Union Electric Company; Callaway Plant, Unit 1; Environmental Assessment and Finding of No Significant Impact

NUCLEAR REGULATORY COMMISSION

[Docket No. 50-482]

Union Electric Company; Callaway Plant, Unit 1; Environmental

Assessment and Finding of No Significant Impact

The U.S. Nuclear Regulatory Commission (the Commission) is

considering the issuance of an amendment to Facility Operating License

No. NPF-30 that was issued to Union Electric Company (the licensee) for

operation of the Callaway Plant, Unit 1 located in Callaway County,

Missouri.

Environmental Assessment

Identification of the Proposed Action

The proposed amendment will revise the Current Technical

Specifications (CTS) for Callaway Plant, Unit 1 in their entirety based

on the guidance provided in NUREG-1431, ``Standard Technical

Specifications, Westinghouse Plants,'' Revision 1, dated April 1995,

and in the Commission's ``Final Policy Statement on Technical

Specifications Improvements for Nuclear Power Reactors,'' published on

July 22, 1993 (58 FR 39132). The proposed action is in accordance with

the licensee's amendment request dated May 15, 1997, as supplemented by

(1) the letters in 1998 dated June 26, August 4, August 27, September

24, October 21 (two letters), November 23, November 25, December 11,

and December 22, and (2) the letters in 1999 dated February 5, March 9,

April 7, April 21 and April 30.

The Need for the Proposed Action

It has been recognized that nuclear safety in all nuclear power

plants would benefit from an improvement and standardization of plant

Technical Specifications (TS). The NRC's ``Interim Policy Statement on

Technical Specification Improvements for Nuclear Power Plants'' (52 FR

3788), contained proposed criteria for defining the scope of TS. Later,

the NRC's ``Final Policy Statement on Technical Specifications

Improvements for Nuclear Power Reactors,'' published on July 22, 1993

(58 FR 39132), incorporated lessons learned since publication of the

interim policy statement and formed the basis for revisions to 10 CFR

50.36, ``Technical Specifications.'' The ``Final Rule'' (60 FR 36953)

codified criteria for determining the content of TS. To facilitate the

development of standard TS for nuclear power reactors, each power

reactor vendor owners' group (OG) and the NRC staff developed standard

TS. For Callaway Plant, Unit 1, the Improved Standard Technical

Specifications (ISTS) are in NUREG-1431. This document formed part of

the basis for the Callaway Plant, Unit 1 Improved Technical

Specifications (ITS) conversion. The NRC Committee to Review Generic

Requirements (CRGR) reviewed the ISTS, made note of its safety merits,

and indicated its support of the conversion by operating plants to the

ISTS.

Description of the Proposed Change

The proposed changes to the CTS are based on NUREG-1431 and on

guidance provided by the Commission in its Final Policy Statement. The

objective of the changes is to completely rewrite, reformat, and

streamline the CTS (i.e., to convert the CTS to the ITS). Emphasis is

placed on human factors principles to improve clarity and understanding

of the TS. The Bases section of the ITS has been significantly expanded

to clarify and better explain the purpose and foundation of each

specification. In addition to NUREG-1431, portions of the CTS were also

used as the basis for the development of the Callaway Plant, Unit 1

ITS. Plant-specific issues (e.g., unique design features, requirements,

and operating practices) were discussed with the licensee, and generic

matters with Westinghouse and other OGs.

This conversion is a joint effort in concert with three other

utilities: Pacific Gas & Electric Company for Diablo Canyon Power

Plant, Units 1 and 2 (Docket Nos. 50-275 and 50-323); TU Electric for

Comanche Peak Steam Electric Station, Units 1 and 2 (Docket Nos. 50-445

and 50-446); and Wolf Creek Nuclear Operating Corporation for Wolf

Creek Generating Station (Docket No. 50-482). It was a goal of the four

utilities to make the ITS for all the plants as similar as possible.

This joint effort includes a common methodology for the licensees in

marking-up the CTS and NUREG-1431 specifications, and the NUREG-1431

Bases, that has been accepted by the staff.

This common methodology is discussed at the end of Enclosure 2,

``Mark-Up of Current TS;'' Enclosure 5a, ``Mark-Up of NUREG-1431

Specifications;'' and Enclosure 5b, ``Mark-Up of NUREG-1431 Bases,''

for each of the 14 separate ITS sections that were submitted with the

licensee's application. Each of the 14 ITS sections also includes the

following enclosures:

Enclosure 1, ``Cross-Reference Table,'' provides the

cross-reference table connecting each CTS specification (i.e., limiting

condition for operation, required action, or surveillance requirement)

to the associated ITS

[[Page 28536]]

specification, sorted by both CTS and ITS specifications.

