View source for ULNRC-05269, Proposed Revision to Technical Specification 3.9.2 Unborated Water Source Isolation Valves and Associated Revisions to Technical Specification 3.3.9 Boron Dilution Mitigation System (Bdms) (License Amendment Request OL 1238)

{{Adams
| number = ML061000347
| issue date = 03/28/2006
| title = Proposed Revision to Technical Specification 3.9.2 Unborated Water Source Isolation Valves and Associated Revisions to Technical Specification 3.3.9 Boron Dilution Mitigation System (Bdms) (License Amendment Request OL 1238)
| author name = Young K
| author affiliation = AmerenUE, Union Electric Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000483
| license number = NPF-030
| contact person = 
| case reference number = ULNRC-05269
| document type = Letter type:ULNRC, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Amendment
| page count = 90
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:AmerenUE                                                                        PO Box E20 CallawayPlant                                                                   Fulton, MO 65251 March 28, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen:                                           ULNRC-05269 WAmerei                                        DOCKET NUMBER 50-483 UE'                                        CALLAWAY PLANT UNION ELECTRIC COMPANY PROPOSED REVISION TO TECHNICAL SPECIFICATION 3.9.2 "UNBORATED WATER SOURCE ISOLATION VALVES" AND ASSOCIATED REVISIONS TO TECHNICAL SPECIFICATION 3.3.9 "BORON DILUTION MITIGATION SYSTEM (BDMS)"
(LICENSE AMENDMENT REQUEST OL 1238)
Pursuant to 10 CFR 50.90, AmerenUE hereby requests an amendment to the Facility Operating License No. NPF-30 for Callaway Plant. The requested amendment would incorporate the attached changes into the Callaway Plant Technical Specifications. Specifically, the requested amendment would revise Technical Specifications (TS) 3.9.2, "Unborated Water Source Isolation Valves," to remove references to specific Chemical and Volume Control system (CVCS) isolation valves BGVO 178 and BGV0601 and to relocate the references to the TS Bases. Specific isolation valves are not required in the Standard Technical Specifications, NUREG-1431. Removing them from the Specifications and relocating them in the appropriate TS Bases is an administrative only change and is consistent with the Standard Technical Specifications. Removing specific valve references makes the Specification generic and applicable for all unborated water source isolation valves. Proposed TS LCO 3.9.2 is also modified by two Notes to allow an exception for decontamination activities and an exception for CVCS resin vessel operation.
In an associated change, TS 3.3.9, "Boron Dilution Mitigation System (BDMS)" is revised to eliminate references to the specific isolation valves BGV0 78 and BGV0601. The revisions make TS 3.3.9 consistent with TS 3.9.2. Removing specific valve references makes the Specification generic and applicable for all a subsidiary of Ameren Corporation

ULNRC-05264 March 28, 2006 Page 2 unborated water source isolation valves. TS 3.3.9 Required Actions B3 and C are modified by a Note that allows an exception for CVCS resin vessel operation.
The appropriate TS Bases changes for the proposed specification revisions are included for information and reflect the proposed changes.
In addition to the proposed TS changes and their associated Bases change<,
specific Bases changes for TS 3.3.9 Condition A and Bases changes for TS 3.3.1, "Reactor Trip System (RTS) Instrumentation", Condition I and Condition K, are also provided for NRC information. These changes remove statements that were previously added to these Bases sections as enhancements, but which have now been determined to be unnecessary and overly restrictive. AmerenUE has determined that these Bases changes do not require prior NRC approval.
Essential information is provided in the attachments to this letter.
Attachment I provides a detailed description and technical evaluation of the proposed changes, including AmerenUE's determination that the proposed changes involve no significant hazards consideration. Attachment 2 provides the existing TS pages marked-up to show the proposed changes. Attachment 3 provides a copy of the revised TS pages with the proposed changes incorporated (if approved). Attachmznt 4 provides the existing TS Bases pages marked-up to show the associated proposed Bases changes (for information only).
This letter identifies actions committed to by AmerenUE in this submittal.
Other statements are provided for information purposes and are not considered to be commitments. A summary of the regulatory commitments included in this submittal is provided in Attachment 5.
The Callaway Plant Review Committee and a subcommittee of the Nucleatr Safety Review Board have reviewed and approved this amendment application. In addition, it has been determined that this amendment application involves no significant hazards consideration as determined per 10 CFR 50.92, and that pursuant to 10 CFR 51.22(b) no environmental assessment should be required to be prepared in connection with the issuance of this amendment.
AmerenUE respectfully requests approval of the proposed license amendment by November 30, 2006. The approved amendment will be implemented within 90 days of approval.
Pursuant to 10 CFR 50.91 (b)(1), AmerenUE is providing the State of MissDuri with a copy of this proposed amendment.

ULNRC-05264 March 28, 2006 Page 3 If you should have any questions on the above or attached, please contact Dave Shafer at (314) 554-3104 or Dwyla Walker at (314) 554-2126.
Sincerely, Executed on: March 28, 2006 eith D. Young Manager, Regulatory Affairs DJW/jdg Attachments: 1)    Evaluation
: 2)  Markup of Technical Specification pages
: 3)  Retyped Technical Specification pages
: 4)  Markup of Technical Specification Bases pages (For information only)
: 5)  Summary of Regulatory Commitments

ULNRC-05269 March 28, 2006 Page 4 cc:    U.S. Nuclear Regulatory Commission (Original and I copy)
Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102

ULNRC-05269 ATTACHMENT 1 EVALUATION

Attachment 1 ULNRC-05269 Page 1 of 18 EVALUATION

==1.0      INTRODUCTION==

This letter is a request to amend Operating License NPF-30 for Callaway Plant.
The amendment application would revise Technical Specifications (TS) 3.9.2, "Unborated Water Source Isolation Valves," to delete references to specific Chemical and Volume Control system (CVCS) isolation valves BGV0178 and BGV0601 and to modify TS LCO 3.9.2 by two Notes to allow an exception for decontamination activities and an exception for CVCS resin vessel operation. These revisions ensure that all unborated water sources and their associated isolation valves, including others in the CVCS and its subsystem, the Boron Thermal Regeneration System (BTRS), and the Nuclear Sampling System (SJ), are included in TS 3.9.2. The proposed TS 3.9.2 precludes all inadvertent boron dilution events in Mode 6. In addition, the revisions adopt a version of TS 3.9.2 similar to the NURREG-1431, Standard Technical Specifications for Westinghouse Plants, Revision 3, version of TS 3.9.2.
In an associated change, TS 3.3.9, "Boron Dilution Mitigation System (BDMS)"
is revised. TS 3.3.9 Required Actions for Conditions B3 and C are revised to eliminate references to the specific isolation valves BGV0178 and BGV0601. The revisions make TS :3.3.9 consistent with TS 3.9.2. The Required Actions B3 and C are also modified by a Note allowing an exception for CVCS resin vessel operation.
In addition to the proposed TS changes and their associated Bases changes, specific Bases changes for TS 3.3.9 Condition A and Bases changes for TS 3.3.1, "Reactor Trip System (RTS) Instrumentation", Condition I and Condition K, are also made as separate and additional changes. These changes remove statements that were previously added to these Bases sections as enhancements, but which have now been determined to be unnecessary and overly restrictive. AmerenUE has reviewed these Bases changes under the Callaway TS Bases and 50.59 review programs and are providing them for NRC information.
In summary, the proposed changes make TS 3.9.2 generic and maintain the plant in a safe condition by ensuring that all potential unborated water sources are isolated in Mode 6. The proposed changes also make TS 3.3.9 generic and maintain the plant in a safe condition by ensuring that all potential unborated water sources are isolated in upper modes of plant operation when both trains of BDMS are inoperable or when a condition of nD RCS loop in operation exists. These changes assure plant compliance with the TS and plant operation within the bounds of the boron dilution accident analyses. The proposed changes do not alter design bases or technical requirements.

Attachment 1 ULNRC-05269 Page 2 of 18

==2.0     DESCRIPTION==
OF PROPOSED AMENDMENT References to specific unborated water sources and their associated isolation valves (BGV0178 and BGV0601) are removed from the current TS 3.9.2 LCO and SURVEILLANCE 3.9.2.1 REQUIREMENT and are transferred to TS 3.9.2 Bases. A NOTE is added to proposed LCO 3.9.2 such that during refueling decontamination activities, an unborated water source path may be unisolated, when required, under administrative controls. Based on Amendment 97 to the Callaway Plant Operating License, administrative controls are used to limit the volume of unborated water which can be added to the refueling pool for decontamination activities in order to prevent diluting the refueling pool boron concentration below TS limits.
Proposed TS 3.9.2 LCO is also modified by another Note allowing an exception for CVCS resin vessel operation. Plant chemistry controls may require some CVCS resin vessels to be configured with resin not intended for boron dilution or resin vessels that have been preconditioned with borated water with a boron concentration that is greater than or equal to the refueling water boron concentration. Because these resin vessels are not boron dilution sources, they are not required to be isolated. However, some CVCS resin vessels may be configured with resin intended for dilution and not preconditioned with borated water. These resin vessels would be isolated as required by TS LCO 3.9.2. However, the Note on the LCO allows these resin vessels to be unisolated when their operation is under administrative controls. The administrative controls include procedural requirements to precondition the resin vessels with borated water prior to their use; to monitor their effluent for boron concentration; and to assess the impact to plant reactivity management. The administrative controls ensure that the resin vessels are not dilution sources.
In an associated change, TS 3.3.9 REQUIRED ACTIONS B.3.1, B.3.2, C.1, and C.2 are revised to eliminate references to specific isolation valves (BGV0178 and BG'V0601). The revisions make TS 3.3.9 consistent with TS 3.9.2. Specific isolation valves are not required in the Standard Technical Specifications, NUREG-1431.
Removing them from the Specifications and relocating them in the appropriate TS Bases is an administrative only change and is consistent with the Standard Technical Specifications. Proposed Required Actions B.3.1, B.3.2, C.1, and C.2 are also modified by the Note permitting an exception for CVCS resin vessel operation.
TS Bases 3.9.2 is revised to reflect the addition of the Notes to the LCO and to incorporate specific valve references. Specific isolation valves are identified for the isolation of unborated reactor makeup water (associated isolation valves BGV0178 and BGV0601), for isolation of CVCS resin vessels configured with resin for dilution (associated isolation valves BG8522A, BG8522B, BGV0039, BGV0043, BGV0051 and BGV0055), and for isolation of the CVCS letdown gamma radiation detector SJRE0001 purge line (associated isolation valve SJV0703). TS Bases 3.3.9 is revised to reflect the

Attachment 1 ULNRC-05269 Page 3 of 18 proposed revisions to TS 3.3.9 Required Actions for Conditions B3 and C. Various other TS Bases are revised to reflect the proposed changes.
In addition to the proposed TS changes and their associated Bases changes, specific Bases changes for TS 3.3.9 Condition A and Bases changes for TS 3.3.1, "Reactor Trip System (RTS) Instrumentation", Condition I and Condition K, are made as separate and additional changes. TS 3.3.9 Condition A (Modes 2 (below P-6), 3, 4, and
: 5) results when one train of BDMS is inoperable. TS 3.3.1 Condition I (Mode 2 (below P-6)) and TS 3.3.1 Condition K (Modes 3, 4, and 5) result when one source range neutron flux channel is inoperable. The changes remove statements that were previously added to these Bases sections as enhancements, but which have now been determined to be unnecessary and overly restrictive. TS 3.3.1 Bases for Condition I and Condition K are revised to remove the following statement: "Introduction of reactor makeup water into the RCS from the Chemical and Volume Control System mixing tee is not permitted when one source range neutron flux channel is inoperable." TS 3.3.9 Bases for Cordition A is revised to remove the following statement: "Introduction of reactor makeup water into the RCS from the Chemical and Volume Control System mixing tee is not permitted when one BDMS train is inoperable."
In summary, the various revised TS Bases include TS Bases 3.3.1, RTS Instrumentation; TS Bases 3.3.9, Boron Dilution Mitigation System; TS Bases 3.4.5, RCS Loops-MODE 3; TS Bases 3.4.6, RCS Loops-MODE 4; TS Bases 3.4.7, RCS Loops-MODE 5, Loops Filled; TS Bases 3.4.8, RCS Loops-MODE 5, Loops Not Filled; and TS Bases 3.9.2, Unborated Water Source Isolation Valves.
Attachment 2 provides the proposed TS markups and Attachment 3 provides the clean copies of the proposed markups. Attachment 4 provides the TS Bases markups for information only.

