ULNRC-05975, Revision to TS LCO 3.4.12, Cold Overpressure Mitigation System (Coms), to Clarify No Limitation on Normal Charging Pump Use During Modes 4, 5 and 6 License Amendment Request LDCN 13-0003

Revision to TS LCO 3.4.12, Cold Overpressure Mitigation System (Coms), to Clarify No Limitation on Normal Charging Pump Use During Modes 4, 5 and 6 License Amendment Request LDCN 13-0003

ML14023A803
Person / Time
Site:	Callaway
Issue date:	01/23/2014
From:	Maglio S Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LDCN 13-0003, ULNRC-05975
Download: ML14023A803 (45)

Text

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WAmeren Callaway Plant MISSOURI January 23, 2014 ULNRC-05975 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 UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 REVISION TOTS LCO 3.4.12, "COLD OVERPRESSURE MITGATION SYSTEM (COMS),"

TO CLARIFY NO LIMITATION ON NORMAL CHARGING PUMP USE DURING MODES 4, 5 AND 6 LICENSE AMENDMENT REQUEST LDCN 13-0003 Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit," Ameren Missouri (Union Electric Company) herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant.

The proposed amendment revises Technical Specification (TS) 3.4.12 to reflect the mass input transient analysis that assumes an Emergency Core Cooling System (ECCS) centrifugal charging pump (CCP) and the normal charging pump (NCP) capable of injecting into the RCS when TS 3.4.12 is applicable. The proposed amendment would additionally revise TS Table 3.3.1-1, "Reactor Trip System Instrumentation," to remove unnecessary page number references.

The appropriate TS Bases changes for the proposed revisions toTS 3.4.12 are included for information and reflect the proposed changes.

The Enclosure provides a description of the proposed changes and the supporting evaluation.

Attachments 1 through 3 provide marked-up Technical Specifications, marked-up Proposed Technical Specification Bases, and retyped Technical Specifications for the proposed changes, respectively, in support of this amendment request. Attachment 2 is provided for information only. Final TS Bases changes will be processed under the program for updates per TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment is implemented.

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • PO Box 620 Fulton, MO 65251 AmerenMissouri.com

ULNRC-05975 January 23, 2014 Page2 It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." 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.

Further, this submittal does not contain new commitments.

The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the proposed changes and have approved the submittal of this amendment application.

The proposed changes toTS 3.4.12 are considered to be administrative changes based on the safety evaluation for Amendment No. 124 to the Callaway Operating License. As such, Ameren Missouri requests approval of the requested license amendment by February 1, 2015. Ameren Missouri further requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.

In accordance with 10 CFR 50.91 "Notice for public comment; State consultation," Section (b)(l), a copy of this amendment application is being provided to the designated Missouri State official.

If there are any questions, please contact J.P. Kovar at 314-225-1478.

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

Sincerely, I I '1 '?, / 2iJ i 4

.Ll~-ti A- M ~

Executed on:

Scott A. Maglio Manager, Regulatory Affairs

Enclosure:

Evaluation of the Proposed Change Attachments to the

Enclosure:

1. Technical Specifications Page Markups

2. Proposed Technical Specification Bases Page Markups

3. Retyped Technical Specification Pages

ULNRC-05975 January 23, 2014 Page 3 cc: Mr. Marc L. Dapas 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-05975 January 23, 2014 Page4 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:

F. M. Diya C. 0. Reasoner III B.L.Cox L. H. Graessle J. S. Geyer S. A. Maglio Corporate Communications NSRB Secretary T. B. Elwood STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Ms. Leann Tippitt-Mosby (DNR)

ENCLOSURE EVALUATION OF THE PROPOSED CHANGE

1. DESCRIPTION The proposed amendment would revise Technical Specification (TS) 3.4.12, "Cold Overpressure Mitigating System (COMS)," to reflect the mass input transient analysis that assumes an Emergency Core Cooling System (ECCS) centrifugal charging pump (CCP) and the normal charging pump (NCP) capable of injecting into the RCS during the TS 3.4.12 Applicability.

An unrelated, proposed editorial change is also included in this amendment request.

Specifically, a revision toTS Table 3.3.1-1, "Reactor Trip System Instrumentation," is proposed in order to correct page numbers given for certain Notes referenced in the Table.

2. PROPOSED CHANGES This amendment application requests changes toTS 3.4.12 that will differentiate between the ECCS CCPs and the non-safety related NCP, and provide clarification that no limits are placed on operation of the NCP during applicability ofTS 3.4.12.

Limiting Condition for Operation (LCO) 3.4.12 is revised to state, in part:

COMS shall be OPERABLE with a maximum of zero safety injection pumps, one Emergency Core Cooling System (ECCS) centrifugal charging pump, and the normal charging pump capable of injecting into the RCS, with the accumulators isolated and one of the following pressure relief capabilities:

Note 1 to LCO 3.4.12 and Condition Bare revised to specify the centrifugal charging pumps as ECCS centrifugal charging pumps.

Required Action B.1 is revised to state:

Initiate action to verify a maximum of one ECCS centrifugal charging pump and the normal charging pump capable of injecting into the RCS.

Surveillance Requirement (SR) 3.4.12.2 is revised to state:

Verify a maximum of one ECCS centrifugal charging pump and the normal charging pump capable of injecting into the RCS.

This amendment application also requests changes to TS Table 3.3.1-1 to correct referenced page numbers, which had been changed under License Amendment 202 (Reference 5). The

Enclosure to ULNRC-05975 Page 2 Allowable Values for Functions 6 and 7 in Table 3.3.1-1 are revised to replace the page number references with the explanatory phrase "(at the end of this Table)."

The TS markups and retyped pages are provided in Attachments 1 and 3, respectively.

Corresponding TS Bases changes are provided for information only in Attachment 2. A change to the Bases forTS SR 3.4.12.8 to provide clarification and remove redundant information is also provided for information only, in Attachment 2.

3. BACKGROUND The cold overpressure mitigation system (COMS) controls RCS pressure at low temperatures in order to ensure the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure-temperature (P-T) limits of 10 CFR 50 Appendix G, as specified in the Pressure Temperature Limits Report (PTLR.) The reactor vessel is the limiting RCPB component for demonstrating such protection, as exceeding the RCS P-T limits by a significant amount could cause brittle cracking of the reactor vessel.

The COMS provisions for pressure relief are two pressurizer power-operated relief valves (PORVs) with reduced lift settings, or two residual heat removal (RHR) suction relief valves, or one PORV and one RHR suction relief valve, or a depressurized reactor coolant system (RCS) and a RCS vent of sufficient size. One RCS relief valve has adequate relieving capability to prevent overpressurization for the required coolant input capability, but two RCS relief valves are required Operable for redundancy. At low temperatures, emergency core cooling system (ECCS) pumps and the normal charging pump (NCP) are potentially capable of providing coolant input to the RCS.

The ECCS provides low, intermediate and high head flowpaths to inject into the reactor coolant system (RCS) capable of mitigating an accident involving loss of reactor coolant inventory. Two residual heat removal (RHR) pumps provide redundant capability for low head ECCS injection, while two safety injection (SI) pumps provide redundant capability for intermediate head ECCS injection. Redundant capability for high head ECCS injection is provided by two ECCS centrifugal charging pumps (CCPs.) Of the ECCS pumps, only the SI pumps and CCPs are capable of producing enough discharge pressure to challenge the RCS P-T limits.

In the Chemical and Volume Control System (CVCS), there are three charging pumps capable of taking suction from the volume control tank (VCT) or a borated water source (i.e., from the refueling water storage tank or the discharge from a boric acid transfer pump) and providing charging or injection flow to the RCS. These include the ECCS CCPs and a non-safety related NCP, which is not an ECCS pump, but which provides charging flow during normal operation.

Use of the NCP instead of an ECCS CCP to provide normal charging to the RCS at low temperatures and pressures offers the following operational advantages:

Enclosure to ULNRC-05975 Page 3

• Due to its design, the NCP may be operated at a discharge flow rate as low as 45 gpm.

In contrast, to prevent excessive wear or damage to the pump from overheating, an ECCS CCP must not be operated with flow < 130 gpm for more than 30 minutes, and must never be operated with flow < 60 gpm.

