Item 10 above. - -

INSERT 5 (page 2 of2) Com12onent Failure Comments

12. UHS cooling tower Passive failure of one The cooling function of two cooling tower cells which removes the heat discharge header ( 179- discharge header within from one essential service water train is lost. The essential plant cooling HBC-30" or 166-HBC- the UHS cooling tower. requirements are met by the remaining two cells which remove the heat 30") from the other essential service water train.

13. UHS cooling tower fan Fails to start or run at The cooling function of one cooling tower cell is lost. The essential plant (CEF01A, B, C, or D) correct speed on cooling requirements are met by two of the remaining cooling tower cells automatic signal. which remove the heat from the other essential service water train.

14. Emergency DG (KKJ01A Fails to start or run and The cooling function of two cooling tower cells which remove the heat orB) provide emergency from one essential service water train is lost. The opposite train's diesel power to the two train- power supply to the remaining two fans is available. Essential plant related UHS cooling cooling requirements are met by the remaining two cells which remove tower fans. the heat from the other essential service water trains.

CALLAWAY- SP TABLE 9.2-6 ESSENTIAL SERVICE WATER SYSTEMpiNDICATING AND ALARM DEVICES ~ Indication Control Room Local Control Room Alarm {'J ESW header flo~ rate Yes No No SU~~~ ESW heeeteMem erature ESW re+ur" e-/J\~e~~ ~(1) ~0e..r No N, ESW flow to air camp essors and ~ Yes Yes aftercoolers N~t:i) Power-operated valve position Yes Yes No (all valves) ESW flow to containment coolers No Yes Yes ('3) ESW pump discharge pressure Yes Yes Yes ESW flow to CCW heat exchangers No Yes No

D..J r£1<1 ~A (l) 11 1sli 011 ietltatiull i1 1pats to trte Air CoFRpressor Trouble alarffi iFI the GeFitrel Roo11 r.

Rev. OL-13 5/03

INSERT 5A Indication Control Room Local Control Room Alarm(o) UHS cooling tower trouble No No Yes(4 ) UHS cooling tower fan speed Yes Yes No ESW pump intake water level Not*J Yes YesP> ES W pump dis_charge strainer high differential pressur~ __ No(I) Yes Yes (1) Main control room computer point only 2 ( ) Instrumentation inputs to the Air Compressor Trouble alarm in the main control room 3 ( ) Alarm on low discharge pressure 4 ( ) Based on a combination ofESW pump run time, ESW return water temperature, UHS cooling tower fan operating (on/off) status, and UHS cooling tower bypass valve position (S) Alarm on high and low water level 6 ( ) Control room annunciators also have indicating lights

f ~.m l ~ C-;m i 20.1 1Cil M) fOO fODO a.APSI!D lw.t! POIT"--CA (H,_J

      ~e.fio.ce wi.J-h        new        0 01A.-esq,;2.-t{o,)

REV. OL-15

             +AriA PJ,:A-{ {.P)                                               5/06 CALLAWAY PLANT FIGURE 9.2-6 NOMINAL HEAT REJECTION RATE TO ULTIMATE HEAT SINK LOCA

Figure 9.2-G(a): A Train Heat Loads to UHS LBLOCA (MaxEvap Model w/ Valve Failure)

                                      ~A     Train Coolers   "'"";>>"'A Train CCW     - A Train Aux 60,000.00 50,000.00 u        40,000.00 cv Ill

s a:l

-cv to c:::

0 30,000.00

+=i u

cv

'Cij' c:::

to cv J: 20,000.00 10,000.00 0.00 l.OOE+OO l.OOE+Ol l.OOE+02 l.OOE+03 l.OOE+04 l.OOE+OS l.OOE+06 l.OOE+07 Time (sec)

                                  -----~--------------*------------

Figure 9.2-G(b): B Train Heat Loads to UHS LBLOCA (MaxEvap Model w/ Valve Failure) 60,000.00

                                          """""""'B Train              B Train CCW   ............. B Train Aux 50,000.00

_40,000.00 u Q) II)

I

 +J
~

Q)

 +J I'll
 ~30,000.00 0
*.;:;                                                                                                       Note: B Train is u

Q)

'(jj'                                                                                                       shutdown within 70 0:::
 +J                                                                                                         minutes (4,200 Sec)

I'll Q) J: 20,000.00 ------- 10,000.00 0.00 l.OOE+OO l.OOE+Ol 1.00E+02 1.00E+03 l.OOE+04 l.OOE+OS 1.00E+06 l.OOE+07 Time {sec)

Figure 9.2-6{c): A Train Heat Loads to UHS LBLOCA{MinHT Model w/ Valve Failure)

                                        = A Train Cooler   "o'""***A Train CCW      ~A Train Aux 60,000.00 50,000.00 v QJ 40,000.00 Ill
....::::J

~

....nJ QJ
~ 30,000.00 0
*zv QJ "Qj' cr:
 ....nJ QJ

c 20,000.00 10,000.00 0.00 l.OOE+OO l.OOE+Ol l.OOE+02 l.OOE+03 l.OOE+04 l.OOE+OS l.OOE+06 l.OOE+07 Time (sec)

Figure 9.2-G(d): B Train Heat Loads to UHS LBLOCA(MinHT Model w/ Valve Failure)

                                        == B Train Coolers       B Train CCW      ............. B Train Aux 60,000.00 50,000.00 u          40,000.00 Q.l VI

s

Q.l n:l

~ 30,000.00 0
~

u Q.l

'(U a:                                                                                                             Note: B Train is n:l Q.l shutdown within 70

I: 20,000.00 minutes (4,200 Sec) 10,000.00 0.00 l.OOE+OO l.OOE+Ol l.OOE+02 l.OOE+03 l.OOE+04 l.OOE+OS l.OOE+06 Time (sec)

Figure 9.2-6(e): Total Heat Rejection Rate to the UHS LBLOCA (MaxEvap Model w/ Valve Failure) 2.0E+05 1.8E+05 1.6E+05 1.4E+05 v(1) Cll ~ .... 1.2E+05 e ....nJ (1) ~ l.OE+OS 0 (1)

~

o:: .... 8.0E+04 nJ (1) z 6.0E+04 4.0E+04 2.0E+04 O.OE+OO l.OOE+OO l.OOE+Ol l.OOE+02 1.00E+03 l.OOE+04 l.OOE+OS l.OOE+06 1.00E+07 Time (sec)

Figure 9.2-G{f): Total Heat Rejection Rate to the UHS LBLOCA (MinHT Model w/ Valve Failure) 2.0E+05 1.8E+05 1.6E+OS 1.4E+OS uCIJ Ill ~+'" 1.2E+05 eCIJ

+'"

nJ ~ l.OE+OS 0 CIJ "Qj' o::

+'"

8.0E+04 nJ CIJ J: 6.0E+04 4.0E+04 2.0E+04 O.OE+OO l.OOE+OO l.OOE+Ol l.OOE+02 1.00E+03 l.OOE+04 l.OOE+OS l.OOE+06 Time (sec)

f!'CQlG - i .m>> 1 Is;!IXJ>> I l-1 11XnG ~ 10 10G tOOO I!!LAPSI!D TIMI! POll lOCA (HMJ ((erfo.u wf.J-j_ r,e_W _p-i'Are_sq,2-/{f).) REV. 16 10/06 Otnd q ,.2-7 {J,) CALLAWAY PLANT FIGURE 9.2-7 NOMINAL INTEGRATBl HEAT REJECTBl TO ULTIMATE HEAT SINK LOCA

Figure 9.2-7{a): 30 Day Total Integrated Heat to UHS LBLOCA {MaxEvap Model w/ Valve Failure) 60,000.00 ---~----~~-----*

30 day final value: 50,000.00 *-------**-*-*-*---*--* ****-*** **-************* 54,792 MBTU _40,000.00 -~~------------ 1-al ~

+J co QJ

I:

~30,000.00

+J J

co

s... tl.O QJ

+J s::

n;

+J 0

1- 20,000.00 10,000.00 I 0.00 _/ 0.01 0.1 1 10 100 1000 Time (Hours)

Figure 9.2-7(b): 30 Day Total Integrated Heat to UHS LBLOCA (MinHT Model w/ Valve Failure) 60,000.00 .~ .** ~- **~~-~~w~~~**""~"''"~~""~' "" .. ""'~'~'"'"' *** " ".. "" '""'"'""""""""~'~"" ' ** ,,.,.,,., "'""-"'"""-"'-""'~""""""""'"""'-*~---*~'"""'""""-""'"'""-""""-'"'"'"~'""-"'""'"' _ _ _ _ ,_.,,,.,,.,,._,.. ,,..._.,,.,.,.,_,.,,.,,.,,,.,,.,._.. ,_._._..., ...,,,..,_._,.,,_, _ _ ._.,,.,, ______ , . , _ ,__ ,_,.,, _ _., ' ...,,.. ,._ _ _ _ , _ " " 30 day final value: 50,000.00 54,906 MBTU - 40,000.00

1 I-cc

~ ...co QJ

I:

]

...co 30,000.00
...~

s::: jij 0 1- 20,000.00 10,000.00 0.00 0.01 0.1 1 10 100 1000 Time {Hours)

FSAR SITE ADDENDUM CALLAWAY- SA precipitation during the month with the greatest PMP, December, is 50.8 g/cm 2 (1 02.4 lb/ cm 2 ). The 100-year return period snowload, unadjusted, is 11.74 g/ cm 2 (21.0 lb/cm 2). The basic snowload coefficient of 0.8 (ANSI, 1972), applicable to flat-roofed unexposed buildings, may be applied to the unadjusted snowload to yield an effective snowload of 9.39 g/cm 2 (16.8 lb/cm 2 ). As required by NRC Regulatory Guide 1.70, the 48-hour winter PMP is retained qy the 100-year return period snowload to yield a combined weight of 60.2 g/cm 2 (119.2 lb/ cm 2 ). 2.3.1.2.12 Meteorological Input to the Ultimate Heat Sink Analysis An analysis of 3-hourly meteorological data (temperature, relative humidity, solar radiation, cloud cover) collected at Columbia, Missouri (NWS, 1945-69) over the period, 1945 through 1969, was performed to determine the meteorological conditions which would result in (1) the smallest heat transfer from the retention pond for a single day and for 30 consecutive days, and (2) the greatest evaporation from the retention pond over 30 consecutive days. The minimum heat transfer rates and evaporation rates were determined by 3-hourly iterative calculations based on existing temperature, wind speed, relative humidity, solar precipitation, and cloud cover. Table 2.3-13 presents the combination of historical meteorological conditions which would result in the smallest heat transfer from the retention pond for a single day and for 30 consecutive days. The most critical single day in the 26-year period was July 12, 1969. The period July 7 through August 5, 1955 was the most critical 30-day period. This period was used to calculate the maximum water temperature in the retention pond. The meteorological conditions 30 days prior to the most critical 30-day period were evaluated to determine the prior water temperature. The meteorological conditions during the antecedent 30-day period, June 7 through July 6, 1955, are presented in Table 2.3-14. Table 2.3-15 provides the historical meteorological conditions during the 30-day period which would result in the greatest evaporative loss from the retention pond. This period was July 2 through 31, 1954. The wind speed is given as 20.44 km/hr (12. 78 mph) in 2.3-15, because this is the value of the greatest average wind speed during the period. The greatest daily average wind speed during the period is used as input in the calculation of total evaporative water loss. The average wind speed during the 30-day period was 16.8 km/hr (1 0.5 mph). The procedures used for determining the meteorological conditions which would result in the minimum heat transfer rates and the greatest evaporation from the retention pond are discussed in ~l=le res~o1 1se to P~RC lte1 11 45~ .36. S"ec-liiJ11 ~, 3 ../, ~,IS , 2.3-12 Rev. OL-19 5/12

CALLAWAY- SA ITEM 451.3C Describe the procedures used for determining the meteorological conditions which would result in the minimum heat transfer rates (Table 2.3-13 and 2.3-14) and the greatest evaporation from the retention pond (Table 2.3-15) for design of the ultimate heat sink. RESPONSE See FSAR Section 2.3.1.2.13. 451.3C-1 Rev. OL-13 5/03

CALLAWAY- SA 2.4 HYDROLOGIC ENGINEERING 2.4.1 HYDROLOGIC DESCRIPTION 2.4.1.1 Site and Facilities The Callaway Plant site is located about 10 miles southeast of Fulton in Callaway County, Missouri, on a plateau lying about 5 mile north of the Missouri River. The plateau has elevations varying from about 830 to 50 feet MSL. The elevation of the Missouri River floodplain near the site is about 52 feet MSL. The plant grade elevation is established at 840 feet MSL and the standard p nt flo~elevation of the safety-related facilities at 840.5 feet MSL. The center of the no afetyffelated natural draft cooling tower is located about 1,200 feet to the northeast of the reactor building at a grade elevation of 845 feet MSL ( Figure 2.1-4). The site and local topography are shown on Figures 2.1-3 and 2.1-4; a larger area surrounding the site is shown on Figure 2.5-14. Locations of and topographic profiles showing the relationship between the Callaway Plant site and the Missouri River Valley are illustrated on Figures 2.4-1 and 2.4-2, respectively. The site physiography is discussed in Section 2.5.1.2.1. The Missouri River, the principal source of makeup water for the cooling tower system, is discussed in detail in Section 9.2. Makeup water will be withdrawn through an inlet located at about Missouri River mile 115 (Figure 2.1-2). It will be pumped to the site via a pipeline, as shown on Figure 2.1-2, and the blowdown water from the cooling water system will be discharged through a separate pipeline to the Missouri River about 100 feet downstream from the intake structure. Emergency safe shutdown of the reactor would be accomplished with a Category I mechanical draft ultimate heat sink (UHS) cooling tower utilizing water from the UHS retention pond located adjacent to the power plant facilities. Consequently, the intake structure at the Missouri River and the supply and discharge pipelines to and from the plant site are not Category I structures. The Category I structures include the reactor, fuel, control, diesel generator, and auxiliary building; the essential service water system (ESWS) pipelines; the ESWS electrical duct banks including manholes; the refueling water storage tank; the UHS mechanical draft cooling tower; the UHS retention pond; the ESWS pumphouse and the ESWS supply lines yard vault. The locations of these safety-related components are shown on Figure 2.1-4. The UHS retenf ________Jes~n---------- pond is an excavation in natural soils located ab ut 400 feet southeast of U it I, as shown on Figure 2.1-3, and contains about 5 .03 acre-feet of water for use s makeup water for the Category I mechanical draft c oling tower system ency safe shutdown. The water surface area in the ond is about 4.1 acres, the water surface elevation is 836.0 feet, and the depth of the water j 8 feet. Jhe pond site area is underlain by accretion-gley and glacial till of extre ely low permeability. Seepage losses will have no significant effect on storage. The ermeab ity of the natural soils surrounding the pond is discussed in Section 2.5 .2. 2.4. -rJ.. -lz, 'a e.+ ( Q_ I1MJ rna /) /,( HS' r-e +e.,-lf4, II)"" I e. v e. I r.r

