Text

License Amendment Request OL-1253 Elimination of Technical Specification Requirements for Hydrogen Recombiners and Monitors Using the Consolidated Line Item Improvement Process
	ML091940542
Person / Time
Site:	Callaway
Issue date:	07/10/2009
From:	Sandbothe S; AmerenUE, Union Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ULNRC-05627
	Download: ML091940542 (50)
	v • d • e

Union Electric PO Box 620 Callawav Plant Fulton, MO 65251 July 10, 2009 ULNRC-05627 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:

~~

wAmeren DOCKET NUMBER 50-483 CALLAW AY PLANT UNIT 1 UE UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 LICENSE AMENDMENT REQUEST OL-1253 ELIMINATION OF TECHNICAL SPECIFICATION REQUIREMENTS FOR HYDROGEN RECOMBINERS AND MONITORS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Pursuant to 10 CFR 50.90, AmerenUE (Union Electric Company) hereby requests an amendment to Facility Operating License No. NPF-30 for the Callaway Plant.

The proposed amendment would delete the Technical Specification (TS) requirements for the containment hydrogen recombiners and hydrogen monitors. The proposed TS changes support implementation of the revision to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. As such, the TS changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP).

Besides the changes related to requirements for the hydrogen recombiners and monitors, this amendment application includes four unrelated, minor changes to correct typographical errors identified in Callaway'S Technical Specifications.

a subsidiary of Ameren Corporation

ULNRC-05627 July 10, 2009 Page 2 Information essential to this amendment application is provided in the attachments to this letter. Attachment 1 provides a description of the proposed changes. It also provides, with regard to the hydrogen recombiner and analyzer TS changes, the confirmation of applicability and plant-specific verifications and commitments as requested in the NRC's Notice of Availability in the Federal Register. Attachment 2 provides the affected TS pages marked-up to show the proposed changes. provides revised/retyped TS pages as they would appear with the proposed changes incorporated. Attachment 4 provides the TS Bases changes (for information only) that are anticipated for the changes to be made to the hydrogen recombiner and analyzer Technical Specifications. Revision to the TS Bases will be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment. Attachment 5 contains a summary of commitments made in conjunction with this application.

This amendment application was reviewed by the Callaway 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.

In light of the CLIIP supporting this amendment request, AmerenUE requests NRC approval within 12 months of the date of this letter. AmerenUE anticipates that the amendment will be effective upon issuance, with implementation no later than 90 days following issuance.

Please contact Scott Maglio, Assistant Manager, Regulatory Affairs at (573) 676-8719 for any questions you may have regarding this amendment application.

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

Sincerely, Executed on: ---J---+--t-/----=-I-o-+t-o-"'---~-"---

Scott Sandbothe Manager, Regulatory Affairs TBEIKRA Attachments: 1 Evaluation 2 Mark-up of Technical Specification Pages 3 Retyped Technical Specification Pages 4 TS Bases Changes (For Information Only) 5 Summary of Regulatory Commitments

ULNRC-05627 July 10, 2009 Page 3 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy)

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

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E . Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Licensing Proj ect Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G14 Washington, DC 20555-2738

ULNRC-05627 July 10, 2009 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

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

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

A. C. Heflin F. M. Diya T. E. Herrmann L. S. Sandbothe S. A. Maglio S. L. Gallagher L. M. Belsky (NSRB)

T. B. Elwood K. R. Austgen Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU)

Mr. Scott Bauer (Palo Verde)

Mr. Stan Ketelsen (PG&E)

Mr. Scott Head (STP)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Mr. Floyd Gilzow (DNR)

Attachment 1 ULNRC-05627 Page 1 of5 EVALUATION

1.0 DESCRIPTION

The proposed license amendment would delete Technical Specification (TS) 3.6.8, "Hydrogen Recombiners," and remove the containment hydrogen analyzers (monitors) from the scope ofTS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation." These proposed TS changes are intended to support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The subject changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 (68 FR 55416) as part of the consolidated line item improvement process (CLIIP).

Included in that Federal Register notice was a model safety evaluation (SE) for licensees to reference in their amendment applications.

2.0 PROPOSED CHANGE

S The proposed changes for the TS requirements concerning the hydrogen recombiners and monitors are described in detail below, i.e., in Section 2.1. The proposed changes for correcting typographical errors identified in the Technical Specifications, as mentioned in the cover letter of this application, are described in Section 2.2.

