ULNRC-06485, License Amendment Request to Revise Technical Specifications for Testing of Main Turbine Control Slave Relay (LDCN 18-0025)

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License Amendment Request to Revise Technical Specifications for Testing of Main Turbine Control Slave Relay (LDCN 18-0025)
ML19071A281
Person / Time
Site: Callaway Ameren icon.png
Issue date: 03/12/2019
From: Bianco F
Ameren Missouri, Union Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LDCN 18-0025, ULNRC-06485
Download: ML19071A281 (21)
v • d • e


Text

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WAmeren Callaway Plant MISSOURI

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March 12, 2018 U.S. Nuclear Regulatory Commission Atfn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

ULNRC-06485 10 CFR 50.90 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 BNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS FOR TESTING OF MAIN TURBINE CONTROL SLAVE RELAY (LDCN 18-0025)

Pursuant tm 10 CPR 50.90, Application for amendment of license or constmction permit," Ameren Missouri (Union Electric Company) herewith transmits an application for amendnient to Renewed Facility Operating License NPF-30 for the Callaway Plant.

The proposed amendment would revise the Technical Specifications (TSs) to remove slave relay K.620 from the scope of TS Surveillance Requirement (SR) 3.3.2.14 and place it within the scope of SR 3.3.2.6. The change requires revising the specific wor:ding of Notes attached to these SRs in the TS.

Attachment l to this letter provides an Evaluation of the Proposed Change. Attacluuents 2 through 4 provide a markup of the Technical Specification pages for the proposed cl1ange, markup of the TS Bases pages for the proposed change and retyped TS pages reflecting the proposed change, respectively, in supp01i of this amendment request. Attachments 3 is provided for infonnation only, as final TS Bases changes will be processed under the program for TS Bases updates per TS 5.5.l 4, "Technical Specifications Bases Control Program, 1

' at the time this amendment is implemented.

It has been detennined that this amendment application does not involve a significant hazards consideration as determined per 10 CFR 50. 92 Issuance of Amendment." In addition, pursuant to 10 CFR 5 I.22 "Ciiterion for Categorical Exclusion; Identification of Licensing and Regulatory Actions 83 15 County Road 459 Steedman, MO 65077 Ameren.Missouri.com

ULNRC-06485 March 12, 2019 Page 2 of 4 Eligible for Categorical Exclusion or Otherwise not Requiring Enviromuental Review," Section (b ), no enviromnental impact statement or enviromnental assessment need be prepared in connection with the issuance of this amendment.

It should be noted that this submittal does not contain new commitments. In addition, the Callaway Onsite Review Committee has reviewed and approved the proposed changes and has approved the subtnittal of th.is amendment application.

Ameren Missouri requests approval of the requested license amendment ptior to March 12, 2020. It is anticipated that the license amendment will 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 )(1 ), a copy of this amendment application is being provided to the designated Missouri State official.

If there are any questions on this amendment application, please contact me at 573-676-8188 or Mr.

Tom Elwood at 314-225-1905.

[ declare under penalty of perjury that the foregoing is true and con*ect.

Sincerely, Executed on: - ---

Fred Bianco Senior Director, Nuclear Operations Attachments:

1. Evaluation of the Proposed Change
2. Markup of Technical Specification Pages for Proposed Change
3. Markup of TS Bases Pages for Proposed Change (for i.nforn1ation only)
4. Retyped Teclmical Specification Pages
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ULNRC-06485 March 12, 2019 Page 3 of 4 Mr. Scott A. Morris 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. L. John IUos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 09E3 Washington, DC 20555-0001

ULNRC-06485 March 12, 2019 Page 4 of 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 Fort Worth, TX 76107 (Certrec receives ALL attaclunents as long as they are non-safeguards and may be publicly disclosed.)

Electronic distJ*ibution for the following can be made via Tech Spec ULNRC Distribution:

F.M.Diya T. E. Henmann B. L. Cox F. I. Bianco S. P. Banker L. H. Kanuckel R. C. Wink T. B. Elwood Corporate Communications NSRB Secretary STARS Regulat01y Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Mr. Dm Buntin (DNR)

Mr. Steve Feeler (DNR)

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0004*********************-*-*********************************-*******"*'************************************************************* ***** *************************** ***-************** *****************************....