                              !114fh-/-arnd l>--l-we~ 11 ~t..       low aNI A~J.. /J/I.r Wtt-kr 2.4-1                                Rev. OL-19a I eve I ~ I tArmr,                                  1112

CALLAWAY- SA 2.4.6 PROBABLE MAXIMUM TSUNAMI FLOODING The site is located far inland from coastal areas and therefore is not subject to tsunami flooding. 2.4.7 ICE EFFECTS No safety-related facilities are expected to be affected by ice flooding. Other potential ice-related effects, however, are discussed below. 2.4.7.1 UHS Retention Pond The UHS retention pond is a safety-related structure and is subject to ice formation in winter. Ice formation, however, does not affect the operation of the UHS retention pond for the following reasons:

a. During winter operation, the cooling phase provided by the UHS cooling towers on the heated return loop can be bypassed to assure that warmer water will be disc}lar~ed to accelerate deicing.

des'1"

b. The invert vation elf the ESWS pumphouse is approximately 26 feet below the ater level of the UHS retention pond, and the invert of the discharge pipes is approximately 17.5 feet below th)twater surface.

desfiJln The effect of ice on the UHS retention pond dependability is discus~d in Section 2.4.11.6. A description of the UHS retention pond is included in Section 9.2.5. 2.4.7.2 UHS Pond Structures The pond structures at the water surface are in contact with surface ice that can form during prolonged subfreezing periods. Ice expansion and wind drag on the ice surface exert forces on these structures. The following sections address the approach used in evaluating the ice thickness and the forces on the ESWS pumphouse and the pond outlet structure caused by the presence of ice. 2.4.7.2.1 Ice Layer Thickness Determination of the ice thickness in the retention pond is based on the analysis of the total number of degree days below freezing, defined as the number of days per month times the difference between 32°F and the mean monthly temperature for the months of December, January, and February. These values are summed to obtain the accumulated number of degree days since freeze-up for each year of record. Accumulated degree days are then subjected to a frequency analysis to determine the degree days for various recurrence intervals. The data used in the analysis are mean monthly air temperatures at Columbia, Missouri, which is located about 35 miles northwest of the site, for the years 1934 to 1973. The ice thickness is then determined for various recurrence intervals using 2.4-24 Rev. OL-19a 7/12

CALLAWAY- SA Assur's empirical method (Chow, 1964). Based on this analysis, the calculated ice layer thicknes at the pond surface ranges from 15 inches to 24 inches for recurrence intervals of 10 years and 100 years, respectively. 2.4.7.2.2 Ice Thrust Due to Thermal Expansion Evaluation of thrust forces due to the expansion of the ice cover as the result of a rise in the air temperature is based on the U.S. Army Corps of Engineers Cold Region monograph (Michel, 1970). The ice thrust force is determined based on a conservatively assumed hourly temperature rise of 5°F with no lateral restraint and with solar energy consideration. The calculated forces on the retention pond structures are presented in Section 3.8.4.3.1. 2.4.7.2.3 Drag Forces Due to Wind The wind drag force on the ice surface is determined by considering a wind speed ranging from 40 to 60 mph for winter months over the 24-inch thick ice in the pond. The drag coefficient is evaluated considering turbulent flow over the ice (smooth surface) and using the drag coefficient values given in Schlichting (1968). The drag force computation assumes that the entire pond surface is covered with ice and that the thrust force is transmitted to the structure, as discussed in Section 3.8.4.3.1. 2.4.7.3 River Structures The water supply intake and water discharge structures on the Missouri River are not safety-related structures, but they are subject to varying amounts of floating ice during the winter low-flow season. River gauge records show that some freezing of the Missouri River between Boonville and Hermann can be expected about every fourth winter. This freezing, however, is not anticipated to cause ice flooding to exceed the probable 200-year high water elevation established for final design of the intake structure. Ice or ice flooding will be no problem at the discharge structure, as the warm discharge water will keep the outfall open. 2.4.8 COOLING WATER CANALS AND RESERVOIRS 2.4.8.1 Canals No canals are present at the site. 2.4.8.2 Reservoirs The UHS retention pond is the only reservior on the site. The pond is excavated to a total depth of 22 feet with side slopes of 3 to 1. The storage capacity of the pond at the flO Ill 1al water level of Elevation 836.0 feet is 56.03 acre-feet. During emergency shutdown, the pond water is utilized to supply makeup water to the UHS cooling towers. Description of the UHS is provided in Section 9.2.5. Hydrologic conditions during PMP and coincident 2.4-25 Rev. OL-19a 7/12

CALLAWAY- SA

                                                                                ~re.

wind wave activities are discussed in Section 2.4.8.2.1. Considerat obable maximum winds is discussed in Section 2.4.8.2.2. These activities aluated at a water level corresponding to Elevation 836.0 feet which.JA'ai th& iRitiakdesign-AefR"Utl water level of the UHS. f r /-Ae. 2.4.8.2.1 Probable Maximum Flood Design Considerations The information on PMP as provided in Section 2.4.2.3 is applicable to the UHS retention pond. For the UHS retention pond with a water level of Elevation 836.0 feet, the probable maximum water level due to a 48-hour PMP on the pond and outflow over the 6-foot wide, broad-crested weir spillway reaches Elevation 837.7 feet, as discussed in Section 2.4.8.2.1.1. A sustained windspeed of 40 mph coincident with the maximum water level results in a maximum run up on the riprap-covered slopes to Elevation 838.3 feet, as discussed in Section 2.4.8.2.1.2. 2.4.8.2.1.1 Water Level Determination The UHS retention pond, which provides water for emergency plant shutdown, is a Category I safety-related structure. Its hydrologic design is controlled by PMP and associated water level. The 48-hour PMP on the pond of 35 inches is distributed as shown in Table 2.4-7, utilizing Hydrometeorological Report 33 (U.S. Weather Bureau, 1956a). The precipitation is redistributed using 1/2-hour time increments and arranged to maximize the water level using the U.S. Army Corps of Engineers Procedure (U.S. Army Corps of Engineers, 1965a). The resulting rainfall is converted to equivalent inflow discharge to the pond and is routed through storage to determine the maximum resulting water level. The outlet structure, which is a 6-foot wide, broad-crested spillway (Figures 3.8-16 and 3.8-17), has a crest elevation of 836.5 feet. The discharge coefficient used in the weir equation is 2.65 (Brater and King, 1976). The flood routing is based on the initial pond water level at the spillway crest. Flood routing indicates that the probable maximum water level in the pond will reach Elevation 837.7 feet with a peak outflow of about 30 cfs based upon an initial level corresponding to 836.0 feet. 2.4.8.2.1.2 Coincident Wind Wave Activity Discussion in this section is limited to consideration of the UHS retention pond since it is the only safety-related hydrologic element at the site which is subject to wind wave activity. Wind wave activity does not constitute major concern in the design of the UHS retention pond because the pond has relatively short dimensions with riprapped side slopes. The hydrometeorological events considered in the analysis are a sustained wind speed of 40 mph occurring coincidentally with the probable maximum water level at Elevation 837.7 feet. The UHS retention pond has a water surface length of 636 feet, a width of 2.4-26 Rev. OL-19a 7/12

CALLAWAY- SA The probable maximum wind was determined based on the method of Them (1968). Them used meteorological data collected over a 21-year period from 150 monitoring stations to provide isotachs of the 0.50, 0.1 0, 0.04, 0.02, and 0.01 quantiles for the annual extreme fastest wind speed for the United States. Them then provided an empirical method to use these data to determine the fastest wind speed for other quantiles at any U.S. location. This method was used to determine the fastest wind speed likely to occur at the 0.001 quantile; the 1000-year mean recurrence interval. The data provided by Them do not allow the calculation of the 95 percent confidence interval for estimates of wind speed at this quantile. Since Them's isotach's and statistics are based on a specific 21-year data base, more recent data cannot be taken into account, except as a comparison of actual extreme speeds with those predicted by Them. As an example, the fastest mile wind speed recorded by the National Weather Service station at Columbia, Missouri from August 1889 through 1979 (a 90-year period) was 63 miles per hour. This compares with values determined from Them's method of 72 miles per hour (50-year recurrence interval) and 85 miles per hour (1 00-year recurrence interval). 2.4.8.2.2.2 Wave Action In the analysis of wave action, an extreme wind sp ed with a 1,000-year return interval occurring coincidentally with a UHS retention pen ater level corresponding to an elevation of 836.0 feet is considered a conservatively postulated combination of hydrometeorological events. This design wind, as discussed in Section 2.4.8.2.2.1, has a 1-minute average speed of 118 mph. Using the methods described in Section 2.4.8.2.1.2, the waves generated by the above hydrometeorological combinations have a significant wave height, H5 , of 2.4 feet, a length of 32 feet, and a wave period of 2.5 seconds. The maximum wave height is 4.0 feet. For a riprapped slope of 3 to 1, designed to resist this wave action, the maximum wave run up is calculated to be 2.0 feet. Including the wind setup value of 0.1 feet, the top of the run up would reach Elevation 838.1 feet. The riprap thickness was determined using the procedure outlined in the U.S. Army Corps of Engineers, EM 1110-2-2300 (1971 b). A double filter, designed according to the criteria presented in U.S. Bureau of Reclamation, Design of Small Dams (1973), is required to provide a free-draining transition to minimize effects of erosion. The riprap and filter design configuration for the pond slope is shown on Figure 2.4-31. The rip rap stone layer thickness is 18 inches. The double filter thickness is 12 inches consisting of 6 inches of fine filter and 6 inches of coarse filter. The protection extends from the top of the slope to Elevation 828.0 feet. The gradation requirements for the 2.4-28 Rev. OL-19a 7/12

CALLAWAY- SA low river flow or Water Treatment Plant Clearwell low levels and the requirement for reducing or shutting down the plant operation. Preliminary calculations indicate that the tower basin would hold enough water to allow 1 hour's full-capacity operation for each foot of basin depth. If blowdown were to be stopped, full operation would be maintained for 1-1/2 hours for each foot of basin depth. Under the latter condition, a 6-foot deep basin would allow nearly 9 hours of operation during periods of the highest evaporative cooling requirements. A low-level alarm would be provided to the main control room operators as soon as the basin fell below the normal operating level. Continuous level-indication would also be provided for the operators so that the rate of level decline could be established and exact lead times determined. If it were determined that the water flow would not meet plant requirements (about 1 hour before the cooling tower basin water supply was exhausted), the operators would initiate plant shutdown and the cooling procedures culminating in the use of the essential service water systems and the UHS. 2.4.11.5.3 Plant Water Effluent The plant water effluent will consist mainly of the blowdown from the cooling tower (Figure 2.4-15). The effluent will enter the Missouri River from a submerged pipe, terminating at the left bank, located about 100 feet downstream of the water supply intake. Discharge velocity will be sufficient to mix the effluent with the river water, for a 7-day, 10-year low flow condition (9,900 cfs, Table 2.4-1 0), in order to minimize thermal effects. These anticipated discharge conditions meet the existing Missouri Water Quality standards. 2.4.11.6 Heat Sink Dependability Requirements The UHS retention pond will be the source of water for the essential service water systems (Section 9.2.1 ). The plant water requirements discussed in Section 2.4.11.5 are supplied from the Missouri River. The low flow conditions in this river do not influence the dependability of the UHS retention pond. Assuming minimum required initial level the pond is designed to provide 30 days' water supply with a ~reater tReR 26 J90FseA~argin without makeup during the worst 30 days :lfN~~ 1:l'/, Prediction of the UH cooling tower evaporation is based upon the unit undergoing a design basis LOCA. * * * ~l:IRetioR. The t:tse ef tRia fuRetieA iA salst:~latiR!!J evaJ90I atio1 1 is eeAse~etive !iRee it tends to O"eFe&tiFRate eoeJ9eFetieR less (RyaA a Ref llerle1, J8FI, 1Q7~). The meteorological data for 30 days of maximum evaporation are obtained from the records at Columbia, Missouri, from July 2, 1954 to July 31, 1954. The wind speed used is based on the maximum 1-day wind speed of 12.8 mph, which is higher than the average 30-day wind speed of 10.5 mph. 2.4-37 Rev. OL-19a 7/12

INSERT 6 Pond evaporation for 30 days is based on the model described in calculation NAI-1508-00 1 which uses a wind speed function that accounts for quiescent evaporation taken from C00-2224-1, "Generic Emergency Cooling Pond Analysis: Emergency Cooling Pond Analysis and the Theoretical Basis of the GEPA Computational Program," J. E. Edinger, et al, University of Pennsylvania, School of Engineering and Applied Science, Civil Engineering, May 1972 - October 1972.

