ULNRC-05345, Proposed Revision to Technical Specification 3.9.2 Unborated Water Source Isolation Valves and Associated Revisions to Technical Specification 3.3.9 Boron Dilution Mitigation System (Bdms).

Proposed Revision to Technical Specification 3.9.2 Unborated Water Source Isolation Valves and Associated Revisions to Technical Specification 3.3.9 Boron Dilution Mitigation System (Bdms).

ML063280186
Person / Time
Site:	Callaway
Issue date:	11/17/2006
From:	Fitzgerald D AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05345
Download: ML063280186 (67)

Text

AmerenUE P0 Box 620 CallawayPlant Fulton, MO 65251 November 17,2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen: ULNRC-05345 Revised wAmeren DOCKET NUMBER 50-483 CALLAWAY PLANT UiE UNION ELECTRIC COMPANY PROPOSED REVISION TO TECHNICAL SPECIFICATION 3.9.2 "UNBORATED WATER SOURCE ISOLATION VALVES" AND ASSOCIATED REVISIONS TO TECHNICAL SPECIFICATION 3.3.9 "BORON DILUTION MITIGATION SYSTEM (BDMS)"

(LICENSE AMENDMENT REQUEST OL 1238)

Reference:

ULNRC-05269, March 28,2006 Pursuant to 10 CFR 50.90, AmerenUE, in the above referenced submittal letter requested an amendment to the Facility Operating License No. NPF-30 for Callaway Plant. As described in the referenced letter, the proposed revisions to Technical Specification (TS) 3.3.9, Boron Dilution Mitigation System (BDMS) and TS 3.9.2, Unborated Water Source Isolation Valves, removed specific valve numbers from the TS to the TS Bases; incorporated exception Notes on TS 3.3.9 Required Actions B.3.1, B.3.2, C.1, and C.2; and incorporated exception Notes on TS 3.9.2 LCO.

During the NRC review, several e-mails were transmitted and tele-conferences were held between AmerenUE personnel and NRC Staff to discuss the proposed license amendment request. In response, AmerenUE has revised the originally proposed TS and TS Bases markups for TS 3.3.9 and TS 3.9.2. The revisions incorporate NRC comments and resolutions from the discussions with the NRC Staff. Specifically, the proposed exception Notes to TS 3.3.9, Required Actions B.3.1, B.3.2, C. 1, and C.2 are eliminated. The Notes would have allowed an exception for unborated water source isolation valves to be unisolated, under administrative controls, for certain plant activities conducted during MODES 2 (below P-6 interlock), 3, 4 and 5. These exceptions are deemed unacceptable during Modes greater than MODE 6.

Aoo I a subsidiaryofAmeren Corporation

ULNRC-05345 November 17,2006 Page 2 The exception Notes originally proposed for TS 3.9.2 LCO, would permit plant activities, performed under administrative controls, that are acceptable during MODE 6. However, the originally proposed Notes are now covered under a single generic exception Note to TS 3.9.2 LCO. The revised exception Note provides a generic statement that permits unborated water sources to be unsiolated under administrative controls for planned boron dilution evolutions.

The revised TS 3.3.9 and TS 3.9.2 and their Bases are included as attachments to this letter. Note that included in the TS Bases markups are the markups for TS 3.3.9 Condition A Bases and TS 3.3.1 Condition I and Condition K Bases as originally provided to the NRC for information.

As discussed above, essential information is provided in attachments to this letter. Attachment 1 provides NRC requests for additional information and the AmerenUE responses. Attachment 2 provides the revised TS markups. provides the retyped TS pages. Attachment 4 provides the revised TS Bases pages marked-up to show the proposed Bases changes (for information only).

This letter revises identified actions committed to by AmerenUE in the submittal. Other statements in this letter are provided for information purposes and are not considered to be commitments. A summary of the regulatory commitments are provided in Attachment 5.

The Callaway Plant Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the attached revised TS and TS Bases markups. Note that these revisions result in an amendment request that has a more limited scope than originally proposed. As such, the original submittal evaluations continue to address these revisions and do not alter original evaluations that the amendment application involves no significant hazards consideration as determined per 10 CFR 50.92, and that pursuant to 10 CFR 51.22(b) no environmental assessment should be required to be prepared in connection with the issuance of this amendment.

In keeping with the original license amendment request, AmerenUE respectfully requests approval of the proposed license amendment by December 31, 2006. The approved amendment will be implemented within 90 days of approval.

• ~- -j ULNRC-05345 November 17,2006 Page 3 Pursuant to 10 CFR 50.91(b)(1), AmerenUE is providing the State of Missouri with a copy of this letter and its attachments.

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

Sincerely, Executed on: November 17, 2006 Dave T. Fitzgerald Manager, Regulatory Affairs Attachments: 1) NRC Requests for Additional Information and AmerenUE Responses

2) Revised Markup of Technical Specification pages

3) Retyped Technical Specification pages

4) Revised Markup of Technical Specification Bases pages (For information only)

5) Summary of Regulatory Commitments

ULNRC-05345 November 17, 2006 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. Mallett 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 O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102

ULNRC-05345 November 17,2006 Page 5 bcc: C. D. Naslund A. C. Heflin T. E. Herrmann L. E. Thibault D. T. Fitzgerald G. A. Hughes D. E. Shafer (470) (2 copies)

S. L. Gallagher (100)

C. J. Struttmann (NSRB)

K. A. Mills D. J. Walker A160.0761 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrecreceives ALL attachments as long as they are non-safeguards andpublic disclosed).

Send the following without attachments:

Ms. Diane M. Hooper Mr. Dennis Buschbaum Supervisor, Licensing TXU Power WCNOC Comanche Peak SES P.O. Box 411 P.O. Box 1002 Burlington, KS 66839 Glen Rose, TX 76043 Mr. Scott Bauer Mr. Stan Ketelsen Regulatory Affairs Manager, Regulatory Services Palo Verde NGS Pacific Gas & Electric P.O. Box 52034, Mail Stop 104/5/536 Mail Station 7636 P.O. Box 56 Phoenix, AZ 85072-2034 Avila Beach, CA 93424 Mr. Scott Head Mr. John O'Neill Supervisor, Licensing Pillsbury Winthrop Shaw Pittman LLP South Texas Project NOC 2300 N. Street N.W.

Mail Code N5014 Washington, DC 20037 P.O. Box 289 Wadsworth, TX 77483

At ULNRC-05345 ATTACHMENT 1 NRC REQUESTS FOR ADDITIONAL INFORMATION AND AMERENUE RESPONSES

A NRC REQUEST FOR ADDITIONAL INFORMATION TRANSMITTED VIA E-MAIL DATED JULY 10, 2006 In reviewing the AmerenUE application dated March 28, 2006 (ULNRC-05269), which proposes revisions to Technical Specifications 3.3.9 and 3.9.2 concerning boron dilution events, the staff has the following questions that were transmitted via e-mail dated July 10, 2006:

NRC Ouestion 1:

The proposed amendment would remove reference to specific valve numbers in the Technical Specifications (TSs) 3.3.9 and 3.9.2, consistent with the Standard Technical Specifications (STS). However, the notes that are proposed to be added to TS 3.3.9 and TS 3.9.2 are not consistent with the STS. Provide a justification for including these notes in TSs 3.3.9 and 3.9.2, and an indication and example as to how these notes would be applied.

AmerenUE Response:

The responses have been revised to incorporate the resolutions from various discussions with NRC staff.

TS 3.9.2 Changes As stated in Attachment 1, Section 2.0 of the submittal, the proposed revisions to TS 3.9.2, Unborated Water Source Isolation Valves, would remove references to specific Chemical and Volume Control system (CVCS) isolation valves, BGV0178 and BGV0601, and relocate them to the TS 3.9.2 Bases. This change is consistent with the Standard Technical Specifications, NUREG-1431. An additional plant specific change is proposed to provide an exception Note to the LCO requirement of TS 3.9.2. The Note would permit unborated water source isolation valves to be unisolated under administrative controls in MODE 6 for planned boron dilution evolutions. The exception is acceptable during MODE 6, based on plant operational needs and on the application of administrative controls to preclude an inadvertent boron dilution event.

The following examples are provided to demonstrate application of the exception Note.

Refueling decontamination activities provide an example when an exception to the LCO requirement to close and secure unborated water sources during MODE 6 would be needed. As a planned dilution evolution, refueling decontamination activities, would require unborated water source paths to be unisolated under administrative controls.

Specifically, the administrative controls approved as part of Amendment 97 to the Callaway Plant Operating License are used to limit the volume of unborated water which can be added to the refueling pool for decontamination activities in order to prevent

Response to NRC RAI July 10, 2006 Page 2 of 4 diluting the refueling pool boron concentration below TS limits. These administrative controls are summarized in the Bases for TS 3.9.1, Boron Concentration, under APPLICABLE SAFETY ANALYSES. These administrative controls are also referenced in the TS 3.9.2 LCO Bases. Specifically in MODE 6, reactor makeup water is used to rinse items removed from the refueling pool and to spray down the refueling pool walls during the pool drain evolution to facilitate decontamination activities. The rinse and spray are done with unborated reactor makeup water supplied via temporary configurations (flexible hose connections to manual reactor makeup water isolation valves). During MODE 6, the exception Note permits these reactor makeup water isolation valves to be unsecured from the closed position, under the administrative controls; so that the above described decontamination activities may be performed.

