ML20140B049
| ML20140B049 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/29/1997 |
| From: | Dromerick A NRC (Affiliation Not Assigned) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| TAC-M97363, TAC-M97364, NUDOCS 9706050283 | |
| Download: ML20140B049 (93) | |
Text
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May 29, 1997 Mr. Charles H. Cruse Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby. MD 20657-4702
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL SPECIFICATIONS FOR THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.
1 AND 2 (TAC NO. M97363 AND M97364)
Dear Mr. Cruse:
On December 4. 1996. Baltimore Gas and Electric Energy (BGE). submitted a license amendment request to convert the Calvert Cliffs Nuclear Power Plant.
Units 1 and 2 Current Technical Specifications to the Improved Technical Specifications (ITS). During the course of our review, we found that we require additional information to complete our evaluation. Please respond to the enclosed request for information (RAI) that seeks to clarify the ITS Sections 3.3.1, 3.3.2: and all of 3.4 and 3.6.
In addition, the staff requests a clear description of all Combustion Engineering Owners Group (CEOG) travelers that did not become Technical Specifications Task Force (TSTF) travelers and a status of all the CEOG travelers. To support the NRC staff's review schedule, your written and electronic response in Wordperfect 5.1 to this RAI is requested within 15 days of the receipt of this letter. Should you have any questions. please do not hesitate to contact me at (301) 415-3473.
Sincerely. !
Original Signed By Alexander W. Dromerick. Senior Project Manager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 ,
l
Enclosure:
RAI NRC F!E CEHER COPY cc w/ encl: See next page l Distribution:
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l Docket File Slittle MLReardon PUBLIC ADromerick OGC PDI-1 Reading CGrimes ACRS ,I SVarga MReinhart LDoerflein. RI DOCUMENT NAME: G:\CC-MAY29.RAI 0FFICE TSB/ADPR l PNJ]ph1 LA:PDI-In() PD:PDi a l NAME MLReardon w zc At r6aferick Slitt F (.7 4VM DATE 5/49/97 5/7)/97 5/ M/97 5/f9/97 L ' UFFICIAL RECORD COPY
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9706050283 970529 PDR ADOCK 05000317 P PDR
Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos. I and 2 cc:
President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland 175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore, MD 21202-6806 James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire 2300 N Street, NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Thomas N. Prichett, Director Baltimore, MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 '
Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. Richard I. McLean t Administrator - Radioecology Department of Natural Resources 580 Taylor Avenue Tawes State Office Building, B3 Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 LA.5 CTS 4.3.1.1.2 requires demonstrating the bypass logic, including the Revise the submittal to 5/20/97 i automatic bypass removal logic Operable prior to each reactor startup, specifically identify the open ,
unless performed during the preceding 92 days. ITS 3.3.1 moves this plant procedures that I requirement to unidentified plant procedures. The justification does contain this requirement not identify the plant procedure that maintains this requirement nor and describe how the specific controls that maintain the requirement in plant changes to it will be '
procedures. controlled.
BGE Response:
2 CTS 4.3.1.1.2 requires demonstrating the Operability of the total Provide discussion and 5/20/97 bypass function during Channel Calibrations of each channel affected justification for this less open by bypass operation. ITS SR 3.3.1.7 requires a Channel Functional restrictive change that Test of only the automatic bypass removal function. The total bypass deletes testing of the function is not demonstrated Operable by the ITS. This less total bypass function.
restrictive change is not justified.
BGE Response:
^
3 LA.2 CTS Table 3.3-1 Notation f, requires at least two decades of overlap Revise the submittal to 5/20/97 between the wide range logarithmic neutron flux monitoring channels specifically identify the open ;
and the power range neutron flux monitoring channels. ITS 3.3.1 plant procedures that moves this detail to unidentified plant procedures. DOC LA.2 does l contain this requirement :
not identify the plant procedure that maintains this requirement nor and descr:be how '
the specific controls that maintain the requirement in plant changes to it will be !
procedures. controlled.
