ULNRC-05821, Union Electric Co. Application for Amendment to Facility Operating License NPF-30 (Ldcn 10-0036) Revision of Technical Specification 3.3.8 TAC ME5173)

Union Electric Co. Application for Amendment to Facility Operating License NPF-30 (Ldcn 10-0036) Revision of Technical Specification 3.3.8 TAC ME5173)

ML113010383
Person / Time
Site:	Callaway
Issue date:	10/27/2011
From:	Maglio S Ameren Missouri
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME5173, ULNRC-05821
Download: ML113010383 (30)

Text

~'t-.

WAmeren Callaway Plant MISSOURI October 27, 2011 ULNRC-05821 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC CO.

APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NPF-30 (LDCN 10-0036)

REVISION OF TECHNICAL SPECIFICATION 3.3.8, TAC NO. ME5173

References:

1. Ameren Missouri letter ULNRC-05744 dated December 10, 2010

2. Ameren Missouri letter ULNRC-05793 dated June 16, 2011

3. Callaway License Amendment No. 202 dated July 29, 2011, "Callaway Plant, Unit 1 -Issuance of Amendment re: Adoption of TSTF-425, Revision 3, 'Relocate Surveillance Frequencies to Licensee Control- RITSTF Initiative 5b' (TAC NO.

ME4506)," ADAMS Accession Number ML111661877 In Reference 1 above Ameren Missouri submitted an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant. Per that amendment application changes are being proposed to Technical Specification (TS) 3.3.8, "Emergency Exhaust System (EES)

Actuation Instrumentation," that would add new Surveillance Requirement (SR) 3.3.8.6. The new SR would require the performance of response time testing on the portion of the EES required to isolate the normal fuel building ventilation exhaust flow path and initiate the fuel building ventilation isolation signal (FBVIS) mode of operation.

In Reference 2 above Ameren Missouri provided responses to an NRC staff request for additional information (RAI) during the review ofReference 1.

In Reference 3 above the NRC issued Callaway License Amendment No. 202 which approved the creation of a Surveillance Frequency Control Program with regard to the applicable Surveillance PO Box 620 Fulton, MD 65251 AmerenMissouri.com

ULNRC-05821 October 27, 2011 Page2 Requirement frequencies specified in the Technical Specifications. The changes approved in Amendment No. 202 were based on TSTF-425-A, Revision 3, "Relocate Surveillance Frequencies to Licensee Control- RITSTF Initiative 5b," and NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." Those industry documents justify the relocation of all periodic Surveillance Frequencies from the Technical Specifications and placing the Frequencies under licensee control in accordance with a new program, the Surveillance Frequency Control Program. All Surveillance Frequencies are relocated except:

• Frequencies that reference other approved programs for the specific interval (such as the Inservice Testing Program or the Primary Containment Leakage Rate Testing Program);

• Frequencies that are purely event-driven (e.g., "Each time the control rod is withdrawn to the

'full out' position");

• Frequencies that are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after thermal power reaching 2: 95% R TP [Rated Thermal Power]"); and

• Frequencies that are related to specific conditions (e.g., battery degradation, age, and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywell to suppression chamber differential pressure decrease" [for BWR plants]).

New SR 3.3.8.6 is of a recurring, periodic nature and does not satisfy any ofthe exclusion criteria above. Therefore, Ameren Missouri requests that the specified Frequency for new SR 3.3.8.6 be controlled in accordance with the Surveillance Frequency Control Program. The initial surveillance test interval (STI) for new SR 3.3.8.6 prior to the first application of the NEI 04-10 process will be 18 months on a STAGGERED TEST BASIS. This is consistent with the approvals given in Callaway Amendment No. 202 for response time surveillances covered by SR 3.3.1.16, SR 3.3.2.10, SR 3.3.5.4, SR 3.3.6.6, and SR 3.3.7.6.

The Attachments provide revised markups for this amendment application. Attachments 1 through 3 provide the final Markup of Technical Specifications, Proposed Technical Specification Bases Changes, and Proposed FSAR Changes, respectively, in support of this amendment request.

Although the only change covered in this letter involves the specified Frequency for new SR 3.3.8.6, for completeness and clarity Attachments 1 through 3 supersede all markups previously provided in References 1 and 2.

