View source for ULNRC-03979, Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6,3.7,3.8,3.9 & 5.0.Suppl to Ltr Dtd 970515,will Be Provided at Later Date

{{Adams
| number = ML20207L101
| issue date = 03/09/1999
| title = Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6,3.7,3.8,3.9 & 5.0.Suppl to Ltr Dtd 970515,will Be Provided at Later Date
| author name = Passwater A
| author affiliation = UNION ELECTRIC CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000483
| license number = 
| contact person = 
| document report number = TAC-M98803, ULNRC-03979, ULNRC-3979, NUDOCS 9903170379
| package number = ML20207L104
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 20
| project = TAC:M98803
| stage = Other
}}

=Text=
{{#Wiki_filter:.--    _ _ _ _ _ _ . _ _    _ - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _                       _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
Union EI:ctric one Ameten VIaza March 9,1999                                                                                 INO$$I[                            l St. Louis, MO 63166-6149 31 n t1 1222 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, D. C. 20555-0001 ULNRC-03979 Gentlemen:                                                                                                                     ''
TAC NO. M98803 DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC COMPANY FOLLOW-UP ITEMS RELATED TO THE b                                                                                             PROPOSED CONVERSION TO TIIE IMPROVED TECHMCAL Tjfggfgg                                                                                       SPECIFICATIONS SECTIONS 3.3. 3.4. 3.6. 3.7. 3.8. 3.9. AND 5.0

==References:==
: 1. ULNRC-03578 dated May 15,1997
: 2. ULNRC-03877 dated August 4,1998
: 3. ULNRC-03927 dated November 25,1998
: 4. ULNRC-03900 dated September 24,1998
: 5. ULNRC-03853 dated June 26,1998
: 6. ULNRC-03905 dated October 21,1998
: 7. ULNRC-03937 dated December 11,1998
: 8. ULNRC-03908 dated October 21,1998
: 9. ULNRC-03926 dated November 23,1998
: 10. ULNRC-03946 dated December 22,1998
: 11. ULNRC-03957 dated February 5,1999 Union Electric Company requested an amendment to the Callaway Facility Operating License (NPF-30) by incorporating changes to the Technical Specifications (TS) as provided in Reference 1. The NRC staff requested additional information regarding Section 3.1, " Reactivity Control Systems,"
Section 3.2, "Powcr Distribution Limits," Section 3.5, " Emergency Core Cooling Systems," Section 3.9, " Refueling Operations," and 4.0, " Design Features," which was provided in Reference 2. The NRC staff requested additional information regarding Section 3.3, " Instrumentation," which was provided in Reference 3. The NRC staff requested additional information regarding Section 3.4, " Reactor Coolant System," and Section 5.0, " Administrative Controls," which was provided in Reference 4. The NRC naff requested additional information regarding Section 3.6," Containment Systems," which was provided in Reference 5. The NRC staff requested additional information regarding Section 3.7, " Plant Systems," which was provided in Reference 6. In addition, the NRC staffrequested additional                                                        I information regarding Section 3.8, " Electrical Power Systems," which was provided in Reference 7.                                                                                                         (
(
l The Attachments to this letter provide (1) additional information or supporting documentation not provided in the original RAI responses, (2) answers tGOGGa~ to follow-up questions, and (3) additional changes identified by the licensee for ITS Sections 3.3,3.4,3.6,3.7,3.8,3.9, and 5.0. Reference 8 provided the first follow-g031703799993o9                                                                          ~-
p                  ADOCK 050                                                             93