Enclosures 3A and 3B, ``Description of Changes to Current

TS'' and ``Conversion Comparison Table,'' provides the description of

the changes to the CTS section and the comparison table showing which

plants (of the four licensees in the joint effort) that each change

applies.

Enclosure 4, ``No Significant Hazards Considerations,''

provides the no significant hazards consideration (NSHC) of 10 CFR

50.91 for the changes to the CTS. A description of the NSHC

organization is provided, followed by generic NSHCs for administrative,

more restrictive, relocation, and moving-out-of-CTS changes, and

individual NSHCs for less restrictive changes.

Enclosures 6A and 6B, ``Differences From NUREG-1431'' and

``Conversion Comparison Table,'' provides the descriptions of the

differences from NUREG-1431 specifications and the comparison table

showing which plants (of the four licensees in the joint effort) that

each difference applies.

The common methodology includes the convention that, if the words in a

CTS specification are not the same as the words in the ITS

specification, but the CTS words have the same meaning or have the same

requirements as the words in the ITS specification, then the licensees

do not have to indicate or describe a change to the CTS. In general,

only technical changes have been identified; however, some non-

technical changes have also been identified. The portion of any

specification which is being deleted is struck through (i.e., the

deletion is annotated using the strike-out feature of the word

processing computer program or crossed out by hand). Any text being

added to a specification is shown by shading the text, placing a circle

around the new text, or by writing the text in by hand. The text being

struck through or added is shown in the marked-up CTS and ISTS pages in

Enclosures 2 (CTS pages) and 5 (ISTS and ISTS Bases pages) for each ITS

section attachment to the application. Another convention of the common

methodology is that the technical justifications for the less

restrictive changes are in the NSHCs.

The proposed changes can be grouped into the following four

categories: relocated requirements, administrative changes, less

restrictive changes involving deletion of requirements, and more

restrictive changes. These categories are as follows:

1. Relocated requirements (i.e., the licensee's ``LG'' or ``R''

changes) are items which are in the CTS but do not meet the criteria

set forth in the Final Policy Statement. The Final Policy Statement

establishes a specific set of objective criteria for determining which

regulatory requirements and operating restrictions should be included

in the TS. Relocation of requirements to documents with an established

control program, controlled by the regulations or the TS, allows the TS

to be reserved only for those conditions or limitations upon reactor

operation which are necessary to obviate the possibility of an abnormal

situation or event giving rise to an immediate threat to the public

health and safety, thereby focusing the scope of the TS. In general,

the proposed relocation of items from the CTS to the Final Safety

Analysis Report (FSAR), appropriate plant-specific programs, station

procedures, or ITS Bases follows the guidance of NUREG-1431. Once these

items have been relocated to other licensee-controlled documents, the

licensee may revise them under the provisions of 10 CFR 50.59 or other

NRC-approved control mechanisms, which provide appropriate procedural

means to control changes by the licensee.

2. Administrative changes (i.e., the licensee's ``A'' changes)

involve the reformatting and rewording of requirements, consistent with

the style of the ISTS in NUREG-1431, to make the TS more readily

understandable to station operators and other users. These changes are

purely editorial in nature, or involve the movement or reformatting of

requirements without affecting the technical content. Application of a

standardized format and style will also help ensure consistency is

achieved among specifications in the TS. During this reformatting and

rewording process, no technical changes (either actual or

interpretational) to the TS will be made unless they are identified and

justified.

3. Less restrictive changes and the deletion of requirements

involves portions of the CTS (i.e., the licensee's ``LS'' and ``TR''

changes) which (1) provide information that is descriptive in nature

regarding the equipment, systems, actions, or surveillances, (2)

provide little or no safety benefit, and (3) place an unnecessary

burden on the licensee. This information is proposed to be deleted from

the CTS and, in some instances, moved to the proposed Bases, FSAR, or

procedures. The removal of descriptive information to the Bases of the

TS, FSAR, or procedures is permissible because these documents will be

controlled through a process that utilizes 10 CFR 50.59 and other NRC-

approved control mechanisms. The relaxation of requirements were the

result of generic NRC actions or other analyses. They will be justified

on a case-by-case basis for the Callaway Plant, Unit 1 and described in

the safety evaluation to be issued with the license amendment.