The information provided in the Attachments does not affect the licensing evaluations submitted in the Reference 1 amendment application, nor do the Attachments alter the conclusions of those licensing evaluations. Attachments 2 and 3 are provided for information only. Final TS Bases Changes will be processed under Callaway's program for updates per TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment is implemented. The FSAR will be updated under the normal update process pursuant to 10 CFR 50.71(e).

ULNRC-05821 October 27, 2011 Page3 Ameren Missouri requests approval of this license amendment request prior to December 10, 2011. Ameren Missouri further requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance with the following exception:

Since SR 3.3.8.6 is a new Surveillance Requirement, the first required performance will come due by the end of the first surveillance interval that begins or is in effect on the date of implementation of this amendment. (This is similar to the License Condition applied to new Surveillance Requirements added by License Amendment 133 for the Improved Technical Specification conversion.) Since the license amendment will be issued after the start ofRefuel18, SR 3.3.8.6 will first be met during Refuel19 (Spring 2013).

No commitments are contained in this correspondence. If you have any questions on this amendment application or the attached information, please contact me at (573) 676-8719 or Mr.

Thomas Elwood at (314) 225-1905.

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

Very truly yours, Executed on: lol-t111.oLl LJc.o r{ Po YV\ ;J Scott A. Maglio Regulatory Affairs Manager GGY/nls Attachments 1 - Technical Specifications Page Markups 2- Proposed Technical Specification Bases Page Markups (for information only) 3- Proposed FSAR Changes (for information only)

ULNRC-05821 October 27, 2011 Page4 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)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738

ULNRC-05821 October 27, 2011 Page 5 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 C. 0. Reasoner III D. W. Neterer L. H. Graessle J. S. Geyer S. A. Maglio S. L. Gallagher NSFUB Secretary T. B. Elwood G. G. Yates Ms. Diane M. Hooper (WCNOC)

Mr. Tim Hope (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (PG&E)

Mr. Wayne Harrison (STPNOC)

Ms. Linda Conklin (SCE)

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

Missouri Public Service Commission Mr. Dru Buntin (DNR)

ATTACHMENT 1 TECHNICAL SPECIFICATIONS PAGE MARKUPS

EES Actuation Instrumentation 3.3.8 SURVEILLANCE REQUIREMENTS

---

N0 T E -----------------------------------------------------------

Refer to Table 3.3.8-1 to determine which SRs apply for each EES Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SR 3.3.8.2 Perform COT. 92 days SR 3.3.8.3 --------------------------------- N0 T E ----------------------------

The continuity check may be excluded.

Perform ACTUATION LOGIC TEST. 31 days on a STAGGERED TEST BASIS SR 3.3.8.4 --------------------------------- N0 T E ----------------------------

Verification of setpoint is not required.

Perform TADOT. 18 months SR 3.3.8.5 Perform CHANNEL CALIBRATION. 18 months CALLAWAY PLANT 3.3-72 Amendment No. 197 I

INSERT 1 SURVEILLANCE FREQUENCY SR 3 .3 .8. 6 -------------------------N 0 T E--------------------------

Radiation monitor detectors are excluded from response time testing.

Verify Fuel Building Ventilation Exhaust ESF In accordance with RESPONSE TIMES are within limits. the Surveillance Frequency Control Program

EES Actuation Instrumentation 3.3.8 Table 3.3.8-1 (page 1 of 1)

EES Actuation Instrumentation APPLICABLE MODES OR SPECIFIED REQUIRED SURVEILLANCE NOMINAL TRIP FUNCTION CONDITIONS CHANNELS REQUIREMENTS SETPOINT

1. Manual (a) 2 SR 3.3.8.4 NA Initiation

2. Automatic (a) 2 trains SR 3.3.8.3 NA Actuation $~3.3.8".,

Logic and Actuation Relays (BOP ESFAS)

3. Fuel (a) 2 SR 3.3.8.1 (b)

Building SR 3.3.8.2 Exhaust SR 3.3.8.5 Radiation s~ "'3.3.i',,

-Gaseous (a) During movement of irradiated fuel assemblies in the fuel building.

(b) Nominal Trip Setpoint concentration value (!!Cilcm 3 ) shall be established such that the actual submersion dose rate would not exceed 4 mR/hr in the fuel building.

CALLAWAY PLANT 3.3-73 Amendment No. 197 I

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION BASES PAGE MARKUPS (for information only)

ESFAS Instrumentation B 3.3.2 BASES SURVEILLANCE SR 3.3.2.9 (continued)

REQUIREMENTS where applicable. This does not include verification of time delay relays.