Another example for application of the exception Note is operation of CVCS resin vessels in MODE 6. The CVCS resin vessels include the resin vessels of its subsystem the boron thermal regeneration system (BTRS). During MODE 6, the BTRS ion exchanger resin is routinely used for refueling chemistry control. When initially placed in service, this resin could remove a slight, pre-calculated, amount of boron from the RCS until it reaches equilibrium with the system. This resin equilibrium period is a planned boron dilution.

The above example is typical of an RCS cooldown to refueling conditions where resin is required to remove corrosion and activation products released from fuel and piping surfaces into the coolant. Removing these impurities is a key factor in Callaway's strategy to keep worker dose and skin contamination potential to ALARA levels during refueling activities. In exception to TS 3.9.2 LCO requirements and as permitted by the proposed exception Note, CVCS and BTRS vessels could be unisolated and operated during MODE 6, under administrative controls.

TS 3.3.9 Changes As stated in Attachment 1, Section 2.0 of the submittal, the proposed revisions to TS 3.3.9, Boron Dilution Mitigation System, would remove references to specific CVCS isolation valves, BGV0178 and BGV0601, from Required Actions B.3.1, B.3.2, C.1 and C.2 and relocate them to the TS Bases. Specific isolation valves are not required in the Standard Technical Specifications, NUREG- 1431, and relocating them to the appropriate TS Bases is an administrative only change and consistent with the Standard Technical Specifications.

The originally proposed exception Notes on TS 3.3.9 Required Actions B.3.1, B.3.2, C. 1, and C.2 are eliminated.

Response to NRC RAI July 10, 2006 Page 3 of 4 NRC Ouestion 2:

In the notes proposed to be added to TSs 3.3.9 and 3.9.2, there is repeated reference to chemical volume control system (CVCS) resin vessels or water source path valves being "intermittently" unisolated "under administrative controls." Address what administrative controls are being referred to in the notes, and provide a definition (i.e., the frequency) of "intermittently."

AmerenUE Response:

This response has been revised to incorporate the resolutions from various discussions with the NRC staff. The notes proposed to be added to TS 3.3.9 are eliminated because the exceptions permitted are not acceptable during modes of operation higher than MODE 6.

The notes originally proposed to be added to TS 3.9.2 are now covered under one generic exception Note that permits unborated water sources to be unisolated under administrative controls for planned boron dilution evolutions. Administrative controls are summarized in the Bases for TS 3.9. 1, Boron Concentration, under APPLICABLE SAFETY ANALYSES and also in the Bases for TS 3.9.2, Unborated Water Source Isolation Valves, under BACKGROUND.

NRC Ouestion 3:

Discuss if the exceptions described in the notes to TS 3.3.9 and 3.9.2 would be used in lieu of limiting conditions for operation (LCOs) 3.3.9 and 3.9.2. Provide assurance that the TS surveillances and LCO required actions would continue to be taken when operating under administrative controls.

AnmerenUE Response:

The responses have been revised to incorporate the resolutions from various discussions with the NRC staff.

TS 3.9.2 Changes The exceptions described in the originally proposed Note I and proposed Note 2 for TS 3.9.2 LCO are now covered under one generic exception Note that permits unborated water sources to be unisolated under administrative controls for planned boron dilution evolutions. The exception modifies the current TS 3.9.2 LCO such that other administrative controls would be used in lieu of those required by TS 3.9.2 LCO. During

of 4 Response to NRC RAI July 10, 2006 Page 4 of 4 MODE 6 operations and under current TS 3.9.2 LCO, all unborated water source isolation valves that are connected to the RCS must be closed and secured to prevent an unplanned boron dilution in the reactor coolant. As stated in the Callaway FSAR, Section 15.4.6, "An uncontrolled boron dilution transient will not occur during this mode of operation.

Inadvertent dilution .... is prevented by administrative controls which isolate the RCS from the potential source of unborated water." Plant administrative controls ensure that the requirements of the current Specification are met.

However, the proposed Note would permit plant activities to be performed with certain unborated water source isolation valves unisolated, when performed under administrative controls. In all cases, the administrative controls preclude the possibility of an inadvertent boron dilution event. At the completion of any planned boron dilution activity, prompt verification assures the unborated water source isolation valves are closed and secured.

When not in use (as allowed by the proposed exception Note), unborated water source isolation valves are closed and secured. The TS 3.9.2 LCO required actions and surveillance requirements would continue to be taken.

TS 3.3.9 Changes The originally proposed exception Notes for TS 3.3.9 Required Actions B.3.1, B.3.2, C.l, and C.2 are eliminated.

Callaway Plant Administrative Controls As discussed above Callaway Plant administrative controls ensure the requirements of the Specifications are met, as well as, any approved exceptions. In all cases the administrative controls provide assurance that plant operations will not result in an inadvertent boron dilution event. This confidence is based on the robust nature of Callaway's administrative controls which include elements such as: (1) adherence to approved procedures; (2) planned evolutions and briefings; (3) calculations for the impact on boron concentrations prior to evolutions; (4) reviews by licensed operators; (5) valve identification with temporary tagging; and (6) prompt verification that unborated water source isolation valves are closed and secured after completion of any planned dilution activities.

NRC COMMENTS (TRANSMITTED VIA E-MAIL ON SEPTEMBER 20,2006)

AND AMERENUE RESPONSES NRC Comment: It is my understanding they are going to withdraw the change to TS 3.3.9.

Response: Callaway will withdraw the proposed Note on proposed TS 3.3.9 Required Actions B.3.l, B.3.2, C.I, and C.2. However, proposed TS 3.3.9 Required Actions B.3.1, B.3.2, C.1, and C.2 have been revised to remove specific isolation valve numbers and relocate them to the TS 3.3.9 Bases and TS 3.9.2 Bases.

NRC Comment: The changes they are proposing for TS Bases 3.4.5, 3.4.6, 3.4.7, and 3.4.8 are adding detail.

Response: AmerenUE concurs that the proposed revisions to TS Bases 3.4.5, 3.4.6, 3.4.7, and 3.4.8 are adding necessary detail.

NRC Comment: The changes they are proposing to TS 3.9.2 and TS Bases 3.9.2 is where the meat of the LAR resides. For that I have a couple comments.

1) Insert I provides examples of "...planned boron management evolutions." The comment is that the only Mode 6 example is a boration not a dilution. There is no question about them being able to borate. They should include a dilution example to ensure everybody knows that is the intent. This TS Bases section only applies in Mode 6, all of the other Mode examples are excess verbiage. Boron dilution in any other Mode is controlled by the BDMS TS.

2) 1 am confused over the preconditioning of ion exchanger (IX) that are not intended for boron dilution. The last two sentences of the first paragraph of Insert IA indicates these are going to be planned boron dilutions. The second paragraph of Insert IA indicates that since they are preconditioned with an appropriate boron concentration they are not potential boron dilution sources. It was my understanding from the first phone call that, for the purposes of this TS, there were two types of IX, those to be used for an intentional boron dilution, i.e., the resin is specifically designed/intended to remove boron from the system, and all other IX uses. Any use of the use of the former would be a planned boron dilution any use of the latter would be preconditioned with an appropriate boron concentration from a source other than the RCS, thereby making them not boron dilution sources when placed in service.

3) There is no mention of a boron dilution by 'feed and bleed.' Is this intentional?

4) Insert 2B indicates they will use the LCO note to flush the gamma radiation detector, Insert IA says they won't. This needs to be clarified.

5) They are inserting specific valve numbers into the TS Bases with Insert 2B, I can't comment on them without a P&ID. I don't need, or want, a P&ID to write a SER, but my wording would be more generic.

NRC Comments and AmerenUE Responses Page 2 of 2 Responses: The following Callaway responses address each item of the NRC comment.

1) Note that INSERT 1 and INSERT IA have been combined into INSERT 1. INSERT 1 is revised to include an example of a boron dilution evolution in Mode 6. See the attached markup and revision to INSERT 1.

2) Note that INSERT 1 and INSERT I A have been combined into INSERT 1. Callaway has revised the language in INSERT 1 to eliminate examples that do not meet the definition of a planned boron dilution. See the attached markup and revision to INSERT 1. In addition, to clarify the NRC's understanding of the ion exchanger resins used at Callaway in Mode 6, the following is provided:

For Mode 6 duty, an ion exchanger resin is routinely used for refueling chemistry control. When initially placed in service, this resin could remove a slight, pre-calculated, amount of boron from the RCS until it reaches equilibrium with the system. This resin equilibrium period is an example of a planned dilution event for Mode 6.

Callaway does not use ion exchanger resin that only functions to remove boron from the reactor coolant system in Mode 6. However, Callaway has this type of resin in a standby status (and connected to the system) for use in other Modes. During Mode 6, to prevent an inadvertent dilution from system leakage through this resin, Callaway isolates and locks the valves on the vessels holding the resin in standby.

3) Callaway intentionally does not mention boron dilution by 'feed and bleed'. Diluting the reactor coolant system in Mode 6 with unborated water, using a 'feed and bleed' method, is not performed at Callaway. It is Callaway's intention to not include feed and bleed as a planned dilution option for Mode 6.

