ML14350B239

Callaway Plant, Unit 1, Issuance of Amendment No. 210, Revise Technical Specification LCO 3.4.12, Cold Overpressure Mitigation System (Coms), to Clarify No Limitation on Normal Charging Pump Use During Modes 4-6 (TAC MF3391)

ML14350B239
Person / Time
Site:	Callaway
Issue date:	01/20/2015
From:	Lyon C F Plant Licensing Branch IV
To:	Diya F Union Electric Co
Lyon C F
References
TAC MF3391
Download: ML14350B239 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251 January 20, 2015

SUBJECT:

CALLAWAY PLANT, UNIT 1 -ISSUANCE OF AMENDMENT RE: REVISION TO TECHNICAL SPECIFICATION 3.4.12, "COLD OVERPRESSURE MITIGATION SYSTEM (COMS)" (TAC NO. MF3391)

Dear Mr. Diya:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 210 to Facility Operating License No. NPF-30 for the Callaway Plant Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated January 23, 2014. The amendment revises TS 3.4.12, "Cold Overpressure Mitigation System (COMS)," to reflect the mass input transient analysis that assumes an Emergency Core Cooling System centrifugal charging pump and the normal charging pump capable of injecting into the reactor coolant system when TS 3.4.12 is applicable.

The amendment also revises TS Table 3.3.1-1, "Reactor Trip System Instrumentation," to remove unnecessary page number references.

A copy of the related Safety Evaluation is also enclosed.

The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice. Docket No. 50-483

Enclosures:

1. Amendment No. 210 to NPF-30 2. Safety Evaluation cc w/encl: Distribution via Listserv Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 UNION ELECTRIC COMPANY CALLAWAY PLANT. UNIT 1 DOCKET NO. 50-483 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 210 License No. NPF-30 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Union Electric Company (UE, the licensee), dated January 23, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 1 0 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-30 is hereby amended to read as follows: (2) Technical Specifications and Environmental Protection Plan* The Technical Specifications contained in Appendix A, as revised through Amendment No. 210 and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. 3. This amendment is effective as of its date of issuance, and shall be implemented within 90 days of the date of issuance.

Attachment:

Changes to the Facility Operating License No. NPF-30 and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:

Jaunuary 20, 2015 ATTACHMENT TO LICENSE AMENDMENT NO. 210 FACILITY OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483 Replace the following pages of the Facility Operating License No. NPF-30 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. REMOVE REMOVE 3.3-20 3.4-25 3.4-26 3.4-28 Facility Operating License Technical Specifications INSERT INSERT 3.3-20 3.4-25 3.4-26 3.4-28

• ** (4) UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source of special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) UE, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 1 0 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level UE is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (1 00% power) in accordance with the conditions specified herein. (2) Technical Specifications and Environmental Protection Plan* The Technical Specifications contained in Appendix A, as revised through Amendment No. 210 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Environmental Qualification (Section 3.11, SSER #3)** Deleted per Amendment No. 169. Amendments 133, 134, & 135 were effective as of April 30, 2000 however these amendments were implemented on April 1, 2000. The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 210 TABLE 3.3.1-1 (PAGE 2 OF 8) Reactor Trip System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED FUNCTION CONDITIONS CHANNELS CONDITIONS

5. Source Range 2(e) 2 I, J Neutron Flux 3. 4. s 2 J, K 6. Overtemperature 1,2 4 E t.T 7. Overpower L'. T 1,2 4 E 8. Pressurizer Pressure a. Low 1(9) 4 M b. High 1,2 4 E RTS Instrumentation SURVEILLANCE REQUIREMENTS Sf? 3<3. i 1 i 7 1 10 7 1 1C .; ' ' l 1 1 1 r 3.3.1 ALLOWABLE VALUE(a) :s: 1.6 E5 cps :s: 1.6 E5 cps Refer to Note 1 (at the end of this Table) Refer to Note 2 (at the end of this Table) ;:, 1874 psig :s: 2393 psig (a) The Allowable Value defines the limiting safety system setting except for Trip Functions 14.a and 14.b (the Nominal Trip Setpoint defines the limiting safety system setting for these Trip Functions).

