ML14183A798

Forwards Request for Addl Info Re TS Change Request to Convert to Improved Standard TS for Plant,Unit 2

ML14183A798
Person / Time
Site:	Robinson
Issue date:	05/22/1997
From:	Mozafari B NRC (Affiliation Not Assigned)
To:	Hinnant C CAROLINA POWER & LIGHT CO.
References
TAC-M96440, NUDOCS 9705290262
Download: ML14183A798 (44)

Text

A.

2 May 22, 1997 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 currentTechnical 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 as indicated in the enclosed tables related to sections 3.0, 3.1, 3.2, 3.5, and 3.9 under the heading "Comments." On February 24, 1997, tables with comments related to sections 3.4, 3.6, and 3.7 were sent to you, and you responded on March 27, 1997, and April 4, 1997.

Requests for additional information (RAI) were sent to you on March 28, and April 9, 1997, associated with sections 3.3, 3.8, and 5.0, and sections 1.0, 2.0, and 4.0, respectively.

To support the NRC staff's review schedule, your written response to this RAI 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 Division of Reactor Projects -

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

Enclosure:

As stated cc w/ enclosure:

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Distribution 0D6ket File C. Grimes M. Reinhart PUBLIC D. Clark C. Schulten OGC S. Varga J. Johnson, RII PD II-1 RF ACRS FILENAME -

G:\\ROBINSON\\ROB96440.RA5 OFFICE PM:PDII-A:PDII-1 PD:PDII-1 NAME BMoza Dunninqton MReinharto' DATE 97 5/ 1/97 5/2 797 COPY Ye o

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

Mr. William D. Johnson Mr. Mel Fry, Acting Director Vice President and Senior Counsel N.C. Department of Environment, Carolina Power & Light Company Health and Natural Resources Post Office Box 1551 Division of Radiation Protection Raleigh, North Carolina 27602 3825 Barrett Dr.

Raleigh, North Carolina 27609-7721 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 Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Mr. T. D. Walt Atlanta, Georgia 30303 Director Operations & Environmental Mr. Dale E. Young Support Department Plant General Manager Carolina Power & Light Company Carolina Power & Light Company 412 S. Wilmington Street H. B. Robinson Steam Electric Plant Raleigh, North Carolina 27601 Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Milton Shymlock U. S. Nuclear Regulatory Commission Public Service Commission Atlanta Federal Center State of South Carolina 61 Forsyth St., SW, Suite 23185 Post Office Drawer 11649 Atlanta, Georgia 30303 Columbia, South Carolina 29211 Mr. T. M. Wilkerson Manager -

Regulatory Affairs Mr. H. K. Chernoff Carolina Power & Light Company Supervisor, Licensing/Regulatory Programs H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Unit No. 2 Hartsville, South Carolina 29550-0790 3581 West Entrance Road Hartsville, South Carolina 29550

BBR ITS SECTIONS 3.0, 3.1, 3.2 ITEM #

DOC#

CTS/STS Description of Issue Date Date COKNTS or REF.

Opened Closed All Most of the more restrictive and Provide additional some of the less restrictive information to address discussions of changes and deficiencies.

justifications for differences do not provide a technical explanation for the change or deviation based on the licensing basis or plant operations.

BASES All Bases should be revised in accordance with changes made to the LCOs

HBR ITS 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ITE. #

DOC #

.TS/STS De.ciption of le.ue.Date Date COMMENTS or REF.

Opened Closed 3.0-1 A2 CTS 3.0 CTS 3.0 does not include a requirement 02/06/97

/

Provide justifi equivalent to STS 3.0.1, which provides cation for this clarity with regard to when LCOs shall more restrictive be met.

ITS 3.0.1 adopts this STS re-change.

quirement.

This enhancement constitutes a more re strictive change for which there is no justification, rather than an adminis trative change.

3.0-2 A3 CTS 3.0 CTS 3.0 does not include a requirement 02/06/97 Provide justifi equivalent to STS 3.0.2, which provides cation for this direction with regard to the Actions re-more restrictive quired to be taken upon discovery of a change.

failure to meet an LCO."

ITS 3.0.2 adopts this STS requirement This enhancement constitutes a more re strictive change for which there is no justification, rather than an adminis trative change.

A-il

HBR ITS 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ITEM #

DOC #

CTS/STS Description of Isaue Date Date COMMENTS or RF.

Opened Closed JFD #

3.0-3 A6 CTS 3.0 CTS 3.0 does not include a requirement 02/06/97 Provide justifi equivalent to STS 3.0.6, which provides cation for the direction related to the appropriate ac-more restrictive tions to be taken when inoperability of change.

a support system also results in the inoperability of one or more related supported system(s).

ITS 3.0.6 adopts STS 3.0.6 in its entirety.

This enhancement constitutes an unjusti fied more restrictive change rather than an administrative change.

3.0-4 A7 CTS 3.0 CTS 3.0 does not include a requirement 02/06/97 Provide justifi equivalent to ITS 3.0.7, which provides cation for this direction with regard to meeting Test more restrictive Exceptions LCOs in ITS 3.1.8, which al-change.

low certain Technical Specification re quirements to be changed (i.e., made applicable in part or whole, or suspend ed) to permit performance of special tests or required operations which oth erwise could not be performed.

This enhancement constitutes a more re strictive change for which there is no justification, rather than an adminis trative change.

A-12

HBR ITS 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ITEM i DOC I CTS/STS Description of IssueDate.Date COMMEN or REF.

Opened loe 3.0-5 A~b.

CTS 4.0 ITS SR 3.0.1 directs that failure to 02/06/97 Provide justifi meet a Surveillance shall be failure to cation for this meet the LCO. The CTS does not include more restrictive this direction.

change.

This enhancement to the technical speci fications constitutes a more restrictive change for which there is no justifica tion, rather than an administrative change.

3.0-6 A9 CTS 4.0 CTS 4.0 states, "specified intervals may 02/06/97 Provide justifi be adjusted plus or minus 25% to accom-cation for this modate normal test schedules.