4) As discussed in response to item (2), INSERT 1A has been combined into INSERT 1 and INSERT I is revised. The revised INSERT I includes clarification that in Mode 6, the maintenance activity of flushing the gamma radiation detector would be performed as a planned dilution using administrative controls. INSERT 2, INSERT 2A, and INSERT 2B have been combined into INSERT 2. INSERT 2 has been revised to be consistent with INSERT 1. See the attached markup and revision to INSERT 2.

5) For clarity, Callaway prefers to include specific equipment descriptions in the TS Bases.

A Unborhted Water Sourceisolation B3.9.2 Valves

• f *

• BASES APPLICABLE The possibility of an inadvertent boron dilution event (Ref. 1) occurring SAFETY during MODE 6 refueling operations is precluded by adherence to this ANALYSES LCO, which requires that potential dilution sources be isolated. Closing the required valves during refueling operations prevents the flow of unborated water to the filled portion of the RCS. The valves are used to isolate unborated water source These valves have the potential to ne allow dilution of the RC ron concentration in MODE 6. By Aisinistuorated water sources, a' ,fety analysis foran uncontro boron dilution accident in accordance te ta r ev Plan (Ref. 2) is not required for MODE 6. ~RS The RCS boron concentration satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

fondi cto bcaablleilto of thein miRatdr ocnrto nMD .B ECO APPLICABILITY In MODE 6, this is applicable to prevent an inadvertent boron Sdilution The booby ensuring event atsisC ocnrto isolation dn2o of all sources Revsio of unboated water to the RCS.

LorLaAA o ther Tilled to the dilution als a0e RevaCcen and

TSB CN 02-016 INSERT 1 Bases 3.9.2 During MODE 6 operations, all unborated water source isolation valves that are connected to the Reactor Coolant System (RCS) must be closed to prevent unplanned boron dilution of the reactor coolant. The isolation valves must be secured in the closed position.

Boron dilution in Mode 6 could occur from reactor makeup water sources containing unborated water or boron dilution could also occur from ion exchange resin contained within the CVCS and BTRS for water chemistry control. Note that CVCS resin vessels include the resin vessels of its subsystem the BTRS. While the purpose of the resin is to control water impurity levels and clarity, it may remove a slight amount of boron from the system's water stream when the resin is initially placed in service. The purified water stream is returned to the RCS at a slightly lower boron concentration until the resin reaches chemical equilibrium and is no longer a dilution source. Operations involving the conditioning and management of resin are permitted in Mode 6 because the amount of global RCS boron removed from the RCS during the equilibrium period can be calculated beforehand. As such, these operations are conducted as planned dilutions using administrative controls.

In Mode 6, operation ofthe CVCS letdown gamma radiation detector SJREOO1 is not required. However, flushing the detector with unborated water for maintenance during Mode 6 would be performed as a planned dilution using administrative controls.

Some unborated water sources, that are not connected to the RCS in their as-built configuration, can be temporarily configured (ex. flexible hose connected) to provide a direct path for unborated water into the RCS. A routine Mode 6 activity requiring this temporary configuration is decontamination of the refueling pool. However, administrative controls will limit the volume of unborated water that can be added to the refueling pool for decontamination or planned dilution activities, in order to prevent diluting the refueling pool and RCS below the specified limits (Ref. 3). (See the Bases for LCO 3.9.1, "Boron Concentration".

Callaway reactivity management provides systematic direction to control activities that impact plant reactivity. This means precluding unplanned or uncontrolled occurrences impacting reactivity (positive or negative), including inadvertent boron dilution events.

Plant operations may require planned boron management evolutions. Reactivity management provides provisions that any planned activities and evolutions with the potential to impact reactivity are identified; are conducted in a controlled manner; are evaluated to ensure the effects of reactivity changes are known and monitored; and are performed by plant personnel briefed so that any anomalous indications are met with

TSB CN 02-016 INSERT 1 continued Bases 3.9.2 conservative action. Specifically, administrative controls include: (1) adherence to approved procedures; (2) planned evolutions and briefings; (3) calculations for the impact on boron concentrations prior to evolutions; (4) reviews by licensed operators; (5) valve identification with temporary tagging; and (6) prompt verification that unborated water source isolation valves are closed and secured after completion of any planned dilution activities.

TSB CN 02-016 INSERT 2 Bases 3.9.2 This LCO requires that unborated water source flow paths connected to the RCS be isolated to prevent unplanned boron dilution during MODE 6 and thus avoid a reduction in SDM. The unborated water source isolation valves must be closed and secured.

Isolation valves connected to the RCS include: (1) unborated reactor makeup water (BGV0178 and BGV0601), (2) CVCS resin vessels configured with resin for dilution during normal operation (BG8522A, BG8522B, BGV0039, BGV0043, BGV0051, and BGV0055) and (3) unborated flushing water for the CVCS letdown radiation monitor (SiV0703).

Some unborated water sources, that are not connected to the RCS in their as-built configuration, can be temporarily configured (ex. flexible hose connected) to provide a direct path for unborated water into the RCS. Isolation valves not connected to the RCS, but modified via temporary configuration to provide a direct path for unborated water into the RCS include: (1) BLVO078, (2) BLVO079 and (3) BLV0055.

This LCO is modified by a NOTE to allow unborated water sources to be unisolated under administrative controls for planned boron dilution evolutions. The NOTE also permits unborated water sources, not connected to the RCS in their as-built configuration, but temporarily, configured (ex. flexible hose connected) to provide a direct path for unborated water into the RCS, to be used under administrative controls for planned boron dilution evolutions.

During refueling activities, it may be necessary for an unborated water source to be unisolated. Based on License Amendment 97, 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 in this case are identified in TS Bases 3.9.1 and are applicable to the LCO NOTE exception for the following specific isolation valves: BLVO078, BLVO079 and BLVO055.

In Mode 6, other plant activities may require unborated water sources to be unisolated under administrative controls for planned boron dilution evolutions. The LCO NOTE allows an isolation exception for use of the reactor makeup water system, for operation of CVCS resin vessels, and for maintenance to flush the CVCS letdown gamma radiation detector SJREOO1 with unborated reactor makeup water. The administrative controls include plant reactivity management requirements and operational awareness and are described in the TS Bases 3.9.2 Background. These requirements are applicable to the LCO NOTE exception for the following specific isolation valves: BGV0178, BGV0601, BG8522A, BG8522B, BGV0039, BGV0043, BGV0051, BGV0055 and SJV0703.

ULNRC- 05345 ATTACHMENT 2 MARKUP OF TECHNICAL SPECIFICATION PAGES

BDMS 3.3.9 3.3 INSTRUMENTATION 3.3.9 Boron Dilution Mitigation System (BDMS)

LCO 3.3.9 Two trains of the BDMS shall be OPERABLE and one RCS loop shall be in operation.

APPLICABILITY: MODES 2 (below P-6 (Intermediate Range Neutron Flux) Interlock), 3, 4, and 5.

NOTE The boron dilution flux multiplication signal may be blocked in MODES 2 (below P-6 (Intermediate Range Neutron Flux) interlock) and 3 during reactor startup.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One train inoperable. A.1 Restore train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.

B. Two trains Inoperable. B.1 ------... NOTE Plant temperature OR changes are allowed provided the temperature Required Action and change is accounted for associated Completion Time in the calculated SDM.

of Condition A not met.

Suspend operations Immediately involving positive reactivity additions.

AND (continued)

CALLAWAY PLANT 3.3-71 Amendment No. 165 I

BDMS 3.3.9 CALLAWAY PLANT 3.3-72 Amendment 165 1

Unborated Water Source Isolation Valves 3.9.2 3.9 REFUELING OPERATIONS o., ,Leo 3.9.2 Unborated Wate 9ý

.XJEo ource, Isolation Valves t03shall be secured in the closed position.

3A.,,,,o APPLICABI 1W: MODE 6.

ACTION KI 'rC Separate'.ondition entry is allowed for each unbo-rated water source isolation valve.

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

e completed whenever AND

• ondillon A is entered.

One or more valves not ecured in closed position.

A.2 Initiate actions to secure valve In closed position.

Immediately

)

AND A-3 Perform SR 3.9.1.1. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> SURV LANCE REQUIREMENTS SURVEILLANCE FRE ENCY SR 3.9.2. Verify each valve that isolates unborated water 31 ys sou r c d Ei v0601,p is secured in the es closed position.

CALLAWAY PLANT CALLA WAY PLANT 3.9-3 Amendment No. 133 Amendment

4 OL 1238 INSERT LCO 3.9.2

---

-NOTE-........----------- ---------- ---------- -------- -

Unborated water sources may be unisolated under administrative controls for planned boron dilution evolutions.

ULNRC- 05345 ATTACHMENT 3 RETYPED TECHNICAL SPECIFICATION PAGES (To Be Provided Later)

ULNRC- 05345 ATTACHMENT 4 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (for information only)

RTS Instrumentation B 3.3.1 BASES APPLICABLE 5. Source Range Neutron Flux SAFETY ANALYSES, The LCO requirement for the Source Range Neutron Flux trip LCO, AND Function ensures that protection is provided against an APPLICABILITY uncontrolled RCCA bank rod withdrawal accident from a (continued) subcritical condition during startup (automatic rod withdrawal is no longer available). This trip Function provides redundant protection to the Power Range Neutron Flux- Low and Intermediate Range Neutron Flux trip Functions. In MODES 3,4, and 5, administrative controls also prevent the uncontrolled manual withdrawal of rods.

