Text

Proposed Revision to Technical Specification (TS) 3.9.2, Unborated Water Source Isolation Valves, to Revise & Rename Specification 3.9.2, Dilution Source Isolation Valves & Associated Revision to TS 3.3.9, Boron Dilution...
	ML033600242
Person / Time
Site:	Callaway
Issue date:	12/15/2003
From:	Keith Young; AmerenUE
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NUREG-1431, ULNRC-04883
	Download: ML033600242 (65)
	v • d • e

AmerenUE PO Box 620 Cal/away Plant Fulton, MO 65251 December 15, 2003 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen: ULNRC-04883 WAmere UE DOCKET NO. 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT PROPOSED REVISION TO TECHNICAL SPECIFICATION 3.9.2 "UNBORATED WATER SOURCE ISOLATION VALVES" TO REVISE AND RENAME SPECIFICATION 3.9.2 "DILUTION SOURCE ISOLATION VALVES" AND ASSOCIATED REVISION TO TECHNICAL SPECIFICATION 3.3.9 "BORON DILUTION MITIGATION SYSTEM (BDMS)"

Pursuant to 10 CFR 50.90, AmerenUE, requests an amendment to the Facility Operating License No. NPF-30 for Callaway Plant. The amendment application would revise Technical Specifications (TS) 3.9.2, "Unborated Water Source Isolation Valves," to remove the phrase "unborated water" throughout and replace it with the word "dilution", including renaming TS 3.9.2. In addition, the reference to specific Chemical and Volume Control system (CVCS) isolation valves BGV0178 and BGV0601 is deleted and replaced with the generic phrase "dilution source isolation valves". The generic reference to dilution source isolation valves ensures that all dilution sources and their associated isolation valves, including the Boron Thernal Regeneration System (BTRS) and the Nuclear Sampling System (SJ), are covered by the Specification. Revised TS 3.9.2 covers all inadvertent boron dilution events in Mode 6.

In an associated change, TS 3.3.9 REQUIRED ACTIONS for CONDITIONS B and C are also revised to substitute the word "dilution" for "unborated water" and to eliminate reference to specific isolation valves. The revisions make TS 3.3.9 consistent with TS 3.9.2. Specific isolation valves are not required in the Standard Technical Specifications, NUREG-1431. Removing them from the Specifications and relocating them in the appropriate TS Bases is an administrative only change and is consistent with the Standard Technical Specifications.

Ap asubsidiary ofAmeren Corporation

ULNRC-04883 December 15, 2003 Page 2 Control rod withdrawal and diluting the reactor coolant system (RCS) boron concentration are the two principle means of inserting positive reactivity into the reactor core. Boron dilution can occur by two methods: (1) adding unborated, primary grade water from the reactor makeup water system (RWMS) into the RCS through the reactor makeup portion of the chemical and volume control system (CVCS) or, (2) removing boron from the CVCS stream prior to RCS return using the ion exchange capability of the BTRS.

TS 3.9.2 LCO identifies two specific valves (BGV0178 and BGV0601) to address the first boron dilution method. Current TS 3.9.2 does not contemplate the potential dilution source associated with flushing the CVCS letdown radiation monitor SJREOO1 (a component of the SJ system) with unborated reactor makeup water. Current TS 3.9.2 also does not contemplate the effect of the BTRS as a potential boron dilution source. As a result, the Specification does not adequately address all potential dilution sources, and does not preclude all potential inadvertent dilution events in Mode 6. By generically referring to "dilution source isolation valves", the revised TS 3.9.2 LCO incorporates all dilution sources and associated isolation valves. References to specific valves are transferred to the TS 3.9.2 Bases.

In addition, TS 3.3.9 is made consistent with TS 3.9.2 by revising the "unborated water" source to "dilution" source and by moving specific isolation valve identification to TS Bases.

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

Attachment I to this submittal provides the required Affidavit. Attachment 2 provides a detailed description, safety analysis of the proposed changes, and the Callaway determination that the proposed change does not involve a significant hazard consideration. Attachment 3 provides the existing TS pages marked-up to show the proposed change. Attachment 4 provides a clean copy of the proposed Technical Specification pages. Attachment 5 provides the existing TS Bases pages marked-up to show the proposed changes (for information only). Finally, Attachment 6 provides FSAR revisions to incorporate the proposed changes (for information only).

This letter identifies actions committed to by AmerenUE and Callaway Plant in this submittal. Other statements are provided for information purposes and are not considered to be commitments. A summary of the regulatory commitments included in this submittal is provided in Attachment 7.

ULNRC-04883 December 15, 2003 Page 3 This amendment application was approved by the Callaway Plant Review Committee and the Nuclear Safety Review Board. It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92. In addition, pursuant to 10 CFR 51.22(b), no environmental assessment need be prepared in connection with the issuance of this amendment.

AmerenUE requests approval of this proposed License Amendment by September 1, 2004. The approved amendment will be implemented within 90 days of approval.

Pursuant to 10 CFR 50.91(b)(1), AmerenUE is providing the State of Missouri with a copy of this proposed amendment.

If you should have any questions on the above or attached, please contact Dave Shafer at (314) 554-3104 orDwyla Walker at (314) 554-2126.

Very truly yours, Keith D. Young Manager, Regulatory Affairs DJW/jdg

Attachment:

1) Affidavit

2) Evaluation

3) Markup of Technical Specification pages

4) Retyped Technical Specification pages

5) Markup of Technical Specification Bases pages (for information only)

6) Markup of Callaway FSAR pages (for information only)

7) Summary of Regulatory Commitments

ULNRC-04883 December 15, 2003 Page 4 cc: U. S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Bruce S. Mallet Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102

Attachment I ULNRC-04883 STATE OF MISSOURI )

SS COUNTY OF CALL WAY Keith D. Young, of lawful age, being first duly sworn upon oath says that he is Manager, Regulatory Affairs, for Union Electric Company; that he has read the foregoing document and knows the content thereof, that he has executed 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 0l{~

Koth D. You Manager, Regulatory Affairs SUBSCRIBED and sworn to before me this I ' day of I erj e r- 2003.

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ULNRC-04883 ATTACHMENT 2 EVALUATION

Attachment 2 Table of Contents ULNRC-04883 PROPOSED REVISION TO TECHNICAL SPECIFICATION 3.9.2, "UNABORATED WATER SOURCE ISOLATION VALVES" TO REVISE AND RENAME SPECIFICATION 3.9.2 "DILUTION SOURCE ISOLATION VALVES" AND ASSOCIATED REVISION TO TECHNICAL SPECIFICATION 3.3.9 "BORON DILUTION MITIGATION SYSTEM (BDMS)"

TABLE OF CONTENTS

1.0 DESCRIPTION

1

2.0 PROPOSED CHANGE

S 1

3.0 BACKGROUND

2 3.1 Boron Dilution Event and Mitigation 2 3.2 Additional Dilution Sources Identified 3 3.3 Summary 5

4.0 TECHNICAL ANALYSIS

5 5.0 REGULATORY SAFETY ANALYSIS 6 5.1 No Significant Hazards Consideration 6 5.2 Applicable Regulatory Requirements/Criteria 8

6.0 ENVIRONMENTAL CONSIDERATION

9 7.0 PRECEDENTS 10

8.0 REFERENCES

10

Attachment 2 ULNRC-04883 EVALUATION

1.0 INTRODUCTION

This letter is a request to amend Operating License NPF-30 for Callaway Plant.

The amendment application would revise Technical Specifications (TS) 3.9.2, "Unborated Water Source Isolation Valves," to remove the phrase "unborated water" throughout and replace it with the word "dilution", including renaming TS 3.9.2 "Dilution Source Isolation Valves". In addition, the reference to specific Chemical and Volume Control system (CVCS) isolation valves BGVO 178 and BGV0601 is deleted and replaced with the generic phrase "dilution source isolation valves". These changes to a generic Specification ensure that all dilution sources and their associated isolation valves, including the Boron Thermal Regeneration System (BTRS) and the Nuclear Sampling System (SJ), are included. The revised TS 3.9.2 precludes all inadvertent boron dilution events in Mode 6.

In an associated change, TS 3.3.9 REQUIRED ACTIONS for CONDITIONS B and C are also revised to substitute the word "dilution" for "unborated water" and to eliminate references to specific isolation valves. The revisions make TS 3.3.9 consistent with TS 3.9.2.

The proposed changes to a generic Specification maintain the plant in a safe condition by ensuring that all potential boron dilution sources are isolated in Mode 6. The proposed changes do not alter design bases or technical requirements.

2.0 DESCRIPTION

OF PROPOSED AMENDMENT The amendment application revises Technical Specifications (TS) 3.9.2, "Unborated Water Source Isolation Valves," to remove the phrase "unborated water" throughout and replace it with the word "dilution", including renaming the TS 3.9.2. In addition, the reference to specific CVCS isolation valves BGVO 178 and BGV0601 is deleted and replaced with the generic phrase "dilution source isolation valves". This ensures that all dilution sources and their associated isolation valves are included in the Specification, (including the potential dilution source associated with the BTRS anion resin vessels and the potential source associated with flushing the CVCS letdown gamma radiation detector SJRE00 1). The revised TS 3.9.2 precludes all inadvertent boron dilution events in Mode 6. References to specific dilution sources and their associated isolation valves are removed from the current TS 3.9.2 LCO and SURVEILLANCE REQUIREMENTS and are transferred to TS 3.9.2 Bases. A NOTE is added to the LCO such that during refueling decontamination activities, a dilution source path may be unisolated, when required, under administrative controls. Based on Amendment 97 to the Callaway Plant Operating License, administrative controls are used to limit the volume of unborated Page I of 11

Attachment 2 ULNRC-04883 water which can be added to the refueling pool for decontamination activities in order to prevent diluting the refueling pool boron concentration below TS limits.

In an associated change, TS 3.3.9 REQUIRED ACTIONS for CONDITIONS B and C are also revised to substitute the word "dilution" for "unborated water" and to eliminate reference to specific isolation valves. The revisions make TS 3.3.9 consistent with TS 3.9.2. Specific isolation valves are not required in the Standard Technical Specifications, NUREG- 1431. Removing them from the Specifications and relocating them in the appropriate TS Bases is an administrative only change and is consistent with the Standard Technical Specifications.

Various TS Bases are revised to incorporate the generic use of the term "dilution sources". In addition, specific isolation valves are identified in various TS Bases for isolation of unborated reactor makeup water (associated isolation valves BGVO 178 and BGV0601) as a dilution source, for isolation of BTRS anion resin vessels configured with anion resin (associated isolation valves BGV0039, BGV0043, BGV0051 and BGV0055),

and isolation of CVCS letdown gamma radiation detector SJREOOOI purge line (associated isolation valve SJV0703) as additional dilution sources. The various revised TS Bases include TS Bases 3.3.1, RTS Instrumentation; TS Bases 3.3.9, Boron Dilution Mitigation System; TS Bases 3.4.5, RCS Loops-MODE 3; TS Bases 3.4.6, RCS Loops-MODE 4; TS Bases 3.4.7, RCS Loops-MODE 5, Loops Filled; TS Bases 3.4.8, RCS Loops-MODE 5, Loops Not Filled; TS Bases 3.9.1, Boron Concentration and TS Bases 3.9.2, Unborated Water Source Isolation Valves. Note that plant chemistry controls may require some BTRS anion resin vessels to be configured with resin not intended for boron dilution. In this case, isolation of these anion resin vessels is not required in Mode 6, if administrative controls ensure the resin is preconditioned with borated water that is equal to or greater than the refueling water concentration.