This is more restrictive changed in ITS SR 3.0.2 to 1.25 times change.

the interval specified in the Frequency, and clearly directs from what point in time the interval is to be measured.

Because this clarifies the requirement, and adds the stipulation regarding from what point in time the interval is to be measured, this is an enhancement to the technical specifications and constitutes a more restrictive change for which there is no justification, rather than an administrative change.

A-13

HBR ITS 3.1.1 SHUTDOWN MARGIN (SDM)

ITEM i DOC#

CTS/STS Description of Issev Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.1-1 A3 CTS 4.9 CTS 4.9 requires submittal of a Spe-02/18/97 Provide discussion and cial Report within 30 days if the justification for this difference between observed and pre-less restrictive dicted steady-state boron concentra-change. Provide dis tion reaches the equivalent of 1 cussion of reasonable percent Ak/k. This requirement is equivalency for com deleted in the ITS.

parison to 100 ppm boron concentration.

3.1.1-2 R1 CTS 3.10.7 CTS 3.10.7 is moved to licensee con-2/25/97 Provide additional trolled documents.

discussion and justi fication for this change, including which licensee con trolled document(s) contain these require ments and how these requirements are con trolled and main tained.

HBR ITS 3.1.2 CORE REACTIVITY ITEM i DOC#

CTS/STS Description of Issue Date Date C0MMENTS or REF.

Opened Closed JFD#

3.1.2-1 M2 CTS 4.9 CTS 4.9 requires, after normaliza-03/03/97 Provide additional tion, periodic comparison of actual discussion and justi boron concentration to predicted fication for the,

boron values. CTS 4.9 does not acceptability of the specify when performance of the nor-ITS frequency and malization is required, nor does it normalization.

specify the frequency of the compar ison check beyond the term "periodi cally."

ITS SR 3.1.2.1 specifies when nor malization shall occur, and places specific times and frequencies on when the comparisons shall be per formed.

HBR ITS 3.1.3 MODERATOR TEMPERATURE COEFFICIENT (NTC)

ITEM #

DOC#

CTS/STS Decription of Ise Date DateC NT or REF.

Opened Closed JFD#

3.1.3-1 L2 CTS With the MTC outside the limits pro-02/25/97 Provide justification 3.1.3.3 vided in the COLR, CTS 3.1.3.3 re-for this extended quires the reactor bemade subcriti-allowed outage time cal by an amount greater than or based on acceptability equal to the potential reactivity of plant design. L2 insertion due to depressurization.

describes the change Since no completion time is explic-but provides no tech itly stated, this specification im-nical justification.

plies completion as soon as practi cal.

(Although not directly appli cable, CTS 3.0 requires hot shutdown within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Without an explicit statement of completion time, the comparable completion time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in CTS 3.0 is considered im plicitly binding.)

With MTC not within the upper limit, ITS 3.1.3 Required Action A.1 mandates estab lishment of administrative withdraw al limits for control banks to main tain NTC within the upper limit with a completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Pro vided ITS 3.1.3 Required Action A.1 is satisfied, no further action is required. While not explicitly stated, establishment of administra tive withdrawal limits for control Continued Next Page...

BBR ITS 3.1.3 MODERATOR TEMPERATURE COEFFICIENT (MTC) banks, to maintain MTC within the upper limit, is not precluded by the CTS. However, the completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to establish administra tive control banks withdrawal limits is less restrictive than the CTS permits. Therefore, this results in an extended allowed outage time.

3.1.3-2 L5 CTS With the HTC outside the limits pro-2/25/97 Provide justification 3.1.3.3 vided in the COLR, CTS 3.1.3.3 re-for the extended quires the reactor be made subcriti-allowed outage time cal by an amount greater than or based on plant design.

equal to the potential reactivity L5 does not provide insertion due to depressurization.

technical Since no completion time is explic-justification.

itly stated, CTS 3.1.3.3 implies completion as soon as practical.

(Although not directly applicable, CTS 3.0 requires hot shutdown within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Without an explicit state ment of completion time, the compa rable completion time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in CTS 3.0 is considered implicitly binding.)

With MTC not within the lower limit, ITS 3.1.3 Required Continued Next Page...

HBR ITS 3.1.3 MODERATOR TEMPERATURE COEFFICIENT (MTC)

Action C.1 mandates being in MODE 4 with a completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This completion time is more than the implicit completion time for CTS 3.1.3.3. This is an extension of an allowed outage time.

3.1.3-3 JFD 3 STS 3.1.3 The STS allows inserting a plant 2/26/97 Provide justification specific number for the limits of for this difference MTC at hot zero power. The ITS has from the STS based on limits for MTC when less than 50%

the current licensing RTP and greater than or equal to 50%

basis if applicable.

RTP. These limits are the same lim its contained in the CTS. This de viation from the STS appears to be based on the current licensing ba sis.

However, the JFD does not make reference to the current licensing basis.

HBR ITS 3.1.4 ROD GROUP ALIGNMENT LIMITS ITEM #

Doc#

CTS/STS Description of Issue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.4-1 A6 CTS CTS 3.10.6.1 requires declaring a 02/18/97 Provide discussion and 3.10.6.1 control rod inoperable if the rod is justification for this misaligned by more than 15 inches more restrictive from its bank. ITS 3.1.4 requires change.

individual rod positions within 7.5 inches of the average of the indi vidual rod positions in the bank when the bank demand position is <

200 steps.

This is a more restric tive change for which there is no discussion or justification.

3.1.4-2 L3 CTS Table CTS Table 4.1-3, Item 2 requires 2/25/97 Provide justification 4.1-3 verification of each control rods for the acceptability freedom of movement every 14 days of ITS change from CTS during reactor critical operations.

to not require fully ITS SR 3.1.4.2 requires this inserted rods to be surveillance to be performed at a 92 exercised.

day frequency. SIts does not require fully inserted rods to be exercised.