2.1. TS CHANGES PROPOSED PER TSTF-447 As noted above, the TS changes proposed for the hydrogen recombiners and monitors are in accordance with TSTF-447 (Rev. 1). Due to slight differences, however, between the Callaway Plant Technical Specifications (and TS Bases) and the model Standard Technical Specifications in NUREG-1431, Revision 2, "Standard Technical Specifications, Westinghouse Plants," minor variances from the TSTF mark-ups/changes are required to some degree. These variances are identified below and do not invalidate the NRC staff s model safety evaluation supporting the adoption of TSTF-447, Revision 1. Consistent with NRC-approved Revision 1 ofTSTF-447, the proposed TS changes consist of the following:

In TS 3.3.3, the Note in Condition C indicating that this Condition is not applicable to hydrogen analyzer channels is deleted. (This Note is not addressed in TSTF-447. However, removal of the hydrogen analyzers from the scope of Callaway TS 3.3.3 requires the removal of all references to the hydrogen analyzers, including this Note.)

Attachment 1 ULNRC-05627 Page 2 of5

In TS 3.3.3, Condition D is deleted (since it solely addresses inoperable hydrogen analyzers).

Deletion of Condition D requires revising the lettering of subsequent Conditions and Required Actions that are listed or identified in the ACTIONS Table and in Table 3.3.3-1.

This change includes removing the reference to this Condition from what will be Condition D (i.e., removing the "or D" in current Condition E).

The text of Surveillance Requirement (SR) 3.3.3.1 is revised to delete the words "for each required instrumentation channel that is normally energized." The hydrogen analyzers are the only instruments in the scope of TS 3.3.3 (Table 3.3 .3-1) to which these provisional words apply (i.e., the analyzers are the only instruments that are normally de-energized). It is therefore appropriate to remove the identified words since they would no longer be applicable upon removal of the hydrogen analyzer requirements. The words to be deleted are not included in the Standard Technical Specifications (NUREG-1431) since they are unique to Callaway with its normally de-energized hydrogen analyzers. Consequently, this change is not included in TSTF-447 and is a variance from the TSTF. The change is a necessary and minor one, however, and is consistent with the changes being made pursuant to TSTF-447.

In TS Table 3.3.3-1, Function 10, "Containment Hydrogen Analyzers," is deleted. The minor variance is that in TSTF-447 the "Hydrogen Monitors" function (identified as Function 11 in the TSTF/Standard Technical Specifications) is simply deleted, whereas in Callaway's mark-up Function 10 is deleted and identified as "Not Used." This precludes renumbering the subsequent Functions, thus minimizing changes to plant procedures.

TS 3.6.8, "Hydrogen Recombiners," is deleted in its entirety. Page 3 of the Table of Contents for the Technical Specifications is revised to reflect the deletion ofTS 3.6.8.

TS 5.6.8, "PAM Report," is revised to reflect changing Condition G to Condition Fin TS 3.3.3 (due to the second change described above).

As described in NRC-approved Revision 1 ofTSTF-447, the changes to TS 3.3.3 and TS 3.6.8 require changes to be made to the associated TS Bases sections. Proposed TS Bases changes, in the form of marked-up TS Bases pages, are indicated in Attachment 4 and are provided for information. (The changes indicated in Attachment 4 include correction of a typographical error on TS Bases page B 3.3.3-15, which is unrelated to the subject changes.) The TS Bases changes will be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment.

Attachment 1 ULNRC-05627 Page 3 of5 2.2 TS CHANGES FOR CORRECTION OF TYPOGRAPHICAL ERRORS The TS changes requested by AmerenUE for correction of typographical errors are as follows:

1. In order to conform with TSTF-GG-05-01, Writer's Guide for Plant-Specific Improved Technical Specifications, "With one" should be replaced with "One" in TS 3.7.4 CONDITION D. Similarly, "Associated" should be replaced with "associated" in REQUIRED ACTION D.1.

2. In TS 3.8.1 REQUIRED ACTION A.2 and C.1 the word "Modes" appears where "MODES" is intended. "Modes" should be replaced with "MODES" to indicate that this is a term defined in TS Section 1.1.

3. In part "e" ofTS 5.5.16, "Containment Leakage Rate Testing Program," the word "or" appears where the word "of' is intended. The "or" should be replaced with "of' so that the sentence begins, "The provisions of Technical Specification SR 3.0.2 do not apply ... "

4. A period that is inadvertently situated within the first sentence ofTS 5.6.3, "Radioactive Effluent Release Report," is to be removed. The unwanted period appears just after the phrase, "prior to May 1 of each year."

3.0 BACKGROUND

The background for this application and justification for the proposed changes concerning requirements for the hydrogen recombiners and monitors are adequately addressed by the NRC Notice of Availability published on September 25,2003 (68 FR 55416), the NRC Notice for Comment published August 2,2002 (67 FR 50374), TSTF-447 (Revision 1), and the documentation associated with the 10 CFR 50.44 rulemaking.

4.0 TECHNICAL ANALYSIS

With regard to the changes proposed for Callaway'S Technical Specifications concerning the hydrogen recombiners and monitors, AmerenUE has reviewed the model SE that was published for such changes on September 25,2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE as well as the information provided to support TSTF-447, Revision 1. AmerenUE has concluded that the justifications presented in the TSTF and the SE prepared by the NRC staff are applicable to the Callaway Plant and justify AmerenUE's proposed changes to the Technical Specifications for the hydrogen recombiners and monitors.