==3.0      BACKGROUND==

3.1      Boron Dilution Event and Mitigation At Callaway, a design basis accident postulates a CVCS malfunction that results in a decrease in the boron concentration in the RCS - an inadvertent boron dilution event.
The postulated inadvertent boron dilution event is considered for all phases of plant operation.
The Reactor Protection System (RPS) functions to limit the consequences of the borcn dilution event by actuation of reactor trip with the plant capable of returning to operation following corrective action. In all plant operating conditions, an automatic alann alerts the operators to the conditions of an inadvertent boron dilution event. The alanns allow operator action to (1) open the CVCS isolation valves from the refueling

Attachment 1 ULNRC-05269 Page 4 of 18 water storage tank (RWST) in order to supply borated water to the RCS and (2) close untorated water source isolation valves to terminate the dilution flow.
In MODE 1, with the reactor under manual rod control, the overtemperature delta-T reactor trip signal serves as the alarm as well as initiating Rod Cluster Control Assemblies (RCCA) insertion. As plant conditions approach the overtemperature delta-T trip setpoint, a warning alarm alerts the operator. After this alarm actuates and once the trip setpoint is reached in two-out-of-four loops, the reactor trip signal is generated. In MODE 1, with the reactor under automatic rod control, the low and low-low rod insertion limit alarms from the rod control system as well as the axial flux difference alarm can alert the operator to the conditions of an inadvertent boron dilution event.
In MODE 2, the source range and power range neutron flux functions can provide the necessary alarm for conditions of an inadvertent boron dilution event, as well as initiate RCCA insertion. These signals are actuated when the trip setpoint is reached in one-out-of-two or two-out-of-four channels, respectively. The boron dilution accident analysis assumes that a reactor trip occurs on a source range neutron flux signal at about the time of the initiation of the dilution.
The Boron Dilution Mitigation System (BDMS) has the primary purpose to mitigate the consequences of the inadvertent addition of unborated primary grade water into the RCS when the plant is in MODES 2 (below P-6 setpoint), 3,4, and 5. The P-6 setpoint relates to the Intermediate Range Neutron Flux interlock.
The BDMS functions with two channels of source range instrumentation. Each source range channel provides a signal to its microprocessor, which continuously records the counts per minute. The BDMS instrumentation senses abnormal increases in source range counts per minute (flux rate) and actuates CVCS and refueling water storage tank valves in order to mitigate an inadvertent boron dilution event. Based on abnormal flux multiplication, BDMS sounds an alarm to alert the operator and also automatically initiates valve movement to terminate the dilution and start boration.
Plant specific analyses have demonstrated a wide range of dilution flow rates that are automatically covered by BDMS and the fact that the times involved allow credit for operator action to terminate the inadvertent dilution transient. As discussed above, because an inadvertent boron dilution would be terminated by Overtemperature AT or by operator action, the BDMS is not required for MODES 1 and 2 (above P-6 setpoint).
TS 3.3.9, "Boron Dilution Mitigation System (BDMS)" ensures the availability of the ]3DMS by requiring two trains of BDMS instrumentation to be OPERABLE and one loop of RCS to be in operation during MODES 2 (below P-6 setpoint) through 5. With no reactor coolant loop in operation in these Modes, boron dilutions must be terminated and dilution sources isolated. The boron dilution accident analysis in these Modes takes

Attachment 1 ULNRC-05269 Page 5 of 18 credit for the mixing volume associated with having at least one reactor coolant loop in operation.
Because the BDMS utilizes the source range instrumentation in its detection system, the OPERABILITY of that portion of the detection system is also part of the OPERABILITY of the Reactor Trip System. TS 3.3.1, "RTS Instrumentation" ensures the availability of the source range neutron flux trip function by requiring two channels of source range neutron flux to be OPERABLE in MODE 2 (below P-6 setpoint) and in MODES 3, 4, and 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted.
The source range neutron flux trip function and the BDMS are not applicable in MODE 6. Note, however, that in MODE 6, TS 3.9.3, "Nuclear Instrumentation" ensures that two source range neutron flux monitors are OPERABLE to provide continuous indication of core reactivity condition.
In MODE 6, the inadvertent boron dilution is precluded by isolating the unboratecd watar source from the RCS. The unborated water source contemplated is the addition of prirmary grade water from the reactor makeup water system (RWMS) into the RCS through the reactor makeup portion of the CVCS. A boric acid blend system (via the CVCS boric acid blending tee) is available to allow the operator to match the makeup's boron concentration to that of the RCS during normal charging. Note that use of the term "mi King tee" or "blending tee" refers to the same CVCS component. Reactor makeup water is used for the blended flow from the blending tee. Under the current TS 3.9.2, inadvertent dilution via the CVCS blending tee is prevented by administrative controls which isolate the RCS from this potential source of unborated water. Under current TS 3.9.2 the CVCS isolation valves BGV0178 and BGV0601 are locked closed during refueling operations. The Callaway Plant FSAR credits the physical barrier created by valve isolation to defeat the dilution source and preclude the possibility of an inadvertent boron dilution event. Also, in MODE 6, during refueling decontamination activities, per Am.ndment 97 to the Callaway Plant Operating License, administrative controls limit the volume of unborated water added to the refueling pool in order to prevent diluting the refueling pool below the limits specified in TS LCO 3.9.1. The administrative controls are discussed in TS Bases 3.9.1, APPLICABLE SAFETY ANALYSES.
3.2      Additional Unborated Water Dilution Sources Identified Callaway Plant has performed a review of plant systems and evaluated other potential unborated water dilution sources from primary system resin beds and other potential dilution paths for reactor makeup water to enter the RCS. As a result, additional unborated water dilution sources have been identified and are discussed below.

Attachment 1 ULNRC-05269 Page 6 of 18 CVCS and BTRS The CVCS and its subsystem the BTRS are designed to vary the RCS boron concentration to compensate for xenon transients and other reactivity changes which occur when the reactor power changes during load following. The CVCS controls the RCS chemistry conditions, activity levels, and boric acid concentrations. To perform these functions, a continuous feed and bleed flow is maintained between the RCS and the CVCS. Reactor coolant is first "letdown" from the RCS into the CVCS system. The letdown flow from the RCS to the CVCS may be diverted to CVCS resin vessels when boron concentration changes or other chemistry changes are desired. Note that the CVCS resin vessels include the resin vessels in the BTRS. The stream of letdown flow is processed through the CVCS resin vessels to achieve the desired chemistry conditions.
After processing by the CVCS and BTRS, the stream is then returned to the letdown flow path and eventually returned to the RCS. Although the primary function is to compensate for xenon transients during load follow, the CVCS and BTRS subsystem are also used to handle boron changes during other modes of plant operation: startups and shutdown.
Prior to the proposed amendment, the effect of the CVCS resin vessels had been overlooked as a possible source of boron dilution. Administrative controls taken by Callaway Plant to isolate the potential RCS dilution sources in Mode 6 did not include con ,ideration of the CVCS resin vessels as a dilution source. The CVCS cation resin vessel location allows a portion of the BTRS to be used for normal operations and for RCS clean-up. As a dilution source the CVCS resin vessels could potentially remove boron from the CVCS stream using the CVCS or BTRS ion exchange capability prior to return to the RCS. The risk of an inadvertent boron dilution via the CVCS resin vessels is related to the potential for resin beds configured for dilution to dilute the RCS boron concentration as a result of equipment failure or human error. Depending on the condition of the resin, operation of the CVCS resin vessel could equate to diluted borated water or to a worst-case pure water addition into the RCS.
Under the proposed TS 3.9.2, deliberate steps are required to isolate the CVCS resin vessels containing resin for dilution, when necessary, to avoid an inadvertent boron dilution event in Mode 6. Proposed TS 3.3.9 ensures that in higher modes of plant operation, the CVCS resin vessels configured with resin for dilution would be secured closed under administrative controls, should both trains of BDMS be unavailable or should a condition of no reactor coolant loop in operation exist.
Flushing CVCS Letdown Gamma Radiation Detector SJREOOI The effect of purging the CVCS letdown gamma radiation detector SJREOOI, by flushling the detector with unborated reactor makeup water, raises concern for a potential dilution path to the CVCS volume control tank (VCT) and the reactor coolant system.
Based on plant experience, the detector SJREOO1 often becomes fouled with boric acid,

Attachment 1 ULNRC-05269 Page 7 of 18 causing it to become plugged and resulting in an intolerable increase in the detector's background gamma radiation. Whenever this occurred in the past, the detector was routinely disassembled and decontaminated at the expense of personnel dose and time. A plant modification was implemented to use existing piping to flush the detector with unborated reactor makeup water.
Although flushing the detector with unborated reactor makeup water is effective, the activity creates a dilution source via the purge line discharge to the VCT. Nuclear sampling system valve SJV0703 isolates the reactor makeup water supply used to purge detector SJRE001. Because flushing the detector is not a requirement in MODE 6, valve SJV0703 may be secured closed to prevent the potential dilution path. Capability to flush the detector may be necessary at higher modes of operation; however, the flushing activity would be covered by the BDMS. In the event the BDMS is unavailable, the valve SJV0703 would be secured closed under administrative controls.
Under proposed TS 3.9.2, securing valve SJV0703 closed precludes the flushing acti vity and the potential of the dilution event. Based on plant experience, a need to flush the detector during refueling activities is unlikely. In higher modes of plant operation, under proposed TS 3.3.9, purging the CVCS radiation detector SJRE001 would be precluded, should both trains of the BDMS be unavailable or should the condition of no reactor coolant loop in operation exist. The requirement to secure valve SJV0703 closed assures that the inadvertent dilution event would not occur.
3.3       Summary In Mode 6, current TS 3.9.2 requires deliberate steps to isolate reactor makeup water valves connected to the RCS to prevent inadvertent dilution. Proposed TS 3.9.2 requires the same degree of control for the CVCS resin vessels and isolation of the purge line for flushing the CVCS letdown gamma radiation detector SJRE001. Deliberate steps are taken to isolate the CVCS resin vessels configured with resin for dilution and to isolate the purge line for detector SJRE001, when necessary, to avoid an inadvertent boron dilution event in Mode 6.
In higher modes of plant operation, when both trains of BDMS are unavailable or when a condition exists where no RCS loop is in operation, current TS 3.3.9 requires deliberate steps taken to isolate the reactor makeup water valves connected to the RCS to prevent inadvertent boron dilution. Proposed TS 3.3.9 requires deliberate steps taken to isolate the reactor makeup water valves connected to the RCS when both trains of BDMS are unavailable or when a condition of no RCS loop in operation exists. In addition, proposed TS 3.3.9 ensures isolation of CVCS resin vessels configured with resin for dilution and isolation of the purge line for detector SJRE001, when necessary, to avoid an inadvertent boron dilution event

Attachment 1 ULNRC-05269 Page 8 of 18

==4.0     TECHNICAL ANALYSIS==

4.1     Revisions to TS 3.9.2 and TS 3.3.9 to Include Additional Unborated Water Dilution Sources In MODE 6, the inadvertent dilution event is avoided when TS 3.9.2 requirements are met. As stated in the Callaway FSAR, Section 15.4.6, inadvertent boron dilution via the CVCS blending tee is prevented by administrative controls which isolate the RCS from potential sources of unborated water. Under current TS 3.9.2 and plant administrative controls, the isolation valves BGV0178 and BGV0601 in the CVCS are locked closed during refueling operations to defeat a dilution source.
However, current TS 3.9.2 does not include consideration of the CVCS resin vessels as potential dilution sources. Based on these omissions, the possibility exists for the occurrence of an inadvertent boron dilution event. Plant compensatory actions have been taken to revise plant administrative procedures to include isolation of the CVCS resin vessels, if needed to avoid a boron dilution event. Procedural guidance requires flushing borated water through the resin beds and subsequent testing of the effluent prior to placing the vessel in service. The proposed revisions to TS 3.9.2 will ensure that the CVCS resin vessels are isolated in MODE 6, if required.
Isolation of the CVCS resin vessels, if needed, to avoid a boron dilution event in higher modes of plant operation is ensured by proposed TS 3.3.9. When both trains of BDMqS are inoperable, the operators are aware of the loss of safety function for automatically mitigating an inadvertent boron dilution event. When there are no RCS loops in operation, the operators are aware of the reduced mixing volume available for an inadvertent boron dilution event. Therefore, should both trains of the BDMS become unavailable, or should a condition of no RCS loop in operation exist, proposed TS 3.3.9 will ensure that the CVCS resin vessel isolation valves are secured closed under administrative controls. The administrative controls include procedural requirements to precondition the resin vessels with borated water prior to their use; to monitor their effluent for boron concentration; and to assess the impact to plant reactivity management.
The administrative controls ensure that the resin vessels are not dilution sources and thus preclude a potential boron dilution event.
Further evaluations were conducted to determine the risk of inadvertent boron dilution events from other primary system resin beds. In all cases the resin beds are borated prior to service to match the influent stream concentration. Plant procedures govern these evolutions and implement the administrative controls important to reactivity mar agement.
Current TS 3.9.2 also does not consider flushing the CVCS letdown gamma radiation detector SJRE001 with unborated reactor makeup water in Mode 6 as a potential dilution source. Valve SJV0703 isolates the reactor makeup water supply used

Attachment 1 ULNRC-05269 Page 9 of 18 to purge the detector SJREOO1. During a purge cycle the unborated reactor makeup purge water flushes through the detector and discharges to the VCT. Plant procedures have been revised so that administrative controls are placed to isolate valve SJV0703 during refueling activities. Proposed TS 3.9.2 will preclude the flushing activity and a potential boron dilution event in MODE 6. In higher modes of plant operation, an inadvertent boron dilution event due to flushing the detector is precluded by proposed TS 3.3.9. Should both trains of the BDMS become unavailable, or a condition of no RCS loop in operation exist, the valve SJV0703 is secured closed. The flushing activity is precluded as well as a potential boron dilution event.
Based on a review of plant systems and an evaluation of other potential dilution sources from primary system resin beds, and other potential dilution paths for reactor makeup water to enter the RCS, there are no other "overlooked" unborated water systems connected to the RCS that could become a credible potential dilution source.
Recognizing that the CVCS resin vessels and flushing the CVCS letdown gamma radiation detector SJRE001 are potential boron dilution sources does not alter the original FSAR analysis, conclusion, and consequences evaluated for the inadvertent boron dilution event during MODE 6. The proposed changes are acceptable and proposed TS 3.3.9 and TS 3.9.2 ensure that isolation requirements are met.
4.2          Discussion of Bases Changes for TS 3.3.1 Condition I and Condition K and Bases Changes for TS 3.3.9 Condition A In addition to the proposed TS changes and their associated Bases changes, specific Bases changes for TS 3.3.9 Condition A and Bases changes for TS 3.3.1, "Reactor Trip System (RTS) Instrumentation", Condition I and Condition K, are made as separate and additional changes. Note that these TS Bases changes are made under the Callaway TS Bases and 50.59 review programs and are provided to NRC for information only.
TS 3.3.9 Condition A (Modes 2 (below P-6), 3, 4, and 5) results when one train of BDMS is inoperable. TS 3.3.1 Condition I (Mode 2 (below P-6)) and TS 3.3.1 Condition K (Modes 3, 4, and 5) result when one source range neutron flux channel is inoperable. The changes remove statements that were previously added to these Bases sections as enhancements, but which have now been determined to be unnecessary and overly restrictive.
The statements disallow the introduction of reactor makeup water into the RCS from the CVCS mixing tee when in the TS 3.3.1 Condition I or Condition K or in TS 3.3.9 Condition A.
Inoperability of one train of BDMS or inoperability of one source range neutron flux channel does not by itself prevent mitigation of an inadvertent boron dilution event. The other train of BDMS remains available or the other source range neutron flux channel remains available to provide the necessary function to automatically mitigate an inadvertent