These are verified via response time testing per SR 3.3.2.1 0.

The portion of the automatic PORV actuation circuitry required for COMS is calibrated in accordance with SR 3.4.12.9.

SR 3.3.2.10 This SR verifies the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

Response time verification acceptance criteria are included in Reference 9. No credit was taken in the safety analyses for those channels with response times listed as N.A. No response time testing requirements apply where N.A. is listed in Reference 9. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position). The safety analyses include the sum of the following response time components:

a. Sensing circuitry delay time from the time the trip setpoint is reached at the sensor until an ESFAS actuation signal is generated by the SSPS (response time testing associated with LSELS and BOP-ESFAS is discussed under SR 3.3.5.4_,-etl'td-SR 3.3.6.fi); ~

JSI<?>.?J."hC~~~ S.R~.3/I4;

b. Any intentional time delay set into the trip circuitry (e.g., NLf cards (lead/lag) associated with the steam line pressure high negative rate trip function) to add margin or prevent spurious trip signals; and

c. The time for the final actuation devices to reach the required functional state (e.g., valve stroke time, pump or fan spin-up time).

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time verification is performed with the time constants set at their nominal values. Time constants are verified during the performance of SR 3.3.2.9. The response time may be verified by a (continued)

CALLAWAY PLANT B 3.3.2-66 Revision 9b

~6~

CREVS Actuation Instrumentation B 3.3.7 B 3.3 INSTRUMENTATION B 3.3.7 Control Room Emergency Ventilation System (CREVS) Actuation Instrumentation BASES BACKGROUND The CREVS provides an enclosed control room environment from which the unit can be operated following an uncontrolled release of radioactivity.

During normal operation, the Control Building Ventilation System provides control room ventilation. Upon receipt of an actuation signal, the CREVS initiates filtered ventilation and pressurization of the control room. This system is described in the Bases for LCO 3. 7.10, "Control Room Emergency Ventilation System (CREVS)."

The actuation instrumentation consists of two gaseous radiation channels in the control room air intake. A high radiation signal from either of these channels will initiate both trains of the CREVS. Since the radiation monitors include an air sampling system, various components such as sample line valves and sample pumps are required to support monitor OPERABILITY. The control room operator can also initiate CREVS trains by manual switches in the control room. The CREVS is also actuated by a Phase A Isolation signal, a Fuel Building Ventilation Isolation signal (FBVIS), or a high radiation signal from the containment purge exhaust gaseous radiation channels. The Phase A Isolation Function is discussed in LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation."

APPLICABLE The control room must be kept habitable for the operators stationed there SAFETY during accident recovery and post accident operations.

ANALYSES The CREVS acts to terminate the supply of unfiltered outside air to the control room, initiate filtration, and pressurize the control room. These actions are necessary to ensure the control room is kept habitable for the operators stationed there during accident recovery and post accident operations by minimizing the radiation exposure of control room personnel.

In MODES 1, 2, 3, and 4, (MODE 4 is subject to LCO 3.3.2, Function 3.a),

the gaseous radiation channel actuation of the CREVS is a backup for the Phase A Isolation signal actuation. This ensures initiation of the CREVS during a loss of coolant accident or steam generator tube rupture.

During CORE ALTERATIONS or during movement of irradiated fuel assemblies within containment, the gaseous radiation channel actuation of the CREVS is the primary means to ensure control room habitability in the (continued)

CALLAWAY PLANT B 3.3.7-1 Revision 9

CREVS Actuation Instrumentation B 3.3.7 BASES APPLICABLE event of a fuel handling accident inside containment. No control room SAFETY habitablilty mitigation is required for the waste gas decay tank rupture ANALYSES accident. There are no safety analyses that take credit for CREVS (continued) actuation upon high containment purge exhaust radiation. A FBVIS is credited to protect the control room in the event of a design basis fuel 1

handling accide~nside the fuel building. F='"HA t;l.4se.