See the Bases for the Nominal Trip Setpoints. (b) With Rod Control System capable of rod withdrawal or one or more rods not fully inserted. (e) Below the P-6 (Intermediate Range Neutron Flux) interlock. (g) Above the P-7 (Low Power Reactor Trips Block) interlock.

CALLAWAY PLANT 3.3-20 Amendment No. 210 COMS 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Cold Overpressure Mitigation System (COMS) LCO 3.4.12 APPLICABILITY:

CALLAWAY PLANT COMS shall be OPERABLE with a maximum of zero safety injection pumps, one Emergency Core Cooling System (ECCS) centrifugal charging pump, and the normal charging pump capable of injecting into the RCS and the accumulators isolated and one of the following pressure relief capabilities:

a. Two power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR, or b. Two residual heat removal (RHR) suction relief valves with setpoints 2 436.5 psig and 463.5 psig, or c. One PORV with a lift setting within the limits specified in the PTLR and one RHR suction relief valve with a setpoint 2 436.5 psig and 463.5 psig, or d. The RCS depressurized and an RCS vent of 2 2.0 square inches. -------------------------------------------

N 0 T E S --------------------------------------------

1. Two ECCS centrifugal charging pumps may be made capable of injecting 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations.

2. One or more safety injection pumps may be made capable of injecting in MODES 5 and 6 when the RCS water level is below the top of the reactor vessel flange for the purpose of protecting the decay heat removal function.

3. Accumulator may be unisolated when accumulator pressure is less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR. MODE 4 with any RCS cold leg temperature 275°F, MODE 5, MODE 6 when the reactor vessel head is on. 3.4-25 Amendment No. 210 ACTIONS COMS 3.4.12 -----------------------------------------------------------

N 0 T E -----------------------------------------------------------

LCO 3.0.4.b is not applicable when entering MODE 4. CONDITION REQUIRED ACTION COMPLETION TIME A One or more safety A.1 Initiate action to verify a Immediately injection pumps capable of maximum of zero safety injecting into the RCS. injection pumps are capable of injecting into the RCS. B. Two ECCS centrifugal 8.1 Initiate action to verify a Immediately charging pumps capable of maximum of one ECCS injecting into the RCS. centrifugal charging pump and the normal charging pump capable of injecting into the RCS. C. An accumulator not isolated C.1 Isolate affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when the accumulator accumulator.

pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR. ( contmued)

CALLAWAY PLANT 3.4-26 Amendment No. 210 SURVEILLANCE REQUIREMENTS SR 3.4.12.1 SR 3.4.12.2 SR 3.4.12.3 SR 3.4.12.4 SR 3.4.12.5 SURVEILLANCE Verify a maximum of zero safety injection pumps are capable of injecting into the RCS. Verify a maximum of one ECCS centrifugal charging pump and the normal charging pump capable of injecting into the RCS. Verify each accumulator is isolated when accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR. Verify RHR suction isolation valves are open for each required RHR suction relief valve. Verify required RCS vent:::::

2.0 square inches open. CALLAWAY PLANT 3.4-28 COMS 3.4.12 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No. 210 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

1.0 INTRODUCTION

RELATED TO AMENDMENT NO. 210 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 By application dated January 23, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14023A803), Union Electric Company (the licensee) requested changes to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1 (Callaway).

The licensee proposed to revise Technical Specification (TS) 3.4.12, "Cold Overpressure Mitigation System (COMS)," to reflect the mass input transient analysis that assumes an Emergency Core Cooling System (ECCS) centrifugal charging pump (CCP) and the normal charging pump (NCP) capable of injecting into the reactor coolant system (RCS) when TS 3.4.12 is applicable.

The licensee also proposed to revise TS Table 3.3.1-1, "Reactor Trip System Instrumentation," to remove unnecessary page number references.