Attachment 1 ULNRC-05269 Page 10 of 18 boron dilution event. When in TS 3.3.1 Condition I or Condition K or in TS 3.3.9 Condition A, in each case the remaining operable BDMS train or the remaining operable source range neutron flux channel provides the BDMS automatic mitigating safety function in the event of an inadvertent boron dilution event. Removing the overly restrictive statements does not adversely impact the BDMS safety function or the LCO 3.3.1 and LCO 3.3.9 requirements that both source range neutron flux channels are operable and that both trains of BDMS are operable.
Based on current plant procedures for evolutions to borate or dilute using the CVCS blending tee and based on requirements to maintain shutdown margin, these statements are not needed and are overly restrictive. Concentrated boric acid held in boric acid storage tanks is blended with reactor makeup water to yield a lower boric acid concentration to the volume control tank or charging pump suction. Blended boric acid can be added to the CVCS system manually by the control room operator or automatically. The control room operator selects the desired boric acid concentration from the main control room panel and monitors plant parameters for the expected results. Administrative controls, control room annunciations, and the CVCS, RMWS, and boric acid storage tanks system designs make an inadvertent boron dilution event highly unlikely. Plant procedures require verification of the settings for use of the reactor makeup water, the boric acid storage tanks, and the blend process. The CVCS and RMWS are designed to limit the potential rate of dilution by providing control room annunciation to the operators and by automatically terminating makeup flow when outside deviation limits. In addition dilution evolutions are finite processes that are performed to completion under the continual observance of operators. Disallowing use of the blending tee when one BDMS train is inoperable or when one source range neutron flux channel is inoperable is unnecessary.
In addition to being overly restrictive, these TS Bases statements are not consistent with current TS 3.3.1 Condition I or Condition K or with TS 3.3.9 Condition A.
Because the statement of the requirement is located in the TS Bases only and is not in the TS, the requirement is not consistent with the TS and could result in a potential violation of TS.
Note that with the loss of both trains of BDMS or loss of both source range neutron flux channels or with the no reactor coolant loop in operation, the plant is in a more degraded condition and with increased vulnerability to a boron dilution accident. Loss of both trains of BDMS or both source range neutron flux channels results in the loss of safety function for automatically mitigating an inadvertent boron dilution event. With a condition of no reactor coolant loop in operation, a reduced mixing volume results for an inadvertent boron dilution event. Proposed TS 3.3.9 ensures that all unborated water source isolation valves are closed and secured and precludes the potential for an inadvertent boron dilution event. Removing the TS Bases statements does not adversely impact plant protection from an inadvertent boron dilution event.

Attachment 1 ULNRC-05269 Page 11 of 18 5.9      REGULATORY SAFETY ANALYSIS 5.1     No Significant Hazards Consideration AmerenUE has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92(c) as discussed below:
: 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed changes do not involve a significant increase in the probability or consequences of an inadvertent boron dilution accident by isolating the CVCS resin vessels in MODE 6 or by isolating the purge line for detector SJRE001 during flushing activities in MODE 6. By recognizing these potential dilution sources and by making TS 3.3.9 and TS 3.9.2 more generic for consideration of all potential dilution sources, plant administrative controls are revised such that the plant is put in a safer condition than before. Specific isolation valves are removed from TS 3.3.9 and TS 3.9.2. They are relocated from the Specifications to the appropriate TS Bases. This is an administrative only change and is consistent with the Standard Technical Specification, NUREG-1431.
Allowing a dilution source path to be unisolated under administrative controls, described in TS Bases 3.9.1 during refueling decontamination activities, is acceptable as allowed by Amandment 97 to the Callaway Operating License and does not involve a significant increase in the probability or consequences of an inadvertent boron dilution accident.
Allowing an exception for CVCS resin vessel operation is acceptable because chemistry conixols may require some CVCS resin vessels to be configured with resin intended for boron dilution. Plant conditions may warrant their use. As allowed by the LCO Note, these vessels may be unisolated under administrative controls. The administrative controls ensure that the resin vessels are not dilution sources. These changes do not involve a significant increase in the probability or consequences of an inadvertent boron dilution accident.
The proposed changes do not involve a significant increase in the probability or consequences of an inadvertent boron dilution accident by requiring the isolation of all unborated water source isolation valves in higher plant modes when both trains of BDMS are inoperable or when a condition of no reactor coolant loop in operation exists.
Proposed TS 3.3.9 Required Actions B3 and C are generic and remain consistent with the plant accident analyses. Allowing exceptions for CVCS resin vessel operation is acceptable because chemistry controls may require some CVCS resin vessels to be configured with resin intended for boron dilution. Plant conditions may warrant their use. As allowed by exception Notes, these vessels may be unisolated under

Attachment 1 ULNRC-05269 Page 12 of 18 administrative controls. The administrative controls ensure that the resin vessels are not dilution sources.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed changes do not create the possibility of a new or different kind of accident. Although other potential dilution sources are identified for administrative control, the evaluation of a MODE 6 dilution event remains unchanged. Isolating the CVCS resin vessels or isolating the purge line for detector SJRE001 during flushing acti vities in MODE 6 and making TS 3.3.9 and TS 3.9.2 more generic does not impact the operability of any safety related equipment required for plant operation. No new equipment will be added and no new limiting single failures are created. The plant will continue to be operated within the envelope of the existing safety analysis. In addition specific isolation valves are removed from TS 3.3.9 and TS 3.9.2. They are relocated from the Specifications to the appropriate TS Bases. This is an administrative only change and is consistent with the Standard Technical Specification, NUREG-1431.
Allowing a dilution source path to be unisolated under administrative controls, described in TS Bases 3.9.1 during refueling decontamination activities, is acceptable as allowed by Amendment 97 to the Callaway Operating License and does not create the possibility of a new or different kind of inadvertent boron dilution accident. Allowing an exception for CVCS resin vessel operation is acceptable because chemistry controls may require some CVCS resin vessels to be configured with resin intended for boron dilution. Plant conditions may warrant their use. As allowed by the LCO Note these vessels may be unisolated under administrative controls. The administrative controls ensure that the resin vessels are not dilution sources. These changes do not create the possibility of a new or different kind of accident from an inadvertent boron dilution accident previously evaluated.
Requiring the isolation of unborated water source isolation valves in higher plant modes when both trains of BDMS are inoperable or when a condition of no RCS loop in operation exists, does not create the possibility of a new or different kind of inadvertent boron dilution accident. Proposed TS 3.3.9 is generic and remains consistent with the plant accident analyses. Allowing exceptions for CVCS resin vessel operation is acceptable because chemistry controls may require some CVCS resin vessels to be configured with resin intended for boron dilution. Plant conditions may warrant their use. As allowed by exception Notes, these vessels may be unisolated under

Attachment 1 ULNRC-05269 Page 13 of 18 administrative controls. The administrative controls ensure that the resin vessels are not dilution sources.
Therefore, the proposed changes do not create a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No The proposed changes do not reduce the margin of safety. Although other potential dilution sources are identified for administrative control and TS 3.3.9 and TS 3.9.2 are made generic for consideration of all potential dilution sources, the evaluated margin of safety for a dilution event in MODE 6 remains the same. Recognition of other potential dilution sources, isolation of the CVCS resin vessels and the purge line for detector SJRE001 during flushing activities in MODE 6, places the plant in a safer condition than before. In addition specific isolation valves are removed from TS 3.3.9 and TS 3.9.2.
They are relocated from the Specifications to the appropriate TS Bases. This is an administrative only change and is consistent with the Standard Technical Specification, NUREG-1431. Finally, allowing a dilution source path to be unisolated under administrative controls, described in TS Bases 3.9.1 during refueling decontamination activities, is acceptable as allowed by Amendment 97 to the Callaway Operating License and does not involve a significant reduction in a margin of safety due to an inadvertent boron dilution accident. Allowing an exception for CVCS resin vessel operation is acceptable because chemistry controls may require some CVCS resin vessels to be configured with resin intended for boron dilution. Plant conditions may warrant their use. As allowed by the LCO Note these vessels may be unisolated under administrative controls. The administrative controls ensure that the resin vessels are not dilution sources. This change does not involve a significant reduction in a margin of safety due to an inadvertent boron dilution accident.
Requiring the isolation of all unborated water source isolation valves in higher plant modes when both trains of BDMS are inoperable or when no reactor coolant loop is in operation does not involve a significant reduction in the margin of safety. The changes to the Specifications make it generic and while it remains consistent with the plant accident analyses. Allowing exceptions for CVCS resin vessel operation is acceptable because chemistry controls may require some CVCS resin vessels to be configured with resin intended for boron dilution. Plant conditions may warrant their use. As allowed by these exception Notes, these vessels may be unisolated under administrative controls. The administrative controls ensure that the resin vessels are not dilution sources.
Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Attachment 1 ULNRC-05269 Page 14 of 18 Based on the above evaluations, AmerenUE concludes that the activities associated with the above described changes present no significant hazards consideration under the stardards set forth in 10 CFR 50.92 and accordingly, a finding of "no significant hazards consideration" is justified.
5.2 Applicable Regulatory Requirements/Criteria The regulatory basis for TS 3.9.2, discussed in Callaway FSAR Section 15.4.6, is to ensure that an uncontrolled boron dilution transient will not occur in MODE 6.
Inadvertent dilution via the CVCS blending tee is prevented by administrative controls which isolate the RCS from potential sources of unborated water. Valves BGV0178 and BG'V0601 in the CVCS are locked closed during refueling operations, creating physical bariiers, via valve isolation, to defeat a dilution source and preclude the possibility of an inadvertent boron dilution event.
NUREG-0800, "U. S. NRC Standard Review Plan," Section 15.4.6, provides guidance to the NRC staff for the review and evaluation of system design features and plant procedures provided for the mitigation of Chemical and Volume Control System malFunctions that result in a decrease in boron concentration in the RCS.
The major regulatory requirements for designing plant systems are the General Design Criteria (GDCs) contained in 10 CFR Part 50, Appendix A. They are also discussed in Section 3.1 of the Callaway FSAR. Those that apply specifically to the mitigation of the boron dilution event are presented below.
GDC 10, Reactor Design, "The reactor core and associated coolant, control, and protection systems shall be designed with an appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences." GDC 10 requires that the RCS is provided with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during normal operations including anticipated operational occurrences.
GDC 15, Reactor Coolant System Design, "The reactor coolant system and associated auxiliary, control, and protection systems shall be designed with sufficient margin to assure that the design conditions of the reactor coolant pressure boundary are not exceeded during any condition of normal operation, including anticipated operational occurrences." GDC 15 assures the RCS and its associated auxiliaries are provided with appropriate margin to assure that the pressure boundary will not be breeched during normal operations including anticipated operational occurrences.

Attachment 1 ULNRC-05269 Page 15 of 18 GDC 20, Protection System Functions, "The protection system 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 20 assures the reactor protection system automatically initiates a reactor trip when any variable monitored by the system or combination of monitored variables exceeds the normal operating range. Setpoints are designed to provide an envelope of safe operating conditions with adequate margin for uncertainties to ensure that the fuel design limits are not exceeded.
GDC 25, Protection System Requirements for Reactivity Control Malfunctions, "The protection system shall be designed to assure that specified acceptable fuel design limits are not exceeded for any single malfunction of the reactivity control systems, such as accidental withdrawal (not ejection or dropout) of control rods." GDC 25 assures the protection system is designed to limit reactivity transients so that the fuel design limits are rnot exceeded. Analyses of the effects of possible malfunctions are discussed in FSAR Chapter 15. The analyses show that for postulated boron dilution during refueling, star:up, manual or automatic operation at power, hot standby, or cold shutdown, the operator has ample time to determine the cause of dilution, terminate the source of dilution, and initiate reboration before shutdown margin is lost. Either manual or automatic controls can be used to terminate dilution and initiate boration. The analyses show that acceptable fuel damage limits are not exceeded even in the event of a single mal Function of either system.
GDC 26, Reactivity Control System Redundancy and Capability, " Two independent reactivity control systems of different design principles shall be provided.
One of the systems shall use control rods, preferably including positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable or reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure that the acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subc:ritical under cold conditions." GDC 26 relates to the reliable control of reactivity changes to assure that specified acceptable fuel design limits are not exceeded, including anticipated operational occurrences. This is accomplished by assuring that appropriate margin for malfunctions, such as stuck rods, are accounted for. Two reactivity control systems are provided. At Callaway, the rod cluster control assemblies (RCCAs) and chemical shim (boric acid) provide two reactivity control systems.
The applicable regulatory requirements and criteria must be satisfied for all conditions of plant operation. As discussed above, in MODES 1 and 2 (above P-6

Attachment 1 ULNRC-05269 Page 16 of 18 setpoint) an inadvertent boron dilution event would be terminated by Overtemperature AT or by operator action. In MODES 2 (below P-6 setpoint) or in MODES 3 through 5 adherence to TS 3.3.9, "Boron Dilution Mitigation System (BDMS)", would terminate an inadvertent boron dilution event.
As discussed in the sections above, the proposed changes and associated administrative controls assure that the applicable regulatory requirements and criteria are satisfied in MODE 6 of plant operation. Adherence to proposed TS 3.9.2, "Unborated Wa:er Source Isolation Valves" would preclude an inadvertent boron dilution event in MCDE 6. Based on proposed TS 3.3.9 and TS 3.9.2 and based on their generic requirements, all potential unborated water dilution sources are considered. Specifically, inadvertent dilution via the CVCS and its subsystem the BTRS is addressed by requiring controls which include isolation of the CVCS resin vessels as potential sources for diluted borated or unborated water. Inadvertent dilution via the purge line used during flushing of CVCS letdown radiation monitor SJRE001 is also addressed by requiring controls which include isolation.
Providing isolation of valves associated with unborated water dilution sources, specifically those affected valves in the CVCS, associated with reactor makeup water; or those affected by operation of the CVCS resin vessels; or those associated with the purge line used during flushing of CVCS monitor SJRE001, during refueling operations, creates physical barriers needed to defeat a potential boron dilution source. This accounts for any potential operational malfunction and precludes the possibility of an inadvertent boron dilution event.
In addition, in higher plant modes, proposed TS 3.3.9 requires all unborated water source isolation valves are closed and secured when both BDMS trains are inoperable, or when there is no reactor coolant loop in operation. These isolations create physical barriers to prevent an inadvertent boron dilution event.
Based on the considerations discussed above, 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the Commission's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==6.0      ENVIRONMENTAL CONSIDERATION==

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

Attachment 1 ULNRC-05269 Page 17 of 18 The requested amendment does not change the facility and does not involve any change in manner of operation of any plant systems. The requested amendment does not increase the gamma radiation dose resulting from the operation of any plant system.
Furthermore, implementation of the proposed change does not contribute to occupational gamma radiation exposure.
As discussed above, the proposed changes do not involve a significant hazards consideration and the consequences from an inadvertent boron dilution accident remain bounded by the FSAR analysis. There is no increase in occupational radiation exposure related to the changes. 10 CFR 51.22(b) specifies the criteria for categorical exclusion from the requirements for a specific environmental assessment per 10 CFR 51.21.
Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.
7.0      PRECEDENTS Callaway is unaware of any precedents for the proposed amendment.

