ML20090C466
| ML20090C466 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/28/1992 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20090C469 | List: |
| References | |
| NUDOCS 9203050047 | |
| Download: ML20090C466 (14) | |
Text
, o .a BALTIMORE GAS AND ELECTRIC 1650 CALVERT CUFFS PARKWAY
- LUSBY, MARYLAND 20657-4702 Gronot C. CnccL vict PassiotwT NCLEan[winov teio)aso-eeas 1 ebruary 28,1992 U. S. Nuclear Regulatory Commission Washington, DC 20555 KITENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant '
. Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Revision to Reauest for License Amendment
REFERENCE:
(a) Letter from hir. G. C. Creel (BG&E) to NRC Document Control Desk, dated h1 arch 28,1991 Gentlemen:
By letter dated h1 arch 28,1991, Baltimore Gas & Electric Company requested an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos. I and 2. The amendment was noticed in the Federal Register on hiay 1,1991 (FR 20028). The amendment requests editorial changes and administrative corrections to the Licenses and Technical Specifications for Unit Nos. I and 2. The attachment to our h1 arch 28,1991 submittal is superseded by the attachments of this letter. This letter describes additional administrative corrections requested by this amendment. For clarity, all requested changes are described below with the cow items denoted with an asterisk.
The editorial changes made throughout the Licenses and Technical Specifications for both Units will encompass the following items:
+ hiake all pages Unit specific
+ hiake all pages single-sided -
+ Remove all intentionally blank pages
+ Renumber pages which are alpha-numeric g DF
[
+ Place Defined Terms (Section 1.0)in alphabetical order pd
+ Capitalize the first letter of system names
+ Rename the "Index" to the " Table of Contents" g\6 9203050047 920228 PDR % \
k P ADOCK 05000317 1 PDR Q. .. .. . ..
Document Control Desk February 28,1992 Page 2
+ Add numbers to the LCO titles so that they are consistent with the Table of Contents
+ Renumber the Figures and Tables so that they are in numerical order and change references accordingly
- Correct obvious typographical errors
- Remove outdated footnotes (see Attachment 1)
In addition to the editorial changes, .nis amendment will make several administrative corrections.
These were determined to be administrative in nature after being researched to ensure that they do not constitute a substantive change to the Technical SpeciGcations. The requested corrections are bric0y described below with the detailed justification discussed in Attachment (2) to this letter.
1.* Facility Operating License (Unit 1) Delete the requirement for an " Optimum Cooling Tower System" from the license.
2.' Facility Operating License (Unit 2) Delete the " Incomplete Construction items, Tests and Other items" requirements from the license.
3.* Facility Operating License (Unit 2) Delete the " Additional Reactivity and Power Distribution Surveillance" from the license.
- 4. Table 2.2-1 (Units 1 & 2) Correct the typographical error which changed the units for the Thermal Margin / Low Pressure Allowable Value Limit from "psla" to "psig".
- 5. Bases 2.1.2 (Unit 1) Correct the typographical error which transp, sed the hydratest pressure for the Reactor Coolar.t System from "3125 psia" to "3215 psia" in Bases 2.1.2.
6.' Bases 2.1.2 (Units 1 & 2) Correct the reference to ANSI Mi.7 fmm 1969 to 1968.
- 7. Section 3/4.1.1.1 (Units 1 & 2) Reinsert the asterisk (*) that provides application of the footnote in 3/,.1.1.1 to each of the three references to "the limit line of Figure 3.1.1 1".
- 8. Specification 4.1.1.1.1 (Unit i) Add the word "line" after limit in this Surveillance Requirement.
- 9. Table 3.3-3 (Unit 2) Make a more complete entry for Auxiliary Feedwater Actuation System of Table 3.3-3.
- 10. Table 33-5 (Unit 2) Reinsert note (1) of Table 33-5 as referenced by Item 4.a of the Table.
L _ _ _ _ _ _ _ _ _ _ _ _ _ __
)
Document Control Desk February 28,1992 Page 3 Correct the typographical error which changed the
- 11. Table 3.3-6 (Units 1 & 2) setpoint of the Containment 1 solation Area Radiation hionitor from 220 m 200 mr/hr in Table 3.3 6.
hiake
- Seismic Acceleration Recorder" t
- 12. Table 4.3-4 (Units 1 & 2) item 3.