3.0 BACKGROUND

3.1 Boron Dilution Event and Mitigation At Callaway, a design basis accident postulates a CVCS malfunction that results in a decrease in the boron concentration in the RCS - an inadvertent boron dilution event.

The postulated inadvertent boron dilution event is considered for all phases of plant operation.

The Boron Dilution Mitigation System (BDMS) has the primary purpose to mitigate the consequences of the inadvertent addition of unborated primary grade water into the RCS when the plant is in MODES 2 (below P-6 setpoint), 3, 4, and 5. The P-6 setpoint relates to the Intermediate Range Neutron Flux interlock.

The BDMS functions with two channels of source range instrumentation. Each source range channel provides a signal to its microprocessor, which continuously records the counts per minute. The BDMS instrumentation senses abnormal increases in source Page 2 of 11

Attachment 2 ULNRC-04883 range counts per minute (flux rate) and actuates CVCS and refueling water storage tank valves in order to mitigate an inadvertent boron dilution event. Based on abnormal flux multiplication, BDMS sounds an alarm to alert the operator and also automatically initiates valve movement to terminate the dilution and start boration.

Plant specific analyses have demonstrated a wide range of dilution flow rates that are automatically covered by BDMS and the fact that the times involved allow credit for operator action to terminate the inadvertent dilution transient. Because an inadvertent boron dilution would be terminated by Overtemperature AT or by operator action, the BDMS is not required for MODES 1 and 2 (above P-6 setpoint).

TS 3.3.9, "Boron Dilution Mitigation System (BDMS)" ensures the availability of the BDMS by requiring two trains of BDMS instrumentation to be OPERABLE and one loop of RCS to be in operation during MODES 2 (below P-6 setpoint) through 5. The BDMS is not applicable in MODE 6.

In MODE 6, the inadvertent boron dilution is precluded by isolating the unborated water source from the RCS. The unborated water source contemplated is the addition of primary grade water from the reactor makeup water system (RWMS) into the RCS through the reactor makeup portion of the CVCS. Under the current TS 3.9.2, inadvertent dilution via the CVCS blending tee is prevented by administrative controls which isolate the RCS from this potential source of unborated water. Under current TS 3.9.2 the CVCS isolation valves BGVO178 and BGV0601 are locked closed during refueling operations. The Callaway Plant FSAR credits the physical barrier created by valve isolation to defeat the dilution source and preclude the possibility of an inadvertent boron dilution event. Also, in MODE 6, during refueling decontamination activities, per Amendment 97 to the Callaway Plant Operating License, administrative controls limit the volume of unborated water added to the refueling pool in order to prevent diluting the refueling pool below the limits specified in TS LCO 3.9.1. The administrative controls are discussed in TS Bases 3.9.1, APPLICABLE SAFETY ANALYSES.

3.2 Additional Dilution Sources Identified Callaway Plant has performed a review of plant systems and evaluated other potential dilution sources from primary system resin beds and other potential dilution paths for reactor makeup water to enter the RCS. As a result, additional dilution sources have been identified and are discussed below.

CVCS and BTRS The CVCS and its subsystem the BTRS are designed to vary the RCS boron concentration to compensate for xenon transients and other reactivity changes which occur when the reactor power changes during load following. Although the primary function is to compensate for xenon transients during load follow, the BTRS is also used to handle boron changes during other modes of plant operation: startups and shutdown.

The letdown flow from the RCS to the CVCS may be diverted to the BTRS when boron Page 3 of 11

Attachment 2 ULNRC-04883 concentration changes are desired. After processing by the BTRS, the stream is returned to the letdown flow path.

Prior to the proposed amendment, the effect of the BTRS had been overlooked as a possible source of boron dilution. Administrative controls taken by Callaway Plant to isolate the potential RCS dilution source in Mode 6 did not include consideration of the BTRS as a dilution source. The CVCS cation resin bed location allows a portion of the BTRS to be used for normal operations and for RCS clean-up. As a dilution source the BTRS could potentially remove boron from the CVCS stream using the BTRS ion exchange capability prior to return to the RCS. The risk of an inadvertent boron dilution via the BTRS is related to the potential for the anion resin, contained in BTRS anion resin vessels, to dilute the RCS boron concentration as a result of equipment failure or human error. Depending on the condition of the anion resin, operation of the BTRS could equate to diluted borated water or to a worst-case pure water addition into the RCS.

Under the revised TS 3.9.2, deliberate steps are required to isolate the BTRS vessels containing anion resin, when necessary, to avoid an inadvertent boron dilution event in Mode 6. Should the BDMS be unavailable in higher modes of plant operation, then the BTRS vessels containing anion resin would be secured closed under administrative controls.

Flushing CVCS Letdown Gamma Radiation Detector SJRE001 The effect of purging the CVCS letdown gamma radiation detector SJREOO1, by flushing the detector with unborated reactor makeup water, raises concern for a potential dilution path to the CVCS volume control tank (VCT) and the reactor coolant system. Based on plant experience, the detector SJREOOI often becomes fouled with boric acid, causing it to become plugged and resulting in an intolerable increase in the detector's background gamma radiation. Whenever this occurred in the past, the detector was routinely disassembled and decontaminated at the expense of personnel dose and time. A plant modification will be implemented to use existing piping to flush the detector with unborated reactor makeup water.

Although flushing the detector with unborated reactor makeup water is effective, the activity creates a dilution source via the purge line discharge to the VCT. Nuclear sampling system valve SJV0703 isolates the reactor makeup water supply used to purge detector SJREOO1. Because flushing the detector is not a requirement in MODE 6, valve SJV0703 may be secured closed to prevent the potential dilution path. Capability to flush the detector may be necessary at higher modes of operation, however, the flushing activity would be covered by the BDMS. In the event the BDMS is unavailable, the valve SJV0703 would be secured closed under administrative controls.

Under the revised TS 3.9.2, securing valve SJV0703 closed precludes the flushing activity and the possibility of the dilution event. Based on plant experience, a need to flush the detector during refueling activities is unlikely. In addition, if the BDMS should become unavailable in other plant modes, then purging the detector would be precluded Page 4 of 11

Attachment 2 ULNRC-04883 under administrative controls until BDMS would become available. The requirement to secure valve SJV0703 closed assures that the inadvertent dilution event would not occur.

3.3 Summary In Mode 6, current TS 3.9.2 requires deliberate steps to isolate reactor makeup water valves connected to the RCS to prevent inadvertent dilution. Revised TS 3.9.2 requires the same degree of control for the BTRS anion resin vessels and isolation of the purge line for flushing the CVCS letdown gamma radiation detector SJRE001. Deliberate steps are taken to isolate the BTRS vessels containing anion resin and to isolate the purge line for detector SJREOO 1,when necessary, to avoid an inadvertent boron dilution event in Mode 6.

Various TS Bases and FSAR Section 15.4.6 are revised to reflect the potential boron dilution sources. These markups are included as attachments to reflect the proposed changes and are provided for information only.

4.0 TECHNICAL ANALYSIS

The amendment application revises Technical Specifications (TS) 3.9.2, "Unborated Water Source Isolation Valves," to remove the phrase "unborated water" throughout and replace it with the word "dilution", including renaming the TS 3.9.2 "Dilution Source Isolation Valves". In addition, the reference to specific CVCS isolation valves BGVO178 and BGV0601 is deleted and replaced with the generic phrase "dilution source isolation valves". These changes to a generic Specification ensure that all dilution sources and their associated isolation valves are included in the Specification. The revised TS 3.9.2 precludes all inadvertent boron dilution events in Mode 6.

In an associated change, TS 3.3.9 REQUIRED ACTIONS for CONDITIONS B and C are also revised to substitute the word "dilution" for "unborated water" and to eliminate reference to specific isolation valves. The revisions make TS 3.3.9 consistent with TS 3.9.2. Specific isolation valves are not required in the Standard Technical Specifications, NUREG- 1431. Removing them from the Specifications and relocating them in the appropriate TS Bases is an administrative only change and is consistent with the Standard Technical Specifications.

In MODE 6, the inadvertent dilution event is avoided when TS 3.9.2 requirements are met. As stated in the Callaway FSAR, Section 15.4.6, inadvertent boron dilution via the CVCS blending tee is prevented by administrative controls which isolate the RCS from potential sources of unborated water. Under current TS 3.9.2 and plant administrative controls, the isolation valves BGVO178 and BGV0601 in the CVCS are locked closed during refueling operations to defeat a dilution source.

However, current TS 3.9.2 does not include consideration of the BTRS vessels as potential dilution source. Based on these omissions, the possibility exists for the Page 5 of I1

Attachment 2 ULNRC-04883 occurrence of an inadvertent boron dilution event. Plant compensatory actions have been taken to revise plant administrative procedures to include isolation of the BTRS anion vessels, if needed to avoid a boron dilution event. Procedural guidance requires flushing borated water through the resin beds and subsequent testing of the effluent prior to placing the vessel in service. The revised TS 3.9.2, "Dilution Source Isolation Valves",

will ensure that the BTRS anion resin vessels are isolated in MODE 6, if required.

Further evaluations were conducted to determine the risk of inadvertent boron dilution events from other primary system resin beds. In all cases the resin beds are borated prior to service to match the influent stream concentration. Plant procedures govern these evolutions and implement the administrative controls important to reactivity management.

Current TS 3.9.2 also does not consider flushing the CVCS letdown gamma radiation detector SJRE001 with unborated reactor makeup water in Mode 6 as a potential dilution source. Valve SJV0703 isolates the reactor makeup water supply used to purge the detector SJREOO1. During a purge cycle the unborated reactor makeup purge water flushes through the detector and discharges to the VCT. Plant procedures have been revised so that administrative controls are placed to isolate valve SJV0703 during refueling activities. This will preclude the flushing activity and a potential boron dilution event in MODE 6. Flushing the detector in higher modes of plant operation is covered by the BDMS. Should the BDMS become unavailable, the valve SJV0703 is secured closed under administrative controls. The flushing activity is precluded as well as a potential boron dilution event.

Based on a review of plant systems and an evaluation of other potential dilution sources from primary system resin beds, and other potential dilution paths for reactor makeup water to enter the RCS, there are no other "overlooked" unborated water systems connected to the RCS that could become a credible potential dilution source.

