ML14170A086

Requests Addl Info Re TS Change Request to Convert to Improved Standard TS for Hb Robinson Steam Electric Plant, Unit 2

ML14170A086
Person / Time
Site:	Robinson
Issue date:	02/24/1997
From:	Mozafari B NRC (Affiliation Not Assigned)
To:	Hinnant C CAROLINA POWER & LIGHT CO.
References
TAC-M96440, NUDOCS 9703030217
Download: ML14170A086 (83)

Text

February 24, 97 Mr. C. S. Hinnant, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATION CHANGE REQUEST TO CONVERT TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR THE H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 (TAC NO. M96440)

Dear Mr. Hinnant:

By letter dated August 27, 1996, you submitted a request to convert the current Technical Specifications (TS) for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR), to be consistent with the Improved Standard Technical Specifications (ISTS) in NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 1, dated April 1995. To complete our review, we need additional information requested in the enclosed table under the heading "Comments."

To support the NRC staff's review schedule, your written response to this request for additional information is expected within 30 days of the receipt of this letter. Should you have any questions, do not hesitate to contact me at (301) 415-2020.

Sincerely, (Original Signed By)

Brenda Mozafari, Project Manager Project Directorate II-1 ov Division of Reactor Projects -

I/II Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

As stated cc w/ enclosure:

See next page Distribution Docket File C. Grimes PUBLIC OGC PD II-I RF ACRS S. Varga J. Johnson, RH M. Reinhart D. Clark C. Schulten FILENAME -

G:\\ROBINSON \\ROB9644A.RA2 OFFICE f,,9MRPDII-1 LA:PDI PD:PDII-

_/

NAME lvM afari Dunning MReinhart rL DATE 2/24/97

?2/24/97 2/24,9]

COPY I Yes/No Je)/No Yes No) 2 OFFICIAL REGORD COPY 280039 9703030217 970224 PDR ADOCK 05000261 P

PDR

Mr. C. S. Hinnant H. B. Robinson Steam Electric Carolina Power & Light Company Plant, Unit No. 2 cc:

Mr..William D. Johnson Mr. Dayne H. Brown, Director Vice President and Senior Counsel Department of Environmental, Carolina Power & Light Company Health and Natural Resources Post Office Box 1551 Division of Radiation Protection Raleigh, North Carolina 27602 Post Office Box 27687 Raleigh, North Carolina 27611-7687 Ms. Karen E. Long Assistant Attorney General Mr. Robert P. Gruber State of North Carolina Executive Director Post Office Box 629 Public Staff - NCUC Raleigh, North Carolina 27602 Post Office Box 29520 Raleigh, North Carolina 27626-0520 U.S. Nuclear Regulatory Commission Resident Inspector's Office Mr. Max Batavia, Chief H. B. Robinson Steam Electric Plant South Carolina Department of Health 2112 Old Camden Road Bureau of Radiological Health Hartsville, South Carolina 29550 and Environmental Control 2600 Bull Street Regional Administrator, Region II Columbia, South Carolina 29201 U.S. Nuclear Regulatory Commission 101 Marietta St., N.W., Ste. 2900 Mr. J. Cowan Atlanta, Georgia 30323 Vice President Nuclear Services and Environmental Mr. Dale E. Young Support Department Plant General Manager Carolina Power & Light Company Carolina Power & Light Company Post Office Box 1551 - Mail 0HS7 H. B. Robinson Steam Electric Plant Raleigh, North Carolina 27602 Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Milton Shymlock U. S. Nuclear Regulatory Commission Public Service Commission 101 Marietta Street, N.W. Suite 2900 State of South Carolina Atlanta, Ga. 3023-0199 Post Office Drawer 11649 Columbia, South Carolina 29211

HBR ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DEPARTURE FROM NUCLEATE BOILING (DNB) LIMITS DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD NO COMMENT 1

HBR ITS 3.4.2, RCS Minimum Temperature for Criticality DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.2-1 JD 2 STS STS 3.4.2 Required Action A.1 requires Functionally how 3.4.2 the plant to be in MODE 3.

can the operator tell he is in ITS 3.4.2 Required Action A.1 changes the Mode 2 Keff less requirement from MODE 3 to "MODE 2 with than 1.0 but gre Keff <

1.0."

ater than.99?

There is inadequate justification for this deviation from the STS.

1

HBR ITS 3.4.3, RCS Pressure and Temperature (P/T) Limits DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.3-1

LA1, CTS CTS 3.1.2.1.a. 3.1.2.1.b, 3.1.2.1.c. and Identify the spe R1 3.1.2.1, 3.1.2.2. 3.1.2.3, and 3.1.2.4 require-cific licensee 3.1.2.2.

ments are moved to "licensee controlled controlled docu 3.1.2.3.

documents."

ments.

3.1.2.4 The specific licensee controlled docu ments are not identified.

3.4.3-2 Al CTS CTS 3.1.2.1 imposes specific limits on 3.1.2.1 reactor coolant pressure. and on Reactor Coolant System (RCS) heatup and cooldown rates.

ITS 3.4.3 imposes specific limits on RCS pressure, RCS temperature and RCS heatup and cooldown rates The addition of "RCS temperature" to the requirement represents a More Restrictive change that is not discussed or justi fied.

1

HBR ITS 3.4.3, RCS Pressure and Temperature (P/T) Limits DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.3-3 M4 CTS If CTS 3.1.2.1 is not met, the operator The justification 3.1.2.1 must place the plant on a shutdown track for this and oth in accordance with CTS 3.0. CTS 3.0 er More restric requires the plant to be in Cold Shutdown tive changes (reactor subcritical and T

! 200F) could use im within 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />.

provement If ITS 3.4.3, and its associated ACTION A is not met, Required Action B requires the operator to place the plant on a shutdown track. From time of entry into Required Action B, the prescribed Comple tion Time to be in MODE 5 (K < 0.99 and RCS Pressure < 420 psig) is V hours.

This represents an extension to an Al lowed Outage Time for which there is no justification.

3.4.3-4 None ITS 3.4.-

Does less than 420 psig in the Required 3, Action Action present a problem given LCO 3.4.12 B

has the relief valves set at less than or equal to 400 psig?

2

e.

HBR ITS 3.4.4 RCS LOOPS MODES 1 and 2 00C CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD NO COMMENT

HBR ITS 3.4.5, RCS LOOPS-MODE 3 DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.5-i Li CTS CTS 3.1.1.1.a.3 does not address that 3.1.1.1.

reactor coolant pumps can be deenergized.

a.3 This is changed in ITS 3.4.5 to allow reactor coolant pumps to be de-energized for s 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in any 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.

There is inadequate justification for this change. While the Li discussion states that this will only be done as part of a special test, in which case it would have to be reviewed pursuant to 50.59 before being implemented. there is nothing in the TS that restricts deenerg izing reactor coolant pumps only to spe cial tests. Therefore. justification needs to be provided that operation in Mode 3 with no RCS flow is consistent with the plant licensing basis.

3.4.5-2 None ITS Bases What does "Boron dilution requires forced Also see Bases 3.4.5 circulation to provide proper mixing, and 3.4.6 C.1 and D.1, D.2, perserve the margin to criticality" mean?

C.2, and Bases SD.3 Boron dilution requires??

3.4.8 B.1 and B.2

HBR ITS 3.4.5, RCS LOOPS-MODE 3 DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.5-3 L18 CTS CTS 3.1.1.2 requires at least two steam Provide discus 3.1.1.2 generators to be operable whenever the Sion and justifi average primary coolant temperature-is cation for this above 3500F. CTS 3.0 requires the unit More Restrictive to be placed in hot shutdown within 8 change.

hours and to be placed in cold shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> until the reac tor is placed in a condition in which the specification is not applicable.

ITS 3.4.5 Required Action B.1 requires Pthat the unit be placed in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The discussion and justification do not address the More Restrictive requirement that the unit be placed in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, versus s3500 F within 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />.

3.4.5-4 L19 CTS CTS 3.1.1.1.a allows the number of oper-Provide addition 3.1.1.1.a ating reactor coolant pumps to be reduced al discussion and provided certain actions are taken.

justification for These actions ensure that a power excur-this More Re sion resulting from a inadvertent control strictive change.

rod withdrawal event is precluded. CTS 3.1.1.1.a does not explicitly provide a time period for implementing these re quirements in the event of a loss of an operating reactor coolant pump.

ITS 3.4.5 Required Action C.1 requires that the conditions of the LCO be met within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. resulting in a More Re strictive change for which there is inad equate discussion and justification.

HBR ITS 3.4.5, RCS LOOPS-MODE 3 DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.5-5 JD6 STS STS 3.4.5 CONDITION D was modified to It is not just 3.4.5 include "Required Action and Completion sufficient to add CONDITION Time of Condition C not Met."

this Action. It D

must be explained There is

.no discussion or justification, what in the HBR for this change.

design requires this extra action

_not in the STS 3.4.5-6 JD6 STS STS 3.4.5 CONDITION C is changed in the 3.4.5 ITS to read "Requirements of the LCO not CONDITION met for reasons other than Condition A or C

D.

ITS 3.4.5 Condition D is not yet entered at this point in the ACTIONS.

