Text

Application for Amendment to Facility Operating License NPF-30 OL1283 - Revision of Technical Specifications 3.3, 3.7, and 3.8
	ML081630016
Person / Time
Site:	Callaway
Issue date:	06/03/2008
From:	Graessle L; AmerenUE, Union Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ULNRC-05494
	Download: ML081630016 (182)
	v • d • e

AmerenUE PO Box 620 Cal/away Plant Fulton, MO 65251 June 3, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC-05494 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC CO.

APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NPF-30 W"Amle/i/UE 0L1283 - REVISION OF TECHNICAL SPECIFICATIONS 3.3, 3.7, AND 3.8 AmerenUE herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant.

The proposed changes will revise Technical Specifications (TSs) 3.3.7, 3.3.8, 3.7.10, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This amendment will:

a. Delete MODES 5 and 6 from the LCO Applicability for the Control Room Emergency Ventilation System and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively). It will be shown that the event that heretofore required these LCOs to be applicable in MODES 5 and 6 (waste gas decay tank rupture) requires no mitigation at Callaway in order to meet GDC 19.

b. Adopt NRC-approved traveler TSTF-36-A for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This change will add an exclusion from LCO 3.0.3 that recognizes that irradiated fuel movement in the fuel building is independent of reactor operation in MODES 1-4 and defaulting to LCO 3.0.3 would force an unnecessary plant shutdown.

c. Add a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not only during MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE in which the plant is operating.

Attachments 1 through 6 provide the Evaluation, Markup of Technical Specifications, Retyped Technical Specifications, Proposed Technical Specification Bases Changes, FSAR markups, and an informational courtesy copy of TSTF-36-A, Revision 4 (with NUREG-1431 markups only), respectively, in support of this amendment request. Attachments 4 through 6 are provided for information only.

aeor a subsidiaryof Ameren Corporation

ULNRC-05494 June 3, 2008 Page 2 Final Bases changes will be processed under our program for updates per TS 5.5'14, "Technical Specifications Bases Control Program," at the time this amendment is implemented. Final FSAR changes will be processed per the update requirements of 10 CFR 50.71 (e). No commitments are contained in this amendment application.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the attached licensing evaluations and have approved the submittal of this amendment application.

AmerenUE requests approval of this LAR prior to February 1, 2009.

AmerenLUE further requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.

In accordance with 10 CFR 50.91, a copy of this amendment application is being provided to the designated Missouri State official. If you have any questions on this amendment application, please contact me at (573) 676-8129, or Mr. Scott Maglio at (573) 676-8719.

I declare under penalty of perjury that the foregoing is true and correct.

Very truly yours, Executed on: .,J&e.. ,c'o.

LA-4>aLh Luke H. Graessle Manager, Regulatory Affairs

ULNRC-05494 June 3, 2008 Page 3 GGY/nls Attachments 1 - Evaluation 2 - Markup of Technical Specifications 3 - Retyped Technical Specifications 4 - Proposed Technical Specification Bases Changes (for information only) 5 - FSAR markups (for information only) 6 - Informational copy of TSTF-36-A, Revision 4 (with NUREG-1431 markups only)

ULNRC-05494 June 3, 2008 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. Elmo E. Collins, Jr.

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. Mohan C. Thadani (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738

ULNRC-05494 June 3, 2008 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed).

Electronic distribution for the following can be made via Tech Spec.ULNRC Distribution:

C. D. Naslund A. C. Heflin T. E. Herrmann L. H. Graessle G. A. Hughes S. A. Maglio S. L. Gallagher L. M. Belsky (NSRB)

T. B. Elwood G. G. Yates Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU)

Mr. Scott Bauer (Palo Verde)

Mr. Stan Ketelsen (PG&E)

Mr. Scott Head (STP)

Mr. John O'Neill (Pillsbury, Winthrop, Shaw, Pittman LLP)

Missouri Public Service Commission Mr. Floyd Gilzow (DNR)

Page 1 of 18 EVALUATION

1. DESCRIPTION Page 2

2. PROPOSED CHANGES Page 2

3. BACKGROUND Page 3

4. TECHNICAL ANALYSIS Page 7

5. REGULATORY SAFETY ANALYSIS Page 12 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION Page 13 5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA Page 15

6. ENVIRONMENTAL CONSIDERATION Page 18

7. REFERENCES Page 18

8. PRECEDENTS Page 18 Page 2 of 18 EVALUATION

1.0 DESCRIPTION

The proposed changes in this amendment application would revise Technical Specifications (TSs) 3.3.7, 3.3.8, 3.7.10, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This amendment will:

a. Delete MODES 5 and 6 from the LCO Applicability for the Control Room Emergency Ventilation System and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively). It will be shown that the event that heretofore required these LCOs to be applicable in MODES 5 and 6 (waste gas decay tank rupture) requires no mitigation at Callaway in order to meet GDC 19.

b. Adopt NRC-approved traveler TSTF-36-A for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This change will add an exclusion from LCO 3.0.3 that recognizes that irradiated fuel movement in the fuel building is independent of reactor operation in MODES 1-4 and defaulting to LCO 3.0.3 would force an unnecessary plant shutdown.

c. Add a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not onlyduring MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE inwhich the plant is operating.

2.0 PROPOSED CHANGE

S This amendment application contains three groups of related changes.

2.1 Control Room Emergency Ventilation System (CREVS) and Actuation Instrumentation TS 3.3.7, "Control Room Emergency Ventilation System Actuation Instrumentation,"

and TS 3.7.10, "Control Room Emergency Ventilation System (CREVS)," are revised to delete MODE 5 and MODE 6 from the LCO Applicability. The specific TS changes are as follows:

, Condition E of TS 3.3.7 is revised to delete "in MODE 5 or 6, or" and the comma after "CORE ALTERATIONS" is also deleted.

" TS Table 3.3.7-1 is revised to delete "5, 6," under the APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS column for Functions 1, 2, and 3. An editorial correction is made to add a period at the end of Table footnote (c).

Page 3 of 18

" The LCO Applicability forTS 3.7.10 is revised to delete "5, and 6," and the word "and" is inserted between "3," and "4."

Conditions D and E of TS 3.7.10 are revised to delete "in MODE 5 or 6, or."

2.2 TSTF-36-A TS 3.3.8, "Emergency Exhaust System Actuation Instrumentation," TS 3.7.13, "Emergency Exhaust System (EES)," TS 3.8.2, "AC Sources - Shutdown," TS 3.8.5, "DC Sources - Shutdown," TS 3.8.8, "Inverters - Shutdown," and TS 3.8.10, "Distribution Systems - Shutdown" are revised to add an ACTIONS Note per NRC-approved TSTF-36-A Revision 4 (copy provided in Attachment 6). This Note reads:

"LCO 3.0.3 is not applicable."

2.3 Electrical Power Systems in MODES 5 and 6 (Shutdown Conditions)

TS 3.8.2, "AC Sources - Shutdown," TS 3.8.5, "DC Sources - Shutdown," TS 3.8.8, "Inverters - Shutdown," and TS 3.8.10, "Distribution Systems - Shutdown" are revised to add the following to the LCO Applicability:

"During movement of irradiated fuel assemblies."

The first group of changes is based on a radiological consequence (dose) calculation for an unmitigated waste gas decay tank rupture. The second group of changes is based on an NRC-approved traveler that is reflected in the current Revision 3.1 of the Standard Technical Specifications (STS) for Westinghouse NSSS plants, NUREG-1431. The third group of changes is a more restrictive change that recognizes the electrical power system requirements that should be in place even if the plant is not in any MODE per the Definitions of TS 1.1 (no fuel in the reactor vessel).

The TS markups and retyped pages are provided in Attachments 2 and 3, respectively.

Corresponding TS Bases changes are provided for information only in Attachment 4.

3.0 BACKGROUND

This section provides background information on the systems affected by the proposed, TS changes.

Attachment 1 Page 4 of 18 3.1 Control Room Emergency Ventilation System (CREVS) and Actuation Instrumentation The CREVS provides a protected environment from which the control room operators can control the plant following an uncontrolled release of radioactivity. The CREVS consists of two independent, redundant trains that pressurize, recirculate, and filter the control room air. Each CREVS train consists of a filtration system train and a pressurization system train. Each filtration system train consists of a fan, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Each pressurization system train consists of a fan, a moisture separator, an electric heater, a HEPA filter, an activated charcoal adsorber

.section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Ductwork, valves or dampers, and instrumentation also form part of the CREVS system.

The CREVS is an emergency system which may also operate during normal plant operation. Actuation of the CREVS by a Control Room Ventilation Isolation Signal (CRVIS) places the system in the emergency mode of operation. Actuation of the system to the emergency mode of operation closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the control room air through the redundant trains of HEPA filters and charcoal adsorbers. The emergency (CRVIS) mode also initiates pressurization and filtered ventilation of the air supply to the control room.

The CREVS actuation instrumentation consists of two gaseous radiation channels in the control room air intake. A high radiation signal from either of these channels will initiate both trains of the CREVS. The control room operator can also initiate CREVS trains by manual switches in the control room. The CREVS is also actuated by a Phase A containment isolation signal, a fuel building ventilation isolation signal (FBVIS), or a high radiation signal from the containment purge exhaust gaseous radiation channels.

The control room pressurization system draws in outside air, processing it through a particulate filter charcoal adsorber train for cleanup. This outside air is diluted with air drawn from the cable spreading rooms and the electrical equipment floor levels within the control building and distributed back into those spaces for further dilution. The control room filtration units take.a portion of air from the exhaust side of the system, upstream of the outside air intake, for dilution with portions of the exhaust air from the control room air-conditioning system and processes it through the control room filtration system adsorption train for additional cleanup. This air is then further diluted with the remaining control room air-conditioning system return air, cooled, and supplied to the control room. This process maintains the control room under a positive pressure of 1/8 inch water gauge with respect to the outside atmosphere. This assures exfiltration from the control room, thus preventing any unprocessed contaminants from entering the control room.

Page 5 of 18 The CREVS is designed to maintain the control room environment for 30 days of continuous occupancy after a design basis accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body. Applicable design basis accidents thatcould cause a radioactivity release, and thus demand the safety function provided by CREVS, include a loss of coolant accident (LOCA), steam generator tube rupture (SGTR), fuel handling accident (FHA) inside containment, and FHA in the fuel building. For shutdown conditions, however, only the FHA is of concern and that is the.

event responsible for requiring CREVS and its actuation instrumentation to be OPERABLE during movement of irradiated fuel assemblies. Evaluation Section 4.1 discusses the postulated waste gas decay tank rupture event.

3.2 Emergency Exhaust System (EES) and Actuation Instrumentation The EES consists of two independent and redundant trains. Each train consists of a heater, a prefilter, a HEPA filter bank, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, dampers, and instrumentation also form part of the system. A second bank of HEPA filters follows the adsorber section to collect carbon fines.

The EES serves both the auxiliary building and the fuel building. Following a safety injection signal (SIS), safety-related dampers isolate the auxiliary building and the EES exhausts potentially contaminated air due to leakage from ECCS. systems. The EES can also filter airborne radioactive particulates from the area of the spent fuel pool following an FHA in the fuel building.

As described in FSAR Section 9.4.2, the EES collects and processes the airborne particulates in the fuel-building in the event of an FHA. In the event of a LOCA, the EES processes the atmosphere of the auxiliary building. The EES is on standby for an automatic start following receipt of a fuel building ventilation isolation signal (FBVIS) or an SIS.

Upon receipt of an FBVIS initiated manually or automatically upon a high radiation signal (gaseous), normal air discharges from the building are terminated, the fuel building is isolated, the stream of ventilation air discharges through the system filter trains, and a CRVIS is generated. High gaseous radiation, monitored by two channels in the fuel building exhaust, provides an FBVIS. Both EES trains are initiated by high radiation detected by either channel. High radiation detected by either monitor initiates fuel building isolation, starts the EES, and initiates a CRVIS. These actions function to prevent exfiltration of contaminated air by initiating filtered exhaust, which imposes a negative pressure on the fuel building. In the FBVIS mode, each train is capable of maintaining the fuel building at a negative pressure of less than or equal to 0.25 inches water gauge relative to the outside atmosphere.

Page 6 of 18 3.3 Electrical Power Systems in MODES 5 and 6 (Shutdown Conditions)

AC Sources The Class 1E AC sources consist of the offsite power sources (preferred power sources, normal and alternate) and the onsite standby power sources (train A and train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17, the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the engineered safety feature (ESF) systems. The onsite Class 1E AC distribution system is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG. Offsite power is supplied to the plant .switchyard from the transmission network by four transmission lines. From the switchyard, two electrically and physically separated circuits provide AC power, through ESF transformers, to the 4.16 kV ESF buses. Automatic load tap changers associated with the ESF transformers, as well as associated capacitor banks, provide voltage regulation for the preferred sources in the event of changing switchyard voltage.

An offsite circuit consists of all breakers, transformers, voltage regulation equipment, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF buses. The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. DGs NEO1 and NE02 are dedicated to ESF buses NBO1 and NB02, respectively. A DG starts automatically on an SIS (initiated by low pressurizer pressure, low steam line pressure, or high containment pressure signals) or on an ESF bus undervoltage signal. After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an SIS.

The DGs will also start and operate in the standby mode without tying to the ESF bus on an SIS alone.

DC Sources The DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety-related equipment and preferred AC vital bus power (via inverters). As required by 10 CFR 50, Appendix A, GDC 17, the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure.

The 125 VDC electrical power system consists of two independent and redundant Class 1E DC electrical power subsystems (train A and train B). Each DC electrical subsystem consists of two 125 VDC batteries, two battery chargers, one swing battery charger and all the associated control equipment and interconnecting cabling. During normal operation, the 125 VDC load is powered from the battery chargers with the batteries Page 7 of 18 floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries. The train A and train B DC electrical power subsystems provide the control power for associated Class 1E AC power load groups, 4.16 kV switchgear, and 480 V load centers. The DC electrical power subsystems also provide DC electrical power to the inverters, which in turn power the AC vital buses.

Inverters The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses. The inverters are normally powered from the station battery; however, a backup AC source provides another source of inverter output via a static switch internal to the inverter. An alternate source of power to the AC vital buses is provided from Class 1E constant voltage transformers. The station battery provides an uninterruptible power source for the instrumentation and controls for the Reactor Trip System (RTS) and the Engineered Safety Feature Actuation System (ESFAS).

Distribution Systems The onsite Class 1E AC, DC, and AC vital bus electrical power distribution systems are divided by train into'two redundant and independent AC, DC, and AC vital bus electrical power distribution subsystems as defined in TS Bases Table B 3.8.9-1. Train A is associated with AC load group 1; train B, with AC load group 2. The AC electrical power subsystem for each train consists of a 4.16 kV ESF bus and 480 V buses and load centers. Each 4.16 kV ESF bus has one separate and independent offsite source of power as well as a dedicated onsite DG source. Each 4.16 kV ESF bus is normally connected to a preferred offsite source. After a loss of the preferred offsite power source to a 4.16 kV ESF bus, the onsite emergency DG supplies power to the bus. A transfer to the alternate offsite source is accomplished by manually repositioning breakers, if required. Control power for the 4.16 kV breakers is supplied from the Class I E batteries.

The 120 VAC vital buses are arranged in two load groups per train and are normally powered through the inverters from the 125 VDC electrical power subsystem. TS Bases B 3.8.7 has further information on the 120 VAC vital system.

The 125 VDC electrical power distribution system is arranged into two buses per train.

TS Bases B 3.8.4 has further information on the 125 VDC electrical power subsystem.

4.0 TECHNICAL ANALYSIS

The following provides further technical analysis and discussion of the three groups of related changes in the order presented in Evaluation Sections 1.0 and 2.0 above.

Page 8 of 18 4.1 Deletion of MODES 5 and 6 from TS 3.3.7 and TS 3.7.10 -

Control Room Radiological Consequences of a Waste Gas Decay Tank Rupture The STS and STS Bases for Westinghouse plants, NUREG-1431, havebrackets around the MODE 5 and MODE 6 Applicability in TS 3.3.7 and TS 3.7.10. Those brackets indicate that individual licensees would adopt MODES 5 and 6 if the waste gas decay tank rupture requires control room staff protection. If that event requires no mitigation or control room habitability protection, then MODES 5 and 6 need not be required in the LCO Applicability for TS 3.3.7 and TS 3.7.10.

The waste gas decay tanks are designed to permit the decay of radioactive gases as a means of reducing or preventing the release of radioactive materials to the atmosphere.

For this accident it is postulated that there is an accidental release of the contents of one of the waste gas decay tanks resulting from a rupture of the tank or from another cause, such as operator error or valve malfunction. The gaseous waste processing system is so designed that the tanks are isolated from each other during use, limiting the quantity of gas released in the event of an accident by preventing the flow of radioactive gas between the tanks. The principal radioactive components of the waste gas decay tanks are the noble gases krypton and xenon, the particulate daughters of some of the krypton and xenon isotopes, and trace quantities of halogens. The maximum amount of waste gases stored in any one tank occurs after a refueling shutdown, at which time the waste gas decay tanks store the radioactive gases stripped from the reactor coolant. The maximum content of a waste gas decay tank is conservatively assumed for the purpose of computing the noble gas inventory available for release. Rupture of the waste gas decay tank is assumed to occur immediately upon completion of the waste gas transfer, releasing the entire contents of the tank to the radwaste building. For the purposes of evaluating the accident, it is assumed that all the activity is immediately released directly to the environment during the 2-hour period immediately following the accident, with no credit taken for decay, holdup in the radwaste building, mixing, or the operation of the radwaste building ventilation system's non-safety charcoal adsorbers.

Offsite doses for a waste gas decay tank rupture are discussed in FSAR Section 15.7.1 and are reported in FSAR Table 15.7-4; however, that table does not report control room doses. A calculation has been performed with no credit taken for the mitigation capability of the CREVS. Using dose conversion factors (DCFs) from FSAR Table 15A-4 (including ICRP-30 for thyroid DCFs and Federal Guidance Report 12 for whole body DCFs), control room thyroid and whole body doses have been calculated for the duration of a waste gas decay tank rupture.

The calculated values are two orders of magnitude less than the regulatory limits for control room occupants; the regulatory limits are 30 rem thyroid and 5 rem whole body.

Attachment 1 Page 9 of 18 The NRC Staff has provided a set of considerations that should be addressed regarding control room habitability analyses performed in support of license submittals. These considerations were provided in Regulatory Issue Summary (RIS) 2001-19, "Deficiencies in the Documentation ofDesign Basis RadiologicalAnalyses Submitted in Conjunction with License Amendment Requests."

The following discussion addresses the issues from RIS 2001-019:

a. The control room design is often optimized for the DBA LOCA, and the protection afforded for other accident sequences may not be as advantageous. For example, in most designs, control room isolation is actuated by engineered safety feature (ESF) signals such as containment high pressure or safety injection (SI),

or radiation monitors, or both. For accidents that rely on radiation monitor actuation, there may be a time delay in isolation that would not occur for the immediate SI signal that would result from a LOCA. In such cases, contaminated air would enter the control room for a longer period preceding isolation than it would for a LOCA.

AmerenUE Response:

As stated above, initiation of control room isolation was intentionally not modeled in the analysis for this amendment.

b. The configuration of radiation monitors has an impact on their sensitivity.

Ideally, the radiation monitors would be located outside in air ventilation intake ductwork. However, there are system designs that place the radiation monitor in recirculation ductwork or downstream of filters. There are also designs that use area radiation monitors. In these latter designs, the contaminated air continues to build up in the control room volume until the concentration is large enough to actuate the radiation monitor.

AmerenUE Response:

Callaway plant's control room intake radiation monitors are located in the normal intake ductwork. These radiation monitors measure the concentration of outside air and are not downstream of any filters. However, no credit for these radiation monitors was taken in the analysis for this amendment.

c. In some cases, control room radiation monitor setpoints may have been based on external exposure concerns, for example, 2.5 mremlhour, rather than thyroid dose from inhalation. The airborne concentration of radioiodines will likely cause elevated thyroid doses before reaching the concentration of all radionuclides necessary to alarm the monitor. This condition is typically seen with accidents that involve a high iodine-to-noble-gas ratio, such as main steam line breaks in PWRs.

Page 10 of 18 AmerenUE Response:

Initiation of control room isolation was intentionally not modeled in the analysis for' this amendment.

d. The distance between the control room and the release point, and the associated wind sectors, may be different for each postulated accident. These differences are usually not significant with regard to offsite doses, but may be significant for control room assessments because of the shorter distances typically involved. The X/Q for the DBA LOCA may not be applicable to other DBAs. A ground-level release associated with a non-LOCA event may be more limiting than the elevated release associated with LOCAs at plants With secondary containments or enclosure buildings.

AmerenUE Response:

The analysis for this amendment used the 0-8 hour control room X/Q value currently provided in Callaway FSAR Table 15A72 for the containment leakage dose pathway, which is considered to be a ground level release. This is the most limiting value available from that table.

e. Licensees should ensure that assumptions regarding control room isolation and infiltration can be supported by appropriate test results or engineering evaluations.

Twenty percent of the licensed power reactors have performed tracer gas tests of control room integrity. All of the tests performed identified as-found infiltration rates greater than those assumed in the design basis calculations.

AmerenUE Response:

AmerenUE responded separately to NRC Generic Letter 2003-01 via ULNRC-04885 dated August 11, 2003 and the license amendment request submitted via ULNRC-05463 dated January 14, 2008. Control room in-leakage will be resolved separately from the license amendment requested herein.

f. The use of personal respirators or the use of potassium iodide (KI) as a thyroid prophylaxis should not be credited as a substitute for process controls or other engineering controls as discussed in 10 CFR 20.1702.