These 13 Table 3.3-11 (Units 1 & 2)
Correct transcription errors m Tabk 3.3 numbers, and a duplicate .isting.
14.* Table 3.311 (Unit 1)
Change the name of the insimment
.^Jea".
Change the name of the instrument location for Room Table 3.3-11 (Unit 1) Numbers 586-590,592,593,595-597,521, and 523, 15.*
Add isolation theValves isolation times associated for Penetration with Co 1 A in Table 3.6-1,
- 16. Table 3.61 (Unit 2)
Renumber the Surveillance Requirement 4.6.5.1 17.
Specification 4.6.5.1 (Units 1 &4.6.5.2
- 2) to 4.6.5.1.1 and 4.6.5.1.2.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD 18.
Specification 3.7.1.1.a (Unit 1) Reinsert the phrase "nextS11UTDOWN v.ithin 3.7.1.1.a.
Correct references to Surveillance Requirements.
- 19. Section 3/4.7.8 (Unit 1) and 3.7.11.5.b before the Place items 3.7.11.5.a 20.* Specification 3.7.11.5 (Units 1 & 2) Applicability statement.
Add the "1.52" to a reference to Regulatory Guide Specification 4.9.12.c (Units 1 & 2) Program" to
- 21. title "htonitoring Restore the Section 3/4.12.1 (Units 1 & 2) LCO 3/4.12.1, 22.
Delete duplicate, incorrect Bases text.
Bases 3/4.2.2,3/4.2.3, 23.
3/4.2.4 (Unit 1)
Remove Bases for deleted~ LCO 55 to 3.7.1.6
- 24. Bases 3/4.7.1.5 (Units 1 & 2) "A" of 10 CFR Part Change Appendix
- 25. Specification 6.4.1 (Units 1 & 2)10 CFR 55.59(c).
Change the name of the individual responsible 26.* Specification 6.4.2 (Units 1 & 2)Fire Brigade Training Program.
~~ -
Document Control Desk February 28,1992 Page 4
- 27. Specification 6.5.4.2 (Unit 2) Add phrase "and shall collectively have expertise in all of the areas of 6.5.4.1" to the last sentence of 6.5,4.2.
- 28. Specification 6.10.2 (Units 1 & 2) Delete 6.10.2 Item 1, as it refers to requirements for Records of Environmental Qualification which no longer exist in Technical Specifications.
I'llOCESS In order to improve the quality of the Technical Specifications, a third party was contracted to retype the entire document (Licenses and Technical Specifications) and verify its accuracy. Attachment (3) -
is their certification that the document is an accurate retyping of the BG&E-supplied Technical Specifications. Additionally Attachment (3) outlines the process used to generate the document and verify its accuracy.
To further ensure the accuracy of this retyping, BG&E performed a 100% verification of the equations, numerical values, graphs, scientific notation, and the text after the third party certification.
I CAMERA READY PAGES-Attachments (4) and (5) to this letter contain the camera ready pages for Units 1 and 2, respectively.
As the entire License and Technical Specifications for both Units are being transmitted, we have placed the new Amendment numbers on the pages. All other Amendment numbers have been removed.
DETERMINATION OF SIGNIFICANT IIA 7ARDS This revision will have no impact on the proposed determination of significant hazards considerations submitted in Reference (a). The basis for this conclusion rests on the fact that the additional items are administrative in nature and do not constitute a substantive . change to the Technical Specifications. Given this, our decision to include these items in the License Amendment request is consistent with the previous approach. Therefore, the significant hazards analysis proposed in Reference (a) remains valid.
L.