Sources of co~roN{!~ ventilation isolation signal (CRV S) initiation which are remote from the Control Room intake louvers re not response time tested. , * *

-F~:~el gwileliFI~ e)(ABt:lst me Rot Fes~oRse tiFFte testeel. Th nalysis-&ees-credi a FBVIS for actuating a CRVIS following a Fuel Handling Accident in th uel Building. Due to the remote location of the Fuel Building exh st radiation monitors relative to the Control Room intake louvers, the BVIS will isolate the Control Room prior to the post-accident ra oactive plume reaching the Control Room intake louvers.-::r:/VS~ /13.3;1 s

Similarly, for a LOCA, the analysis credits a time zero Control Room isolation. A Safety Injection signal initiates a Containment Isolation Phase A, which initiates a CRVIS. This function is also credited for isolating the Control Room prior to the post-accident radioactive plume reaching the Control Room intake louvers.

For a Fuel Handling Accident within Containment, GKRE0004 and GKREOOOS are credited for initiating a CRVIS. These monitors are not remote from the Control Room intake louvers. They are downstream of the Control Room intake. Therefore, a specific response time is modeled, and a response time Surveillance Requirement is imposed for this CRVIS function.

The CREVS actuation instrumentation satisfies Criterion 3 of 10CFR50.36(c)(2)(ii).

LCO The LCO requirements ensure that instrumentation necessary to initiate the CREVS is OPERABLE.

1. Manual Initiation The LCO requires two channels OPERABLE. The operator can initiate the CREVS at any time by using either of two push buttons in the control room.

(continued)

CALLAWAY PLANT B 3.3.7-2 Revision 9

INSERT B 3.3.7 The channels associated with GGRE0027 and GGRE0028, which monitor the Fuel Building ventilation exhaust, are not response time tested with respect to control room isolation and mitigation of control room doses. However, those channels are response time tested per SR 3.3.8.6 with respect to placing the Emergency Exhaust System in the FBVIS mode for the mitigation of offsite radiological consequences.

EES Actuation Instrumentation B 3.3.8 B 3.3 INSTRUMENTATION B 3.3.8 Emergency Exhaust System (EES) Actuation Instrumentation BASES BACKGROUND The EES ensures that radioactive materials in the fuel building atmosphere following a fuel handling accident are filtered and adsorbed prior to exhausting to the environment. The system is described in the Bases for LCO 3.7.13, "Emergency Exhaust System." The system initiates filtered exhaust from the fuel building following receipt of a fuel building ventilation isolation signal (FBVIS), initiated manually or automatically upon a high radiation signal (gaseous).

High gaseous radiation, monitored by two channels, provides an FBVIS.

Both EES trains are initiated by high radiation detected by either channel.

Each channel contains a gaseous monitor. High radiation detected by either monitor initiates fuel building isolation, starts the EES, and initiates a CRVIS. These actions function to prevent exfiltration of contaminated air by initiating filtered exhaust, which imposes a negative pressure on the fuel building. Since the radiation monitors include an air sampling system, various components such as sample line valves and sample pumps are required to support monitor OPERABILITY. In the FBVIS mode, each train is capable of maintaining the fuel building at a negative pressure of less than or equal to 0.25 inches water gauge relative to the outside atmosphere.

The EES is also actuated in the LOCA (SIS) mode as described in the Bases for LCO 3.3.2, "ESFAS Instrumentation." J,. 1,.. 1/ f\

t:'f.$ (;lt.JC.IASS~ In J;.e+ere~

/ ..

APPLICABLE The EES ensures that radioactive materials *n the fuel building SAFETY atmosphere following a fuel handling accide t are filtered and adsorbed ANALYSES prior to being exhausted to the environ men This action reduces the radioactive content in the fuel building exhaust following a fuel handling accident so that offsite doses remain within the limits specified in 10 CFR 100 (Ref. t_a~ control room habitability is maintained.

The EES actuation instrumentation satisfies Criterion 3 of 10CFR50.36(c)(2)(ii).

LCO The LCO requirements ensure that instrumentation necessary to initiate the EES is OPERABLE.

(continued)

CALLAWAY PLANT B 3.3.8-1 Revision 9

EES Actuation Instrumentation B 3.3.8 BASES (Continued)

APPLICABILITY The manual and automatic EES initiation must be OPERABLE when moving irradiated fuel assemblies in the fuel building to ensure the EES operates to remove fission products associated with a fuel handling accident and isolate control room ventilation.

High radiation initiation of the FBVIS must be OPERABLE during movement of irradiated fuel assemblies in the fuel building to ensure automatic initiation of the EES and a CRVIS when the potential for a fuel handling accident exists.

ACTIONS The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by unit specific calibration procedures. Typically, the drift is found to be small and results in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a COT, when the process instrumentation is set up for adjustment to bring it within specification. If the measured Trip Setpoint is less conservative than the tolerance specified by the calibration procedure, the channel must be declared inoperable immediately and the appropriate Condition entered.

LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.

A second Note has been added to the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.8-1 in the accompanying LCO. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

Placing a EES train(s) in the FBVIS mode of operation isolates normal air discharge from the fuel building and initiates filtered exhaust, imposing a negative pressure on the fuel building. Further discussion of the FBVIS mode of operation may be found in the Bases for LCO 3.7.13, "Emergency Exhaust System (EES)," and in Referenc~:3.

(continued)

CALLAWAY PLANT B 3.3.8-3 Revision 9

EES Actuation Instrumentation B 3.3.8 BASES SURVEILLANCE SR 3.3.8.3 (continued)

REQUIREMENTS and the multichannel redundancy available, and has been shown to be acceptable through operating experience. The SR is modified by a Note stating that the continuity check may be excluded. This SR is applied to the balance of plant actuation logic and relays that do not have circuits installed to perform the continuity check.

SR 3.3.8.4 SR 3.3.8.4 is the performance of a TADOT. This test is a check of the Manual Initiation Function and is performed every 18 months. Each Manual Initiation channel is tested through the BOP ESFAS logic. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The Frequency is based on operating experience and is consistent with the typical industry refueling cycle. The SR is modified by a Note that excludes verification of setpoints during the TADOT. The channels tested have no setpoints associated with them.

SR 3.3.8.5 A CHANNEL CALIBRATION is performed every 18 months, or s~ 3.3.8'., approximately at every refueling. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test

DVS£1~;-r$3."3. ~ verifies that the channel responds to a measured parameter within the necessary range and accuracy. The Frequency is based on operating l ---~:>

experience and is consistent with the typical industry refueling cycle.

I.. FSAI!. Sec=li~n IS. 7,4:

REFERENCES ~.:2. 10CFR 100.11. *

~3 .. FSAR Section 7.3.3 and Table 7.3-5.

1-, F.SA~~};Ie. 1~.3-::J..

CALLAWAY PLANT B 3.3.8-7 Revision 9

INSERT B 3.3.8 SR 3.3.8.6 is the performance of the required response time verification on those functions with time limits provided in Reference 4. The SuNeillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the SuNeillance Frequency Control Program.

SR 3.3.8.6 is modified by a Note stating that the radiation monitor detectors are excluded from ESF RESPONSE TIME testing. The Note is necessary because of the difficulty associated with generating an appropriate radiation monitor detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

ATTACHMENT 3 PROPOSED FSAR CHANGES (for information only)

CALLAWAY- SP be isolated. The purge and vent lines are closed on a containment isolation signal, thus minimizing the escape of any radioactivity. The containment purge isolation signal may be initiated by manual action.

b. Fuel Building Accident In the fuel building, a fuel assembly could be dropped in the transfer canal, in the fuel storage pool or in the cask loading pool.

In addition to the area radiation monitors located on the wall around the fuel storage pool, portable radiation monitors capable of emitting audible alarms are located in this area during fuel-handling operations. The doors in the fuel building are closed to maintain controlled leakage characteristics in the fuel storage pool region during operations involving irradiated fuel.

Should a fuel assembly be dropped in the canal, in the cask loading pit, or in the pool and release radioactivity above a prescribed level, the radiation monitors sound an audible alarm.

If one of the redundant discharge vent radiation monitors, GG-RE-27 or 28, indicates that the radioactivity in the vent discharge is greater than the prescribed levels, an alarm sounds and the auxiliary/fuel building normal exhaust is switched to the ESF emergency exhaust system to allow the spent fuel pool ventilation to exhaust through the ESF charcoal filters to remove most of the halogens prior to discharging to the atmosphere via the unit vent. The supply ventilation system servicing the spent fuel pool area is automatically shut down, thus ensuring controlled leakage to the atmosphere through charcoal adsorbers (refer to Section 9.4.2).

The probability of a fuel-handling accident is very low because of the safety features, administrative controls, and design characteristics of the facility, as previously mentioned.

15.7.4.5.1.2 Assumptions and Conditions The major assumptions and parameters assumed in the analysis are itemized in Tables 15.7-7 and 15A-1.