AmerenUE Response:

The analysis for this amendment does not credit respirators or potassium iodide.

Page 11 of 18 Radiological Consequence Conclusions The waste gas decay rupture consequences on control room occupants are much lower than the regulatory limits (30 rem thyroid, 5 rem whole body). Therefore, it can be concluded that mitigation of this event by the CREVS and its actuation instrumentation is not required. TS 3.3.7 and TS 3.7.10 can, therefore, be revised to delete MODES 5 and 6 from the LCO.Applicability.

4.2 TSTF-36-A Change to Add LCO 3.0.3 Exceptions to TS 3.3.8, TS 3.7.13, TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 Technical Specifications 3.3.8 and 3.7.13 currently apply during the movement of irradiated fuel assemblies in the fuel building. The shutdown electrical specifications (TS 3.8.2, TS 3.8.5, TS3.8.8, and TS 3.8.10) are being revised by this amendment application to also apply during the movement of irradiated fuel assemblies (as discussed in Evaluation Section 4.3 below). Irradiated fuel assemblies stored in the fuel building's spent fuel pool may be moved during MODES 1-4 for a variety of reasons, such as:

B.5.b required shuffles e Fuel shuffles during new fuel receipt 0 Fuel movements required to meet TS 3.7.17 and Specification 4.3.1.1 (Region 1 storage vs. Regions 2 and 3)

Healthy fuel inspections as part of the INPO Zero by 2010 Initiative (to improve fuel performance) 0 Inspections of suspected leaking fuel rods

Inspections of lead test assemblies (when used)

Moving fuel to dry cask storage (future activity that might be required) 9 Future spent fuel pool re-racks (if needed).

As discussed in the ACTIONS Bases for TS 3.7.15, "Fuel Storage Pool Water Level," TS 3.7.16, "Fuel Storage Pool Boron Concentration," and TS 3.7.17, "Spent Fuel Assembly Storage," the movement of irradiated fuel assemblies while in MODES 1, 2, 3, and 4 is independent of reactor operations. The LCO 3.0.3 exclusion in TSs 3.7.15 through 3.7.17 should also apply to the TSs in the proposed change. There should be no requirement for the plant to experience the perturbations and shutdown transition risk associated with a forced reactor shutdown per LCO 3.0.3 for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10 in the event of a situation unforeseen by the current TSs or in the event of failure to meet a Required Action or Completion Time in these TSs. These TSs all contain a default Required Action, in the event other Required Actions or Completion Times are not met or for noncompliance with the LCO, to immediately suspend movement of irradiated fuel assemblies. Under a scenario in MODES 1-4 where irradiated fuel movement in the fuel building could not be immediately suspended for some reason, the required response should be to continue taking steps to suspend fuel movement activities, not enter LCO 3.0.3 with its 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for shutdown preparation followed by a shutdown to MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . In this scenario entering LCO Page 12 of 18 3.0.3 would be contrary to safety. The desired plant state is one in which an FHA is no longer possible and irradiated fuel movement has been secured. LCO 3.0.3 is intended to position the plant such that the MODES or specified conditions in the Applicability of a given TS are exited. In the affected TSs, the specified condition "During movement of irradiated fuel assemblies" is not exited by virtue of entering LCO 3.0.3.

NRC approved TSTF-36-A (Reference 7.1) and it was incorporated into Revision 2 of NUREG-143 1. This amendment takes no exceptions to the TS changes approved in TSTF-36-A.

4.3 Electrical Power Systems During Shutdown MODES 5 and 6 The STS and STS Bases for Westinghouse plants, NUREG-1431, include the following specified condition in the LCO Applicability for TS 3.8.2; TS 3.8.5, TS 3.8.8, and TS 3.8.10:

"During movement of [recently] irradiated fuel assemblies."

Callaway is not adopting the bracketed "[recently]" portion of that specified condition at this time; it was the subject of a separate traveler (TSTF-5 1-A). However, the rest of that specified condition will be adopted. During full core offloads, no MODES apply per the TS 1.1 Definitions since there is no fuel in the reactor vessel. However, electrical power requirements should still be observed for the removal of decay heat from the spent fuel pool and to mitigate the potential consequences of a fuel handling accident in the fuel building. While the definition of OPERABLE - OPERABILITY addresses the support to supported system relationships, including all necessary attendant electrical power support, questions can arise with respect to whether normal or emergency power is required during full core offloads. In order to conservatively address this concern, the LCO Applicability in the shutdown electrical power system TSs will adopt this as a prudent, albeit more restrictive, change.

5.0 REGULATORY SAFETY ANALYSIS This section addresses the standards of 10 CFR 50.92 as well as the applicable regulatory requirements and acceptance criteria.

The proposed changes in this amendment application would revise Technical Specifications (TSs) 3.3.7, 3.3.8, 3.7.10, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This amendment will:

a. Delete MODES 5 and 6 from the LCO Applicability for the Control Room Emergency Ventilation System and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively). It will be shown that the event that heretofore required these LCOs to be applicable in MODES 5 and 6 (waste gas decay tank rupture)

Page 13 of 18 requires no mitigation at Callaway in order to meet GDC 19.

b. Adopt NRC-approved traveler TSTF-36-A for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This change will add an exclusion from LCO 3.0.3 that recognizes that irradiated fuel movement in the fuel building is independent of reactor operation in MODES 1-4 and defaulting to LCO 3.0.3 would force an unnecessary plant shutdown.

c. Add a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not only during MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE in which the plant is operating.

5.1 No Significant Hazards Consideration (NSHC)

AmerenUE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," Part 50.92(c), as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes to delete MODES 5 and 6 from the LCO Applicability of Technical Specifications (TSs) 3.3.7 and 3.7.10, adopt TSTF-36-A, and revise the LCO Applicability of the shutdown electrical specifications to be more restrictive does not alter plant design or operation; therefore, these changes will not increase the probability of any accident.

Overall protection system performance will remain within the bounds of the previously performed accident analyses since there are no design changes. All design, material, and construction standards that were applicable prior to this amendment request will be maintained. There will be no changes to any design or operating limits.

The proposed changes will not adversely affect accident initiators or precursors nor adversely alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes will not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended functions to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed changes do not physically alter safety-related systems nor affect the way in which safety-related systems perform their functions.

Page 14 of 18 Deleting MODES 5 and 6 from the LCO Applicability of TSs 3.3.7 and 3.7.10 does not significantly increase the consequences of any accident since it has been demonstrated that the radiological consequences to control room occupants from a waste gas decay tank rupture will remain much less than the regulatory limits with no mitigation from the Control Room Emergency Ventilation System (CREVS) in MODES 5 and 6. The acceptance criteria for this event will continue to be met.

The adoption of TSTF-36-A will not affect the equipment and LCOs needed to mitigate the consequences of a fuel handling accident in the fuel building; however, this change will reduce the chances of an unnecessary plant shutdown due to activities in the fuel building that have no bearing on the operation of the rest of the plant and the reactor core inside the containment building.

The changes to the shutdown electrical specifications will add an additional restriction that is consistent with the objective of being able to mitigate a fuel handling accident during all situations, including a full core offload, in which such an accident could occur.

All accident analysis acceptance criteria will continue to be met with the proposed changes. The proposed changes will not affect the source term., containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. After a postulated release from a waste gas decay tank rapture no CREVS mitigation is required. The applicable radiological dose criteria will continue to be met.

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

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

Response: No There are no proposed design changes nor are there any changes in the method by which any safety-related plant structure, system, or component (SSC) performs its specified safety function. The proposed changes will not affect the normal method of plant operation or change any operating parameters. Equipment performance necessary to fulfill safety analysis missions will be unaffected. The proposed changes will not alter any assumptions required to meet the safety analysis acceptance criteria.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this amendment. There will be no adverse effect or challenges imposed on any safety-related system as a result of this amendment.

Page 15 of 18 The proposed amendment will not alter the design or performance of the 7300 Process Protection System, Nuclear Instrumentation System, or Solid State Protection System used in the plant' protection systems.

The proposed changes to delete MODES 5 and 6 from the LCO Applicability of TSs 3.3.7 and 3.7.10, adopt TSTF-36-A, and revise the LCO Applicability of the shutdown electrical specifications to be more restrictive do not, therefore, create the possibility of a new or different accident from any accident previously evaluated.

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

Response: No There will be no effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, heat flux hot channel factor (FQ), nuclear enthalpy rise hot channel-factor (FAH), loss of coolant accident peak cladding temperature (LOCA PCT), peak local power density, or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met. It has been demonstrated that the CREVS and its actuation instrumentation are not required to mitigate the control room radiological consequences of a waste gas decay tank rupture.

The proposed changes do not eliminate any surveillances or alter the frequency of surveillances required by the Technical Specifications. None of the acceptance criteria for any accident analysis will be changed.

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

==

Conclusion:==

Based on the above evaluation, AmerenUE concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable. Re2ulatory Requirements / Criteria Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The U.S. Nuclear Regulatory Commission's (NRC's) requirements related to the content of the TSs are contained in Section 50.36 of Title 10 of the Code of FederalRegulations (10 CFR 50.36) which requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems

Attachment' 1 Page 16 of 18 settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements per 10 CFR 50.36(c)(3); (4) design features; and (5) administrative controls.

Licensees may revise the TSs to adopt current format and content ofNNUREG-1431 Revision 3.1, "Standard Technical Specifications, Westinghouse Plants," provided that a plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative, or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. This amendment application contains elements of the second and third elements above.

The following regulatory requirements and guidance documents also apply to the affected actuation instrumentation, CREVS, EES, and electrical power systems:

GDC 2 requires that structures, systems, and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

GDC 4 requires that structures, systems, and components important to safety be designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with the normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, discharging fluids that may result from equipment failures, and from events and conditions outside the nuclear power unit. However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.

GDC 13 requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems.

.Attachment 1 Page 17 of 18 GDC 17 and GDC 18 require that the design of the electrical power systems contain sufficient independence, redundancy, inspection readiness and testability to ensure an available source of power to permit the functioning of structures, systems, and components important to safety.

GDC 19 requires that a control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent, to any part of the body, for the duration of the accident.

GDC 20 requires that the protection system(s) shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

GDC 21 requires that the protection system(s) shall be designed for high functional reliability and testability.

o GDC 22 through GDC 25 and GDC 29 require various design attributes for the protection system(s), including independence, safe failure modes, separation from control systems, requirements for reactivity control malfunctions, and protection against anticipated operational occurrences.

Regulatory Guide 1.22 discusses an acceptable method of satisfying GDC-20 and GDC-21 regarding the periodic testing of protection system actuation functions.

These periodic tests should duplicate, as closely as practicable, the performance that is required of the actuation devices in the event of an accident.

Regulatory Guide 1.24 describes methods acceptable to the NRC staff for licensee evaluation of the potential radiological consequences of a waste gas decay tank rupture accident.

10 CFR 50.55a(h) requires that the protection systems meet IEEE 279-1971.

Section 4.2 of IEEE 279-1971 discusses the general functional requirement for protection systems to assure they satisfy the single failure criterion.

There will be no changes to the actuation instrumentation, CREVS, EES, or electrical power systems such that compliance with any of the regulatory requirements and guidance documents above would come into question. The above evaluations confirm that the plant will continue to comply with all applicable regulatory requirements.

Page 18 of 18 In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

AmerenUE has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

7.1 Technical Specification Task Force, Improved Standard Technical Specifications Change Traveler, TSTF-36-A, Revision 4, "Addition of LCO 3.0.3 N/A to Shutdown Electrical Power Specifications," approved by NRC on November 1, 1999.

8.0 PRECEDENTS The options of whether or not to adopt the MODE 5 and MODE 6 LCO Applicability in TS 3.3.7 and TS 3.7.10 as well as the specified condition "during movement of irradiated fuel assemblies" in the LCO Applicability of the shutdown electrical specifications (TS 3.8.2, TS 3:8.5, TS 3.8.8, TS 3.8.10) were included in NUR-EG-1431 Revision 1 which was the set of Standard Technical Specifications upon which Callaway's ITS conversion (License Amendment 133) was based. TSTF-36-A was approved by NRC on November 1, 1999, and later incorporated into Revision 2 of NUREG-1431. Several plants that converted to the ITS after Callaway have adopted the changes contained in TSTF-36-A, such as Duane Arnold (License Amendment 223), Prairie Island (License Amendment 158/149), Quad Cities (License Amendment 199/ 195), and Fitzpatrick (License Amendment 176) to name a few as listed in ADAMS.

ATTACHMENT 2 MARKUP OF TECHNICAL SPECIFICATIONS

CREVS Actuation Instrumentation 3.3.7 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. Both radiation monitoring C.1.1 Enter applicable Immediately channels inoperable. Conditions and Required Actions of LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)," for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

AND C.1.2 Place one CREVS train 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in CRVIS mode.

OR C.2 Place both trains in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months CRVIS mode.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Conditions A; B, AND or C not met in MODE 1, 2, 3, or 4. D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Required Action and E.1 Suspend CORE Immediately associated Completion ALTERATIONS.

Time for Conditions A, B, or C not met in 11DE 5 a_ , AND

--@r-during CORE ALTERATIONS'or during E.2 Suspend movement of Immediately movement of irradiated fuel irradiated fuel assemblies, assemblies.

CALLAWAY PLANT 3.3-63 Amendment No. 165 1

CREVS Actuation Instrumentation 3.3.7 Table 3.3.7-1 (page 1 of 1)

CREVS Actuation Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE TRIP FUNCTION CONDITIONS CHANNELS REQUIREMENTS SETPOINT 1 Manual 1, 2, 3, 4, 2 SR 3.3.7.4 NA Initiation (a), and (c)

2. Automatic 1, 2, 3, 4, 2 trains SR 3.3.7.3 NA Actuation (a), and (c)

Logic and Actuation - (a) 2 trains SR 3.3.7.6 NA Relays (BOP ESFAS)

3. Control Room 1, 2, 3, 44 S 2 SR 3.3.7.1 (b)

Radiation - and (a) SR 3.3.7.2 Control Room SR 3.3.7.5 Air Intakes (a) 2 SR 3.3.7.6 .... (b)

4. Containment Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a, for all initiation functions and Isolation - requirements.

Phase A

,,5. Fuel Building Refer to LCO 3.3.8, "EES Actuation Instrumentation," for all initiation functions and Exhaust requirements.

Radiation-Gaseous (a), During CORE ALTERATIONS or during movement of irradiated fuel assemblies within containment.

3 (b) Nominal Trip Setpoint concentration value ( 1 iCi/cm ) shall be established such that the actual submersion dose rate would not exceed 2 mR/hr in the control room.

(c) During movement of irradiated fuel assemblies in the fuel building, A

CALLAWAY PLANT 3.3-65 Amendment No. 165 I

EES Actuation Instrumentation 3.3.8 3.3 INSTRUMENTATION 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation LCO 3.3.8 The EES actuation instrumentation for each Function in Table 3.3.8-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.8-1.

-Le 9,.

ACTIONS 3 ;'r / /'all ealle K,2, Separate Co'ndition---------

entry 7low77r- h NOTE-o.

etry is'allowved for each Function.

COMPLETION REQUIRED ACTION TIME CONDITION TIME A. One or more Functions A.1 Place one EES train in 7 days with one channel or train the Fuel Building

,inoperable. Ventilation Isolation Signal (FBVIS) mode.

AND A.2 Place one CREVS train 7 days in Control Room Ventilation Isolation Signal (CRVIS) mode.

(continued)

CALLAWAY PLANT 3.3-66 Amendment No. 165 1

CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS)

LCO 3.7.10 Two CREVS trains shall be OPERABLE.

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

-------- 7----

The control room boundary may be opened intermittently under administrative control.

--- I----------------------------------------------- -----------------------------------------------

APPLICABILITY: MODES 1, 2, During movement of irradiated fuel assemblies.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. .,One CREVS train A.1 Restore CREVS train to 7 days inoperable. OPERABLE status.

B. Two CREVS trains B.1 Restore control room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable control room status.

boundary in MODES 1, 2, 3, and 4.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or4. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

CALLAWAY PLANT 3.7-25 Amendment No. 176

CREVS 3.7.10 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREVS train in CRVIS Time of Condition A not met mode.

-in MGODE 5 of 6, z, during movement of irradiated fuel assemblies. I OR D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

E. Two CREVS trains E.1 Suspend CORE Immediately

,inoperable in MODE 5 3, C, ALTERATIONS.

,..muring movement of irradiated fuel assemblies.

AND E.2 Suspend movement of Immediately irradiated fuel assemblies.

F. Two CREVS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

CALLAWAY PLANT 3.7-26 Amendment No. 184

Emergency Exhaust System 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Emergency Exhaust System (EES)

LCO 3.7.13 Two EES trains shall be OPERABLE.

NOTE - - ---

The auxiliary or fuel building boundary 'may be opened i'ntermlttently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies in the fuel building.

- ----N O TE- ---- - ------

The SiS mode 6foperation is required6only in MODES 1, 2, 3 and 4. The FBVIS mode of operation is required only during movement of irradiated fuel assemblies in the fuel building.

_ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One EES train inoperable. A.1 Restore EES train to 7 days OPERABLE status. I B. Two EES trains inoperable B.1 Restore auxiliary building 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to inoperable auxiliary boundary to OPERABLE building boundary in status.

MODE 1, 2, 3 or 4.

(continued)

- - - - - --- AIO7~ - - - -

/- co 3.,0. ? /-Ir 1,04- atla/;" i I&,

'I - - -

CALLAWAY PLANT 3.7-32 Amendment No. 184

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:.

a. One qualified circuit between the offsite transmission network and the onsite Class 1 E AC electrical power distribution subsystem' required by LCO 3.8.10, "Distribution Systems - Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1 E AC electrical power distribution subsystems required by LCO 3.8.10;* and

c. The shutdown portion of one Load Shedder and Emergency Load Sequencer (LSELS) associated with the required DC and AC electrical power distribution train.

APPLICABILITY: MODES 5 and 6) a~rroth/ le--.-

b4kjrho~veoieh4-wkof frI~~~

CTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One required offsite circuit ..... . NOTE -

I -

inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with the required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

I CALLAWAY PLANT 3.8-16 Amendment No. 133

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The Train A or Train B DC electrical power subsystem shall be OPERABLE to support one train of the DC electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6j .

Io-yerhe Xx"

_ACTIONS J

COMPLETION CONDITION REQUIRED ACTION TIME

+ +

A. Required DC electrical A.1 Declare affected required Immediately power subsystem feature(s) inoperable.

inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that cuulu result in loss UI required SDM or boron concentration.

AND (continued)

LeO 3.0."3 CALLAWAY PLANT 3.8-25 Amendment No. 149

Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 The Train A or Train B inverters shall be OPERABLE to support one train of the onsite Class 1 E AC vital bus electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6) .e b tA r.,.jri -u afr' (e ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. 'Qne or more required A.1 Declare affected required Immediately inverters inoperable, feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued) 6 ALLo -WA

("CALLAWAY PLANT N -3 - --

3.8-33 Amendm,,t Amendment N0. 149 9

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of the Train A or Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support one train of equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6) .e,,

vLrl'na ro ve r'J'Q ACTIONS P P COMPLETION CONDITION REQUIRED ACTION TIME A. :One or more required AC, A.1 Declare associated Immediately 1D5C, or AC vital bus supported required elect rical power distribution feature(s) inoperable.

subs ystems inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND ANDI(continued)

L - T-

-mnm*t -- - No-.

CALLAWAY PLANT 3.8-37 Amendment No. 149

ATTACHMENT 3 RETYPED TECHNICAL SPECIFICATIONS

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

CREVS Actuation Instrumentation B 3.3.7

-TARIV -8 B 3.3 INSTRUMENTATION B 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation BASES BACKGROUND The CREVS provides an enclosed control room environment from which the unit can be operated following an uncontrolled release of radioactivity.

During normal operation, the Control Building Ventilation System provides control room ventilation. Upon receipt of an actuation signal, the CREVS initiates filtered ventilation and pressurization of the control room. This system is described in the Bases for LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)."

The actuation instrumentation consists of two gaseous radiation channels in the control room air intake. A high radiation signal from either of these channels will initiate both trains of the CREVS. Since the radiation monitors includean air sampling system, various components such as sample line valves and sample pumps are required to support monitor OPERABILITY. The control room operator can also initiate CREVS trains by manual switches in the control room. The CREVS is also actuated by a Phase A Isolation signal, a Fuel Building Ventilation Isolation signal (FBVIS), or a high radiation signal from the containment purge exhaust gaseous radiation channels. The Phase A Isolation Function is discussed in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation."

APPLICABLE The control room must be kept habitable for the operators stationed there SAFETY during accident recovery and post accident operations.

ANALYSES The CREVS acts to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room. These actions are necessary to ensure the control room is kept habitable for the operators stationed there during accident recovery and post accident operations by minimizing the radiation exposure of control room personnel.

In MODES 1, 2, 3, and 4, (MODE 4 is subject.to.LCO 3.3.2, Function 3.a),

the gaseous radiation channel actuation of the CREVS is a backup for the Phase A Isolation signal actuation. This ensures initiation of the CREVS during a loss of coolant accident or steam generator tube rupture.

.

1 he aseous radiation channel actuation of the CREVS io MODES 5&nd Cf "ring CORE ALTERATiONS/lor during move ment' of irrad iate fuel:

assemblies within containmen i he primary means to ensure control f" -'(continued)

CALLAWAY PLANT B 3.3.7-1 Revision 6

ORE VS Actuation Instrumentation No a2op)1rV rvoon Aa 1Lf-Qb-; ý ..