The NIS source range detectors are located external to the reactor vessel and measure neutrons leaking from the core. The NIS source range detectors do not provide any inputs to control systems. The source range trip is the only RTS automatic protection function required in MODES 3, 4, and 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully Inserted. Therefore, the functional capability at the Trip Setpoint is assumed to be available.

Tl Source Range Neutron Flux to Fcin wnbelow thie logi.TheiTrp uMe2 t Ragt eStpour 5 .S cs h otusofteFntion to RTS logic are not "

Neutron Flux ip Must 6 or when abov rods are fully insre n h o onrlSse sicpable of rod conturol rod ejcionglevents.alr il ialhstrp.Ti ale withdrawal.

0.'o111 Intermediate Range Neutron Flux trip and the Power Range Neutron Flux-Low trip will provide core protection for reactivity accidents. Above the P-6 setpoint, the NIS source range neut flux reactor trip may be manually blocked. When the sour nge trip is blocked, the high voltage to the detectors is also oved.

In MODES 3. 4. and 5 with the Rod Cont tem capable of rod withdrawal or one or more rods not inserted, the Source Range Neutron Flux trip Functi ust also be OPERABLE. Ifthe od Co tem Is e of rod withdrawal, the Source Range Neutron ux trip must be OPERABLE to provide core protection against a rod withdrawal accident. Ifthe Rod Control (continued)

CALLAWAY PLANT B 3.3.1-14 Revision 6

TSBCN 02-016 INSERTI B 3.3.1 In MODE 2, credit is also taken for a reactor trip being initiated by this trip function to alert the control room operators to manually mitigate an inadvertent boron dilution event.

RTS Instrumentation B 3.3.1 BASES ACTIONS G1I and G2 (continued) range channels or the neutron flux channels discussed in LCO 3.3.3.

"Post Accident Monitoring (PAM) Instrumentation," with action to reduce power below the count rate equivalent to the P-6 setpoint.

Below P-6, the Source Range Neutron Flux channels will be able to monitor the core power level. The Completion lime of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will allow a slow and controlled power reduction to less than the P-6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip.

Required Action G.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (i.e.,

temperature or boron concentration fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met and the requirements of LCOs 3.1.5, 3.1.6. and 3.4.2 are met.

H-1 Not used.

Condition I applies to one inoperable Source Range Neutron Flux trip channel when in MODE 2 below the P-6 setpoint. With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions. With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.

This will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.

Required Action 1.1 is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (i.e.,

temperature or boron concentration fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met, the requirements of LCOs 3.1.5. 3.1.6, and 3.4.2 are met, and the initial and critical boron concentration assumptions in FSAR Section 15.4.6 (Ref. 16)

(continued)

CALLAWAY PLANT B 3.3.1-40 Revision 6

TSBCN 02-016 INSERT2 B 3.3.1 See LCO 3.3.9, "Boron Dilution Mitigation System," for requirements related to the mitigation of inadvertent boron dilution events.

RTS Instrumentation B 3.3.1 BASES ACTIONS L. (continued) o Cheoca Condition J applies to two inoperable Source Range Neutron Rux trip channels when in MODE 2 below the P-6 setpoint or in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions. With both source range channels inoperable, the Reactor Trip Breakers (RTBs) must be opened immediately. With the RTBs open, the core is in a more stable condition.

K.1. K.2.1. and K.2.2 Condition K applies to one inoperable source range channel in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6.

the NIS source range performs the monitoring and protection functlions.

With one of the source range channels inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to restore it to an OPERABLE status. Ifthe channel cannot be returned to an OPERABLE status, action must be initiated within the same 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to fully insert all rods. One additional hour is allowed to place the Rod Control System in a condition Incapable of rod withdrawal (e.g., by de-energizing all CRDMs, by opening the RTBs, or de-energizing the motor generator (MG) sets). Once these ACTIONS are completed, the core is in a more stable condition. The allowance of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the channel to OPERABLE status, and the additional hour to place the Rod Control System In a condition incapable of rod withdrawal, are reasonable considering the other source range channel remains OPERABLE to perform the safety function and given the low probability of an event occurring during this interval. Normal plant control operations 00."\ that individually add limited positive reactivity (i.e., temperature or boron concentration fluctuations associated with RCS inventory management or temperature control) are permitted provided the SDM limits specified in 1V 2, the COLR are met and the initial and critical boron concentratlo

- M assumDtions in FSAR Section 15.4.6 (Ref. 16) are satisfied~lodior~

(continued)

CALLAWAY PLANT B 3.3.1-41 Revision 6

TSBCN 02-016 INSERTZ B 3.3.1 See LCO 3.3.9, "Boron Dilution Mitigation System," for requirements related to the mitigation of inadvertent boron dilution events.

BDMS B 3.3.9 B 3.3 INSTRUMENTATION

'se 0 1 -0l1o B 3.3.9 Boron Dilution Mitigation System (BDMS)

BASES BACKGROUND The primary purpose of the BDM o mitigate the consequences of the inadvertent addition of unborat primary grade water Into the Reactor Coolant System (RCS) when e plant is in MODES 2 (below P-6 setpoint), 3, 4, and 5.

The BDMS utilizes two channels of source range Instrumentation. Each source range channel provides a signal to Its microprocessor, which continuously records the counts per minute. At the end of each discrete one-minute interval, an algorithm compares the average counts per minute value (flux rate) of that 1 minute interval with the average counts per minute value for the previous nine, 1 minute intervals. If the flux rate during a I minute interval is greater than or equal to 1.7 times the flux rate during any of the prior nine I minute intervals, the BDMS provides a signal to Initiate mitigating actions.

Upon detection of a flux multiplication by either source range instrumentation train, an alarm is sounded to alert the operator and valve movement is automatically initiated to terminate the dilution and start boration. Valves that isolate the refueling water storage tank (RWST) are opened to supply borated water to the suction of the centrifugal charging pumps, and valves which isolate the Volume Control Tank are closed to terminate the dilution.

APPLICABLE The BDMS senses abnormal increases in source range counts per minute SAFETY (flux rate) and actuates VCT and RWST valves to mitigate the ANALYSES consequences of an inadvertent boron dilution event as described in Reference 1. The accident analyses rely on automatic BDMS actuation to mitigate the consequences of inadvertent boron dilution events in MODES 3, 4, and 5. The MODE 2 analysis In Reference I credits the source ran r fu i njunction with operator action. The ionooe lopstpolnt), 3,4, and 5 provides adequate flow to enuemxnpeetsrand produce gradual reactivity changes during RCS boron concent 0nn reductions. The reactivity change rate associated with boron reduc.n will, therefore, be within the transient mitigation capability of the BDM With no reactor coolant loop in operation In the above MODES. boron dilutions must be terminated andidilution sources isolate! The bo dilution analysis in these MODES takes credit for the ing volume associated wa one rea r coolan op In operation.

(A~a.CbL.~3~C( (rco nued)

TSB CN 02-016 INSERT la Bases 3.3.9 The addition of unborated primary grade water into the RCS results in boron dilution and a potential for an inadvertent boron dilution event. Other potential boron dilution sources have been identified. An inadvertent boron dilution path is created when flushing the Chemical and Volume Control system (CVCS) letdown gamma radiation detector, SJREOOI, with unborated reactor makeup water. Boron dilution may also be accomplished by removing boron from the CVCS stream prior to RCS return using the ion exchange capability of the CVCS resin vessels.

The CVCS resin vessels include the resin vessels of its subsystem, the boron thermal regeneration system.

As described in TS 3.9.2 Bases, plant reactivity management requirements preclude inadvertent boron dilution events, while permitting planned boron dilution evolutions (necessary for plant operations) performed under administrative controls.

1XNSER BBDMS 3.3.9 BASES APPLICABILI In MODE 6, dilution event is precluded by lock valve (continued that isolate the RCS from the potentala I unborated water (according to LCO 3.9.2, "Unborated Wate reIsolation Valves"). 5LWUw0 The Applicability is modified by a Note that allows the boron dilution flux multiplication signal to be blocked during reactor startup in MODE 2 (below P-6 setpolnt) and MODE 3. Blocking the flux mufltiplication signal is acceptable during startup provided the reactor trip breakers are closed with the intent to commence the withdrawal of control banks for startup.

This Applicability Note can not be used to block BDMS prior to or during shutdown bank withdrawal. The P-6 interlock provides a backup block signal to the source range flux multiplication circuit.

ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by the unit specific calibration procedure. Typically, the drift is found to be small and results In a delay of actuation rather than a total loss of function. This determination of setpoint drift is generally made during the performance of a COT when the process Instrumentation Is set up for adjustment to bring it to within specification. Ifthe Trip Setpolnt is less conservative than the tolerance specified by the calibration procedure, the channel must be declared Inoperable immediately and the appropriate Condition entered.

A.1 With one train of the BDMS inoperable, Required Action A.1 requires that the inoperable train must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining BDMS train Is adequate to provide protection. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the BDMS Function and is consistent with Engineered Safety Feature(\

QftC ompletion Times for loss of one redundant train. Also, the remaining OPERABLE train provides continuous indication of core power status to the operator, has an alarm function, and sends a signal to both trains of the BDMS to assure system actuation.

