ML19283C481

Issuance of Amendment No. 221 Main Turbine Control Slave Relay Testing

ML19283C481
Person / Time
Site:	Callaway
Issue date:	12/06/2019
From:	Klos L Plant Licensing Branch IV
To:	Diya F Ameren Missouri
Klos L
References
EPID L-2019-LLA-0054
Download: ML19283C481 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 6, 2019 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Fulton, MO 65077

SUBJECT:

CALLAWAY PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 221 RE:

MAIN TURBINE CONTROL SLAVE RELAY TESTING (EPID L-2019-LLA-0054)

Dear Mr. Diya:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 221 to Renewed Facility Operating License No. NPF-30 for Callaway Plant, Unit No. 1 (Callaway). The amendment consists of changes to the technical specifications (TSs) in response to your application dated March 12, 2019, as supplemented by letter dated June 6, 2019.

The amendment revises the Callaway TSs to modify testing of slave relay K620 during shutdown under Surveillance Requirement (SR) 3.3.2.14 to testing during operation under SR 3.3.2.6.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, L. l Kl , Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

1. Amendment No. 221 to NPF-30

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 221 License No. NPF-30

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Union Electric Company (UE, the licensee),

dated March 12, 2019, as supplemented by letter dated June 6, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-30 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan*

The Technical Specifications contained in Appendix A, as revised through Amendment No. 221 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This amendment is effective as of its date of issuance, and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION r+xJennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-30 and Technical Specifications Date of Issuance: December 6, 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 221 CALLAWAY PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483 Replace the following pages of the Renewed Facility Operating License No. NPF-30 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.3-37 3.3-37 3.3-39 3.3-39 3.3-44 3.3-44

(3) UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source of special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level UE is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal ( 100% power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan*

The Technical Specifications contained in Appendix A, as revised through Amendment No. 221 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Environmental Qualification (Section 3.11, SSER #3)**

Deleted per Amendment No. 169.

• Amendments 133, 134, & 135 were effective as of April 30, 2000 however these amendments were implemented on April 1, 2000.

• • The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-30 Amendment No. 221

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.5 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.6 --------------------------------- NOTE ---------------------------

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

Perform SLAVE RELAY TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.7 --------------------------------- NOTE ---* ------------------------

Verification of relay setpoints not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.8 --------------------------------- NOTE ----------------------------

Verification of setpoint not required for manual initiation functions.

Perform T ADOT. In accordance with the Surveillance Frequency Control Program

\COnunueaJ CALLAWAY PLANT 3.3-37 Amendment No. 221

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued}

SURVEILLANCE FREQUENCY SR 3.3.2.13 --------------------------------- NOTE ----------------------------

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

Perform SLAVE RELAY TEST. In accordance with 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 SR 3.3.2.14 --------------------------------- NOTE ----------------------------

Only applicable to slave relay K750.

Perform SLAVE RELAY TEST. 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 within the previous 92 days CALLAWAY PLANT 3.3-39 Amendment No. 221

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 5 of 11)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE(a)

5. Turbine Trip and Feedwater Isolation

a. Automatic 2 trains G SR 3.3.2.2 NA Actuation Logic SR 3.3.2.4 and Actuation SR 3.3.2.6 Relays (SSPS)

b. Automatic 2 trains<0 > s SR 3.3.2.3 NA Actuation Logic and Actuation Relays (MSFIS)

c. SG Water Level - 4 per SG SR3.3.2.1 ~ 91.4%(s) of High High (P-14) SR3.3.2.5 Narrow Range SR 3.3.2.9 Instrument SR 3.3.2.10 Span

d. Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements. The Applicability exceptions of Footnote (j) also apply to Function 5.d.

(a) The Allowable Value defines the limiting safety system setting except for Functions 1.e, 4.e.(1 ), 5.c, 5.e.(1 ), 5.e.(2),

6.d.( 1), and 6.d.(2) (the Nominal Trip Setpoint defines the limiting safety system setting for these Functions). See the Bases for the Nominal TripSetpoints.

(j) Except when:

1. All MFIVs 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.

(I) Except when all MFIVs are closed and de-activated.

(o) Each train requires a minimum of two programmable logic controllers to be OPERABLE.

(s) 1. If the as-found instrument channel setpoint is conservative with respect to the Allowable Value, but outside its as-found test acceptance criteria band, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. If the as-found instrument channel setpoint is not conservative with respect to the Allowable Value, the channel shall be declared inoperable.

2. The instrument channel setpoint shall be reset to a value that is within the as-left setpoint tolerance band on either side of the Nominal Trip Setpoint, or to a value that is more conservative than the Nominal Trip Setpoint; otherwise, the channel shall be declared inoperable. The Nominal Trip Setpoints and the methodology used to determine the as-found test acceptance criteria band and the as-left setpoint tolerance band shall be specified in the Bases.