In the evaluation of the fuel-handling accident, all the fission product release assumptions of Regulatory Guide 1.25 have been followed. Table 15.7-2 provides a comparison of the design to the requirements of Regulatory Guide 1.25. The following assumptions, related to the release of fission product gases from the damaged fuel assembly, were used in the analyses:

a. The dropped fuel assembly is assumed to be the assembly containing the peak fission product inventory. All the fuel rods contained in the dropped assembly are assumed to be damaged. In addition, for the analyses for 15.7-11 Rev. OL-17 4/09

CALLAWAY - SP the accident in the reactor building the dropped assembly is assumed to damage 20 percent of the rods of an additional assembly.

b. The assembly fission product inventories are based on a radial peaking factor of 1.65.

c. The accident occurs 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after shutdown, which is the earliest time fuel-handling operations can begin. Radioactive decay of the fission product inventories was taken into account during this time period.

d. Only that fraction of the fission products which migrates from the fuel matrix to the gap and plenum regions during normal operation was assumed to be available for immediate release to the water following clad damage.

e. The gap activity released to the fuel pool from the damaged fuel rods consists of 10 percent of the total noble gases other than Kr-85, 30 percent of the Kr-85, and 10 percent of the total radioactive iodine contained in the fuel rods at the time of the accident.

f. The pool decontamination factor is 1.0 for noble gases.

g. The effective pool decontamination factor is 100 for iodine.

h. The iodine above the fuel pool is assumed to be composed of 75 percent inorganic and 25 percent organic species.

i. The activity which escapes from the pool is assumed to be available for release to the environment in a time period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

j. No credit for decay or depletion during transit to the site boundary and outer boundary of the low-population zone is assumed.

k. No credit is taken for mixing or holdup in the fuel building atmosphere. The filter efficiency for the ESF emergency filtration system is assumed to be 90 percent for all species of iodine.

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~

I. The fuel building is switched from the auxiliary/fuel bu normal exhaust system to the ESF emergency exhaust system within seconds from the time the activity reaches the exhaust duct. The activity released before completion of the switchover is assumed to be discharged directly to the environment with no credit for filtration or dilution. Even if fuel building ventilation isolation does not occur automatically, the calculated doses will be less than reported in Table 15.7-8 for the bounding case, inside the rea.ct?r uildi~g .. R~spon.se time t.esting is~require~fer aAy ef tl~e fuel bu1ld1 g vent1lat1on ISolation functiorJ9. ferlecAniCA/ Sfe.ct..freo.-ff'iJn JJ ~ ~~~~r~~

~o.re 15.7-12 Rev. OL-17 4/09

CALLAWAY- SP TABLE 15.7-2 (Sheet 7)

Regulatory Guide 1.25 Position Case 1 (in Fuel Building) Case 2 lin Reactor Building)

R = adult thyroid dose conversion factor for the iodine isotope of interest (rads per curie). Dose conversion factors for Iodine 131-135 are listed in Table 1.9 These values were derived from S"ee. !i.hls. ts-A-4-..

~

"standard man" parameters recommended in ICRP Publication 2. 10 TABLE 1 IA~~!ji!!IBF) Q!jilii ~-~~~~~version Adult Inhalation Thyroid Dose Conversion Factors Table

• 1*' th e thyroid d Table 1; the thyroid dose conversion ctors given rs given i'}(le~!jl!ll8f) 8t:1ide 1.189 are used.

Iodine Conversion Factor (R)  :::r=e. JJD ;, e used.

~/)-:3()

Isotope (Radsfcurie inhaled) "r-30 131 1.48 X 106 132 5.35 X 104 133 4.0 X 105 134 2.5 X 104 135 1.24 X 105

b. The assumptions relative to external whole body dose Complies. See Appendix 15A Section 15A.2.5. Complies. See Appendix 15A Section 15A.2.5.

approximations are:

(1) The receptor is located at a point on or beyond the site boundary where the maximum ground level concentration is expected to occur.

(2) External whole body doses are calculated using "Infinite (2) T~& "'Rele bod; etsse feet:ers fer ;:;wIll liDS ~iotfl iH ReatdateFit Gt1ide 1.189 a: e tiSeel, fer iediAes, Cloud" assumptions, i.e., the dimensions of the cloud are assumed to be large compared to the distance that See Table 15A-4 fo~ose conversion facto;:g.f=nth ~ l<efd~-"+ I :J.. ,

the gamma rays and beta particles travel. The dose at any distance from the reactor is calculated based on wkiQ.iJ,dy the maximum ground level concentration at that distance.