BGE Response: ;
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P CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING '
i 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT i'
STATUS t
4 LA.6 CTS Table 3.3-1, Action 2.b, requires, within one hour, placing all Revise the submittal to 5/20/97 j functional units receiving a parameter input from the inoperable fully explain how Action open '
channel in the same tripped or bypassed condition as the inoperable 2.b of CTS Table 3.31 trip channel. DOC LA.6 states this requirement is moved to the Safety will be accomplished Function Determination Program (SFDP) of ITS 5.5.15. Although the under the ITS. In SFDP is activated under ITS LCO 3.0.6 and ITS LCO 3.0.6 would addition, this is an L-apply when ITS LCO 3.3.1 is not met, it is not certain that the SFDP type, not an LA-type would require taking the same action as Action 2.b of CTS Table 3.3- change. ;
1 or an equivalent action.
I BGE Response:
5 M.1 With one inoperable channel in trip, CTS Table 3.3-1 Action 2.c Revise the submittal to 5/20/97 allows bypassing an additional channel for testing and maintenance discuss and justify the open for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Corresponding ITS 3.3.1 Action B allows placing relaxations associated one inoperable channel in trip and a second in bypass without with ITS 3.3.1 Action B.
restriction on the second channel; that is, the second channel can be inoperable for testing, maintenance, or for any other reason. This is ('
less restrictive because the ITS allows the second RPS channel to be i inoperable for reasons other than permitted by CTS Table 3.3-1 Action 2.c. In addition, in the event a second channel is inoperable for other than routine surveillance testing, the CTS specify no action requirements; thus a plant shutdown would be required by CTS 3.0.3. ,
ITS 3.3.1 Action B permits operation for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before a shutdown (per IT$ 3.3.1 Action G) is required. The submittal does not address these relaxations. 1 CGE Response: I L
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CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 6 A.7 CTS Table 4.3-1, Endnote (3), restricts reactor power to 90% Rated Revise the submittas to 5/20/97 i
L.2 Thermal Power (RTP) if the calibration of the excore channels to the address the open incore detectors is not current; this surveillance specifies no time limit requirements of ITS !
to reduce power -in DOC L.2, BGE apparently interprets it to be 3.3.1 Action C that are !
immediately. However, because it is not explicit, specifying a time more restrictive than limit is considered to be an additional requirement. Corresponding corresponding Notation !
ITS 3.3.1 Action C requires, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, either calibrating the (3) of CTS Table 4.3-1; excore channels to the incore detectors (i.e., performing ITS SR specifically discuss the '
3.3.1.3), or limiting the reactor power to 90% RTP. If either of these 24-hour Completion ;
actions are not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, ITS 3.3.1 Action G requires Time and the explicit shutting the plant down to Mode 3. An explicit time limit of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement to either '
and a shutdown requirement are more restrictive than the requirement calibrate the excore of CTS Endnote (3). Therefore, the addition of Actions C and G is a channels or reduce more restrictive change. power. !
BGE Response: I 7 L.1 ITS SR 3.3.1.2 (heat balance) Note 1 allows delaying the surveillance Revise the submittal to 5/20/97 until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power is > 15% RTP in agreement with CTS address this open Table 4.3-1 Notations (2) and (4). DOC L.1 discusses > 20% RTP inconsistency. If the '
rather than > 15% RTP. ITS uses > 20% RTP, justify it.
BGE Response: !
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CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS' 8 A.1 CTS Table 4.3-1 requires a Channel Calibration daily and at each Provide discussion and 5/20/97 LA.3 refueling interval for Function 2.b, "AT Power - High. In addition, justification for this less open Notation (4) to the daily Channel Calibration requires daily adjustments restrictive change that of the "AT Power Calibrate" potentiometers when above 15% RTP. appears to delete ITS Table 3.3.1-1 does not specify a Function for AT Power - High testing of the Power (but only Power Level- High), and consequently, appears to omit the Level- High, AT Power CTS adjustments and calibrations. This apparent less restrictive Function. See change has no justification. Comment 21.d.
CGE Response:
9 A.9 DOC A.9 mistakenly says that the trip setpoints in CTS Table 2.2-1 Revise the submittal to LA.4 5/20/97 will be listed in ITS Table 3.3.1-1. But DOC LA.4 clearly says they explicitly state the open are moved to unspecified plant procedures - controlled by the " plant procedures containing change control process," which has not been defined in the submittal. the trip setpoints and discuss the regulatory basis of the " plant change control process."
