Text

Revision to Technical Specification Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (License Amendment Request OL-1287)
	ML080230473
Person / Time
Site:	Callaway
Issue date:	01/14/2008
From:	Graessle L; AmerenUE
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-448, Rev 3, ULNRC-05463
	Download: ML080230473 (69)
	v • d • e

AmerenUE P0 Box 620 Cal/away Plant Fulton, MO 65251 January 14, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 w"AmoemUELadies and Gentlemen: ULNRC-05463 DOCKET NUMIBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

REVISION TO TECHNICAL SPECIFICATION REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (LICENSE AMENDMENT REOUEST OL-1287)

Pursuant to 10 CFR 50.90, AmerenUE hereby requests an amendment to Facility Operating License No. NPF-30 for the Callaway plant. The proposed amendment would modify Technical Specification (TS) requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3.

The availability of this TS improvement was announced in the Federal Register on January 17, 2007 (72 FR 2022) as part of the consolidated line item improvement process.

Attachment 1 provides a description of the proposed changes, the requested confirmation of applicability, and plant specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes.

Attachment 3 provides revised (clean) TS pages. Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachment 5 provides the existing TS Bases pages marked up to show proposed changes for information only and will be implemented under the TS 5.5.14 Bases Control Program after NRC approval of 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 a subsidiary of Ameren Corporation

ULNRC-05463 January 14, 2008 Page 2 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

This amendment application was reviewed by the Onsite Review Committee and the Nuclear Safety Review Board. In accordance with 10 CFR 50.91, a copy of this amendment application, with attachments, is being provided to the designated Missouri State official.

AmerenUE requests approval of the proposed amendment by January 2009. The changes proposed are not required to address an immediate safety concern. It is anticipated that the license amendment, as approved, will be effective upon issuance, to be implemented within 120 days from the date of issuance.

Please contact Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479 for any questions you may have regarding this application.

I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Executed on: January 14, 2008 Luke H. Graessle Manager - Regulatory Affairs BFH/nls Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-up)

3. Revised Technical Specification Pages

4. Regulatory Commitments

5. Proposed Technical Specification Bases Changes (Mark-up)

ULNRC-05463 January 14, 2008 Page 3 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. E. E. Collins 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 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8B1 Washington, DC 20555-2738 Mr. Mohan C. Thadani (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-05463 January 14, 2008 Page 4 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly 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 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

ULNRC-05463 Page 1 of 6 ULNRC-05463 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL EVALUATION

ULNRC-05463 Page 2 of 6

1.0 DESCRIPTION

The proposed amendment would modify Technical Specification (TS) requirements related to control room envelope habitability in TS 3.7.10, "Control Room Emergency Ventilation System (CREVS)," and TS Section 5.5, "Administrative Controls - Programs and Manuals."

The changes are consistent with Nuclear Regulatory Commission (NRC) noticed Industry Technical Specification Task Force (TSTF) Standard Technical Specification change TSTF-448 Revision 3, "Control Room Habitability." This TS improvement was published in the Federal Register on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation AmerenUE has reviewed the Safety Evaluation dated January 17, 2007, provided as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-448. AmerenUE has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to the Callaway plant and justify this amendment for the incorporation of the changes to the Callaway Technical Specifications.

2.2 Optional Changes and Variations The TS changes proposed per this license amendment request for the Callaway Plant are consistent with the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staff s model safety evaluation dated January 17, 2007, except as noted below.

1. In Section 3.3 of the model safety evaluation (SE), Evaluations 1, 4, 6, and the last paragraph of Section 3.3 are applicable to Callaway with the exception that the ASTM E741 tracer gas test cannot be performed due to Callaway's design, as further explained below.

The Callaway/SNUPPS (Callaway/Standardized Nuclear Unit Power Plant System) control room envelope (CRE) design is unique. The Control Building envelope (CBE) by and large surrounds the CRE. The CRE is required by Technical Specifications to be at a positive pressure with respect to its surrounding environment. The CBE is also designed to be at a positive pressure with respect to its surrounding environment although not positive with respect to the CRE. In the emergency pressurization and filtration

ULNRC-05463 Page 3 of 6 mode, the Control Room air volume receives air through a filtration system that takes suction on the CBE. The CBE in turn receives filtered air from the outside environment.

The Generic Letter 2003-01 proposed ASTM E741 test methodology is designed for testing a single zone and implicitly assumes that all air can be categorized as either unfiltered outside air or filtered inside air. As described above, the SNUPPS plant design has two separate control zones, the CRE and the CBE. It is invalid to treat them as merely different volumes within a common zone. Based on the SNUPPS plant design, the licensing basis consequence analyses for DBA's has three categories of air:

unfiltered outside air, single filtered control building air, and double filtered Control Room air.

The CBE has multiple common boundaries with the CRE. With the CRE pressurized, a substantial fraction of the out-leakage from the CRE will go into the CBE. This air could then be drawn back intothe filtered pressurization system and put back into the Control Room. The current ASTM E741 tracer gas test does not account for re- introduction of tracer gas back into the test volume, potentially leading to erroneous and non-conservative inleakage test results.

In order to provide valid test results for Callaway's configuration Ameren chose to perform an alternate tracer gas test using the Atmospheric Tracer Depletion (ATD) Method. The ATD Method is described in AmerenUE letters dated December 15, 2004 (ULNRC-05104), June 6, 2006 (ULNRC-05298), July 16, 2007 (ULNRC-05427), and October 30, 2007 (ULNRC-05448). The NRC staff concluded by letter dated November 30, 2007, that the ATD method is acceptable for Callaway Plant.

Properly addressing the CRE-CBE configuration for Callaway, particularly with regard to use of the ATD test methods, requires some modification of the TS changes proposed per TSTF-448, without changing the intent of the changes prescribed per the TSTF. Specifically, proposed TS 5.5.17.c identifies the following exception to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

The Tracer Gas Test based on the Brookhaven National Laboratory Atmospheric Tracer Depletion (ATD) Method is used to determine the unfiltered air inleakage past the CRE boundary in the CRE. The ATD Method is described in AmerenUE letters dated December 15, 2004 (ULNRC-05104), June 6, 2006 (ULNRC-05298), July 16, 2007 (ULNRC-05427), and October 30, 2007 (ULNRC-05448).

ULNRC-05463 Page 4 of 6 In addition, and consistent with the above, in TS 3.7.10, TS 5.5.17, and TS Bases 3.7.10 the phrase "control room envelope (CRE) boundary" [as recommended per TSTF-448] is replaced with "control room envelope (CRE) and control building envelope (CBE) boundaries" where appropriate.

