Text

One-Time Completion Time Extension for Essential Service Water (ESW) System
	ML073100488
Person / Time
Site:	Callaway
Issue date:	10/31/2007
From:	Graessle L; AmerenUE
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ULNRC-05445
	Download: ML073100488 (90)
	v • d • e

AmerenUE P0 Box 620 Cal/awayPlant Fulton, MO 65251 October 31, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC-05445 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC CO.

"Ameren APPLICATION FOR AMENDMENT TO I/E FACILITY OPERATING LICENSE NPF-30 ONE-TIME COMPLETION TIME EXTENSION FOR ESSENTIAL SERVICE WATER (ESW) SYSTEM

Reference:

ULNRC-05434 dated August 30, 2007, "10CFR50.55a Request:

Proposed Alternative to ASME Section XI Requirements for Replacement of Class 3 Buried Piping," Relief Request to Apply ASME Code Case N-755 to Underground ESW Piping AmerenUE herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant.

This amendment application submits a proposed change to Technical Specification (TS) 3.7.8, "Essential Service Water (ESW) System," that will add a Note to the Completion Time of Required Action A. 1 for restoration of an inoperable ESW train to OPERABLE status. This new Note would allow a one-time Completion Time extension from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days per ESW train to be used prior to December 31, 2008, for replacing underground ESW piping. The same change is requested for the Completion Time of Required Action B. 4 of TS 3.8.1, "AC Sources -

Operating." This is a risk-informed amendment request following the guidance of NRC Regulatory Guides 1.174 and 1.177. In addition, the second Completion Time for TS 3.8.1 Required Action B.4 is deleted per NRC-approved TSTF-439-A Revision 2.

Attachments 1 through 6 provide the Evaluation, Markup of Technical Specifications, Retyped Technical Specifications, Proposed Technical Specification Bases changes, Copy of TSTF-439-A, Revision 2 with TS 3.8.1 .B.4 Markups and the associated NRC approval letter dated January 11, 2006, and Summary of Regulatory Commitments, respectively, in support of this amendment request. Attachments 4 and 5 are provided for information only. Final Bases changes will be processed under a subsidiaryofAmeren Corporation 3 * -g - -

ULNRC-05445 October 31, 2007 Page 2 Callaway's program for updates per TS 5.5.14, "Technical Specifications Bases Control Program," when the requested amendment is implemented. No commitments, other than those captured in Attachment 6, are contained in this amendment application.

It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the attached licensing evaluations and have approved the submittal of this amendment application.

This amendment application is related to a 10CFR50.55a request submitted by AmerenUE on August 30, 2007 (i.e., the identified Reference), in which relief was requested from applicable ASME Section XI requirements in order to propose an alternative that supports the use of high-density polyethylene piping material for replacement of the existing steel ESW piping. The license amendment requested herein supports that planned piping replacement.

NRC approval of the proposed alternative described in the August 30, 2007 submittal was requested by May 31, 2008. Consistent with that request, AmerenUE requests approval of this proposed license amendment prior to June 1, 2008.

AmerenUE further requests that the license amendment be made effective upon NRC issuance, to be implemented on or before December 31, 2008. This supports the actual implementation period which is intended to occur after the summer 2008 peak loads but outside of Refuel 16 (scheduled to commence on October 11, 2008).

In accordance with 10 CFR 50.91, a copy of this amendment application is being provided to the designated Missouri State official. If you have any questions on this amendment application, please contact me at (573) 676-8129, or Mr. Scott Maglio at (573) 676-8719.

ULNRC-05445 October 31, 2007 Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Very truly yours, Executed on: (: -3 1- 0"7 Luke H. Graessle Manager, Regulatory Affairs

ULNRC-05445 October 31, 2007 Page 4 Attachments 1 - Evaluation 2 - Markup of Technical Specifications 3 - Retyped Technical Specifications 4 - Proposed Technical Specification Bases Changes (for information only) 5 - Copy of TSTF-439-A, Revision 2 with TS 3.8.1.B.4 Markups and NRC Approval Letter dated January 11, 2006 6 - Summary of Regulatory Commitments

ULNRC-05445 October 31, 2007 Page 5 cc:

U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Elmo E. Collins, Jr.

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 O-8G14 Washington, DC. 20555-2738

ULNRC-05445 October 31, 2007 Page 6 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and public disclosed).

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

C. D. Naslund A. C. Heflin L. H. Graessle G. A. Hughes S. A. Maglio S. L. Gallagher L. M. Belsky (NSRB)

T. B. Elwood G. G. Yates Ms. Diane M. Hooper Mr. Dennis Buschbaum Supervisor, Licensing TXU Power WCNOC Comanche Peak SES P.O. Box 411 P.O. Box 1002 Burlington, KS 66839 Glen Rose, TX 76043 Mr. Scott Bauer Mr. Stan Ketelsen Regulatory Affairs Manager, Regulatory Services Palo Verde NGS Pacific Gas & Electric P.O. Box 52034 Mail Stop 104/5/536 Mail Station 7636 P.O. Box 56 Phoenix, AZ 85072-2034 Avila Beach, CA 93424 Mr. Scott Head Mr. John O'Neill Supervisor, Licensing Pillsbury Winthrop Shaw Pittman LLP South Texas Project NOC 2300 N. Street N.W.

Mail Code N5014 Washington, DC 20037 P.O. Box 289 Wadsworth, TX 77483 Floyd Gilzow Deputy Director Missouri Public Service Department of Natural Resources Commission P.O. Box 176 Governor Office Building Jefferson City, MO 65102 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360

Attachment 1 Attachment I To ULNRC-05445 Page 1 of 22 EVALUATION

1. DESCRIPTION Page 2

2. PROPOSED CHANGES Page 2

3. BACKGROUND Page 3

4. TECHNICAL ANALYSIS Page 9

5. REGULATORY SAFETY ANALYSIS Page 16 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION Page 17 5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA Page 19

6. ENVIRONMENTAL CONSIDERATION Page 21

7.1 REFERENCES

Page 22 7.2 PRECEDENT Page 22

Attachment I Attachment I Page 2 of 22 To ULNRC-05445 EVALUATION

1.0 DESCRIPTION

This amendment application submits a proposed change to Technical Specification (TS) 3.7.8, "Essential Service Water (ESW) System," that would allow a one-time Completion Time extension from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days per ESW train to be used prior to December 31, 2008, for replacing underground ESW piping. The same change is requested for the Completion Time of Required Action B. 4 of TS 3.8.1, "AC Sources - Operating." This is a risk-informed amendment request following the guidance of NRC Regulatory Guides 1.174 and 1.177 (see References 1 and 2). In addition, the second Completion Time for TS 3.8.1 Required Action B.4 is deleted per NRC-approved TSTF-439-A Revision 2.

2.0 PROPOSED CHANGE

S The proposed change to TS 3.7.8, "Essential Service Water (ESW) System," will add a Note to the Completion Time of Required Action A. 1 that requires the restoration of an inoperable ESW train to OPERABLE status. This new Note would allow a one-time Completion Time extension from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days per ESW train to be used prior to December 31, 2008 for replacing underground ESW piping. The new Note would read:

"A one-time Completion Time of 14 days per ESW train is allowed prior to December 31, 2008."

Catawba License Amendment 228/223 is cited in Section 7.2 of this Evaluation as a precedent for this amendment request; however, there are plant-specific design (Callaway will be using a polyethylene piping replacement) and PRA differences, as well as the following differences in approach.

Catawba received a one-time Completion Time of 14 days. Callaway is also requesting a one-time Completion Time of 14 days. However, Catawba revised the TSs for the systems supported by ESW to reflect the one-time Completion Time extension.

Callaway is requesting changes only to TS 3.7.8 and TS 3.8.1. Required Action A.1 of TS 3.7.8 has two Notes that are directed cascades to LCOs 3.4.6 and 3.8.1. All of the Required Actions of LCO 3.4.6 have immediate Completion Times, to either immediately initiate restoration actions or to suspend dilutions. As such, no changes are required to LCO 3.4.6. However, since Condition B of LCO 3.8.1 addresses an inoperable diesel generator (DG), a change to the Completion Time for Required Action B.4 in Condition B is required since TS 3.7.8 directs that the DG associated with an inoperable ESW train likewise be declared inoperable., For all other systems supported by ESW, LCO 3.0.6 is applicable, i.e., "when a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are

Attachment 1 To ULNRC-05445 Page 3 of 22 required to be entered." As such, changes to only TS 3.7.8 and TS 3.8.1 are requested in this amendment application and similar Notes are used in both LCOs.

In addition, the second Completion Time for TS 3.8.1 Required Action B.4 ("AND 6 days from discovery of failure to meet LCO") is deleted per NRC-approved TSTF-439-A Revision 2. The second Completion Times in the Improved Standard TS (ISTS) became a problem when the nuclear industry proposed permanent, risk-informed Completion Times for some of the Specifications which contained the second Completion Times, specifically TSTF-409, Containment Spray System Completion Time Extension (CE NPSD-1045-A), and TSTF-430, AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1). These Travelers extended a Completion Time and, following prior NRC guidance, the second Completion Time was extended by the same amount (i.e., the second Completion Time continued to be the sum of the two Completion Times). However, in letters to the TSTF dated November 15, 2001 and September 10, 2002, the NRC stated that the extension of the second Completion Time in TSTF-409 and TSTF-430 was inappropriate because one of the two Completion Times added to obtain the second Completion Time limit was risk based and the other was deterministic. On September 10, 2002, the NRC provided a letter making a similar statement regarding TSTF-430. Eventually, the NRC accepted that it was acceptable to add these two Completion Times and TSTF-409 and TSTF-430 were approved. However, second Completion Times complicate the presentation of the ISTS and complicate the implementation of risk-informed Completion Times. In addition, other regulatory requirements, not present when the ISTS NUREGs were originally developed (i.e., the 10 CFR 50.65 Maintenance Rule and the Reactor Oversight Process, as discussed in the copy of TSTF-439-A Revision 2), eliminate the need for these second Completion Times. In Reference 3, NRC accepted TSTF-439-A Revision 2 and noted that it was incorporated into Revision 3.1 of the ISTS.

The only change per TSTF-439-A included in this amendment application is the change to TS 3.8.1 Required Action B.4. The remaining changes from TSTF-439-A are being pursued separately as a joint STARS project.

Associated Bases changes for the above will also be made per TS 5.5.14.

3.0 BACKGROUND

The ESW system provides a heat sink for the removal of process and operating heat from safety-related components during a Design Basis Accident (DBA) or transient. During normal operation, and a normal shutdown, the ESW system also provides this function for various safety-related and non-safety related components and receives coolant flow from the non-safety related Service Water System.

The ESW system consists of two separate, 100% capacity, safety-related, cooling water trains. Each train consists of a self-cleaning strainer, prelube tank, one 100% capacity

Attachment 1 Attachment I To ULNRC-05445 Page 4 of 22 pump, piping, valving, and instrumentation. The pumps and valves are remote and manually aligned, except in the unlikely event of a loss of coolant accident (LOCA). The pumps are automatically started upon receipt of a safety injection signal, low suction pressure to the auxiliary feedwater pumps, or loss of offsite power. Upon receipt of one of these signals, the automatically actuated essential valves are aligned to their post-accident positions as required. The ESW system also provides emergency makeup to the spent fuel pool and component cooling water (CCW) system and is the backup water supply to the auxiliary feedwater (AFW) system.

Additional information about the design and operation of the ESW system, along with a list of the components served, is presented in FSAR Section 9.2.1.2. The principal safety-related function of the ESW system is the removal of decay heat from the reactor via the CCW system and removal of containment heat loads via the containment coolers.

The design basis of the ESW system is for one ESW train, in conjunction with the CCW system and a 100% capacity containment cooling system, to remove accident generated and core decay heat following a design basis LOCA as discussed in FSAR Section 6.2.

This prevents the containment sump fluid from increasing in temperature during the recirculation phase following a LOCA and provides for a gradual reduction in the temperature of this fluid as it is supplied to the reactor coolant system by the ECCS pumps. The ESW system is designed to perform its function with a single failure of any active component, assuming the loss of offsite power.

The ESW system, in conjunction with the CCW system, also cools the unit from residual heat removal (RHR) entry conditions to MODE 5 during post accident operations or during a cooldown using only safety-grade equipment, as discussed in FSAR Section 5.4.7. The time required for this evolution is a function of the number of ESW pumps, CCW heat exchangers, and RHR system trains that are operating. One ESW system train is sufficient to remove decay heat during subsequent operations in MODES 5 and 6. This assumes a maximum ESW temperature of 95°F occurring simultaneously with maximum heat loads on the system.

The ESW system satisfies Criterion 3 of 10CFR50.36(c)(2)(ii).

Proposed Polyethylene Piping Design Change To address the need for, and adequacy of, the requested amendment, the following information is provided.