BGE Response:
10 A.14 CTS Table 2.2-1, Function 3, Reactor Coolant Flow - Low, Table Revise the submittal to 5/20/97 Notation *, references CTS 3.2.5, "DNB Parameters," for the design address how reactor open reactor coolant flow. The referral to CTS 3.2.5 for the definition of coolant design flow is design flow is deleted from ITS Table 3.3.1-1, Function 3, Reactor defined and controlled Coolant Flow - Low because the ITS does not reference other for this RPS trip Specifications. The justification does not state design flow is defined Function, in the ITS and the controls over that definition, nor show that definition is adequate for ITS Table 3.3.1-1, Function 3, Reactor Coolant Flow - Low.
CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS t F
BGE Response:
11 LA.4 CTS Table 2.2-1 contains " Trip Setpoint" and " Allowable Values" Revise the submittal to 5/20/97 columns. Corresponding ITS Table 3.3.1-1 contains only the explicitly state the open
" Allowable Values" column. Specific trip setpoints are proposed to be procedures containing moved to plant procedures. The justification for deleting the trip the trip setpoints and setpoints from ITS 3.3.1 does not identify the plant procedures. In discuss the regulatory +
addition, tlan proposed control mechanism for the trip setpoints, the basis of the " plant
" plant change control process," is not described. change control process."
See comment 3.3.1-9.
BGE Response:
12 LA.7 CTS Table 2.2-1 specifies the allowable value for the Thermal Revise the submittai to 5/20/97 :
Margin / Low Pressure (TM/LP) RPS function as not less than the larger clarify if and when the open of 1875 psia or the limits provided in the Core Operating Limits Report COLR will be revised to !
(COLR). Corresponding Function 9.a of ITS Table 3.3.1-1 omits the include the 1875 osia 1875 psia limit. limit.
CGE Response: i 13 M.3 STS 3.3.1 Condition F is for " Required Action and associated Revise the submittal as i
5/20/97 Completion Time not met." ITS 3.3.1 Condition G is for " Required appropriate to reflect open Action and associated Completion Time not met except for Axial withdrawal of changes Power Distribution - High and Loss of Load Trip Functions." The STS and differences based i deviation exempting the Axial Power Distribution - High and Loss of on conforming to TSTF- '
Load Trip Functions from Condition G is based on TSTF-80. TSTF-80 80.
was rejected by the NRC on 3/14/97.
CGE Response: i I
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CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE
- COMMENT STATUS 14 M.3 ITS 3.3.1 adds Condition F for " Required Action and associated Revise the submittal as 5/20/97 Completion Time not met for Axial Power Distribution - High ed loss appropriate to reflect open of Load Trip Functions." The STS deviation adding this condition and withdrawal of changes Required Action, " Reduce THERMAL POWER to < 15% RTP" within a and differences based completion time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is based on TSTF-80. TSTF-80 was on conforming to TSTF-rejected by the NRC on 3/14/97. 80.
CGE Response:
15 A.1 The Note to ITS SR 3.3.1.5 and ITS SR 3.3.1.8 retains the allowance Revise the submittal to 5/20/97 of CTS Table 4.3-1 Notation (5) to exclude neutron detectors from justify the Note open Channel Calibration (CTS 4.3.1.1.1), (affecting ITS 3.3.1 RPS excluding the loss of Functions 1,2,8, and 9.a). This allowance is not contained in load function from a corresponding STS SR 3.3.1.8, the refueling interval Channel refueling-interval Calibration for these RPS Functions. These exclusions are based on Channel Calibration in TSTF-81, which is pending. However, approval of this STS deviation ITS SR 3.3.1.8, and is not contingent on NRC approval of TSTF-81 because it appears explain why ITS SR consistent with the CTS. 3.3.1.8 is not specified for RPS Function 10 in in addition, the Note to ITS SR 3.3.1.8 also excludes the loss of load ITS Table 3.3.1-1.
function from Channel Calibration; this change to the CTS is not addressed. Further, ITS Table 3.3.1-1 Function 10, " Loss of Load,"
does not list ITS SR 3.3.1.8 as a required SR.
CGE Response:
16 A.1 ITS Table 3.3.1-1 contains an applicable Modes column; STS Table Revise the submittal 5/20/97 3.3.1-1 does not have this column. Inclusion of a Modes column is with a plant-specific open based on TSTF-85. TSTF-85 was rejected by the NRC on 3/14/97. justification for this .
deviation from the STS.