• When the NCP is not available to provide charging flow, it is necessary to keep the RHR system/train in aRCS cooldown alignment until RCS pressure exceeds 350 psig, in order to provide adequate letdown flow to prevent overfilling the pressurizer. During heatup from cold shutdown, the following undesirable consequences are associated with this mode of operation:

o Keeping RHR in aRCS cooldown alignment at higher RCS pressures creates the potential for dissolved gases to come out of solution and create gas voids when RHR is later placed in an ECCS lineup to RWST.

o Up to an additional2 hours of outage critical path time are expended by keeping RHR in aRCS cooldown alignment until RCS pressure exceeds 350 psig, due to the additional time needed for RCS heatup.

The PTLR specifies the maximum allowable actuation logic setpoints for the PORVs and the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup to meet the Appendix G requirements during MODES when COMS is in service. The mass injection (MI) transient analysis used to prepare the PTLR presently assumes that the NCP and one ECCS CCP are capable of simultaneously injecting to the RCS.

4. TECHNICAL ANALYSIS Evaluation of Low Temperature Overpressure Transients The ASME Code (Section III, Appendix G) establishes guidelines and upper limits for RCS pressure primarily for low temperature conditions less than approximately 350 °F. The low-temperature transient mitigation system discussed in the Final Safety Analysis Report (FSAR)

Section 5.2.2.1 0 addresses these conditions as discussed in the following paragraphs.

Two specific transients: mass input and heat input, with the RCS in a water-solid condition, have been considered as the design basis for COMS. Each of these scenarios assumes as an initial condition that the RHR System is isolated from the RCS, and thus the relief capability of the RHR System relief valves is not available. Transient analyses have been performed to determine the maximum pressure for the postulated mass input and heat input events.

The COMS PORV setpoint curve (PTLR Figure 2.2-1) is determined based on the updated heatup and cooldown limit curves, and the analysis results of limiting COMS transients. The methodology for this determination is given in WCAP-14040-A (Reference 7). The limiting COMS mechanisms analyzed for Callaway Plant under water solid conditions were:

a. FOR LIMITING MASS ADDITION COMS MECHANISM

Enclosure to ULNRC-05975 Page 4 Operation of one ECCS CCP and the NCP with instrument air failure resulting in the flow control valve in the letdown line failing closed (letdown isolation) and the flow control valve in the charging line failing open (maximum charging flow), and

b. FOR LIMITING HEAT ADDITION COMS MECHANISM Inadvertent start-up of a reactor coolant pump with a maximum 50 °F temperature mismatch between the RCS and the hotter steam generators.

These analyses, using the LOFTRAN computer code, take into consideration pressure overshoot and undershoot beyond the PORV open and close setpoints, which can occur as a result of time delays in signal processing and valve stroke times. The maximum expected pressure overshoot and undershoot calculated from the limiting mass input and heat input transients, in conjunction with the 10 CFR 50 Appendix G pressure limits and reactor coolant pump No. 1 seal pressure limit, are utilized in the selection of the pressure setpoints for the PORV. The mass injection rate assumed in the design-basis mass input transient is based on 100% flow capacity of the NCP and one CCP. The maximum combined pump flow has been assumed in order to envelop the maximum flow possible by the operational configuration that uses the NCP for charging with one CCP remaining OPERABLE, or use of the CCP for charging with the NCP remaining functional, during shutdown modes. The analyses demonstrated that one PORV or one RHR suction relief valve or an RCS vent of at least 2.0 square inches is capable of limiting the RCS pressure excursions below the 10 CFR 50 Appendix G limits.

Both the heat input and mass input analyses take into account the single failure criteria, and therefore, only one PORV was assumed to be available for pressure relief. The above events have been evaluated considering the allowable pressure/temperature limits established by the Appendix G guidelines. The evaluation of the transient results concluded that reactor vessel integrity is not impaired.

The mass injection (MI) analysis for the Callaway COMS setpoints assumes that the flows from one ECCS CCP and the NCP inject into the RCS, a basic assumption in the MI analysis since NRC approval of Callaway License Amendment No. 124 (Reference 2) dated April2, 1998. Detailed discussions of analysis input assumptions and results were provided in support of License Amendment No. 124 via Union Electric letters ULNRC-3756 (Reference 16) dated March 3, 1998 and ULNRC-3774 (Reference 17) dated March 17, 1998. The March 17, 1998 letter included Proprietary and Non-Proprietary attachments since Westinghouse (the owner of the analysis) withheld several aspects of the COMS analysis such as RCS pressure-dependent PORV relief capacity, PORV open stroke time and non-linear flow rates as the PORV stroked open, analysis pressure uncertainties, etc.

For the Callaway Replacement Steam Generator (RSG) project (Callaway License Amendment No. 168 (Reference 4) dated September 29, 2005), Westinghouse reanalyzed the COMS Heat Injection (HI) transient due to SG design changes, but evaluated the MI analysis results to not

Enclosure to ULNRC-05975 Page 5 be impacted. This finding was discussed in Section 4.3.5 ofWCAP-16265-P (Reference 8) which was attached to the RSG license amendment request (ULNRC-05056 (Reference 9) dated September 17, 2004). NRC Request for Additional Information #11 on the COMS analysis for the RSG project was addressed in two letters, ULNRC-05159 (Reference 10) dated June 17, 2005 and ULNRC-05178 (Reference 11) dated July 29, 2005. NRC approval was discussed in the attached excerpt from the NRC's Safety Evaluation for License Amendment No. 168:

"3.4.3.5 Low-Temperature Overpressure System (LTOP) (LAR Section 4.3.5)

The low-temperature overpressure protection (L TOP) system is the cold overpressure mitigation system (COMS) at Callaway. This system provides RCS pressure relief capability at relatively low-temperature operation (i.e., at RCS temperature less than 350°F). Two PORVs are used to provide the automatic relief capability during the design-basis mass input (MI) and the design-basis heat injection (HI) transients to automatically prevent the RCS pressure from exceeding the pressure and temperature limits of 10 CFR 50, Appendix G.

There are differences between the original Westinghouse Model F SGs and the replacement Framatome Model 73/19T SGs that would affect the current design-basis LTOP HI transient. The licensee performed an evaluation of the MI transient and concluded that the current MI analysis remained applicable for the replacement SG.

The licensee re-analyzed the HI transient with the replacement SGs. Using the HI transient re-analysis results and the current MI results, the licensee developed LTOP setpoints.

The current pressure and temperature limits report (PTLR) for Callaway has RCP operation restrictions. Two RCPs would be allowed to operate whenever the RCS temperature is _:s 200 degree °F. The licensee has decided to implement COMS setpoints that have no RCP operation restrictions. These COMS setpoints are more limiting than the currently presented setpoints in the PTLR with the RCP operation restriction. The licensee evaluated the COMS setpoints for no RCP operation restrictions and determined that these setpoints will not present any undue burden on plant operation. Therefore, upon approval of this amendment, the licensee will revise the PTLR for Callaway and change the COMS setpoints to reflect no RCP operation restrictions as part of its implementation of the installation of the replacement SGs.

The current LTOP arming temperature of275°F remains applicable for the replacement SG program. Based on this, the NRC staff finds that the COMS analysis and setpoints are acceptable for the replacement SGs."

License Amendment No. 168 included a License Condition requiring a PTLR update which was submitted (PTLR Revision 4) via ULNRC-05219 (Reference 12) dated October 21, 2005.

Enclosure to ULNRC-05975 Page 6 After the RSG project, Callaway adopted WCAP-14040-A Revision 4 under a change to the PTLR that did not require NRC review and approval. This was reflected in PTLR Revision 5 which was submitted for information per the requirements of Technical Specification 5.6.6, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)," via ULNRC-05356 (Reference 13) dated January 5, 2007. The other change included in PTLR Revision 5 was an increase in the PORV opening and closing stroke times (reported in LER 2006-001-00, ULNRC-05261 (Reference 14) dated March 14, 2006 and 50.59 Summary Report Evaluation 06-06, ULNRC-05734 (Reference 15) dated October 26, 2010). Other than the implementation ofWCAP-14040-A Revision 4 methodology (which was generically approved by the NRC and implemented at Callaway consistent with the NRC's Safety Evaluation conditions) and the change in PORV stroke times, the input assumptions used in the current MI analysis are the same as those previously reviewed by the NRC. PTLR Revision 5 (current revision) contains the maximum allowable PORV setpoints in Figure 2.2-1 and Table 2.2-1.

Additional Information The proposed change to TS LCO 3 .4.12, Required Action B.1 and TS Surveillance Requirement 3.4.12.2 replaces the limitation "a maximum of one centrifugal charging pump" with "a maximum of one ECCS centrifugal charging pump and the normal charging pump" capable of injecting into the RCS. This is considered to be an editorial change to clearly state that TS does not restrict use of the NCP during COMS modes, which is consistent with Callaway's current licensing basis.