Therefore it is inappropriate to refer to the requirements of Condition D.

3.4.5-7 M7 CTS CTS 3.1.1.1.a does not include the provi 3.1.1.1.a sion that the Rod Control System be inca pable of rod withdrawal.

ITS 3.4.5.a includes such a provision as an option.

While M-7 is fine as far as it goes, there is no justification for stating this a more restrictive change even with added option of the rod control provision that is not in CTS 3.1.11.a.

3.4.5-8 None LCO 3.4.5 If Action C is not for rod control as it is in the ITS (covered in the NOTE), why is Action C necessary?

HBR ITS 3.4.5, RCS LOOPS-MODE 3 DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.5-9 L-18 Typo -The Discussion references NUREG 1433.

3.4.5-None Bases To be correct, shouldn't the line begin 10 3.4.5.3 ning "Should a power excursion occur..."

Action have the word "yet" before the word "sat C.1 isfied"? The only time such an excursion can occur is with a. b. c. and d not satisfied.

g0' HBR ITS 3.4.6, RCS LOOPS-MODE 4 DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.6-1 L3 CTS The L-3 discussion focuses on submitting Provide discus 3.1.1.1.-

the report and that discussion is ade-sion and justifi c.2 quate. However, CTS 3.1.1.1.c.2 requires cation for the that, if a reactor coolant pump or RHR More Restrictive pum cannot be restored to operation change.

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />...

ITS 3.4.6 Required Action and Completion Time to initiate action and restore.one loop or train to OPERABLE status and operation is "immediately."

There is no discussion or justification for the More Restrictive requirement of immediately versus 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

3.4.6-2

[2 CTS CTS 3.1.1.1.c.1 includes an ACTION to Provide discus 3.1.1.1. -

establish RCS boron concentration equal sian and justifi c.1 to or greater than that needed to main-cation for the tain a shutdown margin of 1% Ak/k at More Restrictive 2000F. No maximum time is specified to change.

complete this ACTION.

The equivalent ITS 3.4.6 Required Action C.1 requires that all operations involv ing a reduction in RCS boron concentra tion be suspended immediately.

The action is less restrictive however, the change in time constitutes a More Restrictive change for which there is no discussion or justification.

HBR ITS 3.4.6, RCS LOOPS-MODE 4 DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.6-3 JD9 STS STS 3.4.6 Condition A states "One re 3.4.6 quired RCS loop inoperable," and "Two RHR ACTION A loops inoperable."

The modified ITS 3.4.6 Condition A states "One required loop or train inoperable" and "One required RCS loop OPERABLE."

The discussion and justification lacks any degree of detail for this change and is inadequate. The difference in the use of the terms operable and inoperable between the final ITS and the STS markup may explain the comment.

3.4.6-4 JD9 STS STS 3.4.6 Condition B states "One re-Same reasoning as 3.4.6 quired RHR train inoperable." and " Two comment above.

ACTION B required RCS loops inoperable."

The modified ITS 3.4.6 Condition B states "One required loop or train inoperable."

and "One required RHR train inoperable."

The discussion and justification lacks.

any degree of detail for this change and is inadequate.

HBR ITS 3.4.7, RCS LOOPS-MODE 5, LOOPS FILLED DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.7-1 L6 CTS CTS 3.3.1.4 requires both residual heat The BACKGROUND 3.3.1.4 removal (RHR) loops operable.

section of the Bases appear to ITS 3.4.7 requires both RHR trains be provide.the type OPERABLE and one in operation, or one RHR of information train OPERABLE and in operation and one needed.

SG OPERABLE.

There is inadequate discussion and justi fication for use of the SG for decay heat removal.

3.4.7-2 L17 CTS CTS 3.3.1.4.a requires the existence of a Provide addition 3.3.1.4.a method to add make-up water to the RCS be al discussion and verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and the inoper-justification for able RHR loop be restored to operable the changed CTS status within 14 days.

requirement.

ITS 3.4.7 Required Action A.1 requires that action be initiated immediately to restore a second RHR train to operable status.

The discussion and justification do not address the deletion of the make-up water requi rement.

HBR ITS 3.4.7, RCS LOOPS-MODE 5, LOOPS FILLED DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.7-3 L16 CTS CTS 3.3.1.4.a requires the inoperableRHR Provide addition 3.3.1.4.a be restored to operable status within 14 al discussion and days.

-justification for the Less Restric ITS 3.4.7 Required Action and Completion tive change.

Time require initiating action to restore a second RHR Train to OPERABLE status "immediately."

There is no discussion or justification for changing from initiating action imme diately versus restore in'14 days. The discussion only addresses submitting a special report.

00 HBR ITS 3.4.7. RCS LOOPS-MODE 5, LOOPS FILLED DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.7-4 L4 CTS CTS 3.3.1.4.b requires that, if both RHR Provide addition 3.3.1.4.b loops become inoperable, all containment al discussion and penetrations providing direct access from justification for the containment atmosphere to the outside the changed CTS atmosphere be closed prior to the RCS requirement.

average temperature exceeding 2000F.

ITS 3.4.7 does not include this require ment.

There is inadequate discussion and justi fication for this change from CTS requir ements. 1) The requirement to close the penetrations is a provision to preclude the release of radioactive material in steam, the L-4 discussion only focuses on boron stratification which is a addresses the separate concern of the unplanned return to criticality and does make some general references to shutdown risk con siderations but neither summarizes them nor explains why they must be complied with.

0 HBR ITS 3.4.7, RCS LOOPS-MODE 5, LOOPS FILLED DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed 3.4.7-5 M14 CTS CTS 3.3.1.4.b requires that, if both RHR It appears the 3.3.1.4.b loops become inoperable, at least one Bases may contain loop be restored to OPERABLE status as the needed infor soon as possible.

mation.

ITS 3.4.7 Required Action B.1 requires that if both RHR trains become inoperable or "no RHR train is in operation", that all operations involving a reduction in RCS boron concentration be suspended, and that actions be initiated immediately to restore one RHR train to OPERABLE status and operation.

The discussion and justification do not address the change of no RHR train in operation.

HBR ITS 3.4.8, RCS LOOPS-MODE 5, LOOPS NOT FILLED DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.8-1 L17 CTS CTS 3.3.1.4.a requires the existence of a Same comment as 3.3.1.4.a method to add make-up water to the RCS be made for Section verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.4.7 ITS 3.4.8 Required Action A.1 does not retain this requirement.

The discussion and justification do not address deletion of the make-up water requirement.

3.4.8-2 L17 CTS CTS 3.3.1.4.a requires the inoperable RHR Same comment as 3.3.1.4.a loop be restored to operable status with-made for Section in 14 days.

3.4.7.

ITS 3.4.8 Required Action A.1 and Comple tion Time require initiating action to restore a RHR Train to OPERABLE status "immediately."

There is no discussion or justification for initiating action immediately versus restore in 14 days. The discussion ad dresses submitting a special report.

3.4.8-3 A9 CTS CTS 3.3.1.4.a requires that a Special Provide discus 3.3.1.4.a Report be prepared and submitted to the sion and justifi NRC within 30 days.

cation for the administrative ITS 3.4.8 does not include this require-change.

ment.

The discussion and justification have been deleted in the DOCs for this admin istrative change (DOGA9 "Not Used").a

HBR ITS 3.4.8, RCS LOOPS-MODE 5, LOOPS NOT FILLED DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.8-4 L4 CTS CTS 3.3.1.4.b requires that, if both RHR Same comment as 3.3.1.4.b loops become inoperable, all containment made for Section penetrations providing direct access from 3.4.7 the containment atmosphere to the outside atmosphere be closed prior to the RCS average temperature exceeding 2000F.

ITS 3.4.8 does not include this require ment.

There is inadequate discussion and justi fication for this change from CTS requir ements.

HBR ITS 3.4.9, PRESSURIZER DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.9-1 JD12 STS STS 3.4.9.a requires Pressurizer water Provide justific 3.4.9.a level 5 92% in MODES 1, 2, and 3 ation for the STS deviation based This is changed in the ITS to a MODE 1 on the current requirement of Pressurizer water level licensing basis, s63.3%, and a MODE 2 and 3 requirement of system design, or Pressurizer water level 592%.

operational con straints.

The justification provided for the MODE 2 and 3 requirement of 592% comes from where in the current licensing basis, system design, or operational constrain ts.

3.4.9-2 A13 CTS CTS 3.1.3.4 requires that the reactor be Provide addition 3.1.3.4 maintained subcritical until "normal" al discussion and water level is established in the Pres-justification for surizer.

the More Restric tive change.

ITS 3.4.9.a and b require Pressurizer water level 563.3% in MODE 1 and Pressur izer water level s92% in MODES 2 and 3 respectively.

There is inadequate justification for this More Restrictive change as it un clear where the levels chosen come from.

HBR ITS 3.4.9, PRESSURIZER DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.9-3 JD13 ITS SR The STS SR 3.4.9.2 Frequency of 92 days Provide justific 3.4.9.2 is changed in the ITS to 18 months.

ation for the S1S deviation based The justification for this deviation is on the current that there is personnel risk incurred licensing basis.

while performing the required surveil-system design, or lance because permanent instrumentation operational con is not installed, and that 18 months is straints.

consistent with current practice.