In order to address an identified plant health risk tracked for the ESW system (with a designation number EF-03-07), which has manifested itself in numerous pinhole leaks and other localized degradation of the ESW piping due to microbiologically induced corrosion (MIC), a decision has been made to replace the buried ESW carbon steel ASME Class 3 piping with piping using polyethylene (PE) material. Replacement of the current steel ESW piping with PE piping would provide an overall benefit to plant safety

Attachment I Attachment I To ULNRC-05445 Page 5 of 22 since PE piping is much more resistant to fouling and MIC, thus assuring improved long-term reliability of the risk-significant ESW system.

The Callaway ESW system was originally designed with unlined carbon steel piping.

Plant-specific and industry operating experience has shown that carbon steel piping is susceptible to fouling, corrosion, and MIC for raw water applications.

The use of corrosion resistant steel piping provides added resistance to these problems, but does not eliminate susceptibility. Alternatively, the use of internal linings or coatings in carbon steel piping provides resistance to these problems. However, degradation of and/or damage to the linings and coatings can cause exposure of the carbon steel piping to the raw water, resulting in piping degradation. Additionally, the linings and coatings can pose a potential foreign material concern if they are released from the piping wall as a result of the degradation or damage.

Polyethylene piping pipe will not rust, rot, pit, corrode, tuberculate, or support biological growth. The use of polyethylene piping in raw water applications will thus ensure long term reliability from a structural integrity and flow standpoint.

Callaway has recently installed approximately 600 linear feet of 36-inch diameter buried polyethylene piping in a non-safety related blowdown application and has not experienced any significant problems. On a larger scale, Duke Power Company has installed 20,000 linear feet of polyethylene piping at Catawba Nuclear Station in non-safety related raw water applications. Since the installations began in 1998, Duke Power Company has reported that the material has had an excellent service history and has not experienced fouling or corrosion.

ASME Code Case N-755 provides conditions under which PE material may be used for ASME Section III, Class 3 buried piping systems. A relief request to utilize ASME Code Case N-755, with justified materials and design exceptions, has been submitted separately (see Reference 4).

Need for Change The ESW piping replacement can not be completed within the current 72-hour Completion Times allowed under LCOs 3.7.8 and 3.8.1 which are applicable in MODES 1-4. The extent and nature of the compensatory measures that are needed in order to minimize exposure to risk, and the reductions in defense in depth, make it impractical to justify the proposed change on a permanent basis in accordance with References I and 2.

Performing the connection of the new PE ESW piping with the rest of the ESW system during Refuel 16 could be contrary to safety since proper management and project coordination is more difficult during an outage setting. In addition, more systems are available for decay heat removal and accident mitigation at power. If this work were performed during Refuel 16, it would have to be done in MODES 5 or 6 or with the reactor defueled where the RHR system is the only means of removing decay heat. If this

Attachment 1 Attachment I Page 6 of 22 To ULNRC-05445 work is performed outside the outage, as requested by way of this one-time Completion Time extension, it can be done with the full emphasis of the plant staff brought to bear on the modification and with the full complement of heat removal systems available during normal power operation.

Compliance with Current Regulations This amendment request itself does not propose to deviate from existing regulatory requirements, and compliance with existing regulations is maintained by the proposed one-time change to the TS requirements. The associated relief request (Reference 4) follows 10 CFR 50.55a(a)(3)(i) for alternatives that provide an acceptable level of quality and safety and will be judged on its merits separately.

Evaluation of Safety Margins Safety analysis acceptance criteria for the events analyzed in FSAR Chapters 6.2 and 15 are not impacted by the proposed change. A one-time ESW Completion Time extension does not impact any of the assumptions or inputs to the safety analyses. Design exceptions are requested against Code Case N-755 in Reference 4; however, the proposed design will result in improved ESW system performance and enhanced system reliability, and will satisfy the criteria of 10 CFR 50.55a(a)(3)(i). Consequently, safety margins are not affected.

Defense in Depth RG 1.177 contains several attributes that should be examined when requesting risk-informed changes to TS requirements. The following discussion considers those attributes.

A reasonable balance among prevention of core damage, prevention of containment failure, and consequence mitigation is preserved.

The proposed change involves a one-time extension of the current TS 3.7.8 and TS 3.8.1 Completion Times for the ESW piping modification project. The systems that are affected during a particular ESW LCO outage are all associated with the train that corresponds to the affected ESW train, leaving one train of safety equipment fully operable and capable of performing its safety functions. In addition, as shown on FSAR Figure 9.2-2 sheet 1 (P&ID M-22EF01 grid points E-6 and F-6), the normal service water (EA) system will be cross-connected through supply valves EFHV0023 and EFHV0025 to the 'A' train ESW loads (EFI-V0024 and EFHV0026 for the 'B' train ESW load supply) during a portion of the extended Completion Times for each train, as discussed further under Tier 2 in Section 4.0 of this Evaluation. The connection from the ultimate heat sink (UHS) via the ESW pumps will be isolated during this portion of the extended Completion Time as well. Flow from the cooled 'A' train ESW loads will return to the normal service water system via return valves EFHV0039 and EFHV0041 (EFHV0040 Attachment 1 Page 7 of 22 To ULNRC-05445 and EFHV0042 for the 'B' train load return) during this portion of the extended Completion Times for each train, as discussed further under Tier 2 in Section 4.0 of this Evaluation (see FSAR Figure 9.2-1 sheet 2, P&ID M-22EF02 grid points D-2, E-2, and F-2). Automatic closure signals for these cross-connect valves will be defeated during this portion of the 14-day Completion Time to assure there will be no loss of EA system flow to the affected ESW train loads. In addition, automatic open signals for the return valves from the ESW system to the UHS (EFHV0037 and EFHV0038, P&ID M-22EF02 grid points C-2 and G-2) will be defeated during this portion of the 14-day Completion Time to assure there will be no diversion of EA system return flow to the UHS.

Preserving the operability of one ESW train and serving the inoperable ESW train's loads from the normal service water system during this portion of the 14-day Completion Time will maintain the balance among the prevention of core damage, prevention of containment failure, and consequence mitigation.

Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided.

The proposed change involves a one-time extension of the current TS 3.7.8 and TS 3.8.1' Completion Times for the ESW piping modification project. The systems that are affected during a particular ESW LCO outage are all associated with the train that corresponds to the affected ESW train, leaving one train of safety equipment fully operable and capable of performing its safety functions. The proposed extension of the Completion Time (11 day increase to 14 days per ESW train vs. the current 3-day Completion Time)-results in a corresponding increase in the amount of time that the redundancy that is normally afforded by the other (inoperable) ESW train will not be available, thereby increasing the amount of time that safety systems are vulnerable to single failures. However, as discussed above, the normal service water (EA) system will be cross-connected to supply the inoperable ESW train loads during a portion of the extended Completion Times for each train, although the pumped flow from the normal service water system would be unavailable if a loss of offsite power were to occur during this 14-day Completion Time. Steps will be taken to minimize the likelihood of losing offsite power during the use of this one-time Completion Time extension.

Compensatory measures discussed under Tier 2 in Section 4.0 of this Evaluation include programmatic activities. However, because this is a one-time change of limited duration, some use of programmatic activities can be credited for minimizing the risks involved and for maintaining defense-in-depth.

System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers).

The operable train of safety equipment will continue to be capable of performing the necessary safety functions consistent with accident analysis assumptions. The new ESW piping will continue to satisfy the plant design criteria, including the criteria for seismic Attachment 1 Page 8 of 22 To ULNRC-05445 qualification. Compensatory measures discussed under Tier 2 in Section 4.0 of this Evaluation will assure the availability and capability of the operable train of safety equipment while operating in the allowed outage period, including (for example) the avoidance of severe weather situations and periods of grid instability as well as restricting switchyard access and eliminating work in the switchyard. The compensatory measures will also maintain the functional capability of the inoperable ESW train during the time that the normal service water system is functional, as long as offsite power is available.

Therefore, sufficiently redundant, independent, and diverse capabilities will be maintained for performing critical safety functions during the one-time proposed Completion Time extension.

Defenses against potential common cause failures are preserved and the potential for the introduction of new common cause failure mechanisms is assessed.

As discussed in the previous bullet, compensatory measures will be established to assure the availability and capability of redundant, independent, and diverse means of accomplishing critical safety functions during the one-time proposed Completion Time extension. The compensatory measures include avoiding (to the extent possible) severe weather conditions and periods of grid instability when in the proposed Completion Time extension. Compensatory measures discussed under Tier 2 in Section 4.0 of this Evaluation will assure the functional capability of the inoperable ESW train by supplying those loads from the normal service water (EA) system when it is functional, as long as offsite power is available. Steps will be taken to minimize the likelihood of losing offsite power during the use of this one-time Completion Time extension. As such, appropriate measures will be taken to preserve defenses against potential common, cause failures and no new common cause failure mechanisms will be introduced.

Independence of barriers is not degraded.

As discussed above in the third and fourth bullets, additional means of achieving and maintaining safe shutdown conditions will be maintained during the proposed one-time Completion Time extension. These means are independent, redundant, and diverse and, consequently, they should prevent any undue challenges to the fuel cladding, reactor coolant pressure boundary, and containment from occurring. Additionally, the ESW piping modification does not directly impact these barriers or otherwise cause them to be degraded. Therefore, the independence of barriers will not be degraded by the one-time proposed Completion Time extension.

0 Defenses against human errors are preserved.

Compensatory measures discussed under Tier 2 in Section 4.0 of this Evaluation will assure that critical safety functions will be maintained during the proposed Completion Time extension. The compensatory measures include operator training to assure that the operating staff is fully aware of the plant configuration and actions that may be needed in order to respond to problems that could arise during the proposed one-time Completion

Attachment I Attachment I To ULNRC-05445 Page 9 of 22 Time extension for performing the ESW piping modification. Compensatory measures will also be established to prohibit discretionary maintenance on PRA-modeled equipment. These measures will assure that the defenses against human errors will be adequately preserved during the proposed Completion Time extension.

The intent of the GDC in Appendix A to 10 CFR Part 50 is maintained.

The proposed change involves an extension of the current TS Completion Times for systems that are impacted by the ESW piping modification project. The systems that are affected during a particular ESW LCO outage are all associated with the train that corresponds to the affected ESW train, leaving one train of safety equipment fully operable and capable of performing its safety functions. The proposed change does not modify the plant design bases or the design criteria that were applied to structures, systems, and components during plant licensing. Consequently, the plant design with respect to the General Design Criteria is not affected by the proposed change.

4.0 TECHNICAL ANALYSIS

Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," describes a risk-informed approach, acceptable to the NRC, for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations.

RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," describes an acceptable risk-informed approach specifically for assessing proposed permanent TS changes in allowed outage times, referred to in TS parlance as Completion Times. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations.

One acceptable approach to making risk-informed decisions about proposed TS changes is to show that the proposed changes meet the five key principles stated in RG 1.174, Section 2 and RG 1.177, Section B, also listed in Section 5.2 of this Evaluation. The first three of the key principles have been addressed in Section 3.0 of this Evaluation. The remaining two key principles are addressed in this section.

For permanent TS changes, RG 1.174 and RG 1.177 provide numerical risk acceptance guidelines that are helpful in determining whether or not the fourth key principle (small risk increases consistent with the intent of the Commission's Safety Goal Policy Statement) has been satisfied. These guidelines are not intended to be applied in an overly prescriptive manner; rather, they provide an indication, in numerical terms, of what is considered acceptable. The intent in comparing risk results with the risk acceptance guidelines is to demonstrate with reasonable assurance that the fourth key

Attachment I Attachment I Page 10 of 22 To ULNRC-05445 principle has been satisfied.

The risk evaluation presented below addresses the last two key principles of the NRC staff's philosophy of risk-informed decision-making, which concern changes in risk and performance measurement strategies. These key principles were evaluated by using the three-tiered approach described in Chapter 16.1 of the SRP and RG 1.177.

Tier I - The first tier evaluates the Callaway PRA and the impact of the change on plant operational risk, as expressed by the change in core damage frequency (CDF) and the change in large early release frequency (LERF). The change in risk is compared against the acceptance guidelines presented in RG 1.174. The first tier also aims to ensure that plant risk does not increase unacceptably during the period when equipment is taken out of service per the license amendment, as expressed by the incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP). The incremental risk is compared against the acceptance guidelines presented in RG 1.177.

Tier 2 - The second tier addresses the need to preclude potentially high-risk plant configurations that could result if equipment, in addition to that associated with the proposed license amendment, is taken out of service simultaneously, or if other risk-significant operational factors such as concurrent system or equipment testing, are also involved. The objective of this part of the review is to ensure that appropriate restrictions on dominant risk-significant plant configurations associated with the CT extension are in place.

Tier 3 - The third tier addresses Callaway's overall configuration risk management program (CRMP) to ensure that adequate programs and procedures are in place for identifying risk-significant plant configurations resulting from maintenance or other operational activities and taking appropriate compensatory measures to avoid such configurations. The purpose of the CRMP is to ensure that equipment removed from service prior to or during the proposed extended CT period will be appropriately assessed from a risk perspective.