(,* l Document Control Desk February 28,1992 Page5 ,
Should you have any questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, f,, , /'
0/l I for G C. Creel Vice President - Nuclear Energy STATE OF MARYLAND :
TO WIT :
COUNTY OF CALVERT :
I hereby certify that on the 28 day of hruarC/ ,1992 me, the subscriber,
__Pa /ver, b f cunN a Notary Public of the State of Maryland in and for' .
personally appeared Christian 11. Poindexter, being duly sworn, and states that he is Vfee Chairman of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing information for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, mformation, and belief; and that he was authorized to provide the information on behalf of said Corporation. ,
WITNESS my Hand and Notarial Scal: bc Notary Public My Commission Expires: f zdua&,/ M /hf Datt GCC/LMD/Imd/ dim Attachments: (1) Deleted Footnotes (2) Administrative Corrections (3) Third Party Certification Letter
~(4) Camera Ready Technical Specification Pages Unit 1 (5) Camera. Ready Technical Specification Pages - Unit 2 cc: Without Attachments D. A. Brune, Esquire J. E. Silberg, Esquire l R. A. Capta, NRC D. G. Mcdonald, Jr., NRC l T. T. Martin, NRC
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I,^ l ATTACllMENT (1) 1)ELETED FOOTNOTES
- 1. Specification 4.4.10.1.1 (Unit 1 and 2)
Delete the time requirement for RCP flywhcci inspection for the first Mservice Inspection as it is no longer applicable.
- 2. Specification 4.7.8.1 (Unit 1 and 2)
Delete the footnote for Steam Generator Snubbers 1-63-1.1 through 1-63-28 as it is no longer applicable.
- 3. Bases 3/4.1.2 and 3/4.1.3 (Units 1 and 2)
Delete the footnote referring to the NRC letter revision date of 9/11/91 as it has been superseded.
- 4. Bases 3/4.2.1 (Units 1 and 2)
Delete the footnote referring to the NRC letter revision date of 7/18/91 as it has been superseded.
- 5. Bases 3/4.2.5 (Unit 1)
Delete the footnote referring to the NRC letter revision of date of 5/23N0 as it has been superseded.
- 6. Bases 3/4.6.1.4,3/4.6.1.7 and 3/4.6.2.2 (Units 1 and 2).
. Delete the footnote referring to the NRC letter revision of date of 5/23/90 as it has
! been superseded.
l
- 7. Specification 6.1 and 6.2 (Units 1 and 2)
Delete the page . replacement - footnote as this page was updated with Amendments 161/141 and it is no longer applicable.
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1 ATI'ACIIMENT (2)
ADMINISTRATLVE COllRECTIONS 1.* Facility Operating License (Unit 1)
The current Facility Operating License has a requirement for BO&E to com preliminary design and engineering work to select an optimum cooling tow prior to exceeding 60% power in the initial plant startup. This item has completed J anuary 30,1975.
and was documented in a letter from BG&E to requirement for the cooling tower study be removed from the Facility O License.
2.* Facility OperatingLicense (Unit 2)
The current Facility Operating License has a requirem operation of the facility in specified modes or beyond specified h dates. There test items and one inspection item regarding snubbers which fall into t ese categories. All three items were completed and documented in letters to BG&E (December 3,1976, and January 28,1977). Consequently, BG items have been met.
" Incomplete Construction items, Tests and Other Items
- be removed from license.
3.* Facility Operating License (Unit 2)
The current Facility Operating License has a requirement to perform an additio reactivity and power distribution surveillance prior to September 9,1977. As this license requirement has removed from the license.
- 4. Table 2.2-1 (Units 1 & 2)
Technical Specification Table 2.2-1, item 9.a, indicate 1875 "psla" to be consistent with the Bases for this section. The discrepanc limit in question was apparently inserted by Amendment Nos. 71 and 61 fo and 2, respectively. The submittal did not request a char,ge to the limit in qu but did identify that a change to the Bases was needed. This change was disc the NRC Safety Evaluation Report for Amendments 71 and identified as 1875 psia.
amendment, Baltimore Gas and Electric Company (BG&E) requests that the corr trip setpoint limit of 1875 psia be inserted into Table 2.21.
r a ATTACilh1ENT (?J Al)N11NISTRATIVE CORRECTIONS
- 10. Table 3.3 5 (Unit 2)
Footnote (1) in Technical Specification Table 3.3 5, as applied to item 4.a in Amendment Nos. 54 and 37 for Un.91 and 2, respectively, was inadvertently omitted from a subsequent Unit 2 request for amendment. 'Ihis request was approve 41, with the error, as Unit 2 Amendment N1. 61. The error in reference resulted from the incorrect use of an outdated version of the affected page in developing a markup.