CALLAWAY- SA indicates that total water requireme ts for 30 days, including cooling tower evaporation seepage and other water uses, pan evaporation, and cooling tower drift, would be . acre-feet. This is less than the . acre-feet usable pond volume contained above Elevation feet. This elevation (low water level) provides the 8-foot minimum submergence or the ESW pumps. Details of the evaporation and transient temperature analys s are presented in Section 9.2.5. P34-.tJ The pond is excavated bela e surrounding plant grade and thus cannot lose water due to dam failure. Flooding of the pond and related structures is precluded since the pond is about 280 feet above the PMF level in the Missouri River and site grading is designed to direct all runoff, including that from probable maximum precipitation, away from the pond. Slope stability during seismic events and seepage analysis are presented in Sections 2.5.5 and 2.5.4.6, respectively. Ice will form on the surface of the UHS retention pond during severe winter periods, as discussed in Section 2.4.7. No provision is made to prevent ice formation on the pond because the surface of the ice will be about 24 feet above the ESW pump suction end. When the ESWS operates with such ice cover, water from the pond is withdrawn from below the ice formation and the warm water returned from the power block is discharged near the pond bottom. This arrangement precludes any interruption of water supply to the ESWS. Potential of ice submergence at the ESWS intake due to currents induced from the pump operation is also analyzed. This analysis considers a pond water depth of 18 feet at a pond level of Elevation 836.0 feet, along with ice thicknesses corresponding to different recurrence intervals up to 100 years. In the presence of a 24-inch ice cover (Section 2.4. 7 .2.1 ), the resulting induced velocity due to a two-unit pumping rate of 60,000 gpm (assuming all four pumps operating) is about 0.13 fps. The corresponding Froude number of the approaching flow is 0.004. For this Froude number and utilizing the method of Uzner (Uzner and Kennedy, 1972), there is no potential for ice flows to submerge. Thus, there is no possibility for pump blockage by ice. With the cancellation of Unit 2 this analysis remains conservative. The potential for frazil ice formation in the pond is also analyzed. Frazil ice will form when: (1) the meteorological conditions are such that the pond will become supercooled, (2) there is a high degree of turbulence in the pond, and (3) nuclei are present to initiate formation (Muller, 1978). The meteorological data at Columbia, Missouri, were researched to find periods of rapid change in meteorological conditions (drop in air temperature below freezing, minimal cloud cover, low relatively humidity) concurrent with strong and sustained winds. An analysis of heat transfer, using the method of Paily et al. (1974), reveals that under the meteorological conditions selected, the degree of supercooling in the pond is greater than 0.01 C/hr. This is sufficient for frazil ice formation (Williams, 1959). However, the turbulence created by 40 mph wind-wave activity, based on maximum 3-hour winds observed at Columbia, Missouri, is insufficient to extend the 2.4-38 Rev. OL-19a 7/12

CALLAWAY- SA supercooling to more than a 1- to 2-foot depth below the surface of the pond (Carstens, 1970). The frazil ice formation is limited to this layer. The potential offrazil ice withdrawal into the ESWS pumps is analyzed considering a/es{J,n pond water depth of 18 feet, a skimmer wall at the pump intake, an average velocity in 1 the pond due to a two-pump operation of 0.638 fps, and a water temperature of 32°F. Using the method of Harleman (Harleman and Stolzenbach, 1967), the analysis reveals that no frazil ice will be withdrawn into the ESWS pumps. Thus, the clogging of the ESWS strainers by frazil ice is precluded and the normal operation of the ESWS is assured. The fire protection system described in Section 9.5.1 does not draw water from the UHS retention pond. The ESW system does provide the water source for a fire hose station in each ESW pumphouse room. Applicability and compliance with Regulatory Guide 1.127 is discussed in Table 2.4-14. 2.4.12 DISPERSION, DILUTION, AND TRAVEL TIMES OF ACCIDENTAL RELEASES OF LIQUID EFFLUENTS IN SURFACE WATERS 2.4.12.1 Accident Effects 2.4.12.1.1 Introduction Analysis of accidental releases of liquid radwaste, as related to existing or potential future water users, must consider the ability of both the surface- and ground-water environments in dispersing, diluting or otherwise concentrating radioactive effluents. Consideration of an accidental release whereby the liquid radwaste enters the ground-water environment is addressed in Section 2.4.13.3. For the analysis of accidental releases of radioactive liquids from the Callaway Plant site to surface waters, a postulated rupture of the refueling water storage tank, which contains the highest curie inventory of the radioisotopes of relatively long half lives, was assumed. The tank is located between the radwaste building and the turbine-reactor complex. Pertinent details of this tank are presented in Table 2.4-15. The event of a failure producing a subsequent release of the liquid radwaste in the refueling water storage tank to the Missouri River was considered. It was postulated that the liquid content of the refueling water storage tank above 840 feet MSL, corresponding to a volume of 357,700 gallons, would spill into the local Callaway Plant drainage system. It was conservatively assumed that this radwaste would reach the Missouri River without dilution, seepage, or evaporation losses, and be essentially nondecaying. It was further conservatively assumed that the total volume of radwaste would be instantaneously released as a slug discharge at the river bank, which would maximize local concentrations in the Missouri River. 2.4-39 Rev. OL-19a 7/12

CALLAWAY- SA 2.5.5.1 Slope Characteristics 2.5.5.1.1 Permanent Slopes The UHS retention pond, shown on Figure 2.5-106, is 334 feet by 684 feet in plan dimensions (at top), with 3:1 (horizontal to vertical) side slopes. Prior to excavation, the existing natural ground sloped from elevations 848 feet in the south (plant northwest) corner of the pond to 834 feet in the north (plant southeast) corner, as shown on Figure 2.5-1 06.1. The finished grade elevation around the pond is generally 840 feet, rising to J .- 845 feet in the south (plant northwest) corner, as illustrated on Figure 2.5-106. t1 es'Jh maximum of 6 feet of fill was placed on the northeast (plant south) portion o e pond perimeter to bring the grade to the required elevation. The extent of this fill 1s shown on Figure 2.5-106.1. The bottom of the pond is at elevation 818 feet, with ater level at 836 feet and the crest of the outlet structure at 836.5 feet. After 30 days of operational use of water from the pond, the water level will decrease to elevation -i-28. ~feet, assuming that there is no pond replenishment during that time. ?;;J.I .. 0 Typical pond slopes are shown on Figure 2.5-106. Rip rap (Section 2.4.8.2.2.2) extends from the top of the slope to an 8-foot horizontal bench at elevation 828 feet. The pond has several structures built into and adjacent to the slope (see Figure 2.5-1 06). These are the ESWS pumphouse and apron slab, the pond outlet structure, the makeup water line, and the ESWS discharge pipes. The cooling tower for Unit 1 is approximately 75 feet east of the top of the pond slope. the location of the cooling tower excavation relative to the pond excavation is shown on Figure 2.5-121. Details of the field boring program at the pond site are provided in Section 2.5.4.3.1; boring locations are shown on Figure 2.5-106. Menard pressuremeter tests performed in a boring within the pond area are described in Section 2.5.4.2.2.2. Geologic features at the site are described in Section 2.5.1.2. As noted in Section 2.5.4.3.2, geologic mapping of the pond excavation is continuing as excavation progresses. Mapping of the pond slopes completed to date has revealed no zones that pose a seepage threat. Ground-water conditions existing at the site prior to pond excavation are described and discussed in Sections 2.4.13 and 2.5.4.6. Water level conditions assumed for analyses varied with the slope stability cases considered and are described in Section 2.5.5.2.1. As noted in Section 2.5.4.6, although the ground-water table (top of saturated zone) is raised locally in the vicinity of the completed UHS retention pond, permeabilities are low (Section 2.5.4.2.3.1 ), so that there is no significant influence on the ground-water table in the plant area. The pond itself is contained above the Graydon chert conglomerate layer (Figure 2.5-121 ). The low permeabilities of the glacial and postglacial materials (see Table 2.5-15) preclude any significant seepage loss from the pond (Section 2.5.4.6). Therefore, it was considered unnecessary to seal the pond side slopes and bottom with an impervious blanket. The following justification for this conclusion was presented in our response to NRC Question 241.2C. 2.5-166 Rev. OL-19a 7/12

CALLAWAY- SA (ii) Seepage loss from the UHS retention pond was estimated by the construction of flow nets (Reference 2) based on the following: (See Figure 2.5-106 of the Callaway Site FSAR Addendum)

1. A pond slope of 3(H): 1(V) and no liner at the bottom or the sides of the pond.

2. ~JorFAekPond water level at El. 836.

be..ri!th

3. Pond top f1f slope at El. 845, bottom of pond at El. 818.

4. Impervious (horizontal) layer below the pond bottom at El. 789.

5. Permeability of the soil k = 2x1 o- 5cm/sec. This permeability for the Graydon chert conglomerate was selected for the assumed homogenous isotropic soil since it was the highest field permeability for all soil materials present in the pond area. This was done to provide the needed conservatism in sizing the pond against seepage.

6. Ground water away from the pond at Case (1) El. 825 (0.8 acre-feet seepage loss), Case (2) El. 812 (1.3 acre-feet seepage loss).

The conservatively high estimates of the seepage analyses resulted in a total seepage loss of 0.8 to 1.3 acre-feet in 30 days. For sizing the pond, among other factors, a seepage loss of 1.3 acre-feet was assumed for 30 days. In addition, the pond sized to provide a f j margin above the total water requirements fo 0 days following a LO A. The conservatism of the data base for perm ability of soils can be se n in the table below: f.r I:J."/, Summary Of Coefficients of Permeability, k, (em/sec) Material Field Tests Laboratory Tests Modified Loess 3 x 1o-6 5 x 1o-7 Accretion-Giey 2 x 1o-7 2 x 1o-8 Glacial Till 5 x 1o-6 5 x 1o- 8 to 5 x 1o-5 Graydon chert conglomerate 2 X 10-5 3 x 1o-8 k Used in seepage analysis = 2 x 1o- 5 em/sec. 2.5-167 Rev. OL-19a 7/12

CALLAWAY- SA

4. Earthquake, Maximum Pond, 0.25 g 1.1 Acceleration

5. Earthquake, Partial Pond, 0.25 g 1.1 Acceleration PaFtial J90R8 level is tRe level thet vuill 1esult after 20 says of Of90FatioR l:J&iA~ \Vater fro1 11

=iRe UIIS retel ltiol, peru!!, 8SStJFflil'lr:J 1'10 I'O"eJ FeJ9Ie.,ishl,,e.,t eJttFil'l~ tRe 30 says. IR tRiS seRetitieR, tRe f90ReJ leoel is eJr~ritR eJe*(r,rl'l frem ti-le RBFfl'lal Of9eFatiRg le,:el ef elevatio11 836 ..feet to elevatieR a2~ feet, 6 feet aeeve f30ReJ eettemthis partial pond condition approximates the conventional rapid drawdown situ ion for the dug pond.

avs£Kr 7 In addition to the above conditions, the slopes were verified for end of construction and maximum pond conditions for a representative live load case that could occur during construction or during future operations; this load comprised a uniform surcharge of 250 pounds per square foot. Furthermore, the slopes were verified, under seismic conditions, for construction of plant support buildings with footings 65 feet from the top edge of the pond berm with a 15 kip per foot load.

Two sections (Figure 2.5-115) were selected for analysis. The locations of these sections, shown on Figure 2.5-106, are representative of extreme conditions in the pond area. At all locations, the pond slopes are 3:1 (horizontal to vertical). Section X-X' is representative of conditions at the southwest (plant north) end of the pond where the maximum amount of cut is located. Section Y-Y' is representative of conditions at the northeast (plant south) end of the pond where the maximum amount of fill was placed. These sections are based on the boring data and subsurface profiles presented in Section 2.5.4.3. The ground-water and pond level combinations used for the stability analyses represent conditions that will result in conservative estimates of factor of safety. These levels are illustrated on Figures 2.5-115.1 through 2.5-115.6 and summarized in Table 2.5-53. The in-situ soil strength parameters assumed in the slope stability analyses were discussed in Section 2.5.5.1.1 and are presented in Table 2.5-15. The fill properties are based on the remolded strengths of the modified loess described in Section 2.5.4.2 and shown in Tables 2.5-17 and 2.5-21. The accretion-gley material is moderately susceptible to swelling. For the end of excavation condition, soil strength parameters based on tests without swelling are used. For the other conditions, assumed strengths are reduced to account for anticipated swelling. As indicated in Section 2.5.4.2.3.2.1, results from in-situ Menard pressuremeter tests indicate that the undrained strength parameters used in the stability analysis are conservative. Also, the drained strength parameters of the Graydon chert conglomerate underestimate the in-situ strength of the material due mainly to the effects of sample disturbance. 2.5-171 Rev. OL-19a 7/12

INSERT 7 The partial pond level used above is the level equivalent to an elevation of 823 feet, 5 feet above the UHS pond bottom. In this condition, the pond level is drawn down from the design level of elevation 836 feet to elevation 823 feet.

CALLAWAY- SA 3.5.2.3 Ultimate Heat Sink (UHS) Cooling Tower The UHS cooling tower is a tornado-resistant, reinforced concrete structure located as shown in Figure 3.5-1. A perimeter missile shield protects the tower shear walls from tornado missiles and prevents tornado missiles from entering the fill areas of the cooling tower. Exterior and interior walls divide the tower into four cells, providing horizontal tornado missile protection and support for the vertical tornado missile protection above the fan blades. The personnel door at elevation 2035 feet is a tornado-resistant, missile door. Attached to the UHS cooling tower are two tornado-resistant, reinforced concrete electrical rooms which contain pipes, valves, and electrical equipment. Tornado-resistant missile shields protect the inlets and outlets of the ventilation system at the roof elevation. Tornado-resistant covers protect the roof openings. The personnel door at grade is a tornado-resistant, missile door. Figures 3.8-12 through 3.8-14 show the tornado missile protection for the safety-related penetrations in the UHS cooling tower and electrical rooms. 3.5.2.4 The UHS retention pond, which contains emergency makeup towers, is an excavation in existing and fill soils. The-J~~~MI'ta / f-+~afeet. The ESWS intakes are located feet below the~FMfi~.JPffil~.a protected pumpwells. The ESWS discha ge piping is buried below grad cooling towers to the pond, where it term nates at discharge structures. concrete discharge structures are positi ed at the bottom of the pond a sufficiently protected from tornado-miss* e damage by being submerged Je..si~Y\ /eYe)

                                                 ;;tS                                       o The reinforced concrete outlet structure is a slab on grade. This structure and non-Category I headwall structure for the pond makeup water are not required to be tornado missile-resistant because they serve no safety-related function in accordance with the requirements of 10CFR50, Appendix A, General Design Criteria 4.

3.5-3 Rev. OL-18 12/10

CALLAWAY- SA 2 inches deep with 2 1/8 inches clear openings) cover the remaining area between these slabs and the vertical walls (which protect the fan blades from horizontal tornado missiles) and protect the air outlets of the tower from tornado-generated debris. Plans and sections are shown on Figures 3.8-12, 3.8-13, and 3.8-14. Attached to the UHS cooling tower are two tornado-resistant, reinforced concrete electrical rooms which contain pipes, valves, and electrical equipment. Tornado-resistant missile shiel~rotect the entrances and exits of the ventilatio~ 11 1 J., system at the roof elevation. I '1 iJ- Aef, 5' --rh!~~ITJ Pos-u~. 1e-ve_ -1 1.r m~~ e,+ ( fllJfhlnA I Ll n .J rcH""enWh

                                                                 , h~ l>e+wee*" ve 1.r L 1                           -

3.8.4.1.5 Ultimate He Si (U Hs}Rftenifon~r/J' and AuxitYary~ru~s 1cor-. IS"\ rr. e. 1o ~ i__hr 1-/ S C4 "1~ rt'hJ, tt.-n'~"" tev~ 1 The UHS retention pond hich contains water for the UHS cooling tower is an excavation in existing and *

pproximate dim nsions of the pond at grade Elevation 1999.5 feet are 330 by 680 feet. The bottom o~ the pond Elevation is 1977.5 feet, and the side slopes are 3 horizontal to 1 vertical. side slopes are protected by riprap from the surrounding grade elevation to Elevatio . Two submerged, reinforced concrete discharge structures discharge water into the pond from the UHS cooling tower. A reinforced concrete outlet structure is provided for outflow from the pond. A 14-inch-diameter, non-Category I make-up pipe
make-up water manually for the pond. Typical plans and sections are shown on Fig res 3.8-15, 3.8-16, and 3.8-17. Additional information is provided in Section 9.2.5. _1 /

f r~ v i'dr~--..!" ()orlh~ 3.8.4.1.6 ESWS Supply Lines Yard Vault A redundant, below-grade, reinforced concrete ESWS supply lines yard vault houses the transition of ESWS stainless steel piping to polyethylene piping. The ESWS supply lines yard vault consists of two compartments, one for each train separated by reinforced concrete. Watertight boot seals are installed in each penetration sleeve, and the gap between the piping and the penetration sleeve is filled with RTV foam to seal the yard vault. Redundant, reinforced concrete, tornado resistant manholes are provided to permit inspection and maintenance of the piping. Removable manhole covers are bolted down to prevent their movement in the horizontal and vertical directions. ESWS supply lines yard vault plans and sections are shown on Figure 3.8-19. 3.8.4.2 Applicable Codes. Standards. and Specifications All nonstandard Category I structures at the site are designed in accordance with the codes, standards, and specifications listed in Standard Plant FSAR Section 3.8.3.2, with the exception of NRC Regulatory Guide 1.46 and BN-TOP-2, which are not applicable. In addition to those documents listed in Standard Plant FSAR Section 3.8.3.2, the following documents are also used. Compliance with the NRC Regulatory Guides listed is discussed in Appendix 3A. 3.8-3 Rev. OL-18 12/10