f .
U. S. Nuclear Regulatory CCmmission March 9,1999 Page 2 up letter, affecting ITS Sections 3.1, 3.2, 3.4,3.5, and 5.0. Reference 9 provided the
      - second follow-up letter, affecting ITS Sections 1.0,3.4,3.5,3.6,3.7, and 3.9.
l      Reference 10 provided the third follow-up letter, affecting ITS Sections 1.0,3.1, 3.2,3.3,3.4,3.7,3.9, and 5.0. Reference 11 provided the fourth follow-up letter, affecting ITS Sections 1.0, 3.2, 3.3, 3.4, 3.6, 3.7, 3.8, 3.9, and 5.0.
This letter and its Attachments are not a supplement to Reference 1 and have not been reviewed by the Onsite Review Committee or Nuclear Safety Review Board. A supplement to Reference I will be provided at a later date.
,              If you have any questions concerning this response, please contact us.
L L..d &
A Alan C. Passwater
                                                /       Manager, Corporate Nuclear Services GGY/pir                                                                                ;
i

I   .
i l
l l
STATE OF MISSOURI )                                                      1
                                       )   SS                                  I l     CITY OF ST. LOUIS )
David Shafer, of lawful age, being first duly sworn upon oath says that he is Supervising Engineer, Corporate Nuclear Services, Regulatory Operations for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By      As-Al             -
David Shafer '
Supervising Engineer, Regulatory Operations,       i Corporate Nuclear Services I
SUBSCRIB D a               sworn to before me this                   day of        /7 /4ft'                 , 1999.
fj.S..         ...
h    Y?M Y     "jY?
          !E aTlf**%
                !=cwe W
                                    \5
          \          rer#l l" 0
                   ,,,,,F M. .
PATRICIA L REYNOLDS NOTUi/ POUC-LTATE OF MISSOUfu u4. L 4 COUNTY MY COMMISWON EXPIRES DEC.22,2000 l

i cc:  'M. H. Fletcher Wfd Professional Nuclear Consulting, Inc.
19041 Raines Drive Derwood, MD 20855-2432 I'                 RegionalAdministratorWfA U.S. Nuclear Regulatory Commission Region IV                               :
l                  611 Ryan Plaza Drive Suite 400                             ,
Arlington, TX 76011-8064 Senior Resident Inspector W/d Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mel Gray (2) H/fA Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of. Natural Resources P.O. Box 176 Jefferson City, MO 65102 Denny Buschbaum W[A TU Electric P.O. Box 1002                             !
Glen Rose, TX 76043 PatNugentW!d Pacific Gas & Electric Regulatory Services P.O. Box 56 Avila Beach, CA.93424 l
l

                                                                                               .S The item numbers are formatted as follows: [ Source][lTS Section]-[nnn]
Source =         Q - NRC Question NR - NRC Follow-up Question CA- AmerenUE DC-PG&E WC - WCNOC CP - TU Electric TR - Traveler ITS        ltem Number                                      Applicability  Enclosed _
1.0       Q 1.1-1. TSTF-205                                  WC             NA 3.1       WC-3.1-001 (NEW)                                   WC             N-3.2       WC-3.2-002 (NEW)                                   WC             NA
        ~ 3.3       Q 3-LS-GEN, TSTF-135                              WC             NA 3.3        Q 2-02 (3.3)                                      CA, t ;       YLTS 3.3        Q 2-18                                            CA,WC         YES 3.3        Q 2-37                                            WC             NA           l 3.3        O 3-01                                            WC             NA 3.3        Q 7-13                                            CA, WC         YES          l 3.3        Q 3.3-04                                          CA             YES          !
3.3        Q 3.3-21                                          CA, WC         YES          l 3.3        O 2.3-30                                          WC              NA          l 3.3        Q 3.3-32                                          CA,WC          YES          j 3.3        Q 3.3-34                                          CA, DC, WC     YES     _
l 3.3        Q 3.3-55                                          CA,WC          YES          l 3.3        Q 3.3-80                                          CA, WC         YES          l 3.3        0 3.3-99                                          CA,WC          YES          I 3.3        Q 3.3-135                                         CA, WC         YES          I l        3.3        CA-3.3-024 (NEW)                                  CA             YES 3.3         CA-3.3-025 (NEW)                                 CA             YES 3.3       TR-3.3-007                                        DC              NA          !
i-        3.3       WC-3.3-020 (NEW)                                  WC              NA          ,
3.3       WC-3.3-021 (NEW)                                  WC              NA          l 3.3        WC-3.3-022 (NEW)                                 CA, DC, WC     YES 3.3        WC-3.3-023 (NEW)                                 WC              NA 3.3        WC-3.3-024 (NEW)                                 WC           i NA