Later submittals also failed to identify the missing footnoic. Item 4.a continues to reference the footnote and it is needed in the table. Since no basis exists for the omission, BG&E requests that Table 3.3 5 he corrected by reinserting the footnote.
- 11. Table 3.3-6 (Units 1 & 2)
In Technical Specification Table 3.3-6 the Alarmffrip Setpoint for item 1.a.i is currently given as 200 mr/hr. The correct Setpoint is 220 mr/hr. It was determined that this trip setpoint was correctly issued in Amendment Nos. 99 and 81 for Units 1 and 2, respectively, llowever, other discrepancies were identified within that amendment for Table 3.3-6 which were subsequently corrected. When the corrected pages were issed to address the other discrepancies, the setpoint for item 1.a.i was madvertently listed as 200 mr/hr. Since no basis exists for this discrepancy, BG&E l requests that item 1.a.i in Table 3.3-6 be restored to the correct tnp setpoint of l 220 mr/hr, as approved by Amendment Nos. 99 and 81.
- 12. i Table 4.3 4 (Units 1 & 2) i Item 3 under INSTRUh1ENTS AND SENSOR ~ LOCATIONS (Table 4.3 4) has never had a title. All other information under INSTRUh1ENTS : AND SENSOR LOCATIONS in this table is identical to that in Table 3.3-7.' It is clear from comparing the two tables that Item 3 of Table 4.3-4 should have the title ' Seismic Acceleration Recorder." BO&E requests that the title be added to this table for both units. l J
- 13. Table 3.3-11 (Units 1 & 2)
Technical Specification Table 3.';-11 currently lists information which is contrary to actual plant configuration. This information includes an incorrect room number
' (106 should be 116 for Unit 1), transposed detector numbers (Room 111 should have O FLAh1E and 1 Sh10KE detector, while Rooms 112/114 shor* I have 4 FLAh1E and 0 Sh10KE detectors), and a duplicate listing (Room 113 is Unit 1 only; delete from
- ~ Unit 2 list). The information was correctly listed in the amendment requests, but was -
apparently incorrectly . transferred with the pages provided for issuance of Amendment Nos.109 and 92 for Units 1 and 2, respectively. Since no basis exists for this discrepancy, BG&E requests that the Technical Specifications be corrected to !
reficet the table listings as originally requested.
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3 .j i
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NfTACilMENT (2] j Al)MINISTRATIVE CORRECTIONS
- 14.
- Table 3.311 (Unit 1)
Technical Specification Table 3.311 currently lists Room 224 as the "12 MSIV Hyd Area." This name is inconsistent with the listing in the Alarm Manual and plant practice. This manual refers to Room 224 as the " East Piping Area". To provide consistency between the Technical Specifications and the Alarm Manual and plant practice, DG&E requests that the name be changed to " East Piping Area."
- 15.
- Table 3.3-11 (Unit 1)
Technical Specif!:eion Table 3.311 currently lists 20 smoke detectors for the Radiation Chemistry area (Rooms 586-590, 592, 593, 595 597) and the corridors (Rooms 521, 523). The room numbers and instrument location names are not consistent with the actual locations in the Auxiliary Building. The location of the instruments has not changed.
The area was refurbished and ths. Technical Specifications do not reflect the current room numbers and names. In order to correctly reRect this area of the Auxiliary Building in the Fire Detection Instrument Table, BG&E requests that the room numbers and instrument location names be changed.
16.
Table 3.6-1 (Unit 2) t I
The isolation times associated with Containment Isolation Valves for Penetra in Technical Specification Table 3.6-1 were inadvertently omitted in Amendment 47 for Unit 2. The values were correctly listed in the amendment request but were apparently not transferred with the pages provided for issuance of the amendment.
Since no basis exists for this omission, BG&E requests that the isolation time values for Penetration 1 A be included in the Table 3.6-1 to correctly reRect the Table values as originally requested.
17.