No technical or regulatory analysis is required for the proposed typographical corrections included in this application.

Attachment 1 ULNRC-05627 Page 4 of5

5.0 REGULATORY ANALYSIS

5.1 NO SIGNIFICANT HAZARDS CONSIDERATION AmerenUE has reviewed the proposed no significant hazards consideration detennination published on September 25,2003 (68 FR 55416) as part of the CLIIP for the hydrogen recombiner and hydrogen monitor TS changes. AmerenUE has concluded that the proposed detennination presented in the Federal Register notice is applicable to the changes proposed for Callaway's Technical Specifications. Therefore, that detennination, including the conclusion that the requested changes do not involve a significant hazards consideration, is hereby incorporated into this application by reference pursuant to the requirements of 10 CFR 50.91(a).

For the TS changes requested to correct typographical errors identified in Callaway's Technical Specifications, AmerenUE similarly concludes that these changes do not involve a significant hazards consideration. That is, pursuant to 10 CFR 50.91(a), by applying the criteria or standards set forth in 10 CFR 50.92, AmerenUE concludes that the proposed typographical changes do not involve a significant increase in the probability or consequences of an accident previously evaluated, do not create the possibility of a new or different kind of accident from any previously evaluated, and do not involve a significant reduction in the margin of safety, based on the nature of these changes. They are strictly for the purpose of correcting typographical errors and do not change the TS requirements themselves. They involve no changes to the facility, its safety analyses or design requirements, or the manner in which it is operated or expected to respond under nonnal or accident conditions.

5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA A regulatory basis and analysis for the TS changes concerning the hydrogen recombiners and monitors was provided in the NRC Notice of Availability published on September 25,2003 (68 FR 55416), as well as TSTF-447 (Revision 1) and the documentation associated with the 10 CFR 50.44 rulemaking.

6.0 ENVIRONMENTAL CONSIDERATION

AmerenUE has reviewed the environmental evaluation included in the model SE published on September 25,2003 (68 FR 55416) as part of the CLIIP for the hydrogen recombiner and hydrogen monitor TS changes. AmerenUE has concluded that the NRC staffs findings presented in that evaluation are applicable to the proposed TS changes for Callaway, and on that basis the evaluation is hereby incorporated by reference in this application. This includes the conclusion that the proposed changes involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

For the proposed TS changes to correct typographical errors, AmerenUE makes a similar conclusion. That is, based on the nature of these changes, which do not change the affected TS requirements themselves or any other requirements, and do not involve any changes to the

Attachment 1 ULNRC-05627 Page 5 of5 facility whatsoever, it may be concluded that the proposed changes involve no significant increase in the amounts and no significant increase in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. As stated in Section 5.2, these changes involve no significant hazards consideration. Consequently, it may be concluded that the changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

7.0 VERIFICATION AND COMMITMENTS With respect to the model SE published in the Federal Register on September 25,2003 (68 FR 55416) for the TS improvements concerning the hydrogen recombiners and monitors, AmerenUE is making the following verifications and regulatory commitments:

1. AmerenUE has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at the Callaway Plant, and therefore AmerenUE is making a regulatory commitment to maintain that capability.

Requirements for the hydrogen monitors (analyzers) will thus be included in Chapter 16 of the Final Safety Analysis Report when the associated TS changes are implemented. The requirements contained therein will be commensurate with the requirements applicable to the monitors under revised 10 CFR 50.44. This regulatory commitment will be implemented as part of implementing the requested amendment (after NRC approval of the requested amendment). [Note: This commitment regarding the hydrogen monitors is also summarized in Attachment 5.]

2. Callaway Plant does not have an inerted containment.

8.0 REFERENCES

1. Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25,2003 (68 FR 55416).

2. Federal Register Notice: Combustible Gas Control in Containment, Proposed Rule published August 2,2002 (67 FR 50374)

3. Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," Revision 1.

4. Federal Register Notice: Combustible Gas Control in Containment, Final Rule published September 16,2003 (68 FR 54123)

Attachment 2 ULNRC-05627 ATTACHMENT 2 MARK-UP OF 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