However, the risk is not quantified, there is no evidence that a cost benefit analysis has been performed. the results of which demonstrate installation of per manent instrumentation to be prohibitive,.

nor is there any discussion that equip ment reliability supports an interval six aTtimes that of the 15.

HBR ITS 3.4.10, PRESSURIZER SAFETY VALVES DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.10-1 L7 CTS CTS 3.1.1.3.c.1 pressurizer code safety Provide discus 3.1.1.3.

valve lift settings are maintained be-sion and justifi c.1 tween 2485 psig and 2560 psig respective-cation for this ly.

More Restrictive change.

ITS 3.4.10 pressurizer safety valve lift settings a 2410 psig and s 2560 psig.

The discussion and justification do ad dress that a higher setting is less re strictive setting but do not address that a lower safety valve lift setting is a More Restrictive change.

3.4.10-2 L7 CTS CTS-3.1.1.3.c.1 pressurizer code safety 3.1.1.3.

valve lift settings are maintained be c.1 tween 2485 psig and 2560 psig respective ly.

ITS 3.4.10 pressurizer safety valve lift settings a 2410 psig and s 2560 psig.

The discussion and justification address the lift setpoint is 2485 +/-3%, however, it appears the CTS lift setpoint is 2485

-0%

+3%.

0 0

HBR ITS 3.4.10, PRESSURIZER SAFETY VALVES DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.10-3 LA3 CTS CTS 3.1.1.3.a requires that 1 Pressurizer Identify the spe 3.1.1.3.a code safety valve be operable whenever cific licensee the Reactor Head is on the vessel and the controlled docu RCS is not open for maintenance. This ments.

requirement is moved to "licensee con trolled documents." 1) The specific li censee controlled documents are not iden tified. and 2) Is the requirement going to maintained in addition to the require ments of ITS LCOs 3.4.10 and 3.4.12?

3.4.10-4 M20 CTS CTS 3.1.1.3.c requires that all 3 Pres 3.1.1.3 surizer code safety valves be operable when RCS temperature is above 3500F.

ITS 3.4.10 NOTE allows a provision that the lift settings do not have to be with in the limits in MODE 3 for the purpose of setting the Pressurizer code safety valves under ambient conditions.

The discussion and justification do not address this less restrictive part of the change.

3.4.10-5 JD15 S1S ITS Applicability is MODES 1, 2. and 3.

Provide justifi 3.4.10 cation for the STS Applicability is MODES 1, 2. and 3 STS deviation and MODE 4 with all RCS cold leg tempera-based on the cur tures > [275]0F.

rent licensing basis, system The discussion and justification for the design, or opera STS deviation do not adequately address tional con the current licensing basis, system de-straints.

sign,_or operational constraints.f

HBR ITS 3.4.10, PRESSURIZER SAFETY VALVES DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD

HBR ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4-11-1 None ITS SR Either the SR or the Bases should make it 3.4.11.3 clear what components have to undergo functional testing.

3.4.11-2 A16 CTS CTS 3.1.1.5.a requires specific actions 3.1.1.5.a be taken when one or both PORVs are inop erable "because of [leakage through the PORV resulting in excessive RCS leakage ITS 3.4.11 does not include an ACTION Condition of excessive leakage through the PORVs. A-16 explains that Action A of ITS LCO covers this situation requir ing the block valve to be closed within an hour. However, this is inconsistent with LCO 3.4.13 Action A which allows four hours for reducing all other RCS LEAKAGE besides pressure boundary leak age.

3.4.11-3 A17 CTS CTS 3.1.1.5.a.2 does not allow separate Provide discus 3.1.1.5.

Condition entry for each inoperable PORV.

sion and justifi a.2 cation for this ITS 3.4.11 includes ACTIONS Note 1. "Sep-Less Restrictive arate Condition entry is allowed for each change.

PORV."

While consistent with the STS, this represents a Less Restrictive change, rather than an Administrative change.

• a HBR ITS 3.4.11. PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs)

DOC.

CTS/STS Description of Issue Date...Date COMMENTS or LCO Opened Closed 3.4.11-4 M22 CTS CTS 3.1.1.5 Footnote 2, permits power Provide discus 3.1.1.5 operation to continue under certain con-sion and justifi Footnote ditions with a PORV block valve closed cation for the1 2

and power maintained to the block valve.

Administrative change.

ITS 3.4.11 Required Action A.1 permits power operation to continue with a PORV block valve closed and power maintained to the block valve.

This retains the CTS requirement, and is therefore an Administrative change and not a More Restrictive change.

3.4.11-5 None ITS SR Since functional test is not a defined 3.4.11.3 term, the Bases should explain what cons and Bases titues an adequate functional test.

3.4.11-6 LA4 CTS CTS 4.2.4.1.a and CTS 4.2.4.3 requires Identify the spe 4.2.4.1.a performance of a PORV CHANNEL CALIBRATION cific licensee and and isolation of normal air and nitrogen controlled docu CTS supplies to the PORV accumulators when ments.

4.2.4.3 conducting the 18 month accumulator test, respectively.

This detail is not retained in the ITS and is relocated to licensee controlled documents.

The specific licensee controlled docu ments are not identified.

HBR ITS 3.4.11, PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) 00C CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.11-7 NONE STS SR STS SR 3.4.11.2 Frequency has been Provide justifi 3.4.11.2 changed from "[18] months" to "prior to cation for the entering MODE 2 from MODE 3 if not per-STS deviation formed in the previous 18. months."

based on current licensing basis.

There is no discussion or justification system design, or for the Frequency change.

operational con straints.

3.4.11-8 None ITS 3.4-Explain 1) what is meant by the statement

.11 Bases "not safety related" components and 2) if

-Appli-SG tube rupture has to be considered.

cable Safety Analysis

HBR ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.12-1 JD15 STS STS 3.4.12.a and b are incorporated into Given that the 3.4.12 ITS 3.4.12 LCO a. Additional require-HBR LTOP assump ments are added as ITS 3.4.12.b,..c.

tions different and.d which address accumulator isola-than the STS.

tion, safety injection (SI). charging, there are sub and reactor coolant pumps capabilities stantial devia and operation when all cold leg tempera-tions from the tures are ; 1750F, and SI pump capabili-standard. Detail ties when any cold leg temperature is how specifically 1750F.

how the assump tions in JD-15 There is no discussion or justification justify each de for the S15 deviation, viation from the TaS heSS 3.4.12-2 JD15

STS, STS 3.4.12 Applicability is MODE 4 when 3.4.12 all RCS cold leg temperatures area Aplica

[27510F...

bi 1ity ITS.3.4.12 Applicability for MODE 4 does not include the [275s0F cold leg tempera-d ture provision.

There is no discussion or justificatione for the STS deviation.

HBR ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM DOC CTS/STS Description of Issue Date Date COMMENT or LCO Opened Closed JFD 3.4.12-3 JD15 STS STS 3.4.12 ACTIONS A and B have been 3.4.12 changed in ITS 3.4.12 ACTIONS to include ACTIONS A a cold leg temperature requirement in

& B ITS 3.4.12 ACTION A. a new ITS 3.4.12 ACTION B, an additional Condition C requiring one SI pump capable of inject ing into the RCS, and a new ITS 3.4.12 ACTION D.

There is no discussion or justification for the STS deviation.

3.4.12-4 JD15 STS SR STS SR 3.4.12.1. and STS SR 3.4.12.2 3.4.12.1.

have been changed to include a Note.in and SR ITS SR 3.4.12.1 that this surveillance 3.4.12.2 is only required to be met when all RCS cold leg temperatures a 1750F, and to include a Note in ITS SR 3.4.12.2 that this is only required to be met when one SI pump is capable of injecting into the RCS.

There is no discussion or justification for the STS deviation.

HBR ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.12-5 None ITS 3.4-TS 3.4.12 Applicablity is Mode 6 with

.12 the head on. The first and last sen tences of the first paragraph of the Bases also support this position as do SR 3.4.12.8 and Action H.1. However, in the Bases for LCO 3.4.10 Applicability it is Mode 6 when the head is detension ed and not necessarily removed. Which is correct?

3.4.12-6 None ITS SR As stated, the NOTE is only required to 3.4.12.6 be met when complying with LCO 3.4.12 b.

and Bases Shouldn't that be LCO 3.4.12.a.2?

3.4.12-7 NONE CTS CTS 4.2.5.1.a requires performance of an If the difference 4.2.5.1.a ANALOG CHANNEL OPERATIONAL TEST (ACOT),

is explained in the Definitions ITS SR 3.4.12.8 requires performance of section that can a COT (CHANNEL OPERATIONAL TEST).

be referenced.

There is no discussion or justification addressing the difference, or equivalen cy, between an ACOT and a COT.

3.4.12-8 NONE ITS LCO The Applicability indicates that the RCS 3.4.12 temperature of concern is loop Tc. Why doesn't the graph reflect that?

3.4.12-9 None ITS 3.4.-

In the BACKGROUND section under RCS Vent 12 Bases Requirements. The second paragraph appears to offer three specific options for setting up an acceptable vent path.

However, as written it implies those are the only acceptable options. Is that the intent?