Specification 4.6.5.1 (Units 1 & 2)
The original request for Amendment Nos.109 and 92 for Units 1 and 2, respectively called for the Sun eillance Requirements for the Limiting Condition for O)eration 3.6.5.1 to be numbered as 4.6.5.1 and 4.6.5.2. However, this numbering sc Teme causes confusion as the Surveillance Requirement for LCO 3.6.5.2 is also numbered 4.6.5.2. In other words, there are currently two Surveillance Requirements numbered 4.6.5.2. In order to climinate possible confusion, BG&E requests that the Surveillance Requirements for LCO 3.6.5.1 be renumbered to 4.6.5.1.1 and 4.6.5.1.2.
18.
Specification 3.7.1.1.a (Unit 1)
Unit 1 Technical Specification Action statement 3.7.1.1.a and the corresponding Unit 2 Technical Specification provide specific actions to be taken with main steam line code safety valves inoperable. Unit 2 Action statement 3.7.1.1.a concludes with "otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD 4
---______m_______.m________m._. _ _ _ . _
1-ATTARIMENT (?J ADMINISTRATIVE CORRECrlONS
- 5. Bases 2.1.2 (Unit 1)
Unit 1 Technical Specification Bases 2.1.2 currently states that the " entire RCS is hydrotested at 3215 psia." The correct pressure is 3125 psia. With the issuance of Amendment 130 (Unit 1) this number was transposed from 3125 psia to 3215 psia.
Since that amendment request did not invo've this area and no bases exists for this change in pressure, BG&E requests that the pressure be restored to show the correct pressure as it appeared prior to Amendment 130, 6.* Bases 2.1.2 (Units 1 & 2)
Technical Specification Bases 2.1.2 (Units 1 & 2) current!j states that " tlc Reactor Coolant System piping, valves, and fittings are designed to ANSI B31.7, Class I,1969 edition." The Reactor Coolant System piping, valves, and fittings are designed and built to the 1968 draft edition of this standard as - referenced in CE Specification 8067 31-5 and CENC 1179. The bases have referenced the incorrect year since the Technical Specifications were originally approved. Since no basis exists for this discrepancy, BG&E requests that the reference year for this standard be changed to 1968.
- 7. Section 3/4.1.1.1 (Units 1 & 2)
Three references to Footnote
- in the Limiting Condition for Operation and Surveillance Requirements for Technical Specification 3/4.1.1.1 were inadvertently omitted from the final pages which were issued with Amendment Nos.130 and 123 for Units 1 and 2, respectively, The footnote remains on Technical Specification page 3/41-1 and continues to be applicable to the Technical S 3ecification. Since no basis exists for the omission, BG&E . requests t iat the- Technical Specification 3/4.1.1,1 be corrected to reflect correct references to the footnote.
- 8. Specification 4.1.1.1.1 (Unit 1)
The word "line" in the first sentence of Surveillance Requirement 4.1.1.1.1 was inadvertently omitted in Amendment No.130 for Unit 1. The word was included in the amendment request but was apparently not transferred to the final pages issued with the amendment. Since no basis exists for this omission, BG&E requests that the word "line" be placed in the Surveillance Requirement as originally requested.
- 9. Table 3.3-3 (Unit 2)
Unit 2 Technical Specification Table 3.3-3,-itert 9 and 9.a were not correctly.
transposed from the amendment request - to the amendment. . The amendment --
request changed the values within the table itself, however upon issuance of the amendment, the phrase " Actuation System" was not included in item 9 and the term
"(Trip Buttons)" was not included on item 9.a. As there is no basis for the omission of -
these items from Table 3.3-3, BG&E requests that items 9 and 9.a be returned to their pre amendment terminology. Additionally, the acronym "AFAS" should be included in the Unit 2 table to be consistent with Unit 1.
2
NITAcilMENT W ADMINISTRATIVE COltitECI'lONS SilUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." llowever, Unit i eurrently concludes this Action statement with "otherwise, be in at least !!OT STANDBY within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." Research into the reason for this discrepancy found that prior to Amendment No.104 (Unit 1) these two Action statements were similarly worded.
Amendment No.104 requested a changa to this page but did not affect the Action statement of concern. The new page provided with the amendment omitted the phrgn: *next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SIIUTDOWN within the". This apparently was an error in transcription. Since no basis exists for the discrepancy, BG&E requests thai Unh 1 Technical Specification Action statement 3.7.1.1.a be restored to its pre-Amendmem No.104 wording.