I l
I 3.4 O 3.4.11-2, TSTF-288     CA, DC, WC YES  l 3.4 Q 3.4.11-3. TSTF-113     CA, WC     YES l
3.4 WC-3.4-011               WC         NA   l 3.6 O 3.6.1-6                CA,DC      YES :
3.6 O 3.6.3-1                WC          NA l 3.6 O 3.6.3-4                CA         YES i 3.6 O 3.6.3-10               CA         YES I 3.6 O 3.6.3-11               WC         NA  l 3.6 Q 3.6.3-17               CA         YES CA, WC
                                               )
3.6 Q 3.6.3-23                          YES  ,
3.6 Q 3.6.3-33               CA         YES  l l 3.6 Q 3.6.6-8                DC          NA 3.7 O 3.7.16-3               CA, WC     YES 3.7 Q 3.7.17.1-6             CA, WC     YES 3.7 CA-3.7-005               CA         YES 3.7 CA-3.7-010 (NEW)         CA         YES 3.7 CA-3.7-011 (NEW)         CA         YES 3.7 WC-3.7-009 (NEW)         WC          NA 3.7 WC-3.7-010 (NEW)         WC          NA 3.7 WC-3.7-011 (NEW)         WC          NA 3.8 Q 3.8.1-09 CW            CA         YES 3.8 Q 3.8.',-12 DC           DC          NA 3.8 Q 3.8.1-12 WC            WC          NA 3.8 Q 3.8.1-15 WG            WC          NA 3.8 Q 3.8.1-18 DC            DC          NA 3.8 Q 3.8.1-27 DC            DC          NA 3.8 O 3.8.1-29 DC            DC          NA 3.8 Q 3.8.1-33 DC            DC          NA 3.8 Q 3.8.2-04 CW            CA         YES 3.8 O 3.8.3-06 DC            DC          NA 3.8 O 3.8.4-08               WC          NA 3.8 O 3.8.4-10               CA         YES 3.8 O 3.8.4-17               WC          NA 3.8 Q 3.8.4-18               CA         YES 3.8 O 3.8.4-29               WC          NA l 3.8 O 3.8.B-01.a             CA         YES 3.8 Q 3.8.B-01.g             CA         YES l

3 3.8 Q 3.8.B-01.j          CA                   YES 3.8 Q 3.8.B-01.p          CA                   YES 3.8 Q 3.8.B-04.r          WC                   NA 3.8 CA-3.8-003 (NEW)      CA                   YES 3.8 DC-3.8-ED             DC                   NA 3.8 WC-3.8-007 (NEW)      CA, WC               YES 3.9 WC-3.lf-007 (NEW)     CA, DC, WC           YES 4.0 WC-4.0-ED (NEW)       WC                   NA 5.0 Q 5.2-1, TSTF-258     CA                   YES 5.0 WC-5.0-007 (NEW)      WC                    NA l
l 1
1 l
l

c                                                                                             ,
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-02-A (3.3)                       APPLICABILITY: CA, WC REQUEST: CTS ACTION b.1, Equation 2.2-1, and the values for Total Allowance (TA),
Z, and Sensor Error (S) are deleted, consistent with NUREG-1431 Rev.1.
Comment: Explain the LG classification for deleting CTS requirements. The staff position is that this change is less restrictive because limits (required operator actions) contained in the CTS are deleted and now given elsewhere in licensee controlled documents.
{WC, CW} The staff also notes this CN is a duplice'a - CN 2-03 A for LSSS changes. Additional CN 2-03A comments are provn .3 sith that CN in this table.
FLOG RESPONSE (original): New DOC 2-54-M has been written regarding elimination of ACTION b.1 in CTS 3.3.2. DOC 2-03-A in the 2.0 package has been revised to reference DOC 2-54-M in the 3.3 package.
FLOG RESPONSE (supplement): DOC 2 54-M is revised to refer to ACTION b.1 n the first sentence.
ATTACHED PAGES:
Attachment 9, CTS 3/4.3 - ITS 3.3 Enclosure 3A, page 25 (INSERT 3A-25 page 1 of 3) l i