HBR ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.12-10 LAB CTS CTS Table 4.1-3. Item 14 requires test-Identify the spe Table ing the filters associated with the RHR cific licensee 4.1.3 compartment fans.

controlled docu Item 14 ments.

This detail is not retained in ITS 3.4.12 and is relocated to licensee con trolled documents.

The specific licensee controlled docu ments are not identified.

HBR ITS 3.4.13 RCS OPERATIONAL LEAKAGE DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.13-1 M27 CTS CTS 3.1.5.3 addresses primary to second-Provide discus L10 3.1.5.3 ary steam generator leakage in excess of sion and justifi 0.35 gpm per steam generator "or" 1 gpm cation for the total primary to secondary steam genera-Less Restrictive tor leakage through all steam generators.

change.

ITS 3.4.13.d only addresses 1 gpm total primary to secondary steam generator eakage through all steam generators.

The CTS requirement of 50.35 gpm leakage through any one steam generator is not retained.

This constitutes a Less Restrictive change because under the ITS more than

.35 gpm is allowed to come from a single steam generator. There is no discussion or justification.

HBR ITS 3.4.13 RCS OPERATIONAL LEAKAGE DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.13-2 L11 CTS CTS Table 4.1-3. Item 9 requires RCS

-L-11 does not Table leakage evaluated "daily" when the RCS is explain any bene 4.1.3 above the cold shutdown condition.

fit to waiting Item 9 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ITS SR 3.4.13.1.requires performance of after steady an RCS water inventory balance Once with-state is in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reaching steady state achieved.

operation conditions and every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter during steady state operation.

This represents-an extension to a CTS Surveillance Test Interval (STI).

HBR ITS 3.4.14 RCS PRESSURE ISOLATION VALVES (PIVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed 3.4.14-1 A25 CTS CTS 3.1.5.3.a requires that pressure Provide discus A26 3.1.5.3.a isolation valves (PIVs) listed in CTS sion and justifi Table 3.1-1 function as PIVs.

cation for the Less Restrictive ITS 3.4.14 Applicability excludes those change.

PIVs in the RHR flow path when in, or during the transition to or from, the RHR mode of operation.

This change relaxes the CTS require ments, and is therefore a Less Restric tive change rather than an Administra tive Change.

3.4.14-2 LA5 CTS CTS 3.1.5.4.a. 3.1.5.4.b. Table 3.1-1, Identify the spe 3.1.5.4 and Table 4.1-3 Item 17 and Footnotes a.

cific licensee

.a.

b. c. provide a listing of PIVs and pro-controlled docu 3.1.5.4.-

grammatic guidance related to PIV leak-ments.

b.

-age testing.

Table 3.1-1, This detail is not retained in ITS and Table 3.4.14 and is relocated to licensee con 4.1-3 trolled documents.

(Item 17 and Foot The specific licensee controlled docu notes a, ments are not identified.

b.

c)

.0' HBR ITS 3.4.14 RCS PRESSURE ISOLATION VALVES (PIVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.14-3 LA5 CTS CTS 3.1.5.4.b requires manual valves Provide discus 3.1.5.4.b locked in the closed position.

sion and justifi cation for the This requirement is not retained in ITS Less Restrictive 3.4.14.

.change.

There is no discussion or justification for this Less Restrictive change.

3.4.14-4 L12 CTS CTS 3.1.5.4.b requires that, with leak-Provide discus 3.1.5.4.b age from any pressure isolation valve sion and justifi (PIV) not within limits, operation may cation for the continue provided at least two valves More Restrictive are in, and remain in, the mode corre-change.

sponding to the isolated condition.

(There is no time specified.)

ITS 3.4.14 requires initial isolation of the high pressure line by a single valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and by a second valve within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The requirement for 1 valve isolation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is a Less Restrictive change, but the second valve within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is a More Restrictive change be cause a time limit has been placed on the requirement.

HBR ITS 3.4.14 RCS PRESSURE ISOLATION VALVES (PIVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.14-5 NONE GTS CTS Table 4.1-3 Item 17 requires peri-Provide discus Table odic leakage testing on each valve in sion and justifi 4.1-3 Table 3.1-1 accomplished prior to enter-cation for this Item 17 ing reactor operation condition after change.

every time the plant is placed in the cold shutdown condition for refueling.

ITS SR 3.4.14.1 Frequency requires this periodic leakage testing in accordance with the Inservice Testing Program.

There is no discussion or justification for.this change.

3.4.14-6 L13 CTS CTS TABLE 4.1-3 Item 17, requires that Provide adequate A26 TABLE PIV leakage be verified prior to enter-justification for 4.1-3 ing reactor operation condition whenever the Less Restric Item 17 the unit has been in cold shutdown for tive change.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

ITS 3.4.14 requires that PIV leakage be verified whenever the unit has been in MODE 5 for 7 days or more.

The L-13 discussion and justification would apply equally as well to extending from 3 days to 18 months as it would from 3 days to seven day, the issue here is why is seven days not a problem as compared to three days.

HBR ITS 3.4.14 RCS PRESSURE ISOLATION VALVES (PIVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.14-7 NONE STS SR STS SR 3.4.14.1 FREQUENCY requires the Provide justifi 3.4.14.1 RCS PIVs leak tested every 18 months.

cation for the STS deviation ITS SR 3.4.14.1 FREQUENCY requires the based on the cur RCS PIVs leak tested in accordance with rent licensing the Inservice Testing Program.

basis. system design, or opera There is no discussion or justification tional constrain for this S1S deviation.

ts.

3.4.14-8 NONE CTS CTS Table 3.1-1. Footnote 1 states leak-Provide discus Table age rates less than or equal to 1.0 gpm sion and justifi 3.1-1 are considered acceptable.

cation for the Footnote Less Restrictive 1

ITS SR 3.4.14.1 indicates RCS Ply leak-change.

age of less than or equal to an equiva lent of 5 gpm at an RCS pressure a 2235 psig is acceptable.

There is no discussion or justification for this Less Restrictive change.

HBR ITS 3.4.14 RCS PRESSURE ISOLATION VALVES (PIVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.14-9 JD26 STS SR STS SR 3.4.14.1 requires leakage from Provide justifi 3.4.14.1 each RCS PIV is equivalent to 50.5 gpm cation for the per nominal inch of valve size.

STS deviation based on the cur ITS SR 3.4.14.1 requires RCS PIV leakage rent licensing is less than or equal to an equivalent basis, system of 5 gpm at an RCS pressure a 2235 psig.

design. or opera tional The discussion and justification state constraints.

this change is consistent with the cur rent licensing basis, but no further detail is provided, and this limit is not included in the CTS.

HBR ITS 3.4.15 RCS LEAKAGE DETECTION INSTRUMENTATION DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD NO COMMENT 1

HBR ITS 3.4.16 RCS SPECIFIC ACTIVITY DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.16-1 LA6 CTS CTS Table 4.1-2, Items 1 and 2 and Notes 1/6/97 Identify the spe Table 1 and 2 are moved to "licensee controlled cific licensee 4.1-2 documents."

controlled docu ments.

Items 1 & The specific licensee controlled docu

2.

ments are not identified.

Notes 1 &

2 3.4.16-2 R1 CTS CTS Table 4.1-2, Item 1. "Oxygen and 1/6/97 Identify the spe Table chloride concentration in the RCS." is cific licensee 4.1-2 moved to "licensee controlled documents."

controlled docu Item 1 ments.

The specific licensee controlled docu ments are not identified.

3.4.16-3 LA7 CTS CTS Table 4.1-2. Item 4. "Boric Acid Tank 1/6/97 Identify the spe Table boron concentration," is moved to "li-cific licensee 4.1-2 censee controlled documents."

controlled docu Item 4 ments.

The specific licensee controlled docu ments are not identified.

HBR ITS 3.4.16 RCS SPECIFIC ACTIVITY DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFO 3.4.16-4 A24 CTS CTS Table 4.1-2. Item 9, "Stack Gas lo-1/7/97 Provide discus Table dine & Particulate Sample." is moved to sion and justifi 4.1-2 CTS Table 4.10-2.

cation for the Item 9 Less Restrictive CTS Table 4.10-2 is a "Relocated Specifi-change.

cation."

The discussion and justification indicate that this is a duplicate sampling re quirement, when in fact the requirement is removed from the ITS constituting a Less Restrictive Change.

3.4.16-5 A23 CTS CTS Table 4.1-2 Note 3 is not retained in 1/1/91 Provide discus Table ITS 3.4.16.

sion and-justifi 4.1-2 cation for the Note 3 How does DOC A23 apply?

Less Restrictive change.

HBR ITS 3.4.16 RCS SPECIFIC ACTIVITY DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.4.16-6 A27 CTS CTS Table 4.1-2 Note 6 requires a sample 2/19/97 This extension to Table taken after a minimum of 2 EFPD and 20 the CTS Surveil 4.1-2 days of power operation have elapsed lance Test Inter Note 6 since the reactor was last subcritical val is outside for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or longer.

the INEL scope of review.

ITS SR 3.4.16.3 Note, does not require sampling until 31 days after a minimum of Note: Consistent 2 effective full power days and 20 days with the STS.

of MODE 1 operation have elapsed since the reactor was last subcritical for a 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

This is an extension of a CTS Surveil lance Test Interval.