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

- eactivity management briefs of the Control Room Opera' ns Staff pically conducted at the beginning of each shift):

(continued)

CALLAWAY PLANT B 3.3.9-3 Revision 6

TSB CN 02-016 INSERTI Bases 3.3.9 CVCS resin vessels configured for unborated reactor makeup water (BGVOI78 and BGV0601), B08522B, BGV0039, BGV0043, with resin for dilution during normal operation (BG8522A, flushing of CVCS letdown radiation BGVOO5 1, and BGV0055), and the purge line used during monitor (SJV0703)

BDMS B 3.3.9 BASES ACTIONS A.1 (continued)

- Use of self-verification techniques by all licensed operators performing core reactivity manipulations;

- Peer checks for all reactivity manipulations during routine operations and for all positive reactivity additions during transient or off-normal operations;

- Off-normal procedures are available that address reactor makeup malfunctions and potential lo.f shutdown (SDM). (RMCS) margin system control Wuring a operable, oratoe Req iton able inndidciations of nm pon e of Atan Condition equired eAction .1s tobevsh aiuspn allopeationsinvoalvng prositied recivitye ro Sdesiand intentonaltorongdiuton. ytmoeaio sdsusdi FSRSeqieAction 1546. vReerifesnte 1)SD acordi~ng ofto SR31..awti 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This action is intended to confirm that no unintended boron dilution has occurred while the BDMS was inoperable, and that the required SDM has been maintained. The specified Completion Time takes into consideration sufficient tiome for the initial determination of SDM and other information_ vail b ein h~e on rol U>0" *. Required Action B.3.1 requires valves liste pintCO 3.9.2rcv

• • j=t

,* ., ,,-/,* .-,.*,*,:* .*p* *.-,**,-**d *.*to be ecured to prevent the flow of addiiunborated water intoofthe is recognized RCS. nce itinomain*S that two trainsoof the extniildetermindition eD ndtry. e . Qvai bti-/

BDMS are inoperable, the opeSators will be aware of the possibility of a boron dilution, and the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> tompletion Time adequateis A. cO ontinaed to complete tu romrltdto(M teRequired metionf LB3.29en thes recurain dyeficad n timon fo n SOUL"AAYL 82 M

TSB CN 02-016 INSERT lb Bases 3.3.9 An inadvertent dilution event is precluded by locked valves for unborated reactor makeup water (BGVO 178 and BGV0601), CVCS resin vessels configured with resin for dilution during normal operation (BG$522A, BG8522B, BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor (SJV0703) that isolate the RCS from potential sources of unborated water.

BDMS B 3.3.9 BASES ACTIONS B-. (continued)

Re, d Action B.1 is modified by a Note which permits plant te perature changes provided the temperature change is accounted for

,,An the calculated SDM. Introduction of temperature changes, including temperature increases when a positive MTC exists, must be evaluated to ensure they do not result in a loss of required SDM.

0 ,..Otto TNSERTI L Condition C Is entered with no RCS loop in operation. The operation of one RCS loop provides adequate flow to ensure mixing, prevent stratification, and produce gradual reactivity changes during RCS boron concentration reductions. The reactivity change rate associated with boron reduction will, therefore, be within the transient mitigation capability of the Boron Dilution Mitigation System (BDMS). With no reactor coolant loop in operation, dilution sources must be isolated. The boron dilution analysis takes credit for the mixing volume associated with having at least one reactor coolant loop in operation.

1.. closed and secured to prevent the flow of unborated water Into the RCS.

%WAA-031kvThe 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion lime isadequate to perform these local valve

-Lst manipulations. The recurring 31 day verificatilon of Required Action C.2 Condition C entry.

SURVEILLANCE The BOMS trains are subject to a CHANNEL CHECK, valve closu in REQUIREMENTS MODE 5, COT, CHANNEL CALIBRATION, and Response Time sting. In addition, the requirement to verify one RCS loop in operatio subject to periodic surveillance.

erformW of the CHANNEL CH once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ensures that gross allure our ge n mentation has not occurred.

A CHANNEL CHECK Is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious.

A CHANNEL CHECK will detect gross channel failure: thus, Itis key to (continued)

CALLAWAY PLANT B83.3.9-5 Revision 6

TSB CN 02-016 INSERT lb Bases 3.3.9 An inadvertent dilution event is precluded by locked valves for unborated reactor makeup water (BGVO178 and BGV060 1), CVCS resin vessels configured with resin for dilution during normal operation (BG8522A, BG8522B, BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor (SJV0703) that isolate the RCS from potential sources of unborated water.

BDMS B 3.3.9 BASES SURVEILLANCE SR-3.3.9.1 (continued)

REQUIREMENTS verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the unit staff based on a combination of the channel instrument uncertainties, including indication and readability. Ifa channel is outside the criteria, it may be an indication limit.the sensor or that s the signal processing equipment has drifted outside its The Frequency Is on operating experience that demonstrates channel fa0mU ae The CHANNEL CHECK supplements less formal, but frequet checks of channels during normal operational use of displays

"*e associated LCO required channels.

the Gwith 11LLnLOLka W&)e Sakrc.

SR -3.3.9.2 reure 0 SR 3.3.9.2 requiresa v-lvBGVO17 bgsegprior to MOD 5. 3.9.2 equires that this valve also be t ueean close in MODE 6. Closing BGVD178 satisfies the boron ciden analysis assumption that flow orifice BGFO0010 limits the dilution flow rate to no more than 150 gpm in MODE 5. This Surveillance demonstrates that the valve is dosed through a system walkdown. SR 3.3.9.2 is modified by a Note stating that it is only required to be performed In MODE 5. This Note requires that the surveillance be performed prior to entry into MODE 5 and every 31 days while in MODE 5. The 31 day frequency is based on engineering judgment and considered reasonable in view of other administrative controls that will ensure that! valve opening is an unlikely possibility.

SR 3.3.9.3 requires the performance of a COT every 184 days, ensure at each train of the BDMS and associated trip setpoints are ly operational. A successful test of the required contact(s) of a annel relay ay be performed by the verification of the change of bf a single ntact of the relay. This clarifies what is an accepta e CHANNEL O RATIONAL TEST of a relay. This Is accepta because all of the othe ulred contacts of the relay are v dy other Technical Specifi d ons and no-Technical ications tests at least once per refueling in app I e extensions. This test shall include verification that the boron dilution flux multiplication setpoint is equal to or less than an increase of 1.7 times the count rate within a 10 minute (continued)

CALLAWAY PLANT B 3.3.9-6 Revision 6

RCS Loops - MODE 3 B 3.4.5 BASES APPLICABLE changes during RCS boro concentration reductio s. The reactivity SAFETY change rate associated wit boron reduction will, erefore, be within the ANALYSES transient mitigation capabi of the Boron Dilut n Mitigation System (continued) (BDMS). With no reacto olantloopinope tion in either MODES 3.4, or 5, boron dilutions mu be terminated an ilution sources isolated.

The boron dilution analy s in these MODES takes credit for the mixing volume associated with h ing at least one reactor coolant loop in operation. LCO 3.3.9, "B on Dilution Mitigation System (BDMS),"

contains the requirements the BDMS. -$cN 02 -O1(o Failure to provide decay heat moval may result in challenges to fission product barrier. The RC I ps are part of he prima ccess path that functions or actuates to pre . tea sign 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 I OCFR50.36(c)(2)(ii).

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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 3.4.5-2 Revision 6

RCS Loops - MODE 3 B 3.4.5 BASES LCO tlization of the Note is permitted provided the following con iions are (continued) met, along with any other conditions imposed by test procedure s:

a. No operations are permitted that would dilute the RCS bo concentration with coolant at boron concentrations less than required to assure the SDM of LCO 3.1.1, thereby maintaining the A margin to criticality. Introduction of reactor makeup water Into the RCS from the Chemical and Volume Control System mixing tee Is not permitted when no RCS loop is in operation Boron dilution h coolant at boron con required to assure co ai t a ed is prohibited because a uniform concentration distribution throughout the RCS cannot be ensured when in natural circulation; and

,VO,0 - b. Core outlet temperature is maintained at least 10°F below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

An OPERABLE RCS loop consists of one OPERABLE RCP and one OPERABLE SO, which has the minimum water level specified in SR 3.4.5.2. An RCP Is OPERABLE If it is capable of being powere nd is able to provide forced flow if required.

APPLICABILITY 3, this LCO ensures forced circulation of eactor coolant to remove cay heat from the core and to prov proper boron mixing. The most stridgent condition of the LCO, that , two RCS loops OPERABLE andSystm RQS loops in opehdtion, two cpabl..m'i s to MODE 3 with the Rod Control ra-waaI. Telats System caithdrawal. The least stringent condition, that is, two RCS loops OPERABLE and one RCS loop in operation, applies to MODE 3 with the Rod Control System not capable of rod withdrawal.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops - MODES I and 2";

LCO 3.4.6, "RCS Loops - MODE 4";

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

LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled";

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

(conti nued)

CALLAWAY PLANT B 3.4.5-3 Revision 6

TSB CN 02-016 INSERT A operation of CVCS resin vessels configured with resin for dilution during normal operation is not permitted, and operation of the purge line associated with flushing the CVCS letdown radiation monitor is not permitted INSERT Al Note that CVCS resin vessels include the resin vessels of its subsystem the BTRS.