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i.-2--+------+-- LONGITUDINAL CROSS SECTION THRU E.S.W.S. PUiviPHOUSE H. P. !::L.1969'-6" EL.1977'-6" UNION ELECTRIC COMPANY CALLAWAY PLANT FINAL SAFETY ANALYSIS REPORT FIGURE 3.8-2 E-W SECTION E.S.W.S. PUMPHOUSE REV. 4 7/12

CALLAWAY- SA Onsite Meteorological Monitoring Programs for Nuclear Power Plants DISCUSSION: UE complies with the recommendations of this regulatory guide, with the following exceptions: (a) The meteorological tower is not sited at the same elevation as finished plant grade as recommended in section 3 of the regulatory guide. Refer to Site Addendum Section 2.3.3.1.2 (b) The inspection frequencies for the tower guyed wires and anchors will be per the tower vendor recommendations in lieu of the recommendations provided in section 5 of the regulatory guide. Refer to Site Addendum Section 2.3.3.1.1 through 2.3.3.1.7, which contain elements of a graded quality assurance program for meteorological monitoring, and Sections 2.3.4 through 2.3.5, which describe the methods for analyzing meteorological data. REGULATORY GUIDE 1.27 REVISION 2 DATED 1/76 Ultimate Heat Sink for Nuclear Power Plants DISCUSSION: -5: Refer to Site Addendum Section 9.2.5 and Table 9.2-{)"" REGULATORY GUIDE 1.28 Quality Assurance Program Requirements (Design and Construction) DISCUSSION: Refer to the Union Electric Company Operational Quality Assurance Manual. REGULATORY GUIDE 1.30 Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electronic Equipment (Safety Guide 30) DISCUSSION: Refer to the Union Electric Company Operational Quality Assurance Manual. REGULATORY GUIDE 1.33 3.A-3 Rev. OL-18 12/10

CALLAWAY- SA LIST OF TABLES Number 9.2-1 Service Water System Component Data 9.2-2 Essential Service Water System Component Data 9.2-4 Ultimate Heat Sink Component Data 9.2-5 Design Comparison to Regulatory Positions of Regulatory Guide 1.27, Revision 2 Dated January 1976, Titled "Ultimate Heat Sink for Nuclear Power Plants" 9.2-6 Ultifflate lleet Si~l< Si~~le Failure Aflelysis De /e-1-e/ 9.2-7 Deleted 9.0-iii Rev. OL-14 12/04

CALLAWAY- SA 9.2.1.1.2.2 Component Description SW pumps - The three 50 percent system capacity service water pumps are single-stage, double-suction, vertical, constant-speed dual-volute centrifugal type. Each pump is equipped with a hydraulically operated butterfly valve on the discharge for isolation of the pump from the system. The valve is also programmed for quick closure to prevent reverse flow of water and pressure surge in the event of a pump trip. Refer to Table 9.2-1 for SW system component data. Controls are provided to automatically start the remaining pump if a protective relay trips any one of the running pumps. Design data for the SW components outside the Power Block are provided in Table 9.2-1. 9.2.1.1.3 Safety Evaluation The SW system performs no safety-related function. The SW system is not required for safe shutdown of the plant. 9.2.1.1.4 Tests and Inspection Refer to Section 9.2.1.1.4 of the Standard Plant FSAR. 9.2.1.1.5 Instrumentation Applications Starting and stopping the service water pumps is a manual operation from the main control room. Upon loss of a service water pump, a backup pump automatically starts. ~~--J- 9.2.1.2 Essential Service Water System 9.2.1.2.1 Design Bases 9.2.1.2.1.1 Safety Design Bases Section 9.2.1.2 of the Standard Plant FSAR provides the general safety design bases met by this system. SAFETY DESIGN BASIS ONE -The components of the ESW system are sized to deliver, as a minimum, the required flow rates of water for safe shutdown of the plant. Continuation of the minimum required cooling water flows to the engineered safety features equipment served by the system and continuation of the availability of water supplies for the Auxiliary Feedwater System, for the spent fuel pool standby makeup, and for makeup to the Component Cooling Water System are essential to ensure safe operation and safe shutdown of the plant. 9.2-2 Rev. OL-19a 7/12

CALLAWAY- SA The components of the system are designed to meet seismic Category I requirements and the single failure criterion, as discussed in Section 9.2.1.2 of the Standard Plant FSAR. SAFETY DESIGN BASIS TWO - The ESW system is designed so that postulated environmental occurrences cannot impair the system's ability to meet its functional requirements. Failure of any adjacent nonseismic Category I structure will not constitute a hazard to the ESW system. 9.2.1.2.1.2 Power Generation Design Basis The components of the ESW system located outside the Power Block have no power generation design basis. 9.2.1.2.2 System Description 9.2.1.2.2.1 General Description The ESW system outside the Power Block, shown in Standard Plant FSAR Fig. 9.2-2 Sht. 3, consists of pumps, pump prelube storage tanks, piping, self-cleaning strainers, valves, and associated instrumentation. The system consists of two 100-percent redundant flow paths with one pump supplying cooling water to each flow path. Each flow path is fed from the ultimate heat sink retention pond (refer to Site Addendum Sections 9.2.5 and 3.8.4.1.5). The ESW pumps are located in a seismic Category I pumphouse (refer to Site Addendum Section 3.8.4.1.1 ). Each flow path is protected from internally generated missiles, jet impingement, and flooding that may result from cracks in adjacent flow path piping by interior walls. Equipment protection from high winds and floods is discussed in Site Addendum Sections 3.3 and 3.4, respectively. Tornado missile protection is discussed in Section 3.5.2. The ESWS pumphouse forebay inlet openings are intrinsically protected from blockage by credible tornado missiles or debris. Each individual opening is 8 feet wide by 7 feet 6 inches high. As designed, the ESWS is capable of withstanding the blockage of a single pumphouse forebay inlet opening. System redundancy provides assurance that the remaining unblocked train will provide the necessary flow for safe shutdown. This is based on the single failure criterion listed in Standard Plant Section 3.1.2. Therefore, tornado debris must completely block both forebay openings to affect the system. However, as shown on Figures 3.8-1 and 3.8-2 for the ESWS pumphouse, a concrete stop log guide is located between each opening. These guides project 3 feet, 3 inches into the forebay. The total width across two adjacent forebay openings is 31 feet. The ASFR'U!)\UHS retention pond water level is 26 feet above the forebay floor. Therefore, des~, 9.2-3 Rev. OL-19a 7/12

CALLAWAY- SA no credible tornado debris can completely cover both forebay inlet openings blocking all flow to the ESW pump suction. 9.2.1.2.2.2 Component Description ESW PUMPS - Each of the two ESW pumps has a capacity of 100 percent of the flow rate required during accident conditions. The pumps are of the vertical centrifugal type. Pumps are sized to include an additional one percent margin on the flow at the design head to accommodate degradation of performance due to impeller wear. ESW PUMP PRELUBE STORAGE TANKS- Each ESW pump is provided with a prelube storage tank. The tank supplies the pump lineshaft bearings with water to prevent the bearings above the pit water level from running dry during startup. Tank size is based on supplying a minimum of a 5-minute supply of water, at 6 gpm, with no makeup from the pump discharge line. When the pump is operating, the bearings are lubricated by the pumped fluid. ESW SELF-CLEANING STRAINERS - One self-cleaning strainer is provided for each ESW flow path. One hundred percent of the ESW flow is filtered through the strainer element. On high differential pressure, the strainer element is automatically backwashed to eject the accumulated debris. PIPING AND VALVES -Yard piping outside the Power Block is carbon steel, stainless steel, or polyethylene. Two entirely separate and redundant lines are provided. Design data for the ESW pumps, prelube storage tanks, self-cleaning strainers, and piping and valves is provided in Table 9.2-2. Codes and standards applicable to the ESW system are listed in Table 3.2-1 of the Standard Plant FSAR. The ESW system outside the Power Block is quality group C and is seismic Category I. 9.2.1.2.3 System Operation Following an accident which results in generation of an SIS and/or loss of offsite power, the ESW system is automatically isolated from the SW system by motor-operated valves. Both ESW pumps are automatically started by the emergency diesel load sequencer. Pump A starts 32 seconds and pump B starts 37 seconds after receipt of the SIS or loss of offsite power signal. The pumps supply cooling water from the ultimate heat sink to the Power Block components. After cooling the equipment, the heated water is returned to the ultimate heat sink cooling tower. Refer to Standard Plant FSAR Section 9.2.1.2.2.3 for a description of the system operation in the event of loss of only one Class-1 E 4160-V bus. The ESW system provides emergency suction supply to the Auxiliary Feedwater System (AFS) upon failure of the condensate storage tank. In addition to the SIS and loss of offsite power signals, the ESW pump start logic includes the open signal to the ESW supply valves to AFS (auxiliary feedwater low suction pressure, LSP). The auxiliary 9.2-4 Rev. OL-19a 7/12

CALLAWAY- SA feedwater LSP signal also closes the ESW/SW system isolation valves. This assures ESW supply to the AFS following an SSE without an accompanying accident or loss of offsite power (refer to Standard Plant FSAR Section 10.4.9). Following an SSE, operator action lines the discharge of the ESW system to the ultimate heat sink. The ESW pump discharge piping includes a vent line with a normally open, motor-operated valve. This valve remains open until 15 seconds after pump start. This vents the air in the pump column and discharge piping to prevent system water hammer. The prelube storage tank is continuously supplied with water by a connection on the ESW pump discharge, downstream of the check valve and self-cleaning strainer. Tank level can be automatically maintained by action of the supply line to the pump lineshaft bearings and stuffing box, and the open tank overflow, and by the manual setting of the globe valve in the tank supply line. The tank provides water to the lineshaft bearings and stuffing box continuously (provided that the discharge line is pressurized) even during periods when the ESW pumps are idle. The discharge lines are normally pressurized by the SW pumps. When the ESW pump is running, flow in the supply line from the tank reverses and discharges through the overflow. If an undetected failure of the SW pumps is assumed, this could result in loss of prelube supply prior to operator action to start the ESW pump. However, the pump will start and continue to run satisfactorily in an emergency situation with dry bearings. Bronze lineshaft bearings are provided in the ESW pumps because of this possibility. The alternate bearing material (cutless rubber) would have a greater tendency to seize during this transient. The self-cleaning strainers filter the supply water to the Power Block. High differential pressure caused by accumulated debris on the strainer element is corrected automatically by backwashing the element to the ultimate heat sink. 9.2.1.2.4 Safety Evaluation Safety evaluations are numbered to correspond to the safety design bases in Section 9.2.1.2.1. Safety evaluations for the general safety design bases are provided in Standard Plant Section 9.2.1.2.4. SAFETY EVALUATION ONE -The ESW system services two identical trains of engineered safety features equipment which are required for safe shutdown of the reactor. Only one train of the redundant plant components is required for the safe shutdown of the plant after any postulated accident condition. Water is supplied to each train of components by a separate pump and header. Both essential service water trains are capable of individually supplying the required cooling water flows to meet the single failure criterion. The single active failure analysis is presented in Table 9.2-5 of the Standard Plant FSAR. This provides the basis for the technical specifications with regard to limiting conditions for operation and surveillance. 9.2-5 Rev. OL-19a 7/12

CALLAWAY- SA SAFETY EVALUATION TWO - The ESW pumps, prelube storage tanks and self-cleaning strainers are located in a seismic Category I pumphouse which is designed to protect the pumps against adverse environmental occurrences of tornado, missiles, and safe shutdown earthquake. Other parts of the system located outside the Power Block are either buried underground or located in seismic Category I structures. All structures and components of the system are located so that the failure of any nonseismic Category I structure would not constitute a hazard to the ESW system. The location of the ESW system structures and components is such that:

a. It is adequately separated from all no?feismic Category I structures.

b. The essential service water lines and seismic Category I electrical duct banks are placed below noreismic lines at points of intersection, or are otherwise analyzed to be a ceptable considering failure of the nonseismic lines.

c. It precludes any hazard to the system from the failure of man-made structures, such as the failure of slopes or the postulated rupture of storage tanks.