Recognizing that the BTRS anion resin vessels and flushing the CVCS letdown gamma radiation detector SJRE001 are potential boron dilution sources does not alter the original FSAR analysis, conclusion, and consequences evaluated for the inadvertent boron dilution event during MODE 6. The proposed changes are acceptable and the revised administrative controls assure that TS 3.3.9 and TS 3.9.2 requirements are met.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration AmerenUE has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92(c) as discussed below:

Page 6 of 11

Attachment 2 ULNRC-04883 Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes do not involve a significant increase in the probability or consequences of an inadvertent boron dilution accident by isolating the BTRS anion resin vessels in MODE 6 or by isolating the purge line for detector SJREOOI during flushing activities in MODE 6. By recognizing these potential dilution sources and by making TS 3.3.9 and TS 3.9.2 more generic for consideration of all potential dilution sources, plant administrative controls are revised such that the plant is put in a safer condition than before. Specific isolation valves are removed from TS 3.3.9 and TS 3.9.2. They are relocated from the Specifications to the appropriate TS Bases. This is an administrative only change and is consistent with the Standard Technical Specification, NUREG-143 1.

Allowing a dilution source path to be unisolated under administrative controls, described in TS Bases 3.9.1 during refueling decontamination activities, is acceptable as allowed by Amendment 97 to the Callaway Operating License and does not involve a significant increase in the probability or consequences of an inadvertent boron dilution accident.

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

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

Response: No The proposed changes do not create the possibility of a new or different kind of accident.

Although other potential dilution sources are identified for administrative control, the evaluation of a MODE 6 dilution event remains unchanged. Isolating the BTRS anion vessels or isolating the purge line for detector SJREOO1 during flushing activities in MODE 6 and making TS 3.3.9 and TS 3.9.2 more generic does not impact the operability of any safety related equipment required for plant operation. No new equipment will be added and no new limiting single failures are created. The plant will continue to be operated within the envelope of the existing safety analysis. In addition specific isolation valves are removed from TS 3.3.9 and TS 3.9.2. They are relocated from the Specifications to the appropriate TS Bases. This is an administrative only change and is consistent with the Standard Technical Specification, NUREG- 143 1. Allowing a dilution source path to be unisolated under administrative controls, described in TS Bases 3.9.1 during refueling decontamination activities, is acceptable as allowed by Amendment 97 to the Callaway Operating License and does not create the possibility of a new or different kind of inadvertent boron dilution accident.

Therefore, the proposed changes do not create a new or different kind of accident from any accident previously evaluated.

Page 7 of 11

Attachment 2 ULNRC-04883

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

Response: No The proposed changes do not reduce the margin of safety. Although other potential dilution sources are identified for administrative control and TS 3.3.9 and TS 3.9.2 are made more generic for consideration of all potential dilution sources, the evaluated margin of safety for a dilution event in MODE 6 remains the same. Recognition of other potential dilution sources, isolation of the BTRS anion resin beds and the purge line for detector SJREOO I during flushing activities in MODE 6, places the plant in a safer condition than before. In addition specific isolation valves are removed from TS 3.3.9 and TS 3.9.2. They are relocated from the Specifications to the appropriate TS Bases.

This is an administrative only change and is consistent with the Standard Technical Specification, NUREG-1431. Finally, allowing a dilution source path to be unisolated under administrative controls, described in TS Bases 3.9.1 during refueling decontamination activities, is acceptable as allowed by Amendment 97 to the Callaway Operating License and does not involve a significant reduction in a margin of safety due to an inadvertent boron dilution accident.

Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Based on the above evaluations, AmerenUE concludes that the activities associated with the above described changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92 and accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatorv Requirements/Criteria The regulatory basis for TS 3.9.2, discussed in Callaway FSAR Section 15.4.6, is to ensure that an uncontrolled boron dilution transient will not occur in MODE 6.

Inadvertent dilution via the CVCS blending tee is prevented by administrative controls which isolate the RCS from potential sources of unborated water. Valves BGV0178 and BGV0601 in the CVCS are locked closed during refueling operations, creating physical barriers, via valve isolation, to defeat a dilution source and preclude the possibility of an inadvertent boron dilution event.

NUREG-0800, "U. S. NRC Standard Review Plan," Section 15.4.6, provides guidance to the NRC staff for the review and evaluation of system design features and plant procedures provided for the mitigation of Chemical and Volume Control System malfunctions that result in a decrease in boron concentration in the RCS.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 10, "Reactor Design,"

requires that the RCS is provided with appropriate margin to assure that specified Page 8 of 11

Attachment 2 ULNRC-04883 acceptable fuel design limits are not exceeded during normal operations including anticipated operational occurrences.

GDC 15, "Reactor Coolant System Design," assures the RCS and its associated auxiliaries are provided with appropriate margin to assure that the pressure boundary will not be breeched during normal operations including anticipated operational occurrences.

GDC 26, "Reactivity Control System Redundancy and Capability," relates to the reliable control of reactivity changes to assure that specified acceptable fuel design limits are not exceeded, including anticipated operational occurrences. This is accomplished by assuring that appropriate margin for malfunctions, such as stuck rods, are accounted for.

The applicable regulatory requirements and criteria must be satisfied for all conditions of plant operation. As discussed above, in MODES 1 and 2 (above P-6 setpoint) an inadvertent boron dilution event would be terminated by Overtemperature AT or by operator action. In MODES 2 (below P-6 setpoint) or in MODES 3 through 5 adherence to TS 3.3.9, "Boron Dilution Mitigation System (BDMS)", would terminate an inadvertent boron dilution event.

As discussed in the sections above, the proposed changes and associated administrative controls assure that the applicable regulatory requirements and criteria are satisfied in MODE 6 of plant operation. Adherence to revised TS 3.9.2, "Dilution Source Isolation Valves" would preclude an inadvertent boron dilution event in MODE 6. In the revised TS 3.3.9 and TS 3.9.2, based on generic requirements, all potential dilution sources are considered. Specifically, inadvertent dilution via the BTRS is addressed by requiring controls which include isolation of the BTRS anion resin beds as potential sources for diluted borated or unborated water.

Providing isolation of valves associated with dilution sources, specifically those affected valves in the CVCS, associated with reactor makeup water and the BTRS, during refueling operations, creates physical barriers needed to defeat a potential boron dilution source. This accounts for any potential operational malfunction and precludes the possibility of an inadvertent boron dilution event.

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.

Page 9 of 1I

Attachment 2 ULNRC-04883

6.0 ENVIRONMENTAL CONSIDERATION

10 CFR 51.22(b) specifies the criteria for categorical exclusion from the requirements for a specific environmental assessment per 10 CFR 51.21. This amendment request meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

AmerenUE has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational gamma radiation exposure. As demonstrated above the amendment involves "no significant hazards consideration".

The requested amendment does not change the facility and does not involve any change in manner of operation of any plant systems. The requested amendment does not increase the gamma radiation dose resulting from the operation of any plant system.

Furthermore, implementation of the proposed change does not contribute to occupational gamma radiation exposure.

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 PRECEDENTS There are no precedents for the proposed amendment.

8.0 REFERENCES

8.1 FSAR Section 15.4.6, "Chemical and Volume Control System Malfunction that Results in a Decrease in the Boron Concentration in the Reactor Coolant System."

8.2 NUREG-0800, Standard Review Plan, Section 15.4.6, Rev. 1,July 1981.

8.3 FSAR Section 9.3.4., "Chemical and Volume Control System."

8.4 FSAR Section 9.3.4.2.1.4, "Boron Thermal Regeneration System."

8.5 TS and Bases 3.3.9, "Boron Dilution Mitigation System (BDMS)."

8.6 TS and Bases 3.9.2, "Unborated Water Source Isolation Valves."

8.7 TS and Bases 3.3.1,"RTS Instrumentation".

8.8 TS and Bases 3.4.5, "RCS Loops-MODE 3".

Page 10 ofI1

Attachment 2 ULNRC-04883 8.9 TS and Bases 3.4.6, "RCS Loops-MODE 4".

8.10 TS and Bases 3.4.7, "RCS Loops-MODE 5, Loops Filled".

8.11 TS and Bases 3.4.8, "RCS Loops-MODE 5, Loops Not Filled".

8.12 Standard Technical Specifications, NUREG-1431.

Page 11 of 11

ULNRC- 04883 ATTACHMENT 3 MARKUP OF TECHNICAL SPECIFICATION PAGES

BDMS 3.3.9 ACTIONS B.2 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C. No RCS loop 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months CALLAWAY PANT 3.3-71 Amendment No. 133

bsou soation Valves 3.9 REF EQPERATlONS GI \

l 9. 2So rce Isolation Valves LCO 3.9.2 Each valve used to isolatsouece shall be secured in the dosed position.

OL4 I APPUCABILITY: MODE 6.

ACTIONS

\ Separate Condition entry is allowed for ea oce isolation valve.

REQUIRED ACTION COMPLETION ILME CONDITION A. N NOTE A-1 Suspend CORE Immediately Required Action A.3 must ALTERATIONS.

be completed whenever Condition A is entered. AND One or more valves not A.2 Initiate actions to secure Immediately secured in dosed position. valve in dosed position.

AND A.3 Perform SR 3.9.1.1. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SU ILLANCE REQUIREMENTS SURVEILLANCE FREQUE Y SR 3 .1 Verify each valve that isol 31 da source ssecured in the cosed d pos on./

CALLAWAY PLANT\ A Amendment No33 No. 133

OL#1238 INSERT A

-a------a-----------NOTE---------a-----

Dilution source path valves may be unisolated, as required during refieling decontamination activities, under administrative controls.

ULNRC- 04883 ATTACHMENT 4 RETYPED MARKUP OF TECHNICAL SPECIFICATION PAGES

BDMS 3.3.9 ACTIONS C CONDITION REQUIRED ACTION COMPLETION B. (continued)

B.2 Perform SR 3.1.1.1. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND B.3.1 Close and secure dilution 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months source isolation valves.

AND B.3.2 Verify dilution source Once per 31 days isolation valves are closed and secured.

C. No RCS loop in operation. C.1 Close and secure dilution 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months source isolation valves.

AND C.2 Verify dilution source Once per 31 days isolation valves are closed and secured.

CALLAWAY PLANT 3.3-71 Amendment No.

Dilution Source Isolation Valves 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Dilution Source Isolation Valves LCO 3.9.2 Each valve used to isolate dilution sources shall be secured in the closed position.

__ _ _ ------ NO TE Dilution source path valves may be unisolated, as required during refueling decontamination activities, under administrative controls APPLICABILITY: MODE 6.

ACTIONS

_ _ ___-----------NC) I = -- _

Separate Condition entry is allowed for each dilution source isolation valve.

CONDITION REQUIRED ACTION COMPLETION A. NOTE---- A.1 Suspend CORE Immediately Required Action A.3 must ALTERATIONS.

be completed whenever Condition A is entered. AND One or more valves not A.2 Initiate actions to secure Immediately secured in closed position. valve in closed position.

AND A.3 Perform SR 3.9.1.1. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Verify each valve that isolates dilution sources is 31 days secured in the closed position.

CALLAWAY PLANT 3.9-3 Amendment No.

ULNRC- 04883 ATTACHMENT 5 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (for information only)

RTS Instrumentation B 3.3.1 BASES ACTIONS G1 and G2 (continued)

Below. P-6, the.Source Range Neuon Flux channels vIl be able to monitor.fthcare power.leVel. TheCom efion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months will allow a

-slow and cortrolled power reduction to less than the P-6 setpoint and

-ta-es

.n--ac:out thles probablty of oocurence of an event during this period thot may require the protection afforded by the NIS Intermediate Range Neutron Flux trp.:-.