The CRE and CBE boundaries are addressed together or separately, as applicable.

2. The new Required Action B.2 in TS 3.7.10 per TSTF-448 states, "Verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits." However, as described in Regulatory Guide 1.196, there are no "limits" for chemical and smoke hazards. AmerenUE is changing Required Action B.2'in TS 3.7.10 to eliminate any confusion or misunderstanding about the mitigation of chemical and smoke hazards. Proposed Required Action B.2 in TS 3.7.10 now states, "Verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits and CRE occupants are protected from chemical and smoke hazards."

3. The last sentence regarding unfiltered air inleakage limits for hazardous chemicals meeting the assumptions of the licensing basis (as proposed per TSTF-448) has not been included in TS 5.5.17.e. There are no quantitative limits for hazardous chemicals. Additionally, per the Callaway licensing basis, hazardous chemicals are not stored or used onsite in quantities sufficient to necessitate CRE protection, as required by Regulatory Guide 1.78. Nearby industrial, military, and transportation facilities present no hazard to the operation of Callaway, and there are no site-related design basis events due to accidents at these facilities.

4. In the Applicable Safety Analyses section of TS Bases 3.7.10, the discussion of hazardous chemical releases and smoke challenges is clarified by indicating that hazardous chemicals are not stored or used onsite in quantities sufficient to necessitate CRE protection, as required by Regulatory Guide 1.78. It is further explained that the analysis for smoke and hazardous chemical releases assume no CREVS actuation for such events, consistent with the current plant design. In the future, if the Callaway design or environment changes, new Required Action B.2 of TS 3.7.10 addresses hazardous chemicals and smoke to assure that appropriate mitigating actions and/or design feature(s) are considered.

5. In the TS Bases 3.7.10 section that addresses Surveillance Requirement (SR) 3.7.10.3, AmerenUE is maintaining the current discussion regarding the basis for the 18 month Frequency that was incorporated during the conversion to the improved Standard Technical Specifications. There are slight differences in the wording compared to the suggested wording in the

ULNRC-05463 Page 5 of 6 TSTF. However, differences are minor and do not have any safety significance.

6. In the TS Bases 3.7.10 section that addresses Surveillance Requirement (SR) 3.7.10.4, the discussion of hazardous chemical releases and smoke challenges is clarified by inserting the wording, "For Callaway, there is no CREVS actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements that verify OPERABILITY for hazardous chemicals or smoke." This clarification represents the current plant-specific design. In the future, if the Callaway design or environment changes, new Required Action B.2 of TS 3.7.10 addresses hazardous chemicals and smoke to assure that appropriate mitigating actions and/or design feature(s) are considered.

7. The addition of the Control Room Habitability Program results in changes to the Table of Contents, page iv, due to page number changes for Sections 5.6 and 5.7. In addition, there are minor differences in TS numbering and in the TS Bases references. These differences are administrative in nature and do not have any safety significance.

2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements AmerenUE proposes the following as a license condition to support implementation of the proposed TS changes:

Upon implementation of License Amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) and control building envelope (CBE) boundary unfiltered air inleakage as required by SR 3.7.10.4, in accordance with TS 5.5.17.c.(i), the assessment of CRE habitability as required by Specification 5.5.17.c.(ii), and the measurement of control room pressure as required by Specification 5.5.17.d, shall be considered met.

Following implementation:

(a) The first performance of SR 3.7.10.4, in accordance with Specification 5.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from September 19, 2004, the date of the most recent successful tracer gas test, as stated in the December 15, 2004, letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.5.17.c.(ii), shall be within 3 years, plus the 9-month

ULNRC-05463 Page 6 of 6 allowance of SR 3.0.2, as measured from September 19, 2004, the date of the most recent successful tracer gas test, as stated in the November 16, 2004, letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of control room pressure, Specification 5.5.17.d, shall be within 18 months plus the 138 days allowed by SR 3.0.2, as measured from March 16, 2007, the date of the most recent successful pressure measurement test.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination AmerenUE has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

AmerenUE has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Callaway and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.9 1(a).

4.0 ENVIRONMENTAL EVALUATION AmerenUE has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007, as part of the CLIIP. AmerenUE has concluded that the staff's findings presented in that evaluation are applicable to the Callaway Plant and the evaluation is hereby incorporated by reference in this application.

5.0 REFERENCES

5.1 ULNRC-05104, "Response to Generic Letter 2003-01, Control Room Habitability," dated December 15, 2004.

5.2 ULNRC-05298, "Amended Response to Generic Letter 2003-01, Control Room Habitability," dated June 6, 2006.

5.3 ULNRC-05427, "Response to Request forAdditional Information Concerning Generic Letter 2003-01, Control Room Habitability," dated July 16, 2007.

5.4 ULNRC-05448, "Responses to Requests for Additional Information Regarding Generic Letter 2003-01, Control Room Habitability," dated October 30, 2007.

5.5 NRC Letter, "Callaway Plant, Unit 1 - Responses to Genric Letter 2003-01, Control Room Habitability (TAC NO. MB9783)," dated November 30, 2007.

ULNRC-05463 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

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.

Te control roomn-bewndwy may be opened intermittently under Cdiistrat!ive 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 for reasons other inoperable/ t OPERABLE status.

than Condition B.

B. TwoeREG-*FS t,.r.tn..4 R .. control room to.. 24.-h *"

nape~ale dw-- te-boundany to OPERABLEI inoPcrablc control room tus Insert 3.7.1 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, or 4. 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 3.7-25 Amendment No. 176

TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 3.6.3 Containment Isolation Valves ......................................................... 3.6-7 3.6.4 C ontainm ent P ressure ..................................................................... 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 P LA NT S YS T E MS ................................................................................. 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) ................................................................ 3.7-23 3.7.10 Control Room Emergency Ventilation System (CREVS) ........ 3.7-2 3.7.11 Control Room Air Conditioning System (CRACS) ............. ..3.7-2-29 3.7.12 Not Used . ................................................................................. . . 3.7- 4 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 Boron Concentration ...................... 3. -,37-- 38 3.7.17 Spent Fuel Assembly Storage ...................................................... .3.7-3 40 3.7.18 Secondary Specific Activity ........................................................ 3.7 42 3.8 ELECTRICAL POWER SYSTEMS ........................................................ 3.8-1 3.8.1 A C S ources - O perating ................................................................... 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 D C Sources - O perating .................................................................. 3.8-22 3.8.5 DC Sources - Shutdown .................................................................. 3.8-25 3.8.6 Battery C ell Param eters ................................................................... 3.8-27 3.8.7 Inverters - O perating ........................................................................ 3.8-31 3.8.8 Inverters - S hutdow n ........................................................................ 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 176