This is a less restrictive requirement and should be justified.

HBR ITS 3.1.4 ROD GROUP ALIGNMENT LIMITS ITEM #

DOC#

CTS/STS Deacription of Isaue Date Date CORKENTS or REF.

Opened Closed JFD#

3.1.4-3 A6 CTS CTS 3.10.6.1 requires declaring a 2/27/97 Provide discussion and 3.10.6.1 control rod inoperable if the rod is justification for the misaligned by more than 15 inches changed CTS require from its bank. ITS 3.1.4 requires ment for misaligned individual rod positions within 7.5 rods.

inches of the average of the indi vidual rod positions in the bank when the bank demand position is <

200 steps.

This changes the reference against which individual rod misalignment distances are measured from the bank demand position to the average of all the digital rod position indica tors within the bank. There is no discussion or justification for this change.

3.1.4-4 A5 CTS CTS 3.10.1.5 and 3.10.6 do not in-2/27/97 Provide discussion and 3.10.1.5 clude explicit operating condition justification for the applicability statements. ITS 3.1.4 addition of MODES 1 CTS 3.10.6 is applicable in MODES 1 and 2.

and 2. Explain why they are reasonable This change enhances the Technical interprpetations.

Specifications by clearly specifying MODES of applicability. Therefore, this is a more restrictive change, rather than an administrative change.

HBR ITS 3.1.4 ROD GROUP ALIGNMENT LIMITS ITEM I DOC#

CTS/STS Description of Issue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.4-5 A8 CTS CTS 3.10.4.1, requiring rod drop 2/27/97 Provide discussion and 3.10.4.1 time testing, does not specify the justification for the pre-test position of the rod to be pre-test position of tested.

the rod to be tested.

ITS SR 3.1.4.3 requires verification of rod drop time from the fully withdrawn position.

This change enhances the Technical Specifications by clearly specifying the height from which each rod is to be tested. Therefore, this is a more restrictive change, rather than an administrative change.

3.1.4-6 M7 CTS CTS 3.10.1.5 permits 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to re-03/03/97 Provide additional 3.10.1.5 store an out of alignment control discussion and justi rod to within limits.

fication for the changed CTS require ITS 3.1.4 Required Action B.1 per-ment.

mits only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore an out of alignment control rod to within limits.

No discussion is provided which jus tifies the selection of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, ex cept that the change is consistent with the STS.

HBR ITS 3.1.4 ROD GROUP ALIGNMENT LIMITS ITEM #

Doc#

CTS/STS Description of Issue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.4-7 M11 CTS Table CTS Table 4.1-3, Item 2-requires 03/03/97 Provide additional 4.1.3, periodic partial movement of all discussion and justi Item 2 full length control rods, but no fication for the minimum movement distance is speci-changed CTS require fied.

ment.

ITS SR 3.1.4.2 stipulates movement of ? 10 steps in either direction.

No discussion is provided which jus tifies the selection of a 10 steps, except that the change is consistent with the STS.

3.1.4-8 M25 CTS Both CTS 3.10.6.3 and CTS 3.10.4.1 03/03/97 Provide additional 3.10.6.3 are enhanced by ITS 3.1.4 ACTIONS discussion and justi and which introduce specific Conditions, fication for the and Required Actions, and Completion acceptability of M26 Times not found in the CTS. There change relative to the CTS is no justification for these more safety of the plant.

3.10.4.1 restrictive changes, other than to achieve consistency with the STS.

HBR ITS 3.1.6 CONTROL BANK INSERTION LIMITS ITEM I DOC#

CTS/STS Description of Issue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.6-1 LA2 CTS CTS 3.10.1.3 requires placing the 2/24/97 Provide further die 3.10.1.3 reactor in hot shutdown, and speci-cussion including fies that this be accomplished, "us--

which licensee con ing normal operating procedures."

trolled document con This detail, specifying the manner tains these details in which to achieve hot shutdown, is and the change control relocated to licensee controlled process in place for documents. The discussion of change these documents.

does not document which licensee controlled document contains these details, or the change control pro cess in place for these documents.

3.1.6-2 L4 CTS 3.10.3 For control rod banks inserted in 2/25/97 Provide technical excess of the specified insertion justification for limits, CTS 3.10.3 requires correc-acceptability of the tion within one hour.

ITS 3.1.6 extended allowed Required Action A.2 permits two outage time.

hours to restore the banks within limits.

This is an extension of an allowed outage time.

3.1.6-3 M17 None In the event control bank insertion 03/03/97 Provide additional limits, sequence limits and/or over-discussion and justi lap limits are not met, ITS 3.1.6 fication for the mandates specific ACTIONS A.1.1, acceptability of the A.1.2, B.1.1, B.1.2, and B.2.

additional restrictions on plant None of these ITS ACTIONS is includ-operations.

ed in the CTS.

The discussion for this change pro vides no justification of why the specific ACTIONS were selected.

HBR ITS 3.1.6 CONTROL BANK INSERTION LIMITS ITEM #

DOC#

CTS/STS Description of Isue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.6-4 M18 None ITS SR 3.1.6.1 requires verification

/03/97 Provide additional of estimated control bank position discussion and justi within limits specified in the COLR fication for the within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to achieving acceptability of the criticality. ITS SR 3.1.6.2 re-additional quires verification of each control restrictions on plant bank insertion within the limits of operations.

the COLR every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

ITS SR 3.1.6.3 requires verification of sequence and overlap limits met, as specified in the COLR, for control banks not fully withdrawn from the core every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. There are no comparable CTS requirements. There is no justification of why SRs were selected.

3.1.6 Ms The DOCS for the More Restrictive Provide additional changes for 3.1 need to be revised discussion and to include justification of justification for the discussion of the acceptability of changes.

these changes as they apply to the CTS.

3.1.6 Bases STS Bases include under Background Provide the list of the applicable criteria for applicable criteria reactivity and power distribution even though it is design requirements.

included and described in the FSAR.