-- .-. -Rered Ain (1 as ifid by a Noteo indicate that normal plant

.contol operation fhat ind~iv ladd rrited positive reactivt (ie.,

- -,,temperat r boron coentration fluctuations associated with RCS inventory m nagement or tenperature bornrol) are not precluded by thts

.Acfio. pro-ie4 the DM1itespcifedlthe COLR are met and the

- requirements of LeOs3 i i.5.nd 342 are met.

s ; Z- -5 - - --- N -f~~~~~HI ije. -e 1 . , ^,-.

.-. -. ,-, ...... S- } .....

Condition I applies to one ioperableSource Range Neutron Flux trip a channel Condition, when below P4, the2 NIS in MODE below the P-6 source rangestpint.

performs Withthethe unit in thisand monitoring protection functions. With one of the two channels inoperable. operations involving positive reatiity addiions shall be suspended immediately.

This ill pecudeany power escalation. it only one source range

-. . . .. -- -- channel OPE4E core protection is'.60verely. reduced and any actions 7 . :<. . t-ad poseay tohc must be suspended imeditly.-

.----;- .: . redctiod- n oit by .aHNotek Indicate that normal plant

-. .cotrolxoperatis.U

- thatirdKid y addiited positive reacvy (ie..

.., --a..: - ; .temperature .concentration fluctuaons associated with RCS

- nventoryJnaagemet orternperatureiotdol are not precluded by this Acton-- proviedthe SDMW liits specified in the COLR a requiternent of LOs.3.1.5.3.1.6j and-3-42 are and the

- itical bown concentration ssuions In Section 15.4.6 (ef. 16) are satisfied. - Introductiofreac water ito the RCS from the

--.. :-. Chemical and Volume Cntrol ystem tee is not permittec wn oneJsource rang&eutrons. Ioperae.

CALLAWYPLANT B 3(contin CALLAWAY PLANT B 3.3. 38 e~VISIOf 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOOI must be isolated,

RTS Instrumentation

-B3.3.1 BASES - ; -

ACTIONS J.1-- : :- -- :-

(continued)

Condition J applies to two inoeable Sriri& Range Neutron Flux trip channels when in MODE 2 below the P setpoint or in MODE 3.4. or 5

-with the Rod Control ystem capable of rod withdrawal or one or mor rods not fully hserted. With the unitin this-Condition, below P-6, the NIS souroe rnge performs-the monitoring and protection functions. With both source range channels inoperable, the Reactor Trip Breakers (RTBs) must be openec&imndatety.- ihfthe RTBs open, the core is in a more stable condition.

- . . i . -

.(1, K2.1-, andK, 1(2-2 - -

, , , --- ,',- Condio .KarWies to one ioperable source range channel in MODE'3,

4, or - ihe Rod C trol emc pable of rod withdrawal or one or

. -., . .more ro not fuly inset,e.1 Uihe unit n this Condition, below P4,-

. - -c - . - .the H sourw range perfrmslbe rnonitowg and protection functons.

Ntleot W;ith -- ne, ,' the

' sourceange channels inoperable, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to it toan OPERABLEstatus If the chanel cannot be returned to

.restore an OPE

. LE status,,a iortmust in'itiated within the same 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to, fuly insert all rds. Onqaddilonal hour is allowed to place the Rod Control System in a conditionincapab orod withdrawal-(e.g., by

.e-energizing all C Msby opening the RTBs, or de-energzing the

,, i.,motor genertor (M)sats). OncethfseACTIONS are completed, the core is ina

--...- stable more cndiinT 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore chaniet to , nikhe additonal rto place the.

- .. -* Rod pntrol Sys~er- ahia itiot incaable of rod mh wal, are j-stiied in Reference, oal-pla ct operations at indiidually.

add firmnited psi eiti.e.. tem or boron tion

- - .t lans - a torym Mhg anagement tue

- *"t'

'" ' '@ f c9t met adie}

aret

- -: - - - ioron-4poKhS ~ spcfi

^,pl'$

tceitron nth e COS assumptions inFSAR

-. . - Seon 5.4.6 (Ref. 14) are sisfied. Intducton of reactor makeup

'Water to thp RCS from he :Chemical and Volume Control System mixing tee is oesour"e range neutron flux channel is when operitted

- -oper ble.

in.-. ; , -. -/

LI,L2,a L3

- , - , . Not us .,-

. (continued)

CALLAWAY PLANT B 33.1-39 .Re*;sion 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOO1 must be isolated,

BDMS B 3.3.9 B 3;3 INSTRUMENTATION B 3.3.9 Bo Dilution Mitigation Systm (BDMS)-

- . -;- - - .. , --, - - \ -

BASES . - - -:: --

BACKGROQUNDr; The primary purposeof sthe BDMS is tQ mitifate the consequences of the Inadvertent addition of unborated primary grade water into the Reactor Coolant System (RCS) when the plant Is in MODES 2 (below P-6

SnQtp 3 4 and,; 5-,o

-Th: -- 3D~ MS

--- uies.'tw

' o o source rang istrmentatiii' Ea'ch

-squrc -range chanrel provdes a signal' ismicroprocessor, whi

- - *t 3 t .--

cu ;he, OauminUte..At l the end of eah dis one-Mire-Interval, algowiuim %mp0r1he average counts per

'-,,_- * , ,miutevalue (flux ate)ofthat imiauteinterval wihthe average counts

-.., -, ;inute value for.tfepreviounine; ltninute intervals. Ifthe flux rate during a 1 minute intervalis greater-tha.n equal to 1.7 times the flux rate during any of the prior tine 1 minute Intervals, the BDMS provides a

- ' atto4iateVitigaingaions.,.

.- ;s;

Uon.-dettion of a Iux multiplication byeither ce rane Inst: -,,,,t ,ontrn an alam sund to alet the operator and valve

. -ovementJsautoataicay initiate toterminate the dilution and start boration. alvs that isolate the refuellogiwater storage tank (RWST) are

- ,, ,,-- . ;., -- ,opened to suppty borated water tolthe suctio of the centrifugal charging

--- ps valves which isolat The Vol me Control Tank are dosed to

'terminate the dilution.

APPLICABLE The BDMS senses abnomaltcreaM insource range counts per minute

.SAFETY (flux rate) and actuates VCT and RNSU valves to mitigate the ANALYSESo -letfirl -- i0h ent 'as dini

- - -. .Refm ;.. destsiyaut han a BDMS actuation to

,.-.in .;--;, g ,;;--, ~enes- ;v--, -- kai enIilution vent Ms ODES

.- -- --: - -. 3*, ad S. e MODE Z anss inx ece I credits the source

.rangeremttrp fjjcIionjin cj wtoperator action. The

.optQnof one RCS loop in MO S P46 setpoint). 3i 4, an4, _

provmdes adequate flowixng, prevent stratification, and

-.- -egr-iualr dig;gRS boron concentration -

-, -d--o.'m ,. read~y~chaflgerlte ed with boron reduction

,.v. ,b .,,..wit:I,the tan*i flgation capabiTity of the-BDMS.

. ~ hi -r~coolant ,- ,1opera Inthe above MODES, boron op dilons fuistbe terminatd. ulion so~rces Iso at The boron diluton alysis in these MOrS taes cdit for the m ng volume ass~l d with having at Ist one reactor coolant too in operation.

A- ' (contin CALLAWAY PLANT

BASES APPUCABIUY In MODE 6, a dilution event is precluded by aloeIvc (continued) that isolate the RCS from the potential a WA -; ;to ICO 3.9.2,1 jSource soion TheApplicabltis modified by a Note that allows the boron dilution Jf muftiplicatiom signal to betbloced during reactor startup hi MODE 2 (below P-4.setpoint) and-MODE 3. Blocking the flux multiplication al is acceptable during starlup pbvded the reactor trip breakers closed with the Wtent to withdraw rods for startup. The P-6 interlock a Padkupobloc signal to the source rag flu cuti

!J A01I .C . nou of channel.cause hiperabity is outrigt fallure or drift

--.-.ofateir.bistaorcs~ nmodutesufficent to exceed the tolerance

-s

.. ---; allowed by uit spedfia calibration procedure. Typically, the drift is

- a: fnd A bErma atnd results in -a-delay of,actuation rather than a total loss of function. Thds determination of setpoint drift is generally made dwing the performance of a COT ven thprocess Instrumenttion is set

..up for adjustment to bring i to hiin sOefication. If the Trip Setpoint is

-'.^ 1. ? . - less cqpservatve-than the tolerance speciled by the calibration procedure, the dcannetmust be declared inoperable immediately and the appropriate Condition entered.

A..1 Wthone traW of the BDMS inopable, Required Action A1 requires that

--the inpeFable traln must be.restord to OPERABI E status within

-:-.72 -hours.-In this Cono the . remainig 3DMS train is adequate to

.--.- .~:provideprotectiom.,be 72 batzrt CcIetion-Trne is based on the BDMS Fcm- 02 ls0osis'ent withE ere4afety Feature Actuation System Completion Tmn*;toss fone iedundanttran. Also, the remaining OPERABLE train provides continuous indication of core power.

statu'stotheoperator i;as-an alatructionandsends a signal to both

-trains-.of the BOMS to assure system actuation.

Administrative controls require operator awareness during all reactivity manipulations. These aministrative controls include:

- Reactt managemet briefs of theControl Room Operations Staff (typically conducted at the-beginning of each sh);

- Use-of self-verification techniques by all icefnsed operators performing core reactivity manipulations; (continued)

CALLAWAY PLANT B 33.9-3 Revision 3

INSERT 33.9-A for unborated reactor makeup water (BGVO178 and BGV0601), BTRS vessels configured with anion resin for dilution during normal operation (BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor SJREOOI (SJV0703)

INSERT 3.3.9-AA Chemistry controls may require some BTRS vessels to be configured with resin not.

intended for boron dilution. Isolation of these vessels is not required for MODE 6 if steps are taken to precondition the resin with borated water equal to or greater than the.

refueling concentration.

BDMS B 3.3.9 BASES ACTIONS_ A-1 (continued)

- -. Peer checks forall manipulations during routine operatons and for all positive reactivity additions during transient or off-nomal operations;

-Off-nomalproedures ar aa -b at address reactor makeW c s'st'(RMCS)' Wxl potential loss of thutdown

'dtftions margin (SDM). --

Duing.any andaa rod moon; apooll available ididations

of nuc power. During Rgw n evolutios .

operatoo obetications and alarms fr0 lntle RMCS!

-- : dsign monitoringpr pe steh operation as In

'-SA- I

.6I(Referen-4 t- .4intr-1 oduction of reactor

.',waterint RCSrom the ChditcaI andVolume Control System bdng

't,-;Es -:- "e;-' -*s td -plmf n oBMh S-Wn iinoperable. \

ithtwo trains koperabei or the Requfred Action and assocated

;* . * .. -e.; ripon

p. im~e of Condiion A the inUtal action (Requred mtr-e^

Action B.1) is to suspend all perains Invokng posie reactivty additions immediately. This includes withdrawal of control or shutdown rods and intentional boron dilution.