H. B. ROBINSON ITS 3.6.1 CONTAINMENT Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.1-1 A 3 CTS 4.4.4.1 CTS 4.4.4.1 and 4.4.4.2 12/21/96 Provide CTS pages 4.4-5 CTS 4.4.4.2 Require performance of through 4.4-12 ITS SR specified containment tendon appropriately marked-up 3.6.1.2 surveillances and structural and any additional test, respectively.

ITS SR justifications need to 3.6.1.2 requires verification support this change.

of containment structural integrity in accordance with the Containment Tendon Surveillance Program. The mark-ups of CTS 4.4.4.1 and 4.4.4.2 (CTS page 4.4-5 through 4.4-12) are not provided. Thus a determination of whether the addition of ITS SR 3.6.1.2 is an administrative, more restrictive, or less restrictive change cannot be made.

1

H.-B. ROBINSON ITS 3.6.1 CONTAINMENT Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.1-2 A 4 CTS 4.4.2.b CTS 4.4.2.b requires leak 12/21/46 This item to be resolved testing of containment as part of the resolution isolation valves pressurized of Item Number 3.6.1.-7.

by the Penetration Pressurization System in.

accordance with the Containment Leakage Rate Testing Program. ITS SR 3.6.1.1 requires performance of containment visual examination and leakage rate testing in accordance with the Containment Leakage Rate Testing Program. The requirement for leak testing isolation valves pressurized by the Penetration Pressurization System is not retained in the ITS. See Item No. 3.6.1-7. Robinson is only authorized to use Appendix J Option B for Type A tests. Type B and C tests which this surveillance addresses must stay in the ITS.

2

H. B. ROBINSON ITS 3.6.1 CONTAINMENT Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.1-3 A-22 CTS 1.7.b CTS 1.7.b requires the 12/21/96 Provide additional equipment hatch to be closed discussion and and sealed. The licensee justification for this states that this requirement less restrictive change.

is not retained in the ITS, since it is encompassed within the definition of OPERABLE for the containment.

This is true; however, the definition of Containment OPERABILITY has been relocated to the Bases Section B 3.6.1 "Background Section."

This change is a less restrictive (LA) -change.

3.6.1-4 A-22 CTS 1.7.e CTS 1.7.e requires the 12/21/96 Justification needs to be SR 3.6.1.1 containment uncontrolled corrected to reflect this leakage.satisfy specified aspect.

leakage limits. The licensee states that this requirement is not retained in the ITS, since it is encompassed within the definition of OPERABLE for the containment.

This justification is in error.

ITS SR 3.6.1.1 specifies the leakage limits for containment. Therefore, CTS 1.7.e is encompassed by this SR and is retained in

-the ITS.

3

H. B. ROBINSON ITS 3.6.1 CONTAINMENT Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.1-5 L-13 CTS 3.6.1 A condition which permits the 12/21/96 Delete new ACTION A and JFD 3 LCO 3.6.1, containment to be inoperable associated Bases. Delete Bases ACTION A for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.due to or revise justification L JFD 26 inoperable containment 13 as necessary.

isolation valves is added to Condition A to ITS 3.6.1.

The licensee states that this condition is necessary to establish consistency with the four hours permitted for an inoperable containment isolation valve. This ACTION statement is unnecessary and generic.

ITS 3.6.3 specifies the action to be taken for inoperable containment isolation valves and ACTIONS Note 4 refers to ITS 3.6.1 ACTIONS only in the event that the inoperable valve results in containment leakage being exceeding.

3.6.1-6 R I CTS 3.3.5 CTS 3.3.5 precludes reactor 12/21/96 Provide additional criticality unless the Post discussion stating where Accident Containment Venting the CTS requirement is System valves are OPERABLE.

relocated and how the This requirement is not requirement is maintained retained in the ITS. The and controlled.

discussion of the relocation does not identify to what licensee controlled document the requirement is relocated.

4

e0 H. B. ROBINSON ITS 3.6.1 CONTAINMENT Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.1-7 JFD 1 STS The STS requires the visual 12/21/96 Licensee to update Bases SR 3.6.6.1 examinations and leakage rate submittal with regards to JFD 4 testing be performed in the 11/2/95 letter and accordance with 10 CFR 50, updated TSTF 52 when OG Appendix J as modified by provides revision to approved exemptions. The ITS account for partial modifies this requirement to implementation of Option B "in accordance with the or provide additional Containment Leakage Rate justification for Testing Program." A staff SE deviations.

issued 5/28/96 converts the CTS from 10 CFR 50 Appendix J Option A to 10 CFR 50 Appendix J, Option B for Type A tests only. Changes to the STS with regard to Option A versus Option B are covered by a letter from Christopher Grimes to Mr. David J.

Modeen, NEI dated 11/2/95 and TSTF 52. The ITS is not in conformance with the letter or TSTF 52 as supplemented by staff comments, particularly when only a portion of Option B is being implemented.

5

0 H. B. ROBINSON ITS 3.6.2 CONTAINMENT AIR LOCK Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.2-1 A 5 CTS 1.7.c CTS 1.7.c requires at least 12/21/96 Provide additional CTS 3.6.2 one door in the personnel air discussion and lock is properly closed and justification for this sealed. The licensee states less restrictive change.

that the ITS provides a separate specification for air locks. This is true; however, CTS 1.7 has been relocated to the Bases Section B3.6.1 "Background".

This change is a less restrictive (LA) change.

3.6.2-2 A 6 CTS 3.0 The justification contains 12/21/96 The errors and some errors or discrepancies.

discrepancies should be Reference is made to Note 2 corrected.

in the first paragraph, and states that it provides permission for entry and exit to containment. Note 2 does not allow this. Note 1 does.

Also, no mention in the justification is made that the second door in the air lock provides for leak tightness in the event of an inoperable door.

6

H. B. ROBINSON ITS 3.6.2 CONTAINMENT AIR LOCK Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.2-3 A 7 CTS 4.4.1 CTS 4.4.1 requires the 12/21/96 This item to be resolved JFD 1 ITS SR personnel air lock leak rate as part of the resolution Bases 3.6.2.1 test every six months. ITS of Item Number 3.6.1-7.

JFD 4 SR 3.6.2.1 requires air lock leak rate testing in.

accordance with the Containment Leakage Rate Test Program. See Item Number 3.6.1.-7.

3.6.2-4 JFD 15 STS STS SR 3.6.2.2 requires 12/21/96 Licensee to update Bases SR 3.6.2.2 verifying only one door in submittal to be in JFD 20 the air lock will open at a accordance with TSTF 17 or time at six month intervals.

provide additional The interval is modified in justification for the the ITS from 6 months to 24 deviations.

months. This modification is in accordance with TSTF 17; however, the Bases changes are not in accordance with accordancewithTSTFrTSTF

17.

7

00 H. B. ROBINSON ITS 3.3.3 CONTAINMENT ISOLATION VALVES Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.3-1 A 8 CTS 1.7.d CTS 1.7.d requires all 12/21/96 Provide additional automatic containment discussion and isolation valves..." are justification for this OPERABLE or are secured less restrictive change.

closed except as stated in Specification 3.6.3".

ITS 3.6.3 requires all containment isolation valves be OPERABLE. The justification states that the isolation valves are included in CTS definition 1.7. The ITS provides a separate specification for isolation valves. Therefore, this change involves an ITS presentation change only, and is administrative. This is not entirely correct. CTS 1.7.d is relocated to the Bases for LCO 3.6.1.

Therefore, the change is a less restrictive (LA) change.

8

H. B. ROBINSON ITS 3.3.3 CONTAINMENT ISOLATION VALVES Item No.

DOC/JFD CTS/STS Description of Date Date Comments

_LCO Issue Opened Closed 3.6.3-2 LA3 CTS 1.7.d CTS 1.7.d requires manual 12/21/96 Provide additional valves qualifying as discussion stating all the automatic isolation valves be documents to where the secured closed. This requirement is relocated requirement is moved to and how the requirement is licensee controlled controlled.

documents. However, the discussion does not identify to what controlled document the requirement it relocated.

In addition, CTS 1.7 is also relocated to the Bases.

9

• 0 H. B. ROBINSON ITS 3.3.3 CONTAINMENT ISOLATION VALVES Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.3-3 L 2 CTS None No comparable CTS requirement 12/21/96 Provide discussion and exists for ITS 3.6.3 ACTION justification for the less Note I which permits an restrictive change.

inoperable penetration flow path be unisolated intermittently under administrative control.

The less restrictive justification states "Permitting an INOPERABLE penetration to be unisolated intermittently... may be required to prevent a unit shutdown."

The ACTION Note does not allow a flowpath unisolated intermittently in order to relax the Required Actions associated with a Condition resulting from a system made INOPERABLE by a closed containment isolation valve. The discussion does not state why or how the Note is applied such that a shutdown is averted. There is inadequate justification for this Less Restrictive change.

10

0 H. B. ROBINSON ITS 3.3.3 CONTAINMENT ISOLATION VALVES Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.3-4 LA 4 CTS 3.6.4.3 CTS 3.6.4.3 requires the 42 12/21/96 Provide additional inch purge supply and exhaust discussion specifying the valves tested prior to use if controlled document to not tested within the which this requirement is previous quarter.

relocated and how this Additionally, CTS 3.6.4.3 document is controlled.

specifies that the 42 inch valves are not to be cycled quarterly only for testing.