BASES APPLICABLE room habitabiliL in the event of a fuel handling accident inside SAFETY containment waste gas decay tank rupture accident. T-ho prcbab',it, ,-

ANALYSES .. waste gas decay tank rutr ciotorigduraing the pecieJ of (continued) fi*mo outcdo the Appli-abilty of Fun..tion. 1 3 of Tableo -*4-, 1 *

&.isiq*iee . There are no safety analyses that take credit for CREVS actuation upon high containment purge exhaust radiation. A FBVIS is credited to protect the control room in the event of a design basis fuel handling accident inside the fuel building.

Sources of control room ventilation isolation signal (CRVIS) initiation which are remote from the Control Room intake louvers are not response time tested. For example, GGRE0027 and GGRE0028, which monitor Fuel Building exhaust are not response time tested. The analysis does credit a FBVIS for actuating a CRVIS following a Fuel Handling Accident in the Fuel Building. Due to the remote location of the Fuel Building exhaust radiation monitors relative to the Control Room intake louvers, the FBVIS will isolate the Control Room prior to the post-accident radioactive plume reaching the Control Room intake louvers.

Similarly, for a LOCA, the analysis credits a time zero Control Room isolation. A Safety Injection signal initiates a Containment Isolation Phase A, which initiates a CRVIS. This function is also credited for isolating the Control Room prior to the post-accident radioactive plume reaching the Control Room intake louvers.

For a Fuel Handling Accident within Containment, GKRE0004 and GKRE0005 are credited for initiating a CRVIS. These monitors are not remote from the Control Room intake louvers. They are downstream of the Control Room intake. Therefore, a specific response time is modeled, and a response time Surveillance Requirement is imposed for this CRVIS function.

The CREVS actuation instrumentation satisfies Criterion 3 of 10CFR50.36(c)(2)(ii).

LCO The LCO requirements ensure that instrumentation necessary to initiate the CREVS is OPERABLE.

1. Manual Initiation The LCO requires two channels OPERABLE. The operator can initiate the CREVS at any time by using either of two push buttons in the control room.

(continued)

CALLAWAY PLANT B 3.3.7-2 Revision 6

lrscW oa-a' CREVS Actuation Instrumentation B 3.3.7 BASES LCO 4. Containment Isolation - Phase A (continued)

Therefore, the requirements are not repeated in Table 3.3.7-1.

Instead, refer to LCO 3.3.2, Function 3.a, for all initiating Functions and requirements.

5. Fuel Buildinq Exhaust Radiation - Gaseous Control Room Ventilation Isolation is also initiated by high radiation in the fuel building detected by Fuel Building Exhaust Radiation - Gaseous channels (GGRE0027 and GGRE0028).

The requirements are not repeated in Table 3.3.7-1. Instead, refer to LCO 3.3.8 for all initiating Functions and requirements.

APPLICABILITY The Manual Initiation, Automatic Actuation Logic and Actuation Relays (BOP ESFAS), and Control Room Radiation - Control Room Air Intake Functions must be OPERABLE in MODES 1, 2, 3, 4,-&w@during CORE ALTERATIONS, or during movement of irradiated fuel assemblies within containment. -Thasc Fu,,ctOns must be O.ERAHLE Mi DECr-6 5

@Ad 6 fQr a wactc goc decci' tank rpturoe aoeideot, to emstife habitable

......... t f.r t16 O* t.1 rom Opfratcrs. During CORE ALTERATIONS or during movement of irradiated fuel assemblies within containment, these Functions assure the generation of a CRVIS on detection of high gaseous activity in the event of a fuel handling accident within containment.

During movement of irradiated fuel assemblies in the fuel building, the Fuel Building Exhaust Radiation - Gaseous channels (GGRE0027 and GGRE0028) assure the generation of a CRVIS on detection of high gaseous activity in the event of a fuel handling accident in the fuel building. Since this FBVIS-initiated CRVIS requires Function 2 of Table 3.3.7-1 to complete the actuation circuit, and since manual CRVIS actuation provides back-up, Functions 1 and 2 of Table 3.3.7-1 must also be OPERABLE during movement of irradiated fuel assemblies in the fuel building.

The Containment Isolation - Phase A Function is required to be OPERABLE as directed by LCO 3.3.2, Function 3.a. The Fuel Building Exhaust Radiation - Gaseous Function is required to be OPERABLE as directed by LCO 3.3.8, Functions 1, 2, and 3.

ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance (continued)

CALLAWAY PLANT B 3.3.7-4 Revision 6

CREVS Actuation Instrumentation B 3.3.7 BASES ACTIONS D.1 and D.2 (continued)

LCO requirements are not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

E.1 and E.2 Condition E applies when the Required Action and associated Completion Time for Conditions A, B, or Cbave not been met.- MODE ,5 or 6, o, during CORE ALTERATION Sor when irradiated fuel assemblies are being moved: Movement of irradiated fuel assemblies and CORE ALTERATIONS must be suspended immediately to reduce the risk of accidents that would require CREVS actuation. This does not preclude movement of a component to a safe position.

SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.7-1 REQUIREMENTS determines which SRs apply to which CREVS Actuation Functions.

SR 3.3.7.1 Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation 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, it is key to verifying 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. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, (continued)

CALLAWAY PLANT B 3.3.7-7 Revision 6

EES Actuation Instrumentation B 3.3.8 BASES (Continued)

APPLICABILITY The manual and automatic EES initiation must be OPERABLE when moving irradiated fuel assemblies in the fuel building to ensure the EES operates to remove fission products associated with a fuel handling accident and isolate control room ventilation. I High radiation initiation of the FBVIS must be OPERABLE during movement of irradiated fuel assemblies in the fuel building to ensure automatic initiation of the EES and a CRVIS when the potential for a fuel handling accident exists.

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 unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification. If the measured Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.

A'J-ote has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.8-1 in the accompanying LCO. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

Placing a EES train(s) in the FBVIS mode of operation isolates normal air discharge from the fuel building and initiates filtered exhaust, imposing a negative pressure on the fuel building. Further discussion of the FBVIS mode of operation may be found in the Bases for LCO 3.7.13, "Emergency Exhaust System (EES)," and in Reference 2.

A.1 Condition A applies to the actuation logic train Function of the BOP ESFAS, the gaseous radiation monitor channel Function, and the manual initiation channel Function. Condition A applies to the failure of a single actuation logic train, gaseous radiation monitor channel, or manual initiation channel. If one channel or train is inoperable, or one gaseous radiation monitor channel is inoperable, a period of 7 days is allowed to (continued)

CALLAWAY PLANT B 3.3.8-3 Revision 4

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

CREVS B 3.7.10 BASES LCO path can also render the CREVS flow path inoperable. In these (continued) situations, LCOs 3.7.10 and 3.7.11 may be applicable.

APPLICABILITY In MODES 1, 2, 3, and 4, CREVS must be OPERABLE to control operator exposure during and following a LOCA or SGTR.

SM* DE 5&-1, 6, til *R, V IS ..... c 03,-. ..with the de*-i* b.a..

t...I MIle9A from U49 rpWture Of AMw4-6tO g~ea&4tank During movement of irradiated fuel assemblies, the CREVS must be OPERABLE to cope with the release from a design basis fuel handling accident inside containment or in the fuel building.

ACTIONS A.1 When one CREVS train is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREVS train is adequate to perform the control room protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CREVS train could result in loss of CREVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B._1 If the control room boundary is inoperable in MODE 1, 2, 3, or 4 such that neither CREVS train can establish the required positive pressure (but the trains are not otherwise inoperable), action must be taken to restore an OPERABLE control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. (Appropriate compensatory measures include those such as described for the LCO Note in the LCO Bases above).

For the purposes of assessing whether Condition B applies, "control room boundary" may include portions of the Control Building boundary due to analyzed interaction between the Control Building and control room atmospheres during emergency operation of the CREVS, including the (continued)

CALLAWAY PLANT B 3.7.10-4 Revision 7

CREVS B 3.7.10 BASES ACTIONS B.1 (continued) effect of Control Building boundary leakage, as modeled in the control room dose analyses for the DBA LOCA.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, the availability of the CREVS to provide a filtered environment (albiet with potential control room inleakage), and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a reasonable time to diagnose, plan, repair, and test most problems with the control room boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CREVS train or control room boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve-this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1, D.2.1, and D.2.2 m M -5r-,-

I, ., re, --, uring movement of irradiated fuel assemblies, if the inoperable CREVS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREVS train in the CRVIS mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. Required Actions D.2.1 and D.2.2 would place the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

(continued)

CALLAWAY PLANT B 3.7.10-5 Revision 7

CREVS B 3.7.10 BASES ACTIONS E.1 and E.2 (continued)

.'AMDE5or- ý,ruring movement of irradiated fuel assemblies, with two CREVS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

F. 1 If both CREVS trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than an inoperable control room boundary (i.e., Condition B), the CREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe,'testing each train once every month, by initiating from the control room, flow through the HEPA filters and charcoal adsorbers of both the filtration and pressurization systems, provides an adequate check of this system.

Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. Each pressurization system train must be operated for > 10 continuous hours with the heaters functioning. Functioning heaters will not necessarily have the heating elements energized continuously for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ; but will cycle depending on the air temperature. Each filtration system train need only be operated for

Ž 15 minutes to demonstrate the function of the system. The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability.

SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The CREVS filter tests use the test procedure guidance in Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the (continued)

CALLAWAY PLANT B 3.7.10-6 Revision 7

Emergency Exhaust System B 3.7.13 BASES LCO b. HEPA filter and charcoal adsorber are not excessively restricting (continued) flow, and are capable of performing their filtration function, and

c. Heater, ductwork, and dampers are OPERABLE, and air circulation can be maintained.

The LCO is modified by a Note allowing the auxiliary or fuel building boundary to be opened intermittently under administrative controls. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for auxiliary or fuel building isolation is indicated. Plant administrative controls address the breached pressure boundary.

APPLICABILITY In MODE 1, 2, 3, or 4, the Emergency Exhaust System is required to be OPERABLE to support the SIS mode of operation to provide fission product removal associated with ECCS leaks due to a LOCA and leakage from containment and annulus.

In MODE 5 or 6, the Emergency Exhaust System is not required to be OPERABLE since the ECCS is not required to be OPERABLE.

During movement of irradiated fuel in the fuel building, the Emergency Exhaust System is required to be OPERABLE to support the FBVIS mode of operation to alleviate the consequences of a fuel handling accident.

The Applicability is modified by a Note. The Note clarifies the Applicability for the two safety-related modes of operation of the Emergency Exhaust System, i.e., the Safety Injection Signal (SIS) mode and the Fuel Building Ventilation Isolation Signal (FBVIS) mode. The SIS mode which aligns the system to the auxiliary building is applicable when the ECCS is required to be OPERABLE. In the FBVIS mode the system is aligned to the fuel building. This mode is applicable while handling irradiated fuel in the fuel building.

ACTIONS A.*1 With one Emergency Exhaust System train inoperable, action must be

/-MIr taken to restore OPERABLE status within 7 days. During this period, the remaining OPERABLE train is adequate to perform the Emergency Exhaust System function. The 7 day Completion Time is based on the risk from an event occurring requiring the inoperable Emergency Exhaust (continued)

CALLAWAY PLANT B 3.7.13-3 Revision 7

INSERT B 1 LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

AC Sources - Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating BASES BACKGROUND The unit Class 1E AC Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and alternate), and the onsite standby power sources (Train A and Train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

The onsite Class 1 E AC Distribution System is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG.

Offsite power is s*ipplied to the unit switchyard from the transmission network by4reeransmission lines. From the switchyard, two electrically and physically separated circuits provide AC power, through ESF transformers, to the 4.16 kV ESF buses. Automatic load tap changers associated with the ESF transformers, as well as associated capacitor banks, provide voltage regulation for the preferred sources in the event of changing switchyard voltage. A detailed description of the offsite power network and the circuits to the Class 1 E ESF buses is found in the FSAR, Chapter 8 (Ref. 2).

An offsite circuit consists of all breakers, transformers, voltage regulation equipment, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF buses.

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1 E Distribution System. Within 1 minute after the initiating signal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service via the load sequencer.

The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. DGs NE01 and NE02 are dedicated to ESF buses NB01 and NB02, respectively. A DG starts automatically on a safety injection (SI) signal (i.e., low pressurizer pressure, steam line pressure or high containment pressure signals) or on an ESF bus undervoltage signal (continued)

CALLAWAY PLANT B 3.8. 1-1 Revision 7a

AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources-Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6A SAFETY ensures that: :E7/SE/*r '2 ANALYSES

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

(continued)

CALLAWAY PLANT B 3.8.2-1 Revision 3

-FAC2A/ tt-Odta INSERT B2 and during movement of irradiated fuel assemblies

AC Sources - Shutdown B 3.8.2 BASES LCO instrumentation functions is addressed in LCO 3.3.5, "Loss of Power (continued) (LOP) Diesel Generator (DG) Start Instrumentation." Only the shutdown portion of the associated Load Shedder and Emergency Sequencer is required to be OPERABLE in MODES 5 and 6.

In addition, Load Shedder and Emergency Load Sequencer operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts on the ability to start and maintain energized loads required OPERABLE by LCO 3.8.10. However, proper sequencer operation shall only be required on the train supported by the OPERABLE DG.

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 provide assurance that: . /X T.1r*,A2.- -

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. The one train with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

(continued)

CALLAWAY PLANT B 3.8.2-4 Revision 3

INSERT BI LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

INSERT B2 and during movement of irradiated fuel assemblies

DC Sources - Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE The initial conditions of Design Basis Accident and transient analyses in SAFETY the FSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume that ANALYSES Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6Aensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and (continued)

CALLAWAY PLANT B 3.8.5-1 Revision 3

INSERT B2 and during movement of irradiated fuel assemblies

DC Sources - Shutdown B 3.8.5 BASES LCO (continued)

TRAIN A TRAIN B Bus NK01 Bus NK03 Bus NK02 Bus NK04 energized from energized from energized from energized from Battery NK11 and Battery NK13 Battery NK12 and Battery NK14 Charger NK21 or and Charger NK22 or and Swing Charger Charger NK23 Swing Charger Charger NK24 NK25 (powered or NK26 (powered or from AC Load Swing Charger from AC Load Swing Charger Center NG01) NK25 (powered Center NG04) NK26 (powered from AC Load from AC Load Center NG01) Center NG04)

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6 provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Required features needed to mitigate a fuel handling accident are available;

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS By allowing the option to declare required features inoperable with the j2A.1, associated A.2.1, A.2.2, A.2.3, DC power and A.2.4 source inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, (continued)

CALLAWAY PLANT B 3.8.5-4 Revision 3

-7ý57,6N Or-xD, INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

INSERT B2 and during movement of irradiated fuel assemblies

-7rt&Ce2M Ar-d00-.

Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the FSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2),

ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Trip System and Engineered Safety Features Actuation I System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum inverters to each AC vital bus during MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) thatare analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of (continued)

CALLAWAY PLANT B 3.8.8-1 Revision 7

INSERT B2 and during movement of irradiated fuel assemblies

7rd OcW6?- 6 Inverters - Shutdown B 3.8.8 BASES LCO (continued)

TRAIN A TRAIN B Bus NNO1 Bus NN03 Bus NN02 Bus NN04 energized from energized from energized from energized from Inverter NN11 Inverter NN13 Inverter NN12 Inverter NN14 connected to connected to connected to connected to DC bus NK01 DC bus NK03 DC bus NK02 DC bus NK04 APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6Aprovide assurance that: -r-t c-x 7- 61-a

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, and A.2.4 By the allowance of the option to declare required features inoperable with R/ the associated inverter(s) inoperable, appropriate restrictions will be PV- L`--/' ,9 implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or (continued)

CALLAWAY PLANT B 3.8.8-4 Revision 7

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

INSERT B2

,,and during movement of irradiated fuel assemblies

-7ýWecA/ df?-ao:2 Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -

Operating."

APPLICABLE The initial conditions of Design Basis Accident and transient analyses in SAFETY the FSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume ANALYSES Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum AC, DC, and AC vital bus electrical power distribution subsystems during MODES 5 and 6Aensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and (continued)

CALLAWAY PLANT B 3.8.10-1 Revision 3

INSERT B2 and during movement of irradiated fuel assemblies

-7rA'2W dr-e~~

Distribution Systems - Shutdown B 3.8.10 BASES LCO The required AC vital bus electrical power distribution subsystem is (continued) supported by one train of inverters as required by LCO 3.8.8, "Inverters -

Shutdown." When the~second (subsystem) of AC vital bus electrical power distribution is needed to support redundant required systems, equipment and components, the second train may be energized from any available source. The available source must be Class 1 E or another reliable source. The available source must be capable of supplying sufficient AC electrical power such that the redundant components are capable of performing their specified safety function(s) (implicitly required by the definition of OPERABILITY). Otherwise the supported components must be declared inoperable and the appropriate conditions of the LCOs for the redundant components must be entered.

Closure of the tie breaker 52NG0116 between NG01 and NG03 or tie breaker 52NG0216 between NG02 and NG04 will render all four -

degraded voltage channels for the associated 4.16 kV bus inoperable.

Refer to LCO 3.3.5, "LOP DG Start Instrumentation." The 480 V load center transformer load and voltage drop increase when one transformer is supplying both 480 V buses. Since the degraded voltage is sensed on the 4.16 kV bus, the actual 480 V bus voltage will be lower (lower than assumed during a degraded voltage condition) when the protection setpoint is reached. In this case, adequate protection is not provided for the 480 V bus loads.

,APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6 provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, DC, and AC vital bus electrical power distribution subsystems requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

(continued)

CALLAWAY PLANTB B 3.8.10-4 Revision 3

7SA5;9w J£10 INSERT B2 and during movement of irradiated fuel assemblies

-7ý590A/ Pr-eo--

Distribution Systems - Shutdown B 3.8.10 BASES .(Continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable and not in operation, which results in taking the appropriate RHR actions. This would assure consideration is given to shutdown cooling systems that are without required power and that appropriate actions are taken to assure operability of these required systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

(continued)

CALLAWAY PLANT B 3.8.10-5 Revision 3

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

ATTACHMENT 5 FSAR MARKUPS (for information only)

rXA9CAI tO -Ov -7 CALLAWAY - SP The probability of a large break in a piping system (e.g., rupture of ECCS piping),

subsequent to the original large LOCA pipe break, is considered to be sufficiently low that it need not be postulated.

Single failures of passive components in electrical systems are assumed in designing against a single failure.

3.1.2 ADDITIONAL SINGLE FAILURE ASSUMPTIONS In designing for and analyzing for a DBA (i.e., loss-of-coolant accident, main steam line break, fuel handling accident, or steam generator tube rupture), the following assumptions are made, in addition to postulating the initiating event.

a. The events are assumed not to result from a tornado, hurricane, flood, fire, loss of offsite power, or earthquake.

b. Any one of the following occurs:

1. During the short term of an accident, a single failure of any active mechanical component. The short term is defined as less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following an accident, or

2. During the short term of an accident, a single failure of any active or passive electrical component, or

3. A single failure of passive components associated with long-term cooling capability, assuming that a single active failure has not occurred during the short term. Long-term cooling applies to a time.

duration greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. No reactor coolant system transient is assumed, preceding the postulated reactor coolant system piping rupture.

d. No operator action is assumed to be taken by plant operators to correct problems during the first 10 minutes following the accident. Although not a design basis accident, operator action times of less than 10 minutes are assumed in the mitigation of an inadvertent ECCS actuation at power event. See Section 15.5.1.

e. All offsite power is simultaneously lost and is restored within 7 days (except that for events postulated to occur during .4eidshutdown conditions e.g., a fuel handling accident, a loss of all offsite power is not required to e assumed in addition to a single failure).

f. For a LOCA, for additional safety no credit is taken for the functioning of nonseismic Catego I cormponents.

-7 'CI e-- "' /

L _ / 3.1-3 . ,,,"ev. OL-16

" " " , 10/07 '

f~F4A'CA] 0 ?-60 -7 CALLAWAY - SP 16.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) 16.7.8.1 LIMITING CONDITION FOR OPERATION Pressurization System flow rate shall be within limits during system operation CRVIS mode for each CREVS train.

APPLICABILITY: MODES 1,2, 3,4, =and 6 During movement of irradiated fuel assemblies ACTIONS:

a. With Pressurization System flow rate not within limits for one CREVS train in MODES 1, 2, 3 or 4, restore Pressurization System flow rate to within limits within 7 days; otherwise, enter Section 16.0.1.3.

b. With Pressurization System flow rate not within limits for one CREVS train-i4t-

,-rVDES& @F 6, during movement of irradiated fuel assemblies, restore

,Pressurization System flow rate to within limits within 7 days; otherwise,

,immediately place the other CREVS train in CRVIS mode, or immediately

-suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.

16.7.8.1.1 SURVEILLANCE REQUIREMENTS At. least once per 18 months, or (1) after any structural maintenance on the HEPA filter or in any charcoal adsorber housings, or (2) following painting, fire or chemical release ventilation zone communicating with the system, verify the system flow rate is 2200 cfm

(+800/-400) for the Pressurization System.

16.7.8.1.2 BASES Verification of the flow rate in the Pressurization System assures that the ventilation system flows are properly balanced within the system.

16.7-17 Rev. OL-16 10/07

,-',j AR' CA/ d L/7,-,-7/

CALLAWAY - SP v(,j e,.Jv -

16.8.3 A.C. SOURCES-SHUTDOWN 16.8.3.1 LIMITING CONDITION FOR OPERATION The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem; and

c. The Shutdown portion of one Load Shedder and Emergency Load Sequencer (LSELS) associated with the required DG and AC electrical power distribution train.