For temporary TS changes such as that requested in this amendment application, examination of the risk metrics identified in RG 1.174 and RG 1.177 provides insight about the potential risk impacts, even though neither of these RGs provides numerical risk acceptance guidelines for evaluating temporary TS changes against the fourth key principle. It can be demonstrated with reasonable assurance that a temporary TS change meets the fourth key principle if its associated risk metrics:

Satisfy the risk acceptance guidelines in RG 1 .174 and RG 1.177, or

Are not substantially above the risk acceptance guidelines in RG 1.174 and RG 1.177 and effective compensatory measures to maintain lower risk are

Attachment I Attachment I Page I I of 22 To ULNRC-05445 implemented while the temporary TS change, is in effect.

The discussion that follows addresses Tiers 1, 2, and 3 of RG 1.177.

Tier 1, PRA Capability and Insights PRA Capability:

The PRA model used to calculate the core damage risk metrics associated with the requested one-time ESW Completion Time extension is the Callaway Fourth PRA Update, i.e., the fourth revision to the Callaway PRA model, which was originally developed to meet the Individual Plant Examination (IPE) requirement. The Fourth PRA Update was completed in April, 2006, and was undertaken primarily to meet the PRA quality and quantification truncation limit requirements associated with the Mitigating System Performance Index (MSPI).

Updates to the Callaway PRA are controlled by an administrative procedure which includes provisions for monitoring plant changes that could affect the PRA model. The procedure requires an update of the PRA model, to maintain fidelity between the model and actual plant design and operation, at a minimum frequency of every 36 months, or when a plant change is made that would significantly impact the PRA model.

The Callaway PRA has undergone two peer reviews; a review sponsored by the Westinghouse Owners' Group (WOG), which followed NEI-00-02, "Industry PRA Peer Review Process," and a review by Scientech, LLC, against the ASME PRA standard

[ASME RA-S-2002,"Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications" (April 5, 2002), Addendum A to this standard (ASME RA-Sa-2003, December 5, 2003), and Addendum B to this standard (ASMiE RA-Sb-2005, December 30, 2005)A. The WOG peer review generated 4 significance level A Facts and Observations (F&Os) and 28 significance level B F&Os. Of these, 5 (one A and four B)

F&Os have not yet been addressed; however, none of these open F&Os would have a direct impact on the PRA insights developed for this application. The findings from the Scientech review (i.e., gap analysis) against the ASME PRA standard have not yet been addressed in the Callaway PRA model. However, the types of gaps identified, and level of effort estimated to be necessary to address these gaps, are not atypical. Further, AmerenUE does not believe that the gap analysis findings invalidate the PRA insights developed to support this license amendment request.

The Fourth Update Model, used for this application, is an internal events PRA model.

The model does not include internal flooding, fires or seismic events. To meet the Individual Plant Examination of External Events (IPEEE) requirement; Callaway utilized the Electric Power Research Institute's (EPRI's) Seismic Margins Assessment and Fire Induced Vulnerability Evaluation (FIVE) methodologies. These methodologies, as well as the internal flooding analysis method used for Callaway, are essentially successive Attachment I Page 12 of 22 To ULNRC-05445 screening approaches focused on the identification of associated plant vulnerabilities.

The methodologies do not calculate an overall core damage frequency from seismic, fire or flood events, and do not lend themselves to direct incorporation into the internal events PRA model. The Callaway flooding and fire risk analyses, and seismic assessment, are therefore not integrated into the Fourth PRA Update Model. Consequently, the risk metrics provided below do not include a contribution from these sources. The baseline CDF (non-floods) and LERF (non-floods) are 4.22E-05/yr and 5.97E-07/yr, respectively.

PRA Insights:

The following table provides the risk metrics associated with the requested one-time per ESW train Completion Time extension. Note that the values in the table reflect the entire 14-day Completion Time and take no credit for the Tier 2 commitment to cross-connect the normal service water system during the time it is functional.

ICCDP: 3.87E-06 per 14-day CT Delta-CDF: 7.74E-06 per year ICLERP: 1.01E-07 per 14-day CT Delta-LERF: 2.02E-07 per year As seen in the table, above, each one-time 14-day per ESW train Completion Time results in an ICCDP of 3.87E-06. Since a one-time 14-day Completion Time would be permitted for each train of ESW, the increase in core damage frequency, i.e., delta-CDF, in 2008, attributable to this license amendment request, would be twice the calculated ICCDP, or 7.74E-06 per year. In addition, each 14-day Completion Time results in an ICLERP of 1.01E-7, which, when doubled, results in a delta-LERF, for the two 14-day Completion Times, of 2.02E-7 per year.

Although not applicable, per se, to temporary Technical Specification changes, Regulatory Guides 1.177 and 1.174 provide core damage risk increase acceptance thresholds of 5E-7 (ICCDP) and IE-6 (delta-CDF), respectively. The ICCDP and delta-CDF values reported above for the extended, 14-day ESW Completion Time are not substantially above the acceptance thresholds of these Regulatory Guides for permanent changes to the Technical Specifications. In addition, AmerenUJE will implement the identified compensatory measures during the 14-day Completion Time. These measures will effectively serve to lower the core damage and large early release risk associated with the extended ESW Completion Time.

Attachment 1 To ULNRC-05445 Page 13 of 22 Tier 2. Avoidance of Risk-Si2nificant Plant Configurations In the calculation of ICCDP, delta-CDF, ICLERP and delta-LERF, credit is taken for implementation of the following compensatory measures (except for the first and last items) during the extended, 14-day Completion Time:

" The affected portion of the out-of-service (inoperable) ESW train will be isolated from its associated ESW heat loads, such that the non-safety related normal service water (EA) system can cool these heat loads for most of the 14-day Completion Time.

It is estimated that normal service water will be out of service for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for the 'A' train and 102 hours0.00118 days 0.0283 hours 1.686508e-4 weeks 3.8811e-5 months for the 'B' train during the 14-day Completion Time for piping modifications. Previous modifications to the 'A' train will result in less work than is needed on the 'B' train. The 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for the 'A' train include time to install and remove blind flanges and time to drain and re-flood the system. The 102 hours0.00118 days 0.0283 hours 1.686508e-4 weeks 3.8811e-5 months for the 'B' train include time needed to implement modifications to allow normal service water to supply the standby diesel generators, install a spool piece to restore ESW at the end of the LCO outage, and time to drain and re-flood the system. During the time that normal service water is serving the ESW loads, automatic closure signals for the cross-connect supply and return valves between the EA system and ESW, and automatic open signals for the ESW system return to UHS valves, will be defeated.

" No PRA-modeled equipment, other than the affected ESW train, will be voluntarily taken out-of-service during the extended 14-day ESW Completion Time.

No work will be performed in the Callaway switchyard, and access to the switchyard will be controlled, during the extended 14-day ESW Completion Time. See additional discussion below.

" The ESW Completion Time will not be entered if inclement weather is forecast for the 14-day Completion Time period.

Appropriate training will be provided to operations personnel on this TS change and the associated ESW modification, as well as the compensatory measures to be implemented during the one-time extended Completion Time. No explicit credit was taken in the PRA calculations for this operator training compensatory measure.

The existing program for weather monitoring via the National Weather Service includes various weather monitoring distances depending on the specific equipment that is potentially impacted. Different weather monitoring distances are listed in procedure ODP-ZZ-00002, "Equipment Status Control," Attachment 4, for switchyard activities (140 miles) vs. ESW-related activities (70 miles). Since a loss of offsite power is the most relevant concern for this amendment request, weather monitoring during the use of this one-time Completion Time extension will extend out 140 miles from Callaway Plant.

National Weather Service reports will be monitored prior to and throughout each ESW train LCO outage. If severe weather were to occur during the one-time extended

Attachment I Attachment 1 Page 14 of 22 To ULNRC-05445 Completion Time, personnel notification and appropriate actions would be taken per procedure OTO-ZZ-00012, "Severe Weather." The ESW piping modification will be done in the fall, after the peak time of year for tornadoes (spring) and thunderstorms (summer).

In response to NRC Generic Letter (GL) 2006-02, "Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power," the letters cited in Reference 5 discuss the formal agreement between Ameren and our transmission system operator (Midwest Independent System Operator), the Real Time Contingency Analysis program used by the Midwest ISO and Ameren Transmission Operations, control room notification protocols from the Midwest ISO and Ameren Transmission Operations upon deteriorating or degraded grid conditions, degraded voltage bus setpoints and design provisions, offsite power source operability limits and alarm settings, use of the Callaway Safety Monitor described under Tier 3 in Section 4.0 of this Evaluation for maintenance risk assessments, operator training, and several others issues of concern to NRC in GL 2006-02.

Each ESW train will be taken out of service independently to allow one train to be operable at all times during the one-time proposed extended Completion Time. Should the offsite power system become lost during this 14-day Completion Time, the diesel generator not associated with the inoperable ESW train will be fully operable. This diesel generator will retain automatic start capability and would be used to power its associated 4.16-kV safety bus until the grid could be restored.

The diesel generator for the out-of-service ESW train would be functionally available for use as well, with loads supplied from the normal service water system during the time this system is functional as discussed above, as long as offsite power is available. Steps will be taken to minimize the likelihood of losing offsite power during the use of this one-time Completion Time extension.

The Required Actions of TS 3.8.1 would be followed for any combination of inoperable offsite sources and diesel generators.

The above-identified compensatory measures serve to lessen the increase in the core damage risk when an ESW train is out-of-service. If credit were taken for the normal service water system during the time it is expected to be functional, the ICCDP would decrease to 2.19E-06 and ICLERP would decrease to 2.91E-08.

Since the second compensatory measure that will be taken while an ESW train is out-of-service is that no other PRA-modeled equipment will be voluntarily taken out-of-service, risk-significant plant configurations are inherently avoided. Should an emergent condition arise such that plant equipment becomes inoperable, in addition to the out-of-service ESW train, the associated risk will be assessed and managed in accordance with the Tier 3 program discussed below.

Attachment 1 Attachment I To ULNRC-05445 Page 15 of 22 Tier 3, Risk-Informed Configuration Risk Management Tier 3 requires a proceduralized process to assess the risk associated with both planned and unplanned work activities. The objective of the third tier is to ensure that the risk impact of out-of-service equipment is evaluated prior to performing any maintenance activity. As stated in Section 2.3 of Regulatory Guide 1.177, "a viable program would be one that is able to uncover risk-significant plant equipment outage configurations in a timely manner during normal plant operation." The third-tier requirement is an extension of the second-tier requirement, but addresses the limitation of not being able to identify all possible risk-significant plant configurations in the second-tier evaluation. Programs and procedures are in place at Callaway which serve to address this objective.

In particular, APA-ZZ-00315, "Configuration Risk Management Program," and EDP-ZZ-01129, "Callaway Plant Risk Assessment," are an integral part of the work management process at the plant. The Configuration Risk Management Program (CRMP) ensures that configuration risk is assessed (using the PRA-based Safety Monitor, a computer-based program for assessing the impact on plant safety of out of service equipment) and managed prior to initiating any maintenance activity consistent with the requirements of 10 CFR 50.65(a)(4). The ESW system, diesel generators, and safety systems serviced by ESW are within the scope of Callaway's maintenance rule program and have availability and reliability criteria established to monitor performance. The CRMP also ensures that, risk is reassessed if an emergent condition results in a plant configuration that has not been previously assessed.

Under the CRMP, using the associated Safety Monitor, risk thresholds were established to ensure that average baseline risk is maintained within an acceptable band. The four bands used in this program are:

" Green - Key safety functions are at minimum risk. TS LCOs are met.

" Yellow - A key safety function is in a reduced capability. The plant's ability to perform the associated safety function is reduced but still acceptable. Risk Management Action may be required prior to planned entry. For unplanned entry, Risk Management Action plan must be implemented as soon as possible. Plant and equipment availability conditions meet the TS without reliance on the action statements and the minimum equipment requirements.

" Orange - Key safety functions are degraded and steps should be taken to minimize the amount of time in this condition. Risk Management Action plan and specific approval are required prior to planned entry. For unplanned entry, Initiation of a Risk Management Action Plan and Plant Director/EDO notification are required. Approval Forms and Risk Management Action Plans are contained in APA-ZZ-00322, Integrated Work Management Process Description.

Attachment I Attachment 1 To ULNRC-05445 of 22 Page 16 Red - Key safety functions are severely threatened. Immediate actions are required to restore acceptable plant risk. Planned entry is NOT allowed. For unplanned entry, Initiation of a Risk Management Action Plan and Plant Director/EDO notification is required.

