ML20137G775

Forwards Response to RAI Re Section 1.0 of TS Change Request to Convert to Improved TSs

ML20137G775
Person / Time
Site:	Calvert Cliffs
Issue date:	03/27/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M97363, TAC-M97364, NUDOCS 9704010505
Download: ML20137G775 (9)

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Curut.Es II. CRt'sE Baltimore Gas and Electric Company Vice Presiden, Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 410 495-4455 March 27,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

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SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information Regarding the Technical Specification Change Request to Convert to the Improved Technical Specifications for the Calvert Cliffs Nuclear Power Plant. Unit Nos. I and 2

REFERENCE:

(a) Letter from Mr. A. W. Dromerick (NRC) to C. H. Cruse (BGE). Request for Additional Information Regarding the License Amendment Request to Convert to the Improved Technical Specifications for the Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2 (TAC Nos. M97363 and M97364), dated March 27,1997 In the referenced letter you transmitted questions regarding Section 1.0 of our application to convert to the Improved Technical Specifications. Our responses are attached. As we described in our February 4,1997 meeting, Baltimore Gas and Electric Company is currently preparing a supplement to the license amendment request. Changes to our application described in the responses will be reflected in that supplement.

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Document Control Desk March 27,1997

.. Page2 Should you have questions, please contact Brian Mann at (410) 495-6517.  !

Very truly yours,

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STATE OF MARYLAND  :

TO WIT:

COUNTY OF CALVERT  :

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I, Charles H. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, l Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this response on behalf of BGE. To the best of my knowledge and belief, the statements contained in this docun,ent are true and correct. To the extent that these statements are not based on my personal '

knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company y 'c and I beli to be reliable.

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i Subsc[ibed and sworn before me, a Notary Public in and for the State of Maryland and County of (a/verf ,this 27 day of 77/a<cA - .1997.

WITNESS my Hand and Notarial Seal: -

Notary Public  !

My Commission Expires: 2 d(2% . 8 l Ipte CHC/BDM/ dim

Attachment:

(1) Conversion to Improved Technical Specifications; NRC Comments - Section 1.1 cc: D. A. Brune, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC ,

Director, Project Directorate 1-1, NRC R.1. McLean, DNR 1 A. W. Dromerick, NRC J. H. Walter, PSC j

ATTACHMENT m CALVERT CLIFFS NUCLEAR POWER PLANT CONVERSION TO IMPROVED TECIINICAL SPECIFICATIONS NRC COMMENTS - SECTION I.I I.1-01 DOC L.6 [ Discussion ofChange]

Definition of Channel Calibration

. DOC A.6

, Definition of Channel Functional Test TSTF-64

TSTF-64 is meant to clarify the applicability of Channel Calibration and Channel Functional Test by replacing the STS [ Standard TechnicalSpecylcations] words, l

"He Channel Calibration shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the Channel Fonctional i

Test."

"The Channel Functional Test may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested."

with the following:

i "The Channel Calibration shall encompass those components, such as sensors, alarms, displays, and trip functions, required to perform the specified safety J

function (s). The Channel Calibration shall include the Channel Functional Test." -

"He Channel Functional Test may be performed by means of any series of I sequential, overlapping, or total channel steps so that all components in the channai, such as sensors, alarms, displays, and trip functions, required to perform the specified safety function (s) are tested."

As discussed in DOCS L.6 and A.6, respectively, the CTS [ Current Technical Specifications]

wording is changed to the TSTF-64 wording.

a. He DOCS do not state why these changes, which may reduce the scope of testing i believed to be required by the CTS definitions, are acceptable from a safety standpoint.

) Revise the DOC with this information.

b. Why is the change less restrictive for Channel Calibration and administrative for the Channel Functional Test?

