ML24158A523

Application to Revise Technical Specifications to Adopt Tstf-569, Rev. 2, Revise Response Time Testing Definition

ML24158A523
Person / Time
Site:	Callaway
Issue date:	06/06/2024
From:	Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML24158A521	List: ML24158A523 ML24158A524 ML24158A525 ULNRC-06880, Application to Revise Technical Specifications to Adopt Tstf-569, Rev. 2, Revise Response Time Testing Definition (LDCN 24-0008)
References
ULNRC-06880
Download: ML24158A523 (1)

Text

Enclosure to ULNRC-06880 Page 1 of4 ENCLOSURE Application to Revise Technical Specifications to Adopt T$TF-569, Rev. 2, Revise Response time Testing Definition 1.

DESCRIPTION 2.

ASSESSMENT a.

Applicability of Safety Evaluation 5.

Variations 3.

REGULATORY ANALYSIS a.

No Significant Hazards Consideration Determination b.

Conclusions 4.

ENVIRONMENTAL EVALUATION

Enclosure to ULNRC-06880 Page 2 of 4 1.

DESCRIPTION Ameren Missouri requests adoption ofTSTF-569, Rev. 2, Revise Response Time Testing Definition, which is an approved change to the Improved Standard Technical Specifications (ISTS), for the Callaway Plant Technical Specifications (TS). The proposed amendment revises the TS Definitions for Engineered Safety feature (ESf) Response Time and Reactor Trip System (RTS) Response Time in Section 1. 1 of the Technical Specifications.

2.

ASSESSMENT a.

Applicability of Safety Evaluation Ameren Missouri has reviewed the Safety Evaluation for TSTF-569, Rev. 2, as provided by the Nuclear Regulatory Commission (NRC) staffto the Technical Specifications Task Force in a letter dated August 14, 2019 (ADAMS Accession No. ML19176A188). This review included a review ofthe NRC staffs evaluation, as well as the information provided in TSTF-569, Rev. 2.

As described herein, Ameren Missouri has concluded that the justifications presented in TSTF 569, Rev. 2 and the safety evaluation prepared by the NRC staff are applicable to Callaway Plant Unit 1 andjustify this amendment for the incorporation of the changes to the Callaway Plant Technical Specifications.

b.

Variations Ameren Missouri is not proposing any variations from the TS changes described in TSTF-569, Rev. 2, or the applicable parts of the NRC staffs safety evaluation dated August 14, 2019.

3.

REGULATORY ANALYSIS a.

No Significant Hazards Consideration Determination Ameren Missouri requests adoption of TSTF-569, Revise Response Time Testing Definition, Rev. 2, which is an approved change to the Improved Standard Technical Specifications (IST$), for the Callaway Plant Unit 1 Technical Specifications (TS). The proposed amendment revises the TS Definitions for Engineered Safety feature (ESF) Response Time and Reactor Trip System (RTS) Response Time in Section 1.1 ofthe Technical Specifications.

Ameren Missouri has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1.

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

Response: No The proposed change revises the TS Definition of Reactor Trip System (RTS) Response Time and Engineered Safety feature (ESF) Response Time to permit Callaway personnel to evaluate using an NRC-approved methodology and apply a bounding response

Enclosure to ULNRC-06880 Page 3 of4 time for some components in lieu of measurement. The requirement for the instrumentation to actuate within the response time assumed in the accident analysis is unaffected.

The response time associated with the RTS and E$F instrumentation is not an initiator of any accident. Therefore, the proposed change has no significant effect on the probability of any accident previously evaluated.

The affected RTS and E$F instrumentation are assumed to actuate their respective components within the required response time to mitigate accidents previously evaluated.

Revising the TS definition for RTS and ESF instrumentation response times to allow an NRC-approved methodology for verifying response time for some components does not alter the surveillance requirements that verify the RT$ and E$F instrumentation response times are within the required limits. As such, the T$ will continue to assure that the RTS and ESF instrumentation actuate their associated components within the specified response time to accomplish the required safety functions assumed in the accident analyses.

Therefore, the assumptions used in any accidents previously evaluated are unchanged and there is no significant increase in the consequences.

2.

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

Response: No The proposed change revises the TS Definition of ??Reactor Trip System (RTS) Response Time and Engineered Safety feature (ESF) Response Time to permit Callaway personnel to evaluate components using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change does not involve a physical alteration ofthe plant (i.e., no new or different type of equipment will be installed). The proposed change does not alter any assumptions made in the safety analyses. The proposed change does not alter the limiting conditions for operation for the RTS or ESF instrumentation, nor does it change the Surveillance Requirement to verify the RTS and ESF instrumentation response times are within the required limits. As such, the proposed change does not alter the operability requirements for the RTS and ESF instrumentation, and therefore, does not introduce any new failure modes.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the TS Definition of Reactor Trip System (RTS) Response Time and Engineered Safety Feature (ESF) Response Time to permit Callaway personnel to evaluate using an NRC-approved methodology and apply a bounding response time for some components in lieu of measurement. The proposed change has no effect on the required RTS and ESF instrumentation response times or setpoints assumed in the

Enclosure to ULNRC-06880 Page 4 of 4 safety analyses and the TS requirements to verify those response times and setpoints. The proposed change does not alter any Safety Limits or analytical limits in the safety analysis.

The proposed change does not alter the TS operability requirements for the RTS and ESF instrumentation. The RTS and ESF instrumentation actuation of the required systems and components at the required setpoints and within the specified response times will continue to accomplish the design basis safety functions of the associated systems and components in the same manner as before. As such, the RTS and ESF instrumentation will continue to perform the required safety functions as assumed in the safety analyses for all previously evaluated accidents.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

b.

Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions 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.

4.

ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 1 0 CFR 5 1.22(c)(9). Therefore, pursuant to 10 CFR 5 1.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.