This requirement is relocated to controlled documents, however, the justification does not specify which controlled document.

3.6.3-5 JFD 5 ITS 3.6.3.1 A Note has been added to ITS 12/21/96 Provide the corresponding Bases SR 3.6.3.1 which states that ACTION and appropriate JFD 20 the 42 inch and 6 inch valves justification.

may not be open simultaneously. There should be a corresponding ACTION Statement to reflect this condition.

3.6.3-6 JFD 17 ITS SR Changes are made to ITS SR 12/21/96 Change the SR and Base 3.6.3.4 3.6.3.4 and associated Bases associated bases to JFD 20 as a result of TSTF 46. The conform to the approved changes are not in accordance TSTF 46 or provide with TSTF 46.

justification for the deviations.

11

0.

H. B. ROBINSON ITS 3.3.3 CONTAINMENT ISOLATION VALVES Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.3-7 JFD 24 STS SR STS SR 3.6.3.10 requires each 12/21/96 Modify ITS, associated 3.6.3.10 containment purge valve Bases, and justification verified blocked to restrict to retain this SR.

the valve from opening greater than 50%. This requirement is not included in the ITS. The justification for removal of this requirement states the purge valves have been modified to restrict movement to 70 degrees. This is not adequate justification for removing this SR, since changes made to ACTION Note 1 (deletion of purge valves) and to the Bases provide the justification for the retention of this SR.

3.6.3-8 Bases Bases LCO The licensee has 12/21/96 Return paragraph wording JFD 19 substantially modified the to STS wording or provide paragraph on normally closed adequate justification and isolation valves, to allow ITS wording to correct normally closed automatic this major deviation.

valves to be open if capable of closing automatically within the required time.

This statement violates Action Note

1.

12

H. B. ROBINSON ITS 3.3.3 CONTAINMENT ISOLATION VALVES Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.3-9 Bases RA B.1 The licensee modified* the 12/21/96 Delete statement.

JFD 22 Bases discussion for RA B.1 to state that check valves are not used to isolate penetrations. Require Action B.1 is the default condition for Condition A when both valves in a penetration are inoperable.. Condition A allows check valve isolation with flow secured.

Therefore, statement not needed.

3.6.3-10 Bases RA B.1 The licensee provided 12/21/96 Delete the additional JFD 23 RA C.1 clarifying words for the words and reinstate the verification of isolation STS words.

valve closure. A closed valve is considered operable from the perspective of containment isolation/integrity.

Therefore, the clarifying words are unnecessary.

13

e@1 H. B. ROBINSON ITS 3.3.3 CONTAINMENT ISOLATION VALVES Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.3-11 Bases Bases RA The licensee added words to 12/21/96 Provide the appropriate JFD 24 C.1 RA C.1 and C.2 for isolation justifications for these and C.2 devises outside containment changes.

and justification for the Completion Time of Prior to entering Mode 4 from 5 and 92 days. JFD 24 does not have anything to do with this specification 3.6.3. It refers to specification 3.6.6.

3.6.3 None Bases RA The licensee modified LCO RA 12/21/96 Modify the Bases in C.1 C.1 and C.2 Completion Time accordance with TSTF 30 and C.2, in accordance with TSTF 30.

and provide adequate and The Bases has not been justification.

References modified in accordance with TSTF 30.

3.6.3-13 None Base SR Changes are made to LCO SR 12/21/96 Make the appropriate 3.6.3.1 3.6.3.2 and SR 3.6.3.3 as a changes in accordance with and SR result of TSTF 45. The the TSTF 45 or provide 3.6.3.2 corresponding changes have justification for the not been made in the Bases deviation.

section in accordance with TSTF

45.

14

0 H. B. ROBINSON ITS 3.6.4 CONTAINMENT PRESSURE Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.4-1 M 22 CTS 3.6.2 STS 3.6.4 requires 12/21/96 Provide adequate STS 3.6.4 containment pressure justification for the more maintained between [-0.3 and restrictive change.

+L.5 psig].

CTS 3.6.2 Provide justification for requires containment pressure the STS deviation based on maintained between +1.0 psig current licensing basis, and -1.0 psig.

ITS 3.6.4 system design, or changes both of these operation constraints.

requirements specifying Containment Pressure shall be maintained between -0.8 and

+1.0. There is inadequate justification for the changed CTS requirement, which also is an STS deviation for which there is no discussion or justification.

3.6.4-2 None Bases RA The licensee makes a change 12/21/96 Delete change.

A.1 that refers back to LCO 3.6.1 Action B.1.

The change in LCO 3.6.1 which necessitates this change is disapproved.

See Item No. 3.6.1-5 15

H. B. ROBINSON ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.6-1 M 19 CTS 3.0 No comparable CTS 12/21/96 Provide discussion and requirements exist for ITS justification for this 3.6.6 Condition F which administrative change.

requires entry into ITS 3.0.3 if two containment spray trains or any combination of 3 trains or more are INOPERABLE. Thus, CTS 3.0 applies which requires the plant be in Hot Shutdown in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and Cold Shutdown in an additional 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> total).

ITS 3.0.3 allows the operator 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to take ACTION and then requires the plant be in Cold Shutdown within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> (38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> total). This requirement is an administrative change rather than a more restrictive change.

16

H. B. ROBINSON ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.6-2 LA 2 CTS 4.5.1.3 CTS 4.5.1.3 requires 12/21/96 Provide additional Containment Spray tests discussion stating what performed with the isolation plant controlled document valves in the spray supply these requirements are lines and spray additive moved to and how this tanks blocked closed. The document is controlled.

details regarding testing of the Containment Spray System are not retained in the ITS.

The justification does not state the plant controlled document these requirements

___________have been moved to.

3.6.6-3 Bases Applicable The licensee modified the 12/21/96 Return to STS wording or JFD 39 Safety discussion on total response provide adequate Analysis time for containment spray justification to show this based on the assumption that is not true for Robinson.

times given in the Bases are actual system response times.

The Bases (STS) statements are actually the analytical or assumed times. Thus, the STS statement is correct.

17

H. B. ROBINSON ITS 3.3.6 CONTAINMENT SPRAY AND COOLING SYSTEMS Item No.

DOC/JFD CTS/STS Description of Date Date Comments

_LCO Issue Opened Closed 3.6.6-4 Bases Applicable The licensee deleted the 12/21/96 Return wording to STS JFD 40 Safety words "...required to perform wording.

Analysis the accident analyses" in the sentence on containment cooling system capacity on the basis of clarifying the statement. The change does provide added clarification, but deletes important information.

18

H. B. ROBINSON ITS 3.6.7 SPRAY ADDITIVE SYSTEM Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.7-1 A20 CTS 4.5.2.2 CTS 4.5.2.2 verifies the 12/21/96 Provide adequate position of the Containment justification to justify Spray and Cooling Systems and this more restrictive Spray Additive System valves.

change.

The licensee has deleted the words "...during power operation". The justification for the containment spray.and cooling system is classified as M33 while the same change.for the spray additive system is A20.

This change is more restrictive, not administrative.

19

H. B. ROBINSON ITS 3.6.7 SPRAY ADDITIVE SYSTEM Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.7-2 A27 CTS CTS Table 4.1.2 item 5 12/21/96 Provide the current 3.3.1.1.b requires sampling of the NaOH reference, appropriate concentration. The marked up pages and justification refers to CTS adequate justification to 3.3.1.1.b for the NaOH limit.

justify this CTS 3.3.1.1.b is not provided administrative change.

in the ITS 3.6 markup. It is provided in the ITS 3.5 markup, but CTS 3.3.1.1.b deals with accumulators not

,spray additive system.

3.6.7-3 M21.

CTS The licensee states that 12/21/96

'Provide additional 3.3.2.1.a including SR 3.6.7.2 is more justification to justify ITS SR restrictive than the CTS.

this less restrictive JFD.

3.6.7.a2 However, CTS 3.3.2.1.a is equivalent to ITS SR 3.6.7.2.

At most the addition is less restrictive based on ITS SR 3.6.7.2's surveillance frequency of 184 days. The CTS has no frequency specified; thus one can assume that the volume is checked at least once a shift.

3.6.7-4 LA2 CTS 4.5.1.3 See Item No. 3.6.6.-7 12/21/96 See Item No. 3.6.6.-7 20

H. B. ROBINSON ITS 3.6.7 SPRAY ADDITIVE SYSTEM Item No.

DOC/JFD CTS/STS Description of Date Date Comments

_LCO Issue Opened Closed 3.6.7-5 L 9 CTS The licensee has modified CTS 12/21/96 Delete requested change.

L 10 3.3.2.2.c 3.3.2.2.c and STS Condition A JFD 7 CTS 3.3.2 to state "Spray Additive Bases CTS 3.0 System inoperable AND at JFD 20 STS 3.6.7 least 100% of the Spray Associated Additive System flow Bases equivalent to a single OPERABLE Spray additive System train available to an OPERABLE containment spray train."

Condition B has been added to account for all other inoperable conditions.

This change is not reflected in the Robinson CTS. The Bases writeup reflects current WOG design.