Note: The TSB [ Technical Specylcation Branch] reviewer rejected TSTF-64 as unnecessary because the existing wording is clear. Final TSB position is pending. If TSTF-64 is rejected, DOCS L.6 and A.6 and the SE [ Safety Evaluation] will require revision.

l BGEResponse: '

i At a meeting between the NRC Technical Specifications Branch and the Nuclear Energy Institute (NEI) j Technical Specifications Task Force (TSTF) on March 18,1997, the NRC described problems with the current definitions of Channel Calibration and Channel Functional Test. Proposed new definitions were 4

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ATTACHMENT (1)

. , CALVERT CLIFFS NUCLEAR POWER PLANT CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS NRC COMMENTS - SECTION 1.1 put forward by the NRC, and the TSTF agreed to study the proposed definitions and generate generic change travelers to address the concerns. The NRC's proposed new definition will eliminate the ambiguity that TSTF-64 was crafted to correct. Once these new definitions have been developed and accepted by the industry, Baltimore Gas and Electric Company (BGE) will submit a supplement to the application to adopt these new definitions, including any appropriate justifications and descriptions of changes.

1.1-02 DOC LA.1 Definition of Axial Shape Index

'Ihe definition used for trip and pretrip signals in the reactor protective system is removed from the CTS definition of Axial Shape Index.

(a) The new location and regulation controlling future changes are stated ambiguously.

Revise the DOC to be specific.

(b) The DOC does not state why this definition is not necessary to be retained as part of the definition of Axial Shape Index. Revise the DOC with this information.

BGE Resnonse; (a) and (b)- Baltimore Gas and Electric Company will revise DOC LA.1 in our supplement as follows:

The CTS definition of Axial Shape Index contains a discussion of the trip and pretrip signals used by the Axial Power Distribution - High Reactor Protective System trip.

This information is being deleted from the definition. Axial Shape Index, as used in the Technical Specifications, is adequately defined with the remaining information. The  ;

information on the calculation of trip and pretrip values is not needed to use and understand Axial Shape Index as it appears in the Technical Specifications and is )

inconsistent with the type ofinformation contained in other definitions. In addition, the l information is insufficient to determine trip or pretrip values as the discussion refers to "a constant" and "a multiplier" without describing these values, their calculation, or their location. Information on trip values is located in Specifications 3.3.1, RPS l Instrumentation - Operating,3.3.2, RPS Instrumentation - Shutdown, and their respective Bases. Information on pretrip values is located in the Updated Final Safety Analysis Report. Therefore, this information is location in other, more appropriate, locations. As this information is not needed in the definition section, it is being deleted. This change is consistent with NUREG-1432.

1.1-03 Not Used 2

ATTACHMENT (1)

CALVERT CLIFFS NUCLEAR POWER PLANT CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS NRC COMMENTS - SECTION 1.1 1.1-04 TSTF-19 ITS (Improved Technical Specifications] Definition of Channel Calibration STS Definition of Channel Calibration TSTF-19 proposed to remove the STS wording -

"Whenever a sensing element is replaced, the next required Channel Calibration shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element."

In the Vogtle SE, these words were not adopted. This difference was discussed in the SE as follows:

"The licensee proposed to omit from the Channel Calibration definition the language in the STS definition regarding the method of calibrating temperature sensing elements (resistance temperature detectors (RTDs) and thermocouples) because it is not part of the CTS definition.

The existing definition of Channel Calibration does require calibration of the sensors, but does not specify the technique for calibrating RTDs or thermocouples.

Whether the RTDs or thermocouples are calibrated using cross calibration techniques (as specified in the STS definition) or bath immersion (used by the licensee)is considered by the licensee to be irrelevant to the definition. The licensee considers both techniques equally valid, and thus concludes it is sufficient for the purpose of the definition to simply require that they be calibrated.

This difference is based on maintaining the flexibility of the existing definition and the licensee's decision not to backfit the STS language in question. Because the proposed definition is consistent with the current requirement, this difference is acceptable."

The TSB approved TSTF-19 with modifications. NEI approval is pending. The ITS definition adopts TSTF-19 as it was proposed. Since the CTS definition does not have the STS wording proposed for removal, CTS are not affected by this TSTF. The JFD [Justificationfor Di[ference) section of safety evaluation may need revising based on final accepted version of TSTF-19. If TSTF-19 is rejected, then a JFD, similar to the excerpt from the Vogtle SE, must be added to the submittal.