4. More restrictive requirements (i.e., the licensee's ``M''

changes) are proposed to be implemented in some areas to impose more

stringent requirements than are in the CTS. In some cases, these more

restrictive requirements are being imposed to be consistent with the

ISTS. Such changes have been made after ensuring the previously

evaluated safety analysis for the Callaway Plant, Unit 1 was not

affected. Also, other more restrictive technical changes have been made

to achieve consistency, correct discrepancies, and remove ambiguities

from the TS. Examples of more restrictive requirements include: placing

a Limiting Condition for Operation (LCO) on station equipment, which is

not required by the CTS to be operable; more restrictive requirements

to restore inoperable equipment; and more restrictive surveillance

requirements.

There are twenty-four other proposed changes to the CTS that are

included in the proposed amendment to convert the CTS to the ITS. These

are beyond scope issues (BSIs) in that they are changes to both the CTS

and the ISTS. For the Callaway Plant, Unit 1, these are the following:

1. Change 2-06-M (CTS Section

3/4.2). The proposed change to CTS Surveillance Requirement (SR)

4.2.2.2.d would add a frequency of once within 24 hours for verifying

the axial heat flux hot channel factor is within limits after achieving

equilibrium conditions.

2. Change 1-54-LS-37 (CTS Section 3/4.3). The proposed change would

revise Action 5.b of CTS Table 3.3-1 to increase the verification

interval for unborated water source isolation valve position from 14

days to 31 days.

3. Change 1-15-M (CTS Section

3/4.4). The proposed change would revise steam generator (SG) level

requirements from 10% wide range to 4% narrow range in CTS SRs

4.4.1.2.2 and 4.4.1.3.2 for Modes 3 and 4, and from 10% wide range to

66% wide range for Mode 5, to ensure SG tubes are covered and provide

an adequate heat sink.

4. Change 9-17-LS-24 (CTS Section 3/4.4). The proposed change would

revise the applicability note to CTS Limiting Condition for Operation

(LCO) 3.4.9.3 to allow a longer time, up to one hour, for both

centrifugal charging pumps to be capable of injecting into the reactor

coolant system.

5. Change 11-03-M (CTS Section

3/4.9). The proposed change would

[[Page 28537]]

revise the reference for the spent fuel pool level from that above top

of fuel stored in racks to that above the top of racks in CTS LCO

3.9.11.

6. Change 3-15-M (CTS Section 6.0). The proposed change would add

the refueling boron concentration to the Core Operating Limits Report

in CTS 6.9.1.9.

7. Change 3-11-A (CTS Section 6.0). The proposed changes would

revise limits for high radiation areas in CTS 6.12.1 to reflect the

requirements of revised 10 CFR Part 20.

8. Change 1-34-LS-2 (CTS Section 1.0). The proposed change would

add notes to CTS Table 1.2 to identify the number of reactor vessel

head closure bolts required to be fully tensioned for Modes 4 and 5. A

Note is also proposed to address Mode 6 bolt requirements.

9. Change 1-7-LS-3 (CTS Section

3/4.3). The proposed change to CTS Table 3.3-1 would (1) extend the

completion time for CTS Action 3.b from no time specified to 24 hours

for channel restoration or changing the power level to either below P-6

or above P-10, (2) change the applicable modes and delete CTS Action

3.a because it is now outside the revised intermediate range neutron

flux channel applicability, and (3) add a less restrictive new action

that requires immediate suspension of operations involving positive

reactivity additions and a power reduction below P-6 within two hours,

but no longer requires a reduction to Mode 3.

10. Change 1-22-M (CTS Section

3/4.3). The proposed change would add quarterly channel operational

tests (COTs) to CTS Table 4.3-1 for the power range neutron flux-low,

intermediate range neutron flux, and source range neutron flux trip

functions. The CTS only require a COT prior to startup for these

functions. New Note 19 (which is from the STS) would be added to

require that the new quarterly COT be performed within 12 hours after

reducing power below P-10 for the power range and intermediate range

(P-10 is the dividing point marking the applicability for these trip

functions), if not performed in the previous 92 days. New Note 20

(which is from the STS), would be added to state that the P-6 and P-10

interlocks are verified to be in their required state during all COTs

on the power range neutron flux-low and intermediate range neutron flux

trip functions.

11. Change 1-46-M (CTS Section

3/4.3). The proposed change would revise CTS Table 3.3-1 Action 13 and

CTS Table 3.3-3 Action 36 to require an inoperable SG low-low level

(normal containment environment) instrument channel be placed in the

tripped condition within 6 hours. The option to place the associated

environmental allowance monitor (EAM) channels in trip would be

deleted.