Attaclunent 1 to ULNRC-06485 EVALUATION OF THE PROPOSED CHANGE I.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 Proposed Changes

2.2 Background

3. TECHNICAL EVALUATION
4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Cbnsideration Detennination 4.3 Conclusions
5. ENVIRONMENT AL CONSIDERATION
6. REFERENCES Page 1 of 8 Page 2 Page 2 Page2 Page 3 Page 5 Page 5 Page 5 Page 6 Page 8 Page 8 Page 8

Attaclunent 1 lo ULNRC-06485 EVALUATION OF THE PROPOSED CHANGE I.

SUMMARY

DESCRIPTION The proposed amendment would revise the Technical Specifications to remove slave relay K620 from the scope of Technical Specification (TS) Surveillance Requirement (SR) 3.3.2.14 (which requires surveillance testing during shutdown conditions at 18-month intervals) and incorporate it into the scope of SR 3.3.2. 6 (which requires surveillance testing dming power operations, at a frequency detennined in accordance in accordance with the Surveillance Frequency Control Program (SFCP), i.e., at 9-montb intervals). This relocation requires Tevising specific wording-in N otes attached to. these SRs, as the Notes define the scope of testing for each of the SRs in te1ms of what relays (by relay identification number) are required to be tested.

2. DETAILED DESCRIPTION 2.1 Proposed Change Two changes to TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation," are requested in order to change the frequency (and required plant conditions) for testing the K620 relay. Although most of the SR frequencies in the Callaway Tec1u1ical Specifications are controlled under the Surveillance Frequency Control Program (SFCP) and are thus not explicitly specified in the Technical Specifications, the change in the SR frequency for slave relay K620 necessitates moving it from the scope of one SR to another, and this requires changes to be made to Notes attached to these SRs in the Technical Specifications, as described further below.

As explained further in sections 2.2 and 3 of this attaclm1el1t, the basis for the cunent test interval for the K620 relay is being changed such that testing of th.is relay will be performed during plant operation at a frequency c011sistent with online testing as specified per the SFCP, in lieu of testing the.Ielay only during shutdown conditions at 18-month intervals. This change requires moving the K620 relay from the sco1Je of SR 3.3.2.14 to the scope of SR 3.3.2.6.

The Frequency for SR 3.3.2.14 is specified in the SR as "In accordance with the Surveillance Frequency Control Program AND Prior to entering.NlODE 3 when in MODE 5 or 6 > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if not perfonned within the previous 92 days.

11 The Callaway SFCP procedure, '1Surveillance Frequency Control Program STI List, 11 (station procedure APA-ZZ-00340 Appendix 4) specifies a surveillance test interval (STI) of 18 months for slave relay K620 as identified for SR 3.3.2.14, and it notes that the 18-month test interval for this slave relay is based on the need to perform this surveillance under the conditions that apply during a unit 011tage in order to avoid the potential for an unplanned transient if the surveillance were perfo1med with the reactor at power.

(The function of the K620 relay is further described in Section 2.2, "Background," of this attaclnnent.) For the reasons explained in sections 2.2 and 3 of this attachment, tltis basis for the K.620 relay test interval is bemg changed. As* a result, the K620 relay is being removed from the scope of SR 3.3.2.14.

Page 2 of 8 to ULNRC-06485 SR 3.3.2.14 includes a Note which states "Only applicable to relays K620 and K750." This Note requires revision if the K620 relay is to be removed from the scope of this SR. The proposed change to SR.3.3.2.14, therefore, is simply to delete "K620" from the Note (which also requires deleting and" and changing relays" to "relay" within the Note).

TI1e Frequency associated with SR 3.3.2.6 is specified in the SR as "In accordance with the Surveillance Frequency Control Program." The above-noted Callaway SFCP procedure cun-ently specifies an STI of 9 months for this SR, which is consistent with relay testing that is pe1formed dwing plant operation and is thus the new/intended test frequency for the K620 relay.

SR 3.3.2.6 includes a Note, however, stating, "Not applicable to slave relays K602, K620, K622, K624, 1(630, K740, K741, and K750." Adding slave relay K620 to the scope of this SR clearly requires removing the relay from this exception Note. The proposed change for SR 3.3.2.6, therefore, is merely to remove "K620," from the associated Note.

In support of the requested TS changes, the corresponding TS Bases sections (i.e., the TS Bases section 3.3.2 Surveillance Requirements sections for SR.3.3.2.14 and SR 3.3.2.6) would be changed in order to cohfonn to the above-noted TS changes. Specifically, the TS Bases Surveillance Requfrements section for SR 3.3.2.14 would be changed to remove mention of slave relay K620 and make associated editorial changes to the surrounding text. This change would also remove scope-defining wording (specific to the K620 relay) that identifies circuitry not required to be included in the K620 slave relay test.