Specifically, the proposed changes to TS 3.4.12 will differentiate between the ECCS CCPs and the non-safety-related NCP, and provide clarification that no limits are placed on operation of the NCP during applicability of TS 3.4.12. The proposed changes also revise TS Table 3.3.1-1 to correct referenced page numbers, which had been changed in Amendment No. 202 dated July 29, 2011 (ADAMS Accession No. ML 111661877).

The Allowable Values for Functions 6 and 7 in Table 3.3.1-1 are revised to replace the page number references with the explanatory phrase "(at the end of this Table)." 2.0 REGULATORY EVALUATION 2.1 SYSTEM DESCRIPTION The COMS controls RCS pressure at low temperatures in order to ensure the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the temperature (P-T) limits of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix G, "Fracture Toughness Requirements," as specified in the licensee's Pressure Temperature Limits Report (PTLR) in low-temperature modes of operation.

LCO 3.4.12 provides overpressure protection by specifying a maximum coolant input capability and an adequate pressure relief capability.

Enclosure 2 2.2 Applicable Regulatory Requirements Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. In 10 CFR 50.36, "Technical specifications," the NRC established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation:

(1) safety limits, limiting safety system settings, and limiting control settings, (2) LCOs, (3) SRs, (4) design features, and (5) administrative controls.

The regulation does not specify the particular requirements to be included in a plant's TSs. The regulations in 10 CFR 50.36(c)(2)(i}, state, in part, that the "[l]imiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility." More specifically, 10 CFR 50.36(c)(2)(ii) states that "A [TS LCO] of a nuclear reactor must be established for each item meeting one or more of the following criteria:

[ ... ] Criterion

2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier." The COMS controls RCS pressure at low temperatures so that the integrity of the RCPB is not compromised by violating the pressure and temperature limits required by 10 CFR Part 50, Appendix G. The LCO ensures that only a limited inventory of mass input sources are available for injection into the RCS during low-temperature operation, consistent with Criterion 2 of 10 CFR 50.36(c)(2)(ii).

3.0 TECHNICAL EVALUATION 3.1 Proposed TS Changes The current TS LCO 3.4.12 states, in part: COMS shall be OPERABLE with a maximum of zero safety injection pumps and one centrifugal charging pump capable of injecting into the RCS and the accumulators isolated and one of the following pressure relief capabilities:

The revised TS LCO 3.4.12 would state, in part: COMS shall be OPERABLE with a maximum of zero safety injection pumps, one Emergency Core Cooling System (ECCS) centrifugal charging pump, and the normal charging pump capable of injecting into the RCS and the accumulators isolated, and one of the following pressure relief capabilities:

The current Note 1 for the LCO states: 1. Two centrifugal charging pumps may be made capable of injecting for :5 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations. The revised Note 1 for the LCO would state: 1. Two ECCS centrifugal charging pumps may be made capable of injecting for :5 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for pump swap operations.

Actions A and 8 are specific actions in TS LCO 3.4.12 that are related to these pumps. Action A applies to the given condition of, "One or more safety injection pumps capable of injecting into the RCS," and it requires action to be completed immediately to verify a maximum of zero safety injection pumps are capable of injecting into the RCS. Action 8 applies to the given condition of, "Two centrifugal charging pumps capable of injecting into the RCS," and requires action to be completed immediately to verify a maximum of one centrifugal charging pump is capable of injecting into the RCS. Note 1 of LCO 3.4.12, and Condition 8, would each be revised to specify the CCPs as ECCS CCPs. Current Condition 8 states: Two centrifugal charging pumps capable of injecting into the RCS. Revised Condition 8 would state: Two ECCS centrifugal charging pumps capable of injecting into the RCS. Current Required Action 8.1 states: Initiate action to verify a maximum of one centrifugal charging pump is capable of injecting into the RCS. Revised Required Action 8.1 would state: Initiate action to verify a maximum of one ECCS centrifugal charging pump and the normal charging pump capable of injecting into the RCS. Current SR 3.4.12.2 states: Verify a maximum of one centrifugal charging pump is capable of injecting into the RCS. Revised SR 3.4.12.2 would state: Verify a maximum of one ECCS centrifugal charging pump and the normal charging pump capable of injecting into the RCS. This amendment application also requests changes toTS Table 3.3.1-1, to correct references to Notes 1 and 2 for the Allowable Values for Functions 6 and 7, respectively, of Table 3.3.1-1. The notes currently refer to pages 3.3-23 and 3.3-24 instead of the correct pages, which are 3.3-25 and 3.3-26, respectively.