The seismic Category I essential service water pumphouse, designed as a unitized redundant facility, is located approximately 575 feet south-southeast of the centerline of the reactor as shown in Figure 1.2-44. The routing of the essential service water pipe lines, as shown in Figure 1.2-45, is designed to avoid interferences with the circulating water lines which approach the Power Block from the northeast direction. The ESW system lines are located to minimize the number cross-overs with the SW lines and with the pipes within the ESW system itself. The ESW lines are buried at such a depth to preclude any hazard from a postulated failure of any nonseismic Category I pipes located above. 9.2.1.2.5 Tests and Inspections Refer to Section 9.2.1.2.4 of the Standard Plant FSAR. 9.2.1.2.6 Instrumentation Applications Redundant controls are provided to initiate the start of the essential service water pumps following an accident and/or loss of offsite power. Redundant and independent power supplies for controls and instrumentation are provided from Class 1E busses. Refer to Standard Plant Chapter 8.0. Indicating and a _j_ alarm devices tor the system are provided in 'fal31e s.z 3. s~,..JarrJ f/a,..f- R'IJ~ t;;IJte. 1

                                                                                                    ,.::2-{

9.2-6 Rev. OL-19a 7/12

CALLAWAY- SA The effluent from the secondary lagoon will then gravity flow to the tertiary lagoon which is primarily a stilling chamber to allow any remaining solids to settle out. The resulting clear water will then gravity flow to the wetlands lift station where it is pumped to the wetlands for final treatment. The wetlands polishes the water received from the lagoons by natural processes. Water in the wetlands is maintained at a depth which allows the natural process of plants, sunlight and bacteria to clean the water. Effluent from the wetlands is combined with supernatant from the Water Treatment Plant Sludge Lagoon system. This is then recycled to the Water Treatment Plant. 9.2.4.3 Safety Evaluation The PW and SWW system serve no safety-related function. 9.2.4.4 Tests and Inspections The PW system equipment is initially inspected and tested in accordance with applicable codes and preoperational test procedures to insure system integrity and completeness. The effluent of the sewage treatment system is monitored for flow, biochemical oxygen demand, suspended solids, and pH in accordance with the National Pollutant Discharge Elimination System Permit issued by the Missouri Department of Natural Resources. 9.2.4.5 Instrumentation Applications Local and remote indicators and alarms are provided to monitor the systems and to protect system components. Pressure, flow, and level instruments and alarms are provided as necessary to adequately monitor the system. T 9.2.5 ULTIMATE HEAT SINK The ultimate heat sink (UHS) for the plant consists of a 4-cell seismic Category I mechanical draft cooling tower and a seismic Category I source of makeup water (retention pond) for the tower. Heat from the Essential Service Water Systems (ESW), as discussed in Standard Plant FSAR Section 9.2.5, is rejected to the UHS to permit a safe shutdown of the unit following an accident. r-esu l+..r in ~ m fn;~miAfh Jt)t+rA J lA HS wc.-1-e r I e ve.l ...,-e._c,hn[CI\ I j~ec rf'r~,-ff()n I iP\'1+ of /lo ,o .fe_e { h Is /ev~ I rn~ Juk..r 9.2-13/ ~o), ;""t.P]In .hy Vo}IA~. ~~~~- OL-19a

CALLAWAY- SA k t!dtJ JIn~ wc~t-l-er S~tAree 9.2.5.1 Design Bases "lloiVI'd 0-J-.J..e_ ESVv sy.skm 9.2.5.1.1 Safety Design Bases ..Jt, SV.ff 't SAFETY DESIGN BASIS TWO- The UHS is designed to meet the requirements of NRC Regulatory Guide 1.27, Ultimate Heat Sink. ,p .,_1_ ,. ue.. C4l ~C,.T~/.r "" SAFETY DESIGN BASIS THREE -The UHS retention pona"-~~~-~~loS-f3~.flf:fil~ - faeility for uMits 1 aReJ 2, efleJ tRe capasity wettld be sufficient to permit

safe shutdown 4Qr w.<<e r~ctor& fgllgwing-a bOCA in gne1bin it aAel a ASFfflEJI SRt:lteJ~Ydfl in e 1 ,. A sese AS ttflit. 6--F *f"l'e- re~c:-h..- -F~ liD vvrn1, P.. ~esf~n bar~~ I"~~ brl.v. I< ~c ~s we.. II tA.t ~Db I'~ *+k I ot~td.s- ~s.r" c.rtl\--1-ed wr':J-h A n~l-fhAI p IAnf- s~u+~own, Wit~ t~e eeReelletion of U11il'2.~e design and re¥iseei-operational parameters Aeve bee* 1 veFifleeJ tO}J'rovide the required 30 day supply of cooling water following CXLOCA. .

o~ +-lv~. . uI-'I.S )e.slgh b~srr / ~YYJe br-eo. k 9.2.5.1.2 Power Generation Design Basis u d The UHS is not required for power generation. 9.2.5.2 System Description 9.2.5.2.1 General Description

                              £ The UHS fer ttole GeiiEhcaJ Sib~ WAit 1 consists of one seismic Category I mechanical draft cooling tower with redundant c,ells pnd a seismic Category I excavated retention                         1 11 1 1 pond.                             S-hln.o("' >-t>f f.1a..+ F.Sft/ FffltAt*e. /. ~-     :+t  S r fe.JT{IIIAuvAun, FSA!f. Fra.IAna -:3_ r-I:J. J ~l'lt( srk At1Je;Jum Fslt~                  Frgure.

4iigtu es 1.2 4, 1.2 5 OIIF .8-15 show the location and arrangement of the UHS cooling tower and the retention pond. A piping and instrumentation diagram for the UHS is shown in Standard Plant FSAR Figure 9.2-2 Sht. 3. 9.2.5.2.2 Component Description COOLING TOWER- The cooling tower is safety-related, seismic Category I, mechanical draft type, sized with 100-percent redundancy to provide heat dissipation for safe shutdown following an accident. The cooling tower is protected from horizontal and vertical tornado missiles. Details of the tower structural design and missile protection are 9.2-14 Rev. OL-19a 7/12

CALLAWAY- SA provided in Section 3.8.4.1.4. Tornado missile protection design criteria are provided in Section 3.5.3.1. Design data for all cooling tower components is provided in Table 9.2-4. The cooling tower is divided into four cells with one fan assembly (fan, gear reducer and motor) per cell. Two of the four cells (one train of the ESW) are required for safe shutdown. Backup electric power to the fan motors is supplied from the emergency diesel generators located in the Power Blocks. Supply headers and spray pipes for each train of ESW from the Power Block are separated by interior walls. A passive failure of the spray pipe for one train of the ESW will not affect the piping for the other train. 3,.k'-l~ Figure ~rovides the arrangement for the cooling tower components. Refer to Standard Plant Section 9.4.8 for a description of the cooling tower electrical room ventilation equipment. FREEZE PROTECTION - Freeze protect~*o thifJ, er fill is provided by automatic bypass of the spray system. ESW from t w 1 ck is diverted directly into the cooling tower basin (refer to Section 9.2.5. . Fre e protection of the spray system when the tower is idle is provided as follows:

a. Piping above El. 1998'-6" is provided with a continuous drain.

b. Piping from the basin floor (EI. 1996'-6") to El. 1998'-6" is heat traced to keep all the supply pipe above the maximum frost depth free from ice closure.

               '3.'t-ld..

Durin ds when the tower is idle, the fan stack missile protection design shown on Fig. ntrinsically protected against excessive ice, snow or debris blockage. The drip ledge along the bottom periphery of the 28'-4" diameter concrete missile shield support beams will prevent damaging ice formation above the fan. The grating design (2 1/2 inches deep with 2 1/8 inches clear openings) and open beam supports which surround the missile shield contribute to prevention of ice blockage. The grating is completely shadowed by the cooling tower roof with the roof opening diameter being 6 inches less than the diameter of the missile shield. This will protect the grating from contact with vertical sleet or snowfall. Oblique precipitation or debris entering the roof opening will contact only a fraction of the grating. Fan design static pressure exceeds missile protection and tower losses by a margin of 15 percent to account for this possibility. Ice blockage of the grating which causes its static loss to exceed the fan rating could result in degradation of cooling tower performance. However, low UHS retention pond initial temperature (compared to design case) will provide additional cooling capability. Water from the cooling tower basin is fed by gravity through two 36-inch pipes to the retention pond. Normal level in the retention pond results in standing water in the basin 9.2-15 Rev. OL-19a 7/12

CALLAWAY- SA sumps. Two immersion heaters per basin sump are provided to prevent ice blockage when the towers are idle. RETENTION POND- The UHS retention pond which contains makeup water for the UHS cooling tower is an excavation i~ existing and fill soils. :CN S"Ef(r? rJes'3" The approximate dimensio of the pond at grade El. 1999.5 feet ar The bottom of the pond ele tion is 1977.5 feet, and the side slopes re 3 horizontal to 1 vertical. The side slopes ar protected by riprap from the surrounding rade elevation to El. 1987.5 feet. The ater level in the pond is El. 1995.5 feet. wo submerged, reinforced concrete discharge structures discharge water into the pond from the UHS cooling tower. A reinforced concrete outlet structure is provided for outfiQw from tb.Etca-f.- IJJ. 1 _ pond. Jn'1-ra /le.eA11f~l qec.rF1 'ltJI1 V'lan!r 4-?. ~ level rs /(,,(}~ J(J_$~n Approximately 56 acre-feet of water is ma*ntain d below the RQFFTlal epefetieRe~ater I level of 18 feet, plant El. 1995.5. The min mum , plant El. Jq~.; ~990.75'; which maintains a volume over acre-feet in the UHS. The UHS w -Fee.=!- analyzed for the design basis LOCA in accordance with N egulatory Guide 1.27 -, da':J.r assuming two ESWS trains in operation for the first

and single train operatic U .

thereafter. The total inventory loss from the UHS during the 30 day period under the most limiting meteorological conditions (maximum evaporation conditions) was conservatively calculated to be acre-feet. ...:::o:w--trm:~'l'"l'rt,.....,.,._.,-PAt~~~...,_-

                           ,                                                            The total water volume remaining after 30 days

greater thantcre-feet. The usable portion of this volume is greater tha~iracre- et which provid Sa margin !jF8~Aan 56pC1CCIIt Of the total volu.,f~q~~ent. .f-6/l 1. '3 4 + /).'6 ab1ve..

Degradation due to siltation will not occur because of the normal quiet state of the pond and the composition of the in situ clay materials. The in situ clays have very low permeabilities which make seepage negligible. The capacity of the pond is sufficient to accommodate any expected ice formation. Structural design of the UHS retention pond is described in Section 3.8.4. A 14-inch-diameter, norYseismic Category I make-up line provides normal makeup water for the pond. Source of the makeup water is the water treatment plant clearwell. Plant procedures control makeup to the pond from the clearwell deepwell or service water systems. No blowdown for the pond is provided. Typical plans and sections for the UHS retention pond are shown on Figures 3.8-15, 3.8-16, and 3.8-17. 9.2-16 Rev. OL-19a 7/12

INSERT 8 The target (nominal) UHS retention pond level is maintained between levels corresponding to the low and high level alarms.

CALLAWAY- SA 9.2.5.2.3 System Operation Normal cooling of the safety-related equipment is by the service water system, as described in Section 9.2.1. When the ESW system is put into operation, water is drawn from the UHS retention pond by means of the ESW pumps. It is then pumped through the Power Block components and returned to the cooling tower basin. The spray system is bypassed until UHS inlet water temperature from the Power Block reaches 84°F. The fans remain de-energized until UHS inlet water temperature from the Power Block reaches 95°F. The water flows from the cooling tower basin to the retention pond by gravity throu h two 36-inch pipes, one per train of the ESW. Refer to Section 9.2.1.2 for a descriptio of the ESW pumps and piping outside the Power Block. Standard Plant FSAR Secf n 9.2.5 provides the heat loads on the UHS cooling tower and the UHS water che istry analysis.

XNS£RT" Cj I 9.2.5.3 Safety Evaluation t/::l..3 an ESW ..r"ff'}

SAFETY EVALUATION ONE -The UH~s* sized to dissipate the max1 urn heat loads post DBA listed in Standard Plant FSAR ection 9.2.5 while providing~~~*=tA-~ft-water temperature less than or equal to oF. It is assumed that the DBA occurs at the time that the most adverse meterological conditions for tower performance prevail. The UHS pond temperature reached under these conditions will not exceed 92.3°F. ~~--- SAFETY EVALUATION TWO- The.UHS retention pond meets the requirements of NRC Regulatory Guide 1.27 for a single UHS water source. The UHS cooling tower is designed to withstand the safe shutdown earthquake or design basis tornado and for single failure, either active or passive, without loss of function. Additionally, due to the manner in which emergency power is supplied to the pumps and cooling tower fans from the emergency diesels, the system functions are unimpaired by an active diesel failure. Since the UHS pond is an excavated depression and the water is not retained by man-made structural features, the postulation in NRC Regulatory Guide 1.27 of the single failure of man-made structural features does not apply. The UHS pond is designed to withstand the most severe natural phenomena expected. See Section 2.4.3 for coincident wind wave activity and Section 2.4.5 for surge and seiche sources. Slope stability is discussed in Section 2.5.5. The UHS pond is so located that its function is not to be affected by postulated accidents incurred by traffic on vehicle access roads or other site-related events. 9.2-17 Rev. OL-19a 7/12

INSERT 9 after which the fans will start in slow speed. The fans will switch to high speed when the UHS inlet water temperature reaches 105°F. After the EFT-0061 and EFT-0062 ESW pump discharge (ESW supply) temperature control loops are enabled by control room operators using handswitches EFHS0067 and EFHS0068 (one switch per train), the actuation temperatures are, in ascending order, 79°F (bypass valves close), 84.5°F (cooling tower fans start in low speed), and 89.5°F (cooling tower fans switch to high speed).

INSERT C The design-basis maximum ESW supply temperature from the UHS retention pond is 95°F. That value was used in the design of the UHS cooling tower cells (FSAR Site Addendum Table 9.2-4 of Reference 1) and is the assumed ESW inlet temperature to all loads served by ESW except for the electrical penetration room coolers. However, the maximum ESW supply and UHS retention pond temperature of92.3°F establishes the upper acceptance criterion in the minimum heat transfer and maximum evaporation cases in the analysis supporting the 30-day UHS inventory requirement per RG 1.27 (Ref. 2). In addition, an ESW inlet temperature of92.3°F is also assumed in the analysis of the electrical penetration room temperatures (room coolers supplied by ESW). The 92.3 °F value is the maximum temperature allowed in these analyses to support UHS operability assuming an initial maximum temperature of 89°F.

CALLAWAY- SA CJJO j fnd- --Hwer Non-seismic, non-Ca gory I structures near the seismic Category I ltimate heat sink 1 cooling tower include, the fire pumphouse, the portable water plant a d the Maintenance Training Annex/Oper tions Support Facility, as shown in Fig 1.2-44. ~ postulated structural failure of th se non-seismic buildings would not impose a hazard to the cooling tower since the towe enclosure is designed as a tqrnado-resistaot structure. S-htntlrArd rlan F..rA-~-ra~te q,. :~-s: Conformance with R gulatory Guid 1.27 is tabulated in Table 9.2-5. ~ single failure analysis for the UH s contained in ~ ... '1 ,.. 1

                                                          +rr:J.                                     tfte.-S'&n SAFETY EVALUATION THREE - The ESretention pond vol me a e                                  RQ~R=tt*\fevel      is roximately 56 acre-feet. At the mini urn level require                              nical cifications the contained volume is             acre-feet of wate .                     acre-feet is eeded to provide a 30 day supply of cooling and makeup ater post LOCA under maximum evaporation conditions for this period. The total ond water volume remaining after 30 days is                     acre-feet. The usable port* n of this volume is §Feeter 4 . '/7

-tl 1a1 1 12*acre-feet, w 1ch is the volume of water above the inimum level needed to maintain the requir d net positive suction head for the ES S pumps. This remaining volume provides a argin that is greater tha~60 j9eFeoAt f the total water volume.

                           -?, 3                       /;l'f,                 by +he- f JPtnf-ln the event normal plant facilities are not in operation within 30 days~lue U~* 1 w::Ue: 61
,d?¥8 fel depletillg tile se p1 Ceilt I lit! I gill iA tAO UIIS ~epli!J) after an emergency shutdown, approximately 13 acre-feet of water are available from the water treatment plant clarifiers. This water can be pumped into the UHS retention pond by portable pumps for UHS heat dissipation purposes. In the event the clarifiers have been damaged, water can be trucked from offsite. An adequate number of 40,000 to 45,000 pound capacity bulk liquid carriers are available in the metropolitan area. These trucks would be mobilized to obtain water from Fulton (1 0 miles), Jefferson City (25 miles), or Columbia (32 miles). In the extremely unlikely event water would not be available from any of the above cities, portable pumps will be obtained and water can be pumped from the Missouri River (6 miles) to fill the trucks.

