ULNRC-04007, Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6 & 3.7.Encl Includes mark-ups of ITS Sections 3.5,3.6 & 3.8.Suppl to Ltr Will Be Provided at Later Date

Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6 & 3.7.Encl Includes mark-ups of ITS Sections 3.5,3.6 & 3.8.Suppl to Ltr Will Be Provided at Later Date

ML20205L077
Person / Time
Site:	Callaway
Issue date:	04/07/1999
From:	Passwater A UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205L081	List: ML20205L090 ULNRC-04007, Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6 & 3.7.Encl Includes mark-ups of ITS Sections 3.5,3.6 & 3.8.Suppl to Ltr Will Be Provided at Later Date
References
TAC-M98803, ULNRC-04007, ULNRC-4007, NUDOCS 9904140131
Download: ML20205L077 (9)

Text

Union Electric One Ameren Plaza 1C31 Chouteau Avenue i i , i PO Box 66149 I

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' SL louis, MO 63166-6149 April 7,1999 I' -

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1 U.S. Nuclear Regulatory Commission l l ATTN: Document Control Desk Mail Station PI-137 Washington, D.C. 20555-0001 ULNRC-04007 i Gentlemen: -TAC NO. M98803 l

DOCKET NUMBER 50-483 CALLAWAY PLANT

. gg, UNION ELECTRIC COMPANY l FOLLOW-UP ITEMS RELATED TO THE PROPOSED CONVERSION TO THE l NN IMPROVED TECPNICAL SPECIFICATIONS SECTIONS 3.3. 3.4. 3.6. AND 3.7

#E Refere- x 1. ULNRC-03578 dated May is,1997 l

2. ULNRC-03927 dated November 25,1998 l

3 TENRC-03900 dated September 24,1998

4. ULNRC-03853 dated June 26,1998

5. ULNRC-03905 dated October 21,1998

6. ULNRC-03908 dated October 21,1998 l 7. ULNRC-03926 dated November 23,1998

8. ULNRC-03946 dated December 22,1998 l

9. ULNRC-03957 dated Febmary 5,1999

10. ULNRC 03979 dated March 9,1999 Union Electric Company requested an amendment to the Callaway Facility Operating License (NPF-30) by incorporating changes to the Tecimical Specifications (TS) as provided in Reference 1. The NRC staff reguested addthnal information regarding Section 3.3, "Instmmentation," which was provided in Reference 2. The NRC staff requested additional information ./

regarding Section 3.4, "Reaam Coolant System," and Section 5.0," Administrative /

Controls," which was provided in Reference 3. The NRC staff reguested additional information regarding Section 3.6, " Containment Systems," which was provided in Reference 4. In addition, the NRC staff reguested additional information regarding Section 3.7, " Plant Systems," which was provided in Reference 5.

The Attachments to this letter provide (1) additional information or fol o supporting documentation not provided in the original RAI responses, (2) answers to follow-up questions, and (3) additional changes identified by the licensee for ITS Sections 3.3,3.4,3.6, and 3.7. Additional sections are also affected since Comment Number 3.3-99 includes mark-ups ofITS Section 3.8 Bases pages, Comment Number CA-3.7-ED includes mark-ups ofITS Section 4.0 pages, and Comment Number CA-3.7-012 includes mark-ups of Bases pages for ITS Sections 3.5 and 3.6.

• 4 O h f \ 't 9904140131 990407 PDR ADOCK 05000483 P PDR 3 e subsidiary of Amoren Corporation

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U.S. Nuclear Regulatcy Commission R E April 7,1999 Page 2 Reference 6 provided the first follow-up letter, affecting ITS Sections 3.1, 3.2,3.4, 3.5, and 5.0. Reference 7 provided the second follow-up letter, affecting ITS Sections 1.0,3.4,3.5,3.6,3.7, and 3.9. Reference 8 provided the third follow .

up letter, affecting ITS Sections 1.0,3.1,3.2,3.3,3.4,3.7,3.9, and 5.0. Reference 9 provided the fourth follow-up letter, affecting ITS Sections 1.0, 3.2, 3.3, 3.4, 3.6, -

3.7, 3.8, 3.9, and 5.0. Reference 10 provided the fifth follow-up letter, affecting ITS Sections 3.3, 3.4, 3.6, 3.7, 3.8, 3.9, and 5.0.

This letter and its Attachments are not a supplement to Reference 1 and .

have not been reviewed by the Onsite Review Committee or Nuclear Safety Review Board. .A supplement to Reference I will be provided at a later date.

If you have any questions concerning this response, please contact us.