The risk thresholds for these bands are listed in the table that follows, where ICCDP is as defined under Tier I above, CDF' is the conditional core damage frequency, ICLERP is as defined under Tier I above, and LERF' is the conditional large early, release frequency:

ICCDP CDF ICLERP LERF Red > IE-3 >IE-4 Orange > IE-5 > 5.5E-4 >IE-6 >5.2E-5 Yellow IE IE-5 8.7E 5.5E-4 IE IE-6 5.7E 5.2E-5 Green < IE-6 < 8.7E-5 < IE-7 < 5.7E-6 When a risk significant configuration occurs (Safety Monitor in the Yellow, Orange, or Red Bands), Risk Management Action Planning is performed in accordance with Section 4.6 of APA-ZZ-00315 and APA-ZZ-00322, "Integrated Work Management Process Description." Compensatory measures are established to reduce risk (limit unavailability time and implement a contingency plan to restore and/or mitigate the loss of a key safety function). If an unacceptable risk level occurs (in the orange or red band), the Shift Manager / Control Room Supervisor or the Work Week Manager reschedules work as needed to minimize the overall plant risk.

The Callaway CRMP was reviewed and approved by NRC in support of License Amendment 165. See pages 13-15 of the Safety Evaluation attached to Reference 6.

5.0 REGULATORY SAFETY ANALYSIS This section addresses the standards of 10 CFR 50.92 as well as the applicable regulatory requirements and acceptance criteria.

This amendment application submits a proposed change to TS 3.7.8, "Essential Service Water (ESW) System," that would allow a one-time Completion Time extension from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days per ESW train to be used prior to December 31, 2008, for replacing underground ESW piping. The same change is requested for the Completion Time of Required Action B. 4 of TS 3.8.1, "AC Sources - Operating." This is a risk-informed amendment request following the guidance of NRC Regulatory Guides 1.174 and 1.177 (References 1 and 2 respectively). In addition, the second Completion Time for TS 3.8.1 Required Action B.4 is deleted per NRC-approved TSTF-439-A Revision 2.

Attachment 1 Page 17 of 22 To ULNRC-05445 5.1 No Significant Hazards Consideration (NSHC)

AmerenUE has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," Part 50.92(c), as discussed below:

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

Response: No Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed to the protection systems. The same reactor trip system (RTS) and engineered safety feature actuation system (ESFAS) instrumentation will continue to be used. The protection systems will continue to function in a manner consistent with the plant design basis. The use of polyethylene (PE) piping in the ESW system in accordance with ASME Code Case N-755, with justified materials and design exceptions as noted in Reference 4, will result in improved system performance and enhanced system reliability, and will provide an acceptable level of quality and safety. There will be no changes to the essential service water (ESW) system or ultimate heat sink (UHS) surveillance and operating limits.

Reference 4 demonstrates the acceptability of using the PE piping in this buried ASME Class 3 application.

The proposed changes will not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes will not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended functions to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed changes do not affect the way in which safety-related systems perform their functions.

All accident analysis acceptance criteria will continue to be met with the proposed changes. The proposed changes will not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. The proposed changes will not alter any assumptions or change any mitigation actions in the radiological consequence evaluations in the FSAR.

The applicable radiological dose acceptance criteria will continue to be met.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Attachment I Attachment 1 Page 18 of 22 To ULNRC-05445

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

Response: No There are no proposed changes in the method by which any safety-related plant SSC performs its safety function. The proposed changes will not affect the normal method of plant operation or change any operating parameters. No equipment performance requirements will be affected. The proposed changes will not alter any assumptions made in the safety analyses.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this amendment. There will be no adverse effect or challenges imposed on any safety-related system as a result of this amendment.

The proposed amendment will not alter the design or performance of the 7300 Process Protection System, Nuclear Instrumentation System, or Solid State Protection System used in the plant protection systems.

Therefore, the proposed changes do not create the possibility of a new or different accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No There will be no effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, heat flux hot channel factor (FQ), nuclear enthalpy rise hot channel factor (FAH), loss of coolant accident peak cladding temperature (LOCA PCT), peak local power density, or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met.

The proposed changes do not eliminate any surveillances or alter the frequency of surveillances required by the Technical Specifications. None of the acceptance criteria for any accident analysis will be changed.

The proposed changes will have no impact on the radiological consequences of a design basis accident.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Attachment 1 Attachment 1 Page 19 of 22 To ULNRC-05445

Conclusion:

Based on the above evaluation, AmerenUE concludes that the proposed amendment 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.

5.2 Applicable Regulatory ReQuirements / Criteria The regulatory requirements and guidance documents associated with this risk-informed amendment application include the guidance provided by Standard Review Plan (SRP)

Chapter 16.1, "Risk-Informed Decisionmaking: Technical Specifications." SRP Chapter 16.1 refers to RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," as an acceptable approach for assessing proposed risk-informed changes to TS allowed outage times.

.One acceptable approach for making risk-informed decisions about proposed TS changes, including both permanent and temporary TS changes, is to show that the proposed changes meet the five key principles stated in RG 1.177, Section B:

1. The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.

2. The proposed change is consistent with the defense-in-depth philosophy.

3. The proposed change maintains sufficient safety margins.

4. When proposed changes result in an increase in core-damage frequency (CDF) or risk, the increases should be small and consistent with the intent of the Commission's Safety Goal Policy Statement.

5. The impact of the proposed change should be monitored using performance measurement strategies.

The first three principles pertain to traditional engineering considerations and are discussed in Section 3.0 of this Evaluation. The last two principles involve risk considerations as discussed in Section 4.0 of this Evaluation. Another traditional engineering consideration that is listed in Sections II.A and llI.A of SRP Chapter 16.1, and is addressed in Section 3.0 of this Evaluation, is the need for and adequacy of the proposed change.

Although not the direct subject matter of this requested amendment, the ASME Boiler and Pressure Vessel Code Sections III and XI apply to the systems covered by the revised LCOs in this amendment application, as well as the following General Design Criteria:

CRITERION 17 - ELECTRIC POWER SYSTEMS "An onsite electric power system and an offsite electric power system shall be provided to permit the functioning of structures, systems, and components important to safety. The

Attachment 1 Attachment I To ULNRC-05445 Page 20 of 22 safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies."

CRITERION 18 - INSPECTION AND TESTING OF ELECTRIC POWER SYSTEMS "Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system."

CRITERION 44 - COOLING WATER "A system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer

Attachment 1 Attachment I To ULNRC-05445 Page 21 of 22 the combined heat load of these structures, systems, and components under normal operating and accident conditions. Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure."

CRITERION 45 - INSPECTION OF COOLING WATER SYSTEM "The cooling water system shall be designed to permit appropriate periodic inspection of important components, such as heat exchangers and piping, to assure the integrity and capability of the system."

CRITERION 46 - TESTING OF COOLING WATER SYSTEM "The cooling water system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and the performance of the active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation for reactor shutdown and for loss-of-coolant accidents, including operation of applicable portions of the protection system and the transfer between normal and emergency power sources."

Finally, 10 CFR 50.36, "Technical specifications," requires that a licensee's TSs be derived from the analyses and evaluation included in the safety analysis report.

There are no changes being proposed in this amendment application such that commitments to the regulatory requirements and guidance documents above would come into question. The evaluations documented above confirm that Callaway Plant will continue to comply with all applicable regulatory requirements.

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 Commission's regulations, and (3) 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 evaluated the proposed amendment and 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

Attachment 1 Attachment I To ULNRC-05445 Page 22 of 22 radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.1 REFERENCES

1. NRC Regulatory Guide 1.174, Revision 1, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," November 2002.

2. NRC Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," August 1998."

3. NRC Letter from T. H. Boyce to Technical Specification Task Force dated January 11, 2006, "Status of TSTF-439, 'Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO.'

4. ULNRC-05434 dated August 30, 2007, "10CFR50.55a Request: Proposed Alternative to ASME Section XI Requirements for Replacement of Class 3 Buried Piping," Relief Request to Apply ASME Code Case N-755 to Underground ESW Piping.

5. AmerenUE letters in response to NRC GL 2006-02: ULNRC-05270 dated March 31, 2006, ULNRC-05313 dated August 1, 2006, and ULNRC-05362 dated January 31, 2007.

6. Callaway License Amendment No. 165 dated January 31, 2005, "Callaway Plant, Unit 1 - Issuance of Amendment Re: Plant Protection Test Times, Completion Times, and Surveillance Test Intervals (TAC NO. MC 1756)."

7.2 PRECEDENT Catawba License Amendment 228/223, NRC letter from F. Saba to D. M. Jamil dated November 17, 2005, "Catawba Nuclear Station, Units 1 and 2 Re: Issuance of Amendments (TAC NOS. MC5117 and MC5118)," ADAMS Accession Numbers ML053250141, ML053250121, and ML053250376.

Attachment 2 To ULNRC-05445 ATTACHMENT 2 MARKUP OF TECHNICAL SPECIFICATIONS

Attachment 2 To ULNRC-05445 ESW 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Essential Service Water System (ESW)

LCO 3.7.8 Two ESW trains shall be OPERABLE.

APPLICABILITY: MODES 1,2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION 1COMPLETION CTME TIME A. One ESW train inoperable. I A.1 NOTE------ ------

1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating,"

for emergency diesel generator made inoperable by ESW.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"

for residual heat removal loops made inoperable by ESW.

-=-AJ-rW

.'V /

Restore ESW train to -72 0-0 rg-- - - -

OPERABLE status.

(continued)

CALLAWAY PLANT 3.7-21 Amendment No. 176

Attachment 2 To ULNRC-05445 Insert 1 A one-time Completion Time of 14 days per ESW train is allowed to support planned replacement of ESW piping prior to December 31, 2008.

Attachment 2 To ULNRC-05445 AC Sources - Operating 3.8.1 ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME B. One DG inoperable. Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from (continued) feature(s) supported by discovery of the inoperable DG Condition B inoperable when its concurrent with required redundant inoperability of feature(s) is inoperable. redundant required feature(s)

AND B.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG is not inoperable due to common cause failure.

OR B.3.2 NOTE------ ------

The required ACTION of B.3.2 is satisfied by the automatic start and sequence loading of the diesel generator.

Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DG.

AND 7- ý - -

B.4 Restore DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

d-'di6coy cfrcu-4e f~eet 693 (continued)

CALLAWAY PLANT 3.8-3 Amendment 133

Attachment 2 To ULNRC-05445 Insert 1A A one-time Completion support planned Time of 14 days replacement per DG is allowed 2008. of ESW piping to prior to December 31,

Attachment 3 To ULNRC-05445 ATTACHMENT 3 RETYPED TECHNICAL SPECIFICATIONS

Attachment 3 To ULNRC-05445 TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.2 Containment Air Locks ..................................................................... 3.6-3 3.6.3 Containment Isolation Valves ......................................................... 3.6-7 3.6.4 Containment Pressure ..................................................................... 3.6-16 3.6.5 Containment Air Temperature ......................................................... 3.6-17 3.6.6 Containment Spray and Cooling Systems ...................................... 3.6-18 3.6.7 Recirculation Fluid pH Control (RFPC) System ............................... 3.6-21 3.6.8 Hydrogen Recombiners ................................................................... 3.6-22 3.7 PLANT SYSTEMS ................................................................................. 3.7-1 3.7.1 Main Steam Safety Valves (MSSVs) ............................................... 3.7-1 3.7.2 Main Steam Isolation Valves (MSIVs) ............................................ 3.7-5 3.7.'3 MFIVs and MFRVs and MFRV Bypass Valves ............................... 3.7-8 3.7.4 Atmospheric Steam Dump Valves (ASDs) ...................................... 3.7-10 3.7.5 Auxiliary Feedwater (AFW) System ................................................. 3.7-13 3.7.6 Condensate Storage Tank (CST) .................................................... 3.7-17 3.7.7 Component Cooling Water (CCW) System ................. 3.7-19 3.7.8 Essential Service Water System (ESW) .......................................... 3.7-21 3.7.9 Ultimate Heat Sink (UHS) ................................................................ 3.7-24 3.7.10 Control Room Emergency Ventilation System (CREVS) ................. 3.7-26 3.7.11 Control Room Air Conditioning System (CRACS) ........................... 3.7-29 3.7.12 Not Used .......................................................................................... 3.7-32 3.7.13 Emergency Exhaust System (EES) ................................................. 3.7-33 3.7.14 Not Used .......................................................................................... 3.7-36 3.7.15 Fuel Storage Pool Water Level ........................................................ 3.7-37 3.7.16 Fuel Storage Pool Bororn Concentration .......................................... 3.7-38 3.7.1.7 Spent Fuel Assembly Storage ......................................................... 3.7-40 3.7.18 Secondary Specific Activity .............................................................. 3.7-42 3.8 ELECTRICAL POWER SYSTEMS ........................................................ 3.8-1 3.8.1 AC Sources - Operating .................................................................. 3.8-1 3.8.2 AC Sources - Shutdown .................................................................. 3.8-16 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air ....................................... 3.8-19 3.8.4 DC Sources - Operating .................................................................. 3.8-22 3.8.5 DC Sources - Shutdown .................................................................. 3.8-25 3.8.6 Battery Cell Parameters ................................................................... 3.8-27 3.8.7 Inverters - Operating ........................................................................ 3.8-31 3.8.8 Inverters - Shutdown ........................................................................ 3.8-33 3.8.9 Distribution Systems - Operating ..................................................... 3.8-35 3.8.10 Distribution Systems - Shutdown ..................................................... 3.8-37 CALLAWAY PLANT 3 Amendment ###

Attachment 3 To ULNRC-05445 ESW 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Essential Service Water System (ESW)

LCO 3.7.8 Two ESW trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ESW train inoperable. A.1 NOTE-------

1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating,"

for emergency diesel generator made inoperable by ESW.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"

for residual heat removal loops made inoperable by ESW.