~/ / / /~d¢g¢l RJco.¢b~er$l.7.... -/- .. / .. *I .. / .. *I.. *I .../ .../ ..././.. / ../3~1l.'?J 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 Tan k (CST) .................................................... 3.7 -17 3.7.7 Component Cooling Water (CCW) System ..................................... 3.7-19 3.7.8 Essential Service Water System (ESW) .......................................... 3.7-21 3.7.9 Ultimate Heat Sink (UHS) ................................................................ 3.7-24 3.7.10 Control Room Emergency Ventilation System (CREVS) ................. 3.7-26 3.7.11 Control Room Air Conditioning System (CRACS) ........................... 3.7 -30 3.7.12 Not Used .......................................................................................... 3.7-33 3.7.13 Emergency Exhaust System (EES) ................................................. 3.7-34 3.7.14 Not Used .......................................................................................... 3.7-37 3.7.15 Fuel Storage Pool Water Level ........................................................ 3.7-38 3.7.16 Fuel Storage Pool Boron Concentration .......................................... 3.7 -39 3.7.17 Spent Fuel Assembly Storage ......................................................... 3.7 -41 3.7.18 Secondary Specific Activity .............................................................. 3.7-43 3.8 ELECTRICAL POWER SYSTEMS ........................................................ 3.8-1 3.8.1 AC Sources - Operating ................................................................... 3.8-1 3.8.2 AC Sources - Shutdown .................................................................. 3.8-16 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air ....................................... 3.8-19 3.8.4 DC Sources - Operating .................................................................. 3.8-22 3.8.5 DC Sources - Shutdown .................................................................. 3.8-25 3.8.6 Battery Cell Parameters ................................................................... 3.8-27 3.8.7 Inverters - Operating ........................................................................ 3.8-31 3.8.8 Inverters - Shutdown ........................................................................ 3.8-33 3.8.9 Distribution Systems - Operating ..................................................... 3.8-35 3.8.10 Distribution Systems - Shutdown ..................................................... 3.8-37 CALLAWAY PLANT 3 Amendment 190

3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTIONS

NOT E -----------------------------------------------------------

Separate Condition entry is allowed for each Function.

COMPLETION CONDITION REQUIRED ACTION TIME A. One or more Functions with A.1 Restore required 30 days one required channel channel to OPERABLE inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A not Specification 5.6.8.

met.

(continued)

CALLAWAY PLANT 3.3-47 Amendment No. 189 I

PAM Instrumentation 3.3.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C"r~~~~

C.1 Restore all but one 7 days

~-:~~t~;ty--J!J channel to OPERABLE status.

One or more Functions with two or more required channels inoperable.

y./'~~~:~~,,=/'

/ 7*n/"7~/ /

~(fi) Required Action and ~Enter the Condition Immediately tJiT' associated Completion Time of Condition C 8 referenced in Table 3.3.3-1 for the not met. channel.

~ Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND

@@ Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

<iff@ Initiate action in Immediately accordance with Specification 5.6.8.

CALLAWAY PLANT 3.3-48 Amendment No. 189 I

PAM Instrumentation 3.3.3 SURVEILLANCE REQUIREMENTS

NOT E -----------------------------------------------------------

SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 31 days SR 3.3.3.2 --------------------------------- NOT E ----------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. 18 months CALLAWAY PLANT 3.3-49 Amendment No. 189 I

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 2)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED REQUIR~

FUNCTION CHANNELS ACTION~ ~

2

1. Neutron Flux

2. Reactor Coolant System (RCS) Hot Leg 2 Temperature (Wide Range)

3. RCS Cold Leg Temperature (Wide Range) 2

4. RCS Pressure (Wide Range) 2

5. Reactor Vessel Level Indicating System 2 (RVLlS)

6. 2 i!lJ:SO Containment Normal Sump Water Level

7. Containment Pressure (Normal Range) 2 (If) E:

8. Steam Line Pressure 2 per steam generator 4;

9. Containment Radiation Level (High Range) 2 ~

~ 10.

11.

~t;?~;(y'd)&9~~e~ / / / / / 7'/ /,// £)

Pressurizer Water Level 2 12.

13.

Steam Generator Water Level (Wide Range)

Steam Generator Water Level (Narrow Range) 4 2 per steam generator 9

(continued)

CALLAWAY PLANT 3.3-50 Amendment No. 189 I

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 2 of 2)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED REQUIR~

FUNCTION CHANNELS ACTION~~

14. Core Exit Temperature - Quadrant 1 2(a)

15. Core Exit Temperature - Quadrant 2 2(a)

16. Core Exit Temperature - Quadrant 3 2(a)

17. Core Exit Temperature - Quadrant 4 2(a)

18. Auxiliary Feedwater Flow Rate 4

19. Refueling Water Storage Tank Level 2 (a) A channel consists of two core exit thermocouples (CETs).

CALLAWAY PLANT 3.3-51 Amendment No. 189 I

CALLAWAY PLANT 3.6-22 Amendment No. 164 CALLAWAY PLANT 3.6-23 Amendment No. 133 ASDs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Steam Dump Valves (ASDs)

LCO 3.7.4 Four ASD lines shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One required ASD line A.1 Restore required ASD 7 days inoperable for reasons line to OPERABLE other than excessive ASD status.

seat leakage.

B. Two required ASD lines B.1 Restore all but one 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable for reasons required ASD line to other than excessive ASD OPERABLE status.

seat leakage.

C. Three or more required C.1 Restore all but two 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ASD lines inoperable for required ASD lines to reasons other than OPERABLE status.

excessive ASD seat leakage.