CGE Response:
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CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING l 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 17 5 ITS 3.3.1 does not contain figures corresponding to STS Figures Revise the submittal as 5/20/97 3.3.1-1, STS 3.3.1-2,' and 3.3.1-3. In place of referencing these appropriate to reflect open figures for the allowable values for Functionc 8 and 9a of STS Table withdrawal of changes 3.3.3-1,, the ITS references the COLR. These STS deviations are and differences based based on TSTF-80 and the allowable values being controlled by the on conforming to TSTF-COLR. TSTF-80 was rejected by the NRC on 3/14/97. However, 80 not associated with CTS Table 2.2-1 specifies the allowable values for Functions 8 and conforming to the CTS 9.a by referencing the COLR: therefore, the ITS is consistent with the requirements.
CTS. Approval of this STS deviation is not contingent on NRC approval of TSTF-80 because the ITS is consistent with the CTS. '
BGE Response: l 18 A.16 ITS Table 3.3.3-1 Note (e) for RPS Functions 8 and 10 (axial power Revise the submittal to 5/20/97 distribution - high, and loss of load), states these trips are only (1) justify this plant- open applicable in Mode 1 when 215% RTP; DOC A.16 claims CTS (Teble specific deviation from 2.2-1 Note (3) (?)) allow these RPS functions to be bypassed when the STS and relaxation Thermal Power is less than 15% RTP. Thus ITS Note (e) and the CTS of the CTS, and (2)
Applicability for these RPS functions are equivalent. However, the reflect withdrawal of specific CTS reference containing this bypass / applicability allowance changes and deviations is not clearly indicated on the CTS markup and does not appear to be based on conforming to !
specified in the CTS for these two RPS functions. TSTF-80.
In addition, the STS does not contain this bypass allowance for the axial power distribution - high and loss of load RPS functions which is the subject of TSTF-80. TSTF-80 was rejected on 3/14/97.
BGE Response:
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CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 19 LA.3 CTS Table 4.3-1 Notations (2) and (4) specifically require adjusting Revise the submittal to 5/20/97 the Nuclear Power Calibrate Potentiometers and the AT Power explicitly state the open Calibrate Potentiometers, respectively. These details are moved to procedures containing plant procedures. DOC LA.3 does not identify the plant procedures the these procedural that maintain these details. In addition, the proposed control details and discuss the mechanism for these details the " plant change control process," is not regulatory basis of the described. " plant change control process."
See comments 3.3.1-9 and 3.3.1-11.
CGE Response:
20 LA.6 CTS Table 3.3-1 Action 2.b requires placing all functional units Revise the submittal to 5/20/97 receiving a parameter input from the inoperable channel in the same describe the regulatory open tripped or bypassed condition as the inoperable channel within one basis of the plant hour. ITS 3.3.1 does not require this action. This requirement is change control process, moved to the Safety Function Determination Program (SFDP) of ITS and identify the plant 5.5.15. DOC LA.6 states that changes to the SFDP are in accordance procedures that with the plant change control process. The plant change control maintain control over process is not described. the plant change control process and controls over changes to the SFDP.
CGE Response:
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CCNPP ITS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS !
21a ITS 3.3.1. Table 3.3.1-1, Function 1, Power Level - High Revise the submittal 5/20/97 ITS SR 3.3.1.7 Channel Functional Test (CFT) - automatic bypass with an explanation. open i removal feature CTS 3.3.1.1, Table 3.3-1, Functional Unit 2, Power Level - High CTS 4.3.1.1.2 test of total bypass function during Channel Calibration CTS 3.3.1.1, Table 4.3-1, Functional Unit 2.a. Nuclear Power Level
- High i
CTS 4.3.1.1.2 appears to apply to the power level- high functional unit, but corresponding ITS SR 3.3.1.7 is not specified for this function on iTS Table 3.3.1-1. The submittal contains no explanation of this.
CGE Response:
21b CTS Table 4.3-1 specifies that the surveillances for the AT power Revise the submittal 5/20/97 level- high functional unit are required to be met in Mode 1 only. ITS with an explanation. open i Table 3.3.1-1 specifies that the surveillance (and operability) requirements for this function apply in Mode 2 also. The submittal [
contains no explanation of this.
BGE Response: '
i 21c CTS 4.3.1.1.2, test of total bypass function during Channel Revise the submittal 5/20/97 l Calibration, is retained as ITS SR 3.3.1.7 Channel Functional Test with an explanation. open '
(CFT) of the automatic bypass removal feature. The submittal .
contains no explanation of the equivalence of these two test l requirements. !