RCS Loops - MODE 3 B 3.4.5 BASES ACTIONS D,1. D.2. and D.3 (continued) sets). All operations involving Introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron diluti requires forced circulation for proper mixing, and defeating Rod Control System removes the possibility of an inadve withdrawal.

Suspending the introduction of coolant, into the RC. with boron concentration less than required to meet the mum SDM of ICO 3.1.1 is required to assure continued safe operati . With coolant added without forced circulation, unmixed coolan could be introduced to the core, however coolant added with boro concentration meetin minimum SDM maintains acceptable argin to subcriti erations.

Introduction of reactor makeup wate into the RCS fr the Chemical and Volume Control System mixing tee i not permitt hen no RCS loop is in operation, consistent with Requir Action C.1 of LCO 3.3.9, "Boron Dilution Mitigation System (BDMS).* The immediate Completion Time reflects the importance of maintaini g operation for heat removal. The action to restore must be continued pntil one loop is restored to OPERABLE status and operation. I

• SP00 '01(0*(

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR requires verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ui are in operation. Verification may include flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal.

The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is sufficient considering other indications and alarms available to the operator in the control room to monitor RCS loop performance.

SR 3.4.5.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level Is ýý7% for required RCS loops. Ifthe SG secondary side narrow range water level is c 7%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink for removal of the I

decay heat. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered adequate in view of other indications available in the control room to alert the operator to a loss of SG level.

(continued)

CALLAWAY PLANT B 3.4.5-5 Revision 6

TSB CN 02-016 INSERT A resin for dilution during normal operation of CVCS resin vessels configured with purge line associated with flushing the operation is not permitted, and operation of the CVCS letdown radiation monitor is not permitted

RCS Loops - MODE 4 B 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.6 RCS Loops - MODE 4 BASES BACKGROUND In MODE 4, the primary function of the reactor coolant is the removal of decay heat and the transfer of this heat to either the steam generator (SG) secondary side coolant or the component cooling water via the residual heat removal (RHR) heat exchangers. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.

The reactor coolant is circulated through four RCS loops connected in parallel to the reactor vessel, each loop containing an SG, a reactor coolant pump (RCP), and appropriate flow, pressure, level, and temperature instrumentation for control, protection, and indication. The RCPs circulate the coolant through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and to prevent boric acid stratification.

In MODE 4, either RCPs or RHR loops can be used to provide forced circulation. The intent of this LCO is to provide forced flow from at least one RCP or one RHR loop for decay heat removal and transport. The flow provided by one RCP loop or RHR loop is adequate for decay heat removal. The other intent of this LCO is to require that two paths be available to provide redundancy for decay heat removal.

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

ANALYSES The operation of one RCP in MODES 3, 4, and 5 provides adequate flow to ensure mixing, prevent stratification and produ changes during RCS boron concentration redions. The reactivity change rate associated with boron redu will, therefore, be within transient mitigation capability of the B on Dilution Mitigation System (BDMS). With no reactor coolant 1 p in operation in either MODES 3, 4.

or 5, boron dilutions must be term ated n ilution sources isolated.

The boron dilution analyss in th e MODES takes credit for the mixing volume associated with havi at least one r actor coolant loop in operation. LCO 3.3.9, "Bo Dilution Mitiga ion System (BDMS),"

contains the requirements or the BDMS.

RCS Loops -MODE 4 sati *es Criterion 4 of IOCFR50.36(c)(2)(ii).

(continued)

CALLAWAY PLANT 8 3. -1 Revision 6

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 in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. Any one loop in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop Is required to be OPERABLE to provide redundancy for heat removal.

Note 1 permits all RCPs or RHR pumps to be removed from operation for

5 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period. The purpose of the Note is to permit tests that are required to be performed without flow or pump noise. The I hour time period is adequate to perform the necessary testing, and operating experience has shown that boron stratification is not a problem during this short period with no forced flow.

alo,9*th of Utilizati anyNote otherIperm conditions providedby e imposed owi conditions are met thetest procedures a.* Nooeainre permitted that would dilute the RCS bTg cocnrto with coolant at boron concentrations less tan required to assure the SDM of LCO 3.1.1, thereby maintaining th rgin to criticality. Introduction of reactor makeup water into the A rRCS from the Chemical and Volume Control System mixing tee is not permit hen no RCS loop is in operation Boron dilution with coolant at boron concentrations lestha quired to assure St e is iaine lDe-i ecause a uniform concentration distribution throughout the RCS cannot be ensured

,S. 0 2-0 when in natural circulation; and

b. Core outlet temperature is maintained at least 10F below saturation temperature, so that no vapor bubble may form an possibly cause a natural circulation flow obstruction.

Note 2 requires that the secondary side water temperatur each SG be

! 50OF above each of the RCS cold leg temperatur efore the start of a RCP with any RCS cold leg temperature:5 2 F.This restraint is to due to a thermal transient pre an when t a low tempera red. overpressur An OPERABLE RCS loop is comprised of an OPERABLE RCP and an OPERABLE SG, which has the minimum water level specified in SR 3.4.6.2.

(continued)

CALLAWAY PLANT B 3.4.6-2 Revision 6

TSB CN 02-016 INSERT A operation of CVCS resin vessels configured with resin for dilution during normal operation is not permitted, and operation of the purge line associated with flushing the CVCS letdown radiation monitor is not permitted INSERT Al Note that CVCS resin vessels include the resin vessels of its subsystem the BTRS.

RCS Loops - MODE 4 B 3.4.6 BASES ACTIONS B1and2 (continued)

If no loop is OPERABLE or in operation, except during conditions permitted by Note I in the LCO section, all operations involving introduction of coolant, Into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation from at least one RCP for proper mixing so that Inadvertent criticality can be prevented. Suspending the introduction of coolant, 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 operation. With coolant added without forced circulation, unmixed coolant could be in e core, however coolant added with boron concen ion meeting the minimum SDM maintains acceptable margin t, ubcdtical operations.

Introduction of reactor makeup water into th RCS from the Chemical and Volume Control System mixing tee is noermie e en no RCS loop is in operation, consistent with Required ction C.1o0 LCO 3.3.9, "Boron Dilution Mitigation System (BDMS). heoimmedia Completion Times reflect the Importance of maintainin operation for *ecaY heat Iremoval.{

The action to restore must be contl~ dutl one kop is restored to REQUIREMENTS This SR requires verification every 12 ours that one RCS or RHR loop is in operation. Verification may include te, temperature, or pump status monitoring, which help ensure that f rced flow is providing heat removal. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is su icient considering other indications and alarms available to the oper the control room to monitor RCS and RHR loop performance.

SR 3.4.6.2 SR 3.4.6.2 requires verification of SG OPERABILITY. SG OPERABILITY is verified by ensuring that the secondary side narrow range water level is

> 7% for required RCS loops. If the SG secondary side narrow range water level is < 7%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal I

of decay heal The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 6

TSB CN 02-016 INSERT A during normal operation of CVCS resin vessels configured with resin for dilution with flushing the operation is not permitted, and operation of the purge line associated CVCS letdown radiation monitor is not permitted

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

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the time SAFETY available for mitigation of the accidental boron dilution event.

ANALYSES The operation of one RCP in MODES 3, 4, and 5 provides adequate flow to ensure mixing, prevent stratification, and produce gradual reactivity changes during RCS boron concentration redu s. Dactivity-change rate associated with boron reducti ill, therefore, be within th transient mitigation capability of the Bor Dilution Mitigation System (BDMS). With no reactor coolant Ioo operation in either MODES 3, 4.

or 5, boron dilutions must be te ated and ilution sources Isolated.

The boron dilution analysis in th se MODES akes credit for the mixing volume associated with having t least one actor coolant loop in operation. LCO 3.3.9, "Boron D ution Mitigat n System (BDMS),"

contains the requirements forth BDMS. _ . .styg 02-01 (0 RCS Loops - MODE 5 (Loops lled) satisfies iterion 4 of I OCFR5O.36(c)(2)(ii}.

6 LCO The purpose of this LCO is to requ re that at least one of the RHR loops be OPERABLE and in operation Wi n additional RHR loop OPERABLE or two SGs with secondary side wide nge water level ! 86%. As show in Reference 3, any narrow range le I in ication above 7% will ensur the SG tubes are covered. One RHR loop ides s icient forced circulation to perform the safety functions of t eactor er these conditions. An additional RHR loop is required to be OPERABLE to meet single failure considerations. However, if the standby RHR loop is not OPERABLE, an acceptable alternate method is two SGs with their secondary side wide range water levels >_ 86%. Should the operating RHR loop fail, the SGs could be used to remove the decay heat via natural circulation.

Note I permits all RHR pumps to be removed from operation -. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period. The purpose of the Note is to permit tests that are required to be performed without flow or pump noise. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time period is adequate to perform the necessary testing, and operating experience has shown that boron stratification is not likely during this short period with no forced flow.