- RquiredAction B.2 verifies the SDM acooing to SR.3.1.1.1 within 1 hor and once-per-12-hours thv is Ts action is intended to-c-f.irm that no unintended bro ffilution has occurred while the BDMS "was inoprabO, and that .te reqe 8D has been maitained. The

- specified-CoinptetidartmLnetakes

--. etioonsideroton suffcienttWne for the

~~ -...

.-.- -.l'cle-e:-nination of SDM-adithe owncbiSM.b9

,.; *'

LCD 63vr on avahi L 0 e rol Reqt wedAction -3 eq1e'aie

} to ecured toi b§-t~~~~~e Is recognized that two tains BDMS are noperabe the operator wl be aware of the possibility of a borowdilution. and the-4 huCnpleon ime is adequate to complete the requierents of LCO 3.9.2. The recurring 31 day verification of

- * .-*;.- ,-.*: i RequiW Action B.3.2 treS thesealves remain dosed for a

-extended:Condition B entry. - -'

~~~~~~~~~~O

.3 is.\W\

mo/'

-- .--.. Rquired A 3.1 is mod by a Note which permits plant temperature danges provided-the temperature change is accounted for C4 CAUY PLANT 4( inued)

CALLAWAY PIANT B . -4 \ sin

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOOI must be isolated,

BDMS B 3.3.9 BASES ACTIONS B.1, B.2, B.3.1, and B.3.2 (continued) inte calculated SDM. introductionoftemiperature changes, induding

. tempeature -inceases when a positive MT&G-exdsts, must be evaluated to

--.; -.. ensure they do not result in a loss of required SDM.

C. a .22

- . - Condition C is enteredit R loop Jin operation The operaton

-- . -one RCS oop provides adequate flowt ensure mixing, prevent

-- s$tratificatiQn, ld proouce graol t changes during RS

. ^ - corentration

. reductios.-: Thereativity change rate associated wt boron reduction wil, therefore, be within the transient mitigation capablty of the Baron Dilution.Mitigation Syem (BDMS). With no eator coolant -

-. & a~tt b loop in operationilfution source must be Wated. Thebrondiluon ^

analysis takes credit for the mbdng vdkzme associated with having at least-one reacor .coolant loop-in operatin a!9 . cv.'

. -* - G.H ; - -;RjequWiredAction U.1 aquWres thae

'1 ^t V > OoJO\ lsed wic scued.

,he 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion lime- is adequate to T\.;. orm these local valve r

manipulationX ring 31 day verification of Required Action C.2;,

-¢ -. .. - .-.- ;; 8ensurestheev s remailn tlosed aald ec~d for an etended Condition C entry

U.tpRVEIL LAN . Th BDMS tra are subject to a CHANNEL CHECK, valve cosure 1 QUIREMENTS MDE §, COT,- CIfAtN CALIBR AION, anid Response Vmie Te.

In addition, the requirement to verify one RCS loop in operation is siet to periodic surveillance.

. 4*4 Performanceof the CHANNEL CHECK-onceevery 12 hous ensures that

- - - - -.gross failure of source rangeistrumentation has not occurred.

A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channls. It is based on

*- - : - . the assumption that instrument channels moiitong the same parameter should read approximately the same value.. Significant deviations between the two instrument channels-could be an idication of excessive instrument drft in one of the channels or of someing even more serious.

- . : . A CHANNEL CHECK will detect gross channel failure; thus, t Is key to verifying that the instrumentation continues to operate property between each CHANNEL CALIBRATION.

(confinued)

CALLAWAY PLANT 8 3.3.9-5 . . : Revision 3

INSERT 3.3.9-B (for unborated reactor makeup water (BGVO178 and BGV0601), BTRS vessels configured with anion resin for dilution during normal operation (BGV0039, BGV0043, BGV0051, and BGV0055) and the purge line used during flushing of CVCS letdown radiation monitor SJREOO1 (SJV0703)). Chemistry controls may require some BTRS vessels to be configured with resin not intended for boron dilution. Isolation of these vessels is not required for MODE 6 if steps are taken to precondition the resin with borated water equal to or greater than the refueling concentration.

m to v a. I -:,

... a

.'.o ;t.1.

. .w

BDMS B 3.3.9 BASES SURVEILLANCE SR 3.3.9.1 (continued)

REQUIREMENTS

-- - -- Agreemenr teria are deterined by the unit staff based on a

_comblnaion of the channel Instument uncertainties, induding ication

-nd readability. Ifa channel Is outside te criteria, it may be an that the sensor or the signal processing equipmen ed de its limit-

- The Freqt yis based iience that demonstrates

- channelfailure israre. CHANNEL CHECK supplements less fonnal,

-E . .but moref eK,- of c uliduing nomal operational use of the-displays ' ed with the 100required channels.

.SR 3.. .2eqires tia 018 secured and dosed prior to entfntoMODE 5. 3.9. 2 Wursta this alve also be andi '4osed :E Clong O(:V0178 satisfies theboron n accident aysis assumptior that flow orifice BGFOOOIO limits dilutionflow rate to -nomorethan 150Gpin in MODE 5. Ths

-anedernbstratesthat the valve Is cosed through a system

- aown -SR 3.39.2 is mdd by N1te stating tt it is only req to rfonned in MODE S. tlis Note equires that the surveilance

~~~~pefrt priorto entry into MODE 5and every 31days wlein MODE . The 31 day frequency is based on engineering judgment a is

- s!' ' '- c onsdeted reasonablein-vewof othetdMinistratiWe controls that ensde lie valve opening is an ufiike possility/

SR 33.9\

SR 3.3.9.3 quires the performacefaC T e 2 days, to ensure that each of the 1BMS and associated tpoits are fully

. -- tmpefation. '.; ',: ut of t

-, est contact(s) of a channel reay May be ormeby efi the change of state of a single contact of the relay. his c what is an acceptable CHANNEL

-- - - - - : --3PE~lONAL TEST of a relay. -thi is acceptable because all of the otr required contacts. of the relay are verified by other Technical Specifications and non-Technical Specficatins tests at least once per refueing Interval with applicable extenson. This test shaft include

- ;efication at-the bron dilution flixmuiptication setpoint is equal to or less han an increase of 1 times the count rate within a10 minute pe-iod. The 1.7 flux-multiprcation -stpointis a nominal value. SR 3.3.9.3

-ismetif the measured setpoint is ithin a two-skied calibration tolerance

- band on eerside of the nominal-value. SR 3.3.9.3 is modified by a (continued)

CALLAWAY PLANT 3

- B 3.3.9-6 Retefion 3

RCS Loops -IDE 3 BASES 4 X ) -fsS CJ 02-Ol(

APPLICABLE changes during RCS boron conceration redu ons. The reactivity SAFETY change rate associated with bororeduction I, therefore, be within the ANALYSES transient mitigation capability of e Boron DII tion Mitigation System (continued) (BDMS). With no reactor coolant oop in o tion in either MODES 3, or 5. boron dilutions must be term ated ilution sources isolated.

The boron dilution analysis in the MODES takes credit for the mixi volume associated with having at lea one reactor coolant loop in operation. LCO 3.3.9, "Boron Dilution ation System (BDMS contains the requirements for the BDMS.

Failure to provide decay heat removal may result in challenges to a fission product barrier. The RCS loops are part of the primary success path that functions or actuates to prevent or mitigate a Design Basis Accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier.

RCS Loops - MODE 3 satisfy Criterion 3 of I0CFR50-36(c)(2)Qi).

LCO The purpose of this LCO is to require that at least two RCS loops be OPERABLE. In MODE 3 with the Rod Control System capable of rod withdrawal, two RCS loops must be in operation. Two RCS loops are required to be in operation in MODE 3 with the Rod Control System capable of rod withdrawal due to the postulation of a power excursion because of an inadvertent control rod withdrawal. The required number of RCS loops in operation ensures that the Safety Limit criteria will be met for all of the postulated accidents.

When the Rod Control System is not capable of rod withdrawal, only one RCS loop in operation is necessary to ensure removal of decay heat from the core and homogenous boron concentration throughout the RCS. An additional RCS loop is required to be OPERABLE to ensure that redundancy for heat removal is maintained.

The Note permits all RCPs to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. The purpose of the Note is to perform tests that are required to be performed without flow or pump noise. One of these tests is validation of the pump coastdown curve used as input to a number of accident analyses including a loss of flow accident This test is generally performed in MODE 3 during the initial startup testing program, and as such should only be performed once. If, however, changes are made to the RCS that would cause a change to the flow characteristics of the RCS, the input values of the coastdown curve must be revalidated by conducting the test again.

(continued)

CALLAWAY PLANT B 3..2 Revision

RCS Loops - MODE 3 B 3.4.5 BASES

-LO Utilization of the Note is permitted provided the following conditions are (continued) m a conditions imposed by test procedures:

No .- erations peitted that would dilute the RCS boron

- ,nenationf coolant at boron concentrations less than

.--- required tassure SDM of LCO 3.1.1, thereby maintaining the m:a-rgin to criticality. d iof reactor makeup water Into the R* -from the Chern and Volume Control System mbdno tee is ndt h-i. -- RS loop is in operation. Bron dilution wi olmn at bon ettiosess than required to assure the SDM is rnainta is prohibited because a uniform concentration dis throughout the RCS cannot be ensured when in natural culaion;and b.- "Cote-ouettperature is maintained at least OoF below

-satution perature, so that no vapor bubble may form and

.t --i -s.;ipiuse -:-' a natural circulation flow obstruction.

An OP 1-C$ loop consists of one-OPERABLE RCP and one

-OPE\ - GG h accordance with the Steam Generator Tube Sun, ance Pgram, which has the minimum water level specified In 3.4.5.2. An RCP is OPERABLE if it is capable of being powered and Is able to provide forced flow if required.

-A:PPUCAM TY . ln MDE 3, thisLCO ensuresforced circulation of the reactor coolant to

. .emove d.ecay -featfrom the core and to provide proper boron midng.

ie mostringent condition of theLCO that is, two RCS loops OPERABLE and two RCS loops'n operation, applies to MODE 3 with the Rod ControlSystem capable of rod withdrawial. The least stringent

- condltion, thatis, o RCS loops OPERABLE and one RCS loop in

- . -- o:eratio, a. lo lis MODE 3 with the-Rod Control System not capabte of

" ' . '} r-i .: *'t' .s's Wit ; ' e- - *o -

r .? _,. .r- .. ;. . ...

. 4*-*

.S:-; -.---. . -: - Operationin ther MODES iscvered by: -

LCO 3.4.4, RCS Loops -:MODES rnd 2";

LCO 3.4.6, RCS Loops - MODE 4";.

LCO 3.4.7, RCS Loops - MODE 5, Loops Filled";

-tO 3.4.8, RCS Loops - MODE5. Loops. Not Filled";

LCO 3.9.5,Residual Heat Removal (RHR) and Coolant

-.- - -: - Cirulation - High Water Leve (MODE 6); and 1-0 3.9.6, Residual Heat Removat (RHRj and Coolant Circulation - Low Water Lever (MODE 6).