The proposed change to Note 1 toTS LCO 3.4.12 and Condition B is considered to be an editorial change to clearly indicate that the Note and Condition apply only to the ECCS CCPs.

Since original plant licensing in 1984, Ameren Missouri (previously Union Electric) has considered the terminology "centrifugal charging pump" and "CCP" as only referring to the safety-related ECCS CCPs. The MI transient analysis of record analyzes one ECCS CCP and the NCP being capable of injecting into the RCS. The MI transient analysis of record does not analyze both ECCS CCPs and the NCP being capable of injecting into the RCS.

The NCP is normally in service to maintain the charging and letdown functions of the CVCS.

One ECCS CCP is operable and capable of injecting into the RCS but is not typically in operation. During a typical refueling outage, maintenance activities are performed during train- related outage windows (train 'A' or train 'B' safety-related equipment). When the maintenance activities are completed and the train 'A' equipment is restored to service, then train 'B' equipment is taken out of service. Performing ECCS CCP swap operations for maintenance activities requires both CCPs to be capable of injecting for a limited period of time. During the time allowed for pump swap operation, the inoperable/nonfunctional CCP must first be restored to operable status to meet LCO 3.5.3, "ECCS-Shutdown," and FSAR Section 16.1.2, "Boration Systems." FSAR Sections 16.1.2.1 and 16.1.2.3 require that one boration injection flow path with one ECCS CCP be operable/functional in MODES 4, 5, and 6

Enclosure to ULNRC-05975 Page 7 with the reactor vessel head installed. Note 1 to LCO 3 .4.12 allows a 1-hour exception from the MI transient analysis pump flow input assumptions to allow ECCS CCP swap operations.

Prior to implementation of Improved Technical Specifications (ITS), there was no TS LCO restriction on the number of OPERABLE ECCS CCPs during MODE 4. Instead, TS 3/4.5.3 "ECCS Subsystems- Tavg < 350°F," included TS LCO 3.5.3, which stated in part:

As a minimum, One ECCS subsystem comprised of the following shall be OPERABLE:

a. One OPERABLE centrifugal charging pump,

b. One OPERABLE RHR heat exchanger,

c. One OPERABLE RHR pump. And

d. An OPERABLE flow path capable of taking suction from the RWST upon being realigned and transferring suction to the containment sump during the recirculation phase of operation.

Applicability: MODE 4 along with TS SR 4.5 .3 .2, which stated in part:

All centrifugal charging pumps and Safety Injection pumps, except for the above required OPERABLE pumps, shall be demonstrated inoperable* by verifying that the motor circuit breakers are secured, in the open position within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after entering MODE 4 from MODE 3 prior to the temperature of one or more of the RCS cold legs decreasing below 325°F and at least once per 31 days thereafter.

• An inoperable pump may be energized for testing or for filling accumulators provided the discharge of the pump has been isolated from the RCS by a closed isolation valve with power removed from the valve operator, or by a manual isolation valve secured in the closed position.

In MODE 5 and MODE 6 with the reactor vessel head on, TS 3/4.5.4, "ECCS SUBSYSTEMS

- Tavg <200°F," required: "All Safety Injection pumps and one Centrifugal Charging Pump shall be inoperable." Action b required: "With two Centrifugal Charging Pumps OPERABLE, restore one of the Centrifugal Charging Pumps to an inoperable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."

The conversion to ITS utilized Revision 1 ofNUREG-1431 (Reference 6). Standard TS 3.4.12, Condition B, included a Note to Required Action B.l indicating that two charging pumps may be capable of injecting into the RCS during pump swap operation for .:S 15 minutes.

In Callaway's ITS conversion, the Note was relocated from Required Action B.1 to the LCO, consistent with Technical Specification Task Force (TSTF) traveler TSTF-285-A, Rev. 1, "Charging Pump Swap LTOP Allowance," (Reference 18),.

Enclosure to ULNRC-05975 Page 8 The justification associated with the NRC-approved TSTF-285-A allowance to have "N+ 1" pumps temporarily capable of injecting indicates that the mass injection transient analysis is taken into consideration in conjunction with other functions that require an operable ECCS CCP, such that one hour to perform the pump swap operation is reasonable considering the small likelihood of an event during this brief period and other actions available (e.g., operator action to stop any pump that inadvertently starts).

The following additional factors mitigate the risk of a mass injection transient greater than the COMS pressure relieving capability during ECCS CCP pump swaps at low RCS temperature and pressure.

• At low RCS temperature and pressure, TS LCO 3 .4.12 requires redundant active COMS relief valves (any combination of two Operable pressurizer PORVs or RHR suction relief valves) or an adequate [passive] vent path for the reactor coolant system.

Although not credited in the analysis for a mass injection transient, a second Operable COMS relief valve mitigates the risk that an event causing both ECCS CCPs and the NCP to inject to the RCS would create a mass injection transient greater than the available relieving capability.

• In event of an ECCS actuation signal, the automatic signals to start both ECCS CCPs would be offset by an automatic signal to trip the NCP (per the plant's design). This mitigates the risk that both ECCS CCPs and the NCP could be injecting to the RCS following an ECCS actuation signal.

• Callaway TS Administrative Control (AC) 5.4.a states in part that applicable procedures recommended in Regulatory Guide 1.33 Rev. 2, Appendix A shall be established, implemented, and maintained. These include general plant operating procedures for transition from cold shutdown to hot standby, and hot standby to cold shutdown., as well as procedures for startup, operation and shutdown of the RCS, shutdown cooling system (e.g., RHR system), and ECCS. Risk of an inadvertent ECCS actuation signal is mitigated by a procedural requirement to block the analog ECCS actuation signals, except Containment Pressure - High, below the P-11 setpoint (pressurizer pressure less than 1970 psig), in Mode 3.

• When present, a vapor bubble in the pressurizer will mitigate the pressure spike associated with a mass injection transient. Operation with the pressurizer water-solid has been evaluated to be an infrequently performed test or evolution (IPTE) with potential for high consequences if the activity is performed incorrectly. As an IPTE, this activity receives additional oversight from Callaway senior management, including an evaluation of whether just-in-time training (JITT) is needed prior to performing the activity.

5. REGULATORYEVALUATION 5.1 Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TS as part of the license. The Commission's regulatory requirements related

Enclosure to ULNRC-05975 Page 9 to the content ofTS are contained in 10 CFR 50.36, "Technical Specifications." The TS requirements in 10 CFR 50.36 include the following categories: (1) safety limits, limiting safety systems settings and control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls.

Per the requirements of Callaway TS 3.4.1 "Cold Overpressure Mitigation System (COMS),"

the COMS controls RCS pressures at low temperatures to comply with the pressure and temperature limits of 10 CFR Part 50, Appendix G, "Fracture Toughness Requirements," so the integrity of the Reactor Coolant Pressure Boundary is not compromised.

5.2 Precedents The proposed amendment is generally consistent with Wolf Creek Nuclear Operating Company (WCNOC) License Amendment 207 (Reference 1). Although Callaway has requested changes to TS 3 .4.12 similar to the WCNOC License Amendment, Callaway's licensing basis presently differs from WCNOC's, in that the NRC has already reviewed and approved the use of the normal charging pump at Callaway during modes of applicability for COMS, and has recognized that the limitations on centrifugal charging pumps in Callaway's TS 3.4.12 apply only to ECCS pumps.

For the modes of applicability in which the COMS TS requirements are applicable, the NRC safety evaluation for Callaway Plant License Amendment No. 124 states in part that the TS "allows a centrifugal charging pump and the 'normal' charging pump to be operable under these modes of operation."

The NRC safety evaluation for Callaway Plant License Amendment No.l33 (Reference 3) further states in part "the RCS cold overpressure mitigation system (COMS) limitations on ECCS pumps, and related surveillances, are relocated to ITS 3 .4.12."

Consistent with the NRC positions documented in these safety evaluations, the proposed amendment revises TS 3 .4.12 to clarify that limitations on alignment of "centrifugal charging pumps" to inject into the RCS apply to ECCS centrifugal charging pumps, and to specify that the normal charging pump is allowed to inject into the RCS during the Applicability of TS 3.4.12.

