B12183, Forwards Comments on Draft Ol,Draft Suppl to NUREG-1143 & Tech Specs,Per 860530 Request.Proposed Tech Specs Reflect Existing Configuration of Plant

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Forwards Comments on Draft Ol,Draft Suppl to NUREG-1143 & Tech Specs,Per 860530 Request.Proposed Tech Specs Reflect Existing Configuration of Plant
ML20203K129
Person / Time
Site: Millstone Dominion icon.png
Issue date: 07/31/1986
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Charemagne Grimes
Office of Nuclear Reactor Regulation
References
RTR-NUREG-1143 B12183, NUDOCS 8608060175
Download: ML20203K129 (37)


Text

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(203) 666-6911 k ' J% EIC'C July 31,1986 Docket No. 50-245 B12183 Office of Nuclear Reactor Regulation Attn: Mr. Christopher I. Grimes, Director Integrated Safety Assessment Project Directorate Division of PWR Licensing - 8 U.S. Nuclear Regulatory Com.ission Washington, D.C. 20555 Gentlemen:

MILLS'IONE NUCLEAR POWER STATION, UNIT NO.1 CONVERSION OF PROVISIONAL OPERATING LICENSE 'IO FULL TERM OPERATING LICENSE COMMENTS ON DRAFT DOCUMEtiIS On May 30, 1986 the NRC Staff issued, for coment, draft copies of (1) a supplement to the Safety Evaluation Report issued in October 1985 (NUREG-1143),

(2) the Facility Operating Licence, and (3) a newly transcribed copy of the Technical Specifications, through Amendment No. 110, as now contained in Appendix A to the Provisional Operating License No. DPR-21. Comments on all of these documents were requested within 45 days following receipt of the letter from the Staff.

Attachments A, B, and C to this letter contain the coments noted by Northeast Nuclear Energy Company (NNECO) during its review. Attachment A contains coments on the Draft FACILITY OPERATING LICENSE. Attachment B contains coments on the Draft Supplement to NUREG-1143. Attachment C contains comments noted during the review of the Technical Specifications which are to be issued in their entirety as l Appendix A to Facility Operating License DPR-21. In each case, the comments have l been provided in a form indexed to the original draft docts. Gat reviewed. In l certain cases, where it was judged that the existing language was unclear or incorrect, suggested language changes have been provided for the Staff's consideration. Because of the large number of items, the coments on the Technical Specifications are provided in the form of a computer printout which lists comments on a page by page basis to the appropriate paragraph and line. It is intended that the list in Attachment C serve as a guide for the Staff in going through the draft copy of Technical Specifications to correct the transcription

errors noted.

l With the exception of the coments contained in Attachment C to this letter, we conclude that the Technical Specifications contained in Appendix A to the Provisional Operating License (POL) No. DPR-21, through License Amendment No. 110, l have been accurately transcribed in all material respects in the C.I. Grimes letter 1

l l (1) C.I. Grimes letter to J.F.0peka, " Conversion of Provisional Operating License to Full Term operating License (FTCL)," dated May 30, 19aC.

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, 8608060175 860731 6 i PDR ADOCK 05000245 P PDR

to J.F.Opeka, dated May 30, 1986. his conclusion is based upon our editorial review and comparison of existing Technical Specifications with those proposed in the referenced NRC letter, and a limited number of additional changes reflecting some minor format and grammatical changes. We anticipate that some additional editorial comments may be necessary subsequent to issuance of the full term operating license, due in part to the large volume of information involved. ,

Howver, we believe all significant conunents are listed in Attachment C' to this letter.

We also conclude that the proposed h chnical Specifications reflect the existing configuration of Millstone Unit No. 1 to the same degree that existing h chnical Specifications contained in Appendix A to the Provisional Operating License No.

DPR-21 represent the existing plant configuration. In this regard, we have a high degree of confidence that the existing, and accordingly the proposed, Technical Specifications represent the plant configuration. his confidence is based upon the almost sixteen years of plant operation in accordance with the existing Technical Specifications which have been refined significantly with the processing of .110 license amendments. Any necessary chan'ges to the Technical Specifications to correctly reflect plant changes or to make the h chnical Specifications more accurately reflect existing plant configurations have been made over the course of those sixteen years. Consequently, there is reasonable assurance that no material differences exist between the plant configuration and either the existing ,

Technical Specifications or those proposed to be iscued as Appendix A to the Full

Term Operating License (F'IOL). Nonetheless, we do not wish to represent that we have undertaken an exhaustive comparison of the proposed Technical Specifications with the existing plant configuration as part of the POL conversion process.

Very truly yours, Northeast Nuclear Energy Company Johttf) OpekaO A

Senior Vice President l

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i 1

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a . o Docket No. 50-245 B12183 ATTACHPD!NT A C0f95NIS CN DRAFT FACILITY OPERATING LICENSE DPR-21 i

1 July, 1986

o General Comments From the cover letter accompanying the draft Facility Operating License, it is unclear as to whether section 2.C.(3) of the license is intended to enumerate every exemption previously granted by the Commission which still remains in effect or to point out only specific exemptions relating to Appendices R and J of 10CFR50.

As written, paragraph 3 of the draft cover letter would seem to indicate that exemptions not specifically listed in Section 2.C.(3) of the license are not to remain in effect. While Section 2.C.(3) does deal with two major exemptions related to Appendix J and Appendix R of 10CFR50, several other exemptigs not noted also remain in effect. For example, W ECO received an exemption #

from the schedular requirements of 10CFR 50.71(e) for the submittal of an updated Final SafetyAnagsisReportforMillstoneUnitNo.1.Also,WECOhasbeengranted exemptions from certain inspection requirements under 10 CFR 50.55a.

It should be possible to modify the wording of the third paragraph of the cover 4

letter to match the content of the draft license, e.g., "There were certain exemptions granted under the provisional license and those remain in effect.

Specific exemptions relating to 10CFR50 Appandix J and 10CFR Appendix R have been included in Section 2.C.(3) and 2.C.(4) of the enclosed license." Such a change to the wording would aid in making clear that issuance of the FTOL is not meant to make any exemption previously granted, but not listed in section 2.C., n111 and void.

Paragraphs 2.C.(3)(b) and (c) of the draft license should be deleted at this time.

Appendix R modifications are currently being iglemented on a schedule consistent with 10 CFR 50.48 and will not be coupleted until the 1987 refueling outage. In addition, the current FSAR does not discuss the Appendix R safe shutdown methodology or the procedural methods used to revise the approved fire protection program without prior NRC approval. NNECO is planning on requesting a license amendment similar to the proposed wording of paragraphs 2.C.(3)(b) and (c) after the modifications and the updated FSAR have been implemented in accordance with the intent of Generic Letter 86-10. Until these actions occur, we believe it is

! premature to implement wording similar to paragraphs 2.C.(3)(b) and (c) in the l FIOL.

Section 2.C.(4) is proposed as a means of separating discussions of Appendix J

from discussions of Appendix R under the Fire Protection heading.

The draft license appears to elevate the significance of the FSAR. Item No. 2.A identifies the FSAR as part of the " application." Item 1.C would require that the facility be operated in conformity with the application. As such, the license could be interpreted to require Millstone Unit No. 1 to be operated in total l

conformity with the FSAR. In addition, Item 2.B.(2) specifically states that we can receive, possess and use at any time special nuclear material or reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the FSAR. Due to the lack of a current up-to-date FSAR for Millstone Unit No. 1, we request that the FTOL be maintained in a similar fashion to the existing Provisional Operating License with respect to the FSAR and that the FSAR significance not be elevated beyond that currently existing.

l l

l (1) H.L. Thompson Jr. letter to J.F.opeka, " Exemption from Submittal Date for Updated Final Safety Analysis Report (FSAR)," dated November 22, 1985 l

l (2) D.M.Crutchfield letter to W.G.counsil, " Safety Evaluation Report on Section XI ASME Code," dated November 19,1980

Specific Conuments Comments on the draft Facility Operating License are provided as revised paragraphs with change bars marking the location of each proposed change.

