ML112420039

Callaway Plant NFPA 805 Transition Report, Attachment N - Technical Specification Changes

ML112420039
Person / Time
Site:	Callaway
Issue date:	08/29/2011
From:	Ameren Missouri
To:	Office of Nuclear Reactor Regulation
Shared Package
ML112420020	List: ML112420022 ML112420024 ML112420028 ML112420033 ML112420035 ML112420036 ML112420038 ML112420039 ML112420042 ML112420045 ULNRC-05781, Callaway Plant NFPA 805 Transition Report ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment F - Fire-Induced Multiple Spurious Operations Resolution ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment H - NFPA 805 Frequently Asked Question Summary Table, Attachment I - Definition of Power Block & Attachment J - Fire Modeling V & V ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment L - NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vi)) ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment M - License Condition Changes ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment N - Technical Specification Changes ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment T - Clarification of Prior NRC Approvals ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment a - NEI 04-02 Table B-1 and Attachment B - NEI 04-02 Table B-2 ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachments O - Orders and Exemptions, P - RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4), Q - No Significant Hazards Evaluations, & R - Environmental Considerations Evaluation ULNRC-05781, Callaway Plant, Unit 1 - Request for License Amendment to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) (License Amendment Request Ldcn 11-0012) ULNRC-05781, NFPA 805 Transition Report, Attachment X - Other Requests for Approval
References
ULNRC-05781
Download: ML112420039 (11)

Text

Ameren Missouri N. August 2011 Callaway Plant NFPA 805 Transition Report Technical Specification Changes 10 Pages Attached Page N-1 Ameren Missouri Callaway Plant NFPA 805 Transition Report Ameren Missouri implemented the following process for determining which Technical Specification (TS) or Technical Specification Bases (TSB) were required to be either revised or superseded to implement the new fire protection program which meets the requirements in 10 CFR S0.48(a) and 10 CFR S0.48(c).

• A review of the Callaway Plant Technical SpeCifications was performed by the Callaway Plant licensing staff and the NFPA 80S Transition Team. The review was performed by reviewing the Technical Specifications and performing electronic searches using the Callaway Plant Licensing Research System (LRS). The Callaway Plant LRS contains Callaway Plant licensing documents, correspondence, and regulatory and guidance materials, including those documents pertaining to the operating license, the TS, the fire protection program, the FSAR and subsequent revisions, correspondence sent to the NRC, and correspondence received from the NRC. The correspondence sent to the NRC includes any outstanding license amendment request submittals.

Ameren Missouri determined that the following changes to the Callaway Plant TSs and TSBs are necessary for adoption of the new fire protection licensing basis for the following reasons: (1) Revise TS paragraph 5.4.1.d as shown below: S.4.1.d Fire PreteGtien Pregram Not Used; and TS S.4.1.d is being deleted because, after completion of the transition to NFPA 80S, the requirement for establishing, implementing, and maintaining fire protection procedures will be contained in 10 CFR S0.48(a) and 10 CFR S0.48(c), as speCifically outlined in Section 3.2.3, "Procedures," of NFPA 80S. (2) The Applicable Safety Analysis and References sections for TSB 3.3.4 are being revised to include reference to 10 CFR S0.48(c).

The current Applicable Safety Analysis section for TSB 3.3.4, states in part: " ... The criteria governing the design and specific system requirements of the Remote Shutdown System are located in 10 CFR SO, Appendix A, GOC 3 and GOC 19 (Ref. 1 )." The Applicable Safety Analysis for TSB 3.3.4 should be revised to state: " ... The criteria governing the design and specific system requirements of the Remote Shutdown System are located in 1 0 CFR SO, Appendix A, GOC 3 and GOC 19 (Ref. 1), and 10 CFR S0.48(c) (Ref. 2)." The References section for TSB 3.3.4 lists the following references:

1. 10 CFR SO, Appendix A, GOC 3 and GOC 19. 2. Callaway OL Amendments No. 4S dated May 16, 1989 and 108 dated March 11, 1996. The References section for TSB 3.3.4 should be revised to include an additional reference, as follows: 1. 10 CFR SO, Appendix A, GOC 3 and GOC 19. 2. 10 CFR S0.48(c).

3. Callaway OL Amendments No. 4S dated May 16, 1989 and 108 dated March 11, 1996. August 2011 Page N-2 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report Technical Specification Markup 2 Pages Attached Page N-3 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report LDCN 11-0012 TECHNICAL SPECIFICATION MARKUP TS S.4.1.d Page N-4 Ameren Missouri Callaway Plant NFPA 805 Transition Report Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures

5.4.1 Written

procedures shall be established, implemented, and maintained covering the following activities:

a. The applicable procedures recommended In Regulatory Guide 1.33, Revision 2, Appendix A, February 1978; b. The emergency operating procedures required to Implement the requirements of NUREG*0737 and NUREG"()737, Supplement 1, as stated In Generic Letter 82*33;

__

assurance for effluent and environmental monitoring;

e. All programs specified In SpeCification

5.5. CALLAWAY

PLANT 5.0-5 August 2011 Page N-5 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report Technical Specification Retype 1 Page Attached Page N-6 Ameren Missouri Callaway Plant NFPA 805 Transition Report August 2011 Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures

5.4.1 Written

procedures shall be established, implemented.

and maintained covering the following activities:

a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2. Appendix A. February 1978; b. The emergency operating procedures required to Implement the requirements of NUREG*0737 and NUREG*0737.