5.3 No Significant Hazards Consideration Determination The proposed amendment would revise Technical Specification (TS) 3.4.12, "Cold Overpressure Mitigation System (COMS)," to more clearly reflect provisions allowed by the mass input transient analysis presently cited in the TS 3.4.12 Bases. The changes would make it clear that the Limiting Condition of Operation (LCO) of TS 3.4 .12 may be met with a maximum of one Emergency Core Cooling System (ECCS) centrifugal charging pump (CCP) and the normal charging pump (NCP) available, since the mass input transient analysis assumes one ECCS CCP and the NCP capable of injecting into the Reactor Coolant System

Enclosure to ULNRC-05975 Page 10 (RCS) during the TS 3.4.12 Applicability. The proposed amendment would also remove unnecessary page number references from TS Table 3.3.1-1, "Reactor Trip System Instrumentation."

The proposed change does not involve a significant hazards consideration for Callaway Plant based on the three standards set forth in 10 CFR 50.92(c), "Issuance of Amendment," as discussed below:

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

Response: No.

The TS 3.4.12 Limiting Condition for Operation provides RCS overpressure protection by restricting coolant input capability and providing adequate pressure relief capability during applicable Modes. Analyses have demonstrated that one power-operated relief valve (PORV) or one residual heat removal (RHR) suction relief valve or an RCS vent of at least 2.0 square inches is capable of limiting the RCS pressure excursions below the COMS limits which are based on the pressure-temperature limits of 10 CFR 50 Appendix G. The analyzed mass transient for COMS is based on an assumption that one ECCS CCP and the NCP are both capable of injection to the RCS.

The NRC has previously evaluated the allowance for an ECCS CCP and the NCP being capable of injecting into the RCS during the TS 3.4.12 Modes of Applicability. In the safety evaluation dated April2, 1998 related to the Callaway Plant, Unit 1, Amendment No. 124, the NRC concluded:

The mass input transient analysis assumes simultaneous injection of both a centrifugal charging pump and the 'normal' charging pump into the water-solid RCS while the RHRS and the letdown line are isolated.

In the same safety evaluation, the NRC further concluded that the change to TS Bases allowing the NCP to inject to the RCS during COMS applicability was consistent with the TS LCO and "therefore allows a centrifugal charging pump and the 'normal' charging pump to be operable under these modes of operation."

The proposed change clarifies TS 3.4.12 to allow an ECCS CCP and the NCP to be capable of injecting into the RCS during low RCS pressures and temperatures, consistent with Callaway's NRC-approved licensing basis, and also removes unnecessary page number references from TS Table 3.3 .1-1. The proposed change is thus an editorial one that does not involve a change to the design or operation of the plant, including the plant's safety analysis.

Accordingly, the proposed change does not adversely affect accident initiators or precursors nor does it alter any design assumptions, conditions, or allowed configurations of the facility.

Enclosure to ULNRC-05975 Page 11 In addition, the proposed change does not affect the manner in which the plant is operated and maintained. Finally, the proposed change does not adversely affect the ability of structures, systems and components (SSC) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits, nor does it increase the types and amounts of radioactive effluent that may be released offsite or significantly increase individual or cumulative occupational/public radiation exposure.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

As noted in the response to question 1, the proposed change will not physically alter the plant (i.e., no new or different type of equipment will be installed), nor does it change the methods governing normal plant operation. Accordingly, the proposed change does not introduce new accident initiators or impact assumptions made in the safety analysis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined, nor are the safety analysis acceptance criteria impacted by this change. The intent of the proposed change is for TS 3.4.12 to continue to reflect the provisions and limitations of the mass transient analysis that was performed for ensuring cold overpressure protection of the RCPB and which is already part of the NRC-approved licensing basis for the facility. Consequently, there is no change to the margin of safety, and the proposed change will not result in plant operation or a configuration that is outside the design basis.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, 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.

Enclosure to ULNRC-05975 Page 12 5.4 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) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6. ENVIRONMENTAL CONSIDERATION The proposed amendment is confined to format of the Technical Specifications appended to the Operating license, and editorial, corrective or other minor revisions. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10)(v). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7. REFERENCES

1. NRC Letter "Issuance of Amendment Re: Revise Technical Specification 3.4.12, 'Low Temperature Overpressure Protection (LTOP) System' (TAC No. MF0309)," dated December 6, 2013 [ADAMS Accession No. ML13282A534]

2. Callaway Unit 1 License Amendment No. 124, untitled (Modifies Plant Heatup and Cooldown Curves and Maximum Allowable Power Operated Relief Valve Setpoint for Cold Overpressure Protection) dated April2, 1998 [ADAMS Accession No. ML021640371]

3. Callaway Unit 1 License Amendment No. 133, "Conversion to Improved Technical Specifications for Callaway Plant, Unit 1," dated May 28, 1999 [ADAMS Accession No. ML021640446]

4. Callaway Unit 1 License Amendment No. 168, "Issuance of Amendment Regarding the Steam Generator Replacement Project," dated September 29, 2005 [ADAMS Accession No. ML052570086]

5. Callaway Unit 1 License Amendment No. 202, "Issuance of Amendment Re: Adoption of TSTF-425, Revision 3, 'Relocate Surveillance Frequencies to Licensee Control- RITSTF Initiative 5B' (TAC NO. ME4506)," dated July 29, 2011 [ADAMS Accession No. ML111661877]

6. NUREG-1431 Rev. 1, "Standard Technical Specifications- Westinghouse Plants," dated April30, 1995 [ADAMS Accession No. 9506280476]

7. WCAP-14040-A Rev. 4, "Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cool down Limit Curves," dated May 1, 2004

[ADAMS Accession No. ML050120209]

8. WCAP-16265-P, "Callaway Replacement Steam Generator Program NSSS Licensing Report," (Westinghouse Proprietary) dated August 2004, submitted as Appendix A under cover ofULNRC-5606 (Reference 9)

Enclosure to ULNRC-05975 Page 13

9. ULNRC-05056, "Technical Specification Revisions Associated with the Steam Generator Replacement Project," [ADAMS Accession No. ML042870364]

10. ULNRC-05159, "Technical Specification Revisions Associated with the Steam Generator Replacement Project," dated June 17, 2005 [ADAMS Accession No. ML051790249]

11. ULNRC-05178, "Supplemental Technical Specification Revisions for the Steam Generator Replacement Project," dated July 29, 2005 [ADAMS Accession No. ML052220138]

12. ULNRC-05219, "Figure 14.9 Callaway Plant Pressure and Temperature Limits Report,"

dated October 21, 2005 [ADAMS Accession No. ML053050444]

13. ULNRC-05356, "Figure 14.9 Callaway Plant Pressure and Temperature Limits Report,"

dated January 5, 2007 [ADAMS Accession No. ML070160266]

14. ULNRC-05261, "Licensee Event Report 2006-001 Pressurizer PORV Stroke Time and other delays Exceed Times assumed in COMS Analyses," dated March 14, 2006 [ADAMS Accession No. ML060830414]

15. ULNRC-05734, "10 CFR 50.59 Summary Report," dated October 26,2010 [ADAMS Accession No. ML103000160]

16. ULNRC-3756, "Revision to Technical Specification 3/4.4- Reactor Coolant System,"

dated March 3, 1998 [ADAMS Accession No. 980311 0046]

17. ULNRC-3774, "Revision to Technical Specification 3/4.4- Reactor Coolant System,"

dated March 17, 1998 [ADAMS Accession No. 9803300099]

18. TSTF-285-A, Rev. 1, "Charging Pump Swap LTOP Allowance," [ADAMS Accession No. ML040620093]

ATTACHMENT 1 TECHNICAL SPECIFICATIONS PAGE MARKUPS

, Enclosure to ULNRC-05975 Page2 RTS Instrumentation 3.3.1 TABLE 3.3.1*1 (PAGE 20F 8)

Reactor Trip System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(*)

5. Source Range 2(8) 2 I, J SR 3.3.1.1 s 1.6 E5 cpa Neutron Flux SR3.3.1.8 SR 3.3.1.11 3Cb), 4Cb), sCb) 2 J,K SR 3.3.1.1 s 1.6 ES cpa SR3.3.1.7 SR3.3.1.11

6. Overtemperature 1,2 4 E SR 3.3.1.1 Refer to Note 1

.!1T SR3.3.1.3 EP*** a a 23~

SR3.3.1.6

( (lttheendofthlsTable; SR3.3.1.7 SR 3.3.1.10 SR3.3.1.16

7. OVerpower .!1T 1,2 4 E SR 3.3.1.1 Refer to Note 2 SR3.3.1.7 ~*(Page a.a a., .

SR 3.3.1.10 (at the end of this T1ble)

SR3.3.1.16

8. Pressurizer Pressure

a. Low 1(11) 4 M SR3.3.1.1  :<!: 1874 paig SR3.3.1.7 SR3.3.1.10 SR3.3.1.16

b. High 1,2 4 E SR 3.3.1.1 s 2393 palg SR3.3.1.7 SR 3.3.1.10 SR3.3.1.16 (a) The Allowable Value defines the Umlting safety system setting except for Trip Functlona 14.a and 14.b (the Nominal Trip Setpolnt defines the limiting safety system setting for theSe TriP Functions). See the Bales for the Nominal Trip Setpolnts.