(continued)

CALLAWAY PLANT 3.7-21 Amendment No. ###

Attachment 3 To ULNRC-05445 ESW 3.7.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ESW train inoperable. Restore ESW train to -------.NOTE ------

(continued) OPERABLE status. A one-time Completion Time of 14 days per ESW train is allowed to support planned replacement of ESW piping prior to December 31, 2008.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months CALLAWAY PLANT 3.7-22 Amendment ###

Attachment 3 To ULNRC-05445 ESW 3.7.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 ---------------------- NOTE-----------

Isolation of ESW flow to individual components does not render the ESW inoperable.

Verify each ESW manual, power operated, and 31 days automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.7.8.2 Verify each ESW automatic valve in the flow path that 18 months is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.7.8.3 Verify each ESW pump starts automatically on an 18 months actual or simulated actuation signal.

CALLAWAY PLANT 3.7-23 Amendment No. ###

Attachment 3 To ULNRC-05445 UHS 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The UHS shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS REQUIRED ACTION COMPLETION CONDITION TIME A. One cooling tower train A.1 Restore cooling tower 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable, train to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

OR B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months UHS inoperable for reasons other than Condition A.

CALLAWAY PLANT 3.7-24 Amendment No. ### I

Attachment 3 To ULNRC-05445 UHS 3.7.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of UHS is Ž_831.25 ft mean sea 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months level.

SR 3.7.9.2 Verify average water temperature of UHS is _< 90 0 F. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.7.9.3 Operate each cooling tower fan for > 15 minutes in 31 days both the fast and slow speed.

CALLAWAY PLANT 3.7-25 Amendment No. ### I

Attachment 3 To ULNRC-05445 CREVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Emergency Ventilation System (CREVS)

LCO 3.7.10 Two CREVS trains shall be OPERABLE.

.-.--.....----------------------- NOTE -..............--------- -- ---

The control room boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One CREVS train A.1 Restore CREVS train to 7 days inoperable. OPERABLE status.

B. Two CREVS trains B.1 Restore control room 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable control room status.

boundary in MODES 1, 2, 3, and 4.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or4. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

CALLAWAY PLANT 3.7-26 Amendment No. ### I

Attachment 3 To ULNRC-05445 CREVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREVS train in CRVIS Time of Condition A not met mode.

in MODE 5 or 6, or during movement of irradiated fuel assemblies.

OR D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies.

E. Two CREVS trains E.1 Suspend CORE Immediately inoperable in MODE 5 or 6, ALTERATIONS.

or during movement of irradiated fuel assemblies.

AND E.2 Suspend movement of Immediately irradiated fuel assemblies.

F. Two CREVS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.

CALLAWAY PLANT 3.7-27 Amendment No. ### I

Attachment 3 To ULNRC-05445 CREVS 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREVS train pressurization filter unit 31 days for _>10 continuous hours with the heaters operating and each CREVS train filtration filter unit for

_ 15 minutes.

SR 3.7.10.2 Perform required CREVS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). VFTP SR 3.7.10.3 Verify each CREVS train actuates on an actual or 18 months simulated actuation signal.

SR 3.7.10.4 Verify one CREVS train can maintain a positive 18 months on a pressure of _>0.125 inches water gauge, relative to STAGGERED the outside atmosphere during the CRVIS mode of TEST BASIS operation.

CALLAWAY PLANT 3.7-28 Amendment No.### I

Attachment 3 To ULNRC-05445 CRACS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Air Conditioning System (CRACS)

LCO 3.7.11 Two CRACS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One CRACS train A.1 Restore CRACS train to 30 days inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not met AND in MODE 1, 2, 3, or 4.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

CALLAWAY PLANT 3.7-29 Amendment No. ### I

Attachment 3 To ULNRC-05445 CRACS 3.7.11 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME C. Required Action and C.1 Place OPERABLE Immediately associated Completion CRACS train in Time of Condition A not met operation.

in MODE 5 or 6, or during movement of irradiated fuel assemblies.

OR C.2.1 Suspend CORE Immediately ALTERATIONS.

AND C.2.2 Suspend movement of Immediately irradiated fuel assemblies.

D. Two CRACS trains D.1 Suspend CORE Immediately inoperable in MODE 5 or 6, ALTERATIONS.

or during movement of irradiated fuel assemblies.

AND D.2 Suspend movement of Immediately irradiated fuel assemblies.

E. Two CRACS trains E.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

CALLAWAY PLANT 3.7-30 Amendment No. ### I

Attachment 3 To ULNRC-05445 CRACS 3.7.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Verify each CRACS train has the capability to remove 18 months the assumed heat load.

CALLAWAY PLANT 3.7-31 Amendment No. ### I

Attachment 3 To ULNRC-05445 3.7.12 3.7 PLANT SYSTEMS 3.7.12 Not Used.

CALLAWAY PLANT 3.7-32 Amendment No. ### I

Attachment 3 To ULNRC-05445 Emergency Exhaust System 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Emergency Exhaust System (EES)

LCO 3.7.13 Two EES trains shall be OPERABLE.

.-.--.-------- NOTE------- -- -

The auxiliary or fuel building boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies in the fuel building.

NOTE The SIS mode of operation is required only in MODES 1, 2, 3 and 4. The FBVIS mode of operation is required only during movement of irradiated fuel assemblies in the fuel building.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. One EES train inoperable. A.1 Restore EES train to 7 days OPERABLE status.

B. Two EES trains inoperable B.1 Restore auxiliary building 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months due to inoperable auxiliary boundary to OPERABLE building boundary in status.

MODE 1, 2, 3 or 4.

(continued)

CALLAWAY PLANT 3.7-33 Amendment No. ### I

Attachment 3 To ULNRC-05445 Emergency Exhaust System 3.7.13 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B not AND met in MODE 1, 2, 3, or 4.

C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two EES trains inoperable in MODE 1,2, 3, or 4 for reasons other than Condition B.

D. Required Action and D.1 Place OPERABLE EES Immediately associated Completion Time train in the FBVIS mode.

of Condition A not met during movement of irradiated fuel assemblies in the fuel building.

OR D.2 Suspend movement of Immediately irradiated fuel assemblies in the fuel building.

E. Two EES trains inoperable E.1 Suspend movement of Immediately during movement of irradiated fuel irradiated fuel assemblies in assemblies in the fuel the fuel building. building.

CALLAWAY PLANT 3.7-34 Amendment No. ### I

Attachment 3 To ULNRC-05445 Emergency Exhaust System 3.7.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each EES train for Ž_10 continuous hours 31 days with the heaters operating.

SR 3.7.13.2 Perform required EES filter testing in accordance with In accordance with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.7.13.3 Verify each EES train actuates on an actual or 18 months simulated actuation signal.

SR 3.7.13.4 Verify one EES train can maintain a negative pressure 18 months on a

_Ž0.25 inches water gauge with respect to STAGGERED atmospheric pressure in the auxiliary building during TEST BASIS the SIS mode of operation.

SR 3.7.13.5 Verify one EES train can maintain a negative pressure 18 months on a

>_0.25 inches water gauge with respect to STAGGERED atmospheric pressure in the fuel building during the TEST BASIS FBVIS mode of operation.

CALLAWAY PLANT 3.7-35 Amendment No. ### I

Attachment 3 To ULNRC-05445 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Not Used.

CALLAWAY PLANT 3.7-36 Amendment No. ### I

Attachment 3 To ULNRC-05445 Fuel Storage Pool Water Level 3.7.15 3.7 PLANT SYSTEMS 3.7.15 Fuel Storage Pool Water Level LCO 3.7.15 The fuel storage pool water level shall be _>23 ft over the top of the storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool water A.1 ------------ NOTE------

level not within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in the fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15.1 Verify the fuel storage pool water level is Ž!23 ft 7 days above the storage racks.

CALLAWAY PLANT 3.7-37 Amendment No. ### I

Attachment 3 To ULNRC-05445 Fuel Storage Pool Boron Concentration 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Fuel Storage Pool Boron Concentration LCO 3.7.16 The fuel storage pool boron concentration shall be >_2165 ppm.

APPLICABILITY: When fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. Fuel storage pool boron -------------- NOTE --------

concentration not within LCO 3.0.3 is not applicable.

limit.------------------ ---- -

A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.1 Initiate action to restore Immediately fuel storage pool boron concentration to within limit.

OR A.2.2 Verify by administrative Immediately means that a non-Region 1 fuel storage pool verification has been performed since the last movement of fuel assemblies in the fuel storage pool.

CALLAWAY PLANT 3.7-38 Amendment No. ### I

Attachment 3 To ULNRC-05445 Fuel Storage Pool Boron Concentration 3.7.16 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 Verify the fuel storage pool boron concentration is 7 days within limit.

CALLAWAY PLANT 3.7-39 Amendment No. ### I

Attachment 3 To ULNRC-05445 Spent Fuel Assembly Storage 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Spent Fuel Assembly Storage LCO 3.7.17 The combination of initial enrichment and burnup of each spent fuel assembly stored in Region 2 or 3 shall be within the Acceptable Domain of Figure 3.7.17-1 or in accordance with Specification 4.3.1.1.

APPLICABILITY: Whenever any fuel assembly is stored in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.1 - --------- NOTE -----

not met. LCO 3.0.3 is not applicable.

Initiate action to move Immediately the noncomplying fuel assembly to Region 1.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.17.1 Verify by administrative means the initial enrichment Prior to storing the and burnup of the fuel assembly is in accordance with fuel assembly in Figure 3.7.17-1 or Specification 4.3.1.1. Region 2 or 3 CALLAWAY PLANT 3.7-40 Amendment No. ### I

Attachment 3 To ULNRC-05445 Spent Fuel Assembly Storage 3.7.17 5500)0-5000 AC(EPTAB E BURNUP D MAIN FOR REGION 2 AND 3 S-ORAGE 4500)0-010- _____ _____

4000 La 0 3500 CL La 3000 2500)0 2000 FOREGIN 2OR 3SOrG

)0 1500 '0-L-4 1000 UNAC EPTABLE BURNUP COMAIN FOR IEGION 2 OR 3 STO RAGE 500 0.-

1.5 2.0 2.5 3.0 3.5 4.0 4.5¸ 5.0 FUEL ASSEMBLY INITIAL ENRICHMENT (w/o U-235)

Figure 3.7.17-1 (page 1 of 1)

MINIMUM REQUIRED FUEL ASSEMBLY BURNUP AS A FUNCTION OF INITIAL ENRICHMENT TO PERMIT STORAGE IN REGIONS 2 AND 3 CALLAWAY PLANT 3.7-41 Amendment No. ### 1

Attachment 3 To ULNRC-05445 Secondary Specific Activity 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Secondary Specific Activity LCO 3.7.18 The specific activity of the secondary coolant shall be <ý0. 10 PCi/gm DOSE EQUIVALENT 1-131.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Specific activity not within A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months limit.

AND A.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify the specific activity of the secondary coolant is 31 days

<0.10 Ci/gm DOSE EQUIVALENT 1-131.

CALLAWAY PLANT 3.7-42 Amendment No. ### I

Attachment 3 To ULNRC-05445 AC Sources - Operating 3.8.1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. One DG inoperable. Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from (continued) feature(s) supported by discovery of the inoperable DG Condition B inoperable when its concurrent with required redundant inoperability of feature(s) is inoperable. redundant required feature(s)

AND B.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG is not inoperable due to common cause failure.

OR B.3.2 NOTE------ ------

The required ACTION of B.3.2 is satisfied by the automatic start and sequence loading of the diesel generator.

Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DG.

AND (continued)

CALLAWAY PLANT 3.8-3 Amendment ### I

Attachment 3 To ULNRC-05445 AC Sources - Operating 3.8.1 ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME B. One DG inoperable. B.4 Restore DG to --------- NOTE ---......

(continued) OPERABLE status. A one-time Completion Time of 14 days per DG is allowed to support planned replacement of ESW piping prior to December 31, 2008.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months I

C. Two offsite circuits C.1 NOTE -----------

inoperable. In Modes 1, 2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature.

Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from feature(s) inoperable discovery of when its redundant Condition C required feature(s) is concurrent with inoperable. inoperability of redundant required features AND C.2 Restore one offsite circuit 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to OPERABLE status.

(continued)

CALLAWAY PLANT 3.8-4 Amendment ###

Attachment 3 To ULNRC-05445 AC Sources - Operating 3.8.1 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME D. One offsite circuit -- NOTE---

inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One DG inoperable. AC power source to any train.

D.1 Restore offsite circuit to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

OR D.2 Restore DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

E. Two DGs inoperable. E.1 Restore one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status.

F. One required LSELS F.1 Declare the affected DG Immediately inoperable, and offsite circuit inoperable.

AND F.2 Restore required LSELS 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to OPERABLE status.