    -     =-  _ _ _
L
   ,                        INSERT 3A-25 (page 1 of 3)
Ah        2-49     -
Not used.
i' 2-50     LG  'The CTS [##] note of Table 3.3-3 is revised to move the         $ J 7-43 l                          descriptive material related to the automatic blocking of the interlock to the ITS 3.3.2 Bases. Moving these details does not effect the Applicability or the Operability of the Function which will continue to protect the health and safety of the public.
2-51     e Not applicable to Callaway. See Conversion Comparison Q f.7 M Table (Enclosure 38).
2-52     -
Not applicable to Callaway. See Conversion Comparison g1/7.-f5.
Table (Enclosure 38).
2-53     LG   in this Callaway-specific change, the tie breaker closure       $ 7,7-2f discussion in ACTION 19 of CTS Table 3.3-3 is moved to s      the LCO Bases for ITS 3.3.5 as one example of multiple channels inoperable on one bus. Moving this detail to the ITS Bases has no impact on the system attributes required for OPERABILITY. In addition, moving this detail to the Bases is acceptable since OPERABILITY requirements and supporting surveillances are retained in the ITS and
      ~
the moved information will be adequately controlled under the Bases Control Program of ITS Section 5.5.14. There will be no change to current plant practices nor any impact on safety. DOC 2-18-LS-31 contains the justification for extending the 8 hour breaker closure allowance to 12 hours.                                                      _.
2-54     M     Although       C 2-02-A characterizes the deletion of          d 3-O-A ACTION         rom LCO 3.3.2 as adm_inistrative since the change is wnm.=niwith current piant practice, since thP{
trip setpoint adjustment is done for a majority of analog channels with the channel in trip and therefore declared inoperable (i.e., no different in effect than entering ACTION b.2), there could be scenarios where ACTION b.1 would present another attemative. For instance, since containment pressure High-3 has an installed bypass design feature, ACTION b 1 could allow trip setpoint adjustments in bypass. This would eliminate logging requirements for equipment out of service. Since this change is eliminating ACTION b.1 as an allowed recourse, this is a more restrictive change.
2-55       -    Not applicable to Naway. See Conversion Comparison             O 3-d~/
Table (Enclosure 6B).                                           {p,3)