APPLICABILITY: MODES 5 and 6 eEX j ACTION: , -.

a. With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving crane operation with loads over the spent fuel pool.

b. The diesel generators are not considered inoperable when the fuel oil storage

,tank missile shield is removed provided the following Administrative Controls are in place:

1) Weather monitoring is in place prior to and during shield removal, and no thunderstorms are within 70 miles.

2) Equipment, tools, and personnel required to close the missile shield shall be on site and located such that the shield can be closed in one hour or less.

3) Only one Emergency Diesel Fuel Oil storage tank missile shield may be open at a time.

4) Ifthunderstorm watches or warnings, tornado watches or warnings, or high winds are within 70 miles of the plant moving toward the plant, the missile shield must be closed immediately.

5) Installation of hold down bolt nuts and washers are required for tornado missile protection.

16.8-6 Rev. OL-15 5/06

CALLAWAY - SP 711ho 4/,

6) Loads are not hoisted over a given train when the missile shield is removed.

7) Upon completion or stoppage of the activity requiring the shield open, immediately replace the missile shield.

c. In Mode 6, with no OPERABLE emergency diesel generator, the TS ACT 3.9.5.A.4 or TS ACT 3.9.6.B.3 four hour action statement to close all direct access containment penetrations MUST also be applied upon entry into TS ACT 3.8.2.B.1.

16.8.3.1.1 SURVEILLANCE REQUIREMENTS See Technical Specification SR 3.8.2.1.

16.8.3.1.2 BASES See FSAR Section 9.1.4 In order for the diesel generator to remain OPERABLE when the missile cover is removed, appropriate administrative controls are followed to ensure adequate missile protectionh'. Reference includes: RHR 19618, Rev. G.

16.8-7 Rev. OL-15 5/06

ATTACHMENT 6 TSTF-36-A, REVISION 4 (WITH NUREG-1431 MARKUPS ONLY)

(for information only)

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Addition of LCO 3.0.3 N/A to shutdown electrical power specifications NUREGs Affected: WJ 1430 W 1431 [] 1432 [] 1433 W 1434 Classification: 3) Improve Specifications Recommended for CLIIP?: (Unassigned)

Correction or Improvement: (Unassigned)

Industry

Contact:

Tom Silko, (802) 258-4146, tsilko@entergy.com Add "LCO 3.0.3 is not applicable" note to AC Sources - Shutdown, DC Sources - Shutdown, Inverters - Shutdown and Distribution Systems - Shutdown to clarify that the requirements apply only to the Modes or other specified conditions in the Applicability The Actions of Specifications 3.8.2, "AC Sources - Shutdown", 3.8.5, " DC Sources - Shutdown", 3.8.8, "Inverters -

Shutdown", and 3.8.10, "Distribution Systems - Shutdown" have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in Mode 4 or 5 (or 5 and 6 for PWRs), LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in Modes 1, 2, or 3, (or 4 for PWRs) the fuel movement is independent of reactor operations. This clarification is necessary because defaulting to LCO 3.0.3 (during irradiated fuel assembly movement in MODE 1, 2, or 3 [or 4 for PWRs]) would require the reactor to be shutdown unnecessarily. The Note applies to more than one of the Required Actions, thus it has been placed at the beginning of the Actions Table.

Corresponding changes have been made to the Bases. The same logic regarding movement of irradiated fuel applies to the PWR NUREG specifications for fuel building air cleanup systems and its instrumentation.

Revision History OGRevision 0 Revision Status: Closed Revision Proposed by: Peach Bottom Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 14-Jul-95 Owners Group Comments:

Hatch Comments - OK Owners Group Resolution: Approved Date: 14-Jul-95 TSTF Review Information TSTF Received Date: 02-Aug-95 Date Distributed for Review: 02-Aug-95 OG Review Completed: k BWOG [] WOG F] CEOG [. BWROG TSTF Comments:

WOG Comments - Agreed with additional changes necessary to the WOG NUREG regarding FBACS and FBACS Instrumentation.

CEOG Comments - Agree to change. Also applicable to CEOG Spec 3.7.14, Fuel Building Air Cleanup System and 3.3.10, Fuel Handling Isolation Signal (FHIS) (Digital)

TSTF Resolution: Approved Date: 27-Nov-95 NRC Review Information 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 OG Revision 0 Revision Status: Closed NRC Received Date: 03-Jan-96 NRC Comments:

6/11/96 - C. Grimes comment: TSTF-36 will be rolled-in with TSTF-16.

8/12/96 - TSTF-36, Rev. 1 received.

9/18/96 - Closed to Revision 1 Final Resolution: Superceded by Revision Final Resolution Date: 18-Sep-96 TSTF Revision 1 Revision Status: Closed Revision Proposed by: WOG Revision

Description:

Rev. 0 contained WOG Bases markup for B 3.7.14 instead of the correct B 3.7.13. The changes given on the Traveler cover page are correct. A substitute page is provided with Rev. I TSTF Review Information TSTF Received Date: 19-May-96 Date Distributed for Review: 19-May-96 OG Review Completed: [ BWOG [] WOG [] CEOG VJ BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 16-Jun-96

'NRC Review Information NRC Received Date: 16-Jun-96 NRC Comments:

9/26/96 - C. Grimes comment: clarification of note is appropriate. Pending roll-in with TSTF-16.

1/23/97 - Closed to Revision 2 Final Resolution: Superceded by Revision Final Resolution Date: 23-Jan-97 TSTF Revision 2 Revision Status: Closed Revision Proposed by: WOG Revision

Description:

The Bases insert which described the "LCO 3.0.3 is not applicable." Note was written by the BWROG and was not corrected to reflect the additional Modes described in the PWR NUREGS. Substitute insert pages for the PWR NUREGs are provided to correct this error.

TSTF Review Information TSTF Received Date: 16-Aug-96 Date Distributed for Review: 20-Nov-96 OG Review Completed: W BWOG F] WOG [] CEOG F] BWROG TSTF Comments:

31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 TSTF Revision 2 Revision Status: Closed (No Comments)

TSTF Resolution: Approved Date: 19-Dec-96 NRC Review Information NRC Received Date: 23-Jan-97 NRC Comments:

5/9/97 - reviewer recommended rejection. For a typical two train plant, the proposed change is not necessary. Therefore, with respect to Section 3.8, the proposed generic change should be rejected. Inclusion of the proposed exception may be considered on a plant-specific basis if it can be shown that the above discussion is not applicable to the plant design. More reviewer elaboration is contained in hard-copy file.

5/12/97 - to C. Grimes for disposition.

8/28/97 - TSTF OG requested meeting with TSB to resolve obstacles to dispostion.

10/2/97 - E. Tomlinson agreed to generic change by Brunswick.

Final Resolution: Superceded by Revision Final Resolution Date: 11-Jan-98 TSTF Revision 3 Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

The justification and Bases inserts describing "LCO 3.0.3 is not applicable," have been enhanced to address the NRC's request for clarification of the proposed change. The expanded clarification was accepted by E. Tomlinson during the Brunswick ITS review.

TSTF Review Information TSTF Received Date: 11-Jan-98 Date Distributed for Review: 15-Jan-98 OG Review Completed: k BWOG [] WOG [] CEOG [] BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 05-Feb-98 NRC Review Information NRC Received Date: 20-Feb-98 NRC Comments: Date of NRC Letter: 16-Aug-99 4/20/98 - Staff feels that exiting to 3.0.3 generates more confusion than the problem being solved. They are not sure that you would see the condition and that change increases chance of confusion.

4/21/98 - (Comments from TSTF/NRC meeting) Looks to NRC like industry is trying to address the "moving of irradiated fuel at power" issue. Two trains inoperable causes a shutdown even if the 3.0.3 shutdown is addressed. NRC believes that this is an issue but does not want a patch. NRC wants a biggergeneric fix, a more direct approach.

6/16/99 - TSTF to contact NRC by 6/25/99.

31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 TSTF Revision 3 Revision Status: Closed 8/4/99 - NRC comments received:

I have taken a quick look at TSTF-36, R.3 which was rejected by the staff, but which the industry has requested we reconsider. This proposed change would place notes indicating that LCO 3.0.3 does not apply, in a number of LCOs. These LCOs are those that are not normally applicable at power, but become applicable only due to movement of fuel. The concern is that inability to comply with these LCOs and associated AOTs might result in entry into LCO 3.0.3 and a subsequent plant shutdown. In all cases, suspending fuel movement would terminate applicability and prevent an unnecessary shutdown. Thus the staff rejected the TSTF saying it was not needed. However, industry indicates that there have been cases that suspending fuel movement was not possible and a plant shutdown unrelated to the fuel movement problems resulted.

There are two general classes of LCOs for which this proposed change applies:

1. Required electrical sources during shutdown, and

2. Various ventilation systems which are required to mitigate a fuel handling accident.

Relative to the electrical sources, it is difficult to see how the requirements for electrical sources during shutdown should be more restrictive than requirements for electrical sources while at power. Thus entering the shutdown LCOs due to fuel movement should not impose any additional requirement.

The ventilation systems applicable only to fuel movement do represent a potential problem in that these systems have generally have no relationship to power operation. It would be inappropriate and possibly contrary to safety to require a shutdown due to fuel handling problems. While the addition of the proposed note would solve this potential problem, the staff rejected it based on the low likelihood that such a problem would occur and the potential for introducing ambiguities in the TS.

This proposal to exclude LCO 3.0.3 applicability also goes contrary to a desire by the staff to expand applicability of LCO 3.0.3 to all modes of operation. The staff is concerned that if licensees can not comply

.,with LCOs or associated AOTs , there should always be clear requirements. One way of accomplishing this is to expand the applicability of LCO 3.0.3 to shutdown which the staff has proposed as a change to the iSTS.

The staff proposal did not address the issue of LCO applicability solely due to movement of fuel. However, the concern about always having a clear path to follow is directly applicable to the industry concern that, due to an ambiguity in the technical specifications, a fuel handling problem might result in an inappropriate plant shutdown. The staff suggests that rather than making LCO 3.0.3 not applicable to these situations, that the staff proposal to change LCO 3.0.3 be further modified to make it also specifically address the case of fuel movement at power.

8/31/99 - TSTF will provide a revision to the justification and Bases to delete the reference to the 37 hour4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months delay and entry into LCO 3.0.3.

Final Resolution: NRC Requests Changes: TSTF Considering Final Resolution Date: 04-Aug-99 TSTF Revision 4 Revision Status: Active Revision Proposed by: NRC Revision

Description:

Revised to incorporate NRC comments. Revised the Justification and the inserts.

TSTF Review Information 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 TSTF Revision 4 Revision Status: Active TSTF Received Date: 17-Sep-99 Date Distributed for Review: 17-Sep-99 OG Review Completed: F] BWOG W WOG [] CEOG [] BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 17-Sep-99 NRC Review Information NRC Received Date: 08-Oct-99 Date of NRC Letter: 01-Nov-99 Final Resolution: NRC Approves Final Resolution Date: 01-Nov-99 Affected Technical Specifications Action 3.8.2 AC Sources - Shutdown Action 3.8.2 Bases AC Sources - Shutdown Action 3.8.5 DC Sources - Shutdown Action 3.8.5 Bases DC Sources - Shutdown Action 3.8.8 Inverters - Shutdown Action 3:8:8 Bases Inverters - Shutdown Action 3.8.10 Distribution Systems - Shutdown Action 3.8.10 Bases Distribution Systems - Shutdown Action 3.7.13 Fuel Storage Pool Ventilation System (FSPVS) NUREG(s)- 1430 Only Action 3.7.13 Bases Fuel Storage Pool Ventilation System (FSPVS) NUREG(s)- 1430 Only Action 3.3.8 FBACS Actuation Instrumentation NUREG(s)- 1431 Only Action 3.3.8 Bases FBACS Actuation Instrumentation NUREG(s)- 1431 Only Action 3.7.13 Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1431 Only Action 3.7.13 Bases Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1431 Only Action 3.3.10 Fuel Handling Isolation Signal (FHIS) (Digital) NUREG(s)- 1432 Only Action 3.3.10 Bases Fuel Handling Isolation Signal (FHIS) (Digital) NUREG(s)- 1432 Only 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 T iTF-36-A, Rev. 4 Action 3.7.14 Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1432 Only Action 3.7.14 Bases Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1432 Only 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-36, Rev. 4 Insert 3.0.3 NA (PWRs)

LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3,or 4 would require the unit to be shutdown unnecessarily.

-¶ -4=,

I ft.q FBACS Actuation Instrument ation 3.3-8 3.3 INSTRUMENTATION 3.3.8 Fuel Building Air Cleanup System (FBACS) Actuation Instrumentation LCO 3.3.8 The FBACS actuation instrumentation for each Function in Table 3.3.8-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.8-1.

- NONOTE.-------------------------------

eparate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Place one FBACS train 7 days

-:with one channel or in operation.

train inoperable.

B. -One or more Functions B.I.1 Place one FBACS train Immediately with two channels or in operation.

two trains inoperable.

AND B.1.2 Enter applicable Immediately Conditions and Required Actions of LCO 3.7.13, "Fuel Building Air Cleanup System (FBACS)," for one train made inoperable by inoperable actuation instrumentation.

OR (continued)

WOG STS 3.3-60 Rev 1, 04/07/95

7-F-3 6 FBACS 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Fuel Building Air Cleanup System (FBACS)

LCO 3.7.13 Two FBACS trains shall be OPERABLE.

APPLICABILITY: [MODES 1, 2, 3, and 4,j During movement of irradiated fuel assemblies in the fuel ACTIONSV _ .......... . . .

CONDITION REQUIRED ACTION COMPLETION TIME A. One FBACS train A.1 Restore FBACS train 7 days inoperable, to OPERABLE status.

4, B. Required Action B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion Time of AND Condition A not met in .MODE 1, 2, 3, 8.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months or 4.

OR Two FBACS trains inoperable in MODE 1, 2, 3, or 4.

C. Required Action and C.1 Place OPERABLE FBACS Immediately associated Completion train in operation.

Time [of Condition A]

not met during OR movement of irradiated fuel assemblies in the C.2 Suspend movement of Immediately fuel building. irradiated fuel assemblies in the fuel building.

(continued)

WOG STS 3.7-30 Rev 1, 04/07/95

AC Sources--Shutdown

,3 82 ....

3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown LCO 3.8.2 The followinc AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems-Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTION pO CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite ------------- NOTE-----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

WOG STS 3.8-18 Rev 1, 04/07/95

DC Sources-Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown LCO 3.8.5 DC electrical power subsystem shall be OPERABLE to support *. ,*.

the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems--Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.'

-~

....~ ~1 -N ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1.1 Declare affected Immediately DC electrical power required feature(s) subsystems i noperabl e, inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

WOG STS 3_8-28 Rev 1, 04/07/95

Inverters-Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters-Shutdown LCO 3.8.8 Inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems--Shutdown."

APPLICABILITY: MODES 5 and 6, During movement - irradiated fuel assemblies.

if

-VI - - - -

ACTION ~ 1:fc. ?.0~?,3~:

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more [required] A.1 Declare affected Immediately inverters inoperable. required feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

WOG STS 3.8-36 Rev 1, 04/07/95

strt F )& :

Distribution Systemus-Shutdow;-".,'

3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems--Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONSZ/ (!c ,, , **

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC, DC, or AC vital supported required

bus- electrical power feature(s) distribution inoperable.

subsystems inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

WOG STS 3.8-40 Rev 1, 04/07/95

FBACS Actuation Instrumentation i B 3.3.8 BASES ACTIONS specification. If the Trip Setpoint is less conservative (continued) than the tolerance specified by the calibration procedure, .

the channel must be declared inoperable immediately and the '

appropriate Condition entered.

A'N-otehas-b-Ii added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of.

+ this Specification may be entered independently for each Function listed in Table 3.3.8-I in the accompanying LCO.

Mq The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A applies to the actuation logic train function of the Solid State Protection System (SSPS), the radiation monitor functions, and the manual function. Condition A applies to the failure of a single actuation logic train, radiation monitor channel, or manual channel. If one channel or train is inoperable, a period of 7 days is allowed to restore it to OPERABLE status. If the train cannot be restored to OPERABLE status, one FBACS train'must be placed in operation. This accomplishes the actuation instrumentation function and places the unit in a conservative mode of operation. The 7 day Completion Time is the same.as is allowed if one train of the mechanical portion of the system is inoperable. The basis for this time is the same as that provided in LCO 3.7.13.

B.I.1. B.1.2. B.2 Condition B applies to the failure of two FBACS actuation logic trains, two radiation monitors, or two manual channels. The Required Action is to place one FBACS train in operation immediately. This accomplishes the actuation instrumentation function that may have been lost and places the unit in a'conservative mode of operation. The applicable Conditions and Required Actions of LCO 3.7.13 must also be entered for the FBACS train made inoperable by the inoperable actuation instrumentation. This ensures appropriate limits are placed on train inoperability as discussed in the Bases for LCO 3.7.13.

(continued)

WOG STS B 3.3-171 RWy 1, 04/07/95

FBACS B 3.7.13 BASES (continued) BS TF-3(i

A4cv-- .

APPLICABILITY In MODE 1, 2, 3, or 4, the FBACS is required to be OPERABLE to provide fission product removal associated with ECCS leaks due to a LOCA and leakage from containment and annulus.

In MODE 5 or 6, the FBACS is not required to be OPERABLE since the ECCS is not required to be OPERABLE.

During movement of irradiated fuel in the fuel handling area, the FBACS is required to be OPERABLE to alleviate the consequences of a fuel handling accident.

ACTIONS CTIONS A.1 With one FBACS train inoperable, action must be taken to restore OPERABLE status within 7 days. During this period, the remaining OPERABLE train is adequate to perform the J`NA FBACS function. The 7 day Completion Time is based on the risk from an event occurring requiring the inoperable FBACS train, and the remaining FBACS train providing the required protection.

B.1 and B.2 In MODE 1, 2, 3, or 4, when Required Action A.1 cannot be completed within the associated Completion Time, or when both FBACS trains are inoperable, the unit must be placed ir fl a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.I and C.2 When Required Action A.1 cannot be completed within the required Completion Time, during movement of irradiated fuel assemblies in the fuel building, the OPERABLE FBACS train must be started immediately or fuel movement suspended.

This action ensures that the remaining train is OPERABLE, (continued)

WOG STS 8 3.7-68 Rev 1, 04/07/95

AC Sources-Shutdown B 3.8.2-'

BASES LCO It is acceptable for trains to be cross tied during shutdown" (continued) conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during-shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS /A.__1 I An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains are required by LCO 3.8.10, the one train with o,.3 IVA offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

(continued)

WOG STS B 3.8-38 Rev 1, 04/07/95

-77S 7-F- 2 e9~u DC Sources-Shutdown B 3.8.5 BASES LCO interconnecting cabling within the train, are required to be (continued) OPERABLE to support required trains of the distribution systems required OPERABLE by LCO 3.8.10, "Distribution Systems -Shutdown." This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies, provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;,

b. Required features needed to mitigate a fuel handling accident are available; C. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition'.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS A.I. A.2.1. A.2.2. A.2.3. and A.2.4 If two trains are required by LCO 3.8.1,0, the remaining train with DC power available may be capable of supporting sufficient systems to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features inoperable with the associated DC power source(s). inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCD ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the (continued)

WOG STS B 3.8-61 WOG B38-61Rev SS 1, 04/07/95

-7S TF- 3 Inverters -Shutdoi B 3.8 BASES (continued)

LCO The inverters ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The battery powered inverters provide uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kU safety buses are de-energized. OPERABILITY of the inverters requires that the AC vital bus be powered by the inverter. This ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The inverters required to beOPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available

for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS A.I. A.2.1, A.2.2, A.2.3, and A.2.4 If two trains are required by LCO 3.8.10, "Distribution Systems-Shutdown," the remaining OPERABLE Inverters may be capable of supporting sufficient required features to allow 3*o9,3 IVA continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for positive reactivity additions. By the allowance of the option to declare (continued)

WOG STS B 3.8-76 Rev 1, 04/07/95

Distributio'nSystems-Shutdown B 3.8.10 BASES (continued)

ACTIONS A*.1, A.2.1, A.2.2, A.2.3. A.2.4..and A.2.5

+ Although redundant required features may require redundant Y) trains of electrical power distribution subsystems to be

`2 t) AA MA OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions.

In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions).

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore-the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered.

Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

(conti nued)

WOG STS B 3.8-91 Rev 1, 04/07/95

AmerenUE PO Box 620 Cal/awayPlant Fulton, MO 65251 June 3, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P 1-137 Washington, DC 20555-0001 ULNRC-05494 Ladies and Gentlemen:

DOCKET NUMIBER 50-483 CALLAWAY PLANT UNION ELECTRIC CO.

APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NPF-30 Amenn 11F OL1283 - REVISION OF TECHNICAL SPECIFICATIONS 3.3, 3.7, AND 3.8 AmerenUE herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant.

The proposed changes will revise Technical Specifications (TSs) 3.3.7, 3.3.8, 3.7.10, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This amendment will:

a. Delete MODES 5 and 6 from the LCO Applicability for the Control Room Emergency Ventilation System and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively). It will be shown that the event that heretofore required these LCOs to be applicable in MODES 5 and 6 (waste gas decay tank rupture) requires no mitigation at Callaway in order to meet GDC 19.

b. Adopt NRC-approved traveler TSTF-36-A for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This change will add an exclusion from LCO 3.0.3 that recognizes that irradiated fuel movement in the fuel building is independent of reactor operation in MODES 1-4 and defaulting to LCO 3.0.3 would force an unnecessary plant shutdown.

c. Add a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not only during MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE in which the plant is operating.