1. A. We application for an operating license filed by the Northeast Nuclear

!cnergy Company (the Licensee), formerly the Millstone Point Conpany, acting l for itself and as agent for the Connecticut Light and Power Company (CL&P),

and Western Massachusetts Electric Conpany (WMECO), complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the rules and regulations of the Commission, as set forth in 10 CFR Chapter I, and all required notifications to other agencies or bodies have been duly made;

%e licensee is technically and financially qualified to engage in the  !

1.E activities authorized by this operating, license, in accordance with the rules and regulations of the Connaission; 1.F. W e licensee has furnished proof of financial protection that satisfies the l requirements of 10 CFR Part 140; and 2.B.(3) In the first line, the word ' receive' is misspelled.

2.C.(2) Technical Specifications he technical specifications contained in Appendix A are hereby incorporated in the license. %e licensee shall operate the facility in l accordance with the technical specifications.

2.C.(3) Fire Protection W e licensee shall maintain in effect the fire protection program described in the licensee's submittals referenced in, and as approved or modified by,

! the NRC's Fire Protection Safety Evaluations (SEs) dated September 26, 1978, November 19,1980, February 13,1981, and November 6, 1985, or configurations subsequently approved by the NRC.

Add a new section:

(

2.C.(4) Containment Integrity me facility has been granted exemptions from certain requirements of Appendix J to 10CFR 50, " Primary Reactor Containment Leakage Testing For Water-Cooled Power Reactors." Appendix J relates to containment leakage test requirements, specifically periodic verification by tests of the leak-tight integrity of the primary reactor containment and systems and components which penetrate containment. The three exemptions granted on May 10, 1985, on the basis of staff safety evaluation, relate to testing of expansion bellows at containment penetrations, and low pressure tests of containment access air locks and main steam isolation valves.

l l

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2.C.(5) Physical Protection l he Northeast Nuclear Energy Company shall fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans previously approved by the Commission and all amendments and revisions to such plans made pbrsuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). We plans which contain safeguards information under 10 CFR 73.21, are entitled: " Millstone Nuclear Power Station Security Plan," with revisions subnitted through June 24, 1986; " Millstone Nuclear Power Station Guard Training and l Qualification Plan," with revisions subnitted through January 23, 1986; and l

" Millstone Nuclear Power Station Safeguards Contingency Plan," with revisions submitted through October 30, 1985. l

o Docket No. 50-245 B12183 ATIACHMENT B COMMENTS ON DRAFT SUPPLEMENT NO.1 'IO NUREG-1143 July, 1986

Conments on the Draft Supplement to NUREG-1143 are provided, as a guide, on a page by page basis to the paragraph and line level as follows:

Page Comments 1-2 3rd paragraph -line 7 - should read "..of the topic scope and sununaries. . . "

1-4 1st paragraph - 2nd line - Mr. Shea's telephone number should be 492-7639 1-6 1st line "..the original design basis, the licensee was requested by letter dated January 2, 1986 to..."

1-7 1.5.2 - 8th line "..of the Code of Tederal Regulations, Title...."

1-8 1.5.4 - Suggested wording change as follows:

POL item 2.C(6) " Fire Protection" should be changed, the Staff has concluded, to assure that the fire protection program described by the licensee and approved by the NRC is maintained in effect, that no changes are made that could adversely affect the ability to achieve and maintain safe shutdown in the event of a fire, without prior Staff approval, that records are maintained in auditable form for any changes that are made after the 1987 refueling outage, and that all changes are reported annually to the NRC beginning with submittal of the updated Final Safety Analysis Report. The Staff also concluded that the paragraph relating to administrative controls should be omitted in the new 20L because it merely refers to a section of the technical specifications and the specified completion date has been satisfied.

3-1 3.5.3 - last 4 lines - An inspection of the "B" low pressure turbine was

conducted during a May, 1986 outage. No increase in flaw size was noted.

3-2 Last paragraph - 1st line "The December 31, 1985 ..."

5-1 Last sentence. If the Staff evaluation was completed by June 1986 as predicted, this sentence should be updated.

5-3 1st paragraph - line 5 ".. operation for another fuel cycle."

5-3 Section 5.4 - line 11 "....by October, 1986, nine (9) months before new limits..."

6-1 Paragraph 6.2.3, item 1 - In the second to the last sentence the oxygen concentration in the containment ic said to be diluted by the production of hydrogen generated by metal-water reactions. Although that statement is correct, there is some additional oxygen that is formed by radioloysis after a postulated design basis accident. Since our combustible gas control evaluation was performed primarily for design basis accidents, the conclusion reached in the last sentence for " events beyond the design basis" cannot be fully supported based solely upon NNECO-supplied information. We assume that this conclusion is based upon additional NRC Staff evaluations of this issue.

9-1 9.4.4 - 1st paragraph - line 4 ".. requirements for safe shutdown components.

Add item (6) - Turbine Building Cable Vault (Fire Area T-2) (originally T-16) 9-2 Delete (1) as it is no longer required Renumber remaining items (1) through (6) adding footnote to (1)

Delete existing (6) as it is no longer required.

Modify footnote

  • to read
  • We code such as (T-9/R-1)/( 1 )

indicates fire door 1 between Fire Areas T-9 and R-1 9-3 3rd paragraph - lines 3,4 & 7 - the term Fire Zones should be used here rather than Fire Areas 3rd paragraph - line 4 - we have found no previous reference to exemption requests for Fire Zones T-10 and T-17 while exemptions for Zones T-16 and T-19B remain unresolved.(See next item) 4th paragraph - 3rd line "..for completion in October 1986. he Staff is also scheduled to complete its review of the March 1, 1982 request for an exemption for the Cable Vault (fire Area T-16) in October 1986.

5th line ".. letter will be in accordance with 10 CFR 50.48."

18-1 last paragraph - 4th line ".. levels up to 2011 MNth under..."

Docket No. 50-245 B12183 ATrACHMENT C COMMElfrS ON DRAFT TECHNICAL SPECIFICATIONS IVR FACILITY OPERATING LICENSE DPR-21 July, 1986

s.

'Page.No. 1 07/20/86 FTOL likAFT TECHNICAL SPECIE 1 CATIONS COMi1ENT

SUMMARY

GTOUT/LTOUT represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMBER l-1 Pach definition should be Al.L CAPO and should be ALL CAPS whenever the defined term is used in the body of the specifications. The capitalization of the words " Technical Soecifications' should be consistent throughout the document.

1-3 The definition of OPERADLE - OPERABILITY should be checked against LCO 3.0 on page 3/4 0-1. There appears to be a conflict. In the definition of FRACT10N OF LIMlllNG POWER DENCITY reference to BP8x8R bundles should be included.

1-3 No comments 1-4 In item 3 of definition U. " operable

  • should align with "All". The margin at the bottom of the page should be adjusted sn that the text and the pa c)e number .a r e not crowded together.

1-5 -)n def. V items 1 and 2 check tab alignment.

Definition X - Why is operational modes ALL CAPS as it is not a defined term? The last line of Def. X should read 'by the Limiting Condition for Operation." As 'Y' and ' 7. ' are not used as definition markers and the sequence jumps from 'X' to 'hA', it would be a better organization if the defined terms were numbered and ordered alphabetically.

1-6 Same comment as for page 1-4 concerning bottom margin.

1-7 No comments 3-1 2.1.2.A.l.a. The equation fnr S needs the symbols for Less-Than-Or-Equal-To (LTOET).

3-2 The paragraphs at the top of the page under the SAEGTY LIMITS heading are out of sequence. Items B &C from page 2- 4 should appear in this location

! instead. Under the LIMITING SAFETY SYSTEM SETT1NGC (LSSG), in the definition of 'C' should read 'Getting in percent of RATED THERMAL POWER (2011MWt)" )n item b. the symbols for LTOBT are i needed in the equation t' o r 'S'. ' Note (1) should appear at the bottom of the page. In the j  !

definition of MtLPD, the fuel type DP8x0R should j be included. ln the last sentence of the page, j- 'the' is misspelled.

f I

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P. age No. 2 07/28/'86 FTOL 11 RAPT TECHN] CAL SPECIE] CAT 10NG COMMENT

SUMMARY

GTOCT/LTOCT represent Greater /Less-Than-Or-Cqual-To PAGE COMMENTS NUMBER 2-3 For ease of reference, the LOSU number should be repeated when an item is continued such that the

'c.' now shown would become 2.1.2.A.1.c. The equation for APRM requires () as marked. The last line of item c. should read "be allowed to exceed 120% of RATED TH8RMAL POWER." Defined terms should appear as ALL CAPS.

