ML15310A064

License Amendment Request to Relocate Surveillance Frequency Requirements

ML15310A064
Person / Time
Site:	Calvert Cliffs
Issue date:	11/05/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15310A064 (24)

Text

200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com Exelon Generation 10 CFR 50.90 November 5, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318

Subject:

License Amendment Request to Relocate Surveillance Frequency Requirements

Reference:

Letter from U.S. Nuclear Regulatory Commission to David T. Gudger (Exelon Generation Company, LLC), Issuance of Amendments Regarding Implementation of Technical Specification Task Force Traveler 523, Generic Letter 2008-01 , Managing Gas Accumulation," dated July 30, 2015 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is submitting a request for an amendment to the Technical Specifications (TS). The proposed amendment would relocate Surveillance Requirement (SR) Frequencies to the already approved Surveillance Frequency Control Program (SFCP). These SR Frequencies were added to the Calvert Cliffs Nuclear Power Plant, (CCNPP), Units1 and 2 TS by the Referenced letter. The proposed change to relocate the added SR Frequencies is consistent with NRG-approved Technical Specifications Task Force (TSTF) change TSTF-523, Revision 2.

There are no regulatory commitments contained in this letter. Exelon requests approval of the proposed license amendment by November 5, 2016, with the amendment being implemented within 60 days.

These proposed changes have been reviewed by the Plant Operations Review Committee and approved in accordance with Nuclear Safety Review Board procedures.

In accordance with 10 CFR 50.91, "Notice for public comment; state consultation," a copy of this application, with attachments, is being provided to the designated State Official.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5th day of November 2015.

License Amendment Request Relocation of Surveillance Requirement Frequencies Docket Nos. 50-317 and 50-318 November 5, 2015 Page 2 If you should have any questions regarding this submittal, please contact Enrique Villar at 610-765-5736.

Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Change

2. Marked-up Technical Specifications Pages

3. Marked-up Technical Specifications Bases Pages cc: NRC Regional Administrator, Region I w/attachments NRC Senior Resident Inspector - CCNPP NRC Project Manager, NRA - CCNPP S. T. Gray, State of Maryland "

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGE

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGE

Subject:

License Amendment Request to Relocate Surveillance Frequency Requirements 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request Attachment 1 Relocation of SuNeillance Requirement Frequencies Page 1 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes a change to the Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2, Technical Specifications (TS) Appendix A of Renewed Facility Operating License Nos. DPR-53 and DPR-69.

Specifically Exelon proposes to relocate the SuNeillance Requirement (SR) Frequencies of the SRs listed below to the SuNeillance Frequency Control Program (SFCP).

SR Current SR Proposed SR Frequency Frequency SR 3.4 ..6.4 31 days In accordance with the SuNeillance Frequency Control Program SR 3.4.7.4 31 days In accordance with the SuNeillance Frequency Control Program SR 3.4.8.3 31 days In accordance with the SuNeillance Frequency Control Program SR 3.5.2.10 31 days In accordance with the SuNeillance Frequency Control Program SR 3.6.6.9 31 days In accordance with the SuNeillance Frequency Control Program SR 3.9.4.2 31 days In accordance with the SuNeillance Frequency Control Prooram SR 3.9.5.4 31 days In accordance with the SuNeillance Frequency Control Program 2.0 DETAILED DESCRIPTION On July 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) issued Amendments 313 and 291 approving the implementation of Technical Specifications Task Force (TSTF)-523 for CCNPP, Units 1and2 (Reference 1). The Frequency for these SRs, as discussed in TSTF-523, is 31 days for licensees without a SFCP, and for licensees with a SFCP, the Frequency is "In accordance with the SuNeillance Frequency Control Program."

Because CCNPP did not have an approved SFCP at the time of the issuance of TSTF-523, a 31 day Frequency was established for the seven (7) SRs as listed in Section 1.0.

On August 17, 2015, NRC issued Amendments 314 and 292 approving the implementation of TSTF-425 at CCNPP, Units 1 and 2 (Reference 2).

3.0 TECHNICAL EVALUATION

This License Amendment Request is an administrative change. TSTF-523 recognized that these new SR Frequencies fell within the scope of TSTF-425. The Frequency for these SRs, as shown in the marked-up pages of TSTF-523, would have been "In accordance with the SuNeillance Frequency Control Program" for licensees with an approved SFCP, or 31 days for licensees without an approved SFCP.

License Amendment Request Attachment 1 Relocation of Surveillance Requirement Frequencies Page 2 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes Because CCNPP did not have an approved SFCP at the time of issuance of Reference 1 related to TSTF-523, a 31-day Frequency was established for these new SRs.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change is: 1) consistent with TSTF-523, which has been approved by the NRG for CCNPP, Units 1 and 2; 2) meets the requirements under 10 CFR 50.36 ("Technical specifications"); and 3) is consistent with the defense in depth philosophy of Regulatory Guide 1.174.

4.2 Precedence In Reference 3, Seabrook received NRG approval for the use of TSTF-425 Surveillance Frequencies for a TSTF-523.