Attachments 1 through 6 provide the Evaluation, Markup of Technical Specifications, Retyped Technical Specifications, Proposed Technical Specification Bases Changes, FSAR markups, and an informational courtesy copy of TSTF-36-A, Revision 4 (with NUTREG-1431 markups only), respectively, in support of this amendment request. Attachments 4 through 6 are provided for information only.

a subsidiaryof Ameren Corporation

ULNRC-05494 June 3, 2008 Page 2 Final Bases changes will be processed under our program for updates per TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment is implemented. Final FSAR changes will be processed per the update requirements of 10 CFR 50.71(e). No commitments are contained in this amendment application.

It has been determined that this amendment application does not involve a.

significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the attached licensing evaluations and have approved the submittal of this amendment application.

AmerenUE requests approval of this LAR prior to February 1, 2009.

AmerenUE further requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.

In accordance with 10 CFR 50.91, a copy of this amendment application is being provided to the designated Missouri State official. If you have any questions on this amendment application, please contact me at (573) 676-8129, or Mr. Scott Maglio at (573) 676-8719.

I declare under penalty of perjury that the foregoing is true and correct.

Very truly yours, Executed on: -T...JT, IaO Luke H. Graessle Manager, Regulatory Affairs

ULNRC-05494 June 3, 2008 Page 3 GGY/nls Attachments 1 - Evaluation 2 - Markup of Technical Specifications 3 - Retyped Technical Specifications 4 - Proposed Technical Specification Bases Changes (for information only) 5 - FSAR markups (for information only) 6 - Informational copy of TSTF-36-A, Revision 4 (with NUREG-1431 markups only)

ULNRC-05494 June 3, 2008 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. Elmo E. Collins, Jr.

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. Mohan C. Thadani (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738

ULNRC-05494 June 3, 2008 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed).

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

C. D. Naslund A. C. Heflin T. E. Herrmann L. H. Graessle G. A. Hughes S. A. Maglio S. L. Gallagher L. M. Belsky (NSRB)

T. B. Elwood G. G. Yates Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU)

Mr. Scott Bauer (Palo Verde)

Mr. Stan Ketelsen (PG&E)

Mr. Scott Head (STP)

Mr. John O'Neill (Pillsbury, Winthrop, Shaw, Pittman LLP)

Missouri Public Service Commission Mr. Floyd Gilzow (DNR)

Page 1 of 18 EVALUATION

1. DESCRIPTION Page 2

2. PROPOSED CHANGES Page 2

3. BACKGROUND Page 3

4. TECHNICAL ANALYSIS Page 7

5. REGULATORY SAFETY ANALYSIS Page 12 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION Page 13 5.2 APPLICABLE REGULATORY REQU'REMENTS/CRITER!A Page 15

6. ENVIRONMENTAL CONSIDERATION Page 18

7. REFERENCES Page 18

8. PRECEDENTS Page 18 Page 2 of 18 EVALUATION

1.0 DESCRIPTION

The proposed changes in this amendment application would revise Technical Specifications (TSs) 3.3.7, 3.3.8, 3.7.10, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This amendment will:

a. Delete MODES 5 and 6 from the LCO Applicability for the Control Room Emergency Ventilation System and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively). It will be shown that the event that heretofore required these LCOs to be applicable in MODES 5 and 6 (waste gas decay tank rupture) requires no mitigation at Callaway in order to meet GDC 19.

b. Adopt NRC-approved traveler TSTF-36-A for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This change will add an exclusion from LCO 3.0.3 that recognizes that inadiated fuel movement in the fuel-building is independent of reactor operation in MODES 1-4 and defaulting to LCO 3.0.3 would force an unnecessary plant shutdown.

c. Add a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not only during MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE in which the plant is operating.

2.0 PROPOSED CHANGE

S This amendment application contains three groups of related changes.

2.1 Control Room Emergency Ventilation System (CREVS) and Actuation Instrumentation TS 3.3.7, "Control Room Emergency Ventilation System Actuation Instrumentation,"

and TS 3.7.10, "Control Room Emergency Ventilation System (CREVS)," are revised to delete MODE 5 and MODE 6 from the LCO Applicability. The specific TS changes are as follows: .

" Condition E of TS 3.3.7 is revised to delete "in MODE 5 or 6, or" and the comma after "CORE ALTERATIONS" is also deleted.

TS Table 3.3.7-1 is revised to delete "5, 6," under the APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS column for Functions 1, 2, and 3. An editorial correction is made to add a period at the end of Table footnote (c).

Page 3 of 18

The LCO Applicability for TS 3.7.10 is revised to delete "5, and 6," and the word "and" is inserted between "3," and "4."

Conditions D and E of TS 3.7.10 are revised to delete "in MODE 5 or 6, or."

2.2 TSTF-36-A TS 3.3.8, "Emergency Exhaust System Actuation Instrumentation," TS 3.7.13, "Emergency Exhaust System (EES)," TS 3.8.2, "AC Sources - Shutdown," TS 3.8.5, "DC Sources - Shutdown," TS 3.8.8, "Inverters - Shutdown," and TS 3.8.10, "Distribution Systems - Shutdown" are revised to add an ACTIONS Note per NRC-approved TSTF-36-A Revision 4 (copy provided in Attachment 6). This Note reads:

"LCO 3.0.3 is not applicable."

2.3 Electrical Power Systems in MODES 5 and 6 (Shutdown Conditions)

TS 3.8.2, "AC Sources - Shutdown," TS 3.8.5, "DC Sources - Shutdown," TS 3.8.8, "Inverters - Shutdown," and TS 3.8.10, "Distribution Systems - Shutdown" are revised to add the following to the LCO Applicability:

"During movement of irradiated fuel assemblies."

The first group of changes is based on a radiological consequence (dose) calculation for an unmitigated waste gas decay tank rupture. The second group of changes is based on an NRC-approved traveler that is reflected in the current Revision 3.1 of the Standard Technical Specifications (STS) for Westinghouse NSSS plants, NUREG-1431. The third group of changes is a more restrictive change that recognizes the electrical power system requirements that should be in place even if the plant is not in any MODE per the Definitions of TS 1.1 (no fuel in the reactor vessel).

The TS markups and retyped pages are provided in Attachments 2 and 3, respectively.

Corresponding TS Bases changes are provided for information only in Attachment 4.

3.0 BACKGROUND

This section provides background information on the systems affected by the proposed TS changes.

Page 4 of 18 3.1 Control Room Emergency Ventilation System (CREVS) and Actuation Instrumentation The CREVS provides a protected environment from which the control room operators can control the plant following an uncontrolled release of radioactivity. The CREVS consists of two independent, redundant trains that pressurize, recirculate, and filter the control room air. Each CREVS train consists of a filtration system train and a pressurization system train. Each filtration system train consists of a fan, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Each pressurization system train consists of a fan, a moisture separator, an electric heater, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Ductwork, valves or dampers, and instrumentation also form part of the CREVS system.

The CREVS is an emergency system which may also operate during normal plant operation. Actuation of the CREVS by a Control Room Ventilation Isolation Signal (CRVIS) places the system in the emergency mode of operation. Actuation of the system to the emergency mode of operation closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the control room air through the redundant trains of HEPA filters and charcoal adsorbers. The emergency (CRVIS) mode also initiates pressurization and filtered ventilation of the air supply to the control room.

The CREVS actuation instrumentation consists of two gaseous radiation channels in the control room air intake. A high radiation signal from either of these channels will initiate both trains of the CREVS. The control room operator can also initiate CREVS trains by manual switches in the control room. The CREVS is also actuated by a Phase A containment isolation signal, a fuel building ventilation isolation signal (FBVIS), or a high radiation signal from the containment purge exhaust gaseous radiation channels.

The control room pressurization system draws in outside air, processing it through a particulate filter charcoal adsorber train for cleanup. This outside air is diluted with air drawn from the cable spreading rooms and the electrical equipment floor levels within the control building and distributed back into those spaces for further dilution. The control room filtration units take a portion of air from the exhaust side of the system, upstream of the outside air intake, for dilution with portions of the exhaust air from the control room air-conditioning system and processes it through the control room filtration system adsorption train for additional cleanup. This air is then further diluted with the remaining control room air-conditioning system return air, cooled, and supplied to the control room. This process maintains the control room under a positive pressure of 1/8 inch water gauge with respect to the outside atmosphere. This assures exfiltration from the control room, thus preventing any unprocessed contaminants from entering the control room.

Page 5 of 18 The CREVS is designed to maintain the control room environment for 30 days of continuous occupancy after a design basis accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body. Applicable design basis accidents that could cause a radioactivity release, and thus demand the safety function provided by CREVS, include a loss of coolant accident (LOCA), steam generator tube rupture (SGTR), fuel handling accident (FHA) inside containment, and FHA in the fuel building. For shutdown conditions, however, only the FHA is of concern and that is the event responsible for requiring CREVS and its actuation instrumentation to be OPERABLE during movement of irradiated fuel assemblies. Evaluation Section 4.1 discusses the postulated waste gas decay tank rupture event.

3.2 Emergency Exhaust System (EES) and Actuation Instrumentation The EES consists of two independent and redundant trains. Each train consists of a heater, a prefilter, a HEPA filter bank, an activated charcoal adsorber section for removal of gaseous activity (principally iodi-nes)ý, and a fan. Ductwork, dampers, and instrumentation also form part of the system. A second bank of HEPA filters follows the adsorber section to collect carbon fines.

The EES serves both the auxiliary building and the fuel building. Following a. safety injection signal (SIS), safety-related dampers isolate the auxiliary building and the EES exhausts potentially contaminated air due to leakage from ECCS systems. The EES can also filter airborne radioactive particulates from the area of the spent fuel pool following an FHA in the fuel building.

As described in FSAR Section 9.4.2, the EES collects and processes the airborne particulates in the fuel building in the event of an FHA. In the event of a LOCA, the EES processes the atmosphere of the auxiliary building. The EES is on standby for an automatic start following receipt of a fuel building ventilation isolation signal (FBVIS) or an SIS.

Upon receipt of an FBVIS initiated manually or automatically upon a high radiation signal (gaseous), normal air discharges from the building are terminated, the fuel building is isolated, the stream of ventilation air discharges through the system filter trains, and a CRVIS is generated. High gaseous radiation, monitored by two channels in the fuel building exhaust, provides an FBVIS. Both EES trains are initiated by high radiation detected by either channel. High radiation detected by either monitor initiates fuel building isolation, starts the EES, and initiates a CRVIS. These actions function to prevent exfiltration of contaminated air by initiating filtered exhaust, which imposes a negative pressure on the fuel building. In the FBVIS mode, each train is capable of maintaining the fuel building at a negative pressure of less than or equal to 0.25 inches water gauge relative to the outside atmosphere.

Page 6 of 18 3.3 Electrical Power Systems in MODES 5 and 6 (Shutdown Conditions)

AC Sources The Class 1E AC sources consist of the offsite power sources (preferred power sources, normal and alternate) and the onsite standby power sources (train A and train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17, the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the engineered safety feature (ESF) systems. The onsite Class 1E AC distribution system is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG. Offsite power is supplied to the plant switchyard from the transmission network by four transmission lines. From the switchyard, two electrically and physically separated circuits provide AC power, through ESF transformers, to the 4.16 kV ESF buses. Automatic load tap changers associated with the ESF transformers, as well as associated capacitor banks, provide voltage regulation for the preferred sources in the event of changing switchyard voltage.

An offsite circuit consists of all breakers, transformers, voltage regulation equipment, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF buses. The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. DGs NEO1 and NE02 are dedicated to ESF buses NB0I and NB02, respectively. A DG starts automatically on an SIS (initiated by low pressurizer pressure, low steam line pressure, or high containment pressure signals) or on an ESF bus undervoltage signal. After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an SIS.

The DGs will also start and operate in the standby mode without tying to the ESF bus on an SIS alone.

DC Sources The DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety-related equipment and preferred AC vital bus power (via inverters). As required by 10 CFR 50, Appendix A, GDC 17, the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure.

The 125 VDC electrical power system consists of two independent and redundant Class 1E DC electrical power subsystems (train A and train B). Each DC electrical subsystem consists of two 125 VDC batteries, two battery chargers, one swing battery charger and all the associated control equipment and interconnecting cabling. During normal operation, the 125 VDC load is powered from the battery chargers with the batteries Page 7 of 18 floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries. The train A and train B DC electrical power subsystems provide the control power for associated Class 1E AC power load groups, 4.16 kV switchgear, and 480 V load centers. The DC electrical power subsystems also provide DC electrical power to the inverters, which in turn power the AC vital buses.

Inverters The inverters are the preferred source of power for the AC vital buses because of the stability and reliability they achieve. The function of the inverter is to provide AC electrical power to the vital buses. The inverters are normally powered from the station battery; however, a backup AC source provides another source of inverter output via a static switch internal to the inverter. An alternate source of power to the AC vital buses is provided from Class IE constant voltage transformers. The station battery provides an uninterruptible power source for the instrumentation and controls for the Reactor Trip System (RTS) and the Engineered Safety Feature Actuation System (ESFAS).

Distribution Systems The onsite Class IE AC, DC, and AC vital bus electrical power distribution systems are divided by train into two redundant and independent AC, DC, and AC vital bus electrical power distribution subsystems as defined in TS Bases Table B 3.8.9-1. Train A is associated with AC load group 1; train B, with AC load group 2. The AC electrical power subsystem for each train consists of a 4.16 kV ESF bus and 480 V buses and load centers. Each 4.16 kV ESF bus has one separate and independent offsite source of power as well as a dedicated onsite DG source. Each 4.16 kV ESF bus is normally connected to a preferred offsite source. After a loss of the preferred offsite power source to a 4.16 kV ESF bus, the onsite emergency DG supplies power to the bus. A transfer to the alternate offsite source is accomplished by manually repositioning breakers, if required. Control power for the 4.16 kV breakers is supplied from the Class 1E batteries.

The 120 VAC vital buses are arranged in two load groups per train and are normally powered through the inverters from the 125 VDC electrical power subsystem. TS Bases B 3.8.7 has further information on the 120 VAC vital system.

The 125 VDC electrical power distribution system is arranged into two buses per train.

TS Bases B 3.8.4 has further information on the 125 VDC electrical power subsystem.

4.0 TECHNICAL ANALYSIS

The following provides further technical analysis and discussion of the three groups of related changes in the order presented in Evaluation Sections 1.0 and 2.0 above.

Page 8 of 18 4.1 Deletion of MODES 5 and 6 from TS 3.3.7 and TS 3.7.10 -

Control Room Radiological Consequences of a Waste Gas Decay Tank Rupture The STS and STS Bases for Westinghouse plants, NUJREG- 1431, have brackets around the MODE 5 and MODE 6 Applicability in TS 3.3.7 and TS 3.7.10. Those brackets indicate that individual licensees would adopt MODES 5 and 6 if the waste gas decay tank rupture requires control room staff protection. If that event requires no mitigation or control room habitability protection, then MODES 5 and 6 need not be required in the LCO Applicability for TS 3.3.7 and TS 3.7.10.

The waste gas decay tanks are designed to permit the decay of radioactive gases as a means of reducing or preventing the release of radioactive materials to the atmosphere.

For this accident it is postulated that there is an accidental release of the contents of one of the waste gas decay tanks resulting from a rupture of the tank or from another cause, such as operator error or valve malfunction. The gaseous waste processing system is so designed that the tanks are isolated from each other during use, limiting the quantity of gas released in the event of an accident by preventing the flow of radioactive gas between the tanks. The principal radioactive components of the waste gas decay tanks are the noble gases krypton and xenon, the particulate daughters of some of the krypton and xenon isotopes, and trace quantities of halogens. The maximum amount of waste gases stored in any one tank occurs after a refueling shutdown, at which time the waste gas decay tanks store the radioactive gases stripped from the reactor coolant. The maximum content of a waste gas decay tank is conservatively assumed for the purpose of computing the noble gas inventory available for release. Rupture of the waste gas decay tank is assumed to occur immediately upon completion of the waste gas transfer, releasing the entire contents of the tank to the radwaste building. For the purposes of evaluating the accident, it is assumed that all the activity is immediately released directly to the environment during the 2-hour period immediately following the accident, with no credit taken for decay, holdup in the radwaste building, mixing, or the operation of the radwaste building ventilation system's non-safety charcoal adsorbers.

Offsite doses for a waste gas decay tank rupture are discussed in FSAR Section 15.7.1 and are reported in FSAR Table 15.7-4; however, that table does not report control room doses. A calculation has been performed with no credit taken for the mitigation capability of the CREVS. Using dose conversion factors (DCFs) from FSAR Table 15A-4 (including ICRP-30 for thyroid DCFs and Federal Guidance Report 12 for whole body DCFs), control room thyroid and whole body doses have been calculated for the duration of a waste gas decay tank rupture.

The calculated values are two orders of magnitude less than the regulatory limits for control room occupants; the regulatory limits are 30 rem thyroid and 5 rem whole body.

Attachment I Page 9 of 18 The NRC Staff has provided a set of considerations that should be addressed regarding control room habitability analyses performed in support of license submittals. These considerations were provided in Regulatory Issue Summary (RIS) 2001-19, "Deficiencies in the Documentation of Design Basis RadiologicalAnalyses Submitted in Conjunction with License Amendment Requests. "

The following discussion addresses the issues from RIS 2001-019:

a. The control room design is often optimized for the DBA LOCA, and the protection afforded for other accident sequences may not be as advantageous. For example, in most designs, control room isolation is actuated by engineered safety feature (ESF) signals such as containment high pressure or safety injection (SI),

or radiation monitors, or both. For accidents that rely on radiation monitor actuation, there may be a time delay in isolation that would not occur for the immediate SI signal that would result from a LOCA. In such cases, contaminated air would enter the control room for a longer period preceding isolation than it would for a LOCA.

AmerenUE Response:

As stated above, initiation of control room isolation was intentionally not modeled in the analysis for this amendment.

b. The configuration of radiation monitors has an impact on their sensitivity.

Ideally, the radiation monitors would be located outside in air ventilation intake ductwork. However, there are system designs that place the radiation monitor in recirculation ductwork or downstream of filters. There are also designs that use area radiation monitors. In these latter designs, the contaminated air continues to build up in the control room volume until the concentration is large enough to actuate the radiation monitor.

AmerenUE Response:

Callaway plant's control room intake radiation monitors are located in the normal intake ductwork. These radiation monitors measure the concentration of outside air and are not downstream of any filters. However, no credit for these radiation monitors was taken in the analysis for this amendment.

c. In some cases, control room radiation monitor setpoints may have been based on external exposure concerns, for example, 2.5 mrem!hour, rather than thyroid dose from inhalation. The airborne concentration of radioiodines will likely cause elevated thyroid doses before reaching the concentration of all radionuclides necessary to alarm the monitor. This condition is typically seen with accidents that involve a high iodine-to-noble-gas ratio, such as main steam line breaks in PWRs.

Page 10 of 18 AmerenUE Response:

Initiation of control room isolation was intentionally not modeled in the analysis for this amendment.

d. The distance between the control room and the release point, and the associated wind sectors, may be different for each postulated accident. These differences are usually not significant with regard to offsite doses, but may be significant for control room assessments because of the shorter distances typically involved. The x/Q for the DBA LOCA may not be applicable to other DBAs. A ground-level release associated with a non-LOCA event may be more limiting than the elevated release associated with LOCAs at plants with secondary containments or enclosure buildings.

AmerenUE Response:

The analysis for this amendment used the 0-8 hour control room X/Q value currently provided in Callaway FSAR Table 15A-2 for the containment leakage dose pathway, which is considered to be a ground level release. This is the most limiting value available from that table.

e. Licensees should ensure that assumptions regarding control room isolation and infiltration can be supported by appropriate test results or engineering evaluations.

Twenty percent of the licensed power reactors have performed tracer gas tests of control room integrity. All of the tests performed identified as-found infiltration rates greater than those assumed in the design basis calculations.

AmerenUE Response:

AmerenUE responded separately to NRC Generic Letter 2003-01 via ULNRC-04885 dated August 11, 2003 and the license amendment request submitted via ULNRC-05463 dated January 14, 2008. Control room in-leakage will be resolved separately from the license amendment requested herein.

f. The use of personal respirators or the use of potassium iodide (KI) as a thyroid prophylaxis should not be credited as a substitute for process controls or other engineering controls as discussed in 10 CFR 20.1702.

AmerenUE Response:

The analysis for this amendment does not credit respirators or potassium iodide.

Page 11 of 18 Radiological Consequence Conclusions The waste gas decay rupture consequences on control room occupants are much lower than the regulatory limits (30 rem thyroid, 5 rem whole body). Therefore, it can be concluded that mitigation of this event by the CREVS and its actuation instrumentation is not required. TS 3.3.7 and TS 3.7.10 can, therefore, be revised to delete MODES 5 and 6 from the LCO Applicability.

4.2 TSTF-36-A Change to Add LCO 3.0.3 Exceptions to TS 3.3.8, TS 3.7.13, TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10 Technical Specifications 3.3.8 and 3.7.13 currently apply during the movement of irradiated fuel assemblies in the fuel building. The shutdown electrical specifications (TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10) are being revised by this amendment application to also apply during the movement of irradiated fuel assemblies (as discussed in Evaluation Section 4.3 below). Irradiated fuel assemblies stored in the fuel building's spent fuel pool may be moved during MODES 1-4 for a variety of reasons, such as:

" B.5.b required shuffles

Fuel shuffles during new fuel receipt

" Fuel movements required to meet TS 3.7.17 and Specification 4.3.1.1 (Region 1 storage vs. Regions 2 and 3)

" Healthy fuel inspections as part of the INPO Zero by 2010 Initiative (to improve fuel performance)

Inspections of suspected leaking fuel rods

Inspections of lead test assemblies (when used)

Moving fuel to dry cask storage (future activity that might be required)

Future spent fuel pool re-racks (if needed).