When the applicant made changes to the TS under License Amendment No. 202, the pages were changed without updating the references in Table 3.3.1-1. To correct the editorial error, the applicant has proposed to replace the page references with the explanatory phrase "(at the end of this Table)." The proposed change would remove the need to update these references in subsequent license amendments that impact these page numbers in the TSs, without changing the requirements of the TSs. 3.2 Summary of Technical Information Provided by the Licensee In its letter dated January 23, 2014, the licensee stated, in part, that The mass injection rate assumed in the design-basis mass input transient is based on 100% flow capacity of the NCP and one CCP. The maximum combined pump flow has been assumed in order to envelop the maximum flow possible by the operational configuration that uses the NCP for charging with one CCP remaining OPERABLE, or use of the CCP for charging with the NCP remaining functional, during shutdown modes. This assumption is consistent with the TS 3.4.12 LCO, which requires all safety injection pumps and one of the two ECCS CCPs to be made incapable of injecting into the RCS and, therefore, allows an ECCS CCP and the NCP to be functional under these modes of operation.

Note 1 of the LCO allows for two ECCS CCPs to be capable of injection for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during pump swap operation, which is consistent with the NRC-approved Technical Specifications Task Force (TSTF) traveler TSTF-285-A, "Charging Pump Swap L TOP Allowance" (ADAMS Accession No. ML040620093), and is mitigated by the following factors.

• At low RCS temperature and pressure, TS LCO 3.4.12 requires redundant active COMS relief valves or an adequate passive vent path for the RCS, although only one is credited by the analysis for the mass injection transient.

• In event of an ECCS actuation signal, the automatic signals to start both ECCS CCPs would be accompanied by an automatic signal to trip the NCP.

• Risk of an inadvertent ECCS actuation signal is mitigated by a procedural requirement to block the analog ECCS actuation signals, except Containment Pressure -High, below the P-11 set point (pressurizer pressure less than 1970 pounds per square inch gauge), in Mode 3.

• When present, a vapor bubble in the pressurizer will mitigate the pressure spike associated with a mass injection transient.

Operation without a vapor bubble in the pressurizer (pressurizer water-solid) has been evaluated to be an Infrequently Performed Test or Evolution (I PTE) with potential for high consequences if the activity is performed incorrectly.

As an I PTE, this activity receives additional oversight from Callaway senior management, including an evaluation of whether Just-In-Time Training (JITT) is needed prior to performing the activity.

For the Callaway Replacement Steam Generator (RSG) project (License Amendment No. 168, dated September 29, 2005; available at ADAMS Accession No. ML052570086), the licensee's contractor, Westinghouse Electric Company LLC, reanalyzed the COMS heat injection transient due the steam generator design changes, and concluded that the mass injection analysis results would not be impacted.

The analysis was discussed in Section 4.3.5 ofWCAP-16265-P, "Callaway Replacement Steam Generator program NSSS Licensing Report," August 2004 (proprietary, non-publically available) and Section 4.3.5 of the RSG license amendment request dated September 17, 2004 (ADAMS Accession No. ML042870372), and in Section 3.4.3.5 of the NRC staff's license amendment safety evaluation.

The licensee also notes that the staff has reviewed and approved a similar amendment for Wolf Creek Generating Station (WCGS), WCGS License Amendment No. 207, dated December 6, 2013 (ADAMS Accession No. ML 13282A534).