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 2-18                               APPLICABILITY: CA, WC REQUEST: Current TS Table 3.3-3 ACTION Statement 19 is revised to reflect ITS 3.3.5 for the Loss of Power Functional Unit.
Comment: [OOS)- Reject. Proposed change extends CTS AOTs for 2,3, and 4 inoperable channels to 12 hours. The CTS AOT changes are not evaluated. AOT extensions not consistent with ISTS loss of redundancy and loss of function actions and CTS are OOS. Adopt ISTS for loss of redundancy and loss of function for inoperable LOP actuation channels or translate CTS requirements into lTS format.
The NSHC discussion on entry into LCO 3.0.3 specifies this change "does involve any relaxation in the allowed outage time currently required by LCO 3.0,3 " Please clarify this statement. The staff notes that the NUREG gives a one hour repair AOT for loss of function conditions which is allowed based on the one hour in LCO 3.0.3 given that the LCO includes a LCO 3.0.3 equivalent shutdown requirement.
FLOG RESPONSE (original): The last comment under Comment Number Q 1-18-LS-7 is aise applicable to this DOC.
As discussed during meetings with NRC staff on September 15 and 16,1998, ITS 3.3.5 Required Action B.1 has been revised in response to Comment Number Q 3.3-99 to immediately declare the associated load shedder and emergency load sequencer (LSELS) inoperable. The extended AOT for multiple inoperable channels on one bus in MODES 1-4 is evaluated in DOC 2-18-LS-31 and is consistent with Vogtle's approved ITS. We agree that this is an out of scope change, as identified in Attachment 3 of the original ITS submittal. However, we feel that this change is justified and the attached pages include revisions to DOC 2-18-LS-31 and to LS-31 to further support this change.
The NSHC LS-31 discussion referenced in the second paragraph above is based on a comparison of shutdown time requirements in CTS LCO 3.0.3 vs. ITS LCO 3.3.5. Since ACTION 19 of current TS Table 3.3-3 for Functional Units 8.a and 8.b does not address the inoperability of more than one channel, the failure of multiple channels would result in entering current LCO 3.0.3 which requires that the plant be brought to MODE 3 in 7 hours and MODE 5 in 37 hours. ITS 3.3.5 Conditions C and D also require that the plant be brought to MODE 3 in 7 hours and MC-DE 5 in 37 hours. While ITS 3.3.5 Condition C explicitly allows one hour for restoration, ITS 3.3.5 Required Action D.1 (i.e., be in MODE 3 in 6 hours) effectively eliminates the one hour for action initiation present in CTS LCO 3.0.3. Under the current TS, if LCO 3.3.2 were restored in the first hour the plant would exit LCO 3.0.3. Therefore, this is not seen as a relaxation; however, DOC 2-18-LS-31 and NSHC LS-31 have been revised to more correctly characterize this sentence to say that this Condition has the same shutdown track time in both the CTS and ITS.

FLOG RESPONSE (supplement): Additional changes have been made to DOC 2-18-LS-31 and NSHC LS-31. See the attached pages for Comment Number O 3.3-99.
ATTACHED PAGES:
None

l-ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 7-13                            APPLICABILITY: CA, WC          .
t e
REQUEST: This item was identified during the licensee /NRC meeting on August 11, l
1998. The NRC requested a DOC be initiated to identify either moving portions of CTS i
SR 4.3.3.5.2 concerning operating each actuated component from the ASP or deletion of       .
    . the requirement.                                                                        '!
I I
l    FLOG RESPONSE (original): DOC 7-13 LS-44 was initicted. The DOC states:
l            " CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel (ASP) controls be demonstrated OPERABLE at least once per 18 months by operating each                  )
actuated component from the ASP. The proposed change revises CTS SR l
4.3.3.5.2 to delete the phrase ''by operating each actuated component from the       i ASP." The OPERABILITY of the ASP controls ensures there is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should the control room become inaccessible. CTS SR 4.3.3.5.2 verifies that the ASP controls perform the intended function. The CTS requirement to opera!e each actuated component is overly restrictive since the specific components associated with the ASP are verified OPERABLE by other specifications. For example, FSAR Section 7.4.3.1.1 identifies the                   ,
automatic / manual control for each power operated atmospheric dump valve as         !
an ASP control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is          l OPERABLE by performance of one complete cycle of each valve. Operation of the equipment from the ASP is not necessary. The surveillance can be satisfied by' performance of a continuity check. Performance of this surveillance in conjunction with the performance of other required surveillances on equipment associated with the ASP will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3."
FLOG RESPONSE (supplement): Based on comments from the NRC reviewer on
   ' February 4,1999, DOC 7-13-LS-44 and NSHC LS-44 have been revised per the attached.
ATTACHED PAGES:
Attachment 9, CTS 3/4.3 - ITS 3.3 Enclosure 3A, page 29 and INSERT 3A-298 Enclosure 4, page 82 (new)