HBR ITS 3.1.7 ROD POSITION INDICATION ITEM #

DOC#

CTS/STS Description of Issue Date Date COMMENTS or REF.

Opened Closed JFD,#

3.1.7 Rod Position Indication spec does Provide justification not exist in CTS.-

and discussion relative to plant operations and safety analysis.

HBR ITS 3.1.8 PHYSICS TESTS EXCEPTIONS-MODE 2 ITEM #

DOC#

CTS/STS Descripton of leaue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.8 TSTF-CTS markup deletes MODE 2 from the TSTF-14 does not allow 14 Applicability.

deletion of MODE 2.

Rev. 2 proposed deletion, rejected. OG revised Rev 3 to restore. Restore MODE 2 reference in both LCO and Bases.

3.1.8-1 JFD13 STS SR STS SR 3.1.10.1 is deleted. The 02/26/97 Provide justification 3.1.10.1 deletion is not justified on the for the STS deviation basis of current licensing basis, based on current li system design, or operational con-censing basis, system straints.

design, or operational constraints.

HBR ITS 3.1.8 PHYSICS TESTS EXCEPTIONS-MODE 2 ITEM #

DOC#

CTS/STS Description of Issue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.8-2 M20 None In the event ITS 3.1.8, PHYSICS TEST 03/03/97 Provide additional Exceptions-MODE 2, is not met, vari-discussion and justi ous specific ACTIONS are required, fication for the depending on the nature of the anom-changed CTS require aly. The ITS 3.1.8 ACTIONS are ment.

identified as A.1, A.2, B.1, C.1, and D.1, with Completion Times rang ing from "immediately" to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

CTS requirements comparable.to these ITS ACTIONS do not exist, so entry into CTS 3.0 is required. CTS 3.0 requires achieving 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 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Justification is not provided for the shorter Completion Times than required by the CTS, nor is there discussion and justification for the specific Required Actions and Com pletion Times selected.

HBR ITS 3.1.8 PHYSICS TESTS EXCEPTIONS-MODE 2 ITEM #

DQC#

CTS/STS Description of Issue Date Date COMMENTS or REF.

Opened Closed JFD#

3.1.8-3 M23 CTS CTS 3.10.1.6 requires maintaining a 03/03/97 Provide discussion and 3.10.1.6 specified minimum shutdown margin justification for the (SDM), except during the low power administrative change.

physics tests to measure control rod worth and SDM.

ITS 3.1.8, PHYSICS TESTS Excep tions-MODE 2, does not retain this minimum SDM exception, because the N-1 rod worth measurement technique, necessitating the SDM exception, is no longer used.

The discussion states the elimina tion of the SDM exception is an ad ditional restriction on plant opera tion. However, this change imposes no additional restriction, because with the N-1 measurement technique no longer used, neither retention nor removal of the SDM exception has any effect on use and application of the Technical Specifications. This change should be classified, dis cussed, and justified as an adminis trative change.

HBR ITS 3.2.1 HEAT FLUX HOT CHANNEL FACTOR (F9 (Z))

(Fq METHODOLOGY)

DO CTS/STS Decription Of lesue Date Date QQMMENTS or LCO Opened Closed JFD 3.2.1-1 LA1 CTS CTS 3.10.2.1 is changed to state "as 12/3/96 Provide discus 3.10.2.1 approximated by (F

)

sion and justifi cation for the There is no discussion or justification change.

for this change.

3.2.1-2 JD3 STS 3.2.1 STS 3.2.1 is changed from F,,(Z) and 12/6/96 Discuss any W

V FAQ(Z) to "FQ(Z)."

generic implications. Pro There is inadequate justification for vide justifica this change with regard to the current tion for the STS licensing basis.

deviation based on current licensing basis, including deletion of SRs.

RTP 3.2.1-3 LA1 CTS CTS 3.10.2.1, "FA (Z)" is removed from 12/3/96 Provide discus 3.10.2.1 the Nuclear Enthalpy Rise Hot Channel sion and justifi RTP Factor (F. (Z)) equation.

cation for the change.

There is no discussion or justification for this change.

HBR ITS 3.2.1 BEAT FLUX HOT CHANNEL FACTOR (FP(Z))

(FQ METHODOLOGY)

DOC CTS/STS D0scription of lea e Date Date OOMMENTS or LCO Opened Closed JFD 3.2.1-4 JD4 STS STS 3.2.1 Required Action B.1, requiring 12/6/96 JFD4 indicates 3.2.1 reducing AFD limits 2 1% for each 1% FV(Z) that Required M3 Required exceeds its limit, is not adopted in ITS Action B.1 in STS Action 3.2.1.

is invalid.

A.1 Discuss generic ITS 3.2.1 Required Action A.1 requires implication. If reduction of AFD target band limits to plant specific, CTS restore F,(Z) within 15 minutes. This provide 3.10.2.-

requirement is not in CTS 3.10.2.1.1.

discussion why 1.1 statement should There is inadequate justification for not be an AND this change.

statement and justification for the STS deviation based on current licensing basis.

and the changed CTS requirement.

3.2.1-5 L2 CTS CTS 3.10.2.1.1 requires reduction of the 12/5/96 Provide addition 3.10.2.-

overpower delta temperature (OPAT) and al discussion and 1.1 over temperature AT (OTAT) trip setpoints justification for within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

the differences in CTS and NUREG ITS 3.2.1 Required Action A.2.3 extends 1431 methodology this required time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

for power distribution This change represents an extension to a limits based on CTS Allowed Outage Time.

plant requirements.

HBR ITS 3.2.1 HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))

(Fa METHODOLOGY)

DOC CTS/STS Dcription of lsve Date Date OQWMNTS or LCO Opened Closed JFD 3.2.1-6 JD5 STS 3.2.1 STS 3.2.1, Required Action A.1, Comple-12/6/96 This is a Beyond Required tion Time is 15 minutes Scope issue.