Callaway is the same design (standard nuclear power system; SNUPS) as WCGS. The proposed revisions toTS 3.4.12 LCO Note 1, Condition 8, Action 8.1, and SR 3.4.12.2 are the same as those approved by the NRC staff in the WCGS amendment, except for plant-specific nomenclature.

The revised TS LCO 3.4.12 would be the same as the approved WCGS TS LCO 3.4.12 except that the Callaway LCO uses "COMS ... ", instead of the WCGS nomenclature of "An L TOP System ... ", to reflect that the system that performs the L TOP function at Callaway is called the COMS. 3.3 NRC Staff Evaluation The NRC staff reviewed the license amendment request by evaluating the submitted information, verifying that the proposed LCO is consistent with the assumptions in the applicable safety analysis, and verifying the current licensing basis. The staff also verified that the revised Note 1, which provides limited exceptions to the LCO, is augmented by adequate station procedures and additional safety considerations to ensure that the exceptions will continue to provide adequate protection of the public health and safety. The proposed LCO would continue to allow two ECCS CCPs to be in an operable configuration for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (Note 1 of LCO 3.4.12). The mass input analysis does not address this condition, but it is consistent with NRC-approved TSTF-285-A, Insert 1, which states the following:

The LCO is modified by two Notes. Note 1 allows [two charging pumps] to be made capable of injecting for :s; 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during pump swap operations.

One hour provides sufficient time to safely complete the actual transfer and to complete administrative controls and surveillance requirements associated with the swap. The intent is to minimize the actual time that more than [one] charging pump is physically capable of injection.

Based on its review of TSTF-285-A, Insert 1, the NRC staff confirmed that the licensee's proposed revision is consistent with the TSTF. The licensee's proposed LCO Note will similarly minimize the actual time that more than one or two charging pumps at a time will be physically capable of injection.

The licensee provided additional justification, as discussed in Section 3.2 of this safety evaluation, which would mitigate the possible impact of having both ECCS CCPs and the NCP capable of injecting into the RCS during a pump swap. Therefore, the NRC staff determined that having two ECCS CCPs capable of injection for pump swap conditions remains acceptable. In the NRC staff's safety evaluation for Callaway License Amendment No. 124 dated April 2, 1998 (ADAMS Accession No. ML021640371), the staff discussed that one ECCS CCP and the NCP could be operable consistent with LCO 3.5.4.5. Specifically, Section 2.2.1 of the evaluation states, in part, The mass input transient analysis assumes simultaneous injection of both a centrifugal charging pump and the "normal" charging pump into the water-solid RCS while the RHRS [residual heat removal system] and the letdown line are isolated.

This assumption is consistent with LCO 3.5.4, which requires all safety injection pumps and one of the two centrifugal charging pumps to be inoperable while in MODE 5 and MODE 6 operation with the reactor vessel head on, and therefore, allows a centrifugal charging pump and the "normal" charging pump to be operable under these modes of operation.

In Callaway License Amendment No. 133 dated May 28, 1999 (ADAMS Accession No. ML021640446), the licensee converted from custom TSs (CTS) to Improved Technical Specifications (ITS). As part of this change, the TS LCO for COMS was relocated from TS 3.5.4 to TS 3.4.12. The safety evaluation for License Amendment No. 133, page 41, states that, "The initial conditions and assumptions for the COMS mass addition and heat injection transients will be unchanged." The evaluation also approved the relaxation to allow both ECCS CCPs to be capable of injecting into the RCS during pump swap operations during Mode 4: Note 1 on centrifugal charging pump (CCP) swap operations is a relaxation of the CTS in Modes 4 only because it allows both CCPs to be capable of injecting into the RCS for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> throughout applicability to the low temperature overpressure protection provided by the COMS. This is different from the CTS and the STS [Standard Technical Specifications].