T l
CHANGE
^'
   -. NUMBER        HSBC.        DESCRIPTION                                    MIM 3A--39A
'.-J  7 12          A            New Note excludes neutron detectors from CHANNEL CALIBRATION consistent with current TS Table 4.31               47-/M g          gg,, g          Functional Unit 6. Note 4 and with improved TS SR 3.3.4.3.               i MEW 3'A-M8
 /801               A            This change consistent with NUREG-1431 Rev.1. revises
                                 " Channel" and " Instrument" to " Function."
d? 7-jg 8 02          -
Not used.                                                                1 8 03          A            This change revises current TS Table [3.310] to clarify the number of channels required to be operable. This is                  )
an administrative change which deletes the " Minimum                     )
Channels Operable" column [and revises the "[ Total] No. of Channels" column to be the " Required Channels" column].
The required actions are now based on one channel inoperable or two channels inoperable, rather than "less than the Total Number" or "less than Minimum Number."                    )
This change is consistent with NUREG 1431 Rev.1.                         j i
8 04          LS 17        Consistent with NUREG 1431 Rev.1 (ITS 3.3.3 Required                     j Actions C.1. E.1, and G.1). this change deletes the                      i requirement to initiate an alternate means of monitoring within 72 hours when two channels of Containment Radiation Level [or RVLIS] are inoperable as specified in current TS [3.3.3.6 Action c].
8 05          A            In conjunction with CN 8 03 A. this change rearranges the ACTION Statements for the single channel Functions (i.e. .
SG Water Level    -
Wide Range and AFM Flow Rate). No change in A0T is requeste     6Mhire C C @ DED f .rNJ4er 3A-19L)                                   $ E 3"2- 0   ,
8 06          LG           Specific equipment ID numbers are moved to the ITS Bases.                I 8 07          -
Not applicable to Callaway. See Conversion Comparison Table (Enclosure 3B).
8 08          LS 27        Not applicable to Callaway. See Conversion Comparison Table (Enclosure 3B).
                                                                                               ~
3 09          - l-G        M aed. *2WEGR7~ 3% ~1W 8 10          -
Not used.                                                                 l 8 11          LS 30        Not applicable to Callaway.                                              I See Conversion Comparison g p,_jj Table (Enclosure 38).
f, ]l          -                          +                       +
f--//
                      ~
                                                +                       a DESCRIPTION OF CHANGES TO CURRENT TS        29                                    5/15/97

l
     ,                                           INSERT 3A-29A
[ 7-/2M Since neutron flux is one of the required channels and the detectors are normally excluded from CHANNEL CAllBRATIONS in other specifications, this Note applies to the SR Frequency in CTS Table 4.3 6. Neutron detectors are one type of sensor that can no. be adjusted per the definition of CHANNEL CALIBRATION. As discussed in the ITS SR 3.3.1.11 Bases, the CHANNEL CA,LIBRATION for the source range detectors consists of obtaining integral bias curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Note in ITS SR 3.3.4.3 is consisten+ with other CTS requirements for calibrating channels containing neutron detectors. This change is considered an administrative clarification of existing requirements.
INSERT 3A-298 f) %/3 CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel (ASP) controls be demonstrated OPERABLE at least once per 18 months by operating each actuated component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to delete the phrase "by operating each actuated component from the ASP." The OPERABILITY of the ASP
  ~~
controls ensures there is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should tne control room become inaccessible.
CTS SR 4.3.3.5.2 verifies that the ASP controls perform the intended function. The CTS            ;
       . requirement to operate each actuated component is overly restrictive since the specific           j components associated with the ASP are verified OPERABLE by other specifications.
For example, FSAR Sectic,n 7.4.3.1.1 identifies the automatic / manual control for each power operated atmospheric dump valve as an ASP control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by performance of one complete cycle of each valve. Operation of the equipment from the ASP is not necessary. The surveillance            l can be satisfied by performance of a continuity chec Performance of this surveillance             I in conjunction with the performance of other require      rveillances on equipment associated with the ASP will ensure that if the control com becomes inaccessible, the             )
plant can be placed and maintained in MODE 3.
(er M M O'b' *                           !
I l
l l