For an infinite uniform cloud containing x curies of beta radioactivity per cubic meter, the beta dose rate in air at the cloud center is: 11 Rev. OL-17 4/09

CALLAWAY - SP TABLE 15.7-7 PARAMETERS USED IN EVALUATING THE RADIOLOGICAL CONSEQUENCES OF A FUEL-HANDLING ACCIDENT In Fuel Building In Reactor Building I. Source Data

a. Core power level, MWt 3,636 3,636

b. Radial peaking factor 1.65 1.65

c. Decay time, hours 72 72

d. Number of fuel assemblies 1.0 1.2 affected

e. Fraction of fission product gases contained in the gap region of the fuel assembly Per R.G. 1.25 Per R.G. 1.25 II. Atmospheric Dispersion Factors See Table 15A-2 See Table 15A-2 Ill. Activity Release Data

a. Percent of affected fuel assemblies gap activity released 100 100

b. Pool decontamination factors

1. Iodine 100 100

2. Noble gas 1 1 C. Filter efficiency, 0 until isolation percent 90 thereafter 0

d. Building mixing volumes assumed, percent of total volume 0 0

e. HVAC exhaust rate, 20,000 until isolation Activity cfm 9,000 thereafter completely released over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

f. Building isolation time, azsec 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

g. Activity release period, hrs 2 2 CJo Rev. OL-17 4/09

CALLAWAY- SP TABLE 15.7-8 RADIOLOGICAL CONSEQUENCES OF A FUEL HANDLING ACCIDENT Doses (rem)

In Fuel Building Exclusion Area Boundary (0-2 hr)

Thyroid -6.69 ~A-o Whole-body o.z34 0- .::235""

Low Population Zone Outer Boundary (duration)

Thyroid ...Q.SSS 0.~+-IJ Whole-body 0.02:54 IJ~IJ:J.3s-In Reactor Building Exclusion Area Boundary (0-2 hr)

Thyroid 61.7 Whole-body 0.359 Low Population Zone Outer Boundary (duration)

Thyroid 6.17 Whole-body 0.0359 Rev. OL-17 4/09

CALLAWAY - SP TABLE 15A-4 DOSE CONVERSION FACTORS USED IN ACCIDENT ANALYSIS Total Body Beta Skin Rem-meter3 Rem-meter3 Thyroid

• Nuclide Ci-sec Ci-sec Rem/Ci 1-131 8.72E-2 3.17E-2 1.49E+6 1-132 5.13E-1 1.32E-1 1.43E+4 1-133 1.55E-1 7.35E-2 2.69E+5 1-134 5.32E-1 9.23E-2 3.73E+3 1-135 4.21 E-1 1.29E-1 5.60E+4 Kr-83m 2.40E-6 0 NA Kr-85m 3.71 E-2 4.63E-2 NA Kr-85 5.11 E-4 4.25E-2 NA Kr-87 1.88E-1 3.09E-1 NA Kr-88 4.67E-1 7.52E-2 NA Kr-89 5.27E-1 3.20E-1 NA Xe-131 m 2.91 E-3 1.51 E-2 NA Xe-133m 7.97E-3 3.15E-2 NA Xe-133 9.33E-3 9.70E-3 NA Xe-135m 9.91 E-2 2.25E-2 NA Xe-135 5.75E-2 5.90E-2 NA Xe-137 4.51 E-2 3.87E-1 NA Xe-138 2.80E-1 1.31E-1 NA

• The radiological consequences for the replacement SG program (1) have been re-analyzed using the following thyroid dose conversion factors from ICRP-30 and whole body dose conversion factors from Federal Guidance Report 12 (except that RG 1.109 Table B-1 is used for Kr-89 and Xe-137). These factors may be applied to other accident sequences as they are re-analyzed: f' / 1 'I-f - ( e.;, .)..J..Ae rue nerntl, 0-Total Body accrden+~~e.s

• • REM-meter3 adrJ~.r-sep. 1n Nuclide Ci-sec Thyroid Rem/ci S e.c-fro11 /.S: 7,4j:

1-131 6.73E-02 1.07E+06 1-132 4.14E-01 6.29E+03 1-133 1.09E-01 1.81 E+05 1-134 4.81 E-01 1.07E+03 1-135 2.95E-01 3.14E+04 Kr-83m 5.55E-06 NA Kr-85m 2.77E-02 NA Kr-85 4.40E-04 NA Rev. OL-16 10/07