(b) With Rod Control System capable of rod withdrawal or one or more rods not fully Inserted.

(e) Below the P-6 (Intermediate Range Neutron Flux) Interlock.

(g) Above the P-7 (Low Power Reactor Trips Block) Interlock.

CALLAWAY PLANT 3.3-20 Amendment No. 202 1

, Enclosure to ULNRC-05975 Page 3 COMS 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Cold Overpressure Mitigation System (COMS)

, OYld \ht V\or~4) (.~'1"'5iY -pu~p LCO 3.4.12 COMS shall be OPERABLE with ar::.m of zero safety Injection pumpsJ

~ --aA" 9Ae centrifugal charging pum:t'C:~~~e of injecting into the RCS and Otle. Ei'l\e~t.nt'j C.ore. the ac~.u.mulators isolated and one of the following pressure relief t -\* S L , I! , capab1lit1es:

~ '\'\j 'I ~U,W) v:.U..)J

a. Two power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR, or

b. Two residual heat removal (RHR) suction relief valves with setpoints

~ 436.5 psig and s 463.5 psig, or

c. One PORV with a lift setting within the limits specified in the PTLR and one RHR suction relief valve with a setpoint ~ 436.5 psig and s 463.5 psig, or

d. The RCS depressurized and an RCS vent of~ 2.0 square inches.

-NOTES-------------------

1. Tw6'centrifugal charging pumps may be made capable of injecting for s 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations.

2. One or more safety injection pumps may be made capable of injecting in MODES 5 and 6 when the RCS water level is below the top of the reactor vessel flange for the purpose of protecting the decay heat removal function.

3. Accumulator may be unisolated when accumulator pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the PIT limit curves provided in the PTLR.

APPLICABILITY: MODE 4 with any RCS cold leg temperatures 275°F, MODE 5, MODE 6 when the reactor vessel head is on.

CALLAWAY PLANT 3.4-25 Amendment No. 133

, Enclosure to ULNRC-05975 Page4 COMS 3.4.12 ACTIONS

---

NOTE-LCO 3.0.4.b is not applicable when entering MODE 4.

COMPLETION CONDITION REQUIRED ACTION TIME A One or more safety A.1 Initiate action to verify a Immediately injection pumps capable of maximum of zero safety injecting into the RCS. injection pumps are capable of injecting into the RCS.

B. Tw~centrifugal charging 8.1 Initiate action to verify a Immediately pumps capable of injecting maximum of one .,.... - Eu.~

into the RCS. centrifu..s_al charging pum~capable of injecting into the RCS. '"\c)~J -l'lt. V\Ot'NI~\

C.~ll"~-' '?V"'?

c. An accumulator not isolated C.1 Isolate affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when the accumulator accumulator.

pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

(cOntlnuea)

CALLAWAY PLANT 3.4-26 Amendment No. 164

, Enclosure to ULNRC-05975 Page 5 COMS 3.4.12 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Increase all RCS cold 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion leg temperatures to Time of Condition C not > 275°F.

met.

QB.

D.2 Depressurize affected 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> accumulator to less than the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

E. One required RCS relief E.1 Restore required RCS 7days valve inoperable in relief valve to MODE4. OPERABLE status.

F. One required RCS relief F.1 Restore required RCS 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> valve inoperable in relief valve to MODE 5or6. OPERABLE status.

G Two required RCS relief G1 Depressurize RCS and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> valves inoperable. establish RCS vent of

~ 2.0 square inches.

QB.

Required Action and associated Completion Time of Condition A, B, D, E, or F not met.

QB COMS inoperable for any reason other than Condition A, B, C, D, E, or F.

CALLAWAY PLANT 3.4-27 Amendment No. 188

, Enclosure to ULNRC-05975 Page 6 COMS 3.4.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify a maximum of zero safety injection pumps are In accordance capable of injecting into the RCS. with the Surveillance Frequency Control Program

( ECt~

SR 3.4.12.2 Verify a maximum of o~centrifugal charging pump In accordance

-is-capable of injecting into the RCS. with the Surveillance Ot\d t~ t'\O'~"\ cJI'\'~i1_1 ll\JIIl p Frequency Control Program SR 3.4.12.3 Verify each accumulator is isolated when In accordance accumulator pressure is greater than or equal to the with the maximum RCS pressure for the existing RCS cold Surveillance leg temperature allowed by the PIT limit curves Frequency provided in the PTLR. Control Program SR 3.4.12.4 Verify RHR suction isolation valves are open for each In accordance required RHR suction relief valve. with the Surveillance Frequency Control Program SR 3.4.12.5 Verify required RCS vent ~ 2.0 square inches open. In accordance with the Surveillance Frequency Control Program (continued)

CALLAWAY PLANT 3.4-28 Amendment No. 202

, Enclosure to ULNRC-05975 Page 7 COMS 3.4.12 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.12.6 Verify PORV block valve is open for each required In accordance PORV. with the Surveillance Frequency Control Program SR 3.4.12.7 Not used.

SR 3.4.12.8 --------------NOTE------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing any RCS cold leg temperature to s 275°F.

Perform a COT on each required PORV, excluding In accordance actuation. with the Surveillance Frequency Control Program SR 3.4.12.9 Perform CHANNEL CALIBRATION for each required In accordance PORV actuation channel. with the Surveillance Frequency Control Program CALLAWAY PLANT 3.4-29 Amendment No. 202

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS BASES PAGE MARKUPS

, Enclosure to ULNRC-05975 Page 2 COMS 8 3.4.12 8 3.4 REACTOR COOLANT SYSTEM (RCS) 8 3.4.12 Cold Overpressure Mitigation System (COMS)

BASES BACKGROUND The COMS controls RCS pressure at low temperatures so the Integrity of the reactor coolant pressure boundary (RCP8) Is not compromised by violating the pressure and temperature (Pm limits of 10 CFR 50, Appendix G (Ref. 1). The reactor vessel is the limiting RCPB component for demonstrating such protection. The PTLR provides the maximum allowable actuation logic setpoints for the power operated relief valves (PORVs) and the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup to meet the Reference 1 requirements during the COMS MODES, as approved by NRC for Callaway in Ref. 12.

The reactor vessel material is less tough at low temperatures than at normal operating temperature. As the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at low temperatures (Ref. 2). RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased.

The potential for vessel overpressurlzation is most acute when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition.

Exceeding the RCS PIT limits by a significant amount could cause brltUe cracking of the reactor vessel. LCO 3.4.3, "RCS Pressure and Temperature (Pm Limits," requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent

~Eedljf1~:::e~ure coo prole on~~~~ nUnin.Jm input capability and having adequate ressure relief capacity.

Lim coolant input capability requires bo safety injection pumps and one trifugal charging pump to be lncapa e of injection into the RCS and isolating the accumulators. The normal harging pump (NCP) has been analyzed as capable of injecting durin an overpressure transient and the analysis assumes the flow from on ntrifugal charging pump and the NCP. ':Ate tern; "eeAtfiNIII c:bargiRg py~p" GF "CC:P" refers to liM safety relate~ iCC& p1.1~ps a~ly.Jhe pressure relief capacity requires either two redundant RCS relief ves or a depressurized RCS and an RCS vent of sufficient size. On RCS relief valve or the open RCS vent is the overpressure protection d ice that acts to terminate an increasing pressure event. :r::'f\1 SE,f-r-(continued)

CALLAWAY PLANT B 3.4.12-1 Revision 10

, Enclosure to ULNRC-05975 Page 3 INSERT (The term "centrifugal charging pump" or "CCP" refers to the safety-related ECCS pumps only (PBGOSA and PBGOSB). The normal charging pump or NCP (PBG04) does not serve an ECCS function (the NCP is tripped by a safety injection signal).)