INSERT LS-44                              h 7~M
'h IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-44 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS CTS SR 4.3.3.5.2 requires the auxiliary shutdown panel (ASP) controls be demonstrated OPERABLE at least once per 18 months by operating each actuated component from the ASP. The proposed change revises CTS SR 4.3.3.5.2 to delete the phrase "by operating each actuated component from the ASP."If temporary evacuation of the control room is regul' .1 because of some abnormal condition, the operators can establish and maintain the plant in a hot standby condition from outside the control room.
The OPERABILITY of the ASP controls ensures there is sufficient information available on selected unit parameters to place and maintain the unit in MODE 3 should the control room become inaccessible. CTS SR 4.3.3.5.2 verifies that the ASP controls perform the intended function. The CTS requirement to operate each actuated component is overly restrictive since the specific components associated with the ASP are verified OPERABLE by other specifications. For example, FSAR Section 7.4.3.1.1 identifies the automatic / manual control for each power operated atmospheric dump valve as an ASP g   control. ITS SR 3.7.4.1 verifies that the atmospheric dump valve is OPERABLE by performance of one complete cycle of each valve. Operation of the equipment from the ASP is not necessary. The surveillance can be satisfied by performance of a continuiti chec       erformafice of this surve'IIIi' n in conjunction with the performance of other requ        surveillances on equipment as ciated with the ASP will ensure that if the contro om becomes inaccessible, th plant can be placed and maintained in MODE 2.
p3 Z*rTSR 3.2.4;3 This propose          cag            een evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:
7
              'The Commission may make a finaldeterminatio.1, pursuant to the procedures in 50.91, that a proposed amendment to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facilityin accordance with the proposed amendment would not:
: 1.      Invoin a significant increase in the probability or consequences of an accident previously evaluated; or
: 2.      Create the possibility of a new or different kind of accident from any accident previously evaluated; or P2