TABLE OF CONTENTS 3.9 REFUELING O PERATIO NS ................................................................ 3.9-1 3.9.1 Boron Concentration ........................................................................ 3.9-1 3.9.2 Unborated W ater Source Isolation Valves ....................................... 3.9-3 3.9.3 Nuclear Instrum entation ................................................................... 3.9-5 3.9.4 Containment Penetrations ............................................................... 3.9-7 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation - High W ater Level ................................................... 3.9-9 3.9.6 Residual Heat Removal (RHR) and Coolant Circulation - Low W ater Level .................................................... 3.9-1 1 3.9.7 Refueling Pool W ater Level ............................................................. 3.9-13 4.0 DESIG N FEATURES ............................................................................... 4.0-1 4.1 Site Location .................................................................................... 4.0-1 4.2 Reactor Core ......................................................... ,:........................ 4.0-1 4.3 Fuel Storage .................................................................................... 4.0-1 5.0 ADM INISTRATIVE CO NTRO LS ........................................................... 5.0-1 5.1 Responsibility ................................................................................... 5.0-1 5.2 Organization .................................................................................... 5.0-2 5.3 Unit Staff Q ualifications ................................................................... 5.0-4 5.4 Procedures ...................................................................................... 5.0-5 5.5 Program s and Manuals ................................................................ 5. -

5.6 Reporting Requirem ents ............................................................. 5.0-. , 22 5.7 High Radiation Area ................................... ........................... .0-,. 27 CALLAWAY PLANT 4 Amendment 181

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.

d~n fr--envelope (CRE) and control building eenvelopee (CBBEE) bboundarriess Te control roorrlbeundwy may be opened intermittently under d iistrative control.

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

ACTIONS COMPLETIONTIME CONDITION REQUIRED ACTION TIME A. One CREVS train' A.1 Restore CREVS train to 7 days for reasons other inoperable/ L OPERABLE status.

than ConditionB1 B. Two CREVS train. B Rcctorc control room 24-he94s inOPcablc control room tus boHunday On MODES 1, 2, Insert 3.7.1 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, or 4. 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 3.7-25 Amendment No. 176

INSERT 3.7.10.B B. One or more CREVS trains B.1 Initiate action to Immediately inoperable due to an implement mitigating inoperable CRE boundary or actions.

an inoperable CBE boundary in MODE 1, 2, 3, or 4. AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B.2 Verify mitigating actions to ensure CRE occupant radiological exposure will not exceed limits and CRE occupants are protected from chemical and smoke hazards.

AND B.3 Restore the CRE 90 days boundary and CBE boundary to OPERABLE status CALLAWAY PLANT 3.7-25 Amendment No.

CREVS 3.7.10 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION 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.

OR AND One or more CREVS trains inoperable due to an inoperable CRE boundary or an E.2 Suspend movement of Immediately inoperable CBE boundary in MODE 5 or irradiated fuel 6, or during movement of irradiated fuel assemblies.

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 3.7-26 Amendment No. 184

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

SR 3.7.10 4 Vorify on GRE ,S can maintain a p train ,,itivo ,,18,nOths on a o 25inchoG Water gaUgc, olatiVc to SA the utside atmesphcrc duFrin the QRVIS moedc of TS AI I - Perform required unfiltered air inleakage testing of the CRE L-In accordance with and CBE boundaries in accordance with the Control Room the Control Room Habitability Program. Habitability Program CALLAWAY PLANT 3.7-27 Amendment No. 176

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Containment Leakage Rate Testing Program (continued)

2. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.

3. The unit is excepted from post-modification integrated leakage rate testing requirements associated with steam generator replacement during the Refuel 14 outage (fall of 2005).

b. The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 48.1 psig.

c. The maximum allowable containment leakage rate, La, at Pa, shall be 0.20% of the containment air weight per day.

d. Leakage rate acceptance criteria are:

1. Containment leakage rate acceptance criterion is *1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and _< 0.75 La for Type A tests;

2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is _<0.05 La when tested at

Ž Pa; b) For each door, leakage rate is _ 0.005 La when pressurized to _>10 psig.

e. The provisions or Technical Specification SR 3.0.2 do not apply to the test frequencies in the Containment Leakage Rate Testing Program.

f. The provisions of Technical Specification SR 3.0.3 are applicable to the Insert 5.5.17 Containment Leakage Rate Testing Program.

CALLAWAY PLANT 5.0-19 Amendment 168

Insert 5.5.17 -

5.5.17 Control Room Habitability Program A Control Room Habitability Program shall be established and implemented to ensure that control room envelope (CRE) habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE, CRE boundary, control building envelope (CBE), and the CBE Boundary.

b. Requirements for maintaining the CRE and CBE boundaries in their design condition, including configuration control and preventive maintenance.

c. Requirements for (i) determining the unfiltered air inleakage past the CRE and CBE boundaries in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room En*velope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following exception is taken to Sections C.1 and C02 of Regulatory Guide 1.197, Revision 0:

1. The Tracer Gas Test based on the Brookhaven National Laboratory Atmospheric Tracer Depletion (ATD) Method is used to determine the unfiltered air inleakage past the CRE and CBE boundaries. The ATD Method is described in AmerenUE letters dated December 15, 2004 (ULNRC-05104), June 6, 2006 (ULNRC-05298), July 16, 2007 (ULNRC-05427), and October 30, 2007 (ULNRC-05448).

d. Measurement, at designated locations, of the control room pressure relative to the outside atmosphere during the pressurization mode of operation by one train of the CREVS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS.

The results shall be trended and used as part of the 18 month assessment of the control room.

Insert 5.5.17 Continued

e. The quantitative limits on unfiltered air inleakage into CRE and CBE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing control room habitability, determining CRE and CBE unfiltered inleakage, and measuring control room pressure and assessing CRE and CBE as required by paragraphs c and d, respectively.