In addition, the TS Bases Surveillance Requirements section for SR.3.3.2.6 would be changed to remove mention o.f slave relay K620 in the above-mentioned exception Note in SR 3.3.2.6, which cmTently excludes slave relay K620 from the surveillance testing requirements of this SR.

The scope-defining wording that identifies circuitry not required to be included in the K620 slave relay test, which is being removed from the TS Bases Surveillance Requirements section for SR 3.3.2.14, would be added to the TS Bases Surveillance Requirements.section for SR 3.3.2.6.

As noted in the cover letter for this LAR, the TS Bases changes will be processed tmder the TS Bases Control Program specified per TS 5.5.14. They are desc1ibed above and identified in Attaclunent 3 for infonnation onJy.

2.2 Background

2.2.1 Engineered Safety Features Actuation System The K620 relay is part of the solid state protction system (SSPS) circuitry. The SSPS consists of two parts: the reactor trip system (RTS) and the engineered safety feature actuation system (ESFAS). As desc1ibed in FSAR section 7.3.8.1, the ESFAS 1nonitors selected plant parameters, and if predetermined setpoints are exceeded the syste111 sends actuation signals to the appropdate engineered safety feature components.

To be more specific, slave relay K620 (in each of two logic trains) is pait of the SSPS circuitry that trips the main turbine (as well as the main feedwater pumps) on a Steam Generator (SG) Hi-Page 3 of 8

Attachment I to ULNRC-06485 Hi signal or a Safety.Injection (SI) signal. Each SO is equipped with four hi-hi level indicators that provide a signal to SSPS. When. one SG reaches the hi-hi level on two channels, a t11p signal is sent to SSPS card A313, which trips either on this signal or on a safety injection signal.

This trip signal is sent to relay K508, which d1ives slave relay K620, in each of two logic trains (A and B). Activation ofK620 sends a signal to a trip bus in Electrohydraulic Control (EHC)

CabinetACl 19 so that a trip of the K620 relay in either Trait1 A or Train B will effect a turbine trip. In addition, a second contact on each K620 relay provides input to a redundant EHC vital trip logic that activates on a signal from either relay.

Slave relay K620 (along with several other relays) is associated with TS Table 3.3.2-1 "Engineered Safety Feature Actuation System Instrumentation," Fw1ction 5.a, 11Turbine Trip and Feedwater Isolation, Automatic Actuation Logic and Actuation Relays (SSPS)." It is required to be Operable in Modes 1 2 and 3, except wheo:

1. All MFIV s are closed and de-activated:

AND

2. All MFRVs are:

2.a Closed and de-activated, or 2.b Closed and isolated by a closed manual valve; AND

3. All MFRVBVs are:

3.a Closed and de-activated or 3.b Closed and isolated by a closed manual valve, or 3.c Isolated by two closed manual valves.

It should be noted that the ES FAS testing program meets the requirements of Regulatory Guide (RO) 1.22 Rev. 0, "Periodic Testing of Protection System Actuation Functions," as desc1ibed in FSAR-SP Section 7.1.2.5.2.

2.2.2 Cur.rent Licensing Basis Test Frequency for K620 Relay The cunent licensing basis, as desc1ibed in the Bases for TS 3.3.2 and in FSAR...,SP Chapter 7, requires slave relay K620 to be tested at 18-month intervals, i.e. during refuel outages, when the reactor is shut down.

The.TS Bases Surveillance Requirements section for SRJ.3.2.14 currently states, 1'The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program basis for TS SR 3.3.2.14 states, "The 18 month Frequency for these slave relays is based on the need to perfonn -this Surveillance under the conditions that apply during a unit outage to avoid the potential for an unplrumed transient if the Surveillance were perfonned with the reactor at power. The 18-month testing intervals for slave relay K620 were accepted by NRC at initial plant licensing based on SLNRC 84-0038 dated February 27, 1984."

As a result of the Main Turbine Controls upgrade (to be implemented in Callaway's upcoming refueling outage) 1 in which portions of the turbine trip circuitry are being replaced with new equipment, the testability of slave relay K620 is being chru1ged as further described below.