==8.0      REFERENCES==

8.1      FSAR Section 15.4.6, "Chemical and Volume Control System Malfunction that Results in a Decrease in the Boron Concentration in the Reactor Coolant System."
8.2      NUREG-0800, Standard Review Plan, Section 15.4.6, Rev. 1, July 1981.
8.3      FSAR Section 9.3.4., "Chemical and Volume Control System."
8.4      FSAR Section 9.3.4.2.1.4, "Boron Thermal Regeneration System."
8.5      TS and Bases 3.3.9, "Boron Dilution Mitigation System (BDMS)."
8.6      TS and Bases 3.9.2, "Unborated Water Source Isolation Valves."
8.7      TS and Bases 3.3.1,"RTS Instrumentation".
8.8      TS and Bases 3.4.5, "RCS Loops-MODE 3".
8.9      TS and Bases 3.4.6, "RCS Loops-MODE 4".
8.10     TS and Bases 3.4.7, "RCS Loops-MODE 5, Loops Filled".

Attachment 1 ULNRC-05269 Page 18 of 18 8.1.[ TS and Bases 3.4.8, "RCS Loops-MODE 5, Loops Not Filled".
8.12  Standard Technical Specifications, NUREG-1431.

ULNRC- 05269 ATTACHMENT 2 MARKUP OF TECHNICAL SPECIFICATION PAGES

BDMS 3.3.9 3.3 INSTRUMENTATION 3.3.9 Boron Dilution Mitigation System (BDMS)
LCO 3.3.9             Two trains of the BDMS shall be OPERABLE and one RCS loop shall be in operation.
APPLICABILITY:        MODES 2 (below P-6 (Intermediate Range Neutron Flux) interlock), 3, 4, and 5.
L I e%-rr I- I I T-The boron dilution flux multiplication signal may be blocked in MODES 2 (below P-6 (Intermediate Range Neutron Flux) interlock) and 3 during reactor startup.
ACTIONS COMPLETI ON CONDITION                        REQUIRED ACTION                        TIME A. One train inoperable.          A.1         Restore train to            72 hours OPERABLE status.
B. Two trains inoperable.          B.1        ---     NOTE--
Plant temperature OR                                        changes are allowed provided the temperature Required Action and                       change is accounted for associated Completion                     in the calculated SDM.
Time of Condition A not met.
Suspend operations           Immediately involving positive reactivity additions.
AND (continued)
CALLAWAY PLANT                              3.3-71                         Amendment No. 165 l

BDMS 3.3.9 ACTIONS Perform SR 3.1.1.1.
AND AND ify un rated water ircoolation valves, d0178 and BGV0601, closed and secured. '*
ok, .36 CALUMWAY PLANT     3.3-72                        Amendment No. 165 l

OL 1238 INSERT1 TS 3.3.9 ASTUNFTE
                --                          -- I     j' I  r-------------------
CVCS resin vessels may be unisolated intermittently under administrative controls when the vessel resin is not preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration.
B.3.1                  Close and secure unborated                                                      4 hours water source isolation valves.
AND B.3.2                  Verify unborated water source isolation valves                                  Once per 31 days are closed and secure.
INSERT2 TS 3.3.9
                       ._________________       IN        12   -
CVCS resin vessels may be unisolated intermittently under administrative controls when the vessel resin is not preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration.
C.1                     Close and secure unborated                                                      4 hours water source isolation valves.
AND C..2                   Verify unborated water source isolation valves                                   Once per 31 days are closed and secure.

Unborated Water Source Isolation Valves 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Unborted Wat         ource     ation Valves LCO 3.9.               Each valve used to isolate unborated water sourc                ese\
shall be secured in the closed position.
APP ICABILITY:          MODE 6.
A5INS
                                   ----          NOTE---                      --                a/
Se   rate Condition entry is allowed for each unborated water source isolation valve.
I                   j CONDITION                          REQUIRED ACTION
       ----      NOTE---- _            N.A         Suspend CORE Required Action A.3 must                    ALTERATIONS.
be completed whenever Condition A is entered.         kND One or more valves not                       Initiate actions to secure secured in closed position.                  valve in closed position.
AND A.3     Perform SR 3.9.1.1.
LURVEILLANCE REQUIREMENTS                     _.          LLANCE SURVE ILLANCE NSR 393.9.2.1        Verify each valve that isolates unborated water sources                                is secured in the closed position.
CALLAWAY PLANT                                   3.9-3                             Amendment No. 133

OL 1238 INSERT LCO 3.9.2
--------------------------------------- NOTE------------------------------------------------------
I.         Unborated water source path valves may be unisolated, as required during refueling decontamination activities, under administrative controls.
: 2.         CVCS resin vessels may be unisolated intermittently under administrative controls when the vessel resin is not preconditioned with borated water with a boron concentration equal to or greater than the refueling boron concentration.

ULNRC- 05269 ATTACHMENT 3 RETYPED MARKUP OF TECHNICAL SPECIFICATION PAGES

BDMS 3.3.9 ACTIONS CONDITION         REQUIRED ACTION                      ICOMPLEION B. (continued)
B.2          Perform SR 3.1.1.1. 1 hour AND Once per 12 hours thereafter AND CVCS resin vessels may be unisolated intermittently under administrative controls when the vessel resin is not preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration.
B.3.1       Close and secure        4 hours unborated water source isolation valves,                                I AND B.3.2      Verify unborated water   Once per 31 days source isolation valves are closed and secured.                           I CAL LAWAY PLANT              3.3-72                      Amendment No. ###

BDMS 3.3.9 ACTIONS CONDITION                      REQUIRED ACTION                    TIME C. No RCS loop in operation. N---------NOTE-CVCS resin vessels may be unisolated intermittently under administrative controls when the vessel resin is not preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration.
C.1         Close and secure        4 hours unborated water source isolation valves.                            I AND C.2         Verify unborated water   Once per 31 days source isolation valves                       I are closed and secured.
CAL.LAWAY PLANT                          3.3-73                      Amendment No. ###

BDMS 3.3.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                  FREQUE:NCY SR 3.3.9.1      Perform CHANNEL CHECK.                                   12 hours SR 3.3.9.2    ------------------------- NOTE --------------------------
Only required to be performed in MODE 5.
Verify BGV0178 is secured in the closed position.         31 days SR 3.3.9.3        ------------------    NOTE ------------------------
Not required to be performed until 4 hours after reducing power below P-6 interlock.
Perform COT and verify nominal flux multiplication       184 days setpoint of 1.7.
SR 3.3.9.4        ------------------    NOTE -----------------------
Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.                              18 months SR 3.3.9.5     Verify the centrifugal charging pump suction valves       18 months from the RWST open and the CVCS volume control tank discharge valves close in less than or equal to 30 seconds on a simulated or actual actuation signal.
SR 3.3.9.6    Verify one RCS loop is in operation.                       12 hours CAL.LAWAY PLANT                           3.3-74                         Amendment No. ###

Unborated Water Source Isolation Valves 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Unborated Water Source Isolation Valves LCO 3.9.2                      Each valve used to isolate unborated water sources shall be secured in                                        I the closed position.
                                --------- ---------------------- NOTE -------                                    ------------
: 1. Unborated water source path valves may be unisolated, as required during refueling decontamination activities, under administrative controls.
: 2. CVCS resin vessels may be unisolated intermittently under administrative controls when the vessel resin is not preconditioned with borated water with a boron concentration equal to or greater than the refueling boron concentration.
_ ~_ _   ~      ~ ~ - - -- - ----- __                         _       _ _          . _
APPLICABILITY:                  MODE 6.
ACTIONS
 -------------- ----------------------------------- NOTE ----------------------------------------
Separate Condition entry is allowed for each unborated water source isolation valve.
CONDITION                                         REQUIRED ACTION                                       TIME A.      -------------NOTE-----------               A.1               Suspend CORE                            Immediately Required Action A.3 must                                      ALTERATIONS.
be completed whenever Condition A is entered.                     AND A.2               Initiate actions to secure              Immediately One or more valves not                                         valve in closed position.
secured in closed position.
AND A.3       Perform SR 3.9.1.1.                            4 hours CAL.LAWAY PLANT                                                    3.9-3                                      Amendment No. ###

Unborated Water Source Isolation Valves 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.9.2.1    Verify each valve that isolates unborated water       31 days sources is secured in the closed position.                                  I CAL.LAWAY PLANT                           3.9-4                      Amendment No. ###

Nuclear Instrumentation 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Nuclear Instrumentation LCO 3.9.3            Two source range neutron flux monitors shall be OPERABLE.
AF PLICABILITY:      MODE 6.
ACTIONS CONDITION                      REQUIRED ACTION                         TIME A. One required source range     A.1       Suspend CORE                 Immediately neutron flux monitor                   ALTERATIONS.
inoperable.
AND A.2        Suspend operations that      Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.
B. Two required source range     B.1       Initiate action to restore   Immediately neutron flux monitors                  one source range inoperable.                            neutron flux monitor to OPERABLE status.
AND B.2        Perform SR 3.9.1.1.          Once per 12 hours CALLAWAY PLANT                            3.9-5                          Amendment No. ###

Nuclear Instrumentation 3.9.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE                               FREQUENCY SR 3.9.3.1   Perform CHANNEL CHECK.                            12 hours SR 3.9.3.2   -------------------- NOTE        -------------
Neutron detectors are excluded from CHANNEL CALIBRATION.
Perform CHANNEL CALIBRATION.                      18 months e                                                                              =_
CAILLAWAY PLANT                         3.9-6                   Amendment No. J/l/#

Containment Penetrations 3.9.4 3.9 REFUELING OPERATIONS 3.9.4 Containment Penetrations LCO 3.9.4             The containment penetrations shall be in the following status:
: a.      The equipment hatch closed and held in place by four bolts, or if open, capable of being closed;
: b.      One door in the emergency air lock and one door in the personnel air lock capable of being closed; and
: c.      Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:
: 1.           closed by a manual or automatic isolation valve, blind flange, or equivalent, or
: 2.           capable of being closed by an OPERABLE Containment Purge Isolation valve.
                               ------------------- ------ --- -------- NOTE ---------------
Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.
APPLICABILITY:         During CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.
ACTIONS CONDITION                                REQUIRED ACTION                          COMPLEIION A. One or more containment             A.1             Suspend CORE                       Immediately penetrations not in required                       ALTERATIONS.
status.
AND A.2             Suspend movement of                Immediately irradiated fuel assemblies within containment.
CAL LAWAY PLANT                                        3.9-7                                Amendment No. ##M

Containment Penetrations 3.9.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                      FREQUENCY SR 3.9.4.1    Verify each required containment penetration is in the    7 days required status.
SR 3.9.4.2    ------        ------      NOTE------------------
Only required for an open equipment hatch.
Verify the capability to install the equipment hatch      7 days SR 3.9.4.3    Verify each required containment purge isolation          18 months valve actuates to the isolation position on a manual actuation signal.
=                                                                                     =
CAL.LAWAY PLANT                             3.9-8                       Amendment No. ###

RHR and Coolant Circulation - High Water Level 3.9.5 3.9 REFUELING OPERATIONS 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation - High Water Level LCO 3.9.5            One RHR loop shall be OPERABLE and in operation.
The required RHR loop may be removed from operation for < 1 hour per 8 hour period, provided no operations are permitted that would cause introduction into the Reactor Coolant System, coolant with boron concentration less than that required to meet the minimum required boron concentration of LCO 3.9.1.
APPLICABILITY:        MODE 6 with the water level 2 23 ft above the top of reactor vessel flange.
ACTIONS CONDITION                         REQUIRED ACTION                   COMPLE ION A. RHR loop requirements not      A.1          Suspend operations that     Immediately met.                                       would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.
AND A.2         Suspend loading             Immediately irradiated fuel assemblies in the core.
AND (continued)
CAL LAWAY PLANT                               3.9-9                         Amendment No. ###

RHR and Coolant Circulation - High Water Level 3.9.5 ACTIONS CONDITION                         REQUIRED ACTION                    COMPLETION A. RHR loop requirements not     A.3          Initiate action to satisfy  Immediately met.                                       RHR loop requirements.
(continued)
AND A.4          Close all containment      4 hours penetrations providing direct access from containment atmosphere to outside atmosphere.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                        FREQUENCY SR 3.9.5.1        Verify one RHR loop is in operation and circulating        12 hours reactor coolant at a flow rate of 2 1000 gpm.
CAI-LAWAY PLANT                              3.9-1 0                        Amendment No. ###

RHR and Coolant Circulation - Low Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level LCO 3.9.6            Two RHR loops shall be OPERABLE, and one RHR loop shall be in operation.
APPLICABILITY:        MODE 6 with the water level < 23 ft above the top of reactor vessel flange.
ACTIONS CONDITION                      REQUIRED ACTION                    COMPLETION A   Less than the required      A.1         Initiate action to restore   Immediately number of RHR loops                    required RHR loops to OPERABLE.                              OPERABLE status.
OR A.2         Initiate action to establish  Immediately
                                             > 23 ft of water above the top of reactor vessel flange.
(ccntinued)
CALLAWAY PLANT                            3.9-1 1                         Amendment No. ###