12. Change 4-09-LS-36 (CTS Section 3/4.4). The proposed change

would limit the CTS SR 4.4.4.2 requirement to perform the 92-day

surveillance of the pressurizer power operated relief (PORV) block

valves so that it is not required to be performed if the block valve is

closed to meet CTS LCO 3.4.4 Action a. A note is also proposed to be

added to action d to state that the Action does not apply if the block

valve is inoperable solely to satisfy CTS LCO 3.4.4 Action b or c.

13. Change 10-20-LS-39 (CTS Section 3/4.7). The proposed change

would add an action to CTS LCO 3.7.6 for ventilation system pressure

envelope degradation that allows 24 hours to restore the control room

pressure envelope through repairs before requiring the unit to perform

an orderly shutdown. The new action has a longer allowed outage time

than LCO 3.0.4 which the CTS would require to be entered immediately.

The change would recognize that the ventilation trains associated with

the pressure envelope would still be operable.

14. Change 2-25-LS-23 (CTS Section 3/4.8). The proposed change

would allow substitution of a modified performance discharge test for

the battery service test in CTS SR 4.8.2.1.e.

15. Change 1-09-A (CTS Section 6.0). The proposed change would

replace CTS 6.2.2.e requirements concerning overtime with a reference

to administrative procedures for the control of working hours.

16. Change 1-15-A (CTS Section 6.0). The proposed change would

revise CTS 6.2.2.g to eliminate the title of Shift Technical Advisor

(STA). The engineering expertise would be maintained on shift, but not

as a separate individual, as allowed by the Commission's Policy

Statement on engineering expertise.

17. Change 2-17-LS-1 (CTS Section 6.0). The proposed change would

add an allowance to the CTS for the reactor coolant pump flywheel

inspection program to permit an exception to the examination

requirements specified in CTS SR 6.8.5.b (Regulatory position C.b.4 of

NRC Regulatory Guide 1.14, ``Reactor Coolant Pump Flywheel Integrity,''

Revision 1.) The exception would allow either an ultrasonic volumetric

or surface examination as an acceptable inspection method.

18. Change 2-18-A (CTS Section 6.0). The proposed change would

revise the CTS 6.8.4.e.7 dose rate limits in the radiological effluents

controls program to reflect 10 CFR Part 20 requirements.

19. Change 2-22-A (CTS Section 6.0). The proposed change would

revise the radiological effluents controls program in CTS 6.8.3.e to

add clarifying statements denoting that the provisions of CTS 4.0.2 and

4.0.3, which allow extensions to surveillance frequencies, are also

applicable to these program activities.

20. Change 3-18-LS-5 (CTS Section 6.0). The CTS 6.9.1.8 requirement

to provide documentation of all challenges to the power operated relief

valves (PORVs) and safety valves on the reactor coolant system would be

deleted. This would be based on NRC Generic Letter (GL) 97-02,

``Revised Contents in the Monthly Operating Report,'' which reduced the

requirements for submitting such information to the NRC. The GL did not

include these valves for information to be submitted.

21. Change 9-14-M (CTS Section 3/4.4). The proposed change would

add a new surveillance requirement to CTS LCO 3.4.9.3 on overpressure

protection systems to verify each accumulator is isolated when the

accumulator pressure is greater than or equal to the maximum reactor

coolant system (RCS) pressure for the existing RCS cold leg temperature

allowed by the pressure/temperature limit curves provided in the

Pressure Temperature Limit Report.

22. Change 14-09-M (CTS Section 3/4.7). The proposed change would

add a new LCO, with actions and surveillance requirements from the ITS,

to the CTS for the allowable fuel storage boron concentration. The new

specification would be based on ITS 3.7.17 with the proposed minimum

acceptable boron concentration for the spent fuel storage pool being

2165 ppm boron.

23. Change 1-15-A (CTS Section 3/4.3). The proposed change would

modify the applicability of the reactor trip on turbine trip function

in CTS Table 3.3-1 by adding a new footnote (c) stating that this

function would only be required to be operable above the P-9 interlock.

This is proposed since this function is blocked below the P-9

interlock. The applicability change would also be reflected in the

revised trip actuating device operational test (TADOT) requirements for

functional unit #16 in CTS Table 4.3-2.