G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A, B, C, D, E, AND or F not met.

G.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months H. Three or more AC sources H.1 Enter LCO 3.0.3. Immediately inoperable.

CALLAWAY PLANT 3.8-5 Amendment No. ### I

Attachment 4 To ULNRC-05445 ATTACHMENT 4 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (for information only)

Attachment 4 To ULNRC-05445 ESW B 3.7.8 BASES (Continued)

ACTIONS A. 1 If one ESW train is inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, the remaining OPERABLE ESW system train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE ESW system train could result in loss of ESW function. Required Action A.1 is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," should be entered ifan inoperable ESW train results in an inoperable emergency diesel generator. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," should be entered if an inoperable ESW system train results in an inoperable residual heat removal train. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time periodA r- A7-" .

B.1 and B.2 If the ESW System train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.8.1 REQUIREMENTS This SR is modified by a Note indicating that the isolation of the ESW components or systems may render those components inoperable, but does not affect the OPERABILITY of the ESW system.

Verifying the correct alignment for manual, power operated, and automatic valves in the ESW system flow path servicing safety related components provides assurance that the proper flow paths exist for ESW system operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation (continued)

CALLAWAY PLANT B 3.7.8-3 Revision 6j

Attachment 4 To ULNRC-05445 INSERT B1 The Completion Time is modified by a Note that allows a one-time Completion Time of 14 days per ESW train to support the planned replacement of ESW piping prior to December 31, 2008.

Attachment 4 To ULNRC-05445 AC Sources - Operating B 3.8.1 BASES ACTIONS B.3.1 and B.3.2 (continued) be entered. Once the failure is repaired, the common cause failure no longer exists, and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG. Required Action B.3.2 is modified by a Note stating that it is satisfied by the automatic start and sequence loading of the DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the plant corrective action program will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.A

',h second Completion Time for Required Action B.4 establishes a limit on týaximum time allowed for any combination of required AC' er sources t inoperable during any single contiguous occurre of failing to mee LCO. If Condition B is entered while, instance, an offsite circuit is inop ble and that circuit is subse tly restored OPERABLE, the LCO m already have been met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This could lead to a tota of hours, s' initial failure to meet the LCO, to restore the DG. At this ti n offsite circuit could again become inoperable, the DG restored and an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (for a total of 9 days) allowe ior to complete toration of the LCO. The 6 day Completion e provides a limit on time wed in a specified condition a scovery of failure to meet the LCO. llimit is conside reasonable for situations in which Conditions dB are en d concurrently. The "AND" connector between the 72 ho nd (continued)

CALLAWAY PLANT B 3.8.1-9 Revision.6f

Attachment 4 To ULNRC-05445 INSERT B2 The Completion Time is modified by a Note that allows a one-time Completion Time of 14 days per DG to support the planned replacement of ESW piping prior to December 31, 2008.

Attachment 4 To ULNRC-05445 AC Sources - Operating B 3.8.1 BASES ACTIONS BA (continued)

Completion Times means that both Completion Timesvpv--

simulta sly, and he more restrictive Completion must be met.

AiReieAome allows for an exception to the normal time zero" for be he allowed time "clock." This will