Page 4 of 8

Attachment l to ULNRC-06485

3. TECHNICAL EVALUATION The existing analog main turbine control systems are being replaced in the upcoming refue1 outage at Callaway Plant (spring 2019) as part of modification MP 08-0027, "Main Turbine Controls Replacement," with digital technology to eliminate single-point vulnerabilities, address obsolescence, improve reliability and reduce operator burden. Cunently, slave relay K620 is not tested at full power, in order to avoid tripping the main tmbine. However, the new turbine controls include new EHC trip bus coils with an i_mpedence sized to allow a small test cunent to be applied to the trip logic without activating the trip coils.

The test circuitry inside the SSPS cabinet is anned by switching the pole position of a test switch to inclnde a rnsistor in the circuit, which reduces the cun-ent to an acceptab1y low level for testing. This small test cunent will illuminate a light to indicate a successful test (but will not cause a trip). Wit11 the existing control systems, the test current is large enough to tr-ip the main turbine by energizing the turbine nip bus. It is for this reason that slave relay K620 is not tested when the unit is on-line. The new proposed turbine controls, however, iJ1clude new EHC trip bus coils with an impedance sized to allow the small test ci:ment to be applied to the trip logic without activating the trip coils.

In light of the above, the testability of slave relay K620 is being obanged such that the relay can be tested at power with no concern for an inadvertent turbine trip. For other slave relays of the same or similar type and which may be tested during plant operation with no concem for unwanted actuations/trips that could cause a plant transient, the relays are tested at a frequency commensurate with on-line testing, as specified in the SFCP. On that basis, slave relay K.620 should be brought into line with those relays with respect to test frequency. Although the test

frequencies for such relays may be re~evaluated and changed in accordance with the SFCP, a new "initial" frequency for K620 relay is being established as (at least) once per 9 months. As such, it is appropriate to bring the K620 relay into the scope of SR 3.3.2.6 (in lieu of SR 3.3.2.14).
4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The proposed amendment to revise the Teclmical Specifications in order to rnmove slave relay K620 from SR 3.3.2.14 and add it to SR 3.3.2.6 vvould result in a test frequency that is more appropriate for the relay upon iinplementation of the noted hirbine controls modification at Callaway. Required testing would still be perfonned in a manner consistent with applicable regulatory requirements and guidelines.

The proposed amendment wiJl establish a test frequency that is consistent with RG 1.22 Rev. 0, "Periodic Testing of Protection System Actuation Functions," for periodic testing performed dtuing reactor operations, in light of the new capability to test the K620 relay with the plant on line, as a reslillt of the turbi11e controls modification.

Page 5 of 8 lo ULNRC-06485 Testing of the K620 relay per the proposed amendment will still be in compliance with General Design Criterion (GDC) 21, "Protection System Reliability and Testability." GDC 21 states that "The protection system shall be designed to pennit periodic testing of its functioning when the reactor is tn operatio11....

11 At the same time, discussion of GDC 21 in FSAR-SP section 3.1.3 states "Functions that cam1ot be tested with the reactor at power are tested during shutdown, as allowed by the regulatory guide and the above standards." This allowance would no longer be applicable for the testing of slave relay K620 after implementation of the turbine controls modification. Upon implementation of the turbine control's modification the testability of slave relay K620 will be changed such that the relay can be tested with the reactor in operation. The proposed TS changes align the frequency for perfonning the K620 slave relay test to one that is consistent with the other slave relays tested at power. As noted above; this change establishes a test frequency for the K620 relay that is consistent with RG 1.22, and RG 1.22 provides guidance that supports compliance with GDC 21.

4.2 No Significant Hazards Consideration Determination The proposed amendment would revise the Technical Specifications (TSs) to remove slave relay K620 from TS Surveillance Requirement (SR) 3.3.2.14 and add it to SR 3.3.2.6, which is a more appropriate frequency for the relay in light of the change being made to the testability of this component as part of a plant modification being made to the main turbine controls system.

Ameren Missouri has evaluated whether or not a significant hazards consideration is involved with the proposed changes 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 incnase in the probability or consequences of an accident previously evaluated?

Response: No.

Testing slave relay 1(620 more frequently than ctmently required wift not increase the probability or the consequences of a previously evaluated accident.

The 11ew turbine controls being installed under a plant modification include new EHC tiip bus coils with an impedance sized to allow a small test current to be applied to the t1ip logic without activating the trip coils. This pe1mits the K620 slave relay to be tested on-line at the :frequency used for testing other, similar slave relays in the plant and without any significant increase in the probability of an inadvertent turbine trip. Consequently, the new test scheme for this relay does not increase the probabiijty of a previously evaluated transient (i.e., turbine trip) for Callaway.