(continued) 3 Re.so

,~ ~

. AAA

...- P.N .... ..

t CALLAWAY PLANT . : ' 34.5-3 Revision 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOO1 must be isolated,

RCS Loops - MODE 3 B 3.4.5 BASES ACTIONS D.1, D.2. and D.3 (cotinued) sets). Al operationt involving Iro.dction of coolant, o the QR(S, with boron cornnration less thainrequired to meet the minimum SDM of LO

-3.1.1 must be aispendd and ction tditore one of the RCS bops to OPERABLFE tatus and operan mist'be ini:iated. Boron diluon re.quires forced citculatiorrfwr propermbng. and defeating the Rod Control System removes the posslxitybf an Inadvertent rod withdrawal.

Suspending the introduction of coolant, Into the RCS, with boron concentraion less than requird to mee tie muimum SDM of LCO 3.11 is required to assure contuddlb operation. With cblant-ddrd without forced circulation, unmixed coolant could be introduced to the core, her oolant added wivh boix m minimun SDM maintains a ta rgin tos operations.

-Introduction of reactor makeup er into the RCS from the Chemical Volume Control System 4 4 4 bd tee is not permittedihen no RCS loop is

ri . ,~rn w~ithj ',

111~ U H lt U, S lli 4't~II l WU ~. mAUlH I A,.JL. E- 4 WrAIu S. I Vl t f-C ' '2 0 OD,.a I....DJ i.i.%F., I JOI Dilution M"itigation System S).- The nmediat. ! Completion ime reflects the importance of antanig operation for eat removal. The action to restore must.be ued until one loop i restored to OPERABLE status and peration.

SURVEILLANCE SR 3.4.5.1 0*0-I 1l0 REQUIREMENTS This SR requires v cation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required loops are in operation. Verifian n may iclude flow rate, temperature, or pmp st monitoring, which Ip ensure that forced flow is providing heat rem The Frequency of 1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is sufficient considering other indicatio and alarms available to operator in the control room to monitor R loop performance.

SR 3.4.5.2 SR 3.4.5.2 requires verification of SG OPERA3IUTY. SG OPERABIlITY is verified by ensuring that the secondary side narrow range water level is 24% for required RCS loops. If the SG secondary side narrow range water level is < 4%, the tubes may become uncovered and the associated.