RHR and Coolant Circulation - Low Water Level 3.9.6 ACTIONS (continued)
CONDITION                        REQUIRED ACTION                        TIME B. No RHR loop in operation. B.1          Suspend operations that     Immediately would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.
AND B.2          Initiate action to restore Immediately one RHR loop to operation.
AND B.3         Close all containment       4 hours penetrations providing direct access from containment atmosphere to outside atmosphere.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                        FREQUE NCY SR 3.9.6.1      Verify one RHR loop is in operation and circulating         12 hours reactor coolant at a flow rate of 2 1000 gpm.
SR 3.9.6.2      Verify correct breaker alignment and indicated power       7 days available to the required RHR pump that is not in operation.
CAL LAWAY PLANT                             3.9-1 2                        Amendment No. ###

Refueling Pool Water Level 3.9.7 3.9 REFUELING OPERATIONS 3.9.7 Refueling Pool Water Level LCD 3.9.7               Refueling pool water level shall be maintained 2 23 ft above the top of reactor vessel flange.
APPLICABILITY:           During movement of irradiated fuel assemblies within containment:.
ACTIONS CONDITION                           REQUIRED ACTION                        TIME A   Refueling pool water level        A.1         Suspend movement of         Immediately not within limit.                             irradiated fuel assemblies within containment.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                        FREQUENCY SR 3.9.7.1          Verify refueling pool water level is 2 23 ft above the     24 hours top of reactor vessel flange.
CALLAWAY PLANT                                  3.9-13                          Amendment No. ###

ULNRC- 05269 ATTACHMENT 4 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (for information only)

B 3.3.1 BASES APPLICABLE          5. Source RanQe Neutron Flux SAFETY ANALYSES,                The LCO requirement for the Source Range Neutron Fjux thip LCO, AND                 Function ensures that protection is provided against an APPLICABILITY            uncontrolled RCCA bank rod withdrawal accident from a (continued)             subcritical condition during startup (automatic rod withdrawal is no longer available). This trip Function provides redundant prctectlon to the Power Range Neutron Flux- Low and Intermediate Range Neutron Flux trip Functions. In MODES 3,4, and 5, administrative controls also prevent the uncontrolled manual withdrawal of rods.
The NIS source range detectors are located external to the reactor vessel and measure neutrons leaking from the core. The NIS source range detectors do not provide any inputs to control systems. The source jange trip is the only RTS automatic protection function required in MODES 3,4, and 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. Therefore, the functional capability at the Trip Setpoint is assumed to be available.
The LCO requires two channels of Source Range Neutron Flux to be OPERABLE. Two OPERABLE channels are sufficient to ensure no single random failure will disable this trip Function. This Function uses one-out-of-two trip logic. The Trip Setpoint is           II)
                          < 1.0 E5 cps. The outputs of the Function to RTS logic are not required OPERABLE in MODE 6 or when an rods are fully inserted and the Rod Control System is incapable of rod withdrawal.
                         *The Source Range Neutron Flux trip Function Provides protection for control rod withdrawal from subcritiala                and
: .      l ScR  'a
* control rod eiection events.
9   3,3.         lIn MODE 2 when below the P-6 setpoint, the Source Range eutrnon Flux trip must be OPERABLE. Above the P-6 setpoint, the Intemeiate Range Neutron Flux trip and the Power Range Neutron Flux-Low trip will provide core protection for reactivty accidents. Above the P-I setpoint, the NIS source range neutron flux reactor-top may be manually blocked. When the source range trip is blocked, the high voltage to the detectors is also removed.
: in MODES 3,4, and 5 with the Rod Control System capable oif rod withdrawal or one or more rods not fully inserted, the Source Range Neutron Flux trip Function must also be OPERABLE. If the Rod Control System Is capable of rod withdrawal, the Source Range Neutron Flux trp must be OPERABLE to provide core protection against a rod withdrawal accident. ff the Rod Conbol (conttiued)
I)
CALLAWAY PLANT                            B 3.3.1-14                                 Reviskon Se

i-TSBCN 02-016 INSERT1 B 3.3.1 In MODE 2 credit is also taken for a reactor trip being initiated by this trip Function to alert the control room operators to manually mitigate an inadvertent boron dilution event.

RTS Instrumentation B 3.3.1 BASES ACTIONS         GI and G2 (continued) range channels or the neutron flux channels discussed in LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," with action to reduce power below the count rate equivalent to the P-6 setpoint.
Below P-6, the Source Range Neutron Flux channels will be able tb monitor the core power level. The Completion Time of 2 hours will allow a slow and controlled power reduction to less than the P-6 setpoint and takes into account the low probability of occurrence of an event during this period that may require the protection afforded by the NIS Intermediate Range Neutron Flux trip.
Required Action GI is modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (i.e.,
temperature or boron concentration fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met and the requirements of LCOs 3.1.5, 3.1.6, and 3.4.2 are met.
H.1 Not used.
Condition I applies to one inoperable Source Range Neutron Flux tiip channel when in MODE 2 below the P-6 setpoint. With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions. With one of the two channels inoperable, operations involving positive reactivity additions shall be suspended immediately.
This will preclude any power escalation. With only one source range channel OPERABLE, core protection is severely reduced and any actions that add positive reactivity to the core must be suspended immediately.
Required Action 1.1 s modified by a Note to indicate that normal plant control operations that individually add limited positive reactivity (i.e.,
: temperature or boron concentration fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided the SDM limits specified in the COLR are met,-the I                 requirements of LCOs 3.1.5, 3.1.6, and 3.4.2 are met, and the Infitial and critical boron concentration assum tions In FSAR Section 15.4.6 (Ref. 16)
A           are satisfied.        UUF-i      UA1to                     110FEUs (continued)
CALLAWAY PLANT                         B 3.3.140                                   Revision 5e p...

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

RTS Instrumentation 13 3.3.1 BASES ACTIONS          1.1 (continued) oeiIan        lu    ontr System      xng t       is no   rmt J.1 Condition J applies to two inoperable Source Range Neutron Flux thip channels when in MODE 2 below the P-6 setpoint or in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, the NIS source range performs the monitoring and protection functions. With both source range channels inoperable, the Reactor Trip Breakers (RTB!;)
must be opened immediately. With the RTBs open, the core is in a more stable condition.
K.1. K.2.1. and K.2.2 Condition K applies to one inoperable source range channel in MODE 3, 4, or 5 with the Rod Control System capable of rod withdrawal or one or more rods not fully inserted. With the unit in this Condition, below P-6, 1the NIS source range performs the monitoring and protection functions.
With one of the source range channels inoperable, 48 hours is allowed to restore it to an OPERABLE status. If the channel cannot be returned to an OPERABLE status, action must be initiated within the same 48 hours to fully insert all rods. One additional hour is allowed to place the Rod Control System in a condition incapable of rod withdrawal (e.g., by de-energizing all CRDMs, by opening the RTBs, or de-energizing the motor generator (MG) sets). Once these ACTIONS are completed, ihe core is in a more stable condition. The allowance of 48 hours to restore the channel to OPERABLE status, and the additional hour to place the Rod Control System in a condition incapable of rod withdrawal, are reasonable considering the other source range channel remains OPERABLE to perform the safety function and given the low probability of an event occurring during this Interval. Normal plant control operations that individually add limited positive reactivity (i.e., temperature or boron concentration fluctuations associated with RGS inventory management or t      rure control) are permitted provided the SDM limits specified in tXhe COLI are met and-the initial and critical boron concentrati           -
  .  >  ^   \_assumfDtons in FSAR Section 15.4.6 (Ref. 16) are satisfied. i1ntrcti~
(continued)
CALLAWAY PLANT                           B 3.3.1-41                                  Revision 5e

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

BDMS e                                                       B 3.3.9 B 3.3 INSTRUMENTATION B 3.3.9 Boron Dilution Mitigation Sys                   DMS)
BASES        .
B1A.CKGROUND.                     eprimary purpose of the.BDMS is to mitt te the consequences of the inadvertent addition of unborated primary g de water into the Reactor Coolant System (RCS) when the plant is i ODES 2 (below P-6
                              .setpoint), 3,4, and5..,.                 :.
                           ''TheBDMS utilizes'tWo'ch'annls"of source ra nge strumentati6n. 'Each
                               .souroe range channel provides a signal tcfks microprocessor,            ihih
          . ..     , . .. , continuously.records.the counts-periminute..At the end of each discrete one-mirWte. interval, an algorithm compares the average counts per
                             ...iiinute value (fliux rate) of that 1.minute interval with the average counts
                  ;-.... ,. perinute value for the previous..nipe, 1,minute intervals. If the flux rate during a 1 minute interval is greaterthan or equal to 1.7 times the flux rate during any of the prior nine 1 minute intervals, the BDMS proiides a signal .to initiate,mitigating actions.
                               -Upon.detection of a flux multiplication by either source range instrumentation train, an alarmnis sounded-to alert the operator and valve
                ,, .movement                 is.automatically initiated to terminate the dilution and start bora-tion. Valves that isolate therefueling water storage tank (RW',T) are opened to supply borated water to the suction of the centrifugal charging pumps, and valves which isolate the Volume:Control Tank are closed to
                 . .            terminate the dilution.
O'LICABLE                  The BDMS senses abnormal lncreaaesein source range counts per minute
 .#AFETY                        (flux rate) and actuates VCT and RWST valves to mitigate the
: ANLYSES           . \ko ccinsequences. of an inaadTertentolioron idituitioh evenVt'asdescrild (in
                      '9         Refm m,1. The accident analey.sly Qn~automatic BDMS actuation to
                              , mitigatethe consequtences of inadvertent boron dilution events in MODES
 ';            ?)&sect;             .3,4, and 5. The MODE.2 analysis in Reference I credits the source range. reacto!rtrip function, in conjunctionwith operator action. The ope ration of one RCS loop in MODES -Z.(below P-6 setpoint), 3; 4, anc provides adequate flow to ensure mixing, prevent stratification, and' producegradual reactivity chargesciuring RCS boron concentration
                               ;eductions. The reactivity ;change.:rate'associated with boron reduction
                               .will, therefore, be within the transient mitigation capability of the.1B1) MS.
                               .With no' reactor coolant loop in operation in the above MODES, boron dilutions must be terminated andclilution sources isolate46 The boron dilution analysis in these MODES takes credit for the mjing 'volume associated with havi                            coolan        in operation.
2 CAL.LAW)                r[                             B 3.3.9-1                                    Revision 3

TSB CN 02-016 INSERT Ia Bases 3.3.9 The addition of unborated primary grade water into the RCS results in boron dilution and a potential for an inadvertent boron dilution event. Other potential boron dilution sources have been identified. An inadvertent boron dilution path is created when flushing the chemical and Volume Control system (CVCS) letdown gamma radiation detector, SJRE001, with unborated reactor makeup water. Boron dilution may also be accomplished by removing boron from the CVCS stream prior to RCS return using the ion exchange capability of the CVCS resin vessels. The CVCS resin vessels include the resin vessels of its subsystem, the boron thermal regeneration system.
                           - I

B 3.3 BASES APPLICABILITY      In MODE 6, a dilution event is precluded by locked valvessn' (continued) l      Th       at     isolate the RCS from the potential O f unborated water (according to LCO 3.9.2, "Unborated Water Srce Isolation Valves").                                                    0 The Applicability is modified by a Note that allows the boron dilution flux multiplication signal to be blocked during reactor startup in MODE 2 (below P-6 setpoint) and MODE 3. Blocking the flux multiplication signal is acceptable during startup provided the reactor trip breakers are closed with the intent to commence the withdrawal of control banks for startup.
This Applicability Note can not be used to block BDMS prior to or during shutdown bank withdrawal. The P-6 interlock provides a backup block signal to the source range flux multiplication circuit.
ACTIONS            The most common cause of channel inoperability is outright failure or drift/
of the bistable or process module sufficient to exceed the tolerance allowed by the unit specific calibration procedure. Typically, the drift is found to be small and results in a delay of actuation rather than ;3 total loss of function. This determination of setpoint drift is generally made during the performance of a COT when the process instrumentation is set up for adjustment to bring it to within specification. If the Trip Selpoint is
. .less                         conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.
Al1 With one train of the BDMS inoperable, Required Action A.1 requires that the inoperable train must be restored to OPERABLE status within 72 hours. Inthis Condition, the remaining BDMS train is adequate to provide protection. The 72 hour Completion Time is based on the BDMS Function and is consistent with Engineered Safety Feature Q95-(C             ompletion Times for loss of one redundant train. Also, the remaining OPERABLE train provides continuous indication of core power status to the operator, has an alarm function, and sends a signal to both trains of the BDMS to assure system actuation.
Administrative controls require operator awareness during all re       -
                          \manipulations. These administrative controls include entrol                   Room Operations Staff (typically-conducted at the beginning of each shift);
(continued)
C:ALLAWAY PLANT                           B 3.3.9-3                                     Revision 5

TSB CN 02-016 INSERTI Bases 3.3.9 for unborated reactor makeup water (BGVOI78 and BGV0601), CVCS resin vessels configured with resin for dilution during normal operation (BG8522A, BGS522B, EBGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor (SJV0703)

BDMS B 3.3.9 BASES ACTIONS         A.1 (continued)
                -    Use of self-verification techniques by all licensed operators performing core reactivity manipulations;
                -    Peer checks for all reactivity manipulations during routine operations and for all positive reactivity additions during transient or off-normal operations;
                -    Off-normal procedures                     that address eao        keup control system (Ra)        malfunctions and potential loss of s own margin (S Durin ny and all rod motion, operators monitor all available indications o, clear power. During RCS boron concentration change evolutions, operators observe the various indications and alarms provided in the RMCS design for monitoring proper system operation as discussed in FSAR Section 15.4.6 (Reference 1). 4jVodutln otre-ctor mp B.1. B.2, B.3.1, and B.3.2
    /   gnat With two trains inoperable, or the Required Action and associated Completion Time of Condition A not met, the initial action (Required Action B.1) is to suspend all operations involving positive reactivity additions immediately. This includes withdrawal of control or shutdown rods and intentional boron dilution.
Required Action B.2 verifies the SDM according to SR 3.1.1.1 within ONI 1 hour and once per 12 hours thereafter. This action is intended to confirm that no unintended boron dilution has occurred while the BDK4S was inoperable, and that the required SDM has been maintained. The specified Completion Time takes into consideration sufficient time for the initial determination of SDM and other information available in the control room related to SDM.                                                      Jobe Required Action B.3.1 requires valves listed i to be secured to prevent the flow of unborated water into the RCS Once it is recognized that two trains of the BDMS are inoperable, the op~ators will be aware of the possibility of a boron dilution, and the 4 hour completion Time is adequate to complete the requirements of LCO 3.9.2 The recurring 31 day verification of Required Action B.3.2 ensures these valves remain closed for an extended Condition B entry.                     .
A.                                                                                               i\
CALLAWAY PLANT                               34                                        Revision 5

TSB CN 02-016 INSERT lb Bases 3.3.9 A dilution event is precluded by locked valves for unborated reactor makeup water (BGV0178 and BGV0601), CVCS resin vessels configured with resin for dilution during normal operation (BG8522A, BG8522B, BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor (SJ'VO703) that isolate the RCS from potential sources of unborated water.