Slave relay K.620 provides trip signals to the Main Turbine a11d the Main Feedwater trip logic.

Performing this test at the increased frequency will not adversely affect the relay's perfonnance since the new frequency is typical for slave relays that can be tested during plant operation. It is thus reasonable to conclude that the likelihood of relay failure is not increased.

Page 6 of 8 to ULNRC-06485 In regard to accident consequences, the change in test frequency for the K620 relay does not affect its required operability. Since the relay's function is not affected there is no change to how the function is credited or assumed in the plant's accident analysis. The analyzed consequences are thus unaffected.

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 crnate the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Testing slave relay K620 more -frequently than currently required does not create the possibilily of anew or different kind of accident from any accident previously evaluated.

Currently, slave relay K620 is tested with the turbine oftline since under the cmTent (Uilll1odified) design, the testing of slave relay K620 produces a test cunent sufficient to trip the main turbine. The new proposed turbine controls include new EHC hip bus coils with an impedance sized to allow a smalJ test current to be applied to the trip logic without activating the trip coils, thus allowing the slave relay test to be perfonned onhne. There is no change to the desigp or function of the relay itself or its associated logic. Thus, no new failure modes are introduced by the replacement of these tiip coils.

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 TS change only affects the testability of the K620 relay (and thus the frequency at which the relay is tested). The design and fi.mction of.the K620 slave relay itself are unchanged.

No changes to the accident analyses, including any associated assumptions such as instnnnent setpoints or credited hip functions, are required or being made for this proposed change.

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.

Page 7 of 8 to ULNRC-06485 4.3 Conclusions In conclusion, based on the considerations discussed above, (I) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed maimer, (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 secmity or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION Ameren Missouri has evaluated the proposed amendment and has detennined that tbe 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 fol' categoricaJ exclusion set forth in 10 CFR 5l.22(c)(9). Therefore, pursuant to 10 CPR 5 I.22(b), no enviromnental impact statement or environmental assessment need be prepared in cojmection with the proposed amendment.

6. REFERENCES
1. NRC Regulatory Guide (RG) 1.22 Rev. 0, "Pe1iodic Testing of Protection System Actuation Functions," Febrnary, 1972.

Page 8 of 8 to ULNRC-06485 Page 1 of3 ATTACHMENT 2 Markup of Technical Specification Pages for Proposed Change

I f - uc, 2 S t-D c_ I ESFAS lnstrumentat1on 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.5 SR 3.3.'2.6 SR 3.3.2.7 SR.3.3.2.8 SURVEILLANCE Perform COT.

NOTE - -----------

Not applicable to slave relays K6~~

. K-e2Q, K62 \\,

K624, K630, K740, K741, and K7 Perform SLAVE RELAY TEST.

NOTE----------

Verification of relay setpoints not required.

Perform TADOT.

NOTE------

Verification of setpolnt not required for manual initiation functions.

Perform TADOT.

CALLAWAY PLANT 3.3-37 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 202

t,Dl v lf-o 2 ~

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3. 2.13 SR 3.3.2.14 CALLAWAY PLANT SURVEILLANCE

NOTE -----------------

Only applicable to slave relays K602, K622, K624, K630, K740, and 1<741.

Perform SLAVE RELAY TEST.

N01E.....---, --

Only applicable to slave relay~ K7~.

FREQUENCY In accordance witll the Surveillance Frequency Control Program Prior to entering MODE 4 when in MODE 5 or6

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if not performed within the previous 92 days

~

_/ ----*

Perform SLAVE RELAY TEST.

In accordance with the Surveillance Frequency Control. Program 3.3-'39 Prior to entering MODE 3 when in MODE 5 or 6

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, If not performed within the previous 92 days Amendment No. 202 to ULNRC-06485 Page 1 of 3 ATTACHMENT 3 Markup of TS Bases Pages for Proposed Change (for information only)

BASES SURVl;:ILLANCE REQUIREMENTS (continued)

SR 3.3.2.6 ESFAS Instrumentation B 3.3.2 SR 3.3.2.6 is the performance of a SLAVE RELAY TEST. The SLAVE RELAY TEST is the energizing of the slave relays. Contact operation is verified in one of two ways. Actuation equipment that may be operated in G.,~-