4.3 No Significant Hazards Consideration This amendment request involves relocating to the Surveillance Frequency Control Program (SFCP) the Frequencies of Surveillance Requirements (SR) added to the Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Technical Specifications (TS) by Amendments 313 and 291, respectively.

Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The proposed License Amendment Request is an administrative change. The proposed change relocates the specified Frequencies for periodic Surveillance Requirements to licensee control under the SFCP. Surveillance Frequencies (SF) are not an initiator to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The systems and components required by the TS for which the SF are relocated are still required to be operable, meet the acceptance criteria for the SR, and be capable of performing any mitigation function assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No

License Amendment Request Attachment 1 Relocation of Surveillance Requirement Frequencies Page 3 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes The proposed License Amendment Request is an administrative change. The proposed change relocates the specified Frequencies for periodic SR to licensee control under the SFCP. No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements. The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed License Amendment Request is an administrative change. The proposed change relocates the specified Frequencies for periodic SR to licensee control under the SFCP. The design, operation, testing methods, and acceptance criteria for systems, structures, and components (SSCs), specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the Final Safety Analysis Report and Bases to TS), since these are not affected by changes to the SF. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

License Amendment Request Attachment 1 Relocation of Surveillance Requirement Frequencies Page 4 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes

6.0 REFERENCES

1. Letter from U.S. Nuclear Regulatory Commission to David T. Gudger (Exelon Generation Company, LLC), Issuance of Amendments Regarding Implementation of Technical Specification Task Force Traveler 523, Generic Letter 2008-01 ,

Managing Gas Accumulation," dated July 30, 2015

2. Letter from Alexander N. Chereskin (U.S. Nuclear Regulatory Commission) to Bryan C. Hanson (Exelon Generation Company, LLC), Issuance of Amendment RE:

Adoption of TSTF-425, "Relocate Specific Surveillance Frequencies to a Licensee Controlled Program," dated August 17, 2015

3. Letter from John J. Lamb (U.S. Nuclear Regulatory Commission) to Dean Curtland (NextEra Energy Seabrook, LLC), Issuance of Amendment Regarding Technical Specifications Task Force (TSTF) Traveler 523, "Generic Letter 2008-01, Managing Gas Accumulation Using the Consolidated Line Item Improvement Process," dated February 6, 2015

ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATIONS PAGES

RCS Loops - MODE 4 3.4.6

?URVEILLANCE REQUIREMENTS SURVEILLANCE

--r-r---~~~-~~: N~~- -- -

SR 3.4 . 6.1 Verify one RCS or SOC loop is in operation. In accordance with the

, Survei 11 ance I

• Frequency Cont ro 1 Program SR 3.4. 6.2 Verify secondary side water level in ln accordance required steam generator(s) is > -50 inches. with the Surveillance Frequency Control Program SR 3. 4. 6. 3 Verify correct breaker alignment and j I n accordance indicated power available to the required 1 with the loop components that are not in operation.

IFrequency 1

Surveillance i Control Program

• -------- - L --

SR 3.4.6.4 -------------------NOTE-------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.

Verify required SOC train locations susceptible to gas accumulation are sufficiently filled with water.

>In accordance with ithe Surveillance

!Frequency Control

[Program ___ _

CALVERT CLIFFS - UN[T 1 3.4.6-3 Amendment No. 314 CALVERT CLIFFS - UNIT 2 ~nendment No. 292

RCS Loops - MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE

. - . ,+-.

1 FREQUENCY SR 3.4.7.1 Verify one SOC loop is in operation. I In accordance l with the l

, Surveillance

! Frequency

---

*-__ ._. _. ___ _J Cont_:_:ro:"'__

SR 3.4.7.2 Verify required SG secondary side water IIn accordance 1evel is > -50 inches. 1 with the I Survei l la nee

! Frequency

( Centro 1 Program

- - - - - -*- - -* *--- - - -..... . . . . ._ _ _ _ _ *-+

SR 3.4.7.3 Verify correct breaker alignment and j In accordance indicated power available to the required I with the SOC loop components that are not in operation.

l Survei 11 ance

, Frequency j Control Program SR 3.~-~- ~~-;;~ r~~uired SOC train location~------1!-3-l-d~

susceptible to gas accumulation are sufficiently filled with water. I In accordance with the Surveillance Frequency Control Program CALVERT CLIFFS - UNIT 1 3. 4.7-3 l'..inendmen t No. 3111 CALVERT CLIFFS - UNIT 2 Amendment No. 292

RCS Loops - MODE 5, Loops Not Filled

3. 4. 8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

, . _*-*-*-**~--* *--**-**---*******--**--*-******-+---******************-** - ** *- -*

SR 3. 4. 8. 3 Verify SDC train locations susceptible to gas accumulation are sufficiently filled with water.

In accordance with the Surveillance Frequency Control Program CALVERT CLIFFS - UNIT l 3.4.8-3 Amendment No. 314 CALVERT CLIFFS - UNI T 2 Amerniment No. 292

ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.10 Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water.