ý that th e L a t the i nti ll wa s initially C Owas result in establishing tthe time

~~~at line zero" at t B was Co'dition LCO not met, inste ent,.*

at the time Condition B was en e C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps and the turbine driven auxiliary feedwater pump which must be available for mitigation of a feedwater line break. Single train features, other than the turbine driven auxiliary feedwater pump, are not included in this Condition.

A Note is added to this Required Action stating that in MODES 1, 2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature. The reason for the Note is to confirm the OPERABILITY of the turbine driven auxiliary feedwater pump in this Condition, since the auxiliary feedwater pump is not by itself capable of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

The Completion Time for Required Action C.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable; and (continued)

CALLAWAY PLANT B 3.8.1 -10 Revision 6f

Attachment 5 To ULNRC-05445 ATTACHMENT 5 COPY OF APPROVED TRAVELER TSTF-439-A WITH NUREG-1431 ISTS CHANGE MARKUPS TO 3.8.1.B.4

Attachment 5 To ULNRC-05445 STATES UNITED

'A NUCLEAR REGULATORY COMMISSION 0 WASHINGTON, D.C. 20555-0001 January 11, 2006 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

STATUS OF TSTF 439, "ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO" Technical Specification Task Force Traveler (TSTF) 439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO," dated June 20, 2005, proposed a new technical specification (TS) convention to limit the maximum time allowed for any combination of LCO Conditions that could result in a single continuous failure to meet the LCO. This traveler has been incorporated into Revislon .3.1 of the Standard Technical Specifications (STS). The purpose of this letter is to document the Staff's evaluation of the traveler.

Historically, a second Completion Time was included for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that would result in a single continuous failure to meet the LCO. In practice, the addition of second Completion Times did not create an operational restriction because the likelihood of experiencing concurrent failures such that the second Completion Time was limiting is remote. It is important to note that this issue of "flip flopping" between Conditions only applies if the LCO is not met on a continuous basis. In addition, ifthe LCO requirements are met, even if for an instant, this issue does not occur.

The second Completion Times convention became a problem when the NRC staff received a proposed Traveler that integrated risk-informed Completion Times into specifications containing a second Completion Time. The problem results from extending the second Completion Time by the same amount (i.e., the second Completion Time continued to be the sum of the two Completion Times.) The NRC staff expressed concerns that the extension of the second Completion Time was inappropriate because one of the two Completion Times added to obtain the second Completion Time limit was risk-based and the other was derived in a deterministic evaluation, Eventually, the NRC staff stated it could accept the concept that risk-based and deterministic Completion Times could be added because it judged that the added time would still be conservative.

After the NRC staff accepted adding deterministic and risk-based Completion Times, the TSTF reconsidered its position and decided that the second Completion Times complicated the implementation of risk-informed Completion Times, beyond those that involve second Completion Times. The TSTF concluded that other regulatory requirements, not present when the STS were originally developed, could be used to make a case to eliminate second Completion Times. Therefore, the TSTF proposed a Traveler to delete second Completion Times from the affected specification Required Actions. Additionally, the proposed TSTF changes revised STS Example 1.3-3 by removing the discussion of second Completion Times

Attachment 5 To ULNRC-05445 and by establishing a convention prohibiting alternating between Conditions in such a manner that operation could continue Indefinitely without ever restoring systems to meet the LCO.

Thus, by adopting TSTF-439 there is no specific TS to limit the maximum 'time allowed for any combination of Conditions that results in a single continuous occurrence of failing to meet the LCO.

Section 1.3 of the STS, Example 1.3-3, described the use of this type of second Completion Time. The STS contained second Completion Times in the following Specifications:

a AC Sources - Operating (BWRs and PWRs) e Distribution Systems - Operating (BWRs and PWRs) s Containment Spray and Cooling (PWRs)

@ Auxiliary / Emergency Feedwater System (PWRs)

Standby Liquid Control (SLC) System (BWRs)

The NRC Staff concludes that multiple continuous entries into Conditions, without meeting the LCO, Is acceptable because these practices will be controlled by licensee's configuration risk management programs, which were implemented to meet the requirements of the maintenance rule to assess and manage risk, and. controlled by the Use .and Application convention discussed in Section 1.3 of the Technical Specifications. The TS controls, coupled with the licensees' configuration risk management programs, provide adequate assurance against inappropriate use of rombinations of Conditions that result in a single contiguous occurrence of failing to meet the LCO. Accordingly, TSTF 439 has been incorporated into Revision 3.1 of the-STS.

Sincerely, T~homas H.Boyce, hief.

Technical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation cc: D. Hoffman, Excel Services B. Mann, Excel Services M. Crowthers, BWROG W. Sparkman, WOG P. Infanger, BWOG B. Woods,- WOG/CE

Attachment 5 To ULNRC-05445 WOG-165, Rev. 0 TSTF-439-A, Rev. 2 Technical Specification Task Force

-_ -Improved Standard Technical Specifications Change Traveler Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO NUREGs Affected: LJ 1430 [v1 1431 k 1432 I 1433 v 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Improvement NRC Fee Status: Not Exempt Benefit: Prevents Unnecessary Actions Industry

Contact:

Wes Sparkman, (205) 992-5061, wasparkm@southemco.com See attached justification.

Revision History OG Revision 0 Revision Status: Closed Revision Proposed by: Wolf Creek Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 07-Feb-02 Owners Group Comments:

(No Comments)

Owners Group Resolution: Approved Date: 13-Feb-02 TSTF Review Information TSTF Received Date: 07-Feb-02 Date Distributed for Review: 13-Feb-02 OG Review Completed: VJ BWOG V WOG [] CEOG F BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 13-Feb-02 NRC Review Information NRC Received Date: 03-Jun-02 Final Resolution: Superceded by Revision Final Resolution Date: 04-Oct-02 19-Dec-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission isgranted. All other use without written permission is prohibited.

Attachment 5 To ULNRC-05445 WOG-165, Rev. 0 TSTF-439-A, Rev. 2 OG Revision 0 Revision Status: Closed TSTF Revision I Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

TSTF-439 is revised. TSTF-439 deleted the last paragraph prior to the examples in Section 1.3. This paragraph states:

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery.. ." Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

Upon further consideration, the TSTF determined that all but the last two sentences of the paragraph should be retained. The discussion of "once per" Completion Times and of "from discovery" Completion Times is still applicable after implementation of this change. This change only deletes second Completion Times in a Condition that limit the maximum time an LCO can not be met. This type of condition is illustrated in Example 1.3-3, which is deleted by this change. The reference in the above paragraph to Example 1.3-3 must also be deleted. NUREG-1433 and 1434 contain single Completion Times based on failure to meet the LCO (for examples, see NUREG-1433 Required Actions of 3.3.5.1, 3.3.5.2, 3.3.7.1, and 3.4.2.) These Completion Times are unaffected by this proposed change and are described by the subject paragraph in Section 1.3.

To clarify the purpose of the change, the title is changed of TSTF-439 is changed from, "Eliminate Modified Time Zero Completion Times," to "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO."

The third paragraph of Section 1.0, Description, is added to include a discussion of the NRC's letter of September 10, 2002 which states that TSTF-430, "AOT Extension to7 Days for LPI and Containment Spray (BAW-2295-A, Rev. I)" cannot be approved because it modifies a second Completion Time based on time of discovery of failure to meet an LCO. This is consistent with the discussion of the NRC's disposition of TSTF-417 and TSTF-409 in TSTF-439.

(Note: the NRC subsequently approved TSTF-430 and TSTF-409 with the originally proposed extensions of the the second Completion Times limiting time from discovery of failure to meet an LCO.)

TSTF Review Information TSTF Received Date: 04-Oct-02 Date Distributed for Review: 04-Oct-02 OG Review Completed: WJ BWOG [ WOG W CEOG Rv BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 21-Oct-02 NRC Review Information NRC Received Date: 25-Oct-02 NRC Comments: Date of NRC Letter: 03-Mar-03 19-Dec-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

Attachment 5 To ULNRC-05445 WOG-165, Rev. 0 TSTF-439-A, Rev. 2 TSTF Revision I Revision Status: Closed 3/3/03 - NRC provides letter requesting additional information.

TSTF-439 proposes to make changes to standard technical specifications (NUREGs 1430 through 1434) associated with all Nuclear Steam Supply System Vendor design LCO that contain second completion time limits, those completion times that reference the maximum time allowed during any single contiguous occurrence of failing to meet the LCO. For all STS NUREGs the affected specifications include LCO 3.8.1, AC Sources - Operating, and LCO 3.8.9, Distribution Systems - Operating. For BWOG, CEOG and WOG STS the affected specifications also include LCO 3.6.6, Containment Spray and Cooling Systems, and LCO 3.7.5, Auxiliary [Emergency] Feedwater System. For BWR/4 and BWR/6 STS the affected specifications also include LCO 3.1.7, Standby Liquid Control System.

The existing guidance for 10 CFR 50.65(a)(4) is not specific enough to ensure that all licensee programs for structure, system and component unavailability monitoring (Maintenance Rule) will assess and manage cumulative risk concerns regarding second completion time limits. This is because not enough overlap between the maintenance rule, TS, and the configuration risk management program exists to presume these operational limits would be managed by the associated system unavailability monitoring programs required by 10 CFR 50.65(a)(4).

Since TSTF-439 proposes to delete second completion time limits in their entirety, replacing them with unavailability monitoring programs required by 10 CFR 50.65(a)(4), the staff requests additional information to show that unavailability monitoring programs required by 10 CFR 50.65(a)(4) will result in appropriate operational limits and appropriately manage cumulative risks during second completion time limits. Provide a qualitative analysis which explains how the 10 CFR 50.65(a)(4) monitoring program will manage the same kind of limits that exist in standard technical specifications that are proposed for elimination. Discuss the quantitative approaches envisioned as required to support the risk analysis in the 10 CFR 50.65(a)(4) program.

9/23/03 - A series of discussions between the TSTF and the NRC resulted in an agreement to revise TSTF-439 to eliminate the second completion times limiting time from discovery of failure to meet an LCO and to revise (not delete) ISTS Example 1.3-3 to discuss that "flip flopping" between Conditions without meeting the LCO is inapproprate and licensees should establish administrative controls to avoid it.

Final Resolution: Superceded by Revision TSTF Revision 2 Revision Status: Active Revision Proposed by: TSTF Revision

Description:

TSTF-439 is revised based on discussions with the NRC. The changes are:

- Remarked pages on Revision 3 of the ISTS NUREGs.

- Retained Example 1.3-3. Revised the Actions to eliminate the second Completion Times limiting the time from discovery of failure to meet the LCO.

- Revised the Example 1.3-3 discussion to state that repeatedly moving from Condition to Condition without meeting the LCO is inappropriate and licensees should establish administrative controls to prohibit the practice

- Revised the justification to reflect these changes and to expand the discussion based on the extensive discussions held with the NRC on this matter.

TSTF Review Information TSTF Received Date: 18-Mar-05 Date Distributed for Review: 18-Mar-05 OG Review Completed: W BWOG [] WOG 7. CEOG P. BWROG 19-Dec-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

Attachment 5 To ULNRC-05445 WOG-165, Rev. 0 TSTF-439-A, Rev. 2 TSTF Revision 2 Revision Status: Active TSTF Comments:

(No Comments)

TSTF Resolution: Approveed Date: 20-Jun-05 NRC Review Information NRC Received Date: 20-Jun-05 NRC Comments:

The NRC agreed to approve this Traveler as an administrative change to Revision 3.1 of the ISTS NUREGs.

The first plant to submit an amendment request based on this Traveler will be considered the "lead plant" submittal and a generic Safety Evaluation will be written for the Traveler.

Final Resolution: NRC Approves Final Resolution Date: 01-Dec-05 Affected Technical Specifications 1.3 Completion Times Action 3.1.7.B Bases SLC System Action 3.8.1.A AC Sources - Operating Action 3.8.1 .A Bases AC Sources - Operating Action 3.8.1.B AC Sources - Operating Action 3.8.1 .B Bases AC Sources - Operating Action 3.8.9.A Distribution Systems - Operating Action 3.8.9.A Bases Distribution Systems - Operating Action 3.8.9.B Distribution Systems - Operating Action 3.8.9.B Bases Distribution Systems - Operating Action 3.8.9.C Distribution Systems - Operating Action 3.8.9.C Bases Distribution Systems - Operating Action 3.6.6.A Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.6.6.A Bases Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.6.6.C Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.6.6.C Bases Containment Spray and Cooling Systems NUREG(s)- 1430 Only Action 3.7.5.A EFW System NUREG(s)- 1430 Only 19-Dec-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

Attachment 5 To ULNRC-05445 WOG-165, Rev. 0 TSTF-439-A, Rev. 2 Action 3.7.5.A Bases EFW System NUREG(s)- 1430 Only Action 3.7.5.B EFW System NUREG(s)- 1430 Only Action 3.7.5.B Bases EFW System NUREG(s)- 1430 Only Action 3.7.5.B Bases AFW System NUREG(s)- 1431 1432 14331434 Only Action 3.6.6B.A Containment Spray and Cooling Systems (Atmospheric and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6A.A Containment Spray and Cooling Systems (Atmospheric and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6A.A Bases Containment Spray and Cooling Systems (Atmospheric and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6B.A Bases Containment Spray and Cooling Systems (Atmospheric and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6B.B Containment Spray and Cooling Systems (Atmospheric and NUREG(s) 1431 1432 Only Dual)

Action 3.6.6B.B Bases Containment Spray and Cooling Systems. (Atmospheric and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6A.C Containment Spray and Cooling Systems (Atmospheric and NUREG(s)- 1431 1432 Only Dual)

Action 3.6.6A.C Bases Containment Spray and Cooling Systems (Atmospheric and NUREG(s)- 1431 1432 Only Dual)

Action 3.7.5.A AFW System NUREG(s)- 1431 1432 Only Action 3.7.5.A Bases AFW System NUREG(s)- 1431 1432 Only Action 3.7.5.B AFW System NUREG(s)- 1431 1432 Only Action 3.1.7.A SLC System NUREG(s)- 1433 1434 Only Action 3.1.7.A Bases SLC System NUREG(s)- 1433 1434 Only Action 3.1.7.B SLC System NUREG(s)- 1433 1434 Only 19-Dec-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2

1.0 DESCRIPTION

In the Improved Standard Technical Specifications (NUREGs 1430 through 1434) (ISTS) a second Completion Time was included for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the LCO.

These Completion Times (henceforth referred to as "second Completion Times") are joined by an "AND" logical connector to the Condition-specific Completion Time and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second Completion Time was to preclude entry into and out of the ACTIONS for an indefinite period of time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.

The proposed Traveler deletes these second Completion Times from the affected Required Actions. It also revises ISTS Example 1.3-3 to remove the second Completion Times and to revise the discussion in that Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis of the Completion Times and is inappropriate. Therefore, the licensee shall have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO is not inappropriately extended.

2.0 PROPOSED CHANGE

NUREG-1430 ISTS Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6 Required Actions A. 1 and C. 1, Technical Specification 3.7.5 Required Actions A. I and B. 1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A. 1, B. 1, and C. I is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

NUREG-1431 and NUREG-1432 ISTS Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6A Required Actions A.I and C.1, Technical Specification 3.6.6B Required Actions A. I and B. 1, Technical Specification 3.7.5 Required Actions A. I and B. 1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A. 1, B. 1, and C. 1 is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

NUJREG-1433 and NUREG- 1434 ISTS Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.1.7 Required Actions A. 1 and B. 1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A. 1, B. 1, and C. 1 is being deleted. The Bases associated with these Required Actions are also being revised to delete Page 1

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 the discussion of the second Completion Time.

3.0 BACKGROUND

Between July and December of 199 1, the NRC and the ISTS lead plants discussed an issue affecting a small number of Technical Specifications that could theoretically allow indefinite operation of the plant while not meeting an LCO.

Put simply, if an LCO requires OPERABILITY of two systems, it is possible to enter the Condition for one inoperable system and before restoring the first system, the second system becomes inoperable. With the second system inoperable, the first system is restored to OPERABLE status. Before restoring the second system, the first system becomes inoperable again, and so on. Under this scenario, it would be theoretically possible to operate indefinitely without ever meeting the LCO. This also could occur with LCOs which require one only system to be OPERABLE, but for which the Conditions describe two or more mutually exclusive causes of inoperability.

An NRC internal memo dated August 5, 1991 described the issue. As stated in the memo, "In these Specifications the following phrase was added in the Completion Time column of the Conditions that could extend the AOT: '[10 days] from discovery of failure to meet the LCO.' The [10 day] Completion Time cap is found by adding the maximum Completion Times from the two Conditions that could extend the AOT."

The decision to add the second Completion Time is summarized in a memo from the NRC to the industry lead plant representatives dated December 16, 1991. Both memos are attached.

It is important to note that this issue of "flip flopping" between Conditions only applies if the LCO is not met. If the LCO requirements are met, even if for an instant, this issue does not occur. This is a highly unlikely scenario and the Industry argued that it would never occur, but the NRC believed it should be addressed when developing the ISTS because there were no other regulatory processes, in place at that time which could prevent or respond to such a situation, should it occur.

Section 1.3 of the ISTS, Example 1.3-3, describes the use of this type of second Completion Time. The ISTS NUREGs contain these types of second Completion Times in the following Specifications:

" AC Sources - Operating (BWRs and PWRs)

Distribution Systems - Operating. (BWRs and PWRs)

Containment Spray and Cooling (PWRs)

Auxiliary / Emergency Feedwater System (PWRs)

" Standby Liquid Control (SLC) System (BWRs)

The addition of these second Completion Times did not originally create an operational restriction because the likelihood of experiencing concurrent failures such that the second Completion Time is limiting is very remote.

However, these second Completion Times became a problem when the Industry proposed risk-informed Completion Times for some of the Specifications which contained the second Completion Times.

Specifically TSTF-409, Containment Spray System Completion Time Extension (CE NPSD-1045-A),

and TSTF-430, AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1). These Travelers extended a Completion Time and, following the methodology described in the August 5, 1991 memo, the second Completion Time was extended by the same amount (i.e., the second Completion Time continued to be the sum of the two Completion Times.) However, in letters to the TSTF dated November Page 2

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 15, 2001 and September 10, 2002, the NRC stated that the extension of the second Completion Time in TSTF-409 and TSTF-430 was inappropriate because one of the two Completion Times added to obtain the second Completion Time limit was risk based and the other was deterministic. On September 10, 2002, the NRC provided a letter making a similar statement regarding TSTF-430. Eventually, the NRC accepted that it was acceptable to add these two Completion Times and TSTF-409 and TSTF-430 were approved. However, second Completion Times complicate the presentation of the ISTS and complicate the implementation of risk-informed Completion Times. In addition, other regulatory requirements, not present when the ISTS NUREGs were originally developed, eliminate the need for these second Completion Times.

4.0 TECHNICAL ANALYSIS

The adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which could prevent this misuse of the Technical Specifications. However, that is no longer the case. There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent.