, Enclosure to ULNRC-05975 Page4 COMS 8 3.4.12 BASES BACKGROUND With minimum coolant input capability, the ability to provide core coolant (continued) addition is restricted. The LCO does not require the makeup control system deactivated or the safety injection (SI) actuation circuits blocked.

Due to the lower pressures in the COMS MODES and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve. If conditions require the use of more than one E'CCScentrifugal charging pump for makeup In the event of loss of inventory, either the NCP or other ECCS pumps can be made available through manual actions.

The COMS for pressure relief consists of two PORVs with reduced lift settings, or two residual heat removal (RHR) suction relief valves, or one PORV and one RHR suction relief valve, or a depressurized RCS and an RCS vent of sufficient size. Two RCS relief valves are required for redundancy. One RCS relief valve has adequate relieving capabiiHy to prevent overpressurization for the required coolant input capability.

pORV Regujrements As designed for the COMS, each PORV is signaled to open if the RCS pressure approaches a limit determined by the COMS actuation logic.

The COMS actuation logic monitors both RCS temperature and RCS pressure and determines when a condition not acceptable with respect to the PTLR limits is approached. The wide range RCS temperature indications are auctioneered to select the lowest temperature signal.

The lowest temperature signal is processed through a function generator that calculates a pressure limit for that temperature. The calculated pressure limit is then compared with the indicated RCS pressure from a wide range pressure channel. If the indicated pressure meets or exceeds the calculated value, a PORV is signaled to open.

The PTLR presents the setpoints for COMS. The setpoints are normally staggered so only one valve typically opens during a low temperature overpressure transient. Having the setpoints of both valves within the limits in the PTLR ensures that the Reference 1 limits will not be exceeded in any analyzed event.

When a PORV is opened in an increasing pressure transient, the release of coolant will cause the pressure increase to slow and reverse. As the PORV releases coolant, the RCS pressure decreases until a reset pressure is reached and the valve is signaled to close. The pressure continues to decrease below the reset pressure as the valve closes.

(continued)

CALLAWAY PLANT B 3.4.12-2 Revision 10

, Enclosure to ULNRC-05975 Page 5 COMS B 3.4.12 BASES BACKGROUND RHB Syctjon Relief Valve Regyjrements (continued)

During COMS MODES, the RHR System is operated for decay heat removal and low pressure letdown control. Therefore, the RHR suction isolation valves are open in the piping from the RCS hot legs to the inlets of the RHR pumps. While these valves are open, the RHR suction relief valves are exposed to the RCS and are able to relieve pressure transients in the RCS.

The RHR suction isolation valves must be open to make the RHR suction relief valves OPERABLE for RCS overpressure mitigation. The RHR suction relief valves are spring loaded, bellows type water relief valves with pressure tolerances and accumulation limits established by Section Ill of the American Society of Mechanical Engineers (ASME)

Code (Ref. 3) for Class 2 relief valves.

RCS Vent Requirements Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the capabilities of the vent. Thus, the vent path must be capable of relieving the flow resulting from the limiting COMS mass or heat input transient, and maintaining pressure below the PIT limits. The required vent capacity may be provided by one or more vent paths.

APPLICABLE Safety analyses (Ref. 4) demonstrate that the reactor vessel is SAFETY adequately protected against exceeding the Reference 1 PIT limits. In ANALYSES MODES 1, 2, and 3, and in MODE 4 with all RCS cold leg temperatures exceeding 275°F, the pressurizer safety valves will prevent RCS pressure from exceeding the Reference 1 limits. In MODE 4 (with any RCS cold leg temperature s 275°F) and below, overpressure prevention falls to two OPERABLE RCS relief valves or to a depressurized RCS and a sufficient sized RCS vent. Each of these means has a limited overpressure relief capability.

The actual temperature at which the pressure in the PIT limit curve falls below the pressurizer safety valve setpoint increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the PTLR curves are revised, the COMS must be re-evaluated to ensure its functional requirements can still be met using the RCS relief valve method or the depressurized and vented RCS condition.

(continued)

CALLAWAY PLANT B 3.4.12-3 Revision 10

, Enclosure to ULNRC-05975 Page 6 COMS 8 3.4.12 BASES APPLICABLE The PTLR contains the acceptance limits that define the COMS SAFETY requirements. Any change to the RCS must be evaluated against the ANALYSES analyses in References 9 and 12 to determine the impact of the change (continued) on the COMS acceptance limits.

Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients, examples of which follow:

Mass Input Type Transjents

a. Inadvertent safety injection; or

b. Charging/letdown flow mismatch.

Heat lnpyt Type Transjents

a. Inadvertent actuation of pressurizer heaters;

b. Loss of RHR cooling; or

c. Reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.

The following are required, with exceptions described below, during the COMS MODES to ensure that mass and heat input transients do not occur, which either of the COMS overpressure protection means cannot handle:

EJ!CS'

a. Rendering both safety injection pumps and one~ntrifugal charging pump incapable of injection (there are no limitations on the use of the NCP during the COMS MODES);

b. Deactivating the accumulator discharge isolation valves in their closed positions; and

c. Precluding start of an RCP if secondary temperature is more than 50°F above primary temperature in any one loop. LCO 3.4.6, "RCS Loops- MODE 4," and LCO 3.4.7, "RCS Loops- MODE 5, Loops Filled," provide this protection.

The analyses in References 9 and 12 demonstrate that either one RCS relief valve or the depressurized RCS and RCS vent can maintain RCS pressure below limits when on9,fentrifugal charging pump (in addition to EC C.S (continued)

CALLAWAY PLANT 8 3.4.12-4 Revision 10

, Enclosure to ULNRC-05975 Page 7 a 11 ) ~ Ncf

-/, Je. C.~Af"'J /e ~~ frjec.-lf4rt COMS B 3.4.12 BASES £,CCS APPLICABLE the NCP) is actuat . Thus, the LCO allows Mly-one ntrifugal charging SAFETY pump uring the COMS MODES. Since neither one RCS ANALYSES relief valve nor the RCS vent can handle the pressure transient caused by (continued) accumulator injection when RCS temperature is low, the LCO also requires accumulator isolation when accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed in the PTLR.

The isolated accumulators must have their discharge valves closed and the valve power supply breakers fixed in their open positions.

Fracture mechanics analyses established the temperature of COMS Applicability at 275°F, which is conservative with respect to the ASME Code Case N-514 limit of 200°F (Ref. 12).

PORV Performance The fracture mechanics analyses show that the ves the PORVs are set to open at or below the limits sho setpoints are derived by analyses that model the pe rmance of the COMS, assuming the mass injection transient of on centrifugal charging pump and the NCP injecting into the RCS and the heat injection transient of starting an RCP with the RCS 50°F colder than the secondary coolant.

These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from signal processing and valve stroke times. The PORV setpoints at or below the derived limit ensure the Reference 1 PIT limits will be met.

The PORV setpoints in the PTLR will be updated when the revised PIT limits conflict with the COMS analysis limits. The PIT limits are periodically modified as the reactor vessel material toughness decreases due to neutron embrittlement caused by neutron irradiation. Revised limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.3, "RCS Pressure and Temperature (PIT) Limits," discuss these examinations.

The PORVs are considered active components. Thus, the failure of one PORV is assumed to represent the worst case, single active failure.

(continued)

CALLAWAY PLANT B 3.4.12-5 Revision 10

, Enclosure to ULNRC-05975 Page 8 COMS B 3.4.12 BASES APPLICABLE RHR Syctjon Relief valve ferformance SAFETY ANALYSES The RHR suction relief valves do not have variable pressure and (continued) temperature lift setpoints like the PORVs. Analyses show that one RHR suction relief valve with a setpoint at or between 436.5 psig and 463.5 psig will pass flow greater than that required for the limiting COMS transient while maintaining RCS pressure Jess than the PIT limit curve.

The RCS PIT limits are decreased to reflect the loss of toughness in the reactor vessel materials due to neutron embrittlement. The RHR suction relief valves must be analyzed to accommodate the design basis transients for COMS.

The RHR suction relief valves are considered active components. Thus, the failure of one valve is assumed to represent the worst case single active failure.

RCS vent Performance With the RCS depressuriz , analyses show a vent size of 2.0 square inches is capable of mitig ting the limiting COMS transient. The capacity of a vent this size is grea r than the flow of the limiting transient for the COMS configuration, on ntrifugal charging pump and the NCP injecting into the RCS, maintaining RCS pressure less than the maximum pressure on the PIT limit curve.