- 19. Scction 3/4.7.8 (Unit 1)
The Action requirement for Technical Specification 3.7.8.1 references Specification 4.7.8.b and c. Specifications 4.7.8.b and e do not exist. Examination of the subjects involved clearly shows that the reference should be to Specifications 4.7.8.1.b and c. Similarly, Surveillance Requirements 4.7.8.1.b and e each contain reference to Specification 4i7.8.d, which should be 4.7.8.1.d. These identical changes were made to Calvert Cliffs Unit 2 Technical Specifications by-Amendment No.119 on March 24,1989, included with substantive changes that were specific to Unit 2. Baltimore Gas and Electric Company requests that these references be corrected in the Unit 1 Technical Specifications.
20.* Specification 3.7.11.5 (Units 1 & 2)
Items 3.7.11.5.a and 3.7,11.5.b, now located under the Applicability statement of this Technical Specification. describe the yard fire hydrants and hydrant hose houses which are required to be operable. While the origmal submittal requested that these items be placed here, it is apparent that they should be placed before the Applicability statement. In order to climinate any confusion as to which yard fire hydrants and hydrant hose houses are required to be operable, BG&E re- .ests that items 3.7.11.5.a and 3.7,11.5.b be placed before the Applicability statemcat.
- 21. Specification 4.9.12.c (Units 1 & 2)
Amendment Nos.142 and 125 for Units 1 and 2, respectively, included changes involving in-place testing of IIEPA filters and charcoal adsorbers. The testmg reference was changed from ANSI N510-1975 to certain parts of Regulatory Guide 1.52 in many parts of the Technical Specifications, in the last paragraph of Specification 4.9.12.c, the Regulatory Guide number was inadvertently omitted for both units when final pages were prepared. Baltimore Gas and Electric Company requests that the Regulatory Guide number be added to Specification 4.9.12.c for each unit.
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glTACIIMENT (2)
ADMINISTitATIVE CORRECTIONS
- 22. Section 3/4.12.1 (Units 1 & 2)
The Limiting Condition for Operation title "3/4.12.f. Monitoring Program" was omitted from the issuance of Amendment Nos.105 and 86 for Units 1 and 2, respectively. The title was correctly li3ted on the amendment request but it was apparently not transferred with the pages provided for the issuance of the amendment. Since no basis exists for this omission, BG&E rec luests that the title be included to correctly refer to the Limiting Condition for Operation and to correspond with the Table of Contents.
- 23. Bases 3/4.2.2,3/4.2.3,3/4.2.4 (Unit 1)
The Bases section for Unit 1 Technical Specifications 3/4.2.2, 3/4.2.3, and 3/4.2.4 contalin wording which has been inadvertently duplicated on succeeding pages. This wording had also been inaccurately transferred from page B3/4 2-2 to B3/4 21 in the past. The wording in question was correct when issued as Amendment No.39.
Amendment 104 resulted in this text being transferred from page B3/42 2 to B3/4 2-1. During the transfer, the word "not" was inadvertently inserted into the last paragraph of the current page B3/4 2-1. On September 29,1989, unrelated changes were requested to page B3/4 2 2. These Unit I changes were inappropriately identified in that a Unit 2 page was marked up. The Unit 2 page still contained the wording in question. The Unit 1 Bases revision was subsequently issued resulting in the wording in question being re-inserted on Unit 1 page B3/4 2 2. Tha discrepancy was identified at that time. Since no basis exists for this discrepancy, BG AE requests that the Technical Specification Bases be corrected to delete the duplicated text and' reflect the pre-Amendment No.104 wording.
- 24. Bases 3/4.7.1.6 (Units 1 & 2)
The . Amendment Request, dated July 30,1981, for Amendment Nos. 59 and 41, Units 1 and 2, respectively, requested the deletion of the Limiting Condition for Operation 3.7.1.6 and the Surveillance Requirement 4.7.1.6. However, it neglected to request deletion of the corresponding Bases. Since Limiting Condition for Operation 3.7.1.6 and Surveillance Requirement 4.7.1.6 have been deleted and there is no longer the need for Bases 3/4.7,1.6, BG&E requests that this Bases sectior. be deleted from the Technical Specifications.