2-4 Items 8 1 C at the top of the page should be located on page 2- 3 instead. The symbols LTOE1 ar e needed in the equation for S sob 28 in 8.1.a. The flote referenced in B.1.a is on Page 2-2 not 2-3.

In D.1.b., the equation is for G sub RB, not SRB, and the symbols for L10ET are neeced. The definition for MULPD does not match that given on page 1-2 and reference to fuel type BPuxCR should be included.

2-5 Jtem c. should be 2.1.2.B.I.c and in the equation for APRM, the lowercase p should be P. Item C.

should start as "

The Neartor Low.." ltem E.

should start as "The Turbine...' Item H - the use of ' t. t e a m l i n e s ' or ' steam lines' will have to be

decided and used consistently throughout the
specs. 'Steamlines' is suggested.

2-6 2.2.A. symbols used should be for LTOET 108S psig.

The c,etpoints in H. should be plus or minus 1% not plus or minus '- t%' as shown.

Fig. 2.1.2 Each figure appearing in the specs should have its oun page number and should appear as the following page whenever it is first referenced. This comment applies to all figures.

B 2-1 In the 5th line of the first para. the symbol for -

GTOCT is required between 'MCPR' and *1.07' The 15th line of this para. should read "..that from use related cracking, the...'. The 8yh and 9th lines of the 2nd para. should be modified to read

'..is t,h e ratio of the bundle power which would

produce onset of transition boiling to the actual bundle power.' (n the footnote, the second

)

mention of NEDO 10950 is redundant and should be deleted.

B 2-2 No comments B 2-3 No comments l

- . . - - , ,~ --g3 , - - --,,ny ,, r -- -n--- _

P, age No. 3 07/20/86 ETOL IIEhrT TECHN] CAL SPEC 1E1 CATIONS COMMENT SUMM ARY GTOCT/LTOCT represent-Greater /Less-Than-Or-Equal-To l PAGE COMHCNTS NUMBER

, . B 2-4 The 1st line of the 1st para. should read

... expected during operation of Millstone...".

The references appear in reverse order from the way they are numbered.

-B 2-b 2.1.2 A. line 8 of the 1st para - the comma in

' settings, as specified* should be deleted.

B 2-6 See MCPR note page B 2-1. Last line of 1st para.

- the reference to Amendment 16 should be deleted.

2nd para. 2nd line - need symbol for LTOET in front of 15%. Lines 6 1 7 should be changed to read * ... content are minor. Cold water from sources available during startup is not much colder than that already in the system.

T e m p e r a t. u r e . . .

  • 3rd para. 4th 1ine - should read

'..is placed in the RUN position. "

The line above t,he last para requires the symbol for LTOET.

Lines 3 and 4 of the final para should read

'.. steady-state operation, wit.h une recirculation pump operating, the eq u ali::er line shall be isolated." Refer to 3.6.H.3 8 2-7 See MCPR comment previous page. 2.1.2.B 3rd para. - need LTOUT symbols for * . 12% of RATED THERMAL POWER with the switch in REPUEL or STARTUP/ HOT GTAN08Y position."

B 2-0 U line 4 needs LTOET symbol in front of "10%" and Less-Than symbol in front of '4S%' in line 7.

F. line 4- MCPk value should be 1.07 not 1.06.

Last line of 2nd para. of F- the reference to Amendment should be deleted.

B 2-9 No comments B 2-10 In the 2nd para the use of USAS and USA 01 is not consistent.

B 2--11 No comments 3/4 0-) Appears to be a conf]ict between this section 3.0 and Definition 3.

3/4 1-1 3.1.C. line 1 12 should read .. inservice RPS MG set, or alternate power supply, shall be...'

3/4 1- 2 4.1.C.2. Itemt. a.b.c.S d. need symbols for L10ET in a. and d. : GTOUT in b. and c.

b uI' n u _ _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

V -

- P, age No. 4 .

L07/20/86 EIOL likAET TECHNICAL SPECIElCATIONS COMMENT

SUMMARY

GTOET/LTOCT represent Greater /Less-Than-Or-Gqual-To l

' PAGE COMMENTS NUMBER i

j. i i' 3/4,1-3 ' Eliminate some of the right side margin to allow

{ more spacing between columns such as Trip Function ,

+- and Trip Setting. Healign X's and A's for the first item in the table. Symbols for GTOET and LTOET are missing throughout the table. ' TABLE 3.1.l' should be included in title at top.

3/4 1+4 See comments on previous page. Refer to e>:i sting specs for correct symbols.

3/.4 1- U Title table number is incorrect , it should be

! TA B LE :3.1.1 Note U 1st line - "..is placed in kUN. '

Note 11 - should read '... valved out and electrically or hydraulically disarmed..." (Ref 4

Amendment 110). Note A A A' should read

.. instrumentation is 127 inches above.." Note AAAA should be deleted.

13/4.1-6 On the bottom line in the last column, delete the period after outage.

l l 3/4 1-7 Note 1 - 1s the reference to Commonwealth Edison l~ data still necessary? Note 7 - need symbol for LTOET 30 seconds. -

3/4 1-0 Oth line of table - the instrument channel should l be " Condenser Low Vacuum" The tab settings for

N0tes should be checked. Footnote AA should be j deleted.

l 3/4 2-1 No comments 3/4 2 2 The 5th line of the first column should be "2 of 4 in each of' Check tab settings for entries in 2nd column.

Column 3 needs symbols for LTOET and GTOET. The first entry should De GT0l'T 127 inches tref Amend.

, 76}

l l- 3/4 2 3 Adjust tab settings on each column for better j- spacing. En Remarks column, 'drywell' is one word

and check tabs in item 4 between ' gas' and i ' turbine generator". Need proper symbol for LTOET

) in boltom entry of Itip Level Settinq column.

3/4 2-4 Adjust tabs for better spacing. 4th entry of Trip i Level Getting column should have '4.b < P < S.5

! psig' and 5th entry should have '90 < P < 110 l psig

,.+--r-p y- ,,._,,.-.----,-.w,p--,-.-e= --.---w .w.- .-,-c-w-w,w w w.,-r -

e e,rv

. _- ._-. . .. ~. .-

i Ppge l)a. S l

07/28/86 i ET01. likAPT TECHNICAL SPEC 1PICATIONG COMMENT

SUMMARY

GTOCT/LTOCT represent Greater /Less-Than-Or-Equal-To PAGC COMMCNTS NUNHER 4

4 3/4 2 S Trip I.evel Setting column need proper symbols for 4 LT08T and GTOCT LRef current specs]. Note (1)

'p defined terms AI.L CAPG. Note (4) - symbol for GTOCT 100 cps. Note (5) - should read '..may be bypassed, in the higher ranges, when the..*

i 3/4 2-6 Center the Table Title and the 2nd line of the

title should be ALL CAPS and underlined. Note (6) l needs symbol for LTOCT '30% of rated.' and should l read "..of rated. A RBM channel.."

3/4 2-7 [mproper tab settings for Instrument Channel column.

1 3/4 2- 0 Adjust the tab settings for the footnotes to reduce crowding problem at bottom margin.

1 3/42-9 Th i c; is an example of a formatting problem which

. occurs frequently throughout the specs. Refer to page 3/4 3-2 of the DkAFT to see the preferred way to handle numbering. Future instances of this problem will be noted by "EURMAT COMMENT *. For 4

this page, the first ent,ry under the LCO heading should be "

3.2.C.2 Protective ]nstrumentation' 3/4 3-1 4.3.A.L. - line 3- if the word processor being  ;

used does not have a symbol for delta, then ' delta i K" will have to be used rather than trying to draw Greek symbols by hand.