(continued)

CALLAWAY PLANT 3.7-10 Amendment No. 176

ASDs 3.7.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME 0.1 Immediately anual iso ation valve(s).

AND 0.2 Restore ASD(s) to 30 days OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Ti me not met. AND E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CALLAWAY PLANT 3.7-11 Amendment No. 176

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s); and

c. Load Shedder and Emergency Load Sequencer (LSELS) for Train A and Train B.

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

ACTIONS

NOT E -----------------------------------------------------------

LCO 3.0.4.b is not applicable to DGs.

COMPLETION CONDITION REQUIRED ACTION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE offsite circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 ------------ NOTE -----------

I 1, 2, and 3, the urbine driven auxiliary feedwater pump is considered a required redundant feature.

(continued)

CALLAWAY PLANT 3.8-1 Amendment No. 164

AC Sources - Operating 3.8.1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. One DG inoperable. B.4 Restore DG to ---------N 0 T E---------

(continued) OPERABLE status. A one-time Completion Time of 14 days is allowed to support planned replacement of ESW 'B' train piping prior to April 30, 2009.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 6 days from discovery of failure to meet LCO C. Two offsite circuits C.1 inoperable. 1,2, and 3, the turbine driven auxiliary feedwater pump is considered a required redundant feature.

Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from feature(s) inoperable discovery of when its redundant Condition C required feature(s) is concurrent with inoperable. inoperabilityof redundant required features AND (continued)

CALLAWAY PLANT 3.8-4 Amendment 191

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 Band 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.

~Technical Specification SR 3.0.2 do not apply to the test

---e-.--T-h-e-p-r-o-v-is-io-n-s.....

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.

CALLAWAY PLANT 5.0-19 Amendment 168

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 Operating 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 IVB.2, IVB.3, and IVC.

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~

accordance with 10 CFR 50.36a. The report shall include a summa e 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 IVB.1.

5.6.4 Not used.

(continued)

CALLAWAY PLANT 5.0-22 Amendment 190 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 (PIT) 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 Usedto 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 rff)

When a report is required by Condition B or@~o 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 190 I

Attachment 3 ULNRC-05627 ATTACHMENT 3 RETYPED 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 3.7 PLANT SYSTEMS ................................................................................. 3.7-1 3.7.1 Main Steam Safety Valves (MSSVs) ............................................... 3.7-1 3.7.2 Main Steam Isolation Valves (MSIVs) ............................................ 3.7-5 3.7.3 MFIVs and MFRVs and MFRV Bypass Valves ............................... 3.7-8 3.7.4 Atmospheric Steam Dump Valves (ASDs) ...................................... 3.7-10 3.7.5 Auxiliary Feedwater (AFW) System ................................................. 3.7-13 3.7.6 Condensate Storage Tank (CST) .................................................... 3.7-17 3.7.7 Component Cooling Water (CCW) System ..................................... 3.7-19 3.7.8 Essential Service Water System (ESW) .......................................... 3.7-21 3.7.9 Ultimate Heat Sink (UHS) ................................................................ 3.7-24 3.7.10 Control Room Emergency Ventilation System (CREVS) ................. 3.7-26 3.7.11 Control Room Air Conditioning System (CRACS) ........................... 3.7-30 3.7.12 Not Used .......................................................................................... 3.7-33 3.7.13 Emergency Exhaust System (EES) ................................................. 3. 7-34 3.7.14 Not Used .......................................................................................... 3.7-37 3.7.15 Fuel Storage Pool Water Level ........................................................ 3.7 -38 3.7.16 Fuel Storage Pool Boron Concentration .......................................... 3.7-39 3.7.17 Spent Fuel Assembly Storage ......................................................... 3.7-41 3.7.18 Secondary Specific Activity .............................................................. 3.7-43 3.8 ELECTRICAL POWER SYSTEMS ........................................................ 3.8-1 3.8.1 AC Sources - Operating ................................................................... 3.8-1 3.8.2 AC Sources - Shutdown .................................................................. 3.8-16 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air ....................................... 3.8-19 3.8.4 DC Sources - Operating .................................................................. 3.8-22 3.8.5 DC Sources - Shutdown .................................................................. 3.8-25 3.8.6 Battery Cell Parameters ................................................................... 3.8-27 3.8.7 Inverters - Operating ........................................................................ 3.8-31 3.8.8 Inverters - Shutdown ........................................................................ 3.8-33 3.8.9 Distribution Systems - Operating ..................................................... 3.8-35 3.8.10 Distribution Systems - Shutdown ..................................................... 3.8-37 CALLAWAY PLANT 3 Amendment ###

PAM Instrumentation 3.3.3 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. One or more Functions with C.1 Restore all but one 7 days two or more required channel to OPERABLE channels inoperable. status.