Supplement 1, as stated In Generic Letter 82-33: c. Quality assurance for effluent and environmental monitoring;

d. Not Used; and e. All programs specified in Specification

5.5. CALLAWAY

PLANT 5.0-5 Amendmentm Page N-7 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report LDCN 11*0012 TECHNICAL SPECIFICATION BASES MARKUPS (FOR INFORMATION ONLY) TSB 3.3.4 AppUcabJe Safety Analyses TSB 3.3.4 SR 3.3.4.2 TSB 3.3.4 References Page N-8 Ameren Missouri Callaway Plant NFPA 805 Transition Report August 2011 Lt)C).) It' OOI-z... Remote Shutdown System B3.3.4 BASES BACKGROUND (continued)

5. 6. 1. 8. 9. 10. 11. 12. APPLICABLE SAFETY ANALYSES Leo TOTAL NO. OF READOUT FUNCTION CHANNELS LOCATION RCS Hot Leg Temperature 2 Auxiliary Shutdown Panel RCS Cold Leg Temperature 4 Auxiliary Shutdown Panel SG Pressure 21SG Auxiliary Shutdown Panel SG Level 2/SG Auxiliary Shutdown Panel AFW Flow Rate Reactor Coolant Pump Breaker 4 Auxiliary Shutdown Panel Position 1/pump 13.8-kV Switchgear AFW Suction Pressure 3 Auxiliary Shutdown Panel Pressurizer Level 2 Auxiliary Shutdown Panel The Remote Shutdown System Is required to provide equipment at appropriate locations outside the control room with a capability to promptly shut down and maintain the unit In a safe condition In MODE 3. The Remote Shutdown System satisfies Criterion 4 of 10CFR50.36(c)(2)(II).

The Remote Shutdown System LeO provides the OPERABILITY requirements of the Instrumentation and required ASP controls necessary to place and maintain the unit In MODE 3 from a location other than the control room. The Instrumentation required Is listed In Table 3.3.4-1 In the accompanying LeO. The required ASP controls are described In FSAR Section 1.4.3.1.1 and are listed In FSAR Table 1.4ft 1. The remote shutdown controls not located at the ASP are described In FSAR Section 1.4.3.1.2 and are excluded from the requirements of this LCO. (continued)

CALLAWAY PLANT Page N-9 Ameren Missouri Callaway Plant NFPA 805 Transition Report Remote Shutdown System B3.3.4 SURVEILLANCE SR 3 3 4 1 (continued)

REQUIREMENTS CALLAWAY PLANT August 2011 and readability.

If the channels are within the criteria.

It Is an Indication that the channels are OPERABLE.

If a channel Is outside the criteria.

It may be an Indication that the sensor or the signa' processing equipment has drifted outside Its limit. For the RTB Position and the RCP Breaker Position Functions.

this surveillance requirement i8 met by verifying the actual position at the associated switchgear to the main control board Indications.

As speCified In the Surveillance.

a CHANNEL CHECK Is only required for those channels which are normally energized.

The Westinghouse NIS source range neutron flux channel Is not normally energized.

The Frequency of 31 days Ia based upon operating experience which demonstrates that channel failure Is rare. The CHANNEL CHECK supplements less formal. but more frequent.

checks of channels during normal operational use of the displays associated with the LCO required channels.

SR 3342 SR 3.3.4.2 verifies each required Remote Shutdown System ASP control circuit and transfer switch performs the Intended function.

This verification is performed from the auxiliary shutdown panel. Operation of the equipment from the auxiliary shutdown panella not necessary.

The Surveillance can be ,atIsfIed by , performance of a contrnulty check, This will ensure that If ttle cD , ntrol room becc;mes lnaccesslble'.

the-unit can be placed and maintained In MODE 3'from the auxiliary shufdown panel. The 18 month Frequency Is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplannud transient If the Surveillance were performed with the reactor at power. (However.

this Surveillance Is not required to be performed only during a unit outage.) Operating experience demonstrates that auxiliary shutdown controls usually pass the Surveillance test when performed at the 18 month Frequency, The Note allows entry into and E 3 prior to performing the SR for the turbine driven AFW pum This allows testing the associated ASP controls In MODE (continued)

B 3.3.4-5 Page N-10 Ameren Missouri Callaway Plant NFPA 805 Transition Report August 2011 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3,343 Remote Shutdown System B3.3.4 CHANNEL CALIBRATION Is a complete check of the Instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Frequency of 18 months Is based upon operating experience and consistency with the typical Industry refueling cycle. The Notes exclude the source range neutron flux detectors and reactortrlp breaker and RCP breaker position Indications from the CHANNEL CALIBRATION.

Neutron detectors are excluded from the CHANNEL CALIBRATlON because it is Impractical to set up a test that demonstrates and adjusts neutron detector response to known values of the parameter (neutron fiux) that the channel monitors.

Oependlng on which source range channel is used to satiSfy the LCO, Note 1 applies to the source range proportional counter in the Nuclear Instrumentation System (NIS) associated with Indicator SENI0031C or to the Gamma*Metrics fission chamber associated with Indicator SEN10061X.

As discussed In the Bases for SR 3.3.1.11, the CHANNEL CALIBRATION of the Westinghouse NIS source range channel consists of obtaining on Integral bias curve. evaluating that curve. and comparing It to previous data. Whenever an RTO Is replaced In Function 5 or 6, the next required CHANNEL CALIBRATION of the RTOs Is accomplished by an Inplace cross calibration that compares the other senSing elements with the recently Installed sensing element. REFERENCES

1. 10 CFR 50, Appendix A, GOC 3 and GOC 19.

Callaway OL Amendments No. 46 dated May 16,1989 and 108 dated March 11, 1996. CALLAWAY PLANT B 3.3.4-6 Page N-11