The RCS vent size will be re-evaluated for compliance each time the PIT limit curves are revised based on the results of the vessel material surveillance.

The RCS vent is passive and is not subject to active failure.

The COMS satisfies Criterion 2 of 10CFR50.36(c)(2)(ii).

LCO This LCO requires that the COMS is OPERABLE. The COMS is OPERABLE when the maximum specified coolant input and minimum pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient.

To limit the coolant input capability, the LCO requires that a maximum of zero safety injection pumps.&M on:~ntrifugal charging pum e capable of injecting into the RCS a[. ~II accumulator discharg isolation cCCS (continued)

CALLAWAY PLANT B 3.4.12-6 Revision 10

) ani. +l-.e N~f

, Enclosure to ULNRC-05975 Page 9 COMS B 3.4.12 BASES LCO valves be closed and immobilized when accumulator pressure is greater (continued) than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed in the PTLR. C..C.S" The LCO is modified by three Notes. Note 1 allows twcM:entrifugal charging pumps to be made capable of injecting for s 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations. One hour provides sufficient time to safely complete the actual transfer and to complete the administrative controls and surveillance requirements associated with the swap. The intent is to

,. 1 1 L- J A 1 IJ minimize the actual time that IIR&r:e t~aA &A~ntrifugal charging pum~ _._

1 1 r

111 ~~~~II -nfn -n -rt'\t., tV "-r;'~~physically capable of injection. J 1 fJ, E(). c._r :s-.)_...

Note 2 states that one or more safety injection pumps may be made capable of injecting in MODES 5 and 6 when the RCS water level is below the top of the reactor vessel flange for the purpose of protecting the decay heat removal function.

Note 3 states that the accumulator may be unisolated when the accumulator pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature, as allowed by the PIT limit curves provided in the PTLR. The accumulator discharge isolation valve Surveillance is not required under these pressure and temperature conditions.

The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

a. Two OPERABLE PORVs; or A PORV is OPERABLE for COMS when its block valve is open, its lift setpoint is set to the limit required by the PTLR and testing proves its ability to open at this setpoint, and motive power is available to the two valves and their control circuits.

b. Two OPERABLE RHR suction relief valves; or An RHR suction relief valve is OPERABLE for COMS when its RHR suction isolation valves are open, its setpoint is at or between 436.5 psig and 463.5 psig, and testing has proven its ability to open at this setpoint.

c. One OPERABLE PORV and one OPERABLE RHR suction relief valve; or

d. A depressurized RCS and an RCS vent.

(continued)

CALLAWAY PLANT B 3.4.12-7 Revision 10

, Enclosure to ULNRC-05975 Page 10 COMS B3.4.12 BASES LCO An RCS vent is OPERABLE when open with an area of~ 2.0 square (continued) inches.

Each of these methods of overpressure prevention is capable of mitigating the limiting COMS transient.

APPLICABILITY This LCO is applicable in MODE 4 when any RCS cold leg temperature is s 275°F, in MODE 5, and in MODE 6 when the reactor vessel head is on.

The pressurizer safety valves provide overpressure protection that meets the Reference 1 PfT limits above 275°F. When the reactor vessel head is off, overpressurization cannot occur.

LCO 3.4.3 provides the operational PfT limits for all MODES.

LCO 3.4.10, "Pressurizer Safety Valves," requires the OPERABILITY of the pressurizer safety valves that provide overpressure protection during MODES 1, 2, and 3, and MODE 4 above 275°F.

Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable COMS.

There is an increased risk associated with entering MODE 4 from MODE 5 with COMS inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

A.1 and B 1 £CCS With one or more safety injection pumps or twoVcentrifugal charging pumps capable of injecting into the RCS, RCS overpressurization is possible.

J To immediately initiate action to restore restricted coolant input capability C. ;,a.) no S'a~ itju.Jur. f"'~*r ~"o the RCS reflects the urgency of removing the RCS from this condition.

A "'*'""""""

c.cp ~ 6 ~~Cf!S a,.J ~ ~~..[.,;,. c 1 0.1 and o2 C.tAptt..J,Ie. ,.p I~ e..c ~

r An unisolated accumulator requires isolation within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This is only required when the accumulator pressure is at or more than the maximum (continued)

CALLAWAY PLANT B 3.4.12-8 Revision 10

, Enclosure to ULNRC-05975 Page 11 COMS B 3.4.12 BASES ACTIONS C 1 D.1 and D.2 (continued)

RCS pressure for the existing temperature allowed by the Prr limit curves.

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Required Action 0.1 and Required Action D.2 provide two options, either of which must be performed in the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. By increasing the RCS temperature to > 275°F, an accumulator pressure of 648 psig cannot exceed the COMS limits if the accumulators are fully injected. Due to this Specification's Note restricting the application of LCO 3.0.4.b, Required Action D. 1 can only be used if the plant is In MODE 4 when Conditions C and D are entered. Depressurizing the accumulators below the COMS limit from the PTLR also gives this protection.

The Completion Times are based on operating experience that these activities can be accomplished in these time periods and on engineering evaluations indicating that an event requiring COMS is not likely in the allowed times.

In MODE 4 when any RCS cold leg temperature is s 275°F, with one required RCS relief valve inoperable, the RCS relief valve must be restored to OPERABLE status within a Completion Time of 7 days. Two RCS relief valves in any combination of the PORVS and the RHR suction relief valves are required to provide low temperature overpressure mitigation while withstanding a single failure of an active component.

The Completion Time considers the facts that only one of the RCS relief valves is required to mitigate an overpressure transient transient and that the likelihood of an active failure of the remaining valve path during this time period is very low.

E.1 The consequences of operational events that will overpressurize the RCS are more severe at lower temperature (Ref. 7). Thus, with one of the two RCS relief valves inoperable in MODE 5 or in MODE 6 with the head on, the Completion Time to restore two valves to OPERABLE status is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The Completion Time represents a reasonable time to investigate and repair several types of relief valve failures without exposure to a lengthy (continued)

CALLAWAY PLANT B 3.4.12-9 Revision 10

, Enclosure to ULNRC-05975 Page 12 COMS B 3.4.12 BASES ACTIONS F.1 (continued) period with only one OPERABLE RCS relief valve to protect against overpressure events.

The RCS must be depressurized and a vent must be established within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when:

a. Both required RCS relief valves are inoperable; or

b. A Required Action and associated Completion Time of Condition A, B, D, E, or F is not met; or

c. The COMS is inoperable for any reason other than Condition A, B, C,D,E,orF.

The vent must be sized~ 2.0 square inches to ensure that the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. This action is needed to protect the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel.

The Completion Time considers the time required to place the plant in this Condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.

SURVEILLANCE S ' ant/ -#e. Nc/)

REQUIREMENTS To minimize the potential for a w temperature overprefre event by limiting the mass input capabil' , a maximum of zero sa ty injection pump~"d a .,.euiMWM sf one ntrifugal charging pum re verified to be capable of injecting into the RCS and the accumulator discharge isolation valves are verified closed with power removed from the valve operators (Refs. 10 and 11 ). Verification that each accumulator is isolated is only required when accumulator isolation is required as stated in Note 3 to the LCO. eCCr The safety injection pumps and oneVcentrlfugal charging pump are rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative control.

An alternate method of cold overpressure protection control may be employed using at least two independent means to render a pump (continued)

CALLAWAY PLANT 8 3.4.12-10 Revision 10

, Enclosure to ULNRC-05975 Page 13 COMS B 3.4.12 BASES SURVEILLANCE SR 3.4.12.1 SR 3 4 12 2 and SR 3 4 12 3 (continued)

REQUIREMENTS incapable of injecting into the RCS such that a single failure or single action will not result in an injection into the RCS. This may be accomplished by placing the pump control switch in pull to lock and closing at least one valve in the discharge flow path, or by closing at least one valve in the discharge flow path and removing power from the valve operator, or by closing at least one manual valve in the discharge flow path 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.

SR 3.4.12.4 Each required RHR suction relief valve shall be demonstrated OPERABLE by verifying its RHR suction isolation valves are open and by testing it in accordance with the lnservice Testing Program. This Surveillance is only required to be performed if the RHR suction relief valve is being used to meet this LCO.

The RHR suction isolation valves are verified to be opened. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

The ASME Code (Ref. 8), test per lnservice Testing Program verifies OPERABILITY by proving proper relief valve mechanical motion and by measuring and, if required, adjusting the lift setpoint.