loop may not be capable of providing the heat sink for removal of the decay heat The 12 hour-Frequency is considered adequate in view of other indications avalable in the control room to alert the operator to a loss of SG lvel.

- ~~~~~~'(continued)

-- -CALLAWAY PLANT B 3.4.5-5 'Revision 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOO1 must be isolated,

RCS Loops - MODE 4.

B 34.6 B 3.4 REACTOR COOIANT SYSTEM (RCS)

B 3.4.6 RS Loops - MODE 4

-:BASES :: ';!

- .BACKGROUNI - In MODE 4, the-prinary ftio of the reacor coolar is the renoval of decay heat and.the transfer of this heat to either the steam generator (SG) secondary side coolant or the component coolg water via the residual heat removal(Re)at exchafigrs. The secondary funcion of

- -- . the feactor colant is to acta a came fbr soluble neuton poison, boric acid.

-The reactor coolant is rcuated through four RGS loops connected in parallel to the reactor vesselpeach loop contaiing an SG, a reactor

. -. - coolant pump (RCP), and appropriate flow, pressure, level; and 7; . 1 .temperature instrumentation forrntrol, protectionj and indication. The

. .. -. .-.-. RCPs circulate the coolant hrough the reactor vessel and SGs at a

-sufficient rate to ensure proper heat transfer and to prevent boric acid

,' ,. .,, ~r.- _-; ;,strafification. -

I. MODE4, eitherRCPs or RHR0oops can be used to provide forced

.....:;-- .. .. - .. .. The intent

circulation..

of this LCO s to provide forced flow from at least one RCP or one RHR loop for decy heat removal and transport The

- :.' . - . . - by one RCP loop or RHR loop is adequate for decay heat

- :.--flow-provided removal. The other intent of this iCO is to require that two paths be

-availableto provide redundancifor decay heat removal.

APPUCABLI In MODE 4, RCS circulation is considered in the determination of SAFETY- the time available for mitigation of the accidental boron dilution event.

... ALYSSES

-The. ortion, fCone RW-nMODR$ 3,4, and 5 provides adequate low o.. ......-

to ensure mixing,. prevent stratfication, and produce gradual reactivity

' -0c ges during RCS bor, co-red reactiuvty.

.i ,

change rate associated with tioron there be tansient mitigation capityof the Bo Dilion Mitigation System (BDM). With no reactor lant loop operation in either MODES 3,4.

or 5, boron dilutions must be termna lution sources Isolated.

The boron dilution analysis in these ODES akes credit for the mbding volume associated wit having at tone ractor coolant loop in pation. LCO 3.3.9, Boron DiU Mitiaton System (BDMS),'

contains the requirements for theB S \SB 1 oa I

RCS Loops - MODE 4 satisfies (continued)

CALLAWAY PLANT B 3.4.6-1 Revison 0

RCS Loops - MODE 4 B 3.4.6 BASES (continued)

LCO The purpose of this LCO is to require that at least two loops be OPERABLE n MODE 4 and that one of these loops be in operation. The LCO allows the two loops that ar required to be OPERABLE to cost of.

any combination of RCS loops and RHR loops. Any one1oop in operation provies enough floW to remove Me decay heat from thebre wt forced

drlati. n additional loop is;required to be OPERABLE topride redundancy for heat rernovaIL - --

--,---.Noe. . permitsall RC or Rwps to be removed fron operation for.

- - hourp pe I he pupose-of the Note is to permit tests that are required to be performed without flow or pump noise. The1 hour time period Is adequate to perform the necessary testing, and operating.

- .. - --- epece has shown hat boron sttifiation is not a problem ding ths re, w-?;, - - * .- Sh period.W nto forCdflOW.-.

of- Note ispermitted provided the following conditions are met

/ : .- : alo tons-imposed by test procedures:

a. No operatio are peFnitted that Would dilute the RCS boron concentration coolant at boron concentrations less than

-equired to a etheSDMoTLCO 3.1.1, thereby maintaining the

-margin lodtic a Introduction of reactor makeup water into the ROSirom C cal and Volume Control System mdng tee is

=

r- not pennmtt hen o RS$ oopris in operation. Boron dilution

'wiih cooantat boro concentrations less than required to assure

-. SDM Is maintl adis prohibW because a uniform the

- oa-01 6 concentration dis ion throughout the RCS cannot be ensured when in naturat claton; and

\-.- Core outlette ture is naintained at least 10F bblow saturation t perature, so that no vapor bubble may-ffind

.s +~--. t, ;.--.-- - . -.-- . . .a te atLldrculati Flow obstruction.

8;. "'

-- 2'-req: -estuat-e ~ ndary sW water temperature of each SG be

-' . : G above each of the RCS-cd teg temperatures before the start of an R=P vith ary RCS cold leg teipemhe 275-F. This restraint Is to pr-event a lowtemperatue over e event due to a thermal transient

-he--- RCP : is started.

-A-; OPERABLE-RCS loop is 'comprised'of -an OPERABLE RCP and an

-- - -.--- OPABLE SG in accoidanewith theSteam GeneratorTube Survefltnre Program, which has the minmum water level specified in SR 3.4.6.2.

- . '.. .. ~~~~~~~~~~~~~~~

.~~~~~~~~~~~~~~~~(otiud fALLAWAY PLANT B 3A.-2 Revision 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOOI must be isolated,

RCS Loops-MODE 4 8 3.4.6 BASES ACTONS .- B.1 and B2 (continued)

Ifnioop s PER3LE or in opelraon, except dwig conitions r-:' ; i- permitted byNe .1n he-.LI 65fiVU- operations nvolvirig Introduction of coolant ito the RCS, with boron concentration less than required to meet the minimurn SDM of LCO 3.1.1 must be suspended and action to restore one R or RiR loop to OPERABLE status and

- operation must be ntiated. Boron don requires forced' draiia~on from

- 1 Ra - ; - -: tlease r---

4t -th t- f R .^~-Y; tRQP pr m sotatkfadvertent cticary can be prevented.

. c- X Su§pehinghe introduction ofcolant, the RCS with boron

-- - .--. concentration less than required metthe minnum SDM of ICO 3.1.1 is required to assure continued safe operation.prti added

- without forted.ciitift.uniedd o6a be in to the core, however coolant added with o onceration mee t

- mimum SDMnaintabis pta in tosubcra operations.

- - Introdution of eaCtorIm eip o itothe RCS from the Chemical

-W:aelonirotSwsttemmbdii is not pemitt when no RCS loop is-op-ration, fiistert with uimredA ctibn0.1 LCO 3.3.9,"Boron .

- ' ;- .-DiMJ~n' Migati n-stem ( MS -The immedia Completion imes

- . - ; -- . - wfl mporfice of faing operation for y heat removal.

T- ahtionto restbre M e coninued until one p is restored to OPERBLE 'stdatus and tribn.

SURVEILLANCE SR 3.4.6.1

-REQUIREMENTS

-iisSR requrres veifi tion every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one RCS or RHR loop

-nratiO'M

-: - 'aon maindulde fldw rate, temperature, or

- -* - i -m sta-us ontori, wch helpVMW-tht forced flow is providi t

remcV mn- * - - Fr - f 42 hooiseuflent consid indications and aa available to the operator in the Iroo to' Sf' 3A.&' *.*..

SR 3S.. 2requis verficaton-of 8G;OPERABIULY SG OPERABILITY

. is verified by ens ththe ecndary side narrow range water level is

- - : -' 24%forreqtiedRCS loops. If t SGzsecondary side.narrow range water eelis <4%,the tubesmay beconmemcovered and the assoiated ioop may not be capable of provling the heat sink necessary for removal of decay heat The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level.

(continued)

CALLAWAY PLANT B 3.4.6-4 Revision 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOO1 must be isolated,

RCS Loops - MODE 5, Loops Filed B 3.4.7 BASES (continued)

APPUCABLE kMODE n 5, RCS crclatin -i corsidered in the determnation of te tire SAFETY available for mitigation of theaccidental boron diution event

- - 'ANALYSES,;- ; ;-

- ---. - - - opeati ofone-RCP in MODES3, 4, and 5provides adequateflow to ensure mig, prevent stratifiatin, and produce gradual reactivity

-changes-:n RCdngroCoconcentration:

ss4; - s * *chanye rate asiaiwf b r i-wltheoebe WU~i transient mitigationcpabilt'of theSonDluonM System

(-.BDMS}.- Wi i-iear~~ 4xpla in o n in either MODES 3,4, or 5, borevdilutions must e ted an uton sources Isolated.

The boron dilution analysis in ikes cdi crODES for Ohe mixing s-- volume-aatiaeitti i at tone rpctor coolant loop in.

.. lf-.t'

.- rai-s

-. . t.tCQ,- D Mgatp System (BDMS),.

!'.-containsiherequirementforeUMS. &4 OI

-. : ;-. - -:RCS Loops -MODE 5{Loops. il ti Critenon 4 of

-. , . .- OICFR50'-O6(c)(. . ' ..

LCO The purpose of this LCO is to requirest one of the RoR be OPERABLE and in operation with an addI alRHR loo PERABLE o-r-two SGs-with secondary side w ranrge wate%. Asshown

. - -. - in Reference 3, anyiiarow range.devel indication above 4% wil ensure the SG tubes are coveed One R loop provides suffident forced

.rculation to perform the safety functios of the reactor coolant dr these conditions. An- dditionaIVWR loop is required to be OPERABLE to meet single failure considerations. However, if the standby RHR loop is

- -pnot (BORAL!Ej an acceptable alternate method is two SGs with their

-ondary-side wide range water evels k66%. Should the operating

-- RHRloo fall, the SG- culd 1 used toemove the decay heat via

-- ? --- - -: - natrl drc-aio - - :;; --.-

i ; . S {:. -. - - - .S-k Note t permits all RHR pumps to be removed from operation 1 hourper

- -* .*-*t -w -'.'81iourperivid.

tti l pti'6e of It to permit tests Vt are reqtdred toeiprb redwhutflrwotpditpnoise. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months time peiod is

. ;:a. T : - ;perfom adequate-to -- the necssaytesting.-and operating experence has shown thatboronstratification Is-ot likelyduring this short period with no forced flow.

- ~-Uthization of Note ipemited oidd the following conditions are

.met, along with any Oter orfiosnmOsed by test procedures:

-4 (continued)

CALLAWAY PLANT I-B-3.4.7-2 Revision 0

RCS Loops - M(DE 5, Loops Filed B 3.4.7 SES (,contnued)

LCO . a. N ore pernitt that wod dutQ; RCS boron (contined) co tron oolant at boroaconcentrations lessihan required to assue SDM o LC0 3.1.1, theby maing the

. * '..-...to .

5maon dii.i- of-reactor makeup water Into the RCS from the Chem Yn oume Control System mibdng tee Is

.-ot. e tl .n operation. dion with coolantat-bon tao l thaness requd to assure

,the DM is is ed because a uniform

( .A-O.IU-7-q . - .......... .;n ;concehirationthroughout the RCS cannot be ensured when In natural

; b. Coroutettdi .ureismanandat least 10F below

--- *.,--..-saturatiote, Sthat nnapnor~ bble may fonrm and p\sslyca-a at ural~

draoflow obstruction.

ma

- Note2-alowsoneHR tobejnop~ableforaperiodofupto 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provid tthe other RHRIoos OPERABLE and in

operation.

\ petits penodc surveillance tests to be perfom on the inoperab oop durig tfh- on6ly hei -if Atestlng is se ad Note 3 requires that these oary ieater temperature of eah SG be

5OOF above each of the RCS cold leg temperatures before the start of a reactor oblatt pump P) with ayCS cold leg temperatures 275-F.

- -~ - --- This restiction.is to preVent a low temper overpressure event due to a -thermal tfansienVwhe:an RCP s staed.

Note-4 pr6SridW s for arideo trajy Ujt rnfnMODE 5 to MODE 4 during a planned-heatup by permitting removal RHR loops from operation when at least Vne RCS Joopis ii etab rg Tis Note provides for the transition to MODE 4 where aiRCS loop -permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

.,i;RHRi" psare OPERABL

-:.-3---V;::; they a pable of beig powered and:

--. - are

-^ abletorodetlow irequir An OPE RABLE SG can perform as a

-heat sink' ianatural druationwhen it an adequate water level and

-t-1 .¢: - -. Jis OPERABLE in accordance ith ftStearm Generator Tube Surveillance Program. ..

-I.-

APPUCABIIUTY - In MQDE ith RCS loops flled. ths .CQ requirei forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron muxng. One loop of RHR prdvides sufficent drCdation for these purposes. However, one additional RHR loop is required to be OPERABLE, or the secondary side wide range water level of at least two SGs is required to be 2 66%.

(continued)

CALIAWAY PLANT B 3.4.7-3 Revision 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOOI must be isolated,

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES (continued) - -

APPLICABILITY Operation in other MODES is covered by:

(continued)

.LCO 3.4.4,-RCS Loops MaaES ard %

-. .O -3.4.5 "RCS Loops - MODE 3I

.. ICO 3.4.Ik -RCS Loops --MODE 4";

LCO 3A.8, -RCS Loops- MODES, Lops Not Filled;

-.LCO 3.9.5, "Residual Heat:Removal (RHR) and Coolant Circulation - igh Water Lever (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Lever (MODE 6).

ACTONS * - idk2 *.;. , - --- 0

_0 - . t s ..:f.%. -Inprbe- - . .tide. _ . ,;

-f one Rf.-Rloopis inoperable and-the prquired SGs have secondary side wide rane water levels-c W6, redundancy for heat removal is losL Action nust be l-tiated. immediately to restore a second RHR loop to OP-RABLE status or to restore the required SG secondary side water-

.' . -...- . -;. . levels. ;;, Either Required ActionA1 or Required Action A.2 wiN restore redudant heat removal paths. The immiecate Completion Tne reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2 lf norP 1R loopis in operation, except during conditions permitted by Notes - and 4, or ifno loop is OPERABLE. an operations involving introUtinof: oolant, into the-RCS, .witboron concentration less than req

,ac . n.

to,;d , the minimum .SEM ,of CO 3.1.1 must be suspended and one!R1R loopto-OPERABLE status and operation must I.

4'revn ;Le.rItet.qrit kfity duringa boron dilution,

' -p - --;. cX rilantiorn,at~je s ~ IRCios~quired to provide proper.*

ml~dng. Suspending the Introduction of coolant, into the RCS, with boron cmwMtaion less than required to-meet the minimum SDM of tOO 3.1.1 is-quired to assure continued safe operation. Whcoolant added dithoct forced circulation, unr~ixed,coolant could be introduced to the core, however coolant added with boron conen eeting the minimum SDM maintains table marg Introduction of reactor makeup water into RCS from the and VOWe Conol System mixing teeiso itt en noR loopis in operation, consistent with Required A n C.10 LO3.3.9,1 Dilution Mitigation System (BDMS)! - intnedlat Comesletion Tes reflect the importance of maintaining ation for at removal.

CALLAWAY PLANT 8 3.4.74 13

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOO1 must be isolated,

RCS Loops - MODE 5, Loops Not Filed B 3.4.8 B 3.4 REACTOR COOLANT SYSTEM (RCS)

- B 3.4.8 RCS Loops - MODE 5. Loops Not Filled BASESI - -

4 I ACKGROUND :In: MODE 5 with the RC ,6ops not filled,-the primary function of the r-eactor-coolant is-t removal of decay heat generated in the fuel, and the

-transfer of this,h6at to te component coolig water via the residual heat

- - .; - -.; . - ... - removal (RHR) hdat exchangers.: .-The steam generators (SGs) are not

-available as a heat sink When-theloops are not tiled. The secondary

.funcon of the r6etorcootantIs.to actas a carierfor the soluble neutron poison, boric acid.. -

-n MODE.5 withloops not filled, only RHR-pumps can be used for coolant circatio.- The numberof pumps in-.Operation can vary to suit the r --- : - - - - .neds- The intent of this L;O

-operational is to provide forced flow from at least-one RH1R pumpfor decay heat removal and transport and to require

- . . that two paths be available to provide redundancy for heat removal.

~..

.-. .APPUI3ABLE --. ,lnMOD&5,x RCS diration is considered n the determination of the time

- SAFETY

.- available. formiftgation of thae.adetal boron dildution event. The flow ANALYSES provided by one RHR loop is adequate for decay heat removal.