24. Change 1-30-M (CTS Section 3/4.3). The proposed change would

add a new LCO with actions and SR from the ITS for the boron dilution

mitigation system. Additional restrictions not in the CTS would be

added to address the requirement that one RCS loop shall be in

operation for Modes 2 (below P-6), 3,

[[Page 28538]]

4 and 5. This is not included in the CTS or ITS 3.3.9.

Environmental Impacts of the Proposed Action

The Commission has completed its evaluation of the proposed

conversion of the CTS to the ITS for Callaway Plant, Unit 1, including

the beyond scope issues discussed above. Changes which are

administrative in nature have been found to have no effect on the

technical content of the TS. The increased clarity and understanding

these changes bring to the TS are expected to improve the operators'

control of Callaway Plant, Unit 1 in normal and accident conditions.

Relocation of requirements from the CTS to other licensee-

controlled documents does not change the requirements themselves.

Future changes to these requirements may then be made by the licensee

under 10 CFR 50.59 and other NRC-approved control mechanisms which will

ensure continued maintenance of adequate requirements. All such

relocations have been found consistent with the guidelines of NUREG-

1431 and the Commission's Final Policy Statement.

Changes involving more restrictive requirements have been found to

enhance station safety.

Changes involving less restrictive requirements have been reviewed

individually. When requirements have been shown to provide little or no

safety benefit, or to place an unnecessary burden on the licensee,

their removal from the TS was justified. In most cases, relaxations

previously granted to individual plants on a plant-specific basis were

the result of a generic action, or of agreements reached during

discussions with the OG, and found to be acceptable for Callaway Plant,

Unit 1. Generic relaxations contained in NUREG-1431 have been reviewed

by the NRC staff and found to be acceptable.

In summary, the proposed revisions to the TS were found to provide

control of station operations such that reasonable assurance will be

provided that the health and safety of the public will be adequately

protected.

The proposed action will not increase the probability or

consequences of accidents, will not change the quantity or types of any

effluent that may be released offsite, and will not significantly

increase the occupational or public radiation exposure. Also, these

changes do not increase the licensed power and allowable effluents for

the station. The changes will not create any new or unreviewed

environmental impacts that were not considered in the Final

Environmental Statement related to the operation of Callaway Plant,

Unit 1, NUREG-0813, dated January 1982. Therefore, there are no

significant radiological impacts associated with the proposed action.

With regard to potential non-radiological impacts, the proposed

action only involves features located entirely within the restricted

area for the station defined in 10 CFR Part 20 and does not involve any

historic sites. The proposed action does not affect non-radiological

station effluents and has no other environmental impact. It does not

increase any discharge limit for the station. Therefore, there are no

significant non-radiological environmental impacts associated with the

proposed action.

Accordingly, the Commission concludes that there are no significant

environmental impacts associated with the proposed action.

Alternatives to the Proposed Action

As an alternative to the proposed action, the staff considered

denial of the proposed action (i.e., the ``no-action'' alternative).

Denial of the licensee's application would result in no change in

current environment impacts. The environmental impacts of the proposed

action and the alternative action are similar.

Alternative Use of Resources

This action does not involve the use of any resources not

previously considered in the Final Environmental Statement for the

Callaway Plant, Unit 1 dated January 1982.

Agencies and Persons Consulted

In accordance with its stated policy, on May 19, 1999, the staff

consulted with the Missouri State official, regarding the environmental

impact of the proposed action. The State official had no comments to

offer.

Finding of No Significant Impact

Based upon the environmental assessment, the Commission concludes

that the proposed action will not have a significant effect on the

quality of the human environment. Accordingly, the Commission has

determined not to prepare an environmental impact statement for the

proposed action.

For further details with respect to the proposed action, see the

licensee's application dated May 15, 1997, as supplemented by (1) the

letters in 1998 dated June 26, August 4, August 27, September 24,

October 21 (two letters), November 23, November 25, December 11, and

December 22, and (2) the letters in 1999 dated February 5, March 9,

April 7, April 21 and April 30 which are available for public

inspection at the Commission's Public Document Room, The Gelman

Building, 2120 L Street, NW., Washington, DC, and at the local public

document room located at the University of Missouri-Columbia, Elmer

Ellis Library, Columbia Missouri, 65201-5149.

Dated at Rockville, Maryland, this 20th day of May 1999.

For the Nuclear Regulatory Commission.

Mel Gray,

Project Manager, Section 2, Project Directorate IV & Decommissioning

Division of Licensing Project Management, Office of Nuclear Reactor

Regulation.

[FR Doc. 99-13421 Filed 5-25-99; 8:45 am]

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