D. Required Action and 0.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C not Table 3.3.3-1 for the met. channel.

E. As required by Required E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action 0.1 and referenced in Table 3.3.3-1. AND E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. As required by Required F.1 Initiate action in Immediately Action 0.1 and referenced accordance with in Table 3.3.3-1. Specification 5.6.8.

CALLAWAY PLANT 3.3-48 Amendment No. ###

PAM Instrumentation 3.3.3 SURVEILLANCE REQUIREMENTS

NOT E -----------------------------------------------------------

SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK. 31 days SR 3.3.3.2 --------------------------------- NOT E ----------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. 18 months CALLAWAY PLANT 3.3-49 Amendment No. ###

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 2)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED REQUIRED FUNCTION CHANNELS ACTION 0.1 2 E

1. Neutron Flux

2. Reactor Coolant System (RCS) Hot Leg 2 E Temperature (Wide Range)

3. RCS Cold Leg Temperature (Wide Range) 2 E

4. RCS Pressure (Wide Range) 2 E

5. Reactor Vessel Level Indicating System 2 F (RVLlS)

6. Containment Normal Sump Water Level 2 E

7. Containment Pressure (Normal Range) 2 E

8. Steam Line Pressure 2 per steam E generator

9. Containment Radiation Level (High Range) 2 F

10. Not Used.

11. Pressurizer Water Level 2 E

12. Steam Generator Water Level (Wide Range) 4 E

13. Steam Generator Water Level (Narrow Range) 2 per steam E generator (continued)

CALLAWAY PLANT 3.3-50 Amendment No. ###

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 2 of 2)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED REQUIRED FUNCTION CHANNELS ACTION 0.1

14. Core Exit Temperature - Quadrant 1 2(a) E

15. Core Exit Temperature - Quadrant 2 2(a) E

16. Core Exit Temperature - Quadrant 3 2(a) E

17. Core Exit Temperature - Quadrant 4 2(a) E

18. Auxiliary Feedwater Flow Rate 4 E

19. Refueling Water Storage Tank Level 2 E (a) A channel consists of two core exit thermocouples (CETs).

CALLAWAY PLANT 3.3-51 Amendment No. ###

ASDs 3.7.4 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME D. One or more of the required 0.1 Initiate action to close Immediately ASD(s) inoperable because the associated manual of excessive seat leakage. isolation valve(s).

AND 0.2 Restore ASD(s) to 30 days OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CALLAWAY PLANT 3.7-11 Amendment No. ###

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s); and

c. Load Shedder and Emergency Load Sequencer (LSELS) for Train A and Train B.

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

ACTIONS

NOT E -----------------------------------------------------------

LCO 3.0.4.b is not applicable to DGs.

COMPLETION CONDITION REQUIRED ACTION TIME A. One offsite circuit A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE offsite circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 ------------ NOTE -----------

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

(continued)

CALLAWAY PLANT 3.8-1 Amendment No. ###

AC Sources - Operating 3.8.1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. One DG inoperable. B.4 Restore DG to ---------NOT E---------

(continued) OPERABLE status. A one-time Completion Time of 14 days is allowed to support planned replacement of ESW 'B' train piping prior to April 30, 2009.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 6 days from discovery of failure to meet LCO C. Two offsite circuits C.1 ------------ NOTE -----------

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

Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from feature(s) inoperable discovery of when its redundant Condition C required feature(s) is concurrent with inoperable. inoperabilityof redundant required features AND (continued)

CALLAWAY PLANT 3.8-4 Amendment ##If.

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 8 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 8 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 of 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 ###

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 Operating 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 IVB.2, IVB.3, and IVC.

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 IVB.1.

5.6.4 Not used.

(continued)

CALLAWAY PLANT 5.0-22 Amendment ###

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 (PIT) 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 F 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 ###

Attachment 4 ULNRC-05627 ATTACHMENT 4 TS BASES CHANGES (FOR INFORMATION ONLy)