BDMS B 3.3.9
(     B~1ASES                                            \
1CTIO               B.I. B.2. 3.3.1. and B.3.2 (c Required Action B.1 is modified by a Note whi permits plant temperature changes provided the temperature hange is accounted for in the calculated SDM. Introduction of temperatur            es, including
             /   ALrtemperature increases when a positive MTC exists, must bevaluated to ensure they do not result in a loss of required SDM.
Condition C is entered with no RCS loop in operation. The operciti of one RCS loop provides adequate flow to ensure mixing, prevent I stratification, and produce gradual reactivity changes during RCS bor n concentration reductions. The reactivity change rate associated with boron reduction will, therefore, be within the transient mitigation capab of the Boron Dilution Mitigation System (BDMS). With no reactor coolan loopin operationdilution sources must be isolated. The boron dilution analysis takes credit for the mixing volume associated with having at le t one reactor coolant loop in operation.                    ID       iOL r 1     'A              equired Action C. requiresth        t hat al              es       be OA*   'LCK  B 8closed and    secured to prevent the flow of unborated water into the RCS.
The 4 hour Completion Time is adequate to perform these local valve 6t. manipulations. The recurring 31 day verification of Required Action C.2 L4AA1  0Kensures             these valves remain closed and secured for an extended Condition C entry.                                       3                     )
SURVEILLANCE        The BDMS trains are subject to a CHANNEL CHECK, valve closure in REQUIREMENTS        MODE 5, COT, CHANNEL CALIBRATION, and Response Time Testing.
In addition, the requirement to verify one RCS loop in operation is subj t to periodic surveillance.
SR 3.3.9.1 Performance of the CHANNEL CHECK once every 12                   ensures that gross failure of source range instrumentation has not curred.
CHANNEL CHECK is normally                        the parameter indicated on             to a similar         eter on other channels. It is based on the assumption t                  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 ji   -                                                                                     (continued)
CALLAWAY PLANT                             B 3.3.9-5                                    Revision-5

TSB CN 02-016 INSERT lb Bases 3.3.9 A dilution event is precluded by locked valves for unborated reactor makeup water (BC;VO178 and BGV0601), CVCS resin vessels configured with resin for dilution during normal operation (BG8522A, BG8522B, BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor (SJYV0703) that isolate the RCS from potential sources of unborated water.

TSB CN 02-016 INSERT2 Bases 3.3.9 Required Actions B.3.1 and B.3.2 are modified by a Note allowing an isolation exception for some CVCS resin vessels that may contain resin that is not preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration. These vessels may be unisolated intermittently under administrative controls. The administrative controls are identified in TS Bases 3.9.2.
Administrative controls include both plant procedural requirements and operational awareness. Plant procedures ensure shutdown margin is maintained by requiring CVCS resin vessel pre-service flushing with borated water for primary system resins until equilibrium is reached with the RCS boron concentration or the refueling concentration as required. The effluent is monitored for boron and its impact on plant reactivity management determined. Therefore CVCS resin vessel operation is permitted by the Note under these conditions until the CVCS resin vessel is borated and no longer a dilution source. Chemistry controls may also require some CVCS resin vessels to be configured with resin not intended for boron dilution or configured with resin that is preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration. However, these vessels are not boron dilution sources and their isolation is not required per the Required Actions of Condition B.
INSERT3 Bases 3.3.9 Required Actions C.1 and C.2 are modified by a Note allowing an isolation exception for some CVCS resin vessels that may contain resin that is not preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration. These vessels may be unisolated intermittently under administrative controls. The administrative controls are identified in TS Bases 3.9.2. Administrative controls include both plant procedural requirements and operational awareness. Plant procedures ensure shutdown margin is maintained by requiring CVCS resin vessel pre-service flushing with borated water for primary system resins until equilibrium is reached with the RCS boron concentration or the refueling concentration as required. The effluent is monitored for boron and its impact on plant reactivity management determined.
Therefore CVCS resin vessel operation is permitted by the Note under these conditions until the CVCS resin vessel is borated and no longer a dilution source. Chemistry controls may also require some CVCS resin vessels to be configured with resin not intended for boron dilution or configured with resin that is preconditioned with borated water with a boron concentration equal to or greater than the reactor coolant system boron concentration. However, these vessels are not boron dilution sources and their isolation is not required per the Required Actions of Condition C.

BDMS B 3.3.9 BASES SURVEILLANCE   SR 3.3.9.1 (continued)
REQUIREMENTS verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the crite          ay be an indication that the sensor or the signal processin         ment has rifted o ide its limit.
The Frequency i           on operating experience that demonstrates channel failu is rare. The CHANNEL CHECK supplements less lormal, but more f uent, checks of channels during normal operational use of the disys associated with the LCO required channels SR 3.3.9.2 require a valve BGV017 be secured and closed prior to entry into MODE 5.                 .9. equires that this valve also be secured and closed in MODE 6. Closing BGV0178 satisfies the bcron dilution accident analysis assumption that flow orifice BGFOO010 limits the dilution flow rate to no more than 150 gpm in MODE 5. This Surveillance demonstrates that the valve is closed through a system walkdown. SR 3.3.9.2 is modified by a Note stating that it is only required to be performed in MODE 5. This Note requires that the surveillance be performed prior to entry into MODE 5 and every 31 days while in MODE 5. The 31 day frequency is based on engineering judgment and is onsidered reasonable in view of other administrative controls that will etthat the valve opening is an unlikely possibility.
R 3                                       sCA
               'SR 3.3.9.3 requ          erformance of a COT every 184 days, to e ure            I that each train of the B Sand associated trip setpoints are fully operational. A successful test of the required contact(s) of a ch naI relay may be petformed by the Orcation of the change of state a single contact of the relay. This clarifies at is an acc-HANNEL OPERATIONAL TEST of a relay. Thic                  able because all of the otherrequired contacts of the relay are verified by otherTechnical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This test shall include verification that the boron dilution flux multiplication setpoint is equal to or less than an increase of 1.7 times the count rate within a 10 minute (continued)
CALLAWAY PLANT                          B 3.3.9-6                                   Revision 5b

ft,; LOOpS - MUUM   j B 3.4.5 BASES APPLICABLE     changes during RCS born concentration ret ions. The reactivit SAFETY         change rate associated ith boron reduction ill, therefore, be withi the ANALYSES       transient mitigation cap ility of the Boron D ution Mitigation System (continued)   (BDMS). With no reacto coolant loop in o ration in either MOI)ES , 4, or 5, boron dilutions mu be terminated an dilution sources isolate The boron dilution analusis in these MODES takes credit for the mixi g volume associated with aving at least one reactor coolant loop in operation. LCO 3.3.9,         on Dilution Mitigation System (BDMS),"
contains the requirements        the BDMS.        t5"W 02,ol(D Failure to provide decay he        moval may result in challenge t6a fission product barrier. The R loops are part of the primary uccess path that functions or actuates to revent or mitigate a De        Basis Accident or transient that either a      dur the failure or presents a challenge to, the integrity of a fission pr ur.
RCS Loops - MODE 3 satisfy Criterion 3 of IOCFR50.36(c)(2)(ii).
LCO            The purpose of this LCO is to require that at least two RCS loops be OPERABLE. In MODE 3 with the Rod Control System capable of rod withdrawal, two RCS loops must be in operation. Two RCS loops are required to be in operation in MODE 3 with the Rod Control Syslem capable of rod withdrawal due to the postulation of a power excursion because of an inadvertent control rod withdrawal. The required number of RCS loops in operation ensures that the Safety Limit criteria will be met for all of the postulated accidents.
When the Rod Control System is not capable of rod withdrawal, only one RCS loop in operation is necessary to ensure removal of decay heat from the core and homogenous boron concentration throughout the RCS. An additional RCS loop is required to be OPERABLE to ensure that redundancy for heat removal is maintained.
The Note permits all RCPs to be removed from operation for
* 1 hour per 8 hour period. The purpose of the Note is to perform tests that are required to be performed without flow or pump noise. One of these tests is validation of the pump coastdown curve used as input to a number of accident analyses including a loss of flow accident. This test is generally performed in MODE 3 during the initial startup testing program, and as such should only be performed once. If, however, changes are made to the RCS that would cause a change to the flow characteristics cf the RCS, the input values of the coastdown curve must be revatidated by conducting the test again.
(continued)
CALLAWAY PLANT                         B 3.4.5-2                                  Revision 0

RCS Loops - IMODE 3 B 3.4.5 BASES LCO                izaion of the Note is permitte rovided the following conditions are (con  d)      met, along with any other conditions* posed by test procedures:
: a.      No operations are permitted tha would dilute the RCS borDn concentration with coolant at bo on concentrations less than required to assure the SDM of L         3.1.1, thereby maintaining the margin to criticality. Introduction f reactor makeup water into the CS from the Chemical and Volu          Control System mixing tee is SR1 t          not permitte hen no RCS loop is i operation. Boron dilution with coolant at boron concentrations les than required to assure the SDM is maintained is prohibited be use a uniform concentration distribution throughout thRCS cannot be ensured when in natural circulation; and
: b.      Core outlet temperature is maintai d at least 10F below saturation temperature, so that n vapor bubble may form and possibly cause a natural circula on Dow obstruction.
An OPERABLE RCS loop consists of e OPERABLE RCP and one OPERABLE SG, which has the minim m water level specified in SR 3.4.5.2. An RCP is OPERABLE ilit is capable of being powered and is able to provide forced flow if req ed.
APPLIC         In MODE 3 this LCO e            s forced circulation of the reactor coolant to remov ecay             rom the core and to provide proper boron mixing.
most stringent condition of the LCO, that is, two RCS loops OPERABLE and two RCS loops in operation, applies to MODE 3 with the Rod Control System capable of rod withdrawal. The least stringent condition, that is, two RCS loops OPERABLE and one RCS loop ill operation, applies to MODE 3 with the Rod Control System not capable of rod withdrawal.
Operation in other MODES is covered by:
LCO 3.4.4, "RCS Loops - MODES 1 and 2";
LCO 3.4.6, "RCS Loops - MODE 4";
LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled";
LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled";
LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).
(continued)
CALLAWAY PLANT                         8 3.4.5-3                                   Revision 5e

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

RCS Loops - MODE 3 B 3.4.5 BASES ACTIONS        D.1. D.2, and D.3 (continued) sets). All operations involving introduction of coolant, into the RC:S, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended, and action to restore one of the RCS loops to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mi       an deating Control System removes the possibilitof an inadvertent rod withdr al.
Suspending the introduction of cool t, into the RCS, with boron concentration less than required meet the minimum SDM of LCO 3.1.
is required to assure continued afe operation. With coolant added without forced circulation, unm ed coolant could be introduced to the core, however coolant added ith boron concentration meeting the minimum SDM maintains ac ptable margin to subcritical operations.
Introduction of reactor ma up water into the RCS from the Chemical and Volume Control System ixing tee is not permitte when no RC.S loop is in operation, consisten with Required Action C.1 LCO 3.3.9, 'Boron Dilution Mitigation Sy em (BDMS)." The immedia e Completion Time reflects the importan of maintaining operation fo heat removal. The action to restore mus be continued until one loop irestored to OPERABLE status a operation.
SURVEILLANCE   S R 3.4.5.1                      bv     0-l REQUIREMENTS\
This SR requires verific ion every 12 hours that the required loops are in operation. Verificatio may include flow rate, temperature, or pump status monitoring, which he ensure that forced flow is providing heat removal.
The Frequency of 12 ours is sufficient considering other indications and alarms available to th operator in the control room to monitor RCS loop performance.
SR 3.4.5.2 SR 3.4.5.2 requires verification of SG PERABILITY. SG OPERABILI is verified by ensuring that the seconds side narrow range waler le I is 2 7% for required RCS loops. If the S econdary side narrow r ge water level is < 7%, the tubes may becomeu             ed and the      ociated  I loop may not be capable of providing the heat sink forMval of the decay heat. The 12 hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to a loss of SG level.
(continued)
CALLAWAY PLANT                        B 3.4.5-5                                   Revision 5e