Therefore, the change is deemed to be generic and beyond the scope of review for a conversion.

3.6.7-6 Bases Bases LCO The LCO description inserts 12/21/96 Correct this discrepancy None 8.5 for STS number [7.2] for or provide adequate spray solution pH. There is justification for the no JFD associated with this different numbers.

change. In addition, the 11.0 maximum pH has not been changed. Other sections of this Bases uses the maximum number of 10.0.

21

H. B. ROBINSON ITS 3.6.8 ISOLATION SEAL WATER SYSTEM Item No.

DOC/JFD CTS/STS Description of Date Date Comments LCO Issue Opened Closed 3.6.8-1 A25 CTS 4.4.2.c The licensee makes changes to 12/21/96 Provide a Justification M23 CTS 4.4.2.c to change the for the administrative surveillance from a change. Also, provide demonstration of sealing additional justification capability to performance of to show how the a leak test for the Isolation performance of a leakage Seal Water System. The test is more restrictive changes are labeled A25, and than the CIB leakage test.

M23. The DOCs state A25 is Also describe what is not used, and M23 stated the meant by "valves selected change is administrative by the IVSW system" in rather than more restrictive.

aM23.

22

HBR ITS 3.7.1 NAIN STEAN SAFETY VALVES (NSSVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.7.1-1 M2 CTS CTS 3.4.3 requires that, if the require-The Bases appear 3.4.3 ment of the secondary steam system (12 to provide the main steam safety valves OPERABLE) cannot discussion that be met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the operator is missing.

initiate procedures to place the unit in the hot shutdown condition, and if the requirement cannot be met in an addition al 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor be cooled to below 350aF.

ITS 3.7.1 requires that, if the main steam safety valve requirements cannot be met in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the unit be placed in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

There is inadequate discussion and justi fication for this More Restrictive change.

3.7.1-2 A28 CTS CTS TABLE 4.1-3 Item 4 requires that each TABLE MSSV setpoint be verified in accordance 4.1-3 with the Inservice Testing Program (IST).

Item 4 ITS SR 3.7.1.1 NOTE requires that this setpoint be verified in MODES 1 and 2 in accordance with the IST.

How does A-28 explain the ITS SR 3.7.1.1 j

NOTE?

HBR ITS 3.7.1 NAIN STEAN SAFETY VALVES (NSSVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.7.1-3 LAl CTS CTS TABLE 4.1-3 Item 12 requires perfor-Identify the spe TABLE mance of a closure check on the turbine cific licensee 4.1-3 steam stop, control reheat stop, and controlled docu Item 12 interceptor valves. This requirement is ment.

moved to "licensee controlled documents."

The specific licensee controlled document is not identified.

3.7.1-4 JD2 STS In STS Table 3.7.1-1, "OPERABLE MSSV Ver-Provide Justifi Table sus Applicable Power in percent of RTP,"

cation for the 3.7.1-1 applicable power levels are indicated as STS deviation 100, 80, 60, and 40.

based on the cur rent licensing In ITS Table 3.7.1-1, "OPERABLE MSSV Ver-basis, system sus Applicable Power in percent of RTP,"

design, or-opera applicable power levels are indicated as tional con 100, 15, and 50.

straints.

The discussion and Justification for the STS deviation do not adequately address the current licensing basis, system de sign, or operational constraints which would necessitate using different appli cable power levels.

HBR ITS 3.7.1 NAIN STEAN SAFETY VALVES (NSSVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed 3.7.1-5 M3 CTS 3.4.3 CTS 3.4.3 requires the operator initiate Provide addition procedures to place the unit in the hot al discussion and shutdown condition.

Justification for the More Restric ITS 3.7.1 Condition B requires the unit tive change.

placed in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Why are the more definitive action times appropriate.

HBR ITS 3.7.2 NAIN STEAN ISOLATION VALVES (NSIVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed

_JFD 3.7.2-1 M4 CTS CTS 3.4.3 requires that if during power Even if overall 3.4.3 operation the requirements of CTS 3.4.1 the change is (MSIVs OPERABLE) cannot be met within 24 determined to be hours, the operator initiate procedures more restrictive, to place the unit in the hot shutdown the less restric condition.

tive components should be ad ITS 3.7.2 Action B requires that if Ac-dressed.

tion A, one MSIV inoperable in MODE 1, Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> cannot be met, the plant must be placed in MODE 2 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

This results in a Less Restrictive change (hot shutdown versus MODE 2) for which there is inadequate discussion and justi fication.

3.7.2-2 L4 CTS CTS 4.7.1 requires main steam stop valves Provide addition 4.7.1 tested at a frequency of each refueling al discussion and interval or 15 + 3 months, whichever justification for occurs first.

the STI extensio

n.

ITS 3.7.2 requires the valves tested at a Frequency in accordance with the Inservi ce Testing (IST) Program which is 18 months.

There is inadequate discussion and Justi fication for the extension of Surveil lance Test Interval (STI). After one testing cycle the interval could exceed the CTS requirements of 15 + 3 months.

HBR ITS 3.7.2 MAIN STEAM ISOLATION VALVES (NSIVs)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD....

3.7.2-3 NONE STS STS 3.7.2 ACTION C NOTE allows separate Provide discus ACTION C condition entry for each MSIV.

sion and justifi NOTE cation for the There is no discussion or justification Less Restrictive for this Less Restrictive change.

change.

3.7.2.-

NONE ITS SR The SR and its Bases are not consistent.

4 3.7.2.1 The SR is only performed in Modes I and

2.

The Bases says only in Mode 3.

HBR ITS 3.7.3 RAIN FEEDNATER ISOLATION VALVES (NFIVs), NAIN FEEDNATER REGULATION VALVES (NFRVs), AND BYPASS VALVES DOC CTS/STS Description of Issue.Date.

Date COMMENTS or LCO Opened Closed JFD NONE

HBR ITS 3.7.4 AUXILIARY FEEDWATER (AFW) SYSTEN DOC CTS/STS Description of Issue Date Dat COMENTS or LCO Opened Closed 3.7.4-1 NONE ITS 3.7.4 The discussion of the Applicability Bases states "in the event it is called upon to function when MFW is lost." That is not consistent with the Applicable Safety Analysis which discusses loss of MFW and the FWLB.

3.7.4-2 M7 CTS 3.4.5 CTS 3.4.5 requires at least one of two.

ITS Action B is inoperable AFW pumps restored to OPERABLE only addressed in status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

DOCs N 7-10 to say an ultimate ITS 3.7.4 Action B requires restoring 1 completion time motor driven AFW pump or flow path to is added. There operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 8 is no discussion days from discovery.

of the addition of the motor dri This represents a new requirement for yen pump only which there is no discussion or justifi-Action.

cation.

3.7.4-3 M10 CTS CTS 3.4.5 states that with 2 AFW pumps See comment above 3.4.5 inoperable one of the inoperable AFW pumpsDmust be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ITS 3.1.4 ACTION B states 2 motor driven AFW pumps inoperable and 3 motor driven AFW flow paths inoperable.

There is inadequate discussion and Justi fication for the change.

e HBR ITS 3.7.4 AUXILIARY FEEDWATER (AFW) SYSTEN DOC CTS/STS Description of Issue Date Date COMMENTS or LCO opened Closed JF:

3.7.4-4 M11 CTS CTS 4.8.1 and 4.8.2 require the AFW pumps Provide addition 4.8.1 (motor and steam driven) run for 15 min-al discussion and and utes to determine that.the pumps are justification for 4.8.2 OPERABLE.

the change.

ITS SR 3.7.4.2 requires the AFW pumps be run to verify the developed head is grea ter than or equal to the required devel oped head.

Deleting the 15 minutes makes the requir ement less restrictive. Explain why getting the head data is more important than running the pump for a set amount of time.

3.7.4-5 L7 CTS CTS 4.8.3 requires the AFW pump discharge 4.8.3 valves tested monthly.

ITS SR 3.7.4.3 requires these valves tested at 18 month intervals.

This represent an extension of Surveil lance Test Interval (STI). The discus sion needs to be improved. The L-7 Jus tification is even though it is no longer 18 months it is monthly on a staggered basis. However, that is still longer than the CTS monthly interval so it does not adequately justify the change.

HBR ITS 3.7.4 AUXILIARY FEEDWATER (AFN) SYSTEN DOC CTS/STS Description of Issue Date

'Date COMMENTS or LCO Opened Closed JFD 3

.7.4-6_

JFD STS 3.7.4-6 JFD STS STS 3.7.4 ACTIONS A which address steam 7

3.1,4 supply to AFW pumps has been replaced in ACTION ITS 3.7.4 ACTIONS A.

A As written JFD 7 implies that the steam driven AFW pump has one steam supply is that correct. If not, why isn't STS Action A adopted?

HBR ITS 3.7.5 CONDENSATE STORAGE TANK (CST)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD__

3.7.5-1 NONE ITS ITS 3.7.5 states the Condensate Storage 3.7.5 Tank (CST) level shall be >35,000 gal and the backup Service Water System (SWS) supply to the AFW system shall be OPERABLE.