The Maintenance Rule: 10 CFR 50.65 (a)(1), the Maintenance Rule, requires each licensee to monitor the performance or condition of SSCs against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken. The NRC Resident Inspectors monitor the licensee's Corrective Action process and could take action if the licensee's maintenance program allowed the systems required by a single LCO to become concurrently inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65 (a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the ACTIONS of the Technical Specifications and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65 (a)(3).

Under the Technical Specifications the Completion Time for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, if the two systems were required by the same LCO. However 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO.

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable. This Page 3

Attachment 5 To ULNRC-05445 TSTF439, Rev. 2 comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the Technical Specifications.

The Reactor Oversight Process: NEI 99-02, "Regulatory Assessment Performance Indicator Guideline,"

describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NEI document is endorsed by RIS 2001-11, "Voluntary Submission Of Performance Indicator Data." NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System LCOs), and the Auxiliary feedwater system. Extended unavailability of these systems due to multiple entries into the ACTIONS would affect the NRC's evaluation of the licensee's performance under the ROP.

In addition to these programs, a requirement is added to Section 1.3 of the Technical Specifications to require licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This Technical Specification requirement, when considered with the regulatory processes discussed above, provide an equivalent or superior level of plant safety without the unnecessary complication of the Technical Specifications by second Completion Times on some Specifications.

Each of the Specifications affected by this Traveler are discussed below.

AC Sources - Operating(BWRs and PWRs)

Specification 3.8.1, AC Sources - Operating, has a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one offsite circuit inoperable (Condition A) and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one diesel generator inoperable (Condition B). Both Condition A and Condition B have a second Completion Time of "6 days from discovery of failure to meet the LCO." The second Completion Time limits plant operation when Condition A or B is entered, and before the inoperable system is restored, the other Condition is entered, and then the first inoperable system is restored, and before the remaining inoperable system is restored, the other Condition is entered again. This highly improbable scenario is further limited by Condition D which applies when an offsite circuit and a DG are inoperable. It limits plant operation in this Condition to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . See Example 1 for an illustration.

Time 0 Limited by second Completion Time to 6 days LL Less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Diesel Inoperable Diesel Inoperable Condition A Condition A

.* * '* Inoperabilities must overlap and must be less than 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by Condition Ds Offsite Circuit Inoperable Condition B Less than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Example 1 Page 4

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 As stated above, the Reactor Oversight Process monitors the availability of mitigating systems, including the emergency AC sources (DG unavailability). Such frequent, repeated failures of the AC sources would be reported to the NRC and this represents a strong disincentive to such operation.

DistributionSystems - Operating (BWRs and PWRs)

Specification 3.8.9, Distribution Systems - Operating, has an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for one or more AC electrical power distribution subsystems inoperable (Condition A), and a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for one or more AC vital buses (Condition B) or one or more DC electrical power subsystems (Condition C) inoperable. Conditions A, B, and C have a second Completion Time of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO. Condition E applies if two or more electrical distribution subsystems are inoperable and, if it results in a loss of safety function, LCO 3.0.3 must be entered immediately. See Example 2.

Time = 0 Limited by second Completion Time to 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months I I Less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AC subsystem inoperable AC subsystem inoperable Condition A Condition A Inoperabilities mutoverlap.Iflso-

___----- safety function, enter LCO 3.0.3 Vital AC bus immediately by Condition E inoperable Condition B or DC s subsystem than 2 inoperable hours Condition C Example 2 The second Completion Time is not needed. First, it is unusual for an AC electrical power subsystem or AC vital bus to be inoperable without causing a reactor trip. Secondly, Completion Times are very short (8 and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) providing little time to restore systems such that the Conditions overlap and multiple inoperabilities occur. Lastly, should any overlapping inoperabilities that result in a loss of safety function occur, a plant shutdown in accordance with LCO 3.0.3 is required.

ContainmentSpray and Cooling (PWRs)

Specification 3.6.6A, Containment Spray and Cooling Systems (Credit taken for iodine removal), has a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one containment spray train inoperable (Condition A) and a 7 day Completion Time for one containment cooling train inoperable (Condition B). Conditions A and B have a second Completion Time of 10 days from discovery of failure to meet the LCO. Condition F also states that if two containment spray trains are inoperable or any combination of three or more trains are inoperable, LCO 3.0.3 must be entered immediately. Specification 3.6.6B, Containment Spray and Cooling Systems (Credit not taken for iodine removal), has a 7 day Completion Time for one containment spray train inoperable (Condition A) and a 7 day Completion Time for one containment cooling train inoperable (Condition B). Conditions A and B have a second Completion Time of 14 days from Page 5

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 discovery of failure to meet the LCO. Condition G also states that if any combination of three or more trains are inoperable, LCO 3.0.3 must be entered immediately. See Example 3 for an illustration of Specification 3.6.6A.

Time=0 I II Limited by second Completion Time to 10 days Less than 7 days Less than 7 days One containment cooling train One containment cooling train inoperable inoperable Condition C Condition C 14Inoperabilities; must overlap. Ifan

~combination of three or more trains, One /"] '1 enter LCO 3.0.3 immediately by containment Condition F spray train inoperable 0LsIN (Condition A)th n7 hours Example 3 The second Completion Time is not needed. Any combination of two of the four trains can perform the safety function. Adverse combinations require entry into LCO 3.0.3. The second Completion Time restricts operation with only one train inoperable, but that is unnecessary because when one train is inoperable, there are still three operable trains and only two trains are needed to perform the safety function. Therefore, the second Completion Time is overly restrictive.

Auxiliary / Emergency FeedwaterSystem (PWRs)

Specification 3.7.5, Auxiliary Feedwater System (NUREG-1430 - Emergency Feedwater System) has a 7 day Completion Time for one inoperable steam supply to a turbine driven AFW pump (rendering the turbine driven AFW pump inoperable) (Condition A) and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one AFW train inoperable (Condition B). Conditions A and B have a second Completion Time of 10 days from discovery of failure to meet the LCO. In order for the second Completion Time to be limiting, entry into and out of Conditions A and B must occur, which requires the turbine driven and motor driven AFW pumps to be concurrently inoperable. However, Condition C states that if AFW trains are inoperable the plant must be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . See Example 4.

Page 6

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 Time=O I Limited by second Completion Time to 10 daysII IBPI Less than 7 days Less than 7 days i 4 One steam driven AFW train One steam driven AFW train inoperable inoperable Condition A Condition A I* Inoperabilities One motor must overlap.

driven AFW tnprabie Two trains inoperable requires Condition B Lethns7 immediate shutdown by Condition C hours Example 4 The second Completion Time is not needed. For the second Completion Time to be limiting, Conditions A and B must be entered concurrently. However, Condition C requires an immediate shutdown when two trains are inoperable. Therefore, the second Completion Time will never be limiting and can be removed.

In addition, the Reactor Oversight Process monitors the availability of the AFW system. Such frequent, repeated failures of the AFW system would be reported to the NRC and this represents a strong disincentive to such operation.

Standby Liquid Control (SLC) System (BWRs)

Specification 3.1.7, Standby Liquid Control has a 7 day Completion Time for one inoperable SLC subsystem (Condition B) and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for the boron concentration of the boron solution storage tank not within limits (Condition A). The boron solution storage tank is shared by both SLC trains. Conditions A and B have a second Completion Time of 10 days from discovery of failure to meet the LCO. See Example 5.

Page 7

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 Time=O Limited by second Completion Time to 10 days I Less than 7 days Less than 7 days One SLC subsystem One SLC subsystem inoperable inoperable Condition A Condition A I Boron ,nopera ,lites concentration not must overlap.

within limit but I greater than cold shutdown value.

Otherwise immediate than 72 shutdown under hours LCO 3.0.3 Example 5 The second Completion Time is not needed. There are other similar specifications which provide for the parameters of a common tank to be inoperable (for example, PWR Refueling Water Storage Tank) which do not employ a second Completion Time. There is also no significant safety concern. As stated in the Bases, when in Condition A the SLC systems are capable of performing their original design basis function and the SLC system capability still exists for vessel injection. Therefore, the second Completion Time is overly conservative and not required.

In addition to these regulatory programs, Section 1.3 of the Technical Specifications is revised to require administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

Based on the above discussions, the concern regarding multiple continuous entries into Conditions without meeting the LCO is addressed by the system unavailability monitoring programs described above and the administrative controls required by Section 1.3 of the Technical Specifications. Therefore, this potential concern is no longer an issue and the Technical Specifications can be simplified by eliminating the second Completion Times with no detriment to plant safety.

5.0 REGULATORY ANALYSIS

5,1 No Significant Hazards Consideration NUREG-1430, Standard Technical Specifications for Babcock & Wilcox plants, is modified. Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6 Required Actions A. 1 and C. 1, Technical Specification 3.7.5 Required Actions A. 1 and B. 1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A. 1, B. 1, and C. 1 is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

Page 8

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 NUREG-1431 and NUREG-1432, Standard Technical Specifications for Westinghouse and Combustion Engineering plants, respectively, are modified. Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.6.6A Required Actions A. 1 and C. 1, Technical Specification 3.6.6B Required Actions A. 1 and B. 1, Technical Specification 3.7.5 Required Actions A. 1 and B. 1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A. 1, B. 1, and C. I is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

NUREG- 1433 and NUREG-1434, Standard Technical Specifications for Boiling Water Reactors, BWR/4 and BWR/6 respectively, are modified. Completion Times Example 1.3-3 is revised to eliminate the second completion times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with Technical Specification 3.1.7 Required Actions A. 1 and B. 1, Technical Specification 3.8.1 Required Actions A.3 and B.4, and Technical Specification 3.8.9 Required Actions A. 1, B. 1, and C. I is being deleted. The Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time.

The TSTF has evaluated whether or not a significant hazards consideration is involved~with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment,"

as discussed below:

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

Response: No.

The proposed changes eliminate certain Completion Times from the Technical Specifications.

Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed changes do not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed changes do not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed changes are consistent with the safety analysis assumptions and resultant consequences.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

Page 9

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The changes do not alter any assumptions made in the safety analysis.

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 change involve a significant reduction in a margin of safety?

Response: No.

The proposed change to delete the second Completion Time does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined.

The safety analysis acceptance criteria are not affected by this change. The proposed changes will not result in plant operation in a configuration outside of the design basis.

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

Based on the above, the TSTF 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.

5.2 Applicable Regulatory Requirements 10 CFR 50.36, "Technical Specifications." 10 CFR 50.36(c)(2) states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." The revised Actions continue to meet the requirements of this regulation.

10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.

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 manmer, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that 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 (ill) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 10

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2

7.0 REFERENCES

1. Memorandum from Gordon Vytlacil (NRC) to TSPS (NRC), dated August 5, 1991, "Summary of potential Allowed Outage Time (AOT) extension issue."

2. Gordon M. Vytlacil (NRC) to Lee Bush (WOG), et al, dated December 16, 1991, "Information on the Completion Time Cap - to be discussed at Wednesdays meeting with Chris Grimes."

Page 11

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND 6 days fromA discovcr;y of failWro to moot LGO C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable, inoperable when its discovery of redundant required Condition C feature(s) is inoperable, concurrent with inoperability of redundant required features AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

D. One [required] offsite --------------- NOTE ----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no One [required] DG AC power source to any train.

inoperable.

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

OR D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

WOG STS 3.8.1-3 Rev. 3.0, 03/31/04

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) failure is repaired, the common cause failure no longer exists, and Required Action B.3.1 is satisfied. Ifthe cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s),

performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to completing either B.3.1 or B.3.2, the [plant corrective action program) will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), [241 hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem as the inoperable DG.

B.4 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The scco~d GComplotion Timo fc Required ArcAio B.4 a limit

,stablishcs on the maximum timc a!lc-'d for any combination of roquircd AC powc cor~eeeG te be inepcrable during0 any Singlo centiguouc6 occurrence of failing to mooet the LCOQ. if Condition B is onto rod whole, for instance, an offcito cfircuit or, inoperable and that circit is eubsequontY rostoro OPERABLE, the LCO mfay alrcady hayc bccn not moet for Up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This could load to a total of 144 hour0.00167 days 0.04 hours 2.380952e-4 weeks 5.4792e-5 months ,p in~eo initial failure to moot tho LCO, to restore the 9G. At thirs time, an offcitc circ;uit could agai bocome inoperable, the DG rostorod OPERABLE, and an additioa 72 hourS (for a total of 9 dayc) allowod prior to complcte restora-tion Of tho-LCO. The 6 day Com~pletion Time provyides a limit 9R time allowed in a specified condition after discover; of failure to mooet the LCO. This limit is coeiAro~d reasonable forF Situlations in Which Condkitios A and B aro ontfrod concurrently. The "AND" connos~tGr bohyeen the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 6 day Compleio Timcs MoeanisGthat boeth Completion Timer, apply s~fimultaneously, and the mo-re- rotieioCmpletion Time muist be met.

B 3.8.1-9 Rev. 3.0, 03/31/04 WOG STS WOG STS B 3.8.1-9 Rev. 3.0, 03/31/04

Attachment 5 To ULNRC-05445 TSTF-439, Rev. 2 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

Ac inRoquirod Action B.2, the Complotion TimoG aIIoWc forF an oxcoption to) thO nrE*ma*l "ti Zor" o 1 bog0ining tho allowod time "clock." T hic will forF ro'ult in octablichinR the 4"6tFimZr" at the time that tho LCO warin not moet, inctoad Of at the timo Condition B wac ontord C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a complete loss of redundant required safety functions. The Completion Time for this failure of redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

The Completion Time for Required Action C.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable and

b. A required feature is inoperable.

If at any time during the existence of Condition C (two offsite circuits inoperable) a required feature becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

WOG STS B 3.8.1-10 Rev. 3.0. 03/31/04

Attachment 6 To ULNRC-05445 ATTACHMENT 6

SUMMARY

OF REGULATORY COMMITMENTS

Attachment 6 "to To ULNRC-05445

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies those actions committed to by AmerenUE in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Scott Maglio, Assistant Manager - Regulatory Affairs, (573) 676-8719.

COMMITMENT Due Date/Event The proposed changes to the Callaway Technical Specifications Prior to December will be implemented prior to December 31, 2008. 31, 2008.

No PRA-modeled equipment, other than the affected ESW Administrative train, will be voluntarily taken out-of-service during the one- controls in place at time extended Completion Time taken on each train. No work time amendment is will be allowed on the protected (operable) ESW train. implemented.

Access to the switchyard will be limited and no work will be Administrative allowed in the switchyard during the one-time extended controls in place at Completion Time. time amendment is implemented.

The one-time extended Completion Time will not be scheduled Administrative during forecasted inclement weather conditions. National controls in place at Weather Service reports will be monitored prior to and time amendment is throughout each ESW train LCO outage., implemented.

The one-time extended Completion Time will be used such that Administrative the piping tie-in (new underground PE ESW piping to the rest controls in place at of the system) will be performed with the normal service water time amendment is system cooling the affected ESW train heat loads for most of implemented.

the 14-day Completion Time (minus the times discussed in the Tier 2 commitments). During the portion of the extended Completion Time that normal service water is supplying the ESW loads, automatic closure signals for the normal service water to ESW supply and return cross-connect valves will be defeated. Automatic open signals for the ESW return to UHS valves will also be defeated during this portion of the extended Completion Time as well.

Appropriate training will be provided to operations personnel Administrative on this TS change and the associated ESW modification, as controls in place at well as the compensatory measures to be implemented during time amendment is the one-time extended Completion Time. implemented.

v t e Letter Sequence Request
TAC:MD6792, Addition of New Tech Spec on RCS Boron Limits and Revisions to Tech Spec 3.3.1 to Address Rwfs (Open) TAC:MD7252, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance Administration Meeting, Meeting, Meeting, Meeting Questions 7 February 2008 10 June 2008 24 June 2008 Answers Results Approval... Other: ML070390057, ML082630799, ML082630800, ULNRC-05563, One-Time Completion Time Extension for Essential Service Water System
MONTHYEAR2008-02-07 [Table View]

ULNRC-05445, One-Time Completion Time Extension for Essential Service Water (ESW) System

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Reference:

7.1 REFERENCES

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

Conclusion:

6.0 ENVIRONMENTAL CONSIDERATION

7.1 REFERENCES

SUBJECT:

Contact:

Description:

Description:

Description:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

SUMMARY

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ULNRC-05445, One-Time Completion Time Extension for Essential Service Water (ESW) System

Text

Reference:

7.1 REFERENCES

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

Conclusion:

6.0 ENVIRONMENTAL CONSIDERATION

7.1 REFERENCES

SUBJECT:

Contact:

Description:

Description:

Description:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

SUMMARY

SUMMARY

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