Sincerely, AL :AM1 Alan C[Passw#ater Manager, Corporate Nuclear Services ACP/pir

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.1 STATE OF MISSOURI )

-) SS CITY OF ST. LOUIS-)

David Shafer, of lawful age, being first duly-sworn upon' oath says that he is Supervising Engineer, Corporate Nuclear Services, Regulatory Operations for Union Electric Company; that he has read the foregoing document-and knows the content thereof; that he has execuned the same for and on behalf of said company with full power and authority to do so; and that the facts therein~ stated are true and correct to the best of his knowledge, information and belief.

By L_ .: o _1 1 . 1 . -

David Shafer '

Supervising Engineer, Regulatory Operations, Corporate Nuclear Services SUBSCRIBED and sworn to before me this day of (l44EY , 1999.

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cc: M. H. Fletcher Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mel Gray (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 ,

11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Denny Buschbaum TU Electric P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent Pacific Gas & Electric z Regulatory Services 1 P.O. Box 56 Avila Beach, CA 93424

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_____-_____s

The item numbers are formatted as follows: [ Source] [lTS Section)-[nnn)

Source = Q - NRC Question NR - NRC Follow-up Question CA - AmerenUE DC-PG&E WC - WCNOC CP - TU Electric TR - Traveler ITS Item Number Applicability Enclosed 3.3 0 3-08 DC NA 3.3 Q 3.3-21 CA YES 3.3 0 3.3-32 CA YES 3.3 Q 3.3-37 DC NA 3.3 Q 3.3-43 CA,DC YES 3.3 0 3.3-46 DC NA 3.3 Q 3.3-54 DC NA 3.3 Q 3.3-66 DC NA 3.3 0 3.3-71 DC NA 3.3 0 3.3-77 DC NA 3.3 O 3.3-82 DC NA 3.3 0 3.3-99 CA YES 3.3 Q 3.3-104 DC NA 3.3 CA-3.3-002 CA YES 3.3 CA-3.3-006 CA,DC YES 3.3 CA-3.3-024 CA YES

_3J CA-3.3-025 CA YES 3.3 _

CA-3.3 026 CA YES 3.3 CA-3.3-027 CA YES 3.3 DC-3.3-004 DC NA 3.3 DC-3.3-006 (NEW) DC NA 3.3 DC-3.3-007 (NEW) DC NA 3.3 DC-3.3-008 (NEW) DC NA 3.3 DC-3.3-009 (NEW) DC NA 3.3 DC-3.3-ED DC NA 3.3 DC-3.3-ED1 (NEW) DC NA 3.3 DC-ALL-005 (3.3 changes only) DC NA 3.4 Q 3.4.11-3 _

CA YES

3.6 O 3.6.3-10 DC NA 3.6 Q 3.6.3 CA YES 3.6 Q 3.6.3-39 DC NA 3.6 Q 3.6.6-19 DC NA 3.6 CA-3.6-ED2 (NEW) CA YES 3.7 CA-3.7-ED CA YES 3.7 CA-3.7-012 CA YES 3.8 Q 3.8.1-33 DC NA 3.9 DC-ALL-001 (3.9 changes only) DC NA 1

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.3-21 APPLICABILITY: CA REQUEST: ITS 3.3.3 was revised to reflect current TS 3.3.3.6 containment isolation valve position (and Notes) and condensate storage tank level were deleted. [ Combined the power and source range neutron flux entries into a single neutron flux entry.]

Consolidated the thermocouple / core cooling detection system entries. Changed number of required channels for RCS temperature to 2 for both hot and cold leg temperature.

Changed containment pressure wide range to containment pressure normal range and added refueling water storage tank level, steam line press Jre, and SG water level (Narrow Range) functions as these are current TS requirements. Changed the required number of channels for SG water level (Wide Range) and AFW flow rate from 2 per SG to 1 per SG and added corresponcling mtes to Conditions A and C.

Comment: (1) ITS includes thermocouples as PAM instrument functions without specifying the number required to be operable. Provide a revised table entry for function 15. Include the appropriate discussion of change.

(2) Provide a table footnote to specify the need for the operable instruments to be in the same coolant loop. Provide a Bases discussion of the proposed footnote.

{WC}

(3) Correct the table entry making it based on each core quadrant as a table function. The Bases Actions in WC already specify the quadrant basis. CW may need to make conforming Bases changes. {WC & CW}.

(4) Revise ITS Conditions A & C Notes pertaining to AFW and SG water level inoperable channels. Two instrumented SGs are required to be operable to conduct a plant shutdown. Thus, the LCO is 1 channel each of AFW and wide range level per SG The staff does not credit AFW as diverse to Level which means one inoperable AFW or Level channel in a SG results in loss of the PAM monitoring function for that SG Therefore, Conditions are entered when less than 2 SGs have both AFW and wide range level channel operable. Condition A for AFW and wide range level functions should allow a 30 day Completion Time for one or more inoperable AFW or Level channels in one, two or three SGs.