Action Discuss generic A.2.1 ITS 3.2.1, Required Action A.2.1, Comple-implications.

tion Time is 30 minutes Provide discus sion and justifi There is inadequate justification to cation for the support this change.

STS deviation based on current licensing basis.

N HBR LCO 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor (PAN)

DOC CTS/STS Description of usie Date Date COM.ENTS or LCO Opened Closed JFD 3.2.2-1 Al CTS CTS 3.10.2.1.1 requires power distribu-12/10/96 Provide discus 3.10.2.-

tion mapping using the movable in-core sion and justifi 1.1 detector system.

cation for this Less Restrictive This requirement is not included in ITS change.

Section 3.2. However, it is referenced in the Bases.

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

3.2.2-2 M8 CTS CTS 3.10.2.1.1 requires that the hot 12/10/96 Provide discus 3.10.2.-

channel factor be determined following sion and justifi 1.1 initial fuel loading.

cation for the More Restrictive ITS 3.2.2 changes this requirement to change relative each refueling and prior to THERMAL POWER to plant exceeding 75% RTP.

operations.

There is no discussion or justification for this More Restrictive licensing basis change 3.2.2-3 M9 CTS CTS 3.10.2.1.1 requires reactor power to 12/10/96 Provide discus 3.10.2.-

be reduced if either hot channel factor sion and justifi 1.1 limit is exceeded.

cation for this change relative ITS 3.2.2 Required Action A.1.2.1, re-to plant quires reducing THERMAL POWER to <50%

operations.

when the FN limit is exceeded.

There is no discussion or justification ofor this change.

1

HBR LCO 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor (FA.)

DOC CTS/STS Desciption of leave Date Date COMMENTS or LCO Opened Closed JFD 3.2.2-4 M10 CTS CTS 3.10.2.1.1 requires that the high 12/10/96 Provide discus 3.10.2.-

neutron flux trip setpoint be reduced by sion and justifi V

1.1 the ratio of the (F,(Z)) or FAH limit to cation for this the measured value which ever is less.

More Restrictive changerelative ITS 3.2.2 Required Action A.1.2.2, re-plant operations.

quires reducing Power Range Neutron Flux High trip setpoints to S55% RTP.

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

3.2.2-5 L5 CTS CTS 3.10.2.1.1 requires that the oTAT and 12/10/96 Provide addition 3.10.2.-

OPAT setpoints be reduced by the fraction al discussion and 1.1 FAHLimit/FAHactat if an out-of-limit condi-justification for tion for F., is not corrected within 24 this change hours.

relative to plant operations. See This requirement is deleted from ITS 3.2.1-5 also.

3.2.2.

The justification does not adequately address the change as it pertains to the licensing basis.

2

HBR LCO 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor (FN)

DOC CTS/STS Description of Issue Date Date QQMMENTS or LCO Opened Closed JFD 3.2.2-6 M11 CTS CTS 3.10.2.2.3 requires that if FA is 12/10/96 This change is 3.10.2.-

within limits but measurements indicate administrative.

AN 2.3 that FA is increasing, thien the total peaking factor (F,(Z)) shall be increased by 2%.

CTS 3.10.2.2.3 second paragraph requires that F,(Z) be measured and a target AFD re-established at least every seven days until two successive measurements indi N

cate FAN is not increasing.

ITS 3.2.2.1 NOTE, addresses the same re quirements.

The discussion and justification address the change as a more restrictive change instead of an administrative change.

3

HBR ITS 3.2.3, Axial Flux Difference (AFD) (PDC-3 Axial Offset Control Methodology)

D00 CTS/STS Dec.pt

.n

.t *e Date Dat.

0 or LCO Opened closed JFD 3.2.3-1 M415 CTS CTS 3.10.2.5, requires that the indicated 12/11/96 The addition ofa 3.10.2.5 Axial Flux Difference (AFD) shall be requirement in within the target band..and of itself does not ITS 3.2.3.b allows AFD to deviate outside constitute a more the target band during certain conditions restrictive provided the cumulative penalty deviation requirement.

time is.

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

Provide adequate discussion and This represents a less restrictive justification for change.

the Less Restric tive change based on plant operation..

3.2.3-2 A9 CTS CTS 3.10.2.6 contains the Required Action 12/11/96 The change is.

3.10.2.6 to Return the AXIAL FLUX DIFFERENCE (AFD) acceptable, how to the target band "immediately."

ever, a technical justification STS 3.2.3, Required Action A.1, requires relative to plant a completion time of "15 minutes" to operations for restore AFD to within the target band.

the increase to CTS Allowed Out age Time is needed.

1

BBR ITS 3.2.3, Axial Flux Difference (AFD) (PDC-3 Axial Offset Control Methodology)

DOC CTS/STS DesciptiLon of Iase Date Date CORKENTS or L.O Opened Closed JFD 3.2.3-3 M17 CTS CTS 3.10.2.6 contains the Required Action 12/11/96 See 3.2.3-1 and 3.10.2.6 to reduce reactor power to a level no 3.2.3-2 comments.

greater than 90% of rated power "immedi-Provide addition ately."

al discussion and justification to STS 3.2.3, Required Action B.1, requires increase CTS a completion time of "15 minutes" to Allowed Outage reduce THERMAL POWER to < 90% in 15 min-Time.

utes.

3.2.3-4 A10 CTS CTS 3.10.2.7.a, contains the Required 12/11/96 See 3.2.3-1 and 3.10.2.

Action to "immediately" reduce reactor 3.2.3-2 comments.

7.a power to < 50% rated power if cumulative Provide addition time exceeds one (1) hour if the AFD is al discussion and outside of the target band.

justification to increase CTS ITS 3.2.3, Required Action C.1, requires Allowed Outage a Completion Time of "30 minutes" to re-Time.

duce THERMAL POWER to < 50% RTP.