BGE Response:
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l CCNPP iTS 3.3.1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - OPERATING l
3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 21d ITS 3.3.1, Table 3.3.1-1, Function 1, Power Level - High l Revise the submittal 5/20/97 CTS 3.3.1.1, Table 4.3-1, Functional Unit 2.b, AT Power Level - with an explanation. open High The AT power level- high function is not discussed in the Bases for ITS 3.3.1.
BGE Response:
22 ITS 3.3.1, Table 3.3.1-1, Revise the submittal 5/20/97 Function 4, Pressurizer Pressure - High with an explanation. open Function 5, Containment Pressure - High (Note: This comment is Function 7, Steam Generator Level- Low repeated for the power Function 9.b, Asymmetric Steam Generator Transient level- high functional ITS SR 3.3.1.7 Channel Functional Test (CFT) - automatic unit in comment 28.a.)
bypass removal feature CTS 3.3.1.1, Table 3.3-1, Functional Unit 4, Pressurizer Pressure - High Functional Unit 5, Containment Pressure - High Functional Unit 7, Steam Generator Water Level- Low Functional Unit 9.b, Steam Generator Pressure Dif ference - High CTS 4.3.1.1.2 test of total bypass function during !
Channel Calibration CTS 4.3.1.1.2 appears to apply to the pressurizer pressure - high, containment pressure - high, steam generator water level-low, and steam generator pressure difference - high functional units, but corresponding ITS SR 3.3.1.7 is not specified for these functions on ITS Table 3.3.1-1. The submittal contains no explanation of this.
i CCNPP ITS 3.3.'1 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTAT;ON - OPERATING 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS.
CGE Response:
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CCNPP ITS 3.3.2 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - SHUTDOWN t 3.3.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
1 M.1 With one inoperable channel in trip, CTS Table 3.3-1 Revise the submittal to discuss and 5/28/97 >
Action 2.c allows bypassing an additional channel for justify the relaxations associated with open testing and maintenance for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. ITS 3.3.2 Action B.
Corresponding ITS 3.3.2 Action B allows placing one inoperable channel in trip and a second in bypass See comment 3.3.1-05 without restriction on the second channel; that is, the second channel can be inoperable for testing, maintenance, or for any other reason. This is less restrictive because the ITS allows the second RPS channel to be inoperable for reasons other than permitted by CTS Table 3.3-1 Action 2.c. In addition, in the event a second channelis inoperable for other than routine surveillance testing, the CTS specify no action requirements; thus a plant shutdown would be required by CTS 3.0.3. ITS 3.3.1 Action B permits operation for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before a shutdown (per ITS 3.3.2 Action E) is required. The submittal does not address these relaxations. ,
i BGE Response:
2 LA.1 CTS 4.3.1.1.2 requires demonstrating the bypass Revise the submittal to specifically 5/28/97 logic, including the automatic bypass removal logic identify the plant procedures that open -
Operable prior to each reactor startup, unless contain this requirement and describe performed during the preceding 92 days. ITS 3.3.2 how changes to it will be controlled.
moves this requirement to unidentified plant procedures. The justification does not identify the See comment 3.3.1-01 plant procedure that maintains this requirement nor the specific controls that maintain the requirement in plant !
procedures.
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CCNPP ITS 3.3.2 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - SHUTDOWN 3.3.2 DOC JFD CHANGE / DIFFERENCE. COMMENT STATUS QGE Response:
3 LA.3 CTS Table 3.3-1, Action 2.b, requires, within one Revise the submittal to fully explain how
- i 5/28/97 hour, placing all functional units receiving a parameter Action 2.b of CTS Table 3.3-1 will be open input from the inoperable channel.in the same tripped accomplished under the ITS. In addition, or bypassed condition as the inoperable trip channel. this is an L-type, not an LA-type change.
DOC LA.6 states this requirement is moved to the Safety Function Determination Program (SFDP) of ITS See comment 3.3.1-04 5.5.15. Although the SFDP is activated under ITS LCO 3.0.6 and ITS LCO 3.0.6 would apply when ITS LCO 3.3.2 is not met, it is not certain that the SFDP would require taking the same action as Action 2.b of '
CTS Table 3.3-1 or an equivalent action.
BGE Response: I I
4 CTS Table 2.2-1 specifies an Allowable Value for the Revise the submittal with a suitable 5/28/97 power rate of change - high channels of s 2.6 markup of CTS Table 2.2-1 Functional open decades per minute. A CTS markup of this Unit 11 in the CTS markup for ITS !
requirement is not included in the submittal for ITS 3.3.2, and also with a suitable DOC.