ATTACHMENT 3 REVISED TECHNICAL SPECIFICATION PAGES

TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS (continued) 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) ................................................................ 3.7-23 3.7.10 Control Room Emergency Ventilation System (CREVS) ................. 3.7-25 3.7.11 Control Room Air Conditioning System (CRACS) ........................... 3.7-29 3 .7 .12 N ot U se d . ......................................................................................... 3 .7 -3 2 3.7.13 Emergency Exhaust System (EES) ....................... 3.7-33 3 .7 .14 N ot Use d . ......................................................................................... 3 .7 -36 3.7.15 Fuel Storage Pool Water Level ........................................................ 3.7-37 3.7.16 Fuel Storage Pool Boron Concentration .......................................... 3.7-38 3.7.17 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 - O perating ...................................................................... . 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 ###

TABLE OF CONTENTS 3.9 REFUELING O PERATIO NS ................................................................. 3.9-1 3.9.1 Boron Concentration ........................................................................ 3.9-1 3.9.2 Unborated Water Source Isolation Valves ....................................... 3.9-3 3.9.3 Nuclear Instrum entation ................................................................... 3.9-5 3.9.4 Containm ent Penetrations ............................................................... 3.9-7 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation - High W ater Level ................................................... 3.9-9 3.9.6 Residual Heat Removal (RHR) and Coolant Circulation - Low W ater Level .................................................... 3.9-11 3.9.7 Refueling Pool W ater Level ............................................................. 3.9-13 4.0 DESIG N FEATURES ............................................................................... 4.0-1 4.1 Site Location .................................................................................... 4.0-1 4.2 Reactor Core ................................................................................... 4.0-1 4.3 Fuel Storage ........................................ 4.0-1 5.0 ADM INISTRATIVE CO NTRO LS ........................................................... 5.0-1 5.1 Responsibility ................................................................................... 5.0-1 5.2 O rganization .................................................................................... 5.0-2 5.3 Unit Staff Q ualifications ................................................................... 5.0-4 5.4 Procedures ...................................................................................... 5.0-5 5.5 Program s and Manuals ..................................................................... 5.0-6 5.6 Reporting Requirem ents ................ ;-.................................................. 5.0-22 5.7 High Radiation Area ......................................................................... 5.0-27 CALLAWAY PLANT 4 . Amendment ###

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 envelope (CRE) and control building envelope (CBE) boundaries 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 for reasons other OPERABLE status.

than Condition B.

(continued)

CALLAWAY PLANT 3.7-25 Amendment No. ###

CREVS 3.7.10 ACTIONS (continued)

COMPLETION REQUIRED ACTION TIME CONDITION TIME B. One or more CREVS trains B.1 Initiate action to Immediately inoperable due to an implement mitigating inoperable CRE boundary or actions.

an inoperable CBE boundary in MODE 1,2, 3, or 4. AND B.2 Verify mitigating actions to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant radiological exposure will not exceed limits and CRE occupants are protected from chemical and smoke hazards.

AND B.3 Restore the CRE 90 days boundary and CBE boundary to OPERABLE status 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, or 4.

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. ###

CREVS 3.7.10 COMPLETION TIME CONDITION REQUIRED ACTION TIME D. Required Action and D.1 Place OPERABLE Immediately associated Completion Time CREVS train in CRVIS of Condition A not met in mode.

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 OR E.2 Suspend movement of Immediately One or more CREVS trains irradiated fuel inoperable due to an assemblies.

inoperable CRE boundary or an inoperable CBE boundary in MODE 5 or 6, or during movement of 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. ###

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). the 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 Perform required unfiltered air inleakage testing of the In accordance with CRE and CBE boundaries in accordance with the the Control Room Control Room Habitability Program. Habitability Program CALLAWAY PLANT 3.7-28 Amendment No. ###

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

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, or4.

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

CRACS 3.7.11 SURVEILLANCE REQUIREMENTS k 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

3.7.12 3.7 PLANT SYSTEMS 3.7.12 Not Used.

CALLAWAY PLANT 3.7-32 Amendment No. ###

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 REQUIRED ACTION TIME CONDITION 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

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 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. ###

Emergency Exhaust System 3.7.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each EES train for _ 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

_ 0.25 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 anegative 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

3.7.14 3.7 PLANT SYSTEMS 3.7.14 Not Used.

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

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.

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

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION 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

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 Ž>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 CONDITION REQUIRED ACTION TIME 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

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

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 COMPLETION TIME CONDITION REQUIRED ACTION 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

Spent Fuel Assembly Storage 3.7.17 55000 50000 45000 40000 0>

ILi 35000 Lai W 30000 25000

-J 20000 02 15000

-j W

10000 Lii. .q I

5000 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. ###

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:!< 0.10 ýtCi/gm DOSE EQUIVALENT 1-131.

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

ACTIONS COMPLETION REQUIRED ACTION TIME CONDITION 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. ###

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Containment Leakage Rate Testing Program (continued)

2. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.

3. The unit is excepted from post-modification integrated leakage rate testing requirements associated with steam generator replacement during the Refuel 14 outage (fall of 2005).

b. The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 48.1 psig.

c. The maximum allowable containment leakage rate, La, at Pa, shall be 0.20% of the containment air weight per day.

d. Leakage rate acceptance criteria are:

1. Containment leakage rate acceptance criterion is _ 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and < 0.75 La for Type A tests;

2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is < 0.05 La when tested at

> Pa; b) For each door, leakage rate is _< 0.005 La when pressurized to _>10 psig.

e. The provisions or Technical Specification SR 3.0.2 do not apply to the test frequencies in the Containment Leakage Rate Testing Program.

f. The provisions of Technical Specification SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

(continued)

CALLAWAY PLANT 5.0-19 Amendment ###

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.17 Control Room Habitability Program A Control Room Habitability Program shall be established and implemented to ensure that control room envelope (CRE) habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving. radiation exposures in excess of 5 rem whole body or its equivalent to any part of the body for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE, CRE boundary, control building envelope (CBE), and the CBE Boundary.

b. Requirements for maintaining the CRE and CBE boundaries in their design condition, including configuration control and preventive maintenance.

c. Requirements for (i) determining the unfiltered air inleakage past the CRE and CBE boundaries in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii)assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following exception is taken to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

1. The Tracer Gas Test based on the Brookhaven National Laboratory Atmospheric Tracer Depletion (ATD) Method is used to determine the unfiltered air inleakage past the CRE and CBE boundaries. The ATD Method is described in AmerenUE letters dated December 15, 2004 (ULNRC-05104), June 6, 2006 (ULNRC-05298), July 16, 2007 (ULNRC-05427), and October 30, 2007 (ULNRC-05448).

d. Measurement, at designated locations, of the control room pressure relative to the outside atmosphere during the pressurization mode of operation by one train of the CREVS, operating at the flow rate required by the VFTP, at a Frequency of 18 months on a STAGGERED TEST BASIS.

The results shall be trended and used as part of the 18 month assessment of the control room.