BGE Responset The TSTF submitted a revision to TSTF-19 to the NRC on March 28,1997, containing the requested modifications. Those modifications to TSTF-19 are also incorporated into the BGE supplement being prepared. 'Iherefore, BGE's supplement will reflect TSTF-19 with the modifications requested by the NRC.

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CALVERT CLIFFS NUCLEAR POWER PLANT l

CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS  !

NRC COMMENTS - SECTION I.1 l 1.1-05 DOC A.16 i D:finition of ESFAS Response Time l

Definition of Reactor Protective System Response Time l The ITS definitions, consistent with the STS, contain the allowance "The response time may be l measured by means of any series of sequential, overlapping, or total steps so that the entire '

l response time is measured." Neither the CTS response time surveillance requirements (4.3.1.1.3  !

and 4.3.2.1.3) nor the CTS definitions contain this allowance. Although it may be current plant i practice to perform testing in this manner, explicitly adding it to the definitions is less restrictive.  !

Redesignate the change as less restrictive and add appropriate additionaljustification. l l

BERessmnsel Baltimore Gas and Electric Company will change the justification from Administrative to Less  ;

Restrictive in our upcoming supplement. The new DOC will state:

The proposed change adds an allowance to the definitions of ESFAS Response Time and Reactor Protective System Response Time to allow response time measurement to be '

performed by means of any series of sequential, overlapping, or total steps. This explicit allowance is consistent with Calvert Cliffs current practice. This is appropriate as the  ;

safety analyses rely upon a total response time from event to response. Summing the response of portions of the circuit is adequate te verify that the total response time is within the value assumed in the afety analysis. Therefore, the safety ftmetion of the systems continues to be verified. This change is consistent with NUREG-1432.

1.1-06 DOC A.14 JFD.5 CTS Table 1.1 Note "

ITS Table 1.1-1 Note (b)

STS Table 1.1-1 Notes (b) and (c)

Definition of Mode 6, Refueling Definition of Mode TSTF-88 The CTS Note " defines Mode 6, in part, as when the reactor vessel head is " unbolted," but does not specify how many closure bolts must be tensioned for the reactor vessel head to be

" bolted;" i.e., adequately seated in Modes 4 and 5 (vessel pressure s 500 psia). According to JFD.5, Calvert Cliffs has an analysis that shows 12 bolts must be tensioned, but 18 are required by plant procedure. Thus, by procedure, if s 17 bolts are tensioned, the reactor vessel head is considered to be " unbolted" and the plant is in Mode 6, Refueling. By contrast, STS Note (b) l requires all bolts to be fully tensioned in Modes 4 and 5, and Note (c) defines Refueling as when l one or more bolts are less than fully tensioned.

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ATTACHMENT m

. . CALVEP.T CLIFFS NUCLEAR POWER PLANT CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS NRC COMMENTS - SECTION 1.1

a. For consistency viith the STS and most other plants, but consistent with the existing requirements, Cahert Cliffs should adopt STS Notes (b) and (c) with appropriate I modifications to reflect the number of bolts now required by plant procedures to be tensioned for the head to be " bolted," such as:

Suggested Note (b) The 18 or more reactor vessel head closure bolts required for bolting )

the reactor vessel head in Modes 4 and 5 are fully tensioned. I Suggested Note (c) Reactor vessel head unbolted.

b. Ilow many bolts must be tensioned for Modes 1,2, and 3 and for pressure above 500 psia? If the answer is "all," then it is suggested that a note be added for these modes in ITS Table 1.1-1, as follows:

1 All reactor vessel head closure bolts fully tensioned.

c. For consistency with the STS and the above suggestions, the proposed wording " bolting" in the definition of Mode, should be changed to the STS wording " closure bolt tensioning."

BGE Responsci

a. Baltimore Gas and Electric Company disagrees that a change to the Calvert Cliffs current treatment of reactor vessel head bolting in the Mode table is necessary. The proposed Mode table conditions for entry and exit from Modes 5 and 6 are consistent with the Calvert Cliffs CTS, in which the number of reactor vessel head closure bolts is not specified in the Technical i l

Specifications. Maintaining the specifics of reactor vessel head bolting as related to Mode 5 and 6 entry conditions in plant operating procedures has not presented problems for BGE in the past, and we see no safety concern with continuing to maintain that information outside of the Technical Specifications after adoption of the ITS.