3.3.2. In addition, ITS 3.3.2 differs from STS 3.3.2 Acceptance of specifying the allowable ,
by stating the allowable value in ITS SR 3.3.2.4, not in value in ITS SR 3.3.2.4 is contingent on LCO 3.3.2 as in the STS. This difference is based on NRC approval of TSTF-82.
TSTF-82, which has not yet been approved by the 1 NRC. I BGE Response:
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I CCNPP ITS 3.3.2 REACTOR PROTECTIVE SYSTEM (RPS) INSTRUMENTATION - SHUTDOWN 3.3.2 DOC .JFD CHANGE / DIFFERENCE 1
COMMENT STATUS 5
5 A.1 CTS 4.3.1.1.2, test of total bypass function during Revise the submittal with an explanation. 5/28/97 t Channel Calibration, is retained as ITS SR 3.3.2.3 open Channel Functional Test (CFT) of the automatic bypass See comment 3.3.1-21c removal feature for the power rate of change - high function. The submittal contains no explanation of the equivalence of these two test requirements.
in addition, STS LCO 3.3.2 does not specifically include Acceptance of this difference contingent .
automatic bypass removal feature for the power rate of on NRC approval of CEOG-91.
change - high channels, but ITS LCO 3.3.2 does. This difference is based on TSTF-180 (CEOG-91) which has not yet been approved by the NRC. i BGE Response:
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5 CCNPP iTS 3.4.1 RCS PRESSURE. TEMPERATURE, AND FLOW DN8 LIMITS 3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.4.1-1 L.1 JFD.1 CTS 3.2.5 ACTION requires THERMAL POWER Provide justification for the STS reduction to < 5% of RATED THERMAL POWER deviation based on current licensing -
(RTP) if cold leg temperature cannot be restored to basis, system design, or operational I s 548'F within two hours. constraints.
Under the same condition, ITS 3.4.1 ACTION D only Provide additional discussion and ;
requires THERMAL POWER reduction to s 30% justification demonstrating that power !
RTP. reduction to s 30% RTP, versus the
STS 3.4.1 ACTION D includes the 30% of RTP based on plant specific analyses.
value as a bracketed figure, indicating that a plant- ,
specific value may be used in lieu of the STS value. !
However, the change from 5% to 30% of RTP is
i i
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i I
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_ . - _ _ _ _ - - - . , - - - _ . - - - _ - - - - _ _ - . _ _ _ _ - _ . - _ . . - - - _ - - _ . _ - - - . _ . - - . - . _ _ - . _ _ _ - - - - - - - . _ - _ _ _ - - _ _ - - - , , - . , - - - - - - . , ,-,--a , , -. .-,,a ,.e. -- wa-n- - - - - -s--~ - . m
CCNPP ITS 3.4.1 RCS PRESSURE TEMPERATURE, AND FLOW DNB LIMITS 3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATIJS Furthermore, the acceptability of this change is justified merely by stating that the potential for violating the DNBR limit is very remote when operating at s 30% RTP while cold leg temperature is not within limits. The No Significant Hazards Consideration (NSHC) also states that reducing power to s 30% RTP ensures the potential for a DNB anomaly is remote. The NSHC further states that operating in accordance with this change results in meeting the DNBR criterion in the event of a DNB limited transient, and that operatio'n in this i manner ensures that a DNB limit will not be violated. No specific quantifiable information is ,
provided or referenced, however.
}
CCNPP Response: i n
--.m. m . _ _ _ _ - ...m ..._____m____ _.___.___ ____.___ _ _ _ _m_ __._______m- ____ __ _ _---.._ __ _ e -- .--4> -m e ~ , , - n-- -- -~m- -
n - --w-we-*
CCNPP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS 3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.4.1-2 L.3 JFD.1 Performance of CTS Surveillance Requirement BEYOND SCOPE l 4.2.5.2 is required at least once per i8 months.
t in ITS SR 3.4.1.4, this Frequency is extended to 24 !
months. i STS SR 3.4.1.4 specifies an 18-month Frequency !
for this surveillance. The 18-month Frequency is a .
bracketed figure in the STS, indicating that a plant-specific value may be used in lieu of the STS value. !