(continued)

CALLAWAY PLANT 5.0-20 Amendment ###

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.17 Control Room Habitability Program (continued)

e. The quantitative limits on unfiltered air inleakage into CRE and CBE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing control room habitability, determining CRE and CBE unfiltered inleakage, and measuring control room pressure and assessing CRE and CBE as required by paragraphs c and d, respectively.

CALLAWAY PLANT 5.0-21 Amendment ###

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Not Used.

5.6.2 Annual Radiological Environmental Operatina Report The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 1 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period.

The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in a format similar to the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit during the previous year shall be submitted prior to May 1 of each year. in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 Not used.

(continued)

CALLAWAY PLANT 5.0-22 Amendment ### I

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1. Moderator Temperature Coefficient limits in Specification 3.1.3,

2. Shutdown Bank Insertion Limit for Specification 3.1.5,

3. Control Bank Insertion Limits for Specification 3.1.6,

4. Axial Flux Difference Limits for Specification 3.2.3,

5. Heat Flux Hot Channel Factor, FQ(Z), FQRTP, K(Z), W(Z) and FQ Penalty Factors for Specification 3.2.1,

6. Nuclear Enthalpy Rise Hot Channel Factor FNH, FAH RTP and Power Factor Multiplier, PFAH, limits for Specification 3.2.2,

7. Shutdown Margin Limits for Specifications 3.1.1, 3.1.4, 3.1.5, 3.1.6, and 3.1.8,

8. Reactor Core Safety Limits Figure for Specification 2.1.1,

9. Overtemperature AT and Overpower AT Setpoint Parameters for Specification 3.3.1, and

10. Reactor Coolant System Pressure and Temperature DNB Limits for Specification 3.4.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. WCAP-9272-P-A, "WESTINGHOUSE RELOAD SAFETY EVALUATION METHODOLOGY."

2. WCAP-10216-P-A, "RELAXATION OF CONSTANT AXIAL OFFSET CONTROL AND FQ SURVEILLANCE TECHNICAL SPECIFICATION."

3. WCAP-10266-P-A, "THE 1981 VERSION OF WESTINGHOUSE EVALUATION MODEL USING BASH CODE."

(continued)

CALLAWAY PLANT 5.0-23 Amendment ### I

Reporting Requirements 5.6 5.6 Reporting Requirements

4. WCAP-12610-P-A, "VANTAGE + FUEL ASSEMBLY REFERENCE CORE REPORT."

5. WCAP-11397-P-A, "REVISED THERMAL DESIGN PROCEDURE."

6. WCAP-14565-P-A, "VIPRE-01 MODELING AND QUALIFICATION FOR PRESSURIZED WATER REACTOR NON-LOCA THERMAL-HYDRAULIC SAFETY ANALYSIS."

7. WCAP-1 0851-P-A, "IMPROVED FUEL PERFORMANCE MODELS FOR WESTINGHOUSE FUEL ROD DESIGN AND SAFETY EVALUATIONS."

8. WCAP-15063-P-A, "WESTINGHOUSE IMPROVED PERFORMANCE ANALYSIS AND DESIGN MODEL (PAD 4.0)."

9. WCAP-8745-P-A, "DESIGN BASES FOR THE THERMAL OVERPOWER AT AND THERMAL OVERTEMPERATURE AT TRIP FUNCTIONS."

10. WCAP-1 0965-P-A, "ANC: A WESTINGHOUSE ADVANCED NODAL COMPUTER CODE."

11. WCAP-11596-P-A, "QUALIFICATION OF THE PHOENIX-P/ANC NUCLEAR DESIGN SYSTEM FOR PRESSURIZED WATER REACTOR CORES."

12. WCAP-13524-P-A, "APOLLO: A ONE DIMENSIONAL NEUTRON DIFFUSION THEORY PROGRAM."

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

(continued)

CALLAWAY PLANT 5.0-24 Amendment ### I

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, hydrostatic testing and PORV lift setting as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

1. Specification 3.4.3, "RCS Pressure and Temperature (P/T) Limits,"

and

2. Specification 3.4.12, "Cold Overpressure Mitigation System (COMS)."

b. The analytical methods used to determine the RCS pressure and temperature and COMS PORV limits shall be those previously reviewed and approved by the NRC, specifically those described in WCAP-14040-NP-A, "Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves".

c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.7 Not used.

5.6.8 PAM Report When a report is required by Condition B or G of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.9 Not used.

(continued)

CALLAWAY PLANT 5.0-25 Amendment ### I

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.10 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG;

b. Active degradation mechanisms found;

c. Nondestructive examination techniques utilized for each degradation mechanism;

d. Location, orientation (if linear), and measured sizes (if available) of service induced indications;

e. Number of tubes plugged during the inspection outage for each active degradation mechanism;

f. Total number and percentage of tubes plugged to date; and

g. The results of condition monitoring, including the results of tube pulls and in-situ testing.

CALLAWAY PLANT 5.0-26 Amendment ### I

High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601 (a) and (b) of 10 CFR Part 20:

5.7.1 High Radiation Areas with Dose Rates Not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation:

a. Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment;

b. Access to, and activities in, each such area shall be controlled by means of Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.

d. Each individual or group entering such an area shall possess:

1. A radiation monitoring device that continuously displays radiation dose rates in the area; or

2. A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or

3. A radiation monitoring device that continuously transmits does rate and cumulative dose rate information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area, or

4. A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and (continued)

CALLAWAY PLANT 5.0-27 Amendment 168

High Radiation Area 5.7 5.7 High Radiation Area 5.7.1 High Radiation Areas with Dose Rates Not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation: (continued)

(i) Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (ii) Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.

e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.

5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation:

a. Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and, in addition:

1. All such door and gate keys shall be maintained under the administrative control of the Shift Manager/Operating Supervisor or Radiation Protection Department Supervision, or his or her designee.

2. Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.

b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

(Continued)

CALLAWAY PLANT 5.0-28 Amendment 173

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation: (continued)

c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.

d. Each individual or group entering such an area shall possess:

1. A radiation monitoring device that continuously integrates the radiation rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or

2. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area with the means to communicate with and control every individual in the area, or

3. A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and (i) Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (ii) Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area, or

4. In those cases where options (2) and (3), above, are impractical or determined to be inconsistent with the "As Low As is Reasonably (Continued)

CALLAWAY PLANT 5.0-29 Amendment 168

High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation: (continued)

Achievable" principle, a radiation monitoring device that continuously displays radiation dose rates in the area.

e. Except for individual qualified in radiation protection procedures or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.

f. Such individual areas that are within a larger area, such as PWR containment, where no enclosure exists for the purpose of locking and where no enclosure can reasonably be constructed around the individual area need not be controlled by a locked door or gate nor continuously guarded, but shall be barricaded, conspicuously posted, and a clearly visible flashing light shall be activated at the area as a warning device.