SR 34.12 5 The RCS vent of~ 2.0 square inches is proven OPERABLE by verifying its open condition either:

a. For a vent pathway that is not locked, sealed, or otherwise secured in the open position, or

b. For a valve that is locked, sealed, or otherwise secured in the open position. A removed pressurizer safety valve or open manway also fits this category.

(continued)

CALLAWAY PLANT B 3.4.12-11 Revision 10

, Enclosure to ULNRC-05975 Page 14 COMS B 3.4.12 BASES SURVEILLANCE SB 3.4 12 5 (continued)

REQUIREMENTS (continued) The Surveillance Frequency Is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SB 3.412.6 Any passive vent path arrangement must only be open when required to be OPERABLE. This Surveillance is required if the vent is being used to satisfy the pressure relief requirements of the LCO 3.4.12d.

The POBV block valve must be verified open to provide the flow path for each required POBV to perform its function when actuated. The valve must be remotely verified open In the main control room. This Surveillance is only required to be performed if the POBV is being used to meet this LCO.

The block valve is a remotely controlled, motor operated valve. The power to the valve operator is not required removed, and the manual operator is not required locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive seat leakage or does not close (sticks open) after relieving an overpressure situation.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.412.7 Not used.

SB 3.412.8 Performance of a COT is required.wi4ftino*ohetft"efh!Fti!IPIIII_illll..,.ii--

tsmperatuf8 g a7sor on each required PORV to ve

• n~ as necessary, adjust its lift setpoint. A successful test of ttfe required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable because all of the other required contacts of the (continued)

CALLAWAY PLANT 8 3.4.12-12 Revision 10

, Enclosure to ULNRC-05975 Page 15 BASES t!fel'\e 1"'111 r 0\

SURVEILLANCE SR 3 4.12.8 (continued) r7 hre.~k/' tt'\+r- (;lfre._

REQUIREMENTS relay are verified by other Technical Specifi tions and non-Technical Specifications tests. The COT will verify th within the s?'FLR all&" ad n i limits in the PTLR. PORV actuation could depressurize the RCS and is not required.

The Surveillance Frequency Is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

A Note has been added indicating that this SR is not required to be performed until 12 hqurs after decreasing any ~CS cold leg temperature _L ,.

to s 275°F. ~ Nrte lA 1/IJWS;. Juf- Ollf!..r' ,,.f rezurre.) <!.1'\l'f!.,...,IYJ._

..f-~e. C41hS L~ Attlrc.lf'A'Z;Ir-~;J frill~-/-, ~~~Y'"'J:~ -H..e. rr s~ . .

1 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. 10 CFR 50, Appendix G.

2. Generic Letter 88-11 .

3. ASME, Boiler and Pressure Vessel Code, Section HI.

4. FSAR, Chapter 15.

5. 10 CFR 50, Section 50.46.

6. 10 CFR 50, Appendix K.

7. Generic Letter 90-06.

(continued)

CALLAWAY PLANT B 3.4.12-13 Revision 10

, Enclosure to ULNRC-05975 Page 16 COMS 8 3.4.12 BASES REFERENCES 8. ASME Code for Operation and Maintenance of Nuclear Power (continued) Plants.

9. FSAR Section 5.2.2.1 0.

10. FSAR Section 6.3.2.

11. FSAR Section 7.6.4.

12. Amendment No. 124 to Facility Operating License NPF-30 dated April2, 1998.

CALLAWAY PLANT 8 3.4.12-14 Revision 10

ATTACHMENT 3 RETYPED TECHNICAL SPECIFICATIONS PAGES

, Enclosure to ULNRC-05975 Page 2 RTS Instrumentation 3.3.1 TABLE 3.3.1-1 (PAGE 2 OF 8)

Reactor Trip System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE<*>

5. Source Range 2<*> 2 I, J SR3.3.1.1 ~ 1.6 E5 cps Neutron Flux SR 3.3.1.8 SR 3.3.1.11 3(b>, 4(b>, 5(b) 2 J, K SR 3.3.1.1 ~ 1.6 E5 cps SR 3.3.1.7 SR3.3.1.11

6. Overtem perature 1,2 4 E SR 3.3.1.1 Refer to Note 1

~T SR 3.3.1.3 (at the end of SR 3.3.1.6 this Table)

SR 3.3.1.7 SR 3.3.1.10 SR 3.3.1.16

7. Overpower~ T 1,2 4 E SR3.3.1.1 Refer to Note 2 SR 3.3.1.7 (at the end of SR 3.3.1.10 this Table)

SR 3.3.1.16

8. Pressurizer Pressure

a. Low 1(g) 4 M SR3.3.1.1 ~ 1874 psig SR 3.3.1.7 SR3.3.1.10 SR 3.3.1.16

b. High 1,2 4 E SR 3.3.1.1 ~ 2393 psig SR 3.3.1.7 SR 3.3.1.10 SR 3.3.1.16 (a) The Allowable Value defines the limiting safety system setting except for Trip Functions 14.a and 14.b (the Nominal Trip Setpoint defines the limiting safety system setting for these Trip Functions). See the Bases for the Nominal Trip Setpoints.

(b) VVith Rod Control System capable of rod withdrawal or one or more rods not fully inserted.

(e) Below the P-6 (Intermediate Range Neutron Flux) interlock.

(g) Above the P-7 (Low Power Reactor Trips Block) interlock.

CALLAWAY PLANT 3.3-20 Amendment No. ###

, Enclosure to ULNRC-05975 Page 3 COMS 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Cold Overpressure Mitigation System (COMS)

LCO 3.4.12 COMS shall be OPERABLE with a maximum of zero safety injection pumps, one Emergency Core Cooling System (ECCS) centrifugal charging pump, and the normal charging pump capable of injecting into the RCS and the accumulators isolated and one of the following pressure relief capabilities:

a. Two power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR, or

b. Two residual heat removal (RHR) suction relief valves with setpoints

~ 436.5 psig and ~ 463.5 psig, or

c. One PORV with a lift setting within the limits specified in the PTLR and one RHR suction relief valve with a setpoint ~ 436.5 psig and

~ 463.5 psig, or

d. The RCS depressurized and an RCS vent of~ 2.0 square inches.

---

NOTES ------------------------------------------

1. Two ECCS centrifugal charging pumps may be made capable of injecting for ~ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations.

2. One or more safety injection pumps may be made capable of injecting in MODES 5 and 6 when the RCS water level is below the top of the reactor vessel flange for the purpose of protecting the decay heat removal function.

3. Accumulator may be unisolated when accumulator pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the PIT limit curves provided in the PTLR.

APPLICABILITY: MODE 4 with any RCS cold leg temperature~ 275°F, MODE 5, MODE 6 when the reactor vessel head is on.

CALLAWAY PLANT 3.4-25 Amendment No. ###

, Enclosure to ULNRC-05975 Page4 COMS 3.4.12 ACTIONS

---

NOTE ----------------------------------------------------------*

LCO 3.0.4.b is not applicable when entering MODE 4.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more safety A.1 Initiate action to verify a Immediately injection pumps capable of maximum of zero safety injecting into the RCS. injection pumps are capable of injecting into the RCS.

B. Two ECCS centrifugal 8.1 Initiate action to verify a Immediately charging pumps capable of maximum of one ECCS injecting into the RCS. centrifugal charging pump and the normal charging pump capable of injecting into the RCS.

c. An accumulator not isolated C.1 Isolate affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when the accumulator accumulator.

pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

{continued)

CALLAWAY PLANT 3.4-26 Amendment No. #II#

, Enclosure to ULNRC-05975 Page 5 COMS 3.4.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify a maximum of zero safety injection pumps are In accordance capable of injecting into the RCS. with the Surveillance Frequency Control Program SR 3.4.12.2 Verify a maximum of one ECCS centrifugal charging In accordance pump and the normal charging pump capable of with the injecting into the RCS. Surveillance Frequency Control Program SR 3.4.12.3 Verify each accumulator is isolated when In accordance accumulator pressure is greater than or equal to the with the maximum RCS pressure for the existing RCS cold Surveillance leg temperature allowed by the P/T limit curves Frequency provided in the PTLR. Control Program SR 3.4.12.4 Verify RHR suction isolation valves are open for each In accordance required RHR suction relief valve. with the Surveillance Frequency Control Program SR 3.4.12.5 Verify required RCS vent ;::: 2.0 square inches open. In accordance with the Surveillance Frequency Control Program (continued)

CALLAWAY PLANT 3.4-28 Amendment No. ###