L In accordance with the Surveillance Frequency Control Program CALVERT CLIFFS - UNIT 1 3.5.2-4 Amendment No. 314 CALVERT CLlFFS - UNIT 2 Amendment No. 292

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued) ...

SURVEILLANCE I FREQUENCY SR 3.6.6- ; - . Verif;.ach containmen~* spray pump s~a;:--t;;-:cordan:.*

automatically on an actual or simulated 1' with the actuation signal. Surveillance j Frequency

Control Program SR 3.6.6.7 Verify each containment cooling train starts rn accordance automatically on an actual or simulated with the actuation signal. Surveillance Frequency Control Program SR 3.6.6 .8 Verify each spray nozzle is unobstructed . Foll owing maintenance that could 1 result in

• • • • • • • • • • • ---***-"""'"*******v*-*-************"'~"-;.-~--* - -'**----- .......-*-*

t nozzle blockage SR 3.6.6.9 Verify containment spray locations 3t-deys-susceptible to gas accumulation are I\

sufficiently filled with water.

-=. . r:Mlt!,,,.,w :t:$$SS4),,, g w n.......a:.mzt::::::llC:3li

__J in accordance with the Surveillance

!Frequency Control Program CALVERT CL IF FS - UNIT l 3. 6.6-4  !\mendment No . 31 4 CALVERT CLI FFS - UNIT 2 Amendment No. 292

SOC and Coolant Circulation-High Water Level 3.9.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.9.4.2 Verify required SDC loop locations susceptible to gas accumu1ation are sufficiently filled with water.

In accordance with

~~ . he Surveillance

!Frequency Control Program CALVERT CLIFFS - UNIT 1 3.9.4-4 Amendment No. 313 CALVERT CLIFFS - UNIT 2 Amendment No. 291

SOC and Coolant Circulation-Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

- - - *--- * - - - - - *--~----------------+-

SR 3.9.5.4 Verify SOC loop locations susceptible to gas 3+ da-ys-accumulation are sufficiently filled with water.

.s:t--==:;;;:;;;;:::cw;;c:: ==***e===r-e=*~--- rt In accordance with the Surveillance Frequency Control Program CALVERT CLIFFS - UNIT l 3.9.5-5 Amendment No. 314 CALVERT CLIFFS - UNIT 2 Amendment No. 292

ATTACHMENT 3 MARKED-UP TECHNICAL SPECIFICATIONS BASES PAGES

RCS Loops - MODE 4 B .3. 4.6 BASES SDC System locations susceptible to gas accumulation are monitored and, if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radioiogical or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring t he susceptible locations and trending cf the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

CALVERT CLIFFS - UNITS 1 &2 B 3.4.6-6 Revision XX

RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES SOC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mecharrl sms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

REFEREN ES None CALVERT CLIFFS - UNITS 1 &2 B 3.4.7-7 Revision XX

RCS Loops - NOOE 5, Loops Not Filled 8 3.4.8 BASES locations and trending of the results should be sufficient to assure system OPERABILlTY during the Surveillance i nterva 1 .

REFERENCES

---**--***-~-

CALVERT CLIFFS - UNITS l &2 B 3.4.8-5 Revision XX

ECCS - Operating 8 3.5.2 BASES subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e .g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

~~,e~

/~~the t.CCS p1p1ng and the

/~~r~l;;;§91=1:~1s~ s~~* --- *** *-*-*-*-******

REFERENCES~ 1. UFSAR 1 2. 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Sys tems for Light \~ater Nuclear PovJer Plants"

3. Nuclear Regulatory Commission Memorandum ta V. Steno, Jr., from R. L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components,u December l, 1975

4. Inspection and Enforcement Information Notice No. 87 -01, "RHR Valve Misal ignment Causes Degradation of ECCS i n Pt~Rs," January 6, 1987

• .¥- .~ . ....:::::::::~*."::.~:::.~-==-.-:::::::::::.==-~ . _*::::.*=

~:~=~~~-:;:~~~~

~ -TL.. Sur~ o Iknu_. \="re~ u-<M-'-'j Car.k \ \)~~

---"-~'--"'---~"---*"--*"'"__,___ __ .....___)--

CALVERT CLIFFS - UNITS l &2 B 3.5 .2-10 f~e vi s1on XX

Containment Spray and Cooling Systems 8 3.6.6 8.1\SES system configuration, such as stand-by versus operating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e .* the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Survei 11 ance interval.

SOC and Coolant Circulation-High Water Level 8 3.9.4 BASES ---------------****-***--------*------*---------

can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The SOC System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the SOC System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

SOC System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path 1t1hich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety.

For these locations alternative methods (e.g., operating parameters. remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillijnce interval.

CAL VERT CL F Revision XX

SOC and Coolant Circulation - Low Water Leve l B 3. 9. 5 BASES conditions, the plant configu ration, or personnel safety.

For these locations alternative methods {e.g .* operating parameters, remote monitoring) may be used t o monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to as sure system OPERABILJTY during the Su rveillance i nterval.

CALVERT CLIFFS - UNITS 1 &2 B 3.9.5-7 Revision XX