CALLAWAY PLANT 5.0-30 Amendment 168

ULNRC-05463 Page 1 of 1 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 regulatory commitments. Please direct questions regarding these commitments to Tom Elwood, Supervising Engineer, Regulatory Affairs and Licensing at 573-676-6479.

Regulatory Commitments Due Date / Event AmerenUE will develop a control room habitability Program in place at time program to implement Technical Specification 5.5.17. amendment is implemented.

ATTACHMENT 5 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (For Information Only)

CREVS B 3.7.10 B 3.7 PLANT SYSTEMS B 3.7.10 Control Room Emergency Ventilation System (CREVS)

BASES BACKGROUND The CREVS provides a protected environment from which operators can control the unit following an uncontrolled release of radioactivity. The CREVS consists of two independent, redundant trains that pressurize, recirculate, and filter the control room air. Each CREVS train consists of a filtration system train and a pressurization system train. Each filtration system train consists of a fan, a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Each pressurization system train consists of a fan, a moisture separator, an electric heater, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a second HEPA filter follows the adsorber section to collect carbon fines. Ductwork, valves or dampers, and instrumentation also form part of the CREVS system.

The CREVS is an emergency system which may also operate during normal unit operations. Upon receipt of the actuating signal, normal air supply and exhaust to the tFGtreem is isolated, a portion of the control room envelope (CRE) ventilation air is recirculated through the system filter trains, and the pressurization system is started. The prefilters remove any large particles in the air, and a moisture separator removes any entrained water droplets present, to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each pressurization system train for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per month, with the heaters functioning, reduces moisture buildup on the HEPA filters and adsorbers. The heaters are important to the effectiveness of the charcoal adsorbers.

Actuation of the CREVS by a Control Room Ventilation Isolation Signal (CRVIS), places the system in the emergency mode of operation.

Actuation of the system to the emergency mode of operation closes the unfiltered outside air intake and unfiltered exhaust dampers, and aligns the system for recirculation of the GcotrIc reem airfthrough the redundant ithin the trains of HEPA and the charcoal filters. The emergency (CRVIS) mode also initiates pressurization and filtered ventilation of the air supply to the CRE CREcGR4Fntolrom.

The control room pressurization system draws in outside air, processing it through a particulate filter charcoal adsorber train for cleanup. This outside air is diluted with air drawn from the cable spreading rooms and the electrical equipment floor levels within the lontrol uilding and distributed back into those spaces for further dilution. The control room filtration units take a portion of air from the exhaust side of the (continued)

CALLAWAY PLANT B 3.7. 10-1 Revision 7

CREVS B 3.7.10 BASESI BACKGROUND system, upstream of the outside air intake, for dilution with portions of the (continued) exhaust air from the control room air-conditioning system and processes it through the control room filtration system adsorption train for additional cleanup. This air is then further diluted with the remaining control room air-conditioning system return air, cooled, and supplied to the*ee~tI

-eeM. This process will maintain the cntrol roome4under a positive I CRE pressure of 1/8 inch water gauge (min.) with respect to the outside atmosphere. This will assure exfiltration from theteei4.9 feel, thus CRE, preventing any unprocessed contaminants from entering thcectrc! ....

pressure boundary The air entering the control buildingiduring normal operation is continuously monitored by radiation, carbon dioxide/monoxide, and smoke detectors. A high radiation signal initiates the emergency (CRVIS) mode of operation; the other detectors provide an alarm in the control room. A CRVIS is initiated by the radiation monitors (GKRE0004 and GKRE0005), Fuel Building Ventilation Isolation Signal, Containment Isolation Phase A, the containment purge exhaust radiation monitors (GTRE0022 and GTRE0033), and manually. The instrumentation associated with actuation of the CREVS is addressed in LCO 3.3.7, "Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation."

Insert B 3.7.10 BKG 1 -o A single tra in c capablc of proeGurizing the control rooFm to > 0.125 inches wate.,au@4.e The CREVS operation in maintaining the control room habitable is discussed in the FSAR, Section 6. 4 t(Ref. 1V.

and 9.41- Land 9 Redundant pressurization and filtration trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failure of one damper to shut will not result in a breach of isolation. The CREVS is designed in accordance with Seismic Category I requirements. rq---- a habitable environment in the CRE The CREVS is designed to maintainh cortro rom trnvircrnmrnt for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body.

Insert B 3.7.10 BKG 2 -

APPLICABLE The CREVS components are arranged in redundant, safety related SAFETY ventilation trains. The location of components and ducting within the ANALYSES CRE control room nvel.*" e ensures an adequate supply of filtered air to all areas requiring access. The CREVS provides airborne radiological CRE occupants, protection for th cntro.,,l room op.ratorE,, as demonstrated by the GeRtFe4

/ ra t analyses for the most limiting design basis less-ef CRE occupant dose (continued)

CALLAWAY PLANT B 3.7.10-2 Revision 7

Insert B 3.7.10 BKG 1 A single CREVS train will pressurize the CRE to about 0.125 inches water gauge relative to the outside environment. The 0.125 inches water gauge positive pressure is obtained based on a nominal flowrate of 2000 cfm through the filtration filter, which includes 400 cfm of control building envelope (CBE) air.

Insert B 3.7.10 BKG 2 By operation of the control room pressurization trains and the control room filtration units, the CREVS pressurizes, recirculates~and filters air within the CRE as well as the CBE that generally surrounds the CRE. The boundaries of these two distinct but related volumes are credited in the analysis of record for limiting the inleakage of unfiltered outside air.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE.

The CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Habitability Program.

The CBE is an area that largely surrounds the CRE. Occupancy of the CBE is not required to control the unit during normal and accident conditions. The CBE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CBE. The CBE boundary must be maintained to ensure that the inleakage of unfiltered air into the CBE will not exceed the inleakage assumed in the licensing basis analysis of DBA consequences to CRE occupants. The CBE and its boundary are defined in the Control Room Habitability Program.

CREVS B 3.7.10 BASES APPLICABLE eeelaRt accident, fission product release presented in the FSAR, SAFETY Chapter 15A.3 (Ref. 2).

ANALYSES (continued) The worst case single active failure of a component of the CREVS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

Insert B 3.7.10 ASA I The CREVS satisfies Criterion 3 of 10 CFR 50.36 (c)(2)(ii).