The change from 18 months to 24 months is not ,
consistent with the STS, however, because the o plant-specific value in CTS Surveillance Requirement ,
4.2.5.2 is 18 months, not 24 months. ~
This change represents not only a relaxed CTS requirement, but also a deviation from the STS.
k CCNPP Response: , ;
-- - - - . . - - _ - --_ , . . - - - , . - - -_r, - .... _ - _ . - _ m .- .- _ ._ - . _ _ . . . - - . - m.._-- ,-__. ._-m. _ _.--
i CCNPP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNS LIMITS 3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.4.1-3 L.2 CTS Surveillance Requirement 4.2.5.2 requires Correct or delete the L.2 DOC, and [
determining the Reactor Coolant System (RCS) total correct the CTS markup and/or the ITS {
flow rate to be within its limit by measurement. accordingly.
Discussion of change (DOC) L.2 states a note is ,
added in ITS SR 3.4.1.4 which allows not "
performing this surveillance until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 2 90% RTP. The DOC goes on to say this change is required to ensure the test results are representative of RCS total flow, because the test !
results are more accurate when obtained at power levels > 90% RTP.
l ITS SR 3.4.1.4 requires verifying measured RCS '
total flow rate is within limits. There is no note in i ITS SR 3.4.1.4 to allow deferring this surveillance until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 2 90% RTP.
Therefore, in this regard, there is no difference between CTS Surveillance Requirement 4.2.5.2 and ITS SR 3.4.1.4. '
CCNPP Response: >
i s
I i
CCNPP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS 3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT ' STATUS 3.4.1-4 . A.2 Most of the requirements contained in CTS 3/4.2.5, Correct the CTS Markup pages for ITS DNB Parameters, are placed in ITS 3.4.1, RCS 3.4.1 to indicate that CTS 3.2.5.d and Pressure, Temperature, and Flow DNB Limits. its associated ACTION and Surveillance Requirement are discussed in the '
However, CTS 3.2.5.d, requiring AXlAL SHAPE conversion submittal DOCS for ITS INDEX (ASI) and THERMAL POWER within specified 3.2.5, rather than being deleted as an limits, and its associated ACTION and Surveillance Administrative Change.
Requirements, are not placed in ITS 3.4.1, but are retained as ITS 3.2.5, Axial Shape Index.
Accordingly, any changes to these ASI requirements are addressed in the Discussion of Changes (DOCS) '
for ITS 3.2.5.
Since these requirements are retained, but are y
merely not placed in ITS 3.4.1, the CTS Markup should be annotated as such, rather than indicating i the requirement is deleted, and then classifying this change as Administrative.
CCNPP Response:
t e
_ . . _ . . . _ _ _ . _ . _ _ _._-____.-_____.___m.__._.______________m_____._ _ . _ _ _ . _i___ _ _ _ _ _ _ _ _-
-- . . =~- .-.,e-
CCNPP ITS 3.4.1 RCS PRESS 83RE. TEMPERATURE, AND FLOW DNB LIMITS +
t 3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.4.1-5 JFD.1 STS 3.4.1.a and STS 3.4.1.b impose requirements Provide discussion and justification for i on the value of pressurizer pressure and RCS cold not incorporating the STS format and ;
leg temperature, respectively. Each of these content with regard to the requirement parameters' required values is stipulated as a range for a specified range of acceptable of acceptable values, the lower limit designated with values for pressurizer pressure and RCS a 2 sign, and the upper limit designated with a s cold leg temperature.
sign.
Base the justification on current licensing ITS 3.4.1.a and ITS 3.4.1.b do not include both basis, system design, or operational
^
upper and lower limits for these parametric constraints. '
requirements. Instead, ITS 3.4.1.a requires 4 pressurizer pressure 2 2200 psia, and ITS 3.4.1.b '
requires RCS cold leg temperature s 548'F.
s Likewise, while STS SR 3.4.1.1 and STS SR 3.4.1.2 respectively require verification that pressurizer pressure and RCS cold leg temperature are within '
the specified upper and lower limits, ITS SR 3.4.1.1 I requires verification of pressurizer pressure 2 2200 t psia, and ITS SR 3.4.1.2 requiies verification of i RCS cold leg temperature s 54B F. ;
t Beyond incorporation of plant-specific numbers into 1
the brackets, there is no discussion of the reason (s) '
for not adopting the STS format and content.