9.2.5.4 Testing and Inspections The UHS is designed to include the capability for testing through the full operational sequence that brings the system into operation for reactor shutdown and for loss-of-coolant accidents, including operation of applicable portions of the protection system and the transfer between normal and standby power sources. The components of the UHS, i.e., fans, valves, tower fill, and piping (to the extent practicable), are designed and located to permit preservice and inservice inspections. 9.2.5.5 Instrument Applications The UHS instrumentation is designed to facilitate automatic operation, remote control, and continuous indication of system parameters. Redundant and independent power 9.2-18 Rev. OL-19a 7/12

CALLAWAY- SA supplies for cooling tower fan controls and instrumentation are provided from Class 1E sources (refer to Chapter 8.0). I _j_

                                        /)l-IS fn 1!..7 Discharge water from t             we~ck is directed into the cooling tower basin through a normally open spray sy m by~s valve. The bypass valve is controlled by cooling tower inlet water tempera re and ESW pump run time. This arrangement provides freeze protection for the t wer fill. The bypass valve will automatically close when HS                  /1   ln /e_.f zdissl=lar~e water tempe rat re is at or above 84 oF to direct the water through the cooling                     I tower fill. If the

ater temperature increases to 95°F, the cooling tower fans will automatically start in slow speed. In addition, if temperature ~ues to rise, the fans will automatically shift to high speed at 105°F. It is Aetea th~ design setpoints for the UHS cooling tower fanscti\ provide freeze protectio lal+la¥--F9EH:Ht-tt.H:t1'1'0r-ot:mtJ-

.c;in place at tR& ti~& gf tR8 &V8AL Fan status and valve osition indication is provided locally and in the control room. :XNS£1?1' /0 TRe iilblteFRatis 8yJ3ass gf tR& s~r*y syst&~ may ee aefeateet aRe tl:le eyJ3ass ¥alve -r+liilRt::~ally elesea iA eraer te seRa retblrR water ever the fill. This 8llooos UIIS pond eooli11g ar::1d pertorr+liilRC& ~gRiteriR~ eittFiflg pl8nt opel atio11 ovl 1e11 freel:iflg ifl tl:le to over is flet a COl ICe!!!. Level sensors located in the UHS provide control room indication of low pond level and high pond level. Makeup to the pond can also be accomplished by manual operation. Refer to Standard Plant FSAR Figure 9.2-2 Sht. 3, for a description of UHS instrumentation. 9.2-19 Rev. OL-19a 7/12

INSERT 10 in cold weather and protect the UHS retention pond temperature from exceeding 92.3 op in warm weather post-LOCA. After the EFT-0061 and EFT-0062 ESW pump discharge (ESW supply) temperature control loops are enabled by control room operators using handswitches EFHS0067 and EFHS0068 (one switch per train), the actuation temperatures are, in ascending order, 79°F (bypass valves close), 84.5°F (cooling tower fans start in low speed), and 89.5°F (cooling tower fans switch to high speed).

CALLAWAY- SA J)e, Ie*-1-eJ TABLE 9.2-3 -ESSE~JTIAL SERVICE 'forATER SYSTEM INDIGATI~JG AND ALARM DEVICES Control Room Essenti ervice water pump Yes discharge p ssure Essential service ater pump No Yes discharge strainer h1 differential Essential service water pump Yes intake water level Alarms Essential service water pump low No discharge pressure Essential service water pum No intake low water level Essential service wat pump Yes No discharge strainer gh pressure differential Essential s ice water pump Yes intake hi /low water level Rev. OL-13 5/03

CALLAWAY- SA TABLE 9.2-4 ULTIMATE HEAT SINK COMPONENT DATA Cooling Tower Number of towers 1 Number of cells per tower 4 Design Point Each Cell Water flow rate, gpm 7,500 Heat rejection rate, Btu/hr 145 X 106 Hot water temperature, °F 133.7 Cold water temperature, oF 95 Entering wet bulb temperature, oF 81 Range, °F 38.7 Approach, °F 14 Tower Performance Data Each Cell Dry air flow, lb/hr o 2.587 X 1 6 lb D.A./hr/fan Water/air ratio, L/G 1.45 Performance characteristic, KaV/L 2.04 Evaporation loss, lb/Btu 0.00088 lb H2 0/Btu/fan Drift loss, o/o of flow 0.02%> Tower Fill Fill material Crosspack corrugated asbestos cement board (ACB) Effective cooling surface Plan area per cell 1,293.3 sq ft Surface area of fill per cell 190,120 sq ft Fill support spacing 4.042 ft Number of fill deck layers One Packing height 7ft Drift Eliminators Material Corrugated ACB or Corrugated Cellulose Silica Cement Board (CSCB) Number of passes One Mechanical Equipment Fan Quantity 4 (1 per cell) Diameter 24ft Number of blades 12 Speed 164/82 rpm Tip speed 12,365 fpm Rev. OL-19 5/12

CALLAWAY- SA TABLE 9.2-4 (Sheet 2) Blade material Glass reinforced polyester Fan horsepower 165 bhp Fan capacity 692,700 cfm Fan efficiency 71.8 Seismic design Category I Fan Pressure Static 0.9449" H20 Velocity 0.10" H20 Total 1.0449" H20 Air velocity entering tower 900 fpm Air velocity leaving tower 1,167 fpm Entering air density 0.07040 lbs/ft Leaving air density 0.06650 lbs/ft Speed Reducer Type Right angle Quantity (per tower) 4 Service factor 2.0@ 200 bhp Gear material SAE 4620 Casing material ASTM A48 Gear ratio 10.83:1 Horsepower at base design 165 bhp Seismic design Category I Drive Shaft Diameter 6-5/8" O.D. Length 11'-1 1/2" Critical speed 2,750 rpm Material Stainless steel Fan Motor Quantity (per tower) 4 Power supply required 480 V, 3-phase, 60 cycle Rated horsepower 200 hp/50 hp Rated ambient 50°C Speed 1,800 rpm/900 rpm Design code NEMA Seismic design Category I Power supply Class 1E

External Static Pressure Rev. OL-19 5/12

CALLAWAY- SA TABLE 9.2-4 (Sheet 3) Distribution System Piping Number of inlet connections 1 per cell Nominal size of connections 20" Type of connections Raised face flange Seismic design Category I Coating galvanized Material Carbon steel (SA 106 GR B) Design pressure 50 psig Design temperature 200°F Design code ASME Section Ill, Cl.3 Nozzles Quantity 542 Size .601 sq in/nozzle Material Bronze Pressure Drop Pressure drop through inlet 0.102" H20 Pressure drop through outlet 0.3729" H2 0 Pressure drop through fill, spray system, and drift eliminators 0.471" H2 0 Total pressure drop through tower 0.9449" H2 0 Retention Pond __.,.-: J / r r ,__,. . I - / 1 I e!!.CI')rtlC4 .J/Je!.~l't-i(!A-r1dl'\ r- ... 11'}1..,-la Quantity Dimensio , L x W, ft 330 X 680

  -ri~e+ ~derl,,e~le el                                                 El. 19~4.5             -;Jk-~            .~,;

Minimum evel El. 1978' 6" /'1'13 1- " ., Normal water volume, acre-feet 51.2 a.+ (;t I eve/ 1-F 11q+/-t, ~

                 -'A'ateF le'lel star=t of fflake tJp**               --EI. 1993'-2          T Melte tJP 1ala**                                    ~0,000   gplii Tir+l& reefs fer Feestablishffieflt of corl+lalleoel' *                                  -A l'letJr r

v 1e1 I Stl t01 I 1a IC !~~ teffi *IS l:'JSS

- 'v"I a Rev. OL-19 5/12

CALLAWAY- SA (Sheet 1 of 4) TABLE 9.2-5 DESIGN COMPARISON TO REGULATORY POSITIONS OF REGULATORY GUIDE 1.27, REVISION 2 DATED JANUARY 1976, TITLED "ULTIMATE HEAT SINK FOR NUCLEAR POWER PLANTS" Regulatory Guide 1.27 Position CALLAWAY-SA-Callaway Position I. 1. The ultimate heat sink should be capable of providing sufficient cooling for at I. 1. Complies least 30 days (a) to permit simultaneous safe shutdown and cooldown of all Refer to Section 9.2.5.2.2. nuclear reactor units that it serves and to maintain them in a safe shutdown condition, and (b) in the event of an accident in one unit, to limit the effects of that accident safely, to permit simultaneous and safe shutdown of the remaining units, and to maintain them in a safe shutdown condition. Procedures for ensuring a continued capability after 30 days should be available. Sufficient conservatism should be provided to ensure that a 30-day cooling supply is available and that design basis temperatures of safety-related equipment are not exceeded. For heat sinks where the supply may be limited and/or the temperature of plant intake water from the sink may eventually become critical (e.g., ponds, lakes, cooling towers, or other sinks where recirculation between plant cooling water discharge and intake can occur), transient analyses of supply and/or temperature should be performed.

2. The meteorological conditions resulting in maximum evaporation and drift 2. Twenty-five years of meteorological data are used as the basis for the loss should be the worst 30-day average combination of controlling parameters retention pond transient analysis. The worst consecutive 30-day maximum (e.g., dewpoint depression, windspeed, solar radiation). evaporation period is used to determine maximum pond evaporation and cooling tower evaporative loss. Meteorological data used are wet-bulb depression, The meteorological conditions resulting in minimum water cooling should be the worst combination of controlling parameters, including diurnal variations where appropriate, for the critical time period(s) unique to the specific design of the sink.

windspeed and net solar radiation. Cooling tower evaporation loss and discharge water temperature are calculated using conservative methods. Guaranteed maximum drift loss for the cooling tower is included. K The following are acceptable methods for selecting these conditions:

a. Based on regional climatological information, select the most severe observation for the critical time period(s) for each controlling parameter or parameter combination, with substantiation conservatism of these values for site The initial pond temperature on the first day of the accident is based upon the maximum pond temperature allowed by plant technical specifications. The transient temperature performance during the minum heat transfer period has been simulated by using the worst single day (7/12/69) meteorological conditions as the first day of the worst 30-day period 717/55 to 8/5/55). The diurnal i

use. The individual conditions may be combined without regard to historical fluctuation for the worst single day is accounted for by use of three-hour time occurrence. increments, using the appropriate 3-hourly meteorological data. The peak pond outlet temperature occurs on the first day following a LOCA. Rev. OL-13 5/03

CALLAWAY- SA TABLE 9.2-5 (Continued) (Sheet 2 of 4) Regulatory Guide 1.27 Position CALLAWAY-SA-Callaway Position

b. Select the most severe combination of controlling parameters, including diurnal variations where appropriate, for the total of the critical time period(s),

based on examination of regional climatogical measurements that are demonstrated to be representative of the site. If significantly less than 30 years of representative data are available, other historical regional data should be examined to determine controlling meteorological conditions for the critical time period(s). If the examination of other historical regional data indicates that the controlling meteorological conditions did not occur within the period of record for the available representative data, then these conditions should be correlated with the available representative data and appropriate adjustments should be made for site conditions.

c. Less severe meteorological conditions may be assumed when it can be demonstrated that the consequences of exceeding lesser design basis conditions for short time periods are acceptable. Information on magnitude, persistence, and frequency of occurrence of controlling meteorological parameters that

exceed the design basis conditions, based on acceptable data as discussed above, should be presented. The above analysis related to the 30-day cooling supply and the excess

temperature should include sufficient information to substantiate the assumptions and analytical methods used. This information should include actual performance data for a similar cooling method operating under load near the specified design conditions or justification that conservative evaporation and drift loss and heat transfer values have been used.

3. A cooling capacity of less than 30 days may be acceptable if it can be 3. Not applicable. ~

demonstrated that replenishment or use of an alternate water supply can be effected to assure the continuous capability of the sink to perform its safety functions, taking into account the availability of replenishment equipment and limitations that may be imposed on "freedom of movement" following an accident or the occurrence of severe natural phenomena. II. 1. The ultimate heat sink complex, whether composed of single or multiple II. 1. Complies water sources, should be capable of withstanding, without loss of the sink safety functions specified in regulatory position I, following events:

a. The most severe natural phenomena expected at the site, with appropriate ambient conditions, but with no two or more such phenomena occuring simultaneously, Rev. OL-13 5/03

CALLAWAY- SA TABLE 9.2-5 (Continued) (Sheet 3 of 4) Regulatory Guide 1.27 Position CALLAWAY-SA-Callaway Position

b. The site-related events (e.g., transportation accident, river diversion) that historically have occurred or that may occur during the plant lifetime,

c. Reasonably probable combinations of less severe natural phenomena and/or site-related events,

d. A single failure of manmade structural features,

2. Ultimate heat sink features, which are constructed specifically for the nuclear 2. Not applicable.

power plant and which are not required to be designed to withstand tlie Safe Shutdown Earthquake or the Probable Maximum Flood, should at least be designed and constructed to withstand the effects of the Operating Basis Earthquake (as defined in 10 CFR Part 100, Appendix A) and waterflow based on severe historical events in the region. Ill. 1. The ultimate heat sink should consist of at least two sources of water, Ill. 1. A water source for the unit is contained in the retention pond. The retention including their retaining structures, each with the capability to perform the safety pond is seismic Category I and below grade. Hence, there is an extremely low functions specified in regulatory position I, unless it can be demonstrated that probability of losing its capability/( ir u8FI8i8eree eingle feilu:e f!Fee~. there is an extremely low probability of losing the capability of a single source.

2. For close-loop cooling systems there should be at least two aqueducts 2. Complies

CNS'e-/<-1 II connecting the source(s) with the intake structures of the nuclear power units and at least two aqueducts to return the cooling water to the source, unless it can be demonstrated that there is extremely low probability that a single aqueduct can functionally fail entirely as a result of natural or site-related phenomena.

3. For once-through cooling systems, there should be at least two aqueducts 3. Not applicable.

connecting the source(s) with the intake structures of the nuclear power units and at least two aqueducts to discharge the cooling water well away from the nuclear power plant to ensure that there is no potential for plant flooding by the discharged cooling water, unless it can be demonstrated that there is extremely low probability that a single aqueduct can functionally fail as a result of natural or site-related phenomena.

4. All water sources and their associated aqueducts should be highly reliable 4. Complies and should be separated and protected such that failure of any one will not induce failure of any other.

Rev. OL-13 5/03

INSERT 11 Operator actions are credited after a large break LOCA to diagnose and mitigate a postulated single failure of a UHS cooling tower bypass valve to close based on indications from NG07 and NG08 bus voltage annunciators and proper equipment status (bypass valve position, UHS cooling tower on/off status and fan speed) for the prevailing ESW return (UHS inlet) temperature and to switch temperature control loops for the UHS cooling tower bypass valves and cooling tower fans from the ESW return temperature to the ESW pump discharge (ESW supply) temperature. This is discussed in greater detail in Standard Plant FSAR Section 9.2.5.2.2.1.