3/4 3-2 3.3.8.1. The 6th line should read "..so long as '

the reactor is in the shutdown or..'

i 3/4 3-3 4.3.0.1.a. and b. should read 'When the rod....'

3 3/4 3-4 Defined terms ALL CAPS -

i 3/4 3-3 3.3.8.L c. - the value t' o r MCPR should be 1.07 3/4 3-6 No comments l 3/4 3-7 See FORMAT CONMENT 4

3. 3. li . 3. should read " ..than maximum permissible
insertion..." {Ref amend 86}

! 3/4 3 D F0kMAT COMMENT 3 . 3 .1: 3rd line - '. 1% delta K". 4.3.E. 1st '

line - should read "During startups following '

refueling outages," Reference to Startup test

program is dated, i

. - - c-.. - , _ . _ , _ _ _ . . - . , . - , . . . . . _ , _ , . . . . . ._,___.,._.,___ _ _ _ _ _., _ _.._ - _ . _ - _ , _ _ _ . _ _ _, . . -.

...:. ... a .---.... --,- . . - - . . . .. :- - : - - ..

P,cg2 No. 6 07/28/06 FTOL DRAFI TECHNICAL SPECIFICATIONS COMMENT

SUMMARY

GTOCT/LTOEI represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMBER 3/4 4-1 3.4. A - The wording in the DRAFT does not match

,that contained in the existing specs in that 'or Refuel Condition

  • is not contained in the existing specs. 4.4.A.1. 3rd line ' reactor
  • is misspelled.

3/4 4-2 4.4.A.2.a. line b ' valves, and pump capacity.'

The footnote in b. should be deleted .

t 3/4 4- 3 Format Comment '

3.4.B.3 - * ..within 7 days, or 3/4 4-4 FORMAT COMMENT 4.4.C.1. - 2nd line -

..any time water or boron is added..'

3/4 * -1 4.b.A.I. - now the symbol for delta suddenly appears. Need to be consistent with whatever method is used.

Under Frequency Column - check tab settings for l

item c.

i 3/4 5-2 Sam,e commet as previous page for the symbols for LTOET & GTOCT which have suddenly appeared.

3.5.A.2/ 2nd line '..to be inoperable, for any...' 7th line '..of such components, if no external source of power were available, shall..'

3/4 5-3 3.5.A.4. 2nd line - same comment as previous page Format comment for 4.S.B Be.consistnet with

' containment cooling subsystem' used in 3.5.A.4 and ' Containment Cooling Subsystems' used in 4.5.B.

3/4 b-4 3.b.D.3. and B.4 - next to last line of each -

'...of such cosponents, if no...' 3.5.B.6 - 'If the requirements of..'

3/4 $~3 General format comment 3/4 b-6 General f'ormat Lomment 4.5.D.1.a. - 2nd line - ..

  • sequence, but excluding actual..'

4.b.D.2. -?nd line - ".. subsystem is inoperable, the actustion..'

3/4 b-7 General format comment 3/4 5-8 General format comment 3.5.1.2 2nd line - should read "..to be inoperable, for...'

3.5.F.3 2nd line - should read ..to be inoperable, for..'

5th line - should read " . . core cooling and the containment...'

3.5.F.6. Ist line should read 'Except as specified-in 3.5.F.8, when ...'

6

. - . . ,- , ,-r-. . , , . - - - , .

/Pjige No. 7 07/28/86' FTOL llRAFT TECHNICAL SPECIFICATIONS COMMENT

SUMMARY

GTOET/LTOET represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMBER l 3/4 b-9 3.b.F.7.(b) "

..in the reactor vessel, other than I fuel sipping, while a...'

(c) "Either 1)...'

3.b.F.C.(b) - " .. torus drained, i) the operable......... ii) the condensate...'

3/4 6-1 No comments ,

3/4 6-2 General Format Comment l 3.6.B.). line 3 X 4- *

.. dashed-line curve,

representing the PV shell belt-line region, is included since it....'

-3/46-3 3.6.8.2. para, should read "During heatup by non-nuclear (mechanical) means, enoldown

] following..' line 3 - "..of Specification 4.6.A.1 line b- " .. curve, representing the RV -

shell beltline region, is included since it..."

i 3.6.D.3. line 3- * .. fluid temperatures of...'

Last sentence - " .. curve, representing the RV shell beltline region, is included since..."

i j 4.6.B.2. 1st lina - "..heatup by non-nuclear

mears, cooldown following nuclear' shutdown, and l 4.6.B.4. 2nd line - previous usage of shell and fluid have been underlined i

l l 3/4 6-4 2nd line of 2nd para. - ".. effects was removed.."

I r

3/4 6-5 General Format Comment

! 3.6.C.1 First paragraph 2nd line - ' ..any l temperature, or in the .... '

l 3rd line - "... greater than 212 E, the..'

3.6.C.l. 3rd paragraph 6th line - "..than 48 hcurs, or is greater than 4.0 microcuries per

gr am, have...'

i.

3.6.C.b. and 4.6.C.l.b. - reference is made to l specific activity limits using ' epsilon bar' rather than 'E bar' as defined in EE.

i 3/4 6-6 The phrase " Millstone Unit l' and the page number j should appear at the bottom of each page as the l page is road rather than on the side of the page i as shown here.

I l'

l

\

_-,.~..,_..m. . . _ _ _ . . , _ . . _ . - , . . . . , . - - _ . _ , _ _ . - - - . _ _ - . , , - , . _ . . . _ _ - . . . - . - - - , , _ . - . . - . , - . ~ , _ - - - _ - - . . .

P,a g e N o . 8 07/3fd86 FTOL lRAFT TECHN) CAL SPECIF] CAT':UNS COMMENT SUMMAPY GTOCT/LTOCT represent Greater /Less-Than-Or-Equal-To PAGE COMM ut:IS NUMBEP 3/4 6 */ Same ecmment an 3/4 6-G 3/4 6-3 Same comment as 3/4 6-6 3/4 6-9 3.6.C.2.4. should read *

..uater pH, corrected to 77 F, shall be...'

3/4 o 10 Genera) Format Comment 4.6.3.1 - 2nd line - 'each' is misspelled 3/4 6-11 No comments 3/4 6-]2 Genera) Format Commer.',

Defined terms ALL C A' S 4.6.G.]. 3rd line - " .. checked daily by verifying...'

3/4 6- ) 3 Genera) format comment 3.6.U.3. 4th line - ' ..shall be in Cold ....

Defined terms ALL CAPS 3/4 6- ] 4 General format comment Defined terms ALL CAPS 3.6.).b. 2nd line - " ..shall be made OPERABLE, or replaced, prior to...'

3/4 6 lb 4.6.1.3. 9th line - ".. 4.6.1.4.(a) or 4.6.[?4.(b), as...'

4.6.I.3 - *At least once per eighteen (10) months, during shutdown, a...'

line b - * ..Opecification 4.6.).4.(a) or 4.6.I.4.(b), as...'

3/4 6 16 4.6.1.3 2nd line - * ..lables 3.6.1.a and 3.6.1.b have..'

Footnote A- * .. mechanical snubbers, as stated above, will....'

3/4 6-37 This lab]e wi)) have to be redone to get proper c o l u t.n alignment Item )O should be *MS-lH Gupply 1ine" 3/4 6 -l8 Table must be redone to get proper alignment of columns Item 110 S - 4 6 should be 'MS-]C Supply 1.i n e '

3/4 6-L9 Adjust tabs for spacing between columns 3/4 6-20 General format comment Spelling of 'steamline'

Pi age No. 9 07/20/86 FTOL likArt TECl!NICAL SPEClPICAT10NG COMMFNT

SUMMARY

GTOET/LTOUT represent Greater /Less-Than-Or-Cqual-To PAGE COMMENTS NUMBER 3/4 7-1 No comments 3/4 7-2 3.7.A.l.e. line 3- The words 'or Refuel Condition' do not appear in the current tech specs

'4.7 Containment Systems' should be inserted above Applicability 3/4 7-3 Defined terms ALL CAPS 3.7.A.2.c. 3rd line - * ..shall be in COLD SHUTDOWN within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless...'