2

HBR ITS 3.2.3, Axial Flux Difference (AFD) (PDC-3 Axial Offset Control Methodology)

DCP CTS/STS DescriptiQn of Issue Date Date 00MMENTS or LCO Opened Closed JFD 3.2.3-5 L7 CTS CTS 3.10.2.9.a and b allow calibration of 12/12/96 Provide 3.10.2.9 the excore detectors if the AFD is not additional

.a & b outside of the target band for > 90%

justification for rated power, and if the AFD does not change as it re exceed the limits specified in the COLR lates to the li for reactor power between 50% and 90%

censing basis and rated power.

discuss the impact because of ITS 3.2.3.c, NOTE allows up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> differences from to be accumulated with AFD outside of the the STS power target band without penalty deviation distribution time while the excore detectors are being limit calibrated.

methodology.

3.2.3-6 L8 CTS CTS 3.10.2.10 requires that the AFD be 12/12/96 Provide 3.10.2.10 logged every hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, additional and half-hourly thereafter, when the AFD justification for alarm is out of service.

change as it re lates to the li ITS SR 3.2.3.2 requires a Frequency of censing basis and once within 15 minutes and every 15 min-discuss the utes thereafter when THERMAL POWER is z impact because of 90% RTP, and once within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and every differences from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> thereafter when THERMAL POWER is <

the STS power 90 % RTP.

distribution limit This change is less restrictive in the methodology.

case that the AFD monitor alarm remains out of service for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and THERMAL POWER <

90% RTP.

3

HBR ITS 3.2.3, Axial Flux Difference (AFD) (PDC-3 Axial Offset Control Methodology)

DOC CTS/STS Decription of l ee Date*

COMENTS or LCO Opened Closed JFD 3.2.3-7 Al CTS CTS 3.10.2.10 requires that the AFD be 12/12/96 Provide discus 3.10.2.10 logged every hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, sion and justifi and half-hourly thereafter, when the AFD cation for the alarm is out of service.

change.

ITS SR 3.2.3.2 requires logging AFD for each "OPERABLE" excore channel.

There is no discussion or justification

_______ ____for this change.

4

BBR ITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

DOC CTS/STS Desc0iption of Isave t De DatOOMMENTS or LCO Opened Closed JFD 3.2.4-1 L10 CTS CTS 3.10.3 excludes applicability of QPTR 12/13/96 Provide addition 3.10.3 limits during power increases below 50%

al discussion and of rated power.

Justification for the licensing ITS 3.2.4 Applicability is MODE 1 with basis change.

THERMAL POWER > 50% RTP.

Also provide technical The increase of QPTR out of limit risk at discussion for exactly 50% RTP is only qualitatively the resulting stated.

possibility of an unanalyzed There is inadequate discussion and justi-condition, even fication for the licensing basis change.

if small.

3.2.4-2 L1l CTS CTS 3.10.3.1.a, requires that the power 12/13/96 Provide addition 3.10.3.-

range high flux setpoint be reset by two al discussion and l.a (2) percent for every one (1) percent justification of that QPTR exceeds 1.0.

how the remaining Required Actions This requirement is deleted from ITS work to maintain 3.2.4.

the required safety margin There is inadequate discussion and justi-bases on plant fication for the licensing basis change.

operation.

3.2.4-3 L12 CTS CTS 3.10.3.1.b, requires the power range 12/13/96 Provide addition 3.10.3.-

high flux setpoint to be reset to 55% of al discussion and l.b rated power.

Justification for the licensing This requirement is deleted from ITS basis change.

3.2.4.

There is inadequate discussion and justi fication for the licensing basis change.

HBR ITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

DOC CTS/STS Desription of leave Date Date 00MMENTS or LCO Opened Closed JFD

.2.4-4 L13 CTS If QPTR exceeds 1.09, and there is simul-12/16/96 Provide addition 3.10.3.2 taneous indication of a misaligned con-at. justification and.

trol rod, CTS 3.10.3.2 requires specified for the deleted 3.10.3.3 power reduction and elimination of the CTS requirements.

tilt condition within two hours, or the reactor placed in hot shutdown. CTS 3.10.3.2 further limits reactor power to 5 50%, if the rod is realigned within two hours, until the QPTR is again 5 1.09.

If QPTR exceeds 1.09, and there is no simultaneous indication of a misaligned control rod, CTS 3.10.3.3 requires the reactor immediately placed in the hot shutdown condition.

These requirements are not included in ITS 3.2.4.

The provided justification states the change is acceptable because operation of the plant in accordance with ITS 3.2.4 Required Actions reasonably assures that plant operations are within the bounds of the safety analysis.

There is no specif ic discussion indicating the CTS require ments and the ITS Required Actions are both bounded within the same analyzed safety envelope, so the justification provided is inadequate.

HBR ITS 3.5.1, ACCUMULATORS - MODES 1, 2 AND 3 (>1000 psig)

Item #

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

Closed JFD 3.5.1-1 A14 CTS CTS 3.3.1.1.g requires 4/28/97

1) You state in DOC Al4 that the al JD3 3.3.1.1.g removal of control power lowance to restore power to one valve 3.3.1.2.f from a accumulator isola-permitted by CTS 3.3.1.2.f is not tion valves at > 1000 explicitly retained in the ITS.

How STS SR psig. CTS 3.3.1.2.f al-ever, both the clean copy of the pro 3.5.1.5 lows restoration of power posed ITS and the markup of NUREG-1431 to one valve for testing indicate that this allowance is re ar maintenance for a pe-tained as a Note to ITS SR 3.5.1.5.

niod of four hours.

ITS JFD 3 also addresses this Note as SR 3.5.1.5 includes a being added consistent with the cur note that allows control rent licensing basis.

power to be restored to

2) It is not clear why the addition of one accumulator isolation the note to SR 3.5.1.5 is needed valve for no more than since, as stated in DOC Al4, the cam four hours. The note pletion time for Required Action 8.1 also refers to similar would allow 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for this same cir allowances for other ECCS cumstance without the note.

valves. This note is not

3) The note as is can cause confusion contained in the corre-because it also addresses other sponding STS SR.