As discussed in the ACTIONS Bases for TS 3.7.15, "Fuel Storage Pool Water Level," TS 3.7.16, "Fuel Storage Pool Boron Concentration," and TS 3.7.17, "Spent Fuel Assembly Storage," the movement of irradiated fuel assemblies while in MODES 1, 2, 3, and 4 is independent of reactor operations. The LCO 3.0.3 exclusion in TSs 3.7.15 through 3.7.17 should also apply to the TSs in the proposed change. There should be no requirement for the plant to experience the perturbations and shutdown transition risk associated with a forced reactor shutdown per LCO 3.0.3 for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10 in the event of a situation unforeseen by the current TSs or in the event of failure to meet a Required Action or Completion Time in these TSs. These TSs all contain a default Required Action, in the event other Required Actions or Completion Times are not met or for noncompliance with the LCO, to immediately suspend movement of irradiated fuel assemblies. Under a scenario in MODES 1-4 where irradiated fuel movement in the fuel building could not be immediately suspended for some reason, the required response should be to continue taking steps to suspend fuel movement activities, not enter LCO 3.0.3 with its 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for shutdown preparation followed by a shutdown to MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . In this scenario entering LCO Page 12 of 18 3.0.3 would be contrary to safety. The desired plant state is one in which an FHA is no longer possible and irradiated fuel movement has been secured. LCO 3.0.3 is intended to position the plant such that the MODES or specified conditions in the Applicability of a given TS are exited. In the affected TSs, the specified condition "During movement of irradiated fuel assemblies" is not exited by virtue of entering LCO 3.0.3.

NRC approved TSTF-36-A (Reference 7.1) and it was incorporated into Revision 2 of NUREG- 1431. This amendment takes no exceptions to the TS changes approved in TSTF-36-A.

4.3 Electrical Power Systems During Shutdown MODES 5 and 6 The STS and STS Bases for Westinghouse plants, NUREG-1431, include the following specified condition in the LCO Applicability for TS 3.8.2, TS 3.8.5, TS 3.8.8, and TS 3.8.10:

"During movement of [recently] irradiated fuel assemblies."

Callaway is not adopting the bracketed "[recently]" portion of that specified condition at this time; it was the subject of a separate traveler (TSTF-51-A). However, the rest of that specified condition will be adopted. During full core offloads, no MODES apply per the TS 1.1 Definitions since there is no fuel in the reactor vessel. However, electrical power requirements should still be observed for the removal of decay heat from the spent fuel pool and to mitigate the potential consequences of a fuel handling accident in the fuel building. While the definition of OPERABLE - OPERABILITY addresses the support to supported system relationships, including all necessary attendant electrical power support, questions can arise with respect to whether normal or emergency power is required during full core offloads. In order to conservatively address this concern, the LCO Applicability in the shutdown electrical power system TSs will adopt this as a prudent, albeit more restrictive, change.

5.0 REGULATORY SAFETY ANALYSIS This section addresses the standards of 10 CFR 50.92 as well as the applicable regulatory requirements and acceptance criteria.

The proposed changes in this amendment application would revise Technical Specifications (TSs) 3.3.7, 3.3.8, 3.7.10, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This amendment will:

a. Delete MODES 5 and 6 from the LCO Applicability for the Control Room Emergency Ventilation System and its actuation instrumentation (TS 3.7.10 and TS 3.3.7, respectively). It will be shown that the event that heretofore required these LCOs to be applicable in MODES 5 and 6 (waste gas decay tank rupture)

Page 13 of 18 requires no mitigation at Callaway in order to meet GDC 19.

b. Adopt NRC-approved traveler TSTF-36-A for TSs 3.3.8, 3.7.13, 3.8.2, 3.8.5, 3.8.8, and 3.8.10. This change will add an exclusion from LCO 3.0.3 that recognizes that irradiated fuel movement in the fuel building is independent of reactor operation in MODES 1-4 and defaulting to LCO 3.0.3 would force an unnecessary plant shutdown.

c. Add a more restrictive change to the LCO Applicability for TSs 3.8.2, 3.8.5, 3.8.8, and 3.8.10 such that these LCOs apply not only during MODES 5 and 6, but also during the movement of irradiated fuel assemblies regardless of the MODE in which the plant is operating.

5.1 No Significant Hazards Consideration (NSHC)

AmerenUE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," Part 50.92(c), as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes to delete MODES 5 and 6 from the LCO Applicability of Technical Specifications (TSs) 3.3.7 and 3.7.10, adopt TSTF-36-A, and revise the LCO Applicability of the shutdown electrical specifications to be more restrictive does not alter plant design or operation; therefore, these changes will not increase the probability of any accident.

Overall protection system performance will remain within the bounds of the previously performed accident analyses since there are no design changes. All design, material, and construction standards that were applicable prior to this amendment request will be maintained. There will be no changes to any design or operating limits.

The proposed changes will not adversely affect accident initiators or precursors nor adversely alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes will not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended functions to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed changes do not physically alter safety-related systems nor affect the way in which safety-related systems perform their functions.

Page 14 of 18 Deleting MODES 5 and 6 from the LCO Applicability of TS s 3.3.7 and 3.7. 10 does not significantly increase the consequences of any accident since it has been demonstrated that the radiological consequences to control room occupants from a waste gas decay tank rupture will remain much less than the regulatory limits with no mitigation from the Control Room Emergency Ventilation System (CREVS) in MODES 5 and 6. The acceptance criteria for this event will continue to be met.

The adoption of TSTF-36-A will not affect the equipment and LCOs needed to mitigate the consequences of a fuel handling accident in the fuel building; however, this change

'will reduce the chances of an unnecessary plant shutdown due to activities in the fuel building that have no bearing on the operation of the rest of the plant and the reactor core inside the containment building.

The changes to the shutdown electrical specifications will add an additional restriction that is consistent with the objective of being able to mitigate a fuel handling accident during all situations, including a fuall core offload, in which such ani accident could occur.

.All accident analysis acceptance criteria will continue to be met with the proposed changes. The proposed changes will not affect the source termi, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. After a postulated release from a waste gas decay tank rupture no CREVS mitigation is required. The applicable radiological dose criteria will continue to be met.

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

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

Response: No There are no proposed design changes nor are there any changes in the method by which any safety-related plant structure, system, or component (SSC) performs its specified safety function. The proposed changes will not affect the normial method of plant operation or change any operating parameters. Equipment performance necessary to fulfill safety analysis missions will be unaffected. The proposed changes will not alter any assumptions required to meet the safety analysis acceptance criteria.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this amendment. There will be no adverse effect or challenges imposed on any safety-related system as a result of this amendment.

Page 15 of 18 The proposed amendment will not alter the design or performance of the 7300 Process Protection System, Nuclear Instrumentation System, or Solid State Protection System used in the plant protection systems.

The proposed changes to delete MODES 5 and 6 from the LCO Applicability of TSs 3.3.7 and 3.7.10, adopt TSTF-36-A, and revise the LCO Applicability of the shutdown electrical specifications to be more restrictive do not, therefore, create the possibility of a new or different accident from any accident previously evaluated.

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

Response: No There will be no effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, heat flux hot channel factor (FQ), nuclear enthalpy rise hot channel factor (FAH), loss of coolant accident peak cladding temperature (LOCA PCT), peak local power density, or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met. It has been demonstrated that the CREVS and its actuation instrumentation are not required to mitigate the control room radiological consequences of a waste gas decay tank rupture.

The proposed changes do not eliminate any surveillances or alter the frequency of surveillances required by the Technical Specifications. None of the acceptance criteria for any accident analysis will be changed.

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

==

Conclusion:==

Based on the above evaluation, AmerenUE concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 - Applicable Regulatory Requirements / Criteria Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The U.S. Nuclear Regulatory Commission's (NRC's) requirements related to the content of the TSs are contained in Section 50.36 of Title 10 of the Code of FederalRegulations (10 CFR 50.36) which requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems Page 16 of 18 settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements per 10 CFR 50.36(c)(3); (4) design features; and

.(5) administrative controls.

Licensees may revise the TSs to adopt current format and content of NUJREG-143 1 Revision 3.1, "Standard Technical Specifications, Westinghouse Plants," provided that a plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative, or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. This amendment application contains elements of the second and third elements above.

The following regulatory requirements and guidance documents also apply to the affected actuation instrumentation, CREVS, EES, and electrical power systems:

" GDC 2 requires that structures, systems, and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

GDC 4 requires that structures, systems, and components important to safety be designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with the normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, discharging fluids that may result from equipment failures, and from events and conditions outside the nuclear power unit. However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.

GDC 13 requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems.

.Attachment 1 Page 17 of 18 GDC 17 and GDC 18 require that the design of the electrical power systems contain sufficient independence, redundancy, inspection readiness and testability to ensure an available source of power to permit the functioning of structures, systems, and components important to safety.

GDC 19 requires that a control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent, to any part of the body, for the duration of the accident.

GDC 20 requires that the protection system(s) shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel 1 design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

GDC 21 requires that the protection system(s) shall be designed for high functional reliability and testability.

GDC 22 through GDC 25 and GDC 29 require various design attributes for the protection system(s), including independence, safe failure modes, separation from control systems, requirements for reactivity control malfunctions, and protection against anticipated operational occurrences.

Regulatory Guide 1.22 discusses an acceptable method of satisfying GDC-20 and GDC-21 regarding the periodic testing of protection system actuation functions.

These periodic tests should duplicate, as closely as practicable, the performance that is required of the actuation devices in the event of an accident.

Regulatory Guide 1.24 describes methods acceptable to the NRC staff for licensee evaluation of the potential radiological consequences of a waste gas decay tank rupture accident.

" 10 CFR 50.55a(h) requires that the protection systems meet IEEE 279-1971.

Section 4.2 of IEEE 279-1971 discusses the general functional requirement for protection systems to assure they satisfy the single failure criterion.

There will be no changes to the actuation instrumentation, CREVS, EES, or electrical power systems such that compliance with any of the regulatory requirements and guidance documents above would come into question. The above evaluations confirm that the plant will continue to comply with all applicable regulatory requirements.

Page 18 of 18 In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

AmerenUE has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 5 .2"21-b), no enviro=rental impact statement or environmental assessment, need be prepared in connection with the proposed amendment.

7.0 REFERENCES

7.1 Technical Specification Task Force, Improved Standard Technical Specifications Change Traveler, TSTF-36-A, Revision 4, "Addition of LCO 3.0.3 N/A to Shutdown Electrical Power Specifications," approved by NRC on November 1, 1999.

8.0 PRECEDENTS The options of whether or not to adopt the MODE 5 and MODE 6 LCO Applicability in TS 3.3.7 and TS 3.7.10 as well as the specified condition "during movement of irradiated fuel assemblies" in the LCO Applicability of the shutdown electrical specifications (TS 3.8.2, TS 3.8.5, TS 3.8.8, TS 3.8.10) were included in NUREG-1431 Revision 1 which was the set of Standard Technical Specifications upon which Callaway's ITS conversion (License Amendment 133) was based. TSTF-36-A was approved by NRC on November 1, 1999, and later incorporated into Revision 2 of NUREG-143 1. Several plants that converted to the ITS after Callaway have adopted the changes contained in TSTF-36-A, such as Duane Arnold (License Amendment 223), Prairie Island (License Amendment 158/149), Quad Cities (License Amendment 199/ 195), and Fitzpatrick (License Amendment 176) to name a few as listed in ADAMS.

ATTACHMENT 2 MARKUP OF TECHNICAL SPECIFICATIONS

CREVS Actuation Instrumentation 3.3.7 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME C. Both radiation monitoring C.1.1 Enter applicable Immediately channels inoperable. Conditions and Required Actions of LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)," for one CREVS train made inoperable by inoperable CREVS actuation instrumentation.

AND C.1.2 Place one CREVS train, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in CRVIS mode.

OR C.2 Place both trains in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months CRVIS mode.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time for Conditions A, B, AND or C not met in MODE 1, 2, 3, or 4. D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Required Action and E.1 Suspend CORE Immediately associated Completion ALTERATIONS.

Time for Conditions A, B, or C not met in MODE - Or G,* AND

--or-during CORE -

ALTERATION;Sor during E.2 Suspend movement of Immediately movement of irradiated fuel irradiated fuel assemblies. assemblies.

CALLAWAY PLANT 3.3-63 Amendment No. 165 1

CREVS Actuation Instrumentation 3.3.7 Table 3.3.7-1 (page 1 of 1)

CREVS Actuation Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE TRIP FUNCTION CONDITIONS CHANNELS REQUIREMENTS SETPOINT

1. Manual 1, 2, 3, 4, 2 SR 3.3.7.4 NA Initiation (a), and (c)

2. Automatic 1, 2, 3, 4, 2 trains SR 3.3.7.3 NA Actuation (a), and (c)

Logic and Actuation (a) 2 trains SR 3.3.7.6 NA Relays (BOP ESFAS),

3. Control Room 1, 2, 3, 4 2 SR 3.3.7.1 (b)

Radiation - and (a) SR 3.3.7.2 Control Room SR 3.3.7.5 Air Intakes (a) 2 SR 3.3.7.6 (b)

4. Containment Refer to LCO 3.3.2, "ESFAS Instrumentation," Function 3.a, for all initiation functions and Isolation - requirements.

Phase A

5. Fuel Building Refer to LCO 3.3.8, "EES Actuation Instrumentation," for all initiation functions and Exhaust requirements.

Radiation-Gaseous (a) During CORE ALTERATIONS or during movement of irradiated fuel assemblies within containment.

(b) Nominal Trip Setpoint concentration value (ltCi/cm 3) shall be established such that the actual submersion dose rate would not exceed 2 mR/hr in the control room.

(c) During movement of irradiated fuel assemblies in the fuel building#

A CALLAWAY PLANT 3.3-65 Amendment No. 165 1

EES Actuation Instrumentation 3.3.8 3.3 INSTRUMENTATION 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation LCO 3.3.8 The EES actuation instrumentation for each Function in Table 3.3.8-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.8-1.

ACTIONS 61 0-a 9o.3 F..r

-- - - - -**':- '= --------- ----- ----- ----

~NOTE

$e Separate Cohdition entry is allowed for each Function.

COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One or more Functions A.1 Place one EES train in 7 days with one channel or train the Fuel Building inoperable. Ventilation Isolation Signal (FBVIS) mode.

AND A.2 Place one CREVS train 7 days in Control Room Ventilation Isolation Signal (CRVIS) mode.

(continued)

CALLAWAY PLANT 3.3-66 Amendment No. 165 I

CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS)

LCO 3.7.10 Two CREVS trains shall be OPERABLE.

:-- ,*t--- . ----- N O TE Iw---

7L, ----

I** ----------------

The control rodm boundary' may be open ed ihtermittently under administrative control.

APPLICABILITY: MODES 1, 2,3, During movement of irradiated fuel assemblies.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One CREVS train A.1 Restore CREVS train to 7 days inoperable. OPERABLE status.

B. Two CREVS trains B.1 Restore control room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable control room status.

boundary in MODES 1, 2, 3, and 4.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or4. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

CALLAWAY PLANT 3.7-25 Amendment No. 176

CREVS 3.7.10 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREVS train in CRVIS Time of Condition A not met mode.

-'n ODE,- 5 _ , crduring movement of irradiated fuel assemblies.

OR D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

E. Two CREVS trains E.1 Suspend CORE Immediately inoperablc -*,,.M E o, ,, ALTERATIONS;

--er-during movement of irradiated fuel assemblies.

AND E.2 Suspend movement of Immediately irradiated fuel assemblies.

F. Two CREVS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

CALLAWAY PLANT 3.7-26 Amendment No. 184

Emergency Exhaust System 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Emergency Exhaust System (EES)

LCO 3.7.13 Two EES trains shall be OPERABLE.

NOTE The auxiliary or fuel building boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies in the fuel building.

-- ---- ----<N O T E----- --------

The SIS mode of operation is required only'in MODES 1, 2, 3 and 4. The FBVIS mode of operation is required only during movement of irradiated fuel assemblies in the fuel building.

.. CTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One EES train inoperable. A.1 Restore EES train to 7 days OPERABLE status. I B. Two EES trains inoperable B.1 Restore auxiliary building 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to inoperable auxiliary boundary to OPERABLE building boundary in status.

MODE 1,2, 3 or 4.

(continued) co~r -- q r-0.Z -. ..

CALLAWAY PLANT 3.7-32 Amendment No. 184

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:,

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem required by LCO 3.8.10, "Distribution Systems - Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystems required by LCO 3.8.10; and

c. The shutdown portion of one Load Shedder and Emergency Load Sequencer (LSELS) associated with the required DC and AC electrical power distribution train.

APPLICABILITY: MODES 5 and 6) lie-I

~CTIONS b u --egP)ov o) ,re e-f [r-,/P44 }

COMPLETION REQUIRED ACTION TIME CONDITION TIME A. One required offsite circuit ------------ NOTE --------

inoperable. Enter applicable Cdnditions and Required Actions of LCO 3.8.10, with the required train de-energized as a result of Condition A.

A.1 Declare affected required Immediately feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

Li CALLAWAY PLANT 3.8-16 Amendment No. 133

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The Train A or Train B DC electrical power subsystem shall be OPERABLE to support one train of the DC electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6j b&~4~ fovervier' 4- '0 J' P'Ae-~ j~~Er

_CTIONS J

/ COMPLETION

/1 CONDITION REQUIRED ACTION TIME A. Required DC electrical A.1 Declare affected required Immediately power subsystem feature(s) inoperable.

inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

CALLAWAY PLANT 3.8-25 Amendment No. 149

Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 The Train A or Train B inverters shall be OPERABLE to support one train of the onsite Class 1 E AC vital bus electrical power distribution subsystems required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6)-

_,ACTIONS CONDITION COMPLETION REQUIRED ACTION TIME A. One or more required A.1 Declare affected required Immediately inverters inoperable. feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

- - - - - - -~ -

ALLAWAY PLANT 3.8-33 Amendment No. 149

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of the Train A or Train B AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support one train of equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6) b 0 1

,-,-rra- -P-, I *e*~ I CTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One or more required AC, A.1 Declare associated Immediately DC, or AC vital bus supported required elect rical power distribution feature(s) inoperable.

subs ystems inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

-CALAWA PL AN 3.8 -3 A mend --

CALLAWAY PLANT -3.8-37 Amendment No. 149

ATTACHMENT 3 RETYPED TECHNICAL SPECIFICATIONS

(-I~ft-Ovftedl e~~

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

CREVS Actuation Instrumentation B 3.3.7 B 3.3 INSTRUMENTATION B 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation BASES BACKGROUND The CREVS provides an enclosed control room environment from which the unit can be operated following an uncontrolled release of radioactivity.

During normal operation, the Control Building Ventilation System provides control room ventilation. Upon receipt of an actuation signal, the CREVS initiates filtered ventilation and pressurization of the control room. This system is described in the Bases for LCO 3.7.10, "Control Room Emergency Ventilation System (CREVS)."

The actuation instrumentation consists of two gaseous radiation channels in the control room air intake. A high radiation signal from either of these channels will initiate both trains of the CREVS. Since the radiation monitors include an air sampling system, various components such as sample line valves and sample pumps are required to support monitor OPERABILITY. The control room operator can also initiate CREVS trains by manual switches in the control room. The CREVS is also actuated by a Phase A Isolation signal, a Fuel Building Ventilation Isolation signal (FBVIS), or a high radiation signal from the containment purge exhaust gaseous radiation channels. The Phase A Isolation Function is discussed in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation."

APPLICABLE The control room must be kept habitable for the operators stationed there SAFETY during accident recovery and post accident operations.

ANALYSES The CREVS acts to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room. These actions are necessary to ensure the control room is kept habitable for the operators stationed there during accident recovery and post accident operations by minimizing the radiation exposure of control room personnel.

In MODES 1, 2, 3, and 4, (MODE 4 is subject to LCO 3.3.2, Function 3.a),

the gaseous radiation channel actuation of the CREVS is a backup for the Phase A Isolation signal actuation. This ensures initiation of the CREVS during a loss of coolant accident or steam generator tube rupture.

She aseous radiation channel actuation of the CREVS&iMOD!ES 5 c&nd-

~ring CORE ALTERATIONS)or during movement of irradiatEedfuel =

assemnblies within containmeny1e primary means to ensure control

" - *(continued)

CALLAWAY PLANT B 3.3.7-1 Revision 6

-rs'c2A o-CREVS Actuation Instrumentation

+ B c.37 No aok;jýru / r-o,,'h ka l;4zi BASES Ix *~eu-A,

~ Ae 14y APPLICABLE room habitabili*' in the event of a fuel handling accident inside SAFETY containment,9 waste gas decay tank rupture accident.-Th, probbility f ANALYSES -a -t g* ri y t4rn rupt'.ro cWcdojnt .... r:-ig dui9m the . pe-.d of (continued) 4i,, ....o~ d*1to -a"-li ty o;f F, ti-ntlcRs 4 3 of T,,bl, 3. 7-. 4 i"

~f-.Vnt. There are no safety analyses that take credit for CREVS actuation upon high containment purge exhaust radiation. A FBVIS is credited to protect the control room in the event of a design basis fuel handling accident inside the fuel building.