- 25. Specification 6,4.1 (Units 1 and 2)
Specification 6.4.1 contains a reference to Appendix "A" of 10 CFR Part 55-Appendix "A" of 10 CFR Part 55 has been changed to 10 CFR 55.59(c), as indicated .
in paragraph (H)(i) of Federal Register notice 52FR9459. Baltimore Gas and Electric Company requests that Specification 6.4.1 be changed accordingly for both units.
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[ 3 NITACIIMENT (M Al)MINISTilATIVE COltitECTIONS
- 26.
- Specification 6.4.2 (Units 1 & 2)
Specification 6.4.2 states that a training program for the Fire Brigade is maintained under the direction of the Supenisor. Planning and Support. The actual person responsib'c for this program is the Manager. Nuclear Safety and Planning Department, Baltimore Gas and Electric Company requests that Specification 6.4.2 be changed to reDect the appropriate person responsible for this item.
- 27. Specification 6.5.4.2 (Unit 2)
Amendment Nos. 43 and 26 for Units 1 and 2, respectively, called for changes to the composition of OSSRC. The entire change was incorporated into the Unit 1 Technical Specification 6.5.4.2. However, a ~ portion of the change ("and shall collectively have expertise in all areas of 6.5.4.1") was not incorporated into the Unit 2 Technical Specification. As no basis exists for this discrepancy, BG&E requests that the missing phrase be included in 6.5.4.2 of Unit 2,
- 28. Specification 6.10.2 (Units 1 & 2)
Amendment Nos.108 and 91 for Units 1 and 2, respectively, deleted Section 6.13
" Environmental Qualification". Section 6.13 contained schedule requirements for completion of activities involving the environmental qualification of electrical 1 equipment important to safety that had already passed. Moreover, emironmental qualification requirements had been incorpora ed in 10 CFR 50.49 and thus did not need to appear in the Technical Specifications. The amendment request neglected to request the deletion of 6.10.2, Item I, which is also' related to environmental qualification and which references paragraph 6.13. The current paragraph 6.13 now contains information regarding " System Integrity". This is obviously referenced incorrectly as "Environmemal- Qualification" through 6.10.2, Item 1. Since 10CFR 50.49(j) duplicates and supersedes this Technical Specification, and to climinate the discrepancy caused by 6.10.2, Item I, BG&E requests that 6.10.2, Item I be deleted.
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E m mu may amm IVi C n C Ms December 10,1991 NrrACIIMENT m Mr. G.C. Creel TlilllD Pall'lY CEl(TIFICATION LETTEll Vice President Nuclear Engineering Division Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Routes 2 & 4, P.O. Box 1536 Lusby, MD 20657
Dear Mr. Crect:
The Technical Specifications for Units 1 and 2 at Calvert Cliffs ve been Nuclear Powe checked for accuracy against the BG&E supplied marked up Technical S to be an accurate retyping. The process by which the documents were generated i d s escribed below.
1.
independent Parallel Text Entry I
These working indocuments parallel. were produced by two independent teams of word proc incorporating the BG&E approved fannat guide, . The the word product consistency. editors proofed the generated text against the orig to the word processor, then the editor.If any corrections were necessmy, the tex complete. This cycle continued until the documents were II. Electronic File Comparison The finished products were then electronically stripped of fonnatting code footers to allow the files to be electronically compared andThis discrepancies id discrepancies, minor corrections were made after complete alignment.
III. Senior Engineering Comparison i
1 hough the likelihood of textual error was almost non-existent at this po additional safeguard A senior engineer familiar with CE plants compar against an original of the Technical Specifications provided by BG&E.
His comparison review in the original specitication data. focused primarily on the ve The amendments were incorporated after the above process an edit was comp changes were enten d. The output was proofed ag request.
MEREX certifies that the product generated through this strenuous proc recreation of the Technical Specifications received from BG&E. ng with It has been a pl you on this project; we look forward to working with you in the future.
Sincerely, i
sy of); O 1+
Richard M. Twomk Managing Din'clor Wit int my he.iand officiel sea [.g b" A b b M Y^ b ^- '
(b
\J N .Ocrww u &w _A MM gh () RC) 3206 Tower Oaks Blvd., Suite 300
- Rockville, MD 20852 + -301/ 04 816-0500 ' FAX: 301/ 816
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