L the design mitigation mode is either allowed to function, or is placed in a

(

J h.S l A V { [<..e LA y 16 T (

condition, where the relay contact operation can be verified without l

operation of the equipment. Actuati.on equipment that may not be er( r c:" / tlJ...f f::.. {20 d e - Yio1 ) operated in the design mitigation mode is prevented from operation by the J

'-. SLAVE RELAY TEST circuit. For this latter case, contact operation is 1

r\\ L/ vd_e._:c

{ /1e li rl v,1rt.

veri~ed by.a continuity check of the circuit containing tfl~ave-r.eJ2u1_:-:..The

.J SR 1s modified by a Note that excludes slave relays K6

, ~

~2, as s oc.i cd e./) w[ fA -/ he rw:u',1 K624, K630, K740, K741, and K750 which are included in ir1Rre_9\\Jired by SR 3.3.2.13 and SR 3.3.2.14. The Surveillance Frequency is oa'sed on

{e_e df wi., f@ r p rr, p 1'v; /J operating experience, equipment reliability, and plant risk and is controlled

~

r

sofeno,ds.slric.e -f-J,cd;

(

u*~cu~1J se,vi,-.s no~ sR 3.3.2.7

'req v JI' tf St~f {;,, 'H fioh _ SR 3.3.2.7 fs the performance o'. a TADOT. _ This te~t is a check of the J.....

.J AFW pump start on Loss of Offs1te Power tnp Function and the Steam

  • ~ -./ J ' -~

Generator Slowdown and Sample Line Isolation Valve Actuation Function 1 O.d. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refuelfng interval with applicable extensions. The trip actuating devices tested within the scope of SR 3.3.2. 7 are the LS ELS output relays and BOP ESFAS' separation groups 1 and 4 logic associated with the automatic start of the turbine driven auxiliary feedwater pump and closure of the steam generator blowdown isolation valves and sample line isolation valves on an ESF bus undervoltage condition. The SR is modified by a Note that excludes verification of setpoints for relays. The trip actuating devices tested have no associated setpoint.

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

( continued)

B 3,3.2-64 Revision 14

BASES SURVEILLANCE REQUIREMENTS REFERENCES CALLAWAY PLANT J(-oo~.5 SR 3.3.2.13 (continued)

ESFAS Instrumentation B 3.3.2 Frequency Control Program and prior to entering MODE 4 for Functions 1.b, 3.a.(2), and 7.a whenever the unit has been in MODE 5 or 6 for

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if not performed within the previous 92 days (Reference 12).

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

SR 3.3.2.14

all~~-Se.Q£es..l-O+E~~- eG-~~~~*GR-:--. The~~

is b~Jlerat' g exper'enc~eliability, and plant risk and is controlled under t e urveillance Frequency Control Program. Testing, slave relay K750 at power would result in opening the PORVs and depressurizin.9 the RCS. If the PORV block valves are closed, there is not enough pressure to open the PORVs.

1.

FSAR, Chapter 6.

2.

FSAR, Chapter 7.

3.

FSAR, Chapter 15.

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

Cc1llaway Setpoint Methodology Report (NSSS), SNP (UE)-565 dated May 1, 1984, and Callaway Instrument Loop Uncertainty Estimates (BOP), J-U-GEN.

7..

Not used.

(continued)

B 3.3.2-69 Revision 14 to ULNRC-06485 Page 1 of 3 ATTACHMENT4 Retyped Technical Specification Pages

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.5 SR 3.3.2.6 SR 3.3.2.7 SR 3.3.2.8 SURVEILLANCE Perform COT.

NOTE---------

Not applicable to slave relays K602, K622, K624, K630, K740, K741, and K750.

Perform SLAVE RELAY TEST.

NOTE ----------

Verification of relay setpoints not required.

Perform TADOT.

NOTE-------------

Verification of setpoint not required for manual initiation functions.

Perform T ADOT.

CALLAWAY PLANT 3.3-37 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance With the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 202

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.13 SURVEILLANCE

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

Only applicable to slave relays K602, K622, K624, K630, K740, and K741.

Perform SLAVE RELAY TEST.

SR 3.3.2.14 NOTE---------

Only applicable to slave relay K750, Perform SLAVE RELAY TEST.

CALLAWAY PLAN, 3.3-39 FREQUENCY In accordance with the Surveillance Frequency Control Program Prior to entering MODE 4 when in MODE 5 or 6

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if not performed within the previous 92 days In accordance with the Surveillance Frequency Control Program Prior to entering MODE 3 When in MODE 5 or. 6

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if not performed wlthin the previous.

92 days Amendment No. 202

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