CALLAWAY- SA TABLE 9.2-5 (Continued) (Sheet 4 of 4) IV. Regulatory Guide 1.27 Position The technical specifications for the plant should include provisions for actions to IV. wav Position L}_

                                                                                                                                                      . , r.r     rea, No plant technical sp~~tions are req~ired for:~: u;;~:;:;::: pOliO
                                                                                                                                                                           /    1_

t.-~ tK17~

                                                                                                                                                                                   /
                                                                                                                                                                                             , I, f 4..S, ..,...,!J-1 be taken in the event that capability of the ultimate heat sink or the plant                   because: (1) no cordi       tlol:eakil pa: ball ass    II        1 and (2) the temporarily does not satisfy regulatory positions I and Ill during operation.                  plant satisfies Regulatory Positions I and II during operation.

The UHS mechanical draft cooling tower is designed to permit periodic determination of proper system operability, as specified in Technical Specifications. The UHS retention pond temperature and level will be monitored as specified in Technical Specifications. Rev. OL-13 5/03

INSERT 12 Operator actions are credited after a large break LOCA to diagnose and mitigate a postulated single failure of a UHS cooling tower bypass valve to close based on indications from NG07 and NG08 bus voltage annunciators and proper equipment status (bypass valve position, UHS cooling tower on/off status and fan speed) for the prevailing ESW return (UHS inlet) temperature and to switch temperature control loops for the UHS cooling tower bypass valves and cooling tower fans from the ESW return temperature to the ESW pump discharge (ESW supply) temperature. This is discussed in greater detail in Standard Plant FSAR Section 9 .2.5 .2.2.1.

CALLAWAY- SA

                              .De le-4-uJ TABLE 9.2-6 JJ!  !!~dATi! !-lEAf SINI<   OIP~SLE   FAILURE ANALYSIS le Passive Failure                       Analysis of one discharge header within       The cooling function of two         ling tower

g tower cells which removes the at from one essential service wat rain is lost. The essential plant co ng requirements are met by the re tning two cells which remove th eat from a redundant essenti service water train.

Single Active Failure Failure of one cooling tower fa The cooling function of one cooling tower cell is lost. The essential plant cooling requirements are met by two of the remaining cooling tower cells which emove the heat from a redundant e ential service water train. Diesel power failure to o cooling tower The c ling function of two cooling tower fans cells wht remove the heat from one essential s ice water train is lost. Redundant di el power supply to the remaining two fa is available. Essential plant cooling requir ents are met by the remaining two cells w

h remove the heat from a redundant essen I service water trains.

Rev. OL-13 5/03

ATTACHMENT 5 USE OF GOTHIC 7.28

GOTHIC (Generation of Thermal-Hydraulic Information for Containments) is a general-purpose thermal-hydraulics code for containment analysis developed for the Electric Power Research Institute (EPRI) by Numerical Applications, Inc. (NAI), for applications in the nuclear power industry. GOTHIC version 7.2b was used for the EF-123 analysis discussed in Section 3.0 of the Enclosure to this amendment request. The references cited here in Attachment 5 are listed in Section 6.0 of the Enclosure to this amendment request. GOTHIC is developed and maintained for EPRI under NAI's QA Program that conforms to the requirements of 10CFR50 Appendix B and 10CFR Part 21. Detailed descriptions of available GOTHIC user options and models are included in References 6.3 and 6.4. Information about GOTHIC qualification is available in Reference 6.5. The Callaway engineers qualified to use GOTHIC document their proficiency via the Engineering Support Personnel (ESP) qualification card requirement titled "ESP/504A, Perform Containment Pressure I Temperature Calculation Using the GOTHIC Computer Code." GOTHIC version 7.1 patch 1 was used previously for Callaway containment and steam tunnel (Area 5) pressure/temperature analyses in support of the replacement steam generators (RSGs) as discussed in Reference 6.2 (especially Section 3 .6.3 .3 of the NRC Safety Evaluation). Callaway has developed separate software documentation packages and 10 CFR 50.59 evaluations for the change from GOTHIC version 7.1patch 1 to GOTHIC version 7.2a (50.59 Evaluation 06-02) and for the change from GOTHIC version 7.2a to GOTHIC version 7.2b (50.59 Evaluation 10-02). Paramount in the 50.59 evaluations was an examination of situations where the change to the newer code revision results in decreases in the pressure I temperature results (for 50.59 purposes these are considered non-conservative changes) thereby gaining margin. GOTHIC versions 7.2 (September 2004) and 7.2a (January 2006) have been used in several NRC-approved license applications. GOTHIC 7.2 was approved by the NRC in the following:

Ginna's 16.8% Power Uprate License Amendment 97 (TAC No. MC7382) dated July 11, 2006, ADAMS Accession Number ML061380103; and
Dominion topical report DOM-NAF-3 in a letter dated August 30, 2006 from Ho K. Nieh (NRC Division of Policy and Rulemaking) to David A. Christian (Virginia Electric and Power Company), ADAMS Accession Number ML062420511 1

GOTHIC 7.2a was approved by the NRC in the following:

Nile Mile Point's Alternate Source Term License Amendment 194 (TAC No.

MD3896) dated December 19, 2007, ADAMS Accession Number ML073230603; and

WolfCreek's MSIV/MFIV Replacement License Amendment 176 (TAC No.

MD4840) dated March 21,2008, ADAMS Accession Number ML080650219. GOTHIC version 7.2a was also benchmarked against the Callaway RSG analyses using GOTHIC version 7.1patch1 (All3 LOCA cases, two inside containment MSLB cases, and one steam tunnel steam line break case were examined.) The resultant calculation comparisons include some temperature and pressure results that are conservative and some that are non-conservative with respect to results from version 7.1patchl. One of the 3 LOCA cases (double-ended hot leg break, DEHL) and the 1.0 square foot steam line break in the steam tunnel exhibited maximum temperature changes greater than 1% in the non-conservative direction; however, those non-conservative changes were short in duration during rapidly changing conditions (for the steam tunnel steam line break this occurs after the peak temperature has been reached and is changing rapidly from 420°F to 200°F in approximately 6 seconds; for the DEHL LOCA this occurs at 1.042 seconds during the initial temperature profile ramp with containment temperature approximately 180°F). When the peak temperatures and pressures were compared for these six test cases, the largest disagreement was less than 0. 7% in the non-conservative direction. GOTHIC version 7.2b was also benchmarked against the above Callaway RSG analyses using GOTHIC version 7.2a (All3 LOCA cases, two inside containment MSLB cases, and one steam tunnel steam line break case were examined.) The resultant calculation comparisons were either conservative or non-conservative by less than 0.2%. When the peak temperatures and pressures were compared for these six test cases, the largest disagreements were 0.19% in the conservative direction and 0.003% in in the non-conservative direction. The conclusions reached in the Callaway 10 CFR 50.59 evaluations indicate that the results are conservative or essentially the same for GOTHIC version 7 .2b as those from GOTHIC version 7.1 patch1 and do not represent a departure from a method of evaluation described in the FSAR which requires prior NRC approval. Limitations on the use of GOTHIC remain consistent with NRC approval of its use in previous licensee applications, such as the use of the diffusion layer model (DLM) condensation model rather than the mist diffusion layer model (MDLM). In addition, user-controlled enhancements which could impact the results in GOTHIC 7.2b have not been used in Callaway calculations. 2

ATTACHMENT 6 INSTRUMENTATION AND CONTROLS USED TO IMPLEMENT REVISED EOPS

Justification for Credited Operator Actions Twelve (12) criteria from a composite of NRC Information Notice (IN) 97-78, "Crediting of Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times," ANSI/ANS-58.8-1984, "Time Response Design Criteria for Nuclear Safety Related Operator Actions," and the Callaway 10 CFR 50.59 Resource Manual were used to evaluate the credited operator actions.

1. No manual action shall replace an automatic action that is related to the Technical Specification 2.0 Safety Limits.

Information Notice 97-78 states that it is not appropriate to take credit for manual action in place of automatic action for protection of Safety Limits to consider equipment operable. This does not preclude operator action to put the plant in a safe condition, but operator action can't be a substitute for automatic Safety Limit protection. Per Technical Specification 2.0 there are two Safety Limits for Callaway Plant. The first Safety Limit addresses fuel centerline temperature and DNBR. The second Safety Limit requires that RCS pressure not exceed 2735 psig. These Safety Limits are not challenged by the LBLOCA I UHS issues. The credited operator actions in this license amendment request (LAR) do not involve the replacement of automatic functions previously described in the FSAR. Therefore, this LAR does not involve replacing automatic Safety Limit protection with manual Safety Limit protection.

2. The specific operator actions required, and the procedural guidance for those actions.

Credited operator actions include the following: (1) The operators will be credited with diagnosing and mitigating postulated valid single failures that if left uncorrected could result in excessive UHS temperatures and UHS inventory loss post-LOCA. Specifically, at Step 11 in E-1, the control room staff will verify that the UHS is in its intended lineup. The following actions will be taken:

Check for undervoltage I overvoltage on NG07 and NG08;
Determine essential service water (ESW) return temperature (this step may include checking temperatures locally);
Check UHS cooling tower bypass valves (actual position vs. demand position per the temperature control loops); and
Check UHS cooling tower fan speeds (operating status and actual fan speed vs.

demand speed). 1

If the UHS cooling tower bypass valves and fans cannot be placed in the correct operating configuration, then the affected ES W train will be secured per EO P Addendum 17. (2) The operators will be credited with manually switching the UHS cooling tower bypass valve and fan control from the UHS cooling tower inlet to the ESW pump discharge instrumentation loops. These loops measure temperature at different locations and provide control at different setpoints based on the initial need to limit UHS temperature and then the ongoing need to maintain UHS inventory. If this step is not performed it could result in excessive UHS temperatures and inventory loss post-LOCA. Specifically, at Step 19 in E-1 (directing the performance ofEOP Addendum 40 within 4 hours), the control room staff will switch controlling temperature loops for the UHS cooling tower. The following actions in EOP Addendum 40 will be taken:

Check for undervoltage I overvoltage on NG07 and NG08;
Transfer the temperature control to the ESW supply temperature control loops;
Check ES W pump discharge temperature indication;
Check UHS cooling tower bypass valves (actual position vs. demand position per the temperature control loops);
Check UHS cooling tower fan speeds (operating status and actual fan speed vs.

demand speed);

Check UHS level; and
Evaluate long term ESW and UHS status.

(3) The operators will be credited with checking the ESW pump discharge temperature (ESW supply temperature) against the UHS cooling tower fan speeds to ensure successful completion of credited operator action (2) above. A continuous action "#" designator has been added to EOP Addendum 40, Step 5, to ensure continuous monitoring ofUHS cooling tower fan speeds, with respect to the fan control (ES W pump discharge) temperature setpoints, is maintained. If a train of fans is not running in accordance with the enabled fan control temperature setpoints, then the affected ESW train will be secured per EOP Addendum 17. The"#" designator will ensure this action is performed continuously over the duration of the LBLOCA. (4) The operators will be credited with isolation of a train of ES W within 7 days of an LBLOCA initiation if both trains are still running. Continued operation of both trains could result in excessive UHS inventory loss. The Technical Assessment Coordinator (TAC) checklist (EIP-ZZ-00240 Addendum B) for the Technical Support Center (TSC) has been revised to direct the that the Technical Assessment Coordinator review EDP-EF-UHS01, "UHS Cooling Tower Operational Guidance Following a LOCA," within 7 days of an LBLOCA. EDP-EF-UHS01 directs the control room staff to secure one ESW train. 2

3. The action (including required completion time) is reflected in plant procedures and operator training programs.

Credited operator actions (1), (2), and (4) above are reflected in plant procedures E-1, EOP Addenda 17 and 40, EIP-ZZ-00240 Addendum B, and EDP-EF-UHS01. Additionally, these new credited operator actions have been included in APA-ZZ-00395, "Significant Operator Response Timing." Operator action (3) to secure a train ofESW, assuming a failure of the handswitch (EFHS0067 for train 'A' or EFHS0068 for train 'B') to swap UHS bypass valve/fan temperature control loops in operator action (2), does not have a required completion time, but is expected to be completed within 24 hours of reaching fan control temperatures between the fast and slow temperature limits. EOP Addendum 40, Step 5, is a continuous action step which ensures that once UHS temperature is under control, the fan operation and speed will match expected temperatures or the affected ES W train will be secured per EOP Addendum 17. As the analysis, in conjunction with the procedural guidance, demonstrates there is sufficient time to perform this operator action, the 24-hour expectation will not be documented in plant procedures. Training materials were developed and training was implemented for all licensed personnel (Training Request (TRRQ) 201201398). The new operator actions have been incorporated into licensed operator initial and continuing training programs per the TRRQ. Therefore, the actions and required completion times are reflected in plant procedures, as necessary, and in the operator training programs.

4. The licensee has demonstrated that the action can be completed in the time required considering the aggregate affects, such as workload or environmental conditions, expected to exist when the action is required.

The credited operator actions associated with the proposed procedure changes will be performed from the control room which is habitable post-LOCA (mild environment). Verification that UHS cooling tower bypass valves are in their normal position and fans are at the proper speed may be performed locally if radiological conditions permit. (1) Isolation of a failed ESW train within 70 minutes of an LBLOCA has been evaluated and timed using simulator exercises. These exercises have demonstrated the credited operator actions can be accomplished when taking the aggregate operator workload into consideration. 3

(2) Swapping the UHS bypass valve and fan speed control from the UHS cooling tower inlet to the ESW pump discharge temperature instrumentation loops prior to 4 hours into the accident will not be a time-critical action as the operators are not overburdened with work at 4 hours into an LBLOCA. The workload at that time will be acceptably minimal to perform this task. The Operations department has performed table top discussions and walkthroughs during training cycle 12-01 and demonstrated the new procedural guidance to be acceptable. (3) Isolation of an ESW train given failure of the operator action (2) handswitch to swap UHS equipment control is expected to be completed within 24 hours of reaching fan control temperatures between the fast and slow temperature limits. As operators will be continuously monitoring fan speed vs. ESW pump discharge temperature, as soon as the control response is shown to be incorrect, the affected ESW train will be secured per EOP Addendum 17. Since this assumed single failure is only applicable to a scenario in which the UHS cooling tower bypass valve does not fail, an additional indicator of switch failure will manifest itself by virtue of the fact that the two trains of fans will be operating at different speeds. Thus, 24 hours to identify this condition and secure the affected ESW train is more than adequate. (4) Isolation of a train ofESW within 7 days of an LBLOCA was not simulated with respect to the time requirement as the revised procedural controls are sufficient for an operator action time of this length without a simulation. In addition, this is also considered to be acceptable because (at 7 days into an LBLOCA event) additional direction from the TSC will not be burdensome. At 7 days into an LBLOCA event the workload will be minimal. Operator action to secure an ESW train is covered in standard training. Operators have additionally been trained on this 7-day requirement to ensure understanding.