ADDITIONAL INFORMATION COVER SHEET                                    l ADDITIONAL INFORMATION NO: O 3.3-04                            APPLICABILITY: CA REQUEST: This change represents the Callaway plant design as it relates to the SG Water Level-Low Low Environmental Allowance Modifier (EAM) and Trip Time Delay                   i (TTD) circuitry. ITS Table 3.3.1-1 and Table 3.3.2-1 entries and the associated Required         i Actions have been enhanced to remove the redundancy in the current TS and add                    l shutdown actions when inoperable channels aren't tripped per their Completion Time.              I Comment: Beyond Scope - because plant unique actions are modified as stated in the DOC.. . " Enhancements to remove CTS redundancy in the CTS and added shutdown actions."[ sic) Revise ITS Actions E (as applied to function 14), and X to adopt CTS requirements without modification. [see 1-19-LS 8)
Provide a separate DOC for changes made to CTS Action 7 for Functions 13.a and 13.b. CTS Action 7 is translated into ITS Condition W. Condition W applies only to ITS 14.c functions for Vessel AT Power-1, and Power-2 which are                 1 equivalent to CTS Function 13.c.                                                        !
l Based on 8/14/98 meeting (CW) to provide 163 M and 162 LS.                              -
CTS Action 35 provides actions for a single inoperable timer. ITS Action N allows one or more timers to be inoperable. This change is neither noted norjustified in       ;
the CTS markup.                                                                         ;
l l
FLOG RESPONSE (original): DOC 1-19-LS-8 has nothing to do with the SG Water Level Low-Low EAM/TTD trip functions at Callaway. That DOC concerns only those reactor trip functions interlocked with permissive P-7. DOC 1-42-M (DOC 2-14-M for corresponding ESFAS changes) addresses the changes to Actions 7,11, and 13 in                    )
current TS Table 3.3-1 to require entering MODE 3 in 6 hours rather than in 7 hours (as would be the case with an LCO 3.0.3 entry).
Contrary to the Reference 4 meeting minutes, there should be no need to provide a new "1-62-LS" change and a new "163-M" change only to move the TTD timer Action Statement 7 to the Functional Unit to which that Action has always applied. Moving this          j Action Statement number in CTS Table 3.3-1 is administrative; no change to current               )
practices is involved. New DOC 1-62-A has been written to cover the movement of                  ;
Action 7 from Functional Units 13.a and 13.b in current TS Table 3.3-1 to Functional Unit        i 13.c in that table, with a detailed discussion as to why this change is considered to be administrative in nature. Actions 7 and 11 now apply to Functional Unit 13.c since they          l both involve tripping the Vessel AT (Power-1, Power-2) channels. New DOC 1-62-A also discusses the corresponding ESFAS changes which mirror the RTS changes.
JFD 3.3-04 has been ,avised to reflect DOCS 1-42-M (DOC 2-14-M for ESFAS) and 1 A.
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In ITS 3.3.1, Condition E corresponds to Action 6 (which has been rewritten as Action       )
2.1 in the conversion submittal) for current TS Functional Unit 13.a. Condition E has       j been revised in response to Comment Number 3.3-40 (setpoint adjustment deleted from Note).
Condition W corresponds to Actions 7 (added per new DOC 1-62-A) and 11 for current TS Functional Unit 13.c. The format and wording presentation of Condition W and Required Action W.1 are retained for clarity given the discussion in new DOC 1-62-A.
Several of the RTS Conditions identify the affected Function and Required Action W.1 must be clear as what channel (s) to trip to remove the time delay in the event of an inoperable timer.
Condition X corresponds to Action 13 for current T3 Functional Unit 13.b. Required Action X.1 has been retained and DOC 1-46-A has been revised to provide more                 ,
discussion. FSAR Figure 7.2-1 sheet 7A is attached to illustrate the EAM logic.              I Condition Y corresponds to Action 11 for current TS Functional Unit 13.d. Required Action Y.1 is reworded to delete the identity of the affected channel since that identity is already established in the Condition.
In ITS 3.3.2, ESFAS Required Action O.1 has been revised to reflect the change to RTS Required Action Y.1.
The last paragraph of the comment was answered in the September meetings, as reflected by Reference 6.
FLOG RESPONSE (supplement): Based on comments received from the NRC reviewer on February 16,1999, the changes to CTS 3.3.1 ACTION 13 and CTS 3.3.2 ACTION 36 that were previously evaluated under DOC 1-46-A are now evaluated under DOC 1-46-M. These ACTIONS have been revised to handle the SG water level low-low (normal containment environment) channels the same as the SG water level low-low (adverse containment environment) channels, i.e., with one channel inoperable place it in the tripped condition within 6 hours. Corresponding changes to Enclosures 2,3A,3B,        ;
SA, and 5B have been made.                                                                   '
I ATTACHED PAGES:
Attachment 3, Table of Changes not within the Scope of Full Conversion to the ISTS, page 10 Attachment 9, CTS 3/4.3 - ITS 3.3                                                            l Enclosure 2, pages 3/4 3-6(a), insert 3/4 3-6(a)-1,3/4 3-21(b), insert 3/4 3-21(b)
Enclosure 3A, pages 14,15, insert 3A-15 Enclosure 3B, page 10 Enclosure SA, pages 3.3-10,3.3-19,3.3-20, 3.3-31,3.3-32, 3.3-33, insert 3.3-42,3.3-43, 3.3-44, and 3.3-45 Enclosure 58, pages B 3.3-30, B 3.3-48, B 3.3-58, B 3.3-59, B 3.3-60, B 3.3-74, insert B 3.3-110 (page 2 of 2),8 3.3-113, B 3.3-114, B 3.3-128, B 3.3-136, B 3.3-137, B 3.3-138, and B 3.3-150 I
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Enclosure 6A, page 8 Enclosure 68, page 10                                                                    i
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