Utilization of Note 1 is permitted provided the following conditions are met, along with any other conditions imposed by test procedures:

(continued)

CALLAWAY PLANT B 3.4.7-2 Revision 6

a RCS Loops - MODE 5, Loops Filled BASESB3.7 LCO /a. No operations are permitted that would dilute the RC boron

(,tinued) concentration with coolant at boron concenraitions Ies

/ required to assure the SDM of LCO 3.1.1, thereby nai~ntainir the margin to criticality. Introduction of reactor makeup water into he cJAI:ERT A RCS from th Chemical and Volume Control System mixing te is not permitte hen no RCS loop is in operation.A Boron dilution with coolant at boron concentrations less thia quired to assur J -I,T I' ,,-A i be ecause a uniform concentration distribution throughout the RCS cannot be ensur d

-mew 02-0o1 0 when in natural circulation; and

b. Core outlet temperature is maintained at least 10OF below saturation temperature, so that no vapor bubble may form d possibly cause a natural circulation flow obstruction.

Note 2 allows one RHR loop to be inoperable for a peniof up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, provided that the other RHR loop is OP LE and in

• operation. This permits periodic survetests to be performed on the erable loop during the ime when such testing is safe and Note 3 requires that the secondary side water temperature of each SG be

< 50°F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with any RCS cold leg temperature < 2750 F.

This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. A SG can perform as a heat sink via natural circulation when it has an adequate water level and is OPERABLE.

APPLICABILITY In MODE 5 with RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of RHR provides sufficient circulation 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 > 86%. I (continued)

CALLAWAY PLANT B 3.4.7-3 Revision 6

TSB CN 02-016 INSERT A operation of CVCS resin vessels configured with resin for dilution during normal operation is not permitted, and operation of the purge line associated with flushing the CVCS letdown radiation monitor is not permitted INSERT Al Note that CVCS resin vessels include the resin vessels of its subsystem the BTRS.

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES APPLICABILITY Operation in other MODES is covered by:

(continued)

LCO 3.4.4, "RCS Loops - MODES 1 and 2";

LCO 3.4.5, "RCS Loops - MODE 3";

LCO 3.4.6, "RCS Loops - MODE 4";

LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled";

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

ACTIONS If one RHR loop is inoperable and the required SGs have secondary side wide range water levels < 86%, redundancy for heat removal is lost.

Action must be initiated Immediately to restore a second RHR loop to OPERABLE status or to restore the required SG secondary side water levels. Either Required Action A.1 or Required Action A.2 will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

If no RHR loop is in operation, except during conditions permitted by Notes I and 4, or if no loop is OPERABLE, all operations Involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RHR loop to OPERABLE status and operation must be Initiated. To prevent inadvertent criticality during a boron dilution, forced circulation from at least one RCP is required to provide proper mixing. Suspending the introduction of coolant, 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 operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentration meeting the minimum SDM maintains acceptable margin to subcritical operations.

R from thermitted the Cal and Introduction Volume Control Systemmakeup of reactor tee is into mixing water n when no RCS p Is in operation, consistent with Require ction C.1 0 LCO 3.3.9, "Bor Dilution Mitigation System (BDMS). The immediafe Completion Times reflect the importance of maintaini operation for jeat removal.

CALLAWAY PLANT B 3.4.7-4

TSB CN 02-016 INSERT A dilution during normal operation of CVCS resin vessels configured with resin for with flushing the line associated operation is not permitted, and operation of the purge CVCS letdown radiation monitor is not permitted

RCS Loops. MODE 5, Loops Not Filled B 3.4.8 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.8 RCS Loops - MODE 5, Loops Not Filled BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat generated In the fuel, and the transfer of this heat to the component cooling water via the residual heat removal (RHR) heat exchangers. The steam generators (SGs) are not available as a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid.

In MODE 5 with loops not filled, only RHR pumps can be used for coolant circulation. The number of pumps in operation can vary to suit the operational needs. The Intent of this LCO is to provide forced flow from at least one RHR pump for decay heat removal and transport and to require that two paths be available to provide redundancy for heat removal.

APPLICABLE In MODE 5, RCS circulation is considered in the determination of the time SAFETY available for mitigation of the accidental boron dilution event. The flow ANALYSES provided by one RHR loop is adequate for decay heat removal.

The operation of one RCP in MODES 3, 4, and 5 provides adequate flow to ensure mixing, prevent stratification, and produce activty changes during RCS boron concentration re ions. Th ea change rate associated with boron reductn* °will, thereforerbe withi he transient mitigation capability of the Bor n Dilution Mitigation System (BDMS). With no reactor coolant loop n operation in either MODES 3, or 5, boron dilutions must be termin d and dilution sources Isolated.

The boron dilution analysis in thes ODES akes credit for the mixing volume associated with having at ast one actor coolant loop in operation. LCO 3.3.9, uBoron Dil tion Mitiga on System (BDMS),"

contains the requirements for the BDMS.

RCS loops in MODE 5 (loops not led) satis s Criterion 4 of .Oto 10CFR5O.36(c)(2)(ii). X ~

LCO The purpose of this LCO is to r quire that at least two RHR loops be OPERABLE and one of these loo -be in operation. An OPERABLE loop is one that has the capability of tran erring heat from the reactor coolant at a controlled rate. Heatcannot be moved via the RHR System unles forced flow is used. A minimum of o running RHR pump meets the CALLAWAY PLANT B 3.4.8-1 Revision 6

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES LCO LCO requirement for one loop in operation. An additional RHR loop is (continued) required to be OPERABLEi t Singlee Note mt l H up o ermvdfo prton for: 1.ho r.

prohibits boron dilution with coolant at boron concentrations less than required to assure the SDM of ICO 3.1.1 is maintained or draining operations when RHR forced flow is stopped. Introduction of reactor makeup water into"the RCS from the Chemical and Volume Control jfyr system able mixing is not teeflor ntopovies stoppqingd when no RCS loop is inelmtdt permitteD bohRRpmsaet operation.

APPLICAIituationsMD provided that otherntfiled theloutag whenthe loop is OPE tisshor reqir coreouleration.emperatur and This permits An OPERABLE RHR loopis comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger.

RHR pumps are OPERABLE if they are capable of being powered and are LCO~ ~ ~ OE5~~~~'0 3.s7 oosFle" eraLos-mLCO3..6 "es iduflal Hea ýtoRemefmona theRindCopealeant urn the only Cimeulatinths LwWtest resafe" (MOdposil. E n covered by:

LCO 3.4.4, "RCS Loops - MODES 1 and 2";

LCO 3.4.5, "RCS Loops - MODE 3";

LCO 3.4.6, "RCS Loops - MODE 4";

nts LLoopsILCO APPLICA -

MODE 5 ,

wihloops 3.4.7, "RCS Loops - MODEthi5,frmODE ntfilled, Filled"; coehe reuremev Loopsrequiress LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).

Since LCO 3.4.8 contains Required Actions with immediate Completion Times, It is not permitted to enter LCO 3.4.8 from either LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled" or from MODE 6 unless the requirements of LCO 3.4.8 are met.

(c-ontined CALLAWAY PLANT B 3.4.8-2 Revision 6

TSB CN 02-016 INSERT A operation of CVCS resin vessels configured with resin for dilution during normal operation is not permitted, and operation of the purge line associated with flushing the CVCS letdown radiation monitor is not permitted INSERT Al Note that CVCS resin vessels include the resin vessels of its subsystem the BTRS.

RCS Loops - MODE 5, Loops Not Filled B 3.4.8 BASES (Continued)

ACTIONS A.1 If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion lime reflects the importance of maintaining the availability of two paths for heat removal.

B.1 and B.2 If no required RHR loops are OPERABLE or in operation, except during conditions permitted by Note 1, all operations Involving Introduction of coolant, into the RCS. with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation. Boron dilution requires forced circulation from at least one RCP for proper mixing so that inadvertent criticality can be prevented. Suspending the Introduction of coolant, 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 operation. With coolant added without forced circulation, unmixed coolant cobodu he core, however coolant added with boro- -centration eting the minimum SDM maintains acceptable argin to subenctical operations.

Introduction of reactor makeup wate not into the RCS from permittedjp loops RCS;=

henthetheChemical and Volume Control System mixing tee i* n o e a io , o s sent with C S loop i s are not filled or w hen no R o o iui n iig~ation System Required Action C.1 of LCO 3.3.9 ," lm elctsthe importance of (BDMS)." The immediate Comple re vl h cin to restore must. on oo-Ot I~i maintaining operation for heat PE R ABL Es t us and per a i co t n e u til one l ooP is r es t or e t o° O

REUIRVEMELNTS 1 o rst a nel o s Inopera tion.

RERUM N S This SR requires verification e ve eature, or pump status Verification may include flow ratetm e lwispoiig.heat removal.

monitoring, which help ensure th at i i n o ' er n t e n iation s a n d/

Th e Fre qu en cy of 12 ho urs is s uf the control ron alarms available to the operator in performance.