Condition C for AFW or wide range level functions should allow a 7 day Completion for one or more inoperable AFW or Level channels in each SG FLOG RESPONSE (original): (1) This comment is applicable to Wolf Creek only. The ITS markup has been corrected to reflect the Required Channels as "2(*)/ core quadrant" consistent with the CTS.

(2) This comment is applicable to Wolf Creek and Callaway. It is assumed that this comment is referring to Table 3.3.3-1, Functions 2 and 3 (RCS Hot and Cold Leg Temperature (Wide Range)) and the deletion of the "per loop" in the Required Channels column. The "per loop" was deleted based on the plant design of one hot leg temperature indicator (wide range) and one cold !eg temperature indicator (wide range)

in RCS loops 1 and 2. Attached are pages from USAR/FSAR Table 7A-3 (Data Sheets 2.1 and 2.2) that indicate the plant design provisions. This change is consistent with CTS Table 3.3-10.

(3) See the response to item 1 for correcting ITS Table 3.3.3-1 for Wolf Creek. The Wolf Creek and Callaway Bases both state: "When the Required Channels in Table 3.3.3-1 are specified on a per SG or per core quadrant basis, then the Condition may be entered separately for each SG or core quadrant, as appropriate." No changes to the ITS Bases are necessary.

(4) There is one wide range water level indicator for each steam generator (AE-LI-0501 through -0504 in the main control room). Diverse indications are available from four narrow range level indicators for each SG when on scale and one AFW flow indicator per SG as discussed in USAR/FSAR Table 7A-3, Data Sheet 4.1. Reactor coolant pressure and reactor coolant temperature indications are also diverse variables from the aspect that they can be used to determine whether adequate core cooling is provided in the absence of wide range levelindication on a steam generator. Additional heat sink status diversity is also provided by three steamline pressure indicators per loop. There is one AFW flow rate indicator for each SG (AL-FI-0001 A through -004A in the main control room). Although not required for Regulatory Guide 1.97 Category 2 variables, diverse indicatir,5 are available from one wide range level indicator and four narrow range level indic.cors per SG. As discussed in Table 7A-3, Data Sheet 5.1, each of these four flow indicators is powered by a different separation group. Since only two of four SGs are required to establish a heat sink for the RCS, flow indication to at least two intact SGs is assured even if a single failure is assumed. Section 22 of the Safety Evaluation Report, NUREG-0830 for Callaway and NUREG-0881 for Wolf Creek, specifically accepted the response to NUREG-0737 Item ll.E.1.2 Part 2 for AFW flow rate indication and the CTS, as originally issued, did not "AND" wide range level with AFW flow rate as discussed in the comment. Table 7A-3, Data Sheets 4.1 and 5.1 have been attached to this response for information. The proposed ITS mark-ups maintain the CTS 3.3.3.6 requirements.

(5) Item 5 is a new item applicable only to Wolf Creek that was discussed during the Section 3.3 meeting held the week of August 11,1998. This item is to revise Table 3.3.3-1 Function 1, Power Range Neutron Flux and Function 2, Source Range Neutron Flux, into one Function, Neutron Flux. Neutron Flux indication is provided to verify reactor shutdown over the full range of flux that may occur post-accident. One channel of the 5

Gamma-Metric neutron flux monitoring system provides source range (0.1 to 10 cps) and wide range (10*to 200% power)in the control room. The second channel provides source and wide range indication at the auxiliary shutdown panel, as well as a two-pen indicating recorder (SE-NIR-0061) for both source and wide ranges in the control room.

Neutron flux is used for accident diagnosis, verification of subcriticality, and diagnosis of positive reactivity insertion. The Neutron Flux function was added to CTS 3/4.3.3.6 by Amendment No. 89. Therefore, changing the Function to Neutron Flux is consistent with the plant design and the CTS.

FLOG RESPONSE (supplement): As discussed with the NRC reviewer on February 17, 1999, ITS 3.3.3 and associated Bases are revised. Conditions A and C are revised to delete specific reference to the SG Water Level (Wide Range) and AFW Flow Rate Functions. Table 3.3.3-1 is revised for these two Functions to indicate that the Required Channels is 4 (i.e., one per SG). Additiondly, in Table 3.3.3-1, the Core Exit

1 Temperature Functions are restored instead of specifying the Themocouple/ Core i Cooling Detection System.

FLOG RESPONSE (supplement): The attached ITS 3.3.3 Bases changes are made in response to comments received from the NRC reviewer on March 12,1999.

ATTACHED PAGES: , CTS 3/4.3 - ITS 3.3 Enclosure SB, pages B 3.3-170 and B 3.3-173 (insert SR 3.3.3.2) 1