3/4 7- 4 3.7.A.3. " Primary containment integrity, as defined in Section 1.0, shall..'

4th line - ' vessel; except while...'

3/4 7 -S 4.7.A.3.d.(1) 2nd line - " .. pressure of 43 psig, except....'

4.7.A.3.d.(2) last line - ' ...the first of a series of openings.'

3/4 76 4.7.A.3.e.())(a) 1st line - need symbol for LTOET

'O.60 L' 4.7.A.D.e.(1)(b) * .. or isolation valve, except main steam isolation valves, $%..." and in the '

5% L to (43)' the to should be a subscript of the L

S pel l ing of 'steamline' 3/4 7-7 3.7.A.4.b. 3rd line - inoperable, for any reasnn...'

4.7.A.4.a. 2nd line - ' .. associated instrumentation, including setpoint, shall...'

3/4 7-0 befined terms ALL CAPS 3.7.A.b.a.(2) should read 'The valve can be closed by gravity, when released after being manually opened, to within not greater than 0.075 inch or less, as measured at the ....'

3/4 7- 9 4.7.A.5.b.(3) bth line - "..shall be inspected, including internal components, and ... '

3/4 7-10 General format statement Defined terms ALL CAPS 3/4 7--11 3.7.U.2.a. 2nd )ine - ". 500 SCFM, on HEPA fi)ter s and...'

Need symbol for GTOLT at '99% DOP' '99%

halogenated' '90% radioactive' '9S% R . !1. ' and

'190 E'

. P,a g e No. 10 07/20/06 ETOL fiRAlT TECHNICAL SPLCIElCAT10NS COMMENT

SUMMARY

( GTOET/LTOCT represent Greater /Less-Than-Or-Equal-To PAGE COMM8NTS NUMBER 3/4 7-12 3.7.D.3 2nd line - * ..or found to be inoperable, for any...'

! 3.7.b.4. "Durinq fuel handlinq, both..."

4.7.0.3.b. - "At least once per operating cycle, manual..."

4.7.D.3.c. 2nd line -

Note: Any reference found in the specs to the 27.6 KV line should be changed to *24KV line'. In 1(174 as part of the process of bringing CL&P into NU, the 1sne voltages were standardir.ed and the

' Flanders line" became a 24KV line although it was, and sometimes still is, refered to as the 27.6 line.

3/4 7-13 General format comment Defined terms ALL CAPS 3.7.C.] - " Secondary containment integrity, as defined in Section 1, shall..'

3.7.C.I.d. - " irradiated" is misspelled 3/4 7-14 General format statement 4.7.D.1.a and b. should beqin "At least once per operating cycle, the...'

I

! 4.7.D.l.d. is missing lnset t 'd. At least once per month, the main steamline power-operated isolation valves shall be exercised by partial closure and subsequent reopening.'

3/4 7-15 3.7.D.3 2nd line - ' Cold Shutdown' rather than

' cold shutdown' 3/4 7-16 lncorrect page numtier format Column heading (Valve) should be "(Valve Number)'

In Max Operating time column 1st entry need symbols for LTOUT between the 3 and the 5 3/4 7-17 page number f o r r.a t 3/4 6-1 Action item 3 lst & 2nd line - '.. minimum channels OPERADLE reovirement, take the Action shown...'

4.8.A.1, 3rd iine - '..CAllBRAT]ON, and IN STRUM CNT . . . '

- , , , , , - , - - - - , ,.,,,w,m- , y - - - , - - , . - - - , ,,,a y g -

-w-- -- -- -- y- , - - , --> - - --

P, age Nn. 11 07/28/86 FTOL lil: APT TECHNICAL SPEC 1P] CAT 10NG CijHHHNT SUMM ARY GTOET/LT08T represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMBER 3/4 8-.2 aliqn elements of Alarm Setpoints Required column

! heading Footnote A - 2nd & 3rd lines - * ..within the time limit of the specified..."

Footnote AA 2nd line - "... Only those pumps actually...'

3/4 0-3 No comments 3/4 0-4 The first page of Table 4.0-1 is missing from the draft .

The remaininq page numbers from 8-4 will have to be verified once the Table is inserted 3/4 0-b General format Comment Action item ). 3rd line - "..for Table 3.0-2" Action item 1.a. 2nd line - ' ..than required by thje above...'

Action item 1.b. Verify this para graph against existing specs.

3/4 U 0 Pontnote A - 'At alltimes, which means that channels shall be OPHRA8LE and in service on a I.

continuous, uninterrupted basis, except that

! outages are permitted, within the time limits of the specified...."

3/4 8-7 No Comments i

3/4 0-0 Instrument 3. (e) should be " Sampler Flow kate Monitor' 3/48-9 No comments 3/4 8-10 No commentu 3/4 0-11 General Format Comment i 3/4 0-12 General Format Comment 3.8.C.2. a. and b. need symbols t' o r LTOET 3/4 8-13 Game comments as page 3/4 8-12 3.8.0.1.1.b. "

.. for fodine -131...'

. 3/4 0-14 Ceneral Format comment 3.8.ll.2.1.a. Need symbols for I.TOLT. The '3 mrad for gamma' should be "S mrad fro gamma' 3.8.li.2.1.b. Need symbols for LTOLT. comma after radiation should be a period

~Ppge:No. 12 07/20/86

' ETOL DRAP1 TECHNICAL SPECIFICAT10NS COMMENT

SUMMARY

GTOET/LTOCT represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS ,

NUMDER t t

3/4 8-1b General Format Comment

l. 3.8.D.3. ' Caseous Effluents - Dose, Radionuelides...."

1 3.8.D.3.1 2nd line - ".. Tritium, and...' 4th i .line - "(see Figure 3.0-1)'

i

a. A b. need symbols for LTOET 3 . 8 . 11 Action item a. last line is missing a value l .. year-is within mrom to any organ." does not i make sense.

j 3/4 0-16 General Format Statement  ;

j 3.8.D.4.1 - need symbols for LTOET f ACTION Item a. - line 7 & 8 need symbol for LTOET i  !

2nd para 3rd line - "40 CFR Part 190. '

3/4 8-17 3.H.O.S.1 - symbol for LTOET applicability item a. -

last line - 'use of the augmented Off-gas system.'

4.8.D b. - line 3- '

..by Table 3.8-2 or...'

e 3/4 8-10 General format comment Why is 'Off gas system' ALL CAPS?

, 3.8.D.6.1 line 2- '

oCi/sec' 3/4 0-19 no page number on this figure 3/4 9 -- I 3.9.A.4. The 'a.' under item 4 is not necessary as j there ir. no b. to follow Change to " 4. 4160

volt...'

See previous note on 24KV vs 27.6 KV t

Bottom Margin too crowded 1

3/4 9-2 4.9.A.l.b. 2nd line - ".. simulated and a test..'

i 3/4 9-3 General Format Comment i Defined terms ALL CAPS

} .. 3.9.B.2 "From and after the date that incoming

. power is not available from any 345 kv line..."

Line 4 - '... notified, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of..'

r l 3.9.D 3 4th line - '4.5.E unless...'

j 4.9.B.1.b 3rd line - " cell, and temperatur a. . . '

i l

,. _____.. _ ..... .._. . ...-. _._.--.._..... . . ~...

Pags No. 13 07/20'86

/

ETOL DkAFT 11CHNICAL SPECIFICATIONS COMMENT

SUMMARY

GTOET/LTOCT represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMBER 3/49-4 No comments 3/49-5 General format Comment 3/4 10-1 3.10 A. last line - '.. fully inserted, and either electrically or hydraulically disarmed.'

t 3/4 10-2, General Format Comment i 3.10.H 'During core alterations, two SkMs...'

'Yt 3.10.B.2 2nd line - * ...with all rods..' l 4 NP 3/4 10-3 General format comment Defined terms ALL CAPS 3/4 11-1 Margin at bottom of page l 3.11 Objective - '.. Limiting Conditions...'

3.11.A.1. - "..for each type of fuel, as a function of average planar exposure, shall not..'