ECCS valves for which requirements are contained in a separate specification.

There is no reason for these other allowances in a note for an SR that only addresses accumulator valves.

Provide additional explanation as to why the note is necessary. If the decision is made to retain the note, please revise the note to address the 3.3.1.2.f from______ a_____________________

__accumulator valves only.

1

HBR ITS 3.5.1, ACCUMULATORS - MODES 1, 2 AND 3 (>1000 psig)

Item #

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed 3.5.1-2 M3 CTS CTS 3.3.1.1.b stipulates 4/28/97 Provide discussion and justification 3.3.1.1.b a minimum accumulator for selection of the upper accumulator cover pressure limit but cover pressure limit.

does not provide a maximum limit.

ITS SR 3.5.1.3 imposes an upper limit on accumulator cover pressure. No discussion or justifica tion is provided for the bases for selection of the upper limit.

3.5.1-3 M9 CTS CTS 3.3.1.1.b stipulates 4/28/97 Provide discussion and justification 3.3.1.1.b a minimum accumulator for selection of the upper accumulator boron concentration limit boron concentration limit.

but does not provide a maximum limit on boron concentration.

ITS SR 3.5.1.4 imposes an upper limit on accumulator boron concentration. No discussion or justifica tion is provided for the bases for selection of.

the upper limit.

2

HBR ITS 3.5.1, ACCUMULATORS -

MODES 1, 2 AND 3 (>1000 psig)

Item #

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD 3.5.1-4 L1 CTS CTS 3.3.1.2 provides a 4/28/97 The DOC did not provide any discussion 3.3.1.2 completion time of 4 as to why 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is an appropriate hours when an accumulator completion time for this condition.

is inoperable.

ITS 3.5.1 Please provide additional discussion ACTION A.1 provides a to address this issue.

completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when an accumulator is inoperable due to boron concentration being outside limits.

3

HBR ITS 3.5.1, ACCUMULATORS - MODES 1, 2 AND 3 (>1000 psig)

Item #

DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed J FD 3.5.1-5 JD2 STS SRs This JFD addresses two 4/28/97 ITS SR 3.5.2.1 requires verification 3.5.1.1 & separate issues; one of valve position with control power 3.5.1.5 associated with ITS SR removed for several low head and high 3.5.1.1 and one head safety injection valves every 12 associated with ITS SR hours. Explain how these valves are 3.5.1.5. This comment different from the accumulator addresses ITS SR 3.5.1.1.

isolation valves as far as location, STS SR 3.5.1.1 requires functional requirements, and relative verification that each importance to the overall ECCS accumulator isolation function. If there is no significant valve is fully open every difference, provide further 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS SR 3.5.1.1 explanation to justify the difference only requires this in surveillance requirements (i.e.,

verification once prior STS SR 3.5.1.5 shouldn't be adopted).

to removing power from the valve operator, con sistent with the current Also, it is the staff's understanding licensing basis. JFD 2 that most PWR licensees with states that removal of requirements similar to STS SR 3.5.1.1 power disables remote do not make routine containment indication of the valve's entries to perform this verification.

position and, to preclude Explain why HBRSEP operators would the need for routine en-need to enter containment to perform try into containment, this verification.

position verification is only required once before power is removed. The JFD goes on to state that ITS SR 3.5.1.1 and SR 3.5.1.5 in conjunction provide reasonable assurance that the valves 4

HBR ITS 3.5.2 ECCS-OPERATING MODES 1, 2 AND 3 DOC CTS/STS LCO Description of Issue Date Date COMMENTS or Opened Closed J FD 3.5.2-1 A2 CTS 3.3.1 CTS 3.3.1.c through CTS 3.3.1.f 4/28/97 The staff does not provide system specific equipment believe this is an requirements which define an ECCS administrative change train.

ITS 3.5.1 through 3.5.4 do but, rather, a less not contain this level of detail; restrictive change however the Bases for these speci-which moves details fications do. You state in DOC A2 from the LCO to the that this is an administrative Bases. Please revise change and the ITS do not retain the DOC for this this information since it is gener-change from an admin ically encompasses within the defi-istrative change to a nition of operability.

less restrictive change.

(NOTE: THIS CHANGE ALSO APPLIES TO ITS 3.5.3.)

HBR ITS 3.5.2 ECCS-OPERATING MODES 1, 2 AND 3 DOC CTS/STS LCO Description of Issue Date Date COMMENTS or Opened Closed JFD 3.5.2-2 A5 &

CTS 3.3.1.2.e CTS 3.3.1.2.e permits any one ECCS 4/28/97 Please elaborate on J04 flow path to be inoperable for up your statement that to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The note to ITS 3.5.2 the HBRSEP design is Actions permits one SI pump flow not conducive to per path to be isolated for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to forming PIV testing on perform required pressure isolation the SI system and de valve (PIV) testing. You state in scribe the differences JFD 4 that this note is similar to from other PWRs that the STS Applicability Note 1 which necessitate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not used in the ITS. However, to perform this test the STS note only allows the safety ing. Also, the change injection flow paths to be isolated in the location of the for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform PIV note from the Appli testing. You state in JFD 4 that cability (in the STS) the HBRSEP design "is not conducive to the Actions is a to performing this testing, requir-generic change.

ing up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the Please justify this testing."

You also state that you deviation from the STS believe a note to the Actions is on a plant-specific considered more appropriate than a basis, modify your note to the Applicability.

proposal to retain the STS location of the note, or submit a ge neric change package to the TSTF.

3.5.2-3 No JD STS 3.5.2 The markup of NUREG-1431 indicates 4/28/97 Please provide a Applicability that the words "Entry and" are justification for de Note 2 added at the beginning of Applica-viation from the word bility Note 2 to STS 3.5.2. No JD ing of the STS for is referenced to justify this this note, keeping in deviation from the STS. This note mind that the proposed is not contained in the CTS.

change appears to be generic.