1(r)n Two independent and redundant CREVS trains are required to b if

, such as from a loss of both ventilation OPERABLE to ensure that at least one is availablesm single active trains or from an inoperable CRE or failure disables the other train. Total system failure~could result in CBE boundary, exceeding a dose of 5 re to the cnrc9 rcc,, epcmt .in the event of a large radioactive release.1I CRE occupants g

wo u The- RF-V& is considered OPERABLE when the individual components whole body or its equivalent to necessary to limit .p. atertexposure are OPERABLE ItbethFaiRe A any part of the body CREVS train is OPERABLE when the associated: GRE occupants Each CREVS train a. Control Room Air Conditioner, filtration and pressurization fans are OPERABLE;

b. HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions;

c. Heater, moisture separator, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

Insert B 3.7.10 LCO I In .ddt.ion. th .ont rol ... 9rm

.rc... boundr ....MuCt bc maintainod.

in f IR in Inciuaina9 thP intPqr-;yt oth tflo alir,. TiAAqort.1RS ceilinac. ducwoKq-AndAcc

-*7v deGFG.

SCRE and CBE boundaries The LCO is modified by a Note allowing theý,nrb F9FRm beunda.'y to be Insert B 3.7.10 LC0 2 opened intermittently under administrative controls.tFor entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings these should be proceduralized and controlstconsist of stationing a dedicated individual at the opening who is operators in continuous communication with thetc.ntrol room.. This individual will in the CRE.

have a method to rapidly close the openin when a need for G11-491 F0ho-C and thereby restore the affected isolation is indicated. r Cotrols A--t tdmendtc(Rcf. 5) add-rccs the L.. RE envelope boundary to a condition I roqA-FP Ahirl--

Aloclc

" 'j equivalent to the design condition Note that the Control Room Air Conditioning System (CRACS) forms a I

subsystem to the CREVS. The CREVS remains capable of performing its safety function provided the CRACS air flow path is intact and air circulation can be maintained. Isolation or breach of the CRACS air flow (continued)

CALLAWAY PLANT B 3.7.10-3 Revision 7

/?

Insert B 3.7.10 ASA 1 The CREVS provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases (Ref. 7) determined that hazardous chemicals are not stored or used onsite in quantities sufficient to necessitate CRE protection as required by Regulatory Guide 1.78 (Ref. 8). The evaluation of a smoke challenge demonstrates that such an event will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 1). The analysis for smoke and hazardous chemical releases accordingly assumes no CREVS actuation for such events Insert B 3.7.10 LCO 1 In order for the CREVS trains to be considered OPERABLE, the CRE and CBE boundaries must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBA's.

Insert B 3.7.10 LCO 2 This Note only applies to openings in the CRE and CBE boundaries that can be rapidly restored to the intended design condition, suchas doors, hatches, floor plugs, and access panels.

CREVS B 3.7.10 BASES LCO path can also render the CREVS flow path inoperable. In these (continued) situations, LCOs 3.7.10 and 3.7.11 may be applicable.

F-the APPLICABILITY In MODES 1, 2, 3, and 4,CREVS must be OPERABLE to EeRtF9' ensure ensurethat the thtteCRE will wlre remain anhabitable-' prrcxpu

.. ... .....and... during and following a LOCA or SGTR.

and In MODE 5 6, the CREVS is required to cope with the design basis release from the rupture of a waste gas decay tank.

During movement of irradiated fuel assemblies, the CREVS must be OPERABLE to cope with the release from a design basis fuel handling accident inside containment or in the fuel building.

ACTIONS A.1 Insert B 3.7.10.A.1 When one CREVS train is inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREVS train is adequate to perform the centrel Feem CRE occupant protection function. However, the overall reliability is reduced because a eimR& failure in the OPERABLE CREVS train could result in loss of CREVS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

B.1, 1B.2, and B.3 Insert B 3.7.10.B. 1 if the conrol room boun.-dary is inpoRrable i* MODE 1, 2, 3, or 4 .uch that Reither CREVS train can cstablish the roquired positivc p..reure (but the trains are not othorxscn prbl, action must be taken to restore an OPERABLE co*ntrl rm boun`4dary Within 24 hourS. Dn,,.'g the p..id that the control room boun.da.y is in-porabe, approp;*ate cempensator, measurct (consistent With the intent of GDC 10) should be utilized to pr.t.t conrol room. o.peratorsfr potential hazards s'uch as radioactiVe EcEntamination, toxic*chemicals, smk,,. tomperature and rolativ" humidity, and physical secur~bity. (Apfpopriate compensator Leo es inc/lude those suc~h as describe-d forF the- LCO Note in1A the LCO BRases- above).

For the purposes of a*,ss eGsing Whether ConditGn*

applie-s, "-,Rotrol room ntcrudb P9140GRG of the Control Building boundary duo to t*

bnayedar,' May analyz~ed interaction bepweeR the ControlBuilding and control room atmespfleres duAFrng emergency op98ration o thle GREVS, including the (continued)

CALLAWAY PLANT B 3.7.10-4 Revision 7

I Insert B 3.7.10.A.1 for reasons other than an inoperable CRE or CBE boundary Insert B 3.7.10.B.1 If the unfiltered inleakage of potentially contaminated air past a CRE or CBE boundary credited in the accident analysis and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem whole body or its equivalent to any part of the body), actions must be taken to restore the affected boundary (or boundaries) to OPERABLE status within 90 days.

During the period that a CRE or CBE boundary credited in the accident analysis is considered inoperable, action must be initiated to implement mitigating actions to lessen the potential effect on CRE occupants from the hazards of a radiological event. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions ensure CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE or CBE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan, and possibly repair ant test most conditions adversely affecting the CRE or CBE boundary credited in the accident analysis.

CREVS B 3.7.10 BASES ACTIONS B.1 (continued) iffect of Control Buildirg boundar,' Iclakage, a modeled ORthe cORtrol room doec analyses for the DBA LOCA.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time or, roaconabic bacod 9n the low probability of a DBA occurring during thiG timo8 poriod, the availability of the GRE VS to p,,Vid, a filtered '**ir,,*,* t (albiot with potential contG'rl room inleakago), andI the uco of come~nc8atory meaGurec. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completien Time Or a reacsnablo tome to diagncGe, plaHn, repair, and toct mcst problcms with the control room boundaryF.

C.1 and C.2 inoperable CRE or CBE boundary7 In MODE 1,2, 3, or 4, if the inoperable CREVS train or',etrcl rGGm beu4dary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes accident risk. 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.

D.1, D.2.1, and D.2.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, if the inoperable CREVS train cannot be restored to OPERABLE status within the required Completion Time, action must be taken to immediately place the OPERABLE CREVS train in the CRVIS mode. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure would be readily detected.