Baltimore Gas and Electric Company has voluntarily adopted many new requirements in our ITS license amendment when those requirements were needed for consistency or completeness.

However, there are no differences between the CTS and ITS Mode table that lead us to believe that the additional information regarding reactor vessel head bolting is needed for internal consistency in the Specifications or completeness of the requirements.

Therefore, we chose to retain our currect licensing basis in this matter.

b. You suggested that we specify the number of reactor vessel head closure bolts required in Modes 1,2, and 3 in the Mode table. This would be inconsistent with NUREG-1432, which only specifies reactor vessel head closure bolt requirements in Modes 4, 5, and 6. The implied requirement in NUREG-1432, and in the proposed Calvert Cliffs ITS, is that the number of bolts required by the plant design will be installed and tensioned. Therefore, we believe that the proposed change would be inappropriate.

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ATTACHMENT (1)

CALVERT CLIFFS NUCLEAR POWER PLANT CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS NRC COMMENTS - SECTION 1.1

c. We agree that the proposed use of the ecord " bolting" in the Mode definition is poor English usage. However, the suggested use of Mensioning" is ksippropriate in that " tensioning" is not j used in the Calvert Cliffs Mode table. Therefore, we will change " bolting" to " closure bolts" m  :

our supplement.

i 1.1-07 DOC L.3 DOC A.15  ;

STS & ITS Definition of Staggered Test Basis Calvert Cliffs' interpretation of the STS definition of Staggered Test Basis given in DOC L.3 is the following:

"The CTS definition of Staggered Test Basis requires that components tested on a Staggered Test Basis be performed in equel subintervals (e.g., CTS: 3 Control  !

Room Emergency Filtration System fans required to be tested every 92 days on a Staggered Test Basis would require one fan to be tested once per 31 days) The proposed change would delete the requirement to test each component in equal subintervals (e.g., ITS: 3 Control Room Emergency Filtration System fans required to be tested every 31 days on a Staggered Test Basis would require all three fans to be tested within a 92-day period with the interval between components not ,

specified). However, the interval between components should be such that the I intent of staggering is satisfied. The purpose of staggered testing is to ensure that common failures due to testing do not render more than one train inoperable. "

Removal of the "n equal subintervals" wording from the CTS definition, as described above, does not mean it has been removed from the intent of the STS definition. The above interpretation is incorrect. Maintaining the equal subintervals is important to allow flexibility, such as the 25% interval extension allowance, while preserving the benefits of staggered testing.

DOC L.3 should be withdrawn and DOC A.15 should be revised to reflect the correct interpretation.

BGELResponse:

In our DOC, we stated that although the phrase "n equal subintervals" was removed from the definition, "the interval between components should be such that the intent of staggering is satisfied." By this we meant that it is the intent, if no longer the explicit requirement, that the intervals be equal. Some variation in the interval is acceptable, but as a good practice equal intervals should be used. Therefore, BGE will revise DOC L.3 in our supplement to replace the sentence, "However, the interval between components should be such that the intent of staggering is satisfied" with "However, the interval between the testing of components should typically be equal."

Baltimore Gas and Electric Company believes that this change should remain an "L" as the words, if not the practice, in the defin: tion have changed to climinate a requirement. This is consistent with the NRC's request in comment 1.1-05, Def'mition of ESFAS Response Time, in which it was stated that 6

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AIIACIIMENT (1)

CALVERT CLIFFS NUCLEAR POWER PLANT CONVERSION TO IMPROVED TECHNICAL SPECIFICATIONS NRC COMMENTS - SECTION 1.1 changing the definition, even if plant practice is not changed, should control whether a change is Administrative or Less Restrictive.

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1.1-08 A.12 STS & ITS Definition of La '

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The STS bracketed value of 25% of containment air weight per day was replaced with 20%. l Where did this value come from? j 1

BGEllesponse; Baltimore Gas and Electric Company's CTS Containment Leakage Rate Testing Program,6.5.6, and the proposed ITS Containment Leakage Rate Testing Program, 5.5.16, both describe L, as 20% of containment air weight per day.

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