TA8LE OF CONTENTS (Continued) 83.4 REACTOR COOLANT SYSTEM (RCS) ............................................... 8 3.4.1-1 8 3.4.1 RCS Pressure, Temperature, and Flow Departure from Nucleate 80iling (DN8) Limits .......................................... 8 3.4.1-1 83.4.2 RCS Minimum Temperature for Criticality ...................................... 8 3.4.2-1 83.4.3 RCS Pressure and Temperature (PIT) Limits ................................. 8 3.4.3-1 83.4.4 RCS Loops - MODES 1 and 2 ........................................................ 8 3.4.4-1 83.4.5 RCS Loops - MODE 3 .................................................................... 8 3.4.5-1 83.4.6 RCS Loops - MODE 4 .................................................................... 8 3.4.6-1 83.4.7 RCS Loops - MODE 5, Loops Filled ............................................... 83.4.7-1 83.4.8 RCS Loops - MODE 5, Loops Not Filled ........................................ 8 3.4.8-1 83.4.9 Pressurizer ...................................................................................... 8 3.4.9-1 83.4.10 Pressurizer Safety Valves ............................................................... 8 3.4.10-1 83.4.11 Pressurizer Power Operated Relief Valves (PORVs) ..................... 83.4.11-1 8 3.4.12 Cold Overpressure Mitigation System (COMS) .............................. 83.4.12-1 83.4.13 RCS Operational LEAKAGE ........................................................... 83.4.13-1 8 3.4.14 RCS Pressure Isolation Valve (PIV) Leakage ................................ 8 3.4.14-1 83.4.15 RCS Leakage Detection Instrumentation ....................................... 8 3.4.15-1 83.4.16 RCS Specific Activity ...................................................................... 8 3.4.16-1 83.4.17 Steam Generator (SG) Tube Integrity ............................................. 83.4.17-1 8 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) .......................... 8 3.5.1-1 83.5.1 Accumulators .................................................................................. 8 3.5.1-1 83.5.2 ECCS - Operating ........................................................................... 83.5.2-1 83.5.3 ECCS - Shutdown ........................................................................... 8 3.5.3-1 83.5.4 Refueling Water Storage Tank (RWST) ......................................... 8 3.5.4-1 8 3.5.5 Seal Injection Flow .......................................................................... 8 3.5.5-1 83.6 CONTAINMENT SYSTEMS ................................................................. 83.6.1-1 8 3.6.1 Containment ................................................................................... 8 3.6.1-1 8 3.6.2 Containment Air Locks .................................................................... 8 3.6.2-1 8 3.6.3 Containment Isolation Valves ......................................................... 8 3.6.3-1 8 3.6.4 Containment Pressure .................................................................... 8 3.6.4-1 8 3.6.5 Containment Air Temperature ........................................................ 8 3.6.5-1 B 3.6.6 Containment Spray and Cooling Systems ...................................... 8 3.6.6-1 8 3.6.7 Recirculation Fluid pH Control System ........................................... 83.6.7-1 ct1 /S / / /

6 /,~~~9"f1~fifs /..2 ../ .. /..2Z..Z ..Z .. /*/./.Z*/*../7~f~

CALLAWAY PLANT ii Revision 7

PAM Instrumentation B 3.3.3 BASES BACKGROUND Provide information regarding the potential release of radioactive (continued) materials to allow for early indication of the need to initiate action necessary to protect the public, and to estimate the magnitude of any impending threat.

These key variables are identified by References 1 through 4. These analyses identify the unit specific Type A and required non-Type A, Category 1 variables to be included in this specification and provide justification for deviating from the NRC proposed list of Category 1 variables.

Type A variables at Callaway include:

RCS Hot Leg Temperature (Wide Range);

RCS Cold Leg Temperature (Wide Range);

RCS Pressure (Wide Range);

Containment Normal Sump Water Level; Containment Pressure (Normal Range);

Steam Line Pressure; Containment Radiation Level (High Range);

Pressurizer Water Level; Steam Generator (SG) Water Level (Narrow Range); and Refueling Water Storage Tank (RWST) Level.

The required non-Type A, Category 1 variables include:

Neutron Flux; Reactor Vessel Level Indicating System (RVLlS);

SG Water Level (Wide Range); ~

(1fntj3ifrf.eftt t;/d/oief! 1C~Iy'Z;i}@)

Core Exit Temperature.

(continued)

CALLAWAY PLANT B 3.3.3-2 Revision 7b

PAM Instrumentation B 3.3.3 BASES LCO 7. Containment Pressure (Normal Range)

(continued)

Containment Pressure (Normal Range) is a Type A, Category 1 variable provided for verification of RCS and containment OPERABILITY.

Containment pressure is used to verify whether closure of main steam isolation valves (MSIVs) is required (at High-2) and whether containment spray and Phase B isolation are required when containment pressure High-3 is reached.

8. Steam Line Pressure Steam Line Pressure is a Type A, Category 1 variable for event diagnosis and natural circulation. It is a variable for determining if a secondary pipe rupture has occurred. This indication is provided to aid the operator in determining the faulted steam generator and to verify natural circulation.

9. Containment Radiation Level (High Range). GTRIC0059 and GTRIC0060 (or GTRR0060)

Containment Radiation Level is a Type A, Category 1 variable provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans.

Containment radiation level is used to determine if a high energy line break (HELB) has occurred, and whether the event is inside or outside of containment. The radiation monitor identification "RIC" refers to the RM-23 on panel SP067. Chart recorder GTRR0060 may be used to satisfy this specification in lieu of GTRIC0060.

10.

(continued)

CALLAWAY PLANT B 3.3.3-8 Revision 7b

PAM Instrumentation B 3.3.3 BASES ACTIONS (continued)

Condition A applies when one or more Functions have one required channel that is inoperable. Required Action A.1 requires restoring the inoperable channel to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel(s), the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring PAM instrumentation during this interval. Implementation of an alternate method of monitoring is required prior to expiration of the Completion Time.