5. A general discussion of the ingress/egress paths taken by the operators to accomplish functions.

The credited operator actions associated with the EOP changes will be taken from the control room which is habitable post-LOCA and do not involve ingress/egress paths. The revised EOP guidance does include the option (not a requirement) to locally assure that the UHS cooling tower bypass valves are in the correct position, if radiological conditions permit. If radiological conditions do not permit local bypass valve manipulation, the affected ESW train will be secured per EOP Addendum 17.

6. The evaluation of the change considers the ability to recover from credible errors in performance of manual actions and the expected time required to make such a recovery.

The implemented EOP revisions do not involve non-recoverable errors. Addition of heat to the UHS is a reversible process further discussed in FSAR Site Addendum Section 9.2.5.5. 4

(1) Isolation of an ESW train within 70 minutes given a failed train component is governed by procedure E-1 and EOP Addendum 17. This procedure has been extensively trained on and is now included in the operator requalification program. Missing a step in the procedure is unlikely. Identification of failed UHS components will be performed using an assortment of safety-related and non-safety equipment. As only one piece of equipment is assumed to fail in a given scenario, the associated control room indication is assumed to function. Failure ofUHS equipment will be identified in an LBLOCA condition. Subsequent securing of one ESW train involves stopping an ESW pump which will immediately be identified and corrected if an error has been made. (2) Swap over ofUHS Cooling Tower equipment control is governed by procedures E-1 and EOP Addendum 40. As with operator actions (1) and (4) this is a clearly defined requirement that should not be missed once entering the procedure. For the scenarios where another single failure has occurred, such as failure of the bypass valve to close, it is not credible to also have this handswitch fail. However, for the no equipment failure scenario associated with operator action (4) below, the single failure of this switch introduces a new operator action (3) as discussed below. (3) Failure of the swap over handswitch in operator action (2) above could result in automatic control at higher temperatures off the wrong control point and could lead to excessive inventory loss. UHS temperature is continuously monitored during an LBLOCA via EOP Addendum 40, Step 5. Control room operators would know if equipment control was using the wrong temperature loops as the UHS cooling tower fans would not be cycling at the correct temperatures. Additionally, the two trains would be operating via different control parameters and would be operating differently given this condition providing another flag to the operators that there is an issue. (4) Isolation of an ES W train 7 days into an LBLOCA event is governed by procedures EIP-ZZ-00240 Addendum Band EDP-EF-UHSOl. EIP-ZZ-00240 Addendum B directs the review ofEDP-EF-UHS01, which in tum directs the operators to secure one ESW train. The TAC Checklist (EIP-ZZ-00240 Addendum B) is frequently reviewed and this requirement will not be missed. Additionally, securing one ESW train and its ESW pump will be immediately identified and corrected if an error has been made. For the no equipment failure cases in Calculation EF-123 (both maximum evaporation and minimum heat transfer), adequate UHS inventory margin exists to allow for 24 hours of run time with a failed fan control swapover switch once fan control has been obtained. Note that at this time in the accident UHS temperature limits are not in jeopardy. Per FSAR Site Addendum Section 9.2.5.5 operator action has always been considered as potentially necessary to maintain UHS pond temperature within allowable limits. It is acceptable to allow for operator diagnosis and resolution of this condition. 5

7. Any additional support personnel and/or equipment required by the operator to carry out actions.

The credited operator actions will be performed in the control room via local indication and switches requiring no additional personnel and/or equipment. The revised EOP guidance includes actions to locally assure the affected UHS cooling tower bypass valves are in their correct position, if radiological conditions permit. This action would be taken at the UHS cooling tower. This may require equipment operators to manually reposition the bypass valves using valve handwheels.

8. A description of information required by the Control Room staff to determine whether such operator action is required, including qualified instrumentation used to diagnose the situation and to verify that the required action has successfully been taken.

The control room staff will be able to determine whether or not the actual status of UHS cooling tower components matches their demand status using a combination of Class 1E instrumentation and non-safety related plant annunciators, switch indication, and plant computer points. The instrumentation used is not located such that it would be subjected to harsh environments post-LOCA. Therefore, no environmental qualification is necessary. (1) Isolation of an ESW train within 70 minutes given a failed UHS cooling tower component requires the status of the following items: -Annunciators 30E and 31E: NG07 and NG08 bus trouble annunciators - Computer points EFT0067 A & 68A: ESW return temperature (UHS cooling tower inlet temperature) - EFHIS0065A and 66A on control room panel RL019 or locally at EFHV0065 and 66: UHS cooling tower bypass valve position indication. - EFHIS0061A & 62A on control room panel RL019 or locally at EFHIS0063A/C, 63B/D, 64A/C, and 64B/D: UHS cooling tower fan speed indication. Verification of successful isolation can be achieved using the ES W pump running indication found on safety-related hand indication switches EFHIS0055A and EFHIS0056A on control room panel RL019. (2) & (3) Swapover ofUHS cooling tower equipment control is time-based and does not require input information. Verification of the operator action will be to validate the ESW pump discharge temperature on the safety-related main control board (MCB) temperature indicators EFTI0061 & 62 against the expected UHS cooling tower fan speed shown on safety-related handswitches EFHIS0061A & 62A. The fan speed control operating band is lower for the ESW supply (ESW pump discharge) temperature loop than the ESW return (UHS cooling tower inlet) temperature loop. Verification of successful ESW train 6

isolation can be achieved using the ESW pump running indication found on safety-related handswitches EFHIS0055A and EFHIS0056A on control room panel RL019. (4) Isolation of an ESW train 7 days into an LBLOCA event requires ESW pump status indication. If both pumps are running at 7 days, then one train will be secured. Indication of pump status can be found on safety-related hand indication switches EFHIS0055A and EFHIS0056A on control room panel RL019. This indication can also be used to verify the required action has successfully been taken.

9. Consideration of the risk significance of the proposed operator actions.

The credited operator actions have been found to be of low risk significance (LBLOCAs with coincident failures are rare events with low core damage frequency values). Each action has clear and direct procedural guidance as to when and what action to take. The actions are relatively simple in nature and performed in the control room which is a mild-environment. Failure to perform the actions correctly will be identified and corrected in an adequate amount of time.

10. The evaluation considers the effect of the change on plant systems.

The credited operator actions will have no adverse impact on plant systems. Implementation of the proposed changes will enable plant operators to ( 1) diagnose and mitigate a valid single failure by placing the plant in an alignment that is consistent with its design bases, (2) manually switch UHS cooling tower bypass valve and fan control from the UHS cooling tower inlet to the ESW pump discharge to maintain design basis UHS temperature and inventory limits, (3) secure a train ofESW given a failure of the switch associated with credited operator action (2), and (4) secure an ESW train after 7 days to maintain design basis UHS inventory. None of these actions impact normal operating procedures or work. Should a postulated single failure of UHS cooling tower components result in a train of ESW transmitting an excessive heat load to the UHS, the implemented procedure revisions provide a mechanism to diagnose and respond to the failure and prevent UHS bulk temperatures from going beyond the analyzed maximum value of92.3°F. These actions will additionally assure the UHS has adequate inventory over its expected 30-day mission time. If the recovery actions are successful, then both trains ofESW would be in operation in a manner consistent with automatic actuations that occur after an LBLOCA. Should recovery of the degraded train be unsuccessful, following implementation of the credited operator actions, the plant would be placed in a single-train alignment that is consistent with its design basis. 7

11. Nuclear-safety-related operator actions or sequences of actions may be performed by an operator only where a single operator error of one manipulation does not result in exceeding design requirements for design basis events.

The implemented EOP revisions do not involve any nuclear safety-related operator actions or sequences of actions where a single operator error of one manipulation will result in exceeding a design requirement for design basis events. Addition of heat to the UHS is a reversible process. Should an error occur that would result in the wrong train being re-positioned, control room personnel would be made aware that neither train would have a match between demand and actual lineup. Operators would then correct the misalignment. Also, if the UHS cooling tower fan speed temperature loops were not controlling fan speed correctly or if hands witch EFHS0067 (0068) were mispositioned, control room personnel would be made aware of the misalignment of fan speed vs. ESW supply (pump discharge) temperature as they are performing EOP Addendum 40.

12. All nuclear-safety-related operator actions to be performed in less than 30 minutes following the initiation of design basis events shall be capable of being performed in the control room.

This question is not applicable to the credited operator actions associated with this license amendment request as they all occur in time frames greater than 30 minutes following the initiation of a design-basis LBLOCA. EOP Device Pedigree The following devices, indicators, and annunciators are used in the EOPs to cue the credited operator actions: E-I step II.a, main control room annunciator panel RKO IS bus voltage annunciator windows 30E and 3IE forNG07 and NG08 undervoltage-Plant annunciators are non-safety related and non-Class IE; however, these annunciator windows are driven by Class IE, seismically qualified, undervoltage relays NG0727B and NG0827B. Annunciator response procedure OTA-RK-OOOI6 Addenda 30E and 3IE direct the control room operators to check computer points NGE0024A and NGE0026A to verify undervoltage conditions. Computer points are non-safety related and non-Class I E. If the annunciators are caused by bus undervoltage, E-I step II.a (Response Not Obtained (RNO) column) directs that the affected ESW train be secured per EOP Addendum I7. EOP Addendum I7 - All of the controls and indications used in EOP Addendum I7 for securing the affected ESW train are safety-related, Class IE, seismically qualified, and located in the main control room. 8

E-1 step ll.b, computer points EFT0067A and EFT0068A for determining ESW return temperature (UHS inlet) are non-safety related, non-Class 1E, and located in the main control room. If the computer points are not available, E-1 step ll.b RNO column directs the use of EFTSHL0067B and EFTSHL0068B which are non-safety related, non-Class IE, and located in the control building basement (1974 foot elevation). E-1 step ll.c, UHS cooling tower bypass valve position indicators EFHIS0065A and EFHIS0066A are safety-related, Class 1E, seismically qualified, and located in the main control room. E-1 step ll.d, UHS cooling tower fan speed indicators EFHIS006I A and EFHIS0062A are safety-related, Class IE, seismically qualified, and located in the main control room. E-I step I9 transfers to EOP Addendum 40 at 4 hours after event initiation. EOP Addendum 40, step I -See E-I step Il.a (check same bus voltage annunciator windows). EOP Addendum 40, step 2- ESW supply temperature control switches EFHS0067 and EFHS0068 are safety-related, Class IE, seismically qualified, and located in the main control room. EOP Addendum 40, step 3- ESW pump discharge temperature indicators EFTI006I and EFTI0062 are safety-related, Class IE, seismically qualified, and located in the main control room. EOP Addendum 40, step 4- UHS cooling tower bypass valve position indication EFHIS0065A and EFHIS0066A are safety-related, Class IE, seismically qualified, and located in the main control room. EOP Addendum 40, step 5- UHS cooling tower fan speeds indicators EFHIS006IA and EFHIS0062A are safety-related, Class IE, seismically qualified, and located in the main control room. EOP Addendum 40, step 6 - UHS pond level indicating switch EFLIS0027 is a non-safety related, non-Class IE, local indicating switch providing alarm inputs to main control room annunciator panel RK020 level indication window 55D; however, it is only used in this EOP Addendum to assess whether UHS makeup should be initiated which is an action not credited in the ES WIUHS analysis supporting this amendment request. EOP Addendum 40, step 7 -Evaluate long term ESW and UHS status. 9

Justification for Crediting Non-Safety Related Annunciators and Computer Points The following criteria are the bases for identification of Type A variables for the Callaway Plant as discussed FSAR Section 7A.3 .1. The terminology used in the discussion is consistent with that of the generic Emergency Response Guidelines (ERGs) for Westinghouse plants, which were submitted to the NRC by Westinghouse Owners Group letter OG-64, dated November 30, 1981.

a. Variables used for event diagnosis are classified as Type A because these variables direct the operator to the appropriate Optimal Recovery Guidelines (formerly termed Emergency Operating Instructions) or to monitoring of critical Safety Functions.

b. Variables used by the operator to perform manual actions prescribed by the Optimal Recovery Guidelines, which are associated with Condition IV events (LBLOCA, MSLB, and SGTR), are classified as Type A. Condition I, II and III events are not considered in identifying Type A variables (e.g., Spurious Safety Injection).

c. Variables which identify the need for operator action to correct single failures are not classified as Type A. These actions are often identified as "Notes" or "Contingency Actions" in the ERGs.

d. Variables associated with operator actions required for events not currently in the design bases of the plant are not identified as Type A variables.

Since this license amendment request is concerned with single failure recovery, Type A variables are not required. In addition, the analysis of the MODE 1 inadvertent boron dilution event in FSAR Section 15.4.6.2 with rods in automatic control and the analysis of the CVCS malfunction event in FSAR Section 15.5.2.2 take credit for operator actions cued by annunciators (rod insertion limit low-low, pressurizer level, pressurizer pressure alarms). RG 1.97 Review Background The extent of Callaway's conformance with NRC RG 1.97 has been reviewed and approved by the NRC on several occasions. The background documents demonstrating that approval are listed below as support for the current text in FSAR Section 7A.3 .1. SNUPPS letters SLNRC 82-031 (7/6/82), SLNRC 83-0019 (4/15/83), and SLNRC 84-107 (8/16/84) were reviewed and approved in NUREG-0830 Supplements 3 and 4 for the purpose of granting Callaway's Operating License with Condition 2.C.(7.(c) to install 5 instrumentation functions prior to restart from the first refueling outage. In a Safety Evaluation Report dated 4-10-85, the NRC rendered a finding that Callaway 10

instrumentation was acceptable for meeting the recommendations of RG 1. 97 Revision 2. Union Electric letter ULNRC-1289 dated 4-7-86 notified the NRC that the instrumentation required per License Condition 2.C.(7).(c) had been installed and was operable/functional (5 of the radiation release monitors are non-safety related, non-TS devices). NRC Inspection Report 50-483/87015 (8/6/87) closed TI 2515/87 regarding Callaway's implementation ofRG 1.97 with one IN 84-90 issue which was subsequently closed in an NRR letter dated 2-18-88. In the Safety Evaluation for Callaway License Amendment 169 (1 0/25/05) the NRC again found that License Condition 2.C.(7).(c) had been fulfilled and could be deleted from the Operating License. 11}}

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TAC:MF0378, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions 13 May 2013 Answers Results Approval Other: ML13354B816, ML14099A206, ULNRC-06107, ULNRC-06107 - RAI Response
MONTHYEAR2013-05-13 [Table View]

ULNRC-05867, Application for Amendment to License No. NPF-030 (LDCN 12-0015), Revision to Technical Specification 3.7.9

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ULNRC-05867, Application for Amendment to License No. NPF-030 (LDCN 12-0015), Revision to Technical Specification 3.7.9

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Enclosure:

Enclosure:

SUMMARY

SUMMARY

System Description

3.0 TECHNICAL EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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