Based on the NRC staff's safety evaluations for License Amendment Nos. 124, 133, and 168, the proposed change to TS 3.4.12 in this amendment is consistent with the staff's previous approvals that reflect that the Callaway mass input transient analysis assumes that an ECCS centrifugal charging pump and the normal charging pump are capable of injecting into the reactor coolant system, when TS 3.4.12 is applicable (i.e., Mode 4 with any RCS cold leg temperature s 275°F, Mode 5, Mode 6 when the reactor vessel head is on). The staff determined that the LCO as proposed will specify the lowest functional capability or performance equipment for safe operation of the facility as required by 10 CFR 50.36(c)(2)(i).

The staff made this determination because the LCO aligns with the safety analysis provided by the licensee with respect to the assumed mass input sources in the analysis.

The LCO, as proposed, will restrict the available mass input sources to be consistent with those assumed in the safety analysis, which is consistent with 10 CFR 50.36(c)(2)(ii)(B) in that the LCO will restrict operation to the initial condition assumed in the mass input transient analysis, as previously approved in Amendment Nos. 124, 133, and 168. This restriction, in turn, assures that the reactor coolant system will not exceed the pressure/temperature limits required by 10 CFR Part 50, Appendix G. Based on these considerations, the NRC staff determined that the proposed LCO revisions are acceptable. The licensee also proposed a change unrelated to the COMS to revise TS Table 3.3.1-1, "Reactor Trip System Instrumentation," to remove page number references which currently refer to pages 3.3-23 and 3.3-24, instead of to the correct pages 3.3-25 and 3.3-26, respeCtively.

The proposed revision would refer to the "end of the table" instead of to a specific page number. This change is considered administrative and is, therefore, acceptable.

3.4 Conclusion Based on the above, the NRC staff determined that the proposed changes to Callaway TS 3.4.12 and TS Table 3.3.1-1 will continue to comply with 10 CFR 50.36 and 10 CFR Part 50, Appendix G and, therefore, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment.

The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in Federal Register on April 1, 2014 (79 FR 18348). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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. Principal Contributor:

D. Saenz, NRR/DSS/SRXB Date: January 20, 2015 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251 January 20, 2015

SUBJECT:

CALLAWAY PLANT, UNIT 1 -ISSUANCE OF AMENDMENT RE: REVISION TO TECHNICAL SPECIFICATION 3.4.12, "COLD OVERPRESSURE MITIGATION SYSTEM (COMS)" (TAC NO. MF3391)

Dear Mr. Diya:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 210 to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated January 23, 2014. The amendment revises TS 3.4.12, "Cold Overpressure Mitigation System (COMS)," to reflect the mass input transient analysis that assumes an Emergency Core Cooling System centrifugal charging pump and the normal charging pump capable of injecting into the reactor coolant system when TS 3.4.12 is applicable.

The amendment also revises TS Table 3.3.1-1, "Reactor Trip System Instrumentation," to remove unnecessary page number references.

A copy of the related Safety Evaluation is also enclosed.

The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice. Docket No. 50-483

Enclosures:

Sincerely, IRA/ Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

1. Amendment No. 210 to NPF-30 2. Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL4-1 Reading RidsAcrsAcnw_MaiiCTR Resource RidsNrrDoriDpr Resource RidsNrrDorllpl4-1 Resource RidsNrrDssSrxb Resource RidsNrrDssStsb Resource RidsNrrLAJBurkhardt Resource RidsNrrPMCallaway Resource RidsRgn4MaiiCenter Resource DSaenz, NRR/DSS/SRXB ADAMS Accession No ML 143508239

• memo dated OFFICE NRR/DORL/LPL4-1/PM N RR/DORLILPL4-1/LA N RR/DSS/STSB/BC NRR/DSS/SRXB/BC NAME Flyon JBurkhardt REIIiott CJackson*

DATE 12/24/14 12/24/14 12/31/14 12/5/14 OFFICE OGC-NLO NRR/DORLILPL4-1/BC(A)

NRR/DORLILPL4-1/PM NAME A Ghosh EOesterle Flyon DATE 1/15/15 15/17115 1/20/15 OFFICIAL RECORD COPY