CALLAWAY PLANT 3.3-44 Amendment No. 221

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 221 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT. UNIT NO. 1 DOCKET NO. 50-483

1.0 INTRODUCTION

By application dated March 12, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19071A281), as supplemented by letter dated June 6, 2019 (ADAMS Accession No. ML19157A303), Union Electric Company, dba Ameren Missouri (the licensee) requested changes to Renewed Facility Operating License No. NPF-30 for the Callaway Plant, Unit No. 1 (Callaway).

The proposed amendment would revise the Callaway Technical Specifications (TSs) to remove slave relay K620 from the scope of TS Surveillance Requirement (SR) 3.3.2.14 testing during shutdown conditions at 18-month intervals and incorporate it into the scope of SR 3.3.2.6 for surveillance testing during power operations, at a frequency in accordance with the Surveillance Frequency Control Program (SFCP). Specifically, the proposed changes would revise the condition of performing the surveillance test for slave relay K620 only during Mode 5 or 6.

The change is accomplished by moving the relay from the scope of SR 3.3.2.14 to SR 3.3.2.6.

The frequency under SR 3.3.2.14 states "In accordance with the Surveillance Frequency Control Program AND Prior to entering MODE 3 when in MODE 5 or 6 > [greater than] 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." The frequency is now placed under SR 3.3.2.6, which states, "In accordance with the Surveillance Frequency Control Program."

The supplemental letter dated June 6, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on June 4, 2019 (84 FR 25841 ).

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 System Description The solid-state protection system (SSPS) is designed to initiate a reactor trip if safe operating limits are exceeded and to initiate engineered safety features actuations if an accident occurs.

Slave relay K620 is part of the SSPS system and is used to energize the trip bus coil in the electro-hydraulic control (EHC) system that controls the main turbine. The SSPS system includes a built-in feature to test slave relays during operation. The slave relay test uses a low current signal that demonstrates continuity through to the trip coil without actuation. The EHC system trip bus coil that was previously installed did not meet the impedance criteria required for use with the built-in test feature and was at risk for initiating a turbine trip if tested while the plant was operating. To date, slave relay K620 was only tested while the plant was in Mode 5, "Cold Shutdown" or Mode 6, "Refueling."

The SSPS accomplishes testing of slave relays during operation by using a fixed, series resistor that is connected to an individual channel through a rotary selector switch. The resistor limits the current going to the slave relay coil such that it will not trip. This allows testing of these relays during plant operations without fully actuating the function. Because the current limiting series resistor is a fixed value, the impedance of the trip coil under test must meet a minimum value to ensure it will not cause an unintended trip.

2.2 Proposed Changes The licensee proposed changes that would remove the condition of performing the surveillance test for slave relay K620 only during Mode 5 or 6. The change is accomplished by moving the relay from the scope of SR 3.3.2.14 to SR 3.3.2.6. The frequency under SR 3.3.2.14 was "In accordance with the Surveillance Frequency Control Program AND 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." The proposed frequency under SR 3.3.2.6 is "In accordance with the Surveillance Frequency Control Program." Notes for both SR 3.3.2.6 and SR 3.3.2.14 are modified to reflect the change. Slave relay K620 is removed from the "not applicable to" list on the 3.3.2.6 Note because it will now be performed under 3.3.2.6. Slave relay K620 is also removed from the "only applicable to" list on the 3.3.2.14 Note because slave relay K620 will no longer be performed under 3.3.2.14. The Callaway TS are modified to reflect the change as follows:

Current SR 3.3.2.6 Note states:

Not applicable to slave relays K602, K620, K622, K624, K630, K7 40, K7 41, and K750.

Revised SR 3.3.2.6 Note would state:

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

Current SR 3.3.2.14 Note states:

Only applicable to slave relays K620 and K750.

Revised SR 3.3.2.14 Note would state:

Only applicable to slave relay K750.

Current Table 3.3.2-1, Function 5a, SR column states:

SR 3.3.2.2, SR 3.3.2.4, SR 3.3.2.6, SR 3.3.2.14 Revised Table 3.3.2-1, Function 5a, SR column would state:

SR 3.3.2.2, SR 3.3.2.4, SR 3.3.2.6 2.3 Regulatory Requirements and Guidance The NRC's regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications." This regulation requires that the TSs include items in the following five specific categories: ( 1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in plant TSs.

The regulation under 10 CFR 50.36(c)(3) states that, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The license amendment request (LAR) proposes to change the frequency of the surveillance test for slave relay K620.

The regulation under 10 CFR 50.36(a)(1) states, in part, that "A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications."

Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes. The NRC staff noted that the licensee included TS Bases changes in the LAR but did not review the specific TS Bases changes.

Appendix A to 10 CFR Part 50, GDC 21, "Protection System Reliability and Testability," states, in part, that the protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation. The current licensing basis allows testing of slave relay K620 only when the reactor is operating in Modes 5 or 6.

Regulatory Guide (RG) 1.22 describes acceptable methods to meet GDC 21, including functional testing when the reactor is in operation. The current licensing basis allows testing of slave relay K620 only when the reactor is operating in Modes 5 or 6.

Institute of Electrical and Electronics Engineers (IEEE) 279-1971 Clause 4.10 states, in part, that for those parts of the system where the required interval between testing will be less than the normal time interval between generating station shutdowns, there shall be capability for testing during power operation. The current licensing basis allows testing of slave relay K620 only when the reactor is operating in Modes 5 or 6.

3.0 TECHNICAL EVALUATION

As described in Section 2.2 of this safety evaluation, the licensee is proposing to revise the Callaway TSs to move the surveillance testing of slave relay K620 from SR 3.3.2.14 to SR 3.3.2.6. The change impacts the frequency of the surveillance because the frequency of the new SR is not limited to being performed while the plant is in Mode 5 or 6.

The NRC staff reviewed the technical discussion of the proposed changes provided in the LAR to ensure that the reasoning was logical, complete, and clearly written. Specifically, the staff reviewed the proposed changes for continued compliance with the regulation in 10 CFR 50.36(c)(3), GDC 21, RG 1.22, and IEEE 279-1971.

The NRC staff previously made an exception for the testing of relay K620 only during Modes 5 and 6 as acceptable with allowances stated in IEEE 279-1971 Clause 4.10 because the SSPS' built-in test for slave relays had a high risk of tripping the main turbine at that time. However, recent changes to the main turbine's EHC system included a new relay that is compatible with the SSPS' built-in test function which therefore now allows testing while the reactor is in operation without the previous exception applied. Therefore, the NRC staff finds that because slave relay K620 can now be tested while the reactor is operating, the related SR is now consistent with the online-test criteria of GDC 21, RG 1.22, and IEEE 279-1971 Clause 4.10 and that the proposed changes are acceptable.

Callaway TS LCO 3.3.2 states that the" [Engineered Safety Feature Actuation System] ESFAS instrumentation for each Function in Table 3.3.2-1 shall be OPERABLE." Slave relay K620 is associated with TS Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation," Function 5a, "Turbine trip and Feedwater Isolation, Automatic Actuation Logic and Actuation Relays (SSPS)." SR 3.3.2.6 and SR 3.3.2.14 are both SSPS slave relay tests that determine operability for several ESFAS functions, including ESFAS Function 5a. The surveillances differ only in which relays are tested and the frequency of testing. The frequency for SR 3.3.2.6 is "In accordance with the Surveillance Frequency Control Program". The frequency for SR 3.3.2.14 is "In accordance with the Surveillance Frequency Control Program AND 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." The NRC staff notes the proposed change removes the limitation of the surveillance being performed only in Mode 5 or 6, stating instead that the relay should be tested as determined by the SFCP. The NRC staff review concludes that there is reasonable assurance that the requirements and criteria found in 10 CFR 50.36(c)(3) will continue to be met. Therefore, the staff finds the proposed change is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment on September 26, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

T~e amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation

exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, published in Federal Register on June 4, 2019 (84 FR 25841), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributors: S. Wyman H. Kodali Date: December 6 , 2 O1 9

SUBJECT:

CALLAWAY PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 221 RE:

MAIN TURBINE CONTROL SLAVE RELAY TESTING (EPID L-2019-LLA-0054)

DATED DECEMBER 6, 2019 DISTRIBUTION:

PUBLIC RidsNrrDeEeob Resource PM File Copy RidsNrrLAPBlechman Resource RidsACRS MailCTR Resource RidsNrrPMCallaway Resource RidsNrrDorlLpl4 Resource RidsRgn4MailCenter Resource RidsNrrDssStsb Resource SWyman, NRR RidsNrrDeEicb Resource HKodali, NRR ADAMS A ccess1on No. ML19283C481 *b1yema1*1 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DE/EEOB* NRR/DSS/STSB/BC NAME JKlos PBlechman DWilliams VCusumano DATE 9/27/19 10/17/19 9/26/19 10/22/19 OFFICE NRR/DE/EICB/BC (A)* OGC* NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME RAlvarado (WMorton for) KGamin J Dixon-Herrity JKlos DATE 11/13/2019 11/21/19 11/22/19 12/6/19 OFFICIAL RECORD COPY