Defined terms ALL CAPS 4.11.A. Symbol for GIOET in line 2 l

3/4 11-4 This page is numbered out of sequence, the entire section will have to be corrected I General format comment Defined terms ALL CAPS 3.11.D. 2nd para 2nd line - '..it is determined, by normal surveillance, that..'

4.11.B. - symbols for G10L1 25%

, 3/4 11-5 General format Comment l Defined terms ALL CAPS 3.11.C. 2nd para - 'For core flows other than rated, the HCPRs in...'

3/4 11-6 Incorrect page numbering i

3/4 12-1 No Comments l

3/4 12 3 General Format Comment 4.12.k.l.a. snould read '..once per 7 days, by ..'

b. should read *..a STAGGCRCD TC37 BASIS,

. by...'

c. should read "..once per 31 days, by...'
d. should read "...once per 12 months, by..'

t

. . .e. Should read

...once per lu months,_-

f by...'

j e.(3) requires symbol for GTOFT **/5 psig'

, f. should read '...once per 3 years, by..'

l g.(1) should read '...once per 31 days, by...'

I

P, age No. 14 07/28/86 FTOI. DRAFT TECHNICAL SPECIFICATIONS COMMENT St8MMARY GTOET/LTOCf represent Greater /Less-Than-Or-Cqual-To ,

PAGE COMMENTS NUMBER 3/4 12 3 4.12.A.1 9 2. should read " At least once per 92 days, by....' bth line - '... viscosity, water.

content, and sediment.'

4 i h.1. should read ..once per 7 days, j by...'

2. should read *

...ance per 92 days,

by..'

! 3. should read "

....once per 10 months, by...'

l 3.(a) should read "

.. cell plates, and i

battery...'

(b) should read .. free of corrosion, i and coated...'

I 3/4 12-4 3.12.A.3. line 4 - " .. required by Specification 6.9.1, prepare...'

1 I

1 3.12.A 4.b.2. should read "

.. telegraph, mailgram, or facsimile...'

} 4.b.4. says "If 3.a. above.." and there is no 3.a. above i

l 3/4 12- b General format comment 1

! Defined terms ALL CAPS i 3.12.H.2 line 8 - 'inoperability, and the i plans...' ,

3/4 32-6 4.12.H.].b.(1)(b) 3rd line - should read "

.. cycle  !

of full travel, and' t 4.12.H.1.c. - should read '

At least once per 3

) years, by...'

l 3/4 12-7 General Format Comment i 3.12.C.2. 6th line - "..the Commission, pursuant

to Specification 6.9.2, within...'

! 3.12.C.4 2no line - * ..to be operable, within one..'

j 6th line - "...the Commission, pursuant to Specification G.9.2, within...'

l j 4.13. Col.a. should read "

..once per 6 months, j by...'

b. should read ...once per la months,

{

j by...'

4 i

i w, , , - - ,r--- , --.,.-e - ,-w - -. _ .- en,.---.,----,,,,rg-,,,-,,,--m,,m---e -,.v.- -...--.,,,_,_--.--,.,.,.,-------,,r--e--

-, -,-,.e,wm- ,wn,<--

P, age No. 15 -

07/28186

FTOL DRAFT TECHNICAI. SPEClEICATIONS C0hMENT

SUMMARY

4 GTOUT/LTOET represent Greater /Less-Than-Or-8 qual-To i

PAGE COMMENTS NUM Ef ER A

4 1 1

3/4 12-0 4.12.C.2.b. should read "At least once per 18  ;

months, by:

1

3/4 12-9 General Format Comment <
3.12.b.3. should read ' .. fire watch, with backup

! fire suppression equipment, t' o r . . . '

1 4.12.D.l.a. should read 'At least once per 18 monthw, by: *

+

c. should read "..once per 3 years, by; I
3/4 12-10 Table should be moved up to avoid bottom margin a problem 3/4 12-11 No Comments

-!' 3/4 12-12 No Comments l 3/4 12-13 General Format Comment  ;

j 3.12.E.2.a. "Within I hour, establish..."

(

b. 4th line - ' Commission, pursuant to l Specification 6.9.2, within..'
6th line - "inoperability, and i the...'

i 4

3/4 12-14 ltem 7.e. should be "R-3 T]P Room' j 3/4 12-1:i Check item i 12 3/4 12-16 No Comments i

t 3/4 12-17 General format Comment 3.12.P.2. 7th line - ".. Commission, pursuant to Specification 6.9.2, within ... '

i

4.12.P.).a. 'AT least once per 18 months, by..."

i i f

l

[ 3/4 13-1 3.13 Applicability - * ...Section 111, Class 1, 2, i and 3' i i

{ Specificataan - "

...AGME Code Clast, 1, 2, and

( 3 ....

l l 4.13 Applicability - "

... Code. Section 1)), Class ,

1, 2, and 3 and...'  !

4.13.H.l. It L line - ".. Pressure Vessel Code,

{ Section III, Class...'

P, age No. 16 07/281/86 ET01. IIRAFT TECllN) CAL SPECIFICATIOND COMMENT

SUMMARY

GTOCT/LTOGT represent Grester/Less-than-Or-Equal-To PAGE COMMENTS NUMBER 3/4 33-2 No Comments 3/4 14-1 3.14.A. 1st line ' reactor' is misspelled Defined terms ALL CAPS 1

9 i ,

i t

P, age No o 1 07/3828G FTOL DRAFT TECHNICAI. SPEClP] CAT 10NS COMMENT SUMM ARY GTOET/LTOUT represent Greater /Less-Than-Or-Equal-To 4

PAGC C0 lim CN TS -

NUMBER ,

3/4 1- 0 No Comments ,

B 3/4 1-1 No Comments D 3/4 1-2 No Comments

~B 3/4 1 -3 3rd para 4th line from bottom delete symbol in

  • amount of '

last para -

radiation level is or radiation levels are .Suggest

'High radiation level in the main steamline tunnel, above that due to the normal nitrogen and o>:ygen radioacti vity, is an...'

B 3/4 1-4 1st para - 3rd line " ..off gas line, provided the..' 4th line

'..Specif'ication 3.0..' 7th para - the referenced ' Note 11' does not mention ' hydraulically disarmed' B 3/4 1- 5 2nd para - Table 4.1.1 has 14 channels while Table 4.1.2 has 11 channels Where does the 13 come from? BOTTOM MARGIN B 3/4 1-6 No Comments B 3/4 1-7 Pages should be numbered on the bottom of the page 'as read' B 3/4 )~U b. could we eliminate the reference to ' vacuum tube" ?

B 3/4 2- 1 1st para - 7th line ".. control Footnote '(1) N H ll 0 . . . '

rod block. and..' 9th line - BOTTOM MARGIN

.. instrumentation, when required, by..' last para -

4th line - "PSAR, activates the ECCS subsystems, star ts the emergency diesel generator and 1 the gas turbine generator, <

and..'

B 3/4 2- 2 3rd para 4th line from b a t ta ta

.. isolation valves, the operable..'

t ,

~

Page No.- 2

-07/20/8G ETOL DRAFT TECHN1 CAL SPECIPICAT)ONO COMMENT

SUMMARY

GTOET/LTOET represent Greater /Less-Than-Or-Equal-To PAGE COMMUNTS NUMHER c

B-3/4 2-3 del'iNED TERMS ALL CAPS 2nd para '/th line - " .. at 32S psig, 4

inventory.." 3rd para,3rd line

l. - based is misspelled B 3/4 2-4 1st para symbol for less than 1.07 3rd para 5th line '..show that, with..' 8th line - "Below

] 70% power,..' 9th line - symbol

!' for less than 1.07 5th para 2nd line ".. failed, the instrument is not sensitive enough, or the...'

I

,B 3/4 2-S 3rd para - 5th line - ' fuel

~ ' '

pool, and the..'

. B 3/4 2-6 in'the equation for i the square i root symbol will have to be done by hand or change to 1/2 power

, i.e. ie(2t/r) with a superscript i- of 1/2 l B 3/4 2-7 No Comments i

B 3/4 2-0 No Comments

'B.3/4 2-9 No page. number l B 3/4 3-) BOTTOM MARGIN the footnotes appear in the reverse order in '

the text from the order at the'

! bottom of page i

f B 3/4 3-2 No Comments B 3/4 3-3 Reference (4) should be changed to Reference (2) since there is j only one other reference?

t B 3/4 3-4 The first para on this page is essentially a duplication of the l

final para on the previous page.