HBR ITS 3.5.2 ECCS-OPERATING MODES 1, 2 AND 3 DOC CTS/STS LCO Description of Issue Date Date COMMENTS or Opened Closed J FD 3.5.2-4 JD3 STS SR 3.5.2.1 A note is included in ITS SR 4/28/97

1) It is not clear why 3.5.2.1 which is not included in the addition of the STS 3.5.2.1 to allow power or air note to SR 3.5.2.1 is to be restored to one valve for the needed since the corn purpose of testing or maintenance.

pletion time for Re The note also refers to similar quired Action A.1 allowances for other ECCS valves, would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> While the intent of the note main-for this same circum tains consistency with the current stance without the licensing basis, the note applies note.

to, and includes requirements for

2) The note as is can ITS SR 3.5.1.5 and ITS SR 3.5.2.7 cause confusion as well as ITS SR 3.5.2.1 where it because it also is placed.

addresses other ECCS valves, some of which are contained in a separate specification. There is no reason for these allowances for other valves in a note for an SR that doesn't

___address those valves.

3.5.2-5 No JD STS SR 3.5.2.3 STS SR 3.5.2.3 requires 4/28/97 Please provide a verification every 31 days that.justification for ECCS piping is full of water.

The deviation from the STS ITS do not contain this for not including this requirement.

No justification for requirement in the deviation from the STS was provided HBRSEP ITS.

to, and includes for this change.

e as isc

HBR ITS 3.5.2 ECCS-OPERATING MODES 1, 2 AND 3 DOC CTS/STS LCO Description of Issue Date Date COMMENTS or Opened Closed J FD 3.5.2-6 No JD STS SR 3.5.2.7 STS SR 3.5.2.7 requires 4/28/97 Please provide a verification of ECCS throttle valve justification for position.

The ITS do not contain deviation form the STS this requirement. No justification for not including this for deviation form the STS was requirement in the provided for this change.

HPRSEP ITS.

3.5.2-7 JD7 No comparable ITS SR 3.5.2.7 was added to require 4/28/97

1) It is not clear why STS SR surveillance of air operated valves the addition of the FCV-605 & HCV-758. A note is note to SR 3.5.2.7 is included in ITS SR 3.5.2.7 to allow needed since the comn power or air to be restored to one pletion time for Re valve for the purpose of testing or quired Action A.1 maintenance. The note also refers would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to similar allowances for other for this same circum ECCS valves. While the intent of stance without the the note maintains consistency with note.

the current licensing basis, the

2) The note as is can note applies to, and includes re-cause confusion quirements for ITS SR 3.5.1.5 and because it also ITS SR 3.5.2.1 as well as ITS SR addresses other ECCS 3.5.2.7 where it is placed.

valves for some of__

which requirements are contained in a sepa rate specification.

There is no reason for these other allowances in a note for an SR that doesn't address valve___ for___ the____________

purp_____those valves.

HBR ITS 3.5.3 ECCS-SHUTDOWN MODE 4 DOC CTS/STS LCO Description of Issue Date Date COMMENTS or Opened Closed JFD 3.5.3-1 A12 CTS 3.3.1.3 CTS requires two RHR subsystems to be 4/28/97 Although the operable in Hot Shutdown (Modes 3 &

flexibility provided 4).

ITS SR 3.5.3.1 contains a note in the note to ITS that allows an RHR train to be consid-SR 3.5.3.1 may be ered operable during alignment and consistent with your operation for decay heat removal if current interpreta capable of being manually realigned to tion of CTS 3.3.1.3 the ECCS mode of operation. You state and your operating in DOC A12 that, although the CTS do practice, it is, not explicitly provide for RHR subsys-nevertheless, not tems to be considered operable in Hot explicitly provided Shutdown when aligned for decay heat for in your CTS.

removal, it is your current practice Therefore, this is a and interpretation to allow credit to less restrictive be taken for portions of an ECCS change, not an ad subsystem as an operable subsystem al-ministrative change.

though they may be manually aligned to The staff will re function for decay heat removal.

flect it as such in Therefore, you conclude that the addi-the safety evalua tion of this clarification to ITS SR tion. No action is 3.5.3.1 as a note is an administrative required on your change.

part.

HBR ITS 3.5.3 ECCS-SHUTDOWN MODE 4 DOC CT$/STS LCO Description of Issue Date Date COMMENTS or Opened Closed JFD 3.5.3-2 M16 CTS 4.5.2.2 CTS 4.5.2.1 requires verification that 4/28/97 The changes to the JD8 STS SR 3.5.3.1 specified valves are correctly posi-requirements of STS JD12 tioned with control.power removed.

SR 3.5.3.1 to not CTS 4.5.2.2 requires verification that require performance specified valves are correctly posi-of SR 3.5.2.1 but to tioned. Both requirements apply dur-require performance ing power operation.

ITS SR 3.5.3.1 of SR 3.5.2.2 in does not require performance of ITS SR Mode 4 are generic 3.5.2.1 (equivalent to CTS 4.5.2.1) changes that are not and does require performance of SR completely consis 3.5.2.2 (equivalent to CTS 4.5.2.2) in tent with the CTS.

Mode 4. Both of these items are Please provide addi changes to the STS.

tional plant-specif ic justification for these changes in Mode 4 ECCS require ments or submit a generic change package to the TSTF.

HBR ITS 3.5.4 REFUELING WATER STORAGE TANK MODES 1, 2, 3, and 4 DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed J FD 3.5.4-1 M21 CTS CTS 3.3.1.1.a stipulates a minimum RWST 4/28/97 Provide discus 3.3.1.1.a boron concentration limit but does not sion and justifi provide a maximum limit on boron concen-cation for selec tration.

ITS SR 3.5.4.3 imposes an upper tion of the upper limit on RWST boron concentration. No RWST boron con discussion or justification is provided centration limit.

for the bases for selection of the upper limit.