OPERABLE ensures that an Verification that a second RHR pump is ifneeded, to maintain decay additional pump can be placed in operation, (continued)

CALLAWAY PLANT B 3.4.8-3 Revision 6

TSB CN 02-016 INSERT A operation of CVCS resin vessels configured with resin for dilution during normal operation is not permitted, and operation of the purge line associated with flushing the CVCS letdown radiation monitor is not permitted

Unborated Water Source Isolation Valves

• ,f * *B 3.9.2 APPLICABLE

. The possibility of an inadvertent boron dilution event (Ref. 1) occurring SAFETY during MODE 6 refueling operations is precluded by adherence to this ANALYSES LCO, which requires that potential dilution sources be isolated. Closing

~the required valves during refueling operations prevents the flow of unborated water to the filled portion of the RCS. The valves are used to isolate unborated water sources These valves have the potential to (t allow dilution of the RCreoron concentration in MODE 6. Bya bti isolatin~unborated water soures, af fety analysis for an uncontrolled the Standard Reviewolimt Planr boron dilution accident andwRCS in accordance

6. belowthe.

Te 2) is not (Ref. eRCS requed for MODE B*bson)*ocentration satisfies Coterln 2 of ."1 APPLICABILITY In MODE 6, ed isolaeundto this LCO waabler to prevent an inadvertent boron ad vii lvshaeted.etilt applicable Theein is soure so--ti ujrte wate sources a(yaayi o nucontrolled, CAlWA PII an d inacorane 3..2- -. eStndr Review slan0 ANAYE dilution event by ensuring isolation of all sources of unborated water to CALLorAaWA Yter PoE the RC S to 0fcide analves areRevisionlution wsed

TSB CN 02-016 INSERT 1 Bases 3.9.2 During MODE 6 operations, all unborated water source isolation valves that are connected to the Reactor Coolant System (RCS) must be closed to prevent unplanned boron dilution of the reactor coolant. The isolation valves must be secured in the closed position.

Boron dilution in Mode 6 could occur from reactor makeup water sources containing unborated water or boron dilution could also occur from ion exchange resin contained within the CVCS and BTRS for water chemistry control. Note that CVCS resin vessels include the resin vessels of its subsystem the BTRS. While the purpose of the resin is to control water impurity levels and clarity, it may remove a slight amount of boron from the system's water stream when the resin is initially placed in service. The purified water stream is returned to the RCS at a slightly lower boron concentration until the resin reaches chemical equilibrium and is no longer a dilution source. Operations involving the conditioning and management of resin are permitted in Mode 6 because the amount of global RCS boron removed from the RCS during the equilibrium period can be calculated beforehand. As such, these operations are conducted as planned dilutions using administrative controls.

In Mode 6, operation of the CVCS letdown gamma radiation detector SJREOOI is not required. However, flushing the detector with unborated water for maintenance during Mode 6 would be performed as a planned dilution using administrative controls.

Some unborated water sources, that are not connected to the RCS in their as-built configuration, can be temporarily configured (ex. flexible hose connected) to provide a direct path for unborated water into the RCS. A routine Mode 6 activity requiring this temporary configuration is decontamination of the refueling pool. However, administrative controls will limit the volume of unborated water that can be added to the refueling pool for decontamination or planned dilution activities, in order to prevent diluting the refueling pool and RCS below the specified limits (Ref. 3). (See the Bases for LCO 3.9.1, "Boron Concentration".

Callaway reactivity management provides systematic direction to control activities that impact plant reactivity. This means precluding unplanned or uncontrolled occurrences impacting reactivity (positive or negative), including inadvertent boron dilution events.

Plant operations may require planned boron management evolutions. Reactivity management provides provisions that any planned activities and evolutions with the potential to impact reactivity are identified; are conducted in a controlled manner; are evaluated to ensure the effects of reactivity changes are known and monitored; and are performed by plant personnel briefed so that any anomalous indications are met with

TSB CN 02-016 INSERT 1 continued Bases 3.9.2 conservative action. Specifically, administrative controls include: (1) adherence to approved procedures; (2) planned evolutions and briefings; (3) calculations for the impact on boron concentrations prior to evolutions; (4) reviews by licensed operators; (5) valve identification with temporary tagging; and (6) prompt verification that unborated water source isolation valves are closed and secured after completion of any planned dilution activities.

TSB CN 02-016 INSERT 2 Bases 3.9.2 This LCO requires that unborated water source flow paths connected to the RCS be isolated to prevent unplanned boron dilution during MODE 6 and thus avoid a reduction in SDM. The unborated water source isolation valves must be closed and secured.

Isolation valves connected to the RCS include: (1) unborated reactor makeup water (BGV0178 and BGV0601), (2) CVCS resin vessels configured with resin for dilution during normal operation (BG8522A, BG8522B, BGV0039, BGV0043, BGV005 1, and BGV0055) and (3) unborated flushing water for the CVCS letdown radiation monitor (SJV0703).

Some unborated water sources, that are not connected to the RCS in their as-built configuration, can be temporarily configured (ex. flexible hose connected) to provide a direct path for unborated water into the RCS. Isolation valves not connected to the RCS, but modified via temporary configuration to provide a direct path for unborated water into the RCS include: (1) BLVO078, (2) BLVO079 and (3) BLVO055.

This LCO is modified by a NOTE to allow unborated water sources to be unisolated under administrative controls for planned boron dilution evolutions. The NOTE also permits unborated water sources, not connected to the RCS in their as-built configuration, but temporarily. configured (ex. flexible hose connected) to provide a direct path for unborated water into the RCS, to be used under administrative controls for planned boron dilution evolutions.

During refueling activities, it may be necessary for an unborated water source to be unisolated. Based on License Amendment 97, 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 in this case are identified in TS Bases 3.9.1 and are applicable to the LCO NOTE exception for the following specific isolation valves: BLVO078, BLVO079 and BLVO055.

In Mode 6, other plant activities may require unborated water sources to be unisolated under administrative controls for planned boron dilution evolutions. The LCO NOTE allows an isolation exception for use of the reactor makeup water system, for operation of CVCS resin vessels, and for maintenance to flush the CVCS letdown gamma radiation detector SJRE0 with unborated reactor makeup water. The administrative controls include plant reactivity management requirements and operational awareness and are described in the TS Bases 3.9.2 Background. These requirements are applicable to the LCO NOTE exception for the following specific isolation valves: BGVO178, BGV0601, BG8522A, BG8522B, BGV0039, BGV0043, BGV0051, BGV0055 and SJV0703.

Unborated Water Source Isolation Valves B 3.9.2 BASES (Continued)

ACTIONS The ACTIONS table has been modified by a Note that allows separate Condition entry for each unborated water source Isolation valve.

A.1 Continuation of CORE ALTERATIONS is contingent upon maintaining the unit in compliance with this LCO. With any valve used to isolate unborated water sources not secured in the closed position, all operations CORE curin. t valseln. The e envolving n

Complettio iaetlyoAiened.aTe fomperformanT e of Reqdiaed l I DuCondtheiotetahavibengof mdiluted byaNthe boronquconraatoReouithe perform.

sc e opeed Condition A oent whenever nnenoperatort ismntaeta entered.t vampsle cre te on h position.

tootin adetntdilaina othreor coolantsaplboro boncnraton uflinient denden on theunborted at(csonaionuelve is aintinin CALLAWAY PLANT B 3.9.2-2 Revision 0

ak ater Source Isolation Valves B 3.9.2 ASES (Continued)

REQUIREMENTS are to be secured closed to isolate possible dilution at he likelihood of a significant reduction in the ron concentration during MODE 6 operations is remote due to the large mass of borated water in the refueling pool nd the fact that all unborated water sources are isolated, precluding a dilltion. The boron concentration is checked every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during MODE 6 under SR 3.9.1.1. This

.9 m ,,,Surveillance demonstrates that the valves lre closed through a system WA walkdown. The 31 day Frequency is ba on engineering judgment and is considered reasonable in view of other dministrative controls that will ensure that the valve opening is an unlike possibility.

REFERENCES 1. FSAR, Section 15.4.6.

101 dO\ 2. 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

TSB CN 02-016 INSERT 3 Isolation valves for unborated reactor makeup water (BOV0178 and BGV0601), CVCS resin vessels configured with resin for dilution during normal operation (BG8522A, BG8522B, BGV0039, BGV0043, BGV005 1, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor (SJV0703)

I j ULNRC- 05345 ATTACHMENT 5

SUMMARY

OF REGULATORY COMMITMENT

44 41 .

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies those actions committed to by AmerenUE, Callaway Plant in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Dave E. Shafer, Superintendent, Licensing at AmerenUE, Callaway Plant, (314) 554-3104.

COMMITMENT Due Date/Event The proposed amendment will be implemented within 90 days 90 days following NRC after approval approval Administrative controls consisting of written procedures will be 90 days following NRC established prior to the implementation of the proposed changes. approval The procedural controls require that in MODE 6 each valve used to isolate unborated water sources shall be secured in the closed position.

Administrative controls consisting of written procedures will 90 days following NRC ensure prompt verification that unborated water source isolation approval valves are closed and secured after completion of any planned boron dilution activities.

Administrative controls consisting of written procedures will be 90 days following NRC established prior to the implementation of the proposed changes. approval The procedural controls require that when both BDMS trains are inoperable, or when no reactor coolant loop is in operation, and when in MODE 2 (below P-6 setpoint), 3, 4, and 5, each valve used to isolate unborated water sources shall be secured in the closed position.

Identified TS Bases and Callaway FSAR changes will be During implementation incorporated into the TS Bases and the Callaway FSAR during of the amendment implementation of the amendment.