One of them should be deleted.

l

! B 3/4 3-S C. Reference to Amendment 21 be should be deleted. 3.3.C

, 8th line - MCPR value should be

! 1.07 p

i 5

d

Page No. 3 07/20/86 FTOL DRA1:T TECHN1 CAL SPECIFICATIONS COMMENT

SUMMARY

GTOET/LTOCT represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMBER B 3/4 3-6 E. Sth line from bottom Delete

Deviations in core reactivity p e a l.e r thsn 1% delt..s K.

l B 3/4 3-7 C. Should be ' Power /Elow

? Operating Map" 1ootnotes j should be changeduto 3,4 &5

} rather than 5. 6 3 7 for

consistency in humbering i

j B 3/4 4-1 1st para 2nd line from bottom -

l- ..the hot to cold reactivity swing..'

D 3/4 4-2 No Comments f

s B 3/4 U-l 4th para - bth line - * ..LPC) 4th para 8th line - per our LOCA i subsystem, in combination with analysis, the design large braek j' the core spray subsyr. tem, area is 4.34 so. ft rather~than provides..' the S.8 given.

s l B 3/4 S-2 No Comments i

! B 3/4 U-3 No Comments

\. .

! B 3/4 S-4 F. should be ' Emergency Cooling

, Availability' i

! B 3/4 S~S last para 4th line - ".. single failure, loss of transfer bus

] number 7, a ...'

l t

B 3/4 S-6 No Comments l B 3/4 6-1 No Comments othec'than possibly l changing para 8,rext to last

( line to read * ... maximum NDT temperature (NOTT)..'

B 3/4 6- 2 last para uses

  • i!D T temperatore"
and 'NDIT + 60'
B 3/4 6- 3 3nd para spellinq of

'steamlines' 1

i l .B 3/4 6-4 1st para 6th line ".. cold i shutdown condition.." 2nd para i Sth line - should be * .. normal j range, chloride and other j impurities will also be within

their normal ranges. E. - the

! word *new' in the first line

! should be deleted.

l l

'Ppge No. 4 07/28/86

.ETOL llRAFT TECHNICAL SPECIFICATIONS COMMENT SUMMAR Y GTOET/LTOET represent Greater /Less-Than-Or-Equal-To PAGE COMMUNTS 4

NUMI4ER B 3/4.6-5 No Comments 4

~B-3/4 6-6 Pa r i. of sentence missing in p .s r .a 2 It should read as " ..in that loop. Comparison of the data with a normal relationship or

! pattern provides the indication..." H. 2nd line -

'For some' limited, low probability accidents, with ...'

' B 3/4 6-7 No Comments B 3/4 6-8 J 3rd para . Delete (?) the sentence "Since startup of Unit 1, the salt-splitting capacity of the resins has dagraded aboyut 15% from its initial value of 1.2 meq/ml." K. -

spelling of "steamlines" l

B 3/4 7-1 A. lith line - "..at this time, which will.." bth & 6th line from bottom *l.5% delta K' B 3/4-7-2 3rd para - 'the maximum temperature, at the end of blowdown, tested..' 5th para --

last line - ".. containment

sparay interlocks.' Footnotes

- Reference numbers missing should be (3) thru (6)

B 3/4 7-3 2nd para 5th line - '(2) last para on page - 5th line -

initation of of suppression pool '..out of service for...' 7th water coolionq heat exchangers, line - "..is brought to a...'

i and (3) initiation of reactor It appears that the Heading for shutdown.' 3rd para 2nd line - Vacuum helief should be '3,4 and-

'..very slowly. Monitoring 5. Vacuum Relief' these..'

B 3/4 7-4 1st paragraph of 6. 7th line -

l hydrogen is misspelled i

D 3/4 7-5 2nd para of B 2nd line - 3rd para of B. 4th line -

'..after the charcoal adsorbers ".. performance, and reactor 3

to ..' Everywhere in the operation or refueling operation

i. paragraph that ' absorbers
  • may continue while.." Sth line.

appears it must be changed to - " During refueluing, two

'adsorbers' off-site power sources (34SKV or l 24KV)...'

r- w e e.n- -, --w-w.--v-,+,rw-,e w -r-- - ~w- w m m %w w = w n-v , * -=+ - ,e-*-,.e-mn -w--,-- .r v--cv-r-,r- ,,-'ni--- -e*o. wr - - - - - - - -

. - - - - - - - . - - - - - --- -. . - _ _ . . ~. .

Ppge No. 5 07/28*/86 FTOL UNAFT TECHN] CAL SPECIF1CATIONC COMMENT

SUMMARY

, GTOET/LTOUT represent Greater /Less-Than-Or-Cqual-To 4

PAGE COMMENTS

- NUMBER 9

'B 3/4 7-6 2nd line - 'C]osure of one of the valves..."

B 3/4 7- 7 Ist para 3rd line - ".. check of the temperature, volume, and differential..."

. B 3/4 7-8 2nd para 6th line - " .. depleted 4 of oxygen, whereas under..'

9th line - should it read

'.. applied was 0.8 as determined from the...' 3rd para 2nd line

- " ..before the guideline thyroid..' lith line - '

.. test leak rate by 0.75, th er eby . . . '

B 3/4 7 9 1st para. 3rd line - * ..(primary e containment head, equipment hatches, and the.." Yth line -

accident is misspelled 5th para ]st line - " .. performed to check the capability of the...'

1 B 3/4 7-10 1st para 2nd line - . 7 inches "

of water, at the system design

flow rate, will..." 4th line -

'..prerssure drop, and air...'

B 3/4 7-13 2nd para 6th line -

".. instrument delay, as long as 10.5 seconds." last para -

DELETE REE TO OLD AMENDMCNT NO.

l Suggest "..in these lines will e

be performed as described in l

Specification 4.7.D.1.b.'

4 B 3/4 8-1 INCORRECT PAGE NUMBER FORMAT C.2. Sth line ".. flexibility and, at the same time,

, implement..'

B 3/4 0- 2 1NCORRECT PAGM NUMBER FORMAT D.1 12th line increaase is IST PARA Sth line - "..unlikely misspelled Need proper symbols to be substantial]v.." 9th line for LTOET at 500 3000 and 1500 Calculation of Annual ..' Words missing from D.2 4th, Section D. needs its title line - "forth in Section 11.B of:

' Radioactive Gaseuos dffluents' A p p e n d i:: I. The ACT ION

D.1. 10th line -* ..who may, statements provide the required i at times, be..' operating flexibility and at the same...

. P,a g.e N o . 6 07/28*/86 FTOL DRAFT TECHNICAL SPECIPICATIONS COMMENT

SUMMARY

GTOET/LTOCT represent Greater /Less-Than-Or-Cqual-To PAGE COMMENTS NUMBER B 3/4 0-2 D.3 words missing at end of para - last line -

'.. met.nocology provioeo in Regulatory Guide 1.109,

" Calculation of Annual lioses to Man from Routine Releases' B 3/4 0-3 1NC0kktCT PAGE NUMBER FORMAT D.3. (f t h line from bottom - ' . . -

D.3 2ND LING ." SCCTCONS II.C, in particulate form, and ...

II.A..' STH 1lNE -

"..flexability and, at the same time, implement..' */ t h line -

' materials' is misspelled 14th line -- The sentence which begins

'The ODCM ..

makes no sense as is B 3/4 0-4 INCUkkECT PAGE NUMBhk FORMAT D.S 2nd line - "fo' should be

'of" D.6. 1st line - * ..the gross radioactivity rate..."

B 3/4 9-1 A. 1st para 4th line " . 24KV system..' 8. 3rd para 4th l line "

..of the two emergency onsite power.." D. 2nd line -

gas turlei ne gener ator . . " to agree with previous usage. ,

Remove reference to Amendment 10 B 3/4 9-2 A.lst para 6th line - * ..will A. 4th para 6th line - "..to be manually started, simulate a loss of.." C.

l synchronized to the bus, and .. fuel supply weekly, and after load...' 1 r. t para last each operation, assures.."

sentence ' thirty" is misspelled i 2nd para let line - "gan turb m generator..' 3rd para 1st line - " ..the tests, or peaking ooeration, cf..'