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

RCS Loops - MODE 4 B 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.6 RCS Loops - MODE 4 BASES                                                                                             -
BACKGROUND          In MODE 4, the primary function of the reactor coolant is the removal of decay heat and the transfer of this heat to either the steam generator (SG) secondary side coolant or the component cooling water via the residual heat removal (RHR) heat exchangers. The secondary furction of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.
The reactor coolant is circulated through four RCS loops connected in parallel to the reactor vessel, each loop containing an SG, a reactor coolant pump (RCP), and appropriate flow, pressure, level, and temperature instrumentation for control, protection, and indication. The RCPs circulate the coolant through the reactor vessel and SGs at a sufficient rate to ensure proper heat transfer and to prevent boric acid stratification.
In MODE 4, either RCPs or RHR loops can be used to provide forced circulation. The intent of this LCO is to provide forced flow from at least one RCP or one RHR loop for decay heat removal and transport. The flow provided by one RCP loop or RHR loop is adequate for decay heat removal. The other intent of this LCO is to require that two paths tie available to provide redundancy for decay heat removal.
APPLICABLE          In MODE 4, RCS circulation is considered in the determination of SAFETY              the time available for mitigation of the accidental boron dilution evEnt.
ANALYSES The operation of one RCP in MODES 3, 4, and 5 provides adequate flow to ensure mixing, prevent stratification, and produ              eactivity changes during RCS boron concentration                ions. The rea ivily change rate associated with boron re         ion will, therefore, be whin the transient mitigation capability of theoron Dilution Mitigation Syste (BDMS). With no reactor coolan oop in operation in either MODES ,4, or 5, boron dilutions must be terminated and ilution sources isolated.
                   'The boron dilution analysis in t ese MODES akes credit for the mixing volume associated with having at least one r actor coolant loop in operation. LCO 3.3.9, 'Boro       ilution Mitiga on System (BDMS),"
contains the requirements fqf the BDMS.
RCS Loops - MODE 4 satis es Criterion 4 of OCFR50.36(c)(2)(ii).
CALLAWAY PLANT                             B 3.4.6-1

RCS Loops - MODE 4 B 3.4.6 BASES (continued)
LCO               The purpose of this LCO is to require that at least two loops be OPERABLE in MODE 4 and that one of these loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS loops and RHR loops. Any one loop in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide redundancy for heat removal.
Note I permits all RCPs or RHR pumps to be removed from operation for S 1 hour per 8 hour period. The purpose of the Note is to permit tests that are required to be performed without flow or pump noise. The 1 hour time period is adequate to perform the necessary testing, and operating experience has         o           ron stratification is not a problem during this s     it            no forced flo             w Utilization of Note 1 is permitted provided the foling conditions are met along with any other conditions imposed by test pro dures:
: a.       No operations are permitted that would dilute the           S boron concentration with coolant at boron concentrations I s than required to assure the SDM of LCO 3.1.1, thereby ma taining the margin to criticality. Introduction of reactor makeup wa r into the
( s~
       .ERCS  A                  from the Chemical and Volume Control System mi ing tee is :
Vnot permittewhen no RCS loop is in operation. Boron dilution with coolant at boron concentrations less than required assure the SDM is maintained is prohibited because a uniform
     -r6,cta o2 ODb'       concentration when in naturaldistribution throughout the RCS cannot be nsured circulation; and
: b.       Core outlet temperature is maintained at least 100F b low saturation temperature, so that no vapor bubble may rm and possibly cause a natural circulation flow obstruction Note 2 requires that the secondary side water tempera re of each SG be
                  ' 500F above each of the RCS cold leg temperature efore the start of an RCP with any RCS cold leg temperature O F. This restraint is to prevent a low temperature overpressu nt due to a thermal transient RCS loop is comprised of an OPERABLE RCP ani an OPERABLE SG, which has the minimum water level specified in SR 3.4.6.2.
(continued)
CALLAWAY PLANT                            B 3.4.6-2                                      Revision 5e

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

RCS Loops - MODE 4 B 3.4.6 BASES ACTIONS        B.1 and B.2 (continued)
If no loop is OPERABLE or in operation, except during conditions permitted by Note I in the LCO section, all operations involving introduction of coolant, into the RCS, with boron concentration less; than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RCS or RHR loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation from at least one RCP for proper mixing so that inadvertent criticality can be prevented. Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant could be introduced to the core, however coolant added with boron concentratiieeini               e minimum SDM maintains acceptable              nr         itical operatins Introduction of reactor makeup water i io the RCS from the Chemical an Volume Control System mixing te          lot permitte hen no RCS loop is in operation, consistent with R uired Action C.1 c CO 3.3.9, "Boron, Dilution Mitigation System (B MS)." The immedia Completion Times reflect the importance of ma' taining operation for ecay heat removal.
The action to restore must e continued until one I p is restored to OPERABLE status and opeation.
SURVEILLANCE   SR 3.4.6.1                       ssrA6   0941(v         5      ~s     2T REQUIREMENTS\
This SR requires verifi tion every 12 hours that one RCS or RHR loop is in operation. Verificatio may include flow rate, temperature, or pump status monitoring, which        ensure that forced flow is providing heat removal. The Frequency o 12 hours is sufficient considering other indications and alarms avail le to the operator in the control room to monitor RCS and RHR loop p              nce.
SR 3.4.6.2 SR 3.4.6.2 requires verification of SG             ILITY. SG OPE BILITY is verified by ensuring that the secondary side na                 ater level is
               > 7% for required RCS loops. If the SG secondary side narrow range water level is < 7%, the tubes may become uncovered and the associated loop may not be capable of providing the heat sink necessary for removal of decay heat. The 12 hour Frequency is considered adequate in view of other indications available in the control room to alert the operator to the loss of SG level.
(continued)
CALLAWAY PLANT                        B 3.4.64                                    Revision 5e

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

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES (continued)
APPLICABLE              In MODE 5, RCS circulation is considered in the determination of the time SAFETY                  available for mitigation of the accidental boron dilution event.
ANALYSES The operation of one RCP in MODES 3, 4, and 5 provides adequate flow to ensure mixing, prevent stratification, and produce radual reactivity changes during RCS boron concentration redtns. Theyctivi ty change rate associated with boron reducti will, therefore, b           in the transient mitigation capability of the Bor Dilution Mitigation System (BDMS). With no reactor coolant lo in operation in either MODES 3, or 5, boron dilutions must be ter rated anddilution sources isolated.
The boron dilution analysis in th se MODES akes credit for the mixing volume associated with having t least one r actor coolant loop in operation. LCO 3.3.9, "Boron lution Mitiga n System (BDMS),"
contains the requirements forth BDMS.            \                      OS- 1o.
RCS Loops - MODE 5 (Loops Filld) satisfies riterion 4 of 10CFR50.36(c)(2)(ii).              (O LCO                     The purpose of this LCO is to re ire that at least one of the RHR loops be OPERABLE and in operation            an additional RHR loop OPERABLE or two SGs with secondary side wid range water level > 86%. As shown in Reference 3, any narrow range le el indication above 7% will ensure the SG tubes are covered. One RHR oop provides sufficient forcei circulation to perform the safety functio          e reactor coolant under these conditions. An additional RHR loop i required to be OPER/BL o meet single failure considerations. Howevr, if the standby RHR lo is not OPERABLE, an acceptable alternate rnvo                   SGs with t ir secondary side wide -range water levels 2 86%. Shd th                ing RHR loop fail, the SGs could be used to remove the decay heat via natural circulation, Note I permits all RHR pumps to be removed from operation < 1 hour per 8 hour period. The purpose of the Note is to permit tests that are required to be performed without flow or pump noise. The 1 hour time pericd is adequate to perform the necessary testing, and operating experience has shown that boron stratification is not likely during this short period with no forced flow.
Utilization of Note I is permitted provided the following conditions are met, along with any other conditions imposed by test procedures:
(continued)
CALLAWAY PLANT                                  B 3.4.7-2                                  Revision 5e I. ..

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES LCO               a.       No operations are permithat would dilute the RCS boron (co    ed)                concentration with coolant at bn concentrations less than required to assure the SDM of LC 3.1.1, thereby maintaining the margin to criticality. Introduction of eactor makeup water into the RCS from the Chemical and Volume           ntrol System mixing tee is
:IMSELr  A                 hopermitteathen no ROS loop is in o ration. Boron dilution with coolant at boron concentrations less than required to assure 02.1A          the SDM is maintained is prohibited bec use a uniform concentration distribution throughout th RCS cannot be ensured when in natural circulation; and
: b.       Core outlet temperature is maintained a east 100F below saturation temperature, so that no vap bubble may form and possibly cause a natural circulation w obstruction.
Note 2 allows one RHloop to be inorable for a period of up to the             loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible.
Note 3 requires that the secondary side water temperature of each SG be j c 500F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) with any RCS cold leg temperature
* 275 0F.
This restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.
Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of RHR loops from operation when at least one RCS loop is in operation. This Note provides for the transition to MODE 4 where an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.
RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. A SG can perform as a heat sink via natural circulation when it has an adequate water level and is OPERABLE.
APPLICABILITY     In MODE 5 with RCS loops filled, this LCO requires forced circulation of the reactor coolant to remove decay heat from the core and to pro vide proper boron mixing. One loop of RHR provides sufficient circulation for these purposes. However, one additional RHR loop is required to be OPERABLE, or the secondary side wide range water level of at least two SGs is required to be 2 86%.                                                     I  .1 (continued) .- 1 11 CALLAWAY PLANT                             B 3.4.7-3                                Revision Se

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

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES APPLICABILITY  Operation in other MODES is covered by:
(continued)
LCO 3.4.4, "RCS Loops - MODES 1 and 2";
LCO 3.4.5, "RCS Loops - MODE 3";
LCO 3.4.6, "RCS Loops - MODE 4";
LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled";
LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).
ACTIONS        A.1 and A.2 If one RHR loop is inoperable and the required SGs have secondary side wide range water levels < 86%, redundancy for heat removal is lost.
Action must be initiated immediately to restore a second RHR loop, to OPERABLE status or to restore the required SG secondary side water levels. Either Required Action A.1 or Required Action A.2 will restore redundant heat removal paths. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.
B.1 and B.2 If no RHR loop is in operation, except during conditions permitted by Notes I and 4, or if no loop is OPERABLE, all operations involving introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCO 3.1.1 must be suspended and action to restore one RHR loop to OPERABLE status and operation must be initiated. To prevent inadvertent criticality during a boron dilution, forced circulation from at least one RCP is required to provide proper mixing. Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDM of LCCI 3.1.1 is required to assure continued safe operation. With coolant added without forced circulation, unmixed coolant co l           oduced to the core, however coolant added with boron c nentration m6Ll              ed minimum SDM maintains acceptable mf in to subcritical operations.
Introduction of reactor makeup water ino the RCS from the Chemical ad Volume Control System mixing fee is n permitte hen no RCS loop is in operation, consistent with Require ction C.1 LCO 3.3.9, "Boron Dilution Mitigation System (BDMS). The immedie Completion Times reflect the importance of maintain fgoperation for neat removal.
                                                                   \j T           (continued)
CALLAWAY PLANT                        B 3.4.74                                   Revision Se

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

B 3.4.8 B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.8 RCS Loops - MODE 5, Loops Not Filled EASES BACKGROUND           In MODE 5 with the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat generated in the fuel, and the transfer of this heat to the component cooling water via the residual heat removal (RHR) heat exchangers. The steam generators (SGs) are not available as a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid.
In MODE 5 with loops not filled, only RHR pumps can be used for coolant circulation. The number of pumps in operation can vary to suit the operational needs. The intent of this LCO is to provide forced flow from at least one RHR pump for decay heat removal and transport and to require that two paths be available to provide redundancy for heat removal.
APIPLICABLE          In MODE 5, RCS circulation is considered in the determination of the time SAFETY              available for mitigation of the accidental boron dilution event. The flow ANALYSES            provided by one RHR loop is adequate for decay heat removal.
The operation of one RCP in MODES 3,4, and 5 provides adequate flow to ensure mixing, prevent stratification, and produce gradual reactivity changes during RCS boron concentration reducti           . e ctivif change rate associated with boron red            s therefore be             the transient mitigation capability of the oron Dilution Mitigation System (BDMS). With no reactor coolant p in operation in either MODE 3 43, or 5, boron dilutions must be te nated andgdilution sources isolated.
The boron dilution analysis in th e MODES akes credit for the mixing volume associated with having at east one r actor coolant loop in operation. LCO 3.3.9, "Boron Di *on Mitigatin System (BDMS),"
contains the requirements for t e BDMS.
RCS loops in MODE 5 (loops ot filled) satisfie Criterion 4 of 10CFR50.36(c)(2)(ii).                                             -rSBG6 CI  X016 The purpose of this LCO is to requi that at least two RHR loops be OPERABLE and one of these loo be in operation. An OPERABLE loop is one that has the capability of tran erring heat from the reactor coolant at a controlled rate. Heat cannot be             via the RHR System unles forced flow is used. A minimum of one wn g RHR pump me t (continued)
CALLAWAY PLANT                             B 3.4.8-1                                      Revision 0
* _  w  --       -    rc B 3.4.8 BASES LC O           LCO requirement for one loop in operation. An additional RHR loop is (continued)   required to be OPERABLE to meet single failure considerations.
Note 1 permits all RHR pumps to be removed from operation for < 1 hour.
The circumstances for stopping both RHR pum                     limited to situations when the outage time is short          re outlet te erature is maintained at least 100F b!e           tu on temperature. The ote prohibits boron diluti        h coolan at boron concentrations less required to assur e SDM of LCO 3.1.1 is maintained or draining operations whe RHR forced flow is stopped. Introduction of reactor makeup water nto the RCS from the Chemical and Volume Control System mixintee is not permittedowhen                  Operation.
                                       '"CN     02-011I4s            ERT AD Note 2 allow ne RHR loop to be inoperb orajperiodof 2 hours,
* provided tha the other loop is OPERABLE and in operation. This penmis periodic su eillance tests to. be performed on the inoperable loop durin the only tim when these tests are safe and possible.
An OPERABLE               loop is comprised of an OPERABLE RHR pum capable of providin forced flow to an OPERABLE RHR heat ex                 ager.
RHR pumps are OP             BLE if they are capable of be'i         ed and are able to provide flow          u APPLICABILITY  In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.
Operation in other-MODES is covered by:
LCO   3.4.4, "RCS Loops - MODES I and 2";
LCO   3.4.5, "RCS Loops - MODE 3";
LCO   3.4.6, "RCS Loops - MODE 4";
LCO   3.4.7, "RCS Loops - MODE 5, Loops Filled";
LCO   3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Lever (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).
Since LCO 3.4.8 contains Required Actions with immediate Completion Times, it is not permitted to enter LCO 3.4.8 from either LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled" or from MODE 6 unless the requirements of LCO 3.4.8 are met.
(continued)  (c) s, CALLAWAY PLANT                          B 3.4.8-2                                 Revision 5a