Sources of control room ventilation isolation signal (CRVIS) initiation which are remote from the Control Room intake louvers are not response time tested. For example, GGRE0027 and GGRE0028, which monitor Fuel Building exhaust are not response time tested. The analysis does credit a FBVIS for actuating a CRVIS following a Fuel Handling Accident in the Fuel Building. Due to the remote location of the Fuel Building exhaust radiation monitors relative to the Control Room intake louvers, the FBVIS will isolate the Control Room prior to the post-accident radioactive plume reaching the Control Room intake louvers.

Similarly, for a LOCA, the analysis credits a time zero Control Room isolation. A Safety Injection signal initiates a Containment Isolation Phase A, which initiates a CRVIS. This function is also credited for isolating the Control Room prior to the post-accident radioactive plume reaching the Control Room intake louvers.

For a Fuel Handling Accident within Containment, GKRE0004 and GKRE0005 are credited for initiating a CRVIS. These monitors are not remote from the Control Room intake louvers. They are downstream of the Control Room intake. Therefore, a specific response time is modeled, and a response time Surveillance Requirement is imposed for this CRVIS function.

The CREVS actuation instrumentation satisfies Criterion 3 of 10CFR50.36(c)(2)(ii).

LCO The LCO requirements ensure that instrumentation necessary to initiate the CREVS is OPERABLE.

1. Manual Initiation The LCO requires two channels OPERABLE. The operator can initiate the CREVS at any time by using either of two push buttons in the control room.

(continued)

CALLAWAY PLANT B 3.3.7-2 Revision 6

CREVS Actuation Instrumentation B 3.3.7 BASES LCO 4. Containment Isolation - Phase A (continued) I Therefore, the requirements are not repeated in Table 3.3.7-1.

Instead, refer to LCO 3.3.2, Function 3.a, for all initiating Functions and requirements.

5. Fuel Building Exhaust Radiation - Gaseous Control Room Ventilation Isolation is also initiated by high radiation in the fuel building detected by Fuel Building Exhaust Radiation - Gaseous channels (GGRE0027 and GGRE0028).

The requirements are not repeated in Table 3.3.7-1. Instead, refer to LCO 3.3.8 for all initiating Functions and requirements.

APPLICABILITY The Manual Initiation, Automatic Actuation Logic and Actuation Relays (BOP ESFAS), and Control Room Radiation - Control Room Air Intake Functions must be OPERABLE in MODES 1, 2, 3, 4,.t,,l@,during CORE ALTERATIONS, or during movement of irradiated fuel assemblies within containment. F-Thea""tir,; must be EOPERA0:LE i. ,,OD,.v 5 6 for coa mWentc g6 G.ay tAnk ruptuo aeoidc-t, to.GFmuic a habitable

... ,v ,,,,,. fcr -.,- tctol room,, porator. During CORE ALTERATIONS or during movement of irradiated fuel assemblies within containment, these Functions assure the generation of a CRVIS on detection of high gaseous activity in the event of a fuel handling accident within containment.

During movement of irradiated fuel assemblies in the fuel building, the Fuel Building Exhaust Radiation - Gaseous channels (GGRE0027 and GGRE0028) assure the generation of a CRVIS on detection of high gaseous activity in the event of a fuel handling accident in the fuel building. Since this FBVIS-initiated CRVIS requires Function 2 of Table 3.3.7-1 to complete the actuation circuit, and since manual CRVIS actuation provides back-up, Functions 1 and 2 of Table 3.3.7-1 must also be OPERABLE during movement of irradiated fuel assemblies in the fuel building.

The Containment Isolation - Phase A Function is required to be OPERABLE as directed by LCO 3.3.2, Function 3.a. The Fuel Building Exhaust Radiation - Gaseous Function is required to be OPERABLE as directed by LCO 3.3.8, Functions 1, 2, and 3.

ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance (continued)

CALLAWAY PLANT B 3.3.7-4 Revision 6

-r'rRONA Or-dw CREVS Actuation Instrumentation B 3.3.7 BASES ACTIONS D.1 and D.2 (continued)

LCO requirements are not applicable. To achieve this status, the unit must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

E.1 and E.2 Condition E applies when the Required Action and associated Completion Time for Conditions A, B, or Cave not been met-i MODE. 5 u, C, or during CORE ALTERATIONSyor when irradiated fuel assemblies are being moved. Movement of irradiated fuel assemblies and CORE ALTERATIONS must be suspended immediately to reduce the risk of accidents that would require CREVS actuation. This does not preclude movement of a component to a safe position.

SURVEILLANCE A Note has been added to the SR Table to clarify that Table 3.3.7-1 REQUIREMENTS determines which SRs apply to which CREVS Actuation Functions.

SR 3.3.7.1 Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation 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, it is key to verifying 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. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, (continued)

CALLAWAY PLANT B 3.3.7-7 Revision 6

EES Actuation Instrumentation B 3.3.8 BASES (Continued)

APPLICABILITY The manual and automatic EES initiation must be OPERABLE when moving irradiated fuel assemblies in the fuel building to ensure the EES operates to remove fission products associated with a fuel handling accident and isolate control room ventilation.

High radiation initiation of the FBVIS must be OPERABLE during movement of irradiated fuel assemblies in the fuel building to ensure automatic initiation of the EES and a CRVIS when the potential for a fuel handling accident exists.

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 unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification. If the measured Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.

Aýote has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.8-1 in the accompanying LCO. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

Placing a EES train(s) in the FBVIS mode of operation isolates normal air discharge from the fuel building and initiates filtered exhaust, imposing a negative pressure on the fuel building. Further discussion of the FBVIS mode of operation may be found in the Bases for LCO 3.7.13, "Emergency Exhaust System (EES)," and in Reference 2.

A.1 Condition A applies to the actuation logic train Function of the BOP ESFAS, the gaseous radiation monitor channel Function, and the manual initiation channel Function. Condition A applies to the failure of a single actuation logic train, gaseous radiation monitor channel, or manual initiation channel. If one channel or train is inoperable, or one gaseous radiation monitor channel is inoperable, a period of 7 days is allowed to (continued)

CALLAWAY PLANT B 3.3.8-3 Revision 4

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

CREVS B 3.7.10 BASES LCO path can also render the CREVS flow path inoperable. In these (continued) situations, LCOs 3.7.10 and 3.7.11 may be applicable.

APPLICABILITY In MODES 1, 2, 3, and 4, CREVS must be OPERABLE to control operator exposure during and following a LOCA or SGTR.

InMODE &ar 6, the CREV9 i9 roqulirod to eape with the design basis

_r~ .. ... of . ..

fro,m the rp.tur gas dc' t k.

During movement of irradiated fuel assemblies, the CREVS must be OPERABLE to cope with the release from a design basis fuel handling accident inside containment or in the fuel building.

ACTIONS A.1 When one CREVS train is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREVS train is adequate to perform the control room protection functionl However, the overall reliability is reduced because a single failure in the OPERABLE CREVS train could .result in loss of CREVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B. 1 If the control room boundary is inoperable in MODE 1, 2, 3, or 4 such that neither CREVS train can establish the required positive pressure (but the trains are not otherwise inoperable), action must be taken to restore an OPERABLE control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. (Appropriate compensatory measures include those such as described for the LCO Note in the LCO Bases above).

For the purposes of assessing whether Condition B applies, "control room boundary" may include portions of the Control Building boundary due to analyzed interaction between the Control Building and control room atmospheres during emergency operation of the CREVS, including the (continued)

CALLAWAY PLANT B 3.7.10-4 Revision 7

CREVS B 3.7.10 BASES ACTIONS B.1 (continued) effect of Control Building boundary leakage, as modeled in the control room dose analyses for the DBA LOCA.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, the availability of the CREVS to provide a filtered environment (albiet with potential control room inleakage), and the use of compensatory measures. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is a reasonable time to diagnose, plan, repair, and test most problems with the control room boundary.

C.1 and C.2 In MODE 1, 2, 3, or 4, if the inoperable CREVS train or control room boundary cannot be restored to OPERABLE status within 'the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

D.1, D.2.1. and D.2.2

,m , -.

18r,-1.uuring movement of irradiated fuel assemblies, if the inoperable CREVS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREVS train in the CRVIS mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. Required Actions D.2.1 and D.2.2 would place the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position.

(continued)

CALLAWAY PLANT B 3.7.10-5 Revision 7

CREVS B 3.7.10 BASES ACTIONS E.1 and E.2 (continued) u AA4nn0F= &- ' ring n", movement of irradiated fuel assemblies, with two CREVS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room. This places the unit in a condition that minimizes accident risk. This does not preclude the movement of fuel to a safe position.

F. 1 If both CREVS trains are inoperable in MODE 1, 2, 3, or 4, for reasons other than an inoperable control room boundary (i.e., Condition B), the CREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month, by initiating from the control room, flow through the HEPA filters and charcoal adsorbers of both the filtration and pressurization systems, provides an adequate check of this system.

Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. Each pressurization system train must be operated for _Ž10 continuous hours with the heaters functioning. Functioning heaters will not necessarily have the heating elements energized continuously for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ; but will cycle depending on the air temperature. Each filtration system train need only be operated for

Ž!15 minutes to demonstrate the function of the system. The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availability.

SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The CREVS filter tests use the test procedure guidance in Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the (continued)

CALLAWAY PLANT B 3.7.10-6 Revision 7

Emergency Exhaust System B 3.7.13 BASES LCO b. HEPA filter and charcoal adsorber are not excessively restricting (continued) flow, and are capable of performing their filtration function, and

c. Heater, ductwork, and dampers are OPERABLE, and aircirculation can be maintained.

The LCO is modified by a Note allowing the auxiliary or fuel building boundary to be opened intermittently under administrative controls. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for auxiliary or fuel building isolation is indicated. Plant administrative controls address the breached pressure boundary.

APPLICABILITY In MODE 1, 2, 3, or 4, the Emergency Exhaust System is required to be OPERABLE to support the SIS mode of operation to provide fission product removal associated with ECCS leaks due to a LOCA and leakage from containment and annulus.

In MODE 5 or 6, the Emergency Exhaust System is not required to be OPERABLE since the ECCS is not required to be OPERABLE.

During movement of irradiated fuel in the fuel building, the Emergency Exhaust System is required to be OPERABLE to support the FBVIS mode of operation to alleviate the consequences of a fuel handling accident.

The Applicability is modified by a Note. The Note clarifies the Applicability for the two safety-related modes of operation of the Emergency Exhaust System, i.e., the Safety Injection Signal (SIS) mode and the Fuel Building Ventilation Isolation Signal (FBVIS) mode. The SIS mode which aligns the system to the auxiliary building is applicable when the ECCS is required to be OPERABLE. In the FBVIS mode the system is aligned to the fuel building. This mode is applicable while handling irradiated fuel in the fuel building.

ACTIONS A.1 With one Emergency Exhaust System train inoperable, action must be

,I-7I-7 taken to restore OPERABLE status within 7 days. During this period, the remaining OPERABLE train is adequate to perform the Emergency Exhaust System function. The 7 day Completion Time is based on the risk from an event occurring requiring the inoperable Emergency Exhaust (continued)

CALLAWAY PLANT B 3.7.13-3 Revision 7

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

S,6 AC Sources - A-r-AWA8.,

Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating BASES BACKGROUND The unit Class 1 E AC Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and alternate), and the onsite standby power sources (Train A and Train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

The onsite Class 1 E AC Distribution System is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG.

Offsite power is sfipplied to the unit switchyard from the transmission network by4iransmission lines. From the switchyard, two electrically and physically separated circuits provide AC power, through ESF transformers, to the 4.16 kV ESF buses. Automatic load tap changers associated with the ESF transformers, as well as associated capacitor banks, provide voltage regulation for the preferred sources in the event of changing switchyard voltage. A detailed description of the offsite power network and the circuits to the Class 1 E ESF buses is found in the FSAR, Chapter 8 (Ref. 2).

An offsite circuit consists of all breakers, transformers, voltage regulation equipment, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class IE ESF buses.

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1 E Distribution System. Within 1 minute after the initiating signal is received, all automatic and permanently connected loads needed to recover the unit or maintain it in a safe condition are returned to service Via the load sequencer.

The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG. DGs NE01 and NE02 are dedicated to ESF buses NB01 and NB02, respectively. A DG starts automatically on a safety injection (SI) signal (i.e., low pressurizer pressure, steam line pressure or high containment pressure signals) or on an ESF bus undervoltage signal (continued)

CALLAWAY PLANT B 3.8. 1-1 Revision 7a

AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources-Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6 SAFETY ensures that:

ANALYSES

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the

consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no

specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

(continued)

CALLA WAY PLANT B3821Rvso B 3.8.2-1 Revision 3

-7s-gAlM 6A'-dea~

INSERT B2 and during movement of irradiated fuel assemblies

AC Sources - Shutdown B 3.8.2 BASES LCO instrumentation functions is addressed in LCO 3.3.5, "Loss of Power (continued) (LOP) Diesel Generator (DG) Start Instrumentation." Only the shutdown portion of the associated Load Shedder and Emergency Sequencer is required to be OPERABLE in MODES 5 and 6.

In addition, Load Shedder and Emergency Load Sequencer operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts on the ability to start and maintain energized loads required OPERABLE by LCO 3.8.10. However, proper sequencer operation shall only be required on the train supported by the OPERABLE DG.

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6. provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS A._1 y

An offsite circuit would be considered inoperable if it were not available to

/e one required ESF train. The one train with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

(continued)

CALLAWAY PLANT B 3.8.2-4 Revision 3

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

INSERT B2 and during movement of irradiated fuel assemblies

S&N Ar-iAta DC Sources - Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources - Shutdown BASES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating."

APPLICABLE The initial conditions of Design Basis Accident and transient analyses in SAFETY the FSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume that ANALYSES Engineered Safety Feature systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 and 6Aensures that:

ENlA-rA

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and (continued)

CALLAWAY PLANT B 3.8.5-1 Revision 3

1Slrg'wAF D?-ddA INSERT B2 and during movement of irradiated fuel assemblies

1SA'CNI cVp-e6A DC Sources - Shutdown

. B 3.8.5 BASES LCO (continued)

TRAIN A TRAIN B Bus NK01 Bus NK03 Bus NK02 Bus NK04 energized from energized from energized from energized from Battery NKI1 and Battery NK13 Battery NK12 and Battery NK14 Charger NK21 or and Charger NK22 or and Swing Charger Charger NK23 Swing Charger Charger NK24 NK25 (powered or NK26 (powered or from AC Load Swing Charger from AC Load Swing Charger Center NG01) NK25 (powered Center NG04) NK26 (powered from AC Load from AC Load Center NG01) Center NG04)

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and kprovide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Required features needed to mitigate a fuel handling accident are available;

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown .are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS I A.1. A.2.1, A.2.2, A.2.3, and A.2.4 By allowing the option to declare required features inoperable with the associated DC power source inoperable, appropriate restrictions will be Z7N1 JýRG implemented in accordance with the affected required features LCO I'1 ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, (continued)

CALLAWAY PLANT B 3.8.5-4 Revision 3

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 wouldrequire the unit to be shutdown unnecessarily.

INSERT B2 and during movement of irradiated fuel assemblies

Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters - Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters - Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the ESAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2),

ANALYSES assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Trip System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum inverters to each AC vital bus during MODES 5 ad6esrsthat:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of (continued)

CAL LA WAY PLANT BB3881Rvso 3.8.8-1 Revision 7

INSERT B2 and during movement of irradiated fuel assemblies

drr6 df-Ao Inverters - Shutdown

. B 3.8.8 BASES LCO (continued)

TRAIN A TRAIN B Bus NNO1 Bus NN03 Bus NN02 Bus NN04 energized from energized from energized from energized from Inverter NN11 Inverter NN13 Inverter NN12 Inverter NN14 connected to connected to connected to connected to DC bus NK01I DC bus NK03 DC bus NK02 DC bus NK04 APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6 provide assurance that: - ,

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unitin a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS A.1, A.2.1, A.2.2, A.2.3. and A.2.4 By the, allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LOOs' Required'Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or (continued)

CALLAWAY PLANT B 3.8.8-4 Revision 7

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

INSERT B2 and during movement of irradiated fuel assemblies

Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems - Shutdown BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems -

Operating."

APPLICABLE The initial conditions of Design Basis Accident and transient analyses in SAFETY the FSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume ANALYSES Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the AC, DC, and AC vital bus electrical power distribution system is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum AC, DC, and AC vital bus electrical power distribution subsystems during MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and (continued)

CALLAWAY PLANT B 3.8.10-1 Revision 3

-r7TSrcN 64?-Mal INSERT B2 and during movement of irradiated fuel assemblies

Distribution Systems - Shutdown B 3.8.10 BASES LCO The required AC vital bus electrical power distribution subsystem is (continued) supported by one train of inverters as required by LCO 3.8.8, "Inverters -

Shutdown." When the second (subsystem) of AC vital bus electrical power distribution is needed to support redundant required systems, equipment and components, the second train may be energized from any available source. The available source must be Class 1E or another reliable source. The available source must be capable of supplying sufficient AC electrical power such that the redundant components are capable of performing their specified safety function(s) (implicitly required by the definition of OPERABILITY). Otherwise the supported components must be declared inoperable and the appropriate conditions of the LCOs for the redundant components must be entered.

Closure of the tie breaker 52NG0116 between NG01 and NG03 or tie breaker 52NG0216 between NG02 and NG04 will render all four degraded voltage channels for the associated 4.16 kV bus inoperable.

Refer to LCO 3.3;5, "LOP DG Start Instrumentation." The 480 V load center transformer load and voltage drop increase when one transformer is supplying both 480 V buses. Since the degraded voltage is sensed on the 4.16 kV bus, the actual 480 V bus voltage will be lower (lower than assumed during a degraded voltage condition) when the protection setpoint is reached. In this case, adequate protection is not provided for the 480 V bus loads.

APPLICABILITY The AC and DC electrical power distribution subsystems required to be OPERABLE in MODES 5 and 6 provide assurance that:.

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, DC, and AC vital bus electrical power distribution subsystems

.requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

(continued)

CALLAWAY PLANT B 3.8.10-4 Revision 3

isA~iV ii INSERT B2 and during movement of irradiated fuel assemblies

Distribution Systems - Shutdown B 3.8.10 BASES (Continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, and A.2.5 By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered. Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable and not in operation, which results in taking the appropriate RHR actions. This would assure consideration is given to shutdown cooling systems that are without required power and that appropriate actions are taken to assure operability of these required systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

(continued)

CALLAWAY PLANT B 3.8.10-5 Revision 3

INSERT B I LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

ATTACHMENT 5 FSAR MARKUPS (for information only)

rX3Ait' CAIl te-,2)-O7 CALLAWAY - SP The probability of a large break in a piping system (e.g., rupture of ECCS piping),

subsequent to the original large LOCA pipe break, is considered to be sufficiently low that it need not be postulated.

Single failures of passive components in electrical systems are assumed in designing against a single failure.

3.1..2 ADDITIONAL SINGLE FAILURE ASSUMPTIONS In designing for and analyzing for a DBA (i.e., loss-of-coolant accident, main steam line break, fuel handling accident, or steam generator tube rupture), the following assumptions are made, in addition to postulating the initiating event.

a. The events are assumed not to result from a tornado, hurricane, flood, fire, loss of offsite power, or earthquake.

b. Any one of the following occurs:

1. During the short term of an accident, a single failure of any active mechanical component. The short term is defined as less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following an accident, or

2. During the short term of an accident, a single failure of any active or passive electrical component, or

3. A single failure of passive components associated with long-term cooling capability, assuming that a single active failure has not occurred during the short term. Long-term cooling applies to a time duration greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

c. No reactor coolant system transient is assumed, preceding the postulated reactor coolant system piping rupture.

d. No operator action is assumed to be taken by plant operators to correct problems during the first 10 minutes following the accident. Although not a design basis accident, operator action times of less than 10 minutes are assumed in the mitigation of an inadvertent ECCS actuation at power event. See Section 15.5.1.

e. All offsite power is simultaneously lost and is restored within 7 days (except that for events postulated to occur during.eel-shutdown conditions e.g., a fuel handling accident, a loss of all offsite power is not required to e assumed in addition to a single failure).

f. For a LOCA, for additional safety no credit is taken for the functioning of nonseismic Catego I components 3.1-3 1ev. OL-16 10/07

CALLAWAY - SP r'.r,~CA] 0 F-0,0 -7 16.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) 16.7.8.1 LIMITING CONDITION FOR OPERATION Pressurization System flow rate shall be within limits during system operation CRVIS mode for each CREVS train.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6 During movement of irradiated fuel assemblies ACTIONS:

a. With Pressurization System flow rate not within limits for one CREVS train in MODES 1, 2, 3 or 4, restore Pressurization System flow rate to within limits within 7 days; otherwise, enter Section 16.0.1.3.

b. With Pressurization System flow rate not within limits for one CREVS train4if-

-,MODES- 69O 6, Or during movement of irradiated fuel assemblies, restore Pressurization System flow rate to within limits within 7 days; otherwise, immediately place the other CREVS train in CRVIS mode, or immediately

.suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.

16.7.8.1.1 -SURVEILLANCE REQUIREMENTS At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system, verify the system flow rate is 2200 cfm

(+800/-400) for the Pressurization System.

16.7.8.1.2 BASES Verification of the flow rate in the Pressurization System assures that the ventilation system flows are properly balanced within the system.

16.7-17 Rev. OL-16 10/07

? 0,4Al

^I/P*..A,

c.J #,,,f,'

--7 CALLAWAY - SP (

16.8.3 A.C. SOURCES-SHUTDOWN 16.8.3.1 LIMITING CONDITION FOR OPERATION The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1 E AC electrical power distribution subsystem; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem; and

c. The Shutdown portion of one Load Shedder and Emergency Load Sequencer (LSELS) associated with the required DG and AC electrical power distribution train.