D 3/4 10-1 A. 5th para - do we still need references to a "new core'?

B 3/4 10-2 No Comments B 3/4 )l-1 A. 3rd para, 8th line - " ..model requires that at the..' 8. 4th lino - * .. rod movement, has caused..." DCFINED TCRMG ALL l CAPS e.g. "

. 2SZ khilcD THERMAL l POWCR. the .. '

i

, - . - - - , , , , ------.- ,,e... , , - . , , , - , . , , , , , - , - . , . , , . - , - ,. .s n.r.--.. - , . . . , , , . - , - -

P,a gy *N o . 7 07/20/86 FTUL liR AFT TECHN1C AL SPECIF1C AT 10NO COMMENT GUMMARY GTOCT/LTOUT represent Greater /Less-than-Or-Cqual-To PAGE COMMCNTS NUMBER D 3/4 11-3 C. 1. "

..LOCA analysis, a MCPR of..." C.2. "..of the transients, or distur bances ,

caused.." 2nd para - OCCINED TERML ALL CAPG 11 5th line -

'. 3.ll.A, n, and C, that if, at any time durinq poaer operation, it is..' Oth line - '. 15 minutes if..'

B 3/4 L2-1 No Comments D 3/4 13-1 No Comments 5-1 D CS IGN t'SATURES incorrect page number should be b-1 b.2 B.

2nd line - ' ..shall be hafnium and /or . . ' 5.5 B. 3rd line -

".. dependent K infinity of the..' ltem b.b.C. was eliminated by Amendment 107 5-2 Incorrect page number '3-3' should be 5-2 6-1 6.3.2.b. 'At 1 cast one 6.2.2.f. 2nd line - include is licensed..' [n 6.2.2 d & f the misspelled

'A' used for the footnote should be t instead and the footnote should be 't Gee note on Page 6-3' PLEASC NOTE THAT IF THE FIGURES ARE TO BE PL ACLII AT THE END OF THC SGCTION THE RUF PAGE W O U L ll Bb 6-4 6-2 No Comments 6-3 Pootnote A does not read pr operly, should it be 'A Does not include the licensed Lenior Reactor Goerator or Senior Reactor Operator 1imited to Fuel Handling individual supervising CORE A I 'l E R A T 10 Nf; after the initial fuel loading.'

6-4 6.4.3 3rd Jine - ' . . e::c e p t that fire...'

6-b 6.b.].b "of the Chai r man, or the A U'l H O R I T Y heading at the I) i c e Chairman, or..." bottom of th9 page should be 6.b.1.6.a. 3r d lino - moved to the next page

.. procedures, or changes thereto, as ...

G.b.1.6.i.

"..d9 terminations, in writing, m . - __ -_

Page No. 8 OY/28986 FTOL likAFT TECHNICAL SPECIF]CA110NS COMMENT

SUMMARY

GTOET/LTOCT represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMBER 6-6 HOTTOM MAkGIN 6-/ ti . S . a . / . a . 2nd Line -

' disapproval, in meeting minutes, of...' 6.S.2.7.b.

1st line - ".. notification, or meet,ing minutes, to.." DOTTOM M ARG IN 6-8 B0110M MARGlN 6.5.3.2 1st line - " ..less than seven, nor...' 6.5.3.4 the reference to the initial year of operation is dated - suggest ..shall meet '

at least once per six months and as convened by the NRD Chairman.'

6-9 BOTTOM MAWGIN 6.5.3.5 3r d 1ine - 'the Chairman, or his designated altetnate, and at..*

4 6.S.3.6.d. '...of these Technical Specifications or Licenses."

6-10 B0110M MARG]N 6.S.3.7.c. 3rd line - '.. nuclear safety, at least..' 6.L.4.1 S I TE NllC1.E A R REV ICtJ BO ARD (SNRD) should be under)ined 6-1] 6.5.4.2 3rd line - '.. Chairman, and members, of..' Sth line -

.. degree in an engineering...'

6.6.4.3 - ' .. expert advice to..." 6.5.4.b. - ' .. quorum of the GNRB shall consist of the Chairman or his ...'

6.S.4.6.b. ".. common to all units.'

6-12 BOTTOM MARGIN (remove extra line between b. and c. of 6.S.4.7 6.5.4.7.e. - ' ..and audit of the fire...'

6-13 B0110M MARG)N 6.7.1.d. 2nd line

'..the NR8, and the Vice President Nuclear Operations within 14 days ur the violation.' 6.0.1.c. FORMAT

Pace No. 9 0*7728'/86 FTOL DRAFT 1ECHNICAl. SPECIFICAT10NS COMMENT

SUMMARY

GTOET/LTOCT represent Greater /Less-Than-Or-Equal-To PAGE COMMENTS NUMDER 6-14 6.8.1.h. 2nd line - "..for 6.8.b lst para. line 4 --

Section I.E. , Radiological...' "

... Assessment Branch or the 6.8.2 2nd 1ine - '..by the Production...*

PORC/3 ORC,...' 6.8.3.c. "..by the PORC/S0kC, as..."

6-15 HOTTOM MAkO]N G.9.1.1 2nd line 6.9.1.b 1st line - 'A should be '..folLowing (1) tabulation, on an annual basis, receipt..' 6th line - of ..." Footnote Format

'.. nuclear, thermal, or..." (missing line) 6.9.].2 7th line - '...detailu required in..." 6.9.1.4 Reference to Lhe

  • initial report" should be deleted 6-16 H O T T O tt MARGlN 6.9.1.0 4th line

- " .. Regulatory Commission, or his ...' 6.9.1.8.d. 3rd 1ine - If THE DELTA SYMBOL IS NOT AVAL]AHLE ON THE WORDPROCESSOR USCD fMEN DCLTA SHOUI.li BE SPELI.ED OUT {e.g. ' or equal to 1% delta K/K...'}

6-17 BOTTOM MAHG1N 6.9.1.8.d. 3rd 6.9.1.U.i. 4th & 6th lines -

line - ".. reactivity increases replace Safety Analysis Report that...' IIEl.T A K/K COMriENT with SAR in each line 6.9.1.9 6.9.1.0.e. Last line - "..in the 4th line - "..shall include, as Safety Analysin Report (SAR)." a minimum, a completed...'

6.9.1.0.h. 2nd line - 3HOULD SAR ACTUALLY BU FSAR??

".. described in the SAN or SEE 6.10.2.a.

in...'

6-18 BUTTOM MARG]N 6.9.1.9.b. 2nd Can 6.9.2.c. be truly deleted linn - " ..for operation or and the remaininf items plant..' 6.9.1.9.c 3rd line - renumbered a. through f. ?

. . cauw reduction of degree of redundancy..."

6-19 IlOTTOM MARG)N 6.9.2 9 6.10.2.a. SEE Paqe 6-17 comment

'.. Specifications in 3.0.C.2, concerning FSAR vs SAR 3.8.C.2, 3 . 8 . lt. 3 , a n d 3 . 8.11. 4 . '

( 6.10.1.d. .. inspections, and calibrations requirnd by these technical specifications."

l 6.lO.2.b. - ' ..anventory, fuel l

transfers, and...'

6-20 It0TTOM MARGJN 6.10.2.f. "..of transients or..' 6.10.2.k. -

..the G0HC and the SNRB.*

Footnote A -

  • A Health Physien..."

r No. 10 P,,:s 0?/2f g,' f/ 8 6 E T 01. IIR AFT TI:CilN IC A1 SPECIFICA110NS COMMENT

SUMMARY

GT O C T/LT01:T represent Greater /Less-Than-Or-Equal-To PAGC COMMUNTS NUMBER 6-2] No (:o m m e n t s 6-22 6.16 2nd line - * .. approved, the footnote A reference does maintained, and adh9ted...' not appear in the body o t' the text. It could be -

"..use of a ppro pr iate A waste treatment..." in line 4 of 6.16