ITS Action A.1 states that with CST not within limits verify by administrative means the OPERABILITY of backup water supply. Similarly, SR 3.7.5.2 requires verficatiby administrative means of the OPERABILITY of the backup SWS supply. 1)

The wording of Action A.1 needs to indi cate SWS as the backup means and 2)

Verifying OPERABILITY by administrative means has two meanings in the TS Bases.

In the Bases for for SR 3.7.5.2 it is a lineup check and in the Bases for 3.7.5 Actions A.1 and A.2 it is a lineup check and verification of adequate SW level.

Resolve the difference.

HBR ITS. 3.7.6 COMPONENT COOLING WATER (CCU) SYSTEN DOC CTS/STS Description of Issue Date Date CO9tENTS LCO opened Closed JFD NO COM MENTS

HBR ITS 3.7.7 SERVICE WATER SYSTEN (SMS)

DOC CTS/STS Description of Issue Date DatCOMENT or LCO Opened Closed JFD 3.7.7-1 M-23 ITS 3.7.-

ITS 3.7.7 requires two SWS trains and the 7.1 and Turbine Building loop isolation valves SR 3.7.-

operable.

7.2 However, the discussion and justification for the SR do not discuss why addition of only an electrical surveillance check on only one of the three turbine building isolation valves is adequate given the discussion of the isolation valves given in the BACKGROUND section of the 3.7.7 Bases.

3.7.7-2 JD16 STS STS 3.7.1 Required Action A.1, Note 2 3.7.7 addresses entering the applicable condi Required tion for RHR loops when SWS is inopera Action ble.

A.1 Note 2 This note is deleted in ITS 3.7.7 Re quired Action A.1.

The discussion and justification for this STS deviation do not adequately address the current licensing basis, system de sign, or operational constraints for the deletion of Note 2. Specifically, the JFD and the TS Bases indicate that the system normally operates cross-connected but that is not discussed in the CTS.

Where it is discussed in the FSAR or the plant accident analysis.

HBR ITS 3.7.8 ULTINATE HEAT SINK (UHS)

• DOC CTS/STS Description of Issue Date Date COWVENTS or LCO Opened Closed 3.7.8-1 JFD STS The JFD is used as the justification for Provide justifi 1

3.7.8 deletion of the Action and the SRs.

cation for the ACTION A However, the JFD justifies word prefer-STS deviation and STS ences etc. In this case the issue is based on the cur SR 3.7.8-whether certain equipment is part of the rent licensing

.3 and licensing basis.

basis, system 3.7.8.4 design, or opera tional con straints.

3.7.8-2 None ITS SR The SR says verify SW temp is less than 3.7.8.2 or equal to 95 degrees F. The Bases for the SR says it verifies average service water temperature. If an average is used then the Bases should explain that aver age.

3.7.8-3 None ITS LCO The Bases discuss UHS temperature while 3.7.8 the TS refer to SW temperature. Is there Bases a difference? If not, why is the wording not consistent?

HBR ITS 3.7.9 CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.7.9-1 NONE ITS SR SR 3.7.9.4 and its Bases state the accep 3.7.9.4 tance limit as 400 cfm as does the Back and 3.7.9 ground section of the 3.7.9 Bases. How Bases ever, in the LCO section of the Bases the limit is 400 scfm.

3.7.9-2 L14 CTS CTS 4.15.c, requires verifying the Con 4.15.c trol Room Air Conditioning System main tains a positive pressure in the control room when operating in the emergency pressurization mode. This must be per formed on a 31 day STAGGERED TEST BASIS.

ITS SR 3.7.9.4 requires verification of positive pressure in the control room under measured conditions at an 18 month Frequency on a STAGGERED TEST BASIS.

This change represents an extension to a CTS Surveillance Test Interval (STI) for which the discussion should justify whet her performance history supports going from every 62 days to every 36 months for each train.

3.7.9.3 None ITS 3.7.9 The LCO section of the Bases leaves out Bases the "or equivalent to any part of the body" correctly included in the Back ground section.

HBR ITS 3.7.9 CONTROL ROOM EMERGENCY FILTRATION SYSTEM (CREFS)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.7.9-4 JD18 STS ACTION F is added to ITS 3.7.9 which Provide justifi 3.7.9 requires the plant to be in MODE 3 in 6 cation for the hours and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, if Required STS deviation Action E.1 and the Completion Time of based on the cur Condition E are not met.

rent licensing basis, system JD18 addresses the 48 hrs of Condition E.

design, or opera However, there is no discussion of Condi-tional con tion F.

strai nts.

3.7.9-5 112 CSS CTS 3.15.2.b, requires suspending any Provide addition 3.b15.2.b operation which would reduce shutdown al discussion and margin to less than that required for Justification for cold shutdown or refueling, this Less Re strictive change.

This requirement is not retained in the ITS and it is unclear why given there is no explanation why it was included in the CTS.

There is inadequate discussion and Justi fication for the Less Restrictive change.

HBR ITS 3.7.10 CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL (CREATC)

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.7.10-1 L16 CTS CTS 3.15.1.a and 3.15.2.a. require re 3.15.1.a storing an inoperable train of the Con and trol Room Air Conditioning System to 3.15.2.a operable status within 7 days.

ITS 3.7.10 requires restoring the inoper able train to OPERABLE status within 30 days.

L16 discusses alternative safety and nonsafety cooling as part of the justifi cation, provide some specific discussion of those capabilities.

3.7.10-2 LA3 CTS CTS 4.15.a requires verification the 4.15.a Control Room air temperature is less than or equal to 85 degrees F at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This Surveillance Requirement is not re tained in ITS 3.7.10 and is moved to li censee controlled documents.

The specific licensee controlled document is not identified.

HBR ITS 3.7.11 FUEL BUILDING AIR CLEANUP SYSTEM (FBACS)

DOC CTS/STS Description of Issue Date Date COMENTS or LCO Opened Closed JFD 3.7.11-1 L19 CTS CTS 3.8.2.e requires "fuel handling oper-Provide-addition 3.8.2.e ations" terminated if the Spent Fuel al discussion and Building filter system is inoperable.

justification for the Less Restric ITS 3.7.11 Required Action A requires tive change.

"movement of irradiated fuel assemblies be suspended" if the Spent Fuel Building filter system is inoperable.

The discussion and justification state that fuel handling involves more than movement of irradiated fuel assemblies but fail to establish whether or not any of the activities being eliminated in the wording change are potnetially more lim iting to the FBACS than movement of irra-.

diated fuel assemblies

HBR ITS 3.7.12 FUEL STORAGE POOL WATER LEVEL DOC CTS/STS Description of Issue Date Date COMENTS or LCO Opened Closed JFD 3.7.12-1 NONE ITS 3.7-This specification is not in the CTS

.12 therefore it is not clear where the 21 foot limit comes. Provide the FSAR or accident analysis reference that supports F

I.

I that value.

HBR ITS 3.7.13 FUEL STORAGE POOL BORON CONCENTRATION DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.7.13-1 M35 CTS CTS 5.4.4 is modified in ITS 3.7.13 Re-The 5.4.4 quired Action A, which requires that fuel Bases appear to movement be suspended in the event spent contain the in fuel storage pool boron concentration is formation re not 1500 ppm.

quired.

There is inadequate discussion and justi fication for this More Restrictive change.

3.7-13-2 None ITS 3.7-Provide the basis for 1500 ppm boron as

.13 the limit.

3.7.13-3 M36 CTS CTS Table 4.1-2, Item 7, requires spent See comment #1 Table fuel pit boron concentration to be ana-above.

4.1.2 lyzed prior to refueling or new fuel Item 7 movement in the spent fuel pit.

ITS SR 3.7.13.1 requires fuel storage pool boron concentration analyzed at a Frequency of 7 days.

There is inadequate discussion and justi fication for this More Restrictive change.

The discussion states this is a new requirement, is more restrictive and has no adverse impact on safety.

HBR ITS 3.7.14 NEW AND SPENT FUEL ASSENBLY STORAGE DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.7.14-1 M37 CTS CTS 5.4.2.1 is modified to adopt ITS and 5.4.2.1 3.7.14 in its entirety. This adds new JFD and spent fuel storage requirements.

27 There is inadequate discussion and justi fication for these new requirements. The discussion states this is a new require ment, is more restrictive and has no adverse impact on safety. For example there is no discussion of why the STS and its Figure 3.7.17-1 are not adopted.

HBR ITS 3.7.15 SECONDARY SPECIFIC ACTIVITY DOC CTS/STS Description of Issue Date Date COMENTS or LCO Opened Closed JFD 3.7.15-1 118 CTS CTS Table 4.1-2, Item 8, requires analy-Provide discus Table sis for secondary specific activity at sion and Justifi 4.1.2 Frequencies of: 1) minimum I per 72 cation for the Item 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with 3 days maximum time between More Restrictive tests; 2) 1 per 31 days whenever the change.

gross activity determination indicates iodine concentrations are greater than 10% of the allowable limit; and 3) 1 per 6 months whenever the gross activity determination indicates iodine concentra tions are less than 10% of the allowable limit.

ITS SR 3.1.15.1 requires the equivalent analysis be performed at a Frequency of 31 days.

The discussion and Justification address the Less Restrictive change but do not address the More Restrictive change from 1 per 6 months to 31 days when less than 10 percent of allowable limit.