CALLAWAY - SP TABLE 15A-4 (Sheet 2)

Total Body

• • REM-meter3 Nuclide Ci-sec Thyroid Rem/ci Kr-87 1.52E-01 NA Kr-88 3.77E-01 NA Kr-89 5.27E-01 NA Xe-131m 1.44E-03 NA Xe-133m 5.07E-03 NA Xe-133 5.77E-03 NA Xe-135m 7.55E-02 NA Xe-135 4.40E-02 NA Xe-137 4.51 E-02 NA Xe-138 2.14E-01 NA 3

• • Federal Guidance Report 12 uses units of S~-meter q -sec

Conversion factors are: 1 Sv 100 Rem and 1 Bq 2. 7E-11 Ci. The above WB dose conversion factors are equal to those in Federal Guidance Report 12.

(1) FSAR sections re-analyzed for radiological consequences as part of the replacement steam generator program include:

15.1.5 STEAM SYSTEM PIPING FAILURE 15.2.6 LOSS OF NONEMERGENCY AC POWER TO THE STATION AUXILIARIES 15.3.3 REACTOR COOLANT PUMP SHAFT SEIZURE (LOCKED ROTOR) 15.4.8 SPECTRUM OF ROD CLUSTER CONTROL ASSEMBLY EJECTION ACCIDENTS 15.6.2 BREAK IN INSTUMENT LINE OR OTHER LINES FROM REACTOR COOLANT PRESSURE BOUNDARY THAT PENETRATE CONTAINMENT 15.6.3 STEAM GENERATOR TUBE FAILURE Rev. OL-16 10/07

CALLAWAY- SP TABLE 16.3-2 (Sheet 3)

INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS

b. Start Turbine-Driven Auxiliary ~ 60(8)(17)

Feedwater Pump C. Feedwater Isolation ~ 2(5),(8)

10. Loss-of-Offsite Power Start Turbine-Driven Auxiliary ~ 60( 9)

Feedwater Pump

11. Trip of All Main Feedwater Pumps Start Motor-Driven Auxiliary N.A.

Feedwater Pumps

12. Auxiliary Feedwater Pump Suction Pressure-Low Transfer to Essential Service Water ~ 60( 1)

13. RWST Level-Low-Low Coincident with Safety Injection Automatic Switch over to Containment ~ 40(10)

Sump

14. Loss of Power

a. 4 kV Bus Undervoltage-Loss of Voltage

b. 4 kV Bus Undervoltage-Grid Degraded Voltage

15. Phase "A" Isolation

a. Control Room Isolation N.A.

b. Containment Purge Isolation ~ 2(5)

16. Control Room High Gaseous Activity Control Room Isolation ~ 60(14) r

rNS£~-r TABLE NOTATIONS FSAI( I (1) Signal actuation, diesel generator starting, and sequencer loading delays included. Valve stroke times and spin-up times for pumps and fans included, as applicable.

(2) Diesel generator starting delay not included. Offsite power available. Signal actuation, sequencer loading, and pump spin-up delays included.

(3) Signal actuation, diesel generator starting and sequencer loading delays included.

RHR pumps not included. Sequential transfer of charging pump suction from the VCT to the RWST (RWST valves open, then VCT valves close) is included.

Rev. OL-18 12/10

INSERT FSAR 1 INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS

17. Fuel Building Ventilation Exhaust High Gaseous Activity Emergency Exhaust System in the FBVIS Mode ~ go< 19 )

CALLAWAY - SP TABLE 16.3-2 (Sheet 5) of non-emergency AC and the loss of normal feedwater accident analyses, initiation of AFW flow is assumed delayed for 90 seconds following reactor trip on a low-low steam generator water level signal.

(17) Response times noted above include the transmitters, 7300 process protection cabinets, solid state protection cabinets, and actuation devices only. For the feed line break accident analysis, initiation of AFW flow is assumed delayed for 90 seconds following reactor trip on low-low steam generator water level signal.

(18) The response time for the reactor trip breakers to open and the gripper release time are satisfied by measurement and included in the response time for each required reactor trip functon.

Rev. OL-18 12/10

INSERT FSAR 2 (19) The radiation monitor detector is excluded from response time testing.

The stated response time accounts for the elapsed time between introduction of a count rate from the detector corresponding to the actuation setpoint and repositioning of the components necessary to place the Emergency Exhaust System in the FBVIS mode of operation.