Condition B applies when the Required Action and associated Completion Time for Condition A are not met. This Required Action specifies initiation of actions in Specification 5.6.8, which requires a written report to be submitted to the NRC within the following 14 days. Implementation of an alternate method of monitoring is required in lieu of a shutdown requirement since alternative actions are identified before loss of functional capability, and given the likelihood of unit conditions that would require information provided by this instrumentation.

Condition C applies when one or more Functions have two or more inoperable required channels (i.e., two or more channels inoperable in the same Function). Required Action C.1 requires restoring all but one channel in the Function(s) to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information. Implementation of an alternate method of monitoring is required prior to expiration of the Completion Time. Continuous operation with two or more required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation. Therefore, requiring restoration of all but one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.

Gta1n!t. Cfitrrr7 c N ftr e;:ctefht't1 1"YJ (continued)

CALLAWAY PLANT B 3.3.3-13 Revision 7b

PAM Instrumentation B 3.3.3 BASES ACTIONS (continued) he Required Action and asso~d completi~

~=t,;:CJ not met. Required Action equires D. \

entering the appropriate ondition referenced in Table 3.3.3-1 for the channel immediately. The applicable Condition referenced in the Ta~~

Function dependent. Each time an inoperable channel has not met~

Re uired Action of Condition C tlJ), and the associated Completion Time has expired, Conditio is entered for that channel and provides for transfer to the appropriate subsequent Condition.

(fjOiiJ~

~ If the Required Action and associated Completion Time of Condition' C LJ:9J"~not met and Table 3.3.3-1 directs entry into Condition~

must be brought to a MODE where the requirements of this Lc-6-d~ '~-ot 't.8J' apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 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.

Alternate means of monitoring Reactor Vessel Level Indicating System and Containment Radiation Level (High Range) have been developed.

These alternate means may be temporarily used if the normal PAM channel cannot be restored to OPERABLE status within the allotted time.

If these alternate means are used, the Required Action is not to shut down the unit but rather to follow the directions of Specification 5.6.8, in the Administrative Controls section of the TS. Monitoring the core exit thermocouples, pressurizer level indication (BB-Ll-0459A, -0460A, or

-0461), and RCS subcooling monitor indication (BB-TI-1390A or B)

(continued)

CALLAWAY PLANT B 3.3.3-14 Revision 7b

PAM Instrumentation

~

B 3.3.3 BASES ACTIONS .0ntinUed) provide an alternate means for RVLlS. These three parameters provide diverse information to verify there is adequate core cooling. When Containment Radiation Level (High Range) monitors (GTRIC0059 and GTRIC0060 or GTRR0060) are inoperable, the area radiation monitors inside containment are used as an alternate method below 10 R/hr, and portable survey equipment with the capability to detect gamma radiation over the range 1E-03 to 1E-tehr is used above 10 Rlhr.

SURVEILLANCE A Note has been added to the SR Table to clarify that SR 3.3.3.1 and REQUIREMENTS SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SR 3.3.3.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The RM-23 unit display for loop GTR-0059, and either the RM-23 unit display or the GTRR0060 recorder for loop GTR-0060, must be used to perform the CHANNEL CHECK of the Containment Radiation Level (High Range) monitors.

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.

The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK (continued)

CALLAWAY PLANT B 3.3.3-15 Revision 7b

S 5 and 6, the ability and con quences of a L A are low, to the pressure a temperature Ii . ations in these DES.

Therefore, hydr en recombiners not required in ese MODES.

SURVEILLANC REQUIREM S d)

Attachment 5 ULNRC-05627 Page 1 of1 LIST OF COMMITMENTS The following table identifies those actions committed to by AmerenUE in this document. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to: Mr. Scott Maglio, Assistant Manager, Regulatory Affairs, (573) 676-8719.

COMMITMENT Due Date/Event AmerenUE has verified that a hydrogen monitoring system When the associated TS capable of diagnosing beyond design-basis accidents is changes are implemented installed at the Callaway Plant, and therefore AmerenUE is after NRC approval of the making a regulatory commitment to maintain that capability. requested license Requirements for the hydrogen monitors (analyzers) will thus amendment.

be included in Chapter 16 of the Final Safety Analysis Report when the associated TS changes are implemented. The requirements contained therein will be commensurate with the requirements applicable to the monitors under revised 10 CFR 50.44.

v t e Letter Sequence Request
TAC:ME1720, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2009-07-28 [Table View]

ULNRC-05627, License Amendment Request OL-1253 Elimination of Technical Specification Requirements for Hydrogen Recombiners and Monitors Using the Consolidated Line Item Improvement Process

Text

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

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ULNRC-05627, License Amendment Request OL-1253 Elimination of Technical Specification Requirements for Hydrogen Recombiners and Monitors Using the Consolidated Line Item Improvement Process

Text

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

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