Theoperationtofone RCP,.inMODES3,4, and5 e teflow to ensure.iift,: preverd:stratification and uce gradual changes during RCS boron concentra The rea bedutons.

chan e rate .assclatedwithboron r will, therefore, be within *e transient miigation capabirity of Boron Dilution Mitigation System (BDMS). Wdh no reactor. coolaloopin.operation in either MODES 3,4, or 5, borondilutions must bt mated iluion sources isolated.

. . The borq dl o a i #a kes credit for the mbdng

.. . . -ihb .a -leas d 3 ast Zueiractor coolant boop in

- u Mitiga System (BDMS) -

--n{.- '.r.tairen rthe BDMS.

- - - . - - .- ROB loops in MODE 5(1 not filed) satisfies Criterion 4 of 10CFR50.36(c)(2)(i).

-- the purpose of this 1CO is to that at least two RHR loops be

- OPERABLE anzlone of.these l be in operation. An OPERABLE loop

-:. . . - - is one that has the capability of errigheat from the reactor coolant at a controlled rate. Heat cannot be r ved via the RHR System unl forced flow is used. A minimum of one n I ' '

(continued)

.- -CALLAWAY PLANT B 3.4.8-1 Revision 0

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES LCO LCO requirement for one loop nopertion An addinal RHR loop is (continued) required to be OPERABLE to meet single failure considerations.

Note pennits all RHR pumps to be removed from operation f;s; 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

- - The dra an for stopping both RHR punps are to be limitd to situatis j

--.- ther oute tiapirne is shortard core:otet temperture Is

- .: *-- ; -.<. - . - .maWntahed at least F below saturation temperature. The Note p.ro.; borm

-. cdlution I r I DOeqdto 3.t1 ismaintainedordraV

, s than op-opRHforced ratio a- . R.I- flowls stopped. Introduction of rectd

'\. :*,;

- .a. - zo+- < mak er intote .R from-the iCemical and Volume Control

-yste : bdng tee is not pemittwenno

-No U. :tsoteRHRloopto worpe n r do2hou

/-atthe othdloop is OPERABLE -and in operation. its Rhis

- .;-..--. .- --.- :.p isatvella tests to be peformed on the noperable loop *ng

, - the. time wen ttise tests:are.safe-and possible.

capi of proviiiig forced flow to an OPERABLE RHR he xchanger.

* \ - '."'

AnERBL R uR . ar-OPERAE RR oo i cmpisd f n PEABEand if te;?arcaable of red m ad

-h it i - - am mb s~id9 required A;APPUeAdIUY In MOE ith Joops not fied, this LCO requires core heatremoval and

- - .:ntrculation by the RHRSystem.:: -

pblon- -. ;--er MODES is covered by.

--L-CO 3A. 'IRCSLoops - MODES.1 atihd2

-L.0".WO3. ;4.5:'-tLoopsISoos. - MOEDE 3;--

. ~ -s. :K40D-_4 ioos~Fl.

- "; ed

, ~ft,"d't-l &t' W'it

f 'R Coolant t?6-and

-. >CiiUlaton

.;-: -wHighWater Lever (MODE 6); and LCO 3.9.6. Residual Heat Removal (RHR) and Coolant Circulation 6 Water Lever (MODE 6).

The Apr!;abfity Is modified by a Note stating that entry into MODE 5 with RCS loops not filed from MODE 5 with RCS -loops filled is not permitted

WhieLZGG3A.8 s not met Thi Note-spedfies an exception t6-

. . . ~~~~~!w wul'reet*-dr ng:RCS

- 'Q ,t34 wt-'o~dd efmtte

-:-posbitj o eat removal, Whilethe RHR function was degraded.

(continued)

CALLAWAY PLANT . 34.8-2 Revision 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOO1 must be isolated,

RCS Loops - MODE 5, Loops Not Fned

. B 3.4.8 BASES (continued)

AClIONS A1:

Ifonlyone RIloopis OPERABL£,and hioperation, redundancyfor

-ffi.- :.. - . -..-- -RR Ris losLm beitiated tovestore a second loop to

-OP satus. eetion oLE Time eflects the impQanc maintaiing the e tap

-ofi ty of two paths for heat ernoval.

B.1 aidB.2 If no required RHR loops are OPERABLE or in operation, except during coridid pbhrihi i by Noto ,-al 6prioiS. wohbi4i of coolant, Into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.11 must be suspended and action must be Initiated immediately to restore an RHR loop to OPERABLE status and operation. Boron dilution requires forced circulation frorn at least one RCP for proper mbdng so that Inadvertent criticality can be prevented. Suspending the Itroductin of co6lant, into the RCS, With boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe o added with6ut forced circulation, unmied oothe core, however coolant added with qoncentration meeting minimum SDM maintains acce marin to subcritical operations.

Introduction of reactor mak ter into the RCS from the Chemical

-Volume Control System tee is not pernit the RCS loops are not Sled or when no looIs in operation, stent with Required Action C1 oflCO 3.3.9, Boron Dlution itigationSystem N

(BDMS).' The in te Completion Tune re the importance of maintaining operati for heat removal. The acti to restore must continue until one p is restored to OPMABLE status and operation Q1 IM/C1 I AWNC

%A'%04 V L5.ULXVU %A.

00

%JIp %

A-l

.t . U Ic cI , A REQUIREMENTS This SR requires erification evely 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that one loop is in operation.

Verification may dude flow rate. temperature, or pump status monitoring, which ensure that forced flow Is providing heat removal.

The Frequency -ofIhours Issufficient consklering other indications and alarms available to the control room to monitor RHR loop noperator performance.

SR 3.4.8.2 Verification that a second RHR pum Is OPERABLE ensures tht an additional pump can be placed in operation, if needed, to maintain decay (continued)

CALLAWAY PLANT B 3.4.8-3 Revision 3

INSERT A

, BTRS vessels configured with anion resin for dilution during normal operation must be isolated, and the purge line associated with flushing CVCS letdown radiation monitor SJREOOI must be isolated,

Boron Concentration B 3.9.1 BASES BACKGROUND and assist in maintaining uniform boron concentrations in the RCS and

-(continued) the refieling pool above the LCO limits. Administrative controls will limit the volume of unborated water that can be added to the refueling pool for decontamination activities in order to prevent diluting the refueling pool below the specified limits (Ref. 3).

APPLICABLE The boron concentration LCO limits are based on the core reactivity at SAFETY the beginning of each fuel cycle (the end of refueling) and includes an ANALYSES uncertainty allowance.

The required boron concentration and the plant refueling procedures that verify the correct fuel loading plan (including full core mapping) ensure that the kff of the core will remain

0.95 during the ref ration.

Hence, at least a 5% Ak/k margin of safety is esta ed during re Safety analyses assume a B-10 abundance o .9 atom % (Ref.e .

Administrative controls ensure that the re ty insertion from the reactor coolant system and the refueling pa eflects this assumption.

During refueling, the water vol ie in the refueling pool and the reactor vessel form a single mass. a result, the soluble boron concentration is relatively the same in each these volumes having direct access to the reactor vessel. /; I ur1GssCM 1 ij -

The limiting boron dilutio accident an ed occurs in MODE 5 (Ref. 2).

Boron dilution accidents re precluden MODE 6 by isolating potential dilution flow paths. See L 3.9.2, t e 6urce Isolation Valves." Unacceptable dii ion from reue ing pool decontamination activities is precluded by e following (Ref. 3):

1. The maximum al wable amount of unborated reactor makeup water that may added to the r fueling pool for decontamina' n activities is calculat or eac ef eling and will not cause th refueling pool boron co atio to fall below the LCO Iid;.

This maximum allowable volume based on initial pool ron concentration and one-half the RC olume at mid

2. The refueling pool is drained to approxi yone foot above the reactor cavity seal/shield ring. The refueling pool is then drained via the reactor coolant drain tank pumps or other available means (excluding the RHR system) until the level is below the seal/shield ring. This directs potentially diluted water at the top of the pool away from the reactor vessel and core.

(continued!)l CALLAWAY PLANT B 3.9.1-2 Revision

Soure Isolation Valves B 3.9.2 3.9 REFUELING OPERATIONS B 3.9.our e Isolation Valves SOL)

BASES BACKGROUND During MODE 6 operations, aisolation valves

/ that are connected to the Reactor Ol lo Coolant System (RCS) must be closed to prevent unplanned boron dilution of the reactor coolant. The isolation valves G Admistrat will limit the volume of unborated water that can be added to the refueling pool for decontamination activities in order to.

przevent dilutin the refueling pool and RCS below the s iecired (Ref. 3). ( o* . 9e39Il c&3 APPLICABLE The possibility of an inadvertent boron dil ev t (Ref. 1) occurring SAFETY during MODE 6 refueling operations is ad b adherence to this ANALYSES LCO, which requires that potential dil n sources isolated. Closing the required valves during refuei prevtsIheflow ttions of unborated water to the filled port of the RCS. The alves are used to sple _bemtedvW source These valves have potential to DiruTwoA4 indietly allow dilution of the RCS boron concentraion MODE 6. By

! isola ingbertedwal sources, a safety analysis for uncontrolled ALL ->I4TK boronddcioon accideot in rdance with the Standard Mview Plin (Ref. 2) is not required for MODE 6.

The RCS boron concentration satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ui). f Son 'A

\0 Ths00LCO requires that flow paths via b Isolated to prevent reduction n 5MW. D APPLICABILITY In MODE 6, this LCO Is applicable to preve i dilution event by ensuring isolation of all soffis ofo the RCS.

For all other MODES, the boron dilution accident was analyzed and was found to be capable of being mitigated

?-connued)

) CALLAWAY PLANT . B 3.9.2-1 Revision 0

INSERT 1 for unborated reactor makeup water (BGVO1 78 and BGV060 1), BTRS vessels configured with anion resin for dilution during normal operation (BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor SJRE001 (SJV0703)

INSERT 1A Chemistry controls may require some BTRS vessels to be configured with resin not intended for boron dilution. Isolation of these vessels is not required for MODE 6 if steps are takento-precondition the resin with borated water equal to or greater than the refueling concentration.

INSERT 2 unborated reactor makeup water (BGV01 78 and BGV0601), BTRS vessels configured with anion resin for dilution during normal operation (BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor SJREOO1 (SJV0703)

INSERT 2A Chemistry controls may require some BTRS vessels to be configured with resin not intended for boron dilution. Isolation of these vessels is not required for MODE 6 if steps are taken to precondition the resin with borated water equal to or greater than the refueling concentration.

TSB CN 02-016 INSERT 2B The LCO is modified by a Note allowing dilution source path valves to be unisolated, as required during refueling decontamination activities, under administrative controls.

During refueling activities, it may be necessary for a dilution source to be unisolated.

Based on Reference 3, administrative controls are used to limit the volume of unborated water which can be added to the refueling pool for decontamination activities in order to prevent diluting the refueling pool boron concentration below TS limits. The administrative controls are identified in the Applicable Safety Analysis Bases for LCO 3.9.1, "Boron Concentration."

The following valves are excluded from the LCO Note: BGVO 178, BGV0601, BGV0039, BGV0043, BGV0051, BGV0055 and SJV0703. The following valves are included under the LCO Note: BLVO078, BLVO079 and BLVO055.

S=ourceI oValves ID~11-14T~11 tloI B 3.9.2 BASES (continued)

ACTIONS The ACTIONS table has been modified by a Note that allows separa e Condition entry for each source Isolation valve.

A/A Continuation of CORE ALTERATIONS is contingent upon maintainng¢ unit in compilance with is LCO. With any valve used to Isolate

%AT% sare s not secured in the cosed position, all operati CORE ALTERATIONS must be suspended kImediatey. The Completion lune of "immediately for performance of Required Action shalt not preclude completion of movement of a component to a safe k ~~~~position.,.I -

Condition A has been modified by a Note to ire that Required Action A3 be completed whenever Condit entered.

0)

{A.2 Preventing inadvertent dilution of the reactor coolant boron conce n is dependent on maintaining the tion valves U o. So6 8 ~ ~ jj~~ secuec red dosed. Secuning the valves iH dosed position, under administrative controls, ensures that the valves ares not inadvertently opened. The Completion Tkme of "imnediately" requires an operator to initiate actions to dose an open valve and secure the isolation valve in the dosed position immediately. Once actions are initiated, they must be continued until the valves are secured in the closed.

position.

A.3 Due to the potential of having diluted the boron concentration of reactor coolant, SR 3.9.1.1 (erfication of boron concentra ust be performed whenever Condition A Is entered to demonstrate t th required boron concentration exists. The Completion lime hous Iss4 sufficient to obtain and analyze a reactor coolant sampler boron concentration. : -

(continued)

CALLAWAY PLANT B 3.9.2-2 Revision 1

a o ation Valves BASES (continued)

SURVEILLANCE SR 3.9.2.1 'a' REQUIREMENTS _

ZEE orlvj are to be edclosedto isolate (ossible dilution ths.iThe likelihood of a s nificant reduction n the boron concentration during MODE 6 operat'ns is remote due to the large mass of borated water in the refueling pool and the fact that aI *

\S ourc sources are isolated, precluding a dilution. The boron concentration is checked every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months during MODE 6 under SR 3.9.1.1. This Surveillance demonstrates that the valves are closed 5itCAi through a system walkdown. The 31 day Frequency is based on engineering judgment and is considered reasonable in view of othe administrative controls that will ensure that the valve opening Is unlikely possibility.

RF ENCES 1. FSAR, Section 15.4.6.

NUREG-0800, Section 15.4.6.

3. Amendment 97 to Facility Operating License No. NPF-30, Callaway Unit 1, dated March 31, 1995.

CALLAWAY PLANT B 3.9.2-3 Revision 0

INSERT 3 Isolation valves for unborated reactor makeup water (BGV0178 and BGV0601), BTRS vessels configured with anion resin for dilution during normal operation (BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor SJREOO1 (SJV0703)

INSERT 3A Chemistry controls may require some BTRS vessels to be configured with resin not intended for boron dilution. Isolation of these vessels is not required for MODE 6 if steps are taken to precondition the resin with borated water equal to or greater than the refueling concentration.

ULNRC-04883, Proposed Revision to Technical Specification (TS) 3.9.2, Unborated Water Source Isolation Valves, to Revise & Rename Specification 3.9.2, Dilution Source Isolation Valves & Associated Revision to TS 3.3.9, Boron Dilution...

Contents

Text

Attachment:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

1.0 INTRODUCTION

2.0 DESCRIPTION

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

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ULNRC-04883, Proposed Revision to Technical Specification (TS) 3.9.2, Unborated Water Source Isolation Valves, to Revise & Rename Specification 3.9.2, Dilution Source Isolation Valves & Associated Revision to TS 3.3.9, Boron Dilution...

Text

Attachment:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

1.0 INTRODUCTION

2.0 DESCRIPTION

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

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