APPLICABILITY: MODES 5 and 63 , ,e ACTION: .. b* , ove.r +' f

a. With less than the above minimum required A.C. electrical power sources OPERABLE, immediately suspend all operations involving crane operation with loads over the spent fuel pool.

b. The diesel generators are not considered inoperable when the fuel oil storage tank missile shield is removed provided the following Administrative Controls are in place:

1) Weather monitoring is in place prior to and during shield removal, and no thunderstorms are within 70 miles.

2) Equipment, tools, and personnel required to close the missile shield shall be on site and located such that the shield can be closed in one hour or less.

3) Only one Emergency Diesel Fuel Oil storage tank missile shield may be open at a time.

4) If thunderstorm watches or warnings, tornado watches or warnings, or high winds are within 70 miles of the plant moving toward the plant, the missile shield must be closed immediately.

5) Installation of hold down bolt nuts and washers are required for tornado missile protection.

16.8-6 Rev. OL-15 5/06

CALLAWAY - SP 11-0474-

6) Loads are not hoisted over a given train when the missile shield is removed.

7) Upon completion or stoppage of the activity requiring the shield open, immediately replace the missile shield.

c. In Mode 6, with no OPERABLE emergency diesel generator, the TS ACT 3.9.5.A.4 or TS ACT 3.9.6.B.3 four hour action statement to close all direct access containment penetrations MUST also be applied upon entry into TS ACT 3.8.2.B. 1.

16.8.3.1.1 SURVEILLANCE REQUIREMENTS See Technical Specification SR 3.8.2.1.

16.8.3.1.2 BASES See FSAR Section 9.1.4 In order for the diesel generator to remain OPERABLE when the missile cover is removed, appropriate administrative controls are followed to ensure adequate missile protection. Reference includes: RHR 19618, Rev. G.

16.8-7 Rev. OL-15 5/06

ATTACHMENT 6 TSTF-36-A, REVISION 4 (WITH NUREG-1431 MARKUPS ONLY)

(for information only)

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Addition of LCO 3.0.3 N/A to shutdown electrical power specifications NUREGs Affected: W 1430 W 1431 R] 1432 F- 1433 W 1434 Classification: 3) Improve Specifications Recommended for CLIIP?: (Unassigned)

Correction or Improvement: (Unassigned)

Industry

Contact:

Tom Silko, (802) 258-4146, tsilko@entergy.com Add "LCO 3.0.3 is not applicable" note to AC Sources - Shutdown, DC Sources - Shutdown, Inverters - Shutdown and Distribution Systems - Shutdown to clarify that the requirements apply only to the Modes or other specified conditions in the Applicability The Actions of Specifications 3.8.2, "AC Sources - Shutdown", 3.8.5, " DC Sources - Shutdown", 3.8.8, "Inverters -

Shutdown", and 3.8.10, "Distribution Systems - Shutdown" have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in Mode 4 or 5 (or 5 and 6 for PWRs), LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in Modes 1, 2, or 3, (or 4 for PWRs) the fuel movement is independent of reactor operations. This clarification is necessary because defaulting to LCO 3.0.3 (during irradiated fuel assembly movement in MODE 1, 2, or 3 [or 4 for PWRs]) would require the reactor to be shutdown unnecessarily. The Note applies to more than one of the Required Actions, thus it has been placed at the beginning of the Actions Table.

Corresponding changes have been made to the Bases. The same logic regarding movement of irradiated fuel applies to the PWR NUREG specifications for fuel building air cleanup systems and its instrumentation.

Revision History OG Revision 0 Revision Status: Closed Revision Proposed by: Peach Bottom Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 14-Jul-95 Owners Group Comments:

Hatch Comments - OK Owners Group Resolution: Approved Date: 14-Jul-95 TSTF Review Information TSTF Received Date: 02-Aug-95 Date Distributed for Review: 02-Aug-95 OG Review Completed: W BWOG F] WOG [] CEOG Wi BWROG TSTF Comments:

WOG Comments - Agreed with additional changes necessary to the WOG NUREG regarding FBACS and FBACS Instrumentation.

CEOG Comments - Agree to change. Also applicable to CEOG Spec 3.7.14, Fuel Building Air Cleanup System and 3.3.10, Fuel Handling Isolation Signal (FHIS) (Digital)

TSTF Resolution: Approved Date: 27-Nov-95 NRC Review Information 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written pennission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 OG Revision 0 Revision Status: Closed NRC Received Date: 03-Jan-96 NRC Comments:

6/11/96 - C. Grimes comment: TSTF-36 will be rolled-in with TSTF-16.

8/12/96 - TSTF-36, Rev. 1 received.

9/18/96 - Closed to Revision 1 Final Resolution: Superceded by Revision Final Resolution Date: 18-Sep-96 TSTF Revision 1 Revision Status: Closed Revision Proposed by: WOG Revision

Description:

Rev. 0 contained WOG Bases markup for B 3.7.14 instead of the correct B 3.7.13. The changes given on the Traveler cover page are correct. A substitute page is provided with Rev. I TSTF Review Information TSTF Received Date: 19-May-96 Date Distributed for Review: 19-May-96 OG Review Completed: W BWOG [] WOG F. CEOG V BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 16-Jun-96 NRC Review Information NRC Received Date: 16-Jun-96 NRC Comments:

9/26/96 - C. Grimes comment: clarification of note is appropriate. Pending roll-in with TSTF-16.

1/23/97 - Closed to Revision 2 Final Resolution: Superceded by Revision Final Resolution Date: 23-Jan-97 TSTF Revision 2 Revision Status: Closed Revision Proposed by: WOG Revision

Description:

The Bases insert which described the "LCO 3.0.3 is not applicable." Note was written by the BWROG and was not corrected to reflect the additional Modes described in the PWR NUREGS. Substitute insert pages for the PWR NUREGs are provided to correct this error.

TSTF Review Information TSTF Received Date: 16-Aug-96 Date Distributed for Review: 20-Nov-96 OG Review Completed: [; BWOG 0] WOG F] CEOG W BWROG TSTF Comments:

31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 TSTF Revision 2 Revision Status: Closed (No Comments)

TSTF Resolution: Approved Date: 19-Dec-96 NRC Review Information NRC Received Date: 23-Jan-97 NRC Comments:

5/9/97 - reviewer recommended rejection. For a typical two train plant, the proposed change is not necessary. Therefore, with respect to Section 3.8, the proposed generic change should be rejected. Inclusion of the proposed exception may be considered on a plant-specific basis if it can be shown that the above discussion is not applicable to the plant design. More reviewer elaboration is contained in hard-copy file.

5/12/97 - to C. Grimes for disposition.

8/28/97 - TSTF OG requested meeting with TSB to resolve obstacles to dispostion.

10/2/97 - E. Tomlinson agreed to generic change by Brunswick.

Final Resolution: Superceded by Revision Final Resolution Date: 11-Jan-98 TSTF Revision 3 Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

The justification and Bases inserts describing "LCO 3.0.3 is not applicable," have been enhanced to address the NRC's request for clarification of the proposed change. The expanded clarification was accepted by E. Tomlinson during the Brunswick ITS review.

TSTF Review Information TSTF Received Date: 11-Jan-98 Date Distributed for Review: 15-Jan-98 OG Review Completed: W BWOG [] WOG [] CEOG [] BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 05-Feb-98 NRC Review Information NRC Received Date: 20-Feb-98 NRC Comments: Date of NRC Letter: 16-Aug-99 4/20/98 - Staff feels that exiting to 3.0.3 generates more confusion than the problem being solved. They are not sure that you would see the condition and that change increases chance of confusion.

4/21/98 - (Comments from TSTF/NRC meetihg) Looks to NRC like industry is trying to address the "moving of irradiated fuel at power" issue. Two trains inoperable causes a shutdown even if the 3.0.3 shutdown is addressed. NRC believes that this is an issue but does not want a patch. NRC wants a bigger generic fix, a more direct approach.

6/16/99 - TSTF to contact NRC by 6/25/99.

31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 TSTF Revision 3 Revision Status: Closed 8/4/99 - NRC comments received:

I have taken a quick look at TSTF-36, R.3 which was rejected by the staff, but which the industry has requested we reconsider. This proposed change would place notes indicating that LCO 3.0.3 does not apply in a number of LCOs. These LCOs are those that are not normally applicable at power, but become applicable only due to movement of fuel. The concern is that inability to comply with these LCOs and associated AOTs might result in entry into LCO 3.0.3 and a subsequent plant shutdown. In all cases, suspending fuel movement would terminate applicability and prevent an unnecessary shutdown. Thus the staff rejected the TSTF saying it was not needed. However, industry indicates that there have been cases that suspending fuel movement was not possible and a plant shutdown unrelated to the fuel movement problems resulted.

There are two general classes of LCOs for which this proposed change applies:

1. Required electrical sources during shutdown, and

2. Various ventilation systems which are required to mitigate a fuel handling accident.

Relative to the electrical sources, it is difficult to see how the requirements for electrical sources during shutdown should be more restrictive than requirements for electrical sources while at power. Thus entering the shutdown LCOs due to fuel movement should not impose any additional requirement.

The ventilation systems applicable only to fuel movement do represent a potential problem in that these systems have generally have no relationship to power operation. It would be inappropriate and possibly contrary to safety to require a shutdown due to fuel handling problems. While the addition of the proposed note would solve this potential problem, the staff rejected it based on the low likelihood that such a problem would occur and the potential for introducing ambiguities in the TS.

This proposal to exclude LCO 3.0.3 applicability also goes contrary to a desire by the staff to expand applicability of LCO 3.0.3 to all modes of operation. The staff is concerned that if licensees can not comply with LCOs or associated AOTs, there should always be clear requirements. One way of accomplishing this is to expand the applicability of LCO 3.0.3 to shutdown which the staff has proposed as a change to the iSTS.

The staff proposal did not address the issue of LCO applicability solely due to movement of fuel. However, the concern about always having a clear path to follow is directly applicable to the industry concern that, due to an ambiguity in the technical specifications, a fuel handling problem might result in an inappropriate plant shutdown. The staff suggests that rather than making LCO 3.0.3 not applicable to these situations, that the staff proposal to change LCO 3.0.3 be further modified to make it also specifically address the case of fuel movement at power.

8/31/99 - TSTF will provide a revision to the justification and Bases to delete the reference to the 37 hour4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months delay and entry into LCO 3.0.3.

Final Resolution: NRC Requests Changes: TSTF Considering Final Resolution Date: 04-Aug-99 TSTF Revision 4 Revision Status: Active Revision Proposed by: NRC Revision

Description:

Revised to incorporate NRC comments. Revised the Justification and the inserts.

TSTF Review Information 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 TSTF Revision 4 Revision Status: Active TSTF Received Date: 17-Sep-99 Date Distributed for Review: 17-Sep-99 OG Review Completed: n. BWOG [] WOG [] CEOG W BWROG TSTF Comments:

3.8.8 (No Comments)

TSTF Resolution: Approved Date: 17-Sep-99 NRC Review Information NRC Received Date: 08-Oct-99 Date of NRC Letter: 01-Nov-99 Final Resolution: NRC Approves Final Resolution Date: 01-Nov-99 Affected Technical Specifications Action 3.8.2 Action 3.8.2 AC Sources AC Sources -- Shutdown Shutdown Action Action 3.8.2 Bases AC Sources - Shutdown Action Action 3.8.5 DC Sources - Shutdown Action Action 3.8.5 Bases DC Sources - Shutdown Action Action 3.8.8 Inverters - Shutdown Action 3.8.8 Bases Inverters - Shutdown Action 3.8.10 Distribution Systems - Shutdown Action 3.8.10 Bases Distribution Systems - Shutdown Action 3.7.13 Fuel Storage Pool Ventilation System (FSPVS) NUREG(s)- 1430 Only Action 3.7.13 Bases Fuel Storage Pool Ventilation System (FSPVS) NUREG(s)- 1430 Only Action 3.3.8 FBACS Actuation Instrumentation NUREG(s)- 1431 Only Action 3.3.8 Bases FBACS Actuation Instrumentation NUREG(s)- 1431 Only Action 3.7.13 Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1431 Only Action 3.7.13 Bases Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1431 Only Action 3.3.10 Fuel Handling Isolation Signal (FHIS) (Digital) NUREG(s)- 1432 Only Action 3.3.10 Bases Fuel Handling Isolation Signal (FHIS) (Digital) NUREG(s)- 1432 Only 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

3.8.2 Bases 3.8.5 AC Sources - Shutdown DC

BWROG-8, Rev. 0 TSTF-36-A, Rev. 4 Action 3.7.14 Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1432 Only Action 3,7.14 Bases Fuel Building Air Cleanup System (FBACS) NUREG(s)- 1432 Only 31-Jul-03 Traveler Rev. 3. Copyright (C) 2003, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-36, Rev. 4 Insert 3.0.3 NA (PWRs)

LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3,or 4 would require the unit to be shutdown unnecessarily.

FBACS Actuation Instrumentation 3.3.8 3.3 INSTRUMENTATION 3.3.8 Fuel Building Air Cleanup System (FBACS) Actuation Instrumentation -

LCO 3.3.8 The FBACS actuation instrumentation for each Function in Table 3.3.8-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.8-1.

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

eparate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Place one FBACS train 7 days with one channel or in operation.

train inoperable.

B. One or more Functions B.1.1 Place one FBACS train Immediately with two channels or in operation.

two trains inoperable.

AND B.1.2 Enter applicable Immediately Conditions and Required Actions of LCO 3.7.13, "Fuel Building Air Cleanup System (FBACS)," for one train made inoperable by inoperable actuation instrumentation.

OR (continued)

WOG STS 3.3-60 Rev 1, 04/07/95

FBACS -,- -

3.7.13 3.7 PLANT SYSTEMS 3.7.13 Fuel Building Air Cleanup System (FBACS)

LCO 3.7.13 Two FBACS trains shall be OPERABLE.

APPLICABILITY: [MODES 1, 2, 3, and 4,]

During movement of irradiated fuel assemblies in the fuel building.

ACTIONS 31 CONDITION REQUIRED ACTION COMPLETION TIME A. One FBACS train A.1 Restore FBACS train 7 days inoperable, to OPERABLE status.

B. Required Action B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion Time of AND Condition A not met in MODE 1, 2, 3, B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months or 4.

OR Two FBACS trains inoperable in MODE 1, 2, 3, or 4.

C. Required Action and C.1 Place OPERABLE FBACS Immediately associated Completion train in operation.

Time [of Condition A]

not met during OR movement of irradiated fuel assemblies in the C.2 Suspend movement of Immediately fuel building. irradiated fuel assemblies in the fuel building.

(continued)

WOG STS 3.7-30 Rev 1, 04/07/95

AC Sources -Shutdown 3.8.2..

3.8 ELECTRICAL POWER SYSTEMS .....*

.*::-,*:*,.*4.*

.. .2%?

3.8.2 AC Sources-Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems--Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLTCABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTION J . U ' :"

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite ------------ NOTE-----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

WOG STS 3.8-18 Rev 1, 04/07/95

DC Sources-Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources-Shutdown LC0 3.8.5 DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems-Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS k C 's CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1.1 Declare affected Immediately DC electrical power required feature(s) subsystems inoperable, inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

WOG STS 3.8-28 Rev 1, 04/07/95

Inverters-Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters-Shutdown LCO 3.8.8 Inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems-Shutdown."

APPLICABILITY: MODES 5 and 6, During movement iradiated fuel assemblies.

ACTION Lt*f~~1 ... _______

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more [required] A.I Declare affected Immediately inverters inoperable, required feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

WOG STS 3.8-36 Rev 1, 04/07/95

Distribution Systems-Shutdown 3.8 C';

3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems--Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS--o_-,'

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC, DC, or AC vital supported required bus electrical power feature(s) distribution inoperable.

subsystems inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

WOG STS 3.8-40 Rev 1, 04/07/95

FBACS Actuation Instrumentation B 3.318 BASES ACTIONS specification. If the Trip Setpoint is less conservative" (continued) than the tolerance specified by the calibration procedurei:.'

the channel must be declared inoperable immediately and the' appropriate Condition entered.

Avote haste2Edded to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.8-1 in the accompanying LCO.

) Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A._I Condition A applies to the actuation logic train function of the Solid State Protection System (SSPS), the radiation monitor functions, and the manual function. Condition A applies to the failure of a single actuation logic train, radiation monitor channel, or manual channel. If one channel or train is inoperable, a period of 7 days is allowed to restore it to OPERABLE status. If the train cannot be restored to OPERABLE status, one FBACS train must be placed in operation. This accomplishes the actuation instrumentation function and places the unit in a conservative mode of operation. The 7 day Completion Time is the same as is allowed if one train of the mechanical portion of the system is inoperable. The basis for this time is the same as that provided in LCO 3.7.13.

B.-.1, B.1.2, B.2 Condition B applies to the failure of two FBACS actuation logic trains, two radiation monitors, or two manual channels. The Required Action is to place one FBACS train in operation immediately. This accomplishes the actuation instrumentation function that may have been lost and places the unit in a conservative mode of operation. The applicable Conditions and Required Actions of LCO 3.7.13 must also be entered for the FBACS train made inoperable by the inoperable actuation instrumentation. This ensures appropriate limits are placed on train inoperability as discussed in the Bases for LCO 3.7.13.

(continued)

WOG STS 8 3.3-171 Rev 1, 04/07/95

B 3.7.13 TsTF-36 BASES (continued)

APPLICABILITY In MODE 1, 2, 3, or 4, the FBACS is required to be OPERABLE to provide fission product removal associated with ECCS leaks due to a LOCA and leakage from containment and annulus.

In MODE 5 or 6, the FBACS is not required to be OPERABLE since the ECCS is not required to be OPERABLE.

During movement of irradiated fuel in the fuel handling area, the FBACS is required to be OPERABLE to alleviate the consequences of a fuel handling accident.

ACTIONS A.1 With one FBACS train inoperable, action must be taken to restore OPERABLE status within 7 days. During this period, the remaining OPERABLE train is adequate to perform the

]3~ NA FBACS function. The 7 day Completion Time is based on the risk from an event occurring requiring the inoperable FBACS train, and the remaining FBACS train providing the required protection.

B.1 and B.2 In MODE 1, 2, 3, or 4, when Required Action A.1 cannot be completed within the associated Completion Time, or when both FBACS trains are inoperable, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.I and C.2 When Required Action A.1 cannot be completed within the required Completion Time, during movement of irradiated fuel assemblies in the fuel building, the OPERABLE FBACS train must be started immediately or fuel movement suspended.

This action ensures that the remaining train is OPERABLE, (continued)

WOG STS B 3.7-68 Rev 1, 04/07/95

AC Sources -Shutdown B 3. 2 :"LL-*

8]**=:**

BASES LCO It is acceptable for trains to be cross tied during shutdown*".

(continued) conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS A.__I An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains are required by LCO 3.8.10, the one train with 0.3 IVA offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

(conti nued)

WOG STS 8 3.8-38 Rev 1, 04/07/95

DC Sources-Shutdown B 3.8-5 BASES LCO interconnecting cabling within the train, are required to be (continued) OPERABLE to support required trains of the distribution systems required OPERABLE by LCO 3.8.10, "Distribution Systems-Shutdown." This ensures the availability of sufficient DC electrical power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies, provide assurance that:

a. Required features to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Required features needed to mitigate a fuel handling accident are available;

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS A A-7-1 A-2 A-2 and A-74 If two trains are required by LCO 3.8.10, the remaining train with DC power available may be capable of supporting sufficient systems to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the (continued)

WOG STS B 3.8-61 Rev 1, 04/07/95

I ,-. I V %J 0 Inverters -Shutdown..

B 3.8...8 BASES (continued)

LCO The inverters ensure the availability of electrical power for the instrumentation for systems required to shut down ...

the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The battery powered inverters provide uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kV safety buses are de-energized. OPERABILITY of the inverters requires that the AC vital bus be powered by the inverter. This ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6 and during movement of irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for-MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

ACTIONS A.1. A.2.1, A.2.2, A.2.3, and A.2.4 If two trains are required by LCO 3 .8.10, "Distribution Systems-Shutdown," the remaining 0PERABLE Inverters may be capable of supporting sufficient re quired features to allow

-3,013IVA continuation of CORE ALTERATIONS, f uel movement, and operations with a potential for pos itive reactivity

drditinn*_ Rv th* allnwanc* of th*

Vl W* option to declare additions Bv the allowance of the (continued)

WOG STS B 3.8-76 Rev 1, 04/07/95

Distribution Systems--Shutdown B 3.8.10

,*.at BASES (continued)

ACTIONS L'.1. A.2.1, A.2.2, A.2.3, A.2.4. and A.2.5 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution subsystem LCO's Required Actions.

In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions).

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required residual heat removal (RHR) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.4 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the RHR ACTIONS would not be entered.

Therefore, Required Action A.2.5 is provided to direct declaring RHR inoperable, which results in taking the appropriate RHR actions.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

(conti nued)

WOG STS B 3.8-91 Rev 1, 04/07/95

v t e Letter Sequence Request
TAC:MD8953, TSTF-36 (Approved, Closed)
Initiation Request Acceptance Administration Questions 3 October 2008 Answers Results Approval Other: ULNRC-05582, Submittal of Revision of Technical Specifications 3.3, 3.7, and 3.8
MONTHYEAR2008-09-17 [Table View]

ULNRC-05494, Application for Amendment to Facility Operating License NPF-30 OL1283 - Revision of Technical Specifications 3.3, 3.7, and 3.8

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ULNRC-05494, Application for Amendment to Facility Operating License NPF-30 OL1283 - Revision of Technical Specifications 3.3, 3.7, and 3.8

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