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

B 3.4.8 EASES (continued)
ACTIONS              A.1 If only one RHR loop is OPERABLE and in operation, redundancy for
                     -RHR is lost. Acion must be initiated to restore a second loop to
                    -.OPERABLE status. The immediate Completion Time reflects the
                    - importance of maintaining the availability of two paths for heat rernoval.
B.1and B.2 If no required RHR loops are OPERABLE or in operation, except during
              "     ' coitions permitted by Note 1,-all operations' involving intridi tkti of coolant, into the RCS, with boron concentration less than requirei to meet the minimum SDM of LCO 3.11 must be suspended and action must be initiated immediately to restore an RHR loop to OPERABLE status and operation. Boron dilution requires forced circulation from at least one RCP for proper mixing so that inadvertent criticality can be prevented. Suspending the introduction of coolant, into the RCS, with boron concentration less than required to meet the minimum SDMA of LCO
:     '3.1.1       is required to assure continued safe operatlo       ith coolant added with6ut forced circulation, unmixed coolant old be intro             tcr the core, however coolant added with boro, ncentration meeting t ie minimum SDM maintains acceptable argin tosubcritical operations.
Introduction of rea6tor makeup w        nto the RCS from the Chemical and Volume Control System mixi tee is not permitte en the RCS loops are not filed or when no Sloop is in operation, nsistent with Required Action C.1 of 03.3.9, "Boron Dilution itigation System (BDMS).* The immedi e Completion Time reflect the importance of maintaining operation r heat removal. The action to restore must continue until one loop restored to OPERABLE s tus and operation.
. SURVEILLANCE        SR 3.4.8.1                           T36C?     D20:3 RIEQUIREMENTS      '
This SR requires verifica on every 12 hours that one loop is in oparation.
Verification may include 1 w rate, temperature, or pump status monitoring, which help ensu           forced flow is providing heat removal.
The Frequency of 12 hours i ufficient considering other indications and alarms available to the oper or in the control room to monitor RHR loop performance.
VR             that a      n Verification that a second RHR pump is OPERABLE ensures that an additional pump can be placed in operation, if needed, to maintain decay (continued)
CALLAWAY PLANT                              B 3.4.8-3                                   Revision 3

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

B 3.9 REFUELING OPERATIONS B 3.9.2 Unborated Water            S      o        tm BASES                 /
BACKGROUN               During MQDE        opepon B sesl
            .. /                   _     _      _are                          connected to theeactor 2 C~           m     (tSJmustbe dosed to prevent            pa       boron.
dilui6n otlt reactor cWO         t The Isolationval      vess;Re
                  /must                        be secured i te dosed pofto
                            /,Addls~b~j6 o             will JmA Ue vrne of unborated water that can be added to th refuekn pool for decominton activities in order to (e.                    g                  p       r        n       di     fi daRG1 APPLICABLE              The possibfiiy of an Inadvertent boron dilution event (Ref. 1) occuring.
SAFETY                   during MODE 6 refuelig operations Is precluded by adherence to this ANALYSES                 LCO, .W h e             that poteta dilutfon sources be        ated. Clig the ies                   ireeig                  s prevents the flow oE unborated water to the iled poition of the RCS. The valves are umed to
*.I                          isolateo.urbQiated water souce These valves have the potential to i       K      diution of the RCoron concentration in MODE C.. By
             ,44oait0at                                 er sources,       afaysis for an uncorld.
boron OtM aciderd ii accorda                 th S         rd Review P3n (Ref. 2) is not red        for MODE 6.                       cReveP The RCS boron concentration satisfies C             ro
                           . 10 CFR 50.36(c)(2)(i).                                            I*Z(t     a
                                                 ;      flw paths via b      be Isolated to prevent uplanned bo       >v
                                                 )DE and thus oid a mckidion hi SDM. 4
     ,CppuJCABILflY           In MODE 6,this LCO Is applicable to                  iadvertent Ieventan boron diution event by ensuring Isolation of all souris of unborated water to.
the RCS.
For al. otlr MODES,. the boron dilikon accientd                      andlwasnd fo'md to be capable of beng mktigated.
CALUAWAY PLANT                                  B 3.9.2-                                    RevS!on 0

TSB CN 02-016 INSERT 1 Examples of isolation valves connected to the RCS include: (1) unborated reactor makeup water (BGVO 178 and BGV0601), (2) CVCS resin vessels configured with resin.
for dilution during normal operation (BG8522A, BG8522B, BGV0039, BGV0043, BGV005 1, and BGV0055) and (3) unborated flushing water for the CVCS letdown radiation monitor (SJV0703). These isolation valves must be secured in the closed position.
Some dilution sources, that are not connected to RCS in their as-built configuration, can be temporarily configured (ex. flexible hose connected) to provide a direct path for unborated water into the RCS. A routine Mode 6 activity requiring this temporary configuration is decontamination of the refueling pool. Examples of isolation valves not connected to the RCS, but can be modified include: (1) BLVO078, (2) BLVO079 and (3)
BLVO055.
INSERT 2 d.ution source flow paths connected to the RCS INSERT 2A This LCO is modified by NOTE I to allow dilution sources, not connected to the RCS, t:o be used under administrative controls when temporary configurations are implemented.

TSB CN 02-016 INSERT IA Boron dilution may also be accomplished by removing boron from the Chemical and Volume Control system (CVCS) stream prior to RCS return using the ion exchange capability of the CVCS resin vessels. The CVCS resin vessels may be configured with iesin designed for controlling RCS chemistry during normal operations and shutdown periods. The CVCS resin vessels include the resin vessels of its subsystem, the Boron Thermal Regeneration system (BTRS). During refueling operations, BTRS vessel operation may be required for RCS impurity removal to improve water clarity and to reduce refueling cavity dose rates for the fuel handlers. These situations require the BTRS resin vessels to be unisolated intermittently as required for system operation and use, and as allowed by LCO 3.9.2 for Mode 6. Plant procedures ensure shutdown margin is maintained by requiring pre-service flushing with borated water for primary system resins. This operation in Mode 6 is permitted under these conditions because the BTRS resin is borated and no longer a dilution source.
Chemistry controls may require some CVCS resin vessels to be configured with resin not intended for boron dilution or configured with resin that is preconditioned with borated water with a boron concentration equal to or greater than the refueling boron concentration. Because these vessels are not boron dilution sources, their isolation is not required. Some CVCS vessels may contain resin that is not preconditioned with borated water with a boron concentration equal to or greater than the refueling boron concentration. These vessels may be unisolated intermittently under administrative controls.
The effect of purging the CVCS letdown gamma radiation detector SJREOO 1, by flushing the detector with unborated reactor makeup water, raises concern for a potential dilution path to the CVCS volume control tank (VCT) and the reactor coolant system. Based on plant experience, the detector SJREOO1 often becomes fouled with boric acid, causing it to become plugged and resulting in an intolerable increase in the detector's background g;.nma radiation. A plant modification was implemented to use existing piping to flush the detector with unborated reactor makeup water.
Although flushing the detector with unborated reactor makeup water is effective, the activity creates a dilution source via the purge line discharge to the VCT. Nuclear sampling system valve SJV0703 isolates the reactor makeup water supply used to purge detector SJREOOI. Because flushing the detector is not a requirement in MODE 6, valve SJV0703 may be secured closed to prevent the potential dilution path.

TSB CN 02-016 INSERT 2B During refueling activities, it may be necessary for a dilution source to be unisolated.
Based on License Amendment 97, administrative controls are used to limit the volume of unborated water which can be added to the refueling pool for decontamination activities in order to prevent diluting the refueling pool boron concentration below TS limits. The administrative controls are identified in TS Bases 3.9.1.
The following valves are excluded from the TS 3.9.2 LCO NOTE 1: BGV0178, 13GV0601, BG8522A, BG8522B, BGV0039, BGV0043, BGV0051, BGV0055 and
&SJV0703. The following valves are included under the LCO NOTE 1: BLVO078, ILV0079 AND BLVO055.
This LCO is modified by NOTE 2 allowing an isolation exception for some CVCS resin vessels that may contain resin that is not preconditioned with borated water with a boron concentration equal to or greater than the refueling boron concentration. These vessels may be unisolated intermittently under administrative controls.
Administrative controls include both plant procedural requirements and operational awareness. Plant procedures ensure shutdown margin is maintained by requiring CVC.S resin vessel pre-service flushing with borated water for primary system resins until equilibrium is reached with the RCS boron concentration or the refueling concentration as required. The effluent is monitored for boron and its impact on plant reactivity management determined. Therefore CVCS resin vessel operation is permitted by Note 2 under these conditions until the CVCS resin vessel is borated and no longer a dilution source.
Chemistry controls may also require some CVCS resin vessels to be configured with resin not intended for boron dilution or configured with resin that is preconditioned with orated water with a boron concentration equal to or greater than the refueling boron concentration. However, these vessels are not boron dilution sources and their isolation is not required per this LCO.

BASES (continued).
ACTIONS              The ACTIONS table has been modified by a Note that allows separate Condition entry for each unborated water source isolation vatve.
AS.        .
Contination of CORE ALTERATIONS is contingent upon maintaining the unit Incompliance with this LCO. With any                       to isolate tbrted         Yt~e soob                              desrations           pcos nolfin COiRE ALTE               OHS must be suspended immediatet Complktion llne             medlateff for performance of Required /cti Al shal not             competon of movement of a component to a A ha been                byaNotetorequrethat Requirei\
Action A.3 be completed                ver Cond Isentered.
A2                                          <     3 Preventing Irdvtent dilution of the reactor oo~nt boron concentration is deairinonm a               ing the unborated wat      frsolation valves i        lIJseeured                    closed. Securing the valves in the
                      . 1l66d positn, ude~r administrative controls, ensures that the valves are n       d            oped. The Completion Time of "immediatel requires an o atoro h             actions to cose an open valve and secure Ihe isoiationnave hi th. closed position inmedately. Once actions aire initiated, they must be continued until the valves are secured in tRe closed
                  .                                                                                    /2
                /     A.3
                    . Due to the potenti of having diluted the boron concentration of e reactr ce           .nSR 3.9.1.1 (vefcation of boron concntration) m' be.
perforMWd fieV Condiion A Is entered to demonsrate f requred boron c           r         exists. The Completion Time          hcis Is
             .*       suffiient to obtain and analyze a reactor coolant sam                 boron C         AcAcentrato n0
                               *                   \co/
CALAA    PUV                                    3..-2R/so
                                                         *1
                        -4

BASE -1ntnued) .
Cp45__T3
          /                                        I
      ' KtUUIKtMtNIb       _:
                                                                                                        +/- _+/-
are to be s      closedtoIso13te "dilution    ossijdifuhe                                 likelihood of a s         l %~ionIn te 3          conenrdatmionfing MODE 6                                     pIs remoe -uetothe laprge Jmass f botatd iate r In,                       r9n           pooPnd the fact that apiboratbedI watrs. .ces are             ibt             precw*ig.a dhffion. The boron                 -
   'I                     conce.,             checIsevry 72hoirs duing MODE 6 under
                - C       SR.3.1.1. -Th1 .Surv                  nce denfonbatest                the valves are closed th uroh a sy*tem wD IowTe 31 day Frequency Isbated on engineering.judgnert.aW is eonsrder-d reasonable inview of otler admnistrative controIs that w1 ensure that the valve opening Isain REFERENCE
: 2.        NUREG-OB0, Section 15.4.6.
: 3.        Amednit.97 to Facijt:y Oprating License No. NPF-30,
                                   .Caliaway-;Uni 1,dated March 31,1995.
                                ,,~~~~~~aa             -.... ;.    .;.-,
                                               ..      .          .:      .I   ;
                                 .    .. .                    I .
:. I CALLAWAY PLANT                     * -S ':   'B 3.92-3                                                 Revision O

TSB CN 02-016 INSERT 3 I3olation valves for unborated reactor makeup water (BGVO 178 and BGV060 1), CVCS r, sin vessels configured with resin for dilution during normal operation (BG8522A, EIG8522B, BGV0039, BGV0043, BGV0051, and BGV0055), and the purge line used during flushing of CVCS letdown radiation monitor (SJV0703)
INSERT3A Chemistry controls may require some CVCS resin vessels to be configured with resin not intended for boron dilution or configured with resin that is preconditioned with borated water with a boron concentration equal to or greater than the refueling boron concentration. Because these vessels are not boron dilution sources, their isolation is not required. Some CVCS resin vessels may contain resin that is not preconditioned with borated water with a boron concentration equal to or greater than the refueling boron concentration. These vessels may be unisolated intermittently under administrative controls per LCO Note 2.

ULNRC- 05269 ATTACHMENT 5

==SUMMARY==
OF REGULATORY COMMITMENTS

==SUMMARY==
OF REGULATORY COMMITMENTS The :ollowing table identifies those actions committed to by AmerenUE, Callaway Plant in this document. Any other statements in this tubmittal are provided for information purposes and are not considered to be comnutments. Please direct questions regarding thesc commitments to Dave E. Shafer, Superintendent, Licensing at AmerenUE, Callaway Plant, (314) 554-3104.
COMMITMENT                                                                                           Due Date/Event The proposed amendment will be implemented within 90 days                                             90 days following after approval                                                                                       NRC approval Administrative controls consisting of written procedures will be                                      90 days following established prior to the implementation of the proposed changes.                                     NRC approval The procedural controls require that in MODE 6 each valve used to isolate unborated water sources shall be secured in the closed pcsition.
Administrative controls consisting of written procedures will be                                     90 days following established prior to the implementation of the proposed changes.                                     NRC approval The procedural controls require that when both BDMS trains are inoperable, or when no reactor coolant loop is in operation, and when in MODE 2 (below P-6 setpoint), 3, 4, and 5, each valve used to isolate unborated water sources shall be secured in the closed position.
Identified TS Bases and Callaway FSAR changes will be During incorporated into the TS Bases and the Callaway FSAR during implementation of implementation of the amendment.                                                                     the amendment}}