An alternative to Required Action D. 1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of CRE. e Required Actions D.2.1 and D.2.2 would place the unit in a condition that minimizes risk. This does not preclude the movement of fuel to a safe position. L the accident (continued)

CALLAWAY PLANT B 3.7.10-5 Revision 7

CREVS B 3.7.10 BASES ACTIONS E.1 and E.2 (continued) or one or more CREVS trains inoperable In MODE 5 or 6, or during movement of irradiated fuel assemblies, with due to an inoperable CRE or CBE EV rain oerabl action must be taken immediately to boundary suspend activities that could result in a release of radioactivity that might

'nter the control room. This places the unit in a condition that minimizes the require isolation of the CRE. .. iaccident risk. This does not preclude the movement of fuel to a safe.

position.

F.1 If both CREVS trains are inoperable in MODE 1, 2, 3, or 4, for reasons CRE and CBE boundary other than an inoperabl *cGr9 re.m bou~dary (i.e., Condition B), the CREVS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.10.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every month, by initiating from the control room, flow through the HEPA filters and charcoal adsorbers of both the filtration and pressurization systems, provides an adequate check of this system.

Monthly heater operations dry out any moisture accumulated in the charcoal from humidity in the ambient air. Each pressurization system train must be operated for _>10 continuous hours with the heaters functioning. Functioning heaters will not necessarily have the heating elements energized continuously for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ; but will cycle depending on the air temperature. Each filtration system train need only be operated for

>_15 minutes to demonstrate the function of the system. The 31 day Frequency is based on the reliability of the equipment and the two train redundancy availabilit.

SR 3.7.10.2 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP).

The CREVS filter tests use the test procedure guidance in Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the (continued)

CALLAWAY PLANT B 3.7.10-6 Revision 7

CREVS B 3.7.10 BASES SURVEILLANCE SR 3.7.10.2 (continued)

REQUIREMENTS physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.10.3 This SR verifies that each CREVS train starts and operates on an actual or simulated actuation signal. The actuation signal includes Control Room Ventilation Isolation or Fuel Building Ventilation Isolation. The CREVS train automatically switches on an actual or simulated CRVIS signal into a CRVIS mode of operation with flow through the HEPA filters and charcoal adsorber banks. The Surveillance Requirement also verifies that a control room ventilation isolation signal (CRVIS) will be received by the LOCA sequencer to enable an automatic start of the Diesel Generator loads that are associated with a CRVIS. Verification that these loads will start and operate at the appropriate step in the LOCA sequencer and that other auto-start signals for these loads will be inhibited until the LOCA sequencer is reset is accomplished under Surveillance Requirement SR 3.8.1.12. The Frequency of 18 months is consistent with the typical operating cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the 18 month frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.10.4 Insert B 3.7.10 SR 4 This SR .... ific. the intcgity of the control room enRclsuFe, and the assumed inleakagc ratcs of the potontially contaMinatcd air. The conrolI roomA positiVc preSSUrc, with respect to the otieatmosphce, is perioidically tested to vorif,' propcr functioning of the CREVS. During the ORVIS mo~dc of opcration, the CREVS Is dosigned to pressurize the control room Ž!0.125 inches water; gauge positiVe prFuc ihrspect to the outside atmosphere in ordcr to provont u-nfiltorod inlcakage. The CREVS is dcsigcd to, maintain this positive pFresure wi.t.h Anc train. The FrceqUcncy of 18 mon~ths 9R a STAGGEREDQ TEST BASIS is G9nsistcnt with the guidancc provigded inNUREG 0800 (Ref. 1).

REFERENCES 1. FSAR, Section 6.4, Habitability Systems.

2. FSAR, Chapter 15A.3, Control Room Radiological Consequences Calculation Models.

(continued)

CALLAWAY PLANT B 3.7.10-7 Revision 7

Insert B 3.7.10 SR 4 This SR verifies the OPERABILITY of the CRE and CBE boundaries credited in the accident analysis by testing for unfiltered are inleakage past the credited envelope boundaries and into the CRE. The details of the testing are specified in the Control Room Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem whole body or its equivalent to any part of the body and the CRE occupants are protected from hazardous chemicals and smoke. For the Callaway plant, there is no CREVS actuation for hazardous chemical releases or smoke and there are no Surveillance Requirements that verify OPERABILITY for hazardous chemicals or smoke. This SR verifies that the unfiltered air inleakage into CRE and CBE boundaries credited in the accident analysis is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater then the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the envelope boundary credited in the accident analysis to OPERABLE status provided mitigating actions can ensure that the CRE remains with the licensing basis habitability limits for the occupants following an accident.

Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 4) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 5). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 6). Options for restoring the envelope boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the envelope boundary credited in the accident analysis, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the envelope boundary credited in the accident analysis has been restored to OPERABLE status.

CREVS B 3.7.10 BASES REFERENCES 3. Regulatory Guide 1.52, Rev. 2, Design, Testing, and Maintenance (continued) Criteria for Atmospheric Cleanup System Air Filtration and Adsorption Units of Light Water Cooled Nuclear Power Plants.

Insert B 3.7.10 REF 4- NUREG 0800, Section 6.4, Rev. 2, July 1981, Standlard Review Plan fGr the Review o~f Safoty Analysic Repeots for Puclolar Power PIet -. ,

S ro,,.-cdure ErDP ZZ 04107, HVAC F , 66, e Bounda*y -aR4 Watertight (DoorConro1.

CALLAWAY PLANT B 3.7.10-8 Revision 7

Insert B 3.7.10 REF

4. Regulatory Guide 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," Revision 1.

5. NEI 99-03, "Control Room Habitability Assessment," June 2001.

6. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

7. FSAR Section 2.2, Nearby Industrial, Transportation, and Military Facilities.

8. Regulatory Guide 1.78, "Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release," Rev. 0.

9. FSAR Section 9.4, Air Conditioning, Heating, Cooling, and Ventilation.

v t e Letter Sequence Request
TAC:MD8006, Control Room Habitability, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation (Approved, Closed)
Initiation Request, Request Acceptance... Administration Questions 9 October 2008 Answers 26 November 2008 17 December 2008 Results Approval Other: ML100541229, TSTF-08-08, TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation.
MONTHYEAR2008-12-17 [Table View]

ULNRC-05463, Revision to Technical Specification Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (License Amendment Request OL-1287)

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ULNRC-05463, Revision to Technical Specification Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (License Amendment Request OL-1287)

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3.0 REGULATORY ANALYSIS

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