[
r CCNPP Response:
l
CCNPP ITS 3.4.1 RCS PRESSURE, TEMPERATURE, AND FLOW DNB LIMITS i
3.4.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS i 3.4.1-6 JFD.1 STS 3.4.1.b imposes requirements on the value of Provide discussion and justification for RCS cold leg temperature, with a specified allowable not incorporating the STS format and band for < 1701% RTP, and a different specified content with regard to including two allowable band for 2 [70]% RTP. Likewise, STS SR separate bands of acceptable values for 3.4.1.2 requires verification that RCS cold leg RCS co!d leg temperature, depending on temperature is within its specified range for reactor power level. Base the ;
oporation at either < 170]% RTP, or 2 [70]% RTP, justification on current licensing basis, '
as applicable. system design, or operational constraints. '
ITS 3.4.1.b and ITS SR 3.4.1.2 merely state the j
required value for RCS cold leg temperature as s .;
548'F, regardless of reactor power level. I Beyond incorporation of plant-specific numbers into the brackets, there is no discussion of the reason (s) for not adopting the STS format and content.
CCNPP Response:
- 3.4.1-7 STS SR 3.4.1.4 requires RCS total flow rate verified Acceptance of this change is contingent by performing a precision heat balance (a on NRC approval of TSTF-105. "
calorimetric calculation).
ITS SR 3.4.1.4 stipulates this verification by measuring the RCS total flow rate.
This STS deviation is based on TSTF-105. t CCNPP Response:
i.
i
_ . _ _ . _. . , _ _ _ . _ _ . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ ___ _ . - . _ _ . . _ . . . . _ . . _ , , , . . _ _ _ , . ~.
1 k
CCNPP ITS 3.4.2 RCS MINIMUM TEMPERATURE FOR CRITICALITY
- i 3.4.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2 A.3 CTS Surveillance Requirement 4.1.1.5.b includes a Provide discussion and justification for stipulation that the surveillance is required when the the more restrictive change, including -
RCS T, is < 525'F. why it is preferable and acceptable to require performance of the required '
ITS SR 3.4.2.1 changes this stipulation by surveillance whenever any one RCS -
specifying Tm < 525'F in any RCSloop. loop's Tm is < 525'F, rather than !
when the RCS T, of unspecified loop (s) !
This change constitutes a more restrictive change is < 525'F rather than an administrative change. In addition, ,
this change constitutes an STS deviation, the basis Contingent upon CEOG-113. Has this ,
for which is CEOG-113. been rejected. What is the TSTF i number. l CCNPP Response: t 3 M.1 ITS SR 3.4.2.2 is added, requiring RCS Tm in each Contingent upon CEOG-113. Has this I loop verified 2 515 F occe per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when T, been rejected. What is the TSTF in any RCS loop is 2 525"F. number.
This requirement is not included in CTS 3.1.1.5.
This change from the :
CTS requirements is based on CEOG-113. <
CCNPP Response:
i I
I
l CCNPP ITS 3.4.2 RCS MINIMUM TEMPERATURE FOR CRITICALITY 3.4.2 DOC JFD CHANGE / DIFFERENCE COMMENT '
STATUS 4 STS 3.4.2 Applicability is MODE 1 with Tm in one Contingent upon CEOG-113. Has this or more RCS loops < [525f F, and MODE 2 with been rejected. What is the TSTF T, in one or more RCS loops < [535TF and K ,, 2 number.
1.0.
ITS 3.4.2 Applicability is merely MODE 1, and MODE 2 with K.,, 2 1.0.
The discussion and justification for this STS deviation is contained in CEOG-113.
CCNPP Response:
i t
_ _ _ _ _ _ _ _ _ _ _____-__._____.___________.._______m_______...______.m __.__________m___ _ _ _ _ _ _ _ _____________.____________m_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _
CCNPP ITS 3.4.3 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS 3.4.3 DOC JFD -
CHANGE / DIFFERENCE COMMENT STATUS 1 A.1 JFD.2 CTS 3.4.9.1 requires maintaining RCS temperature Add information showing where limits and pressure within the limits indicated on Figures are specified. As in ... maintained within 3.4.9-1 and 3.4.9-2. the limits shown in Figures _ and _.
These curves, CTS Figures 3.4.9-1 and 3.4.9-2, are included on two pages in ITS 3.4.3, as Figures 3.4.3-1 and 3.4.3-2. However, the wording of ITS 3.4.3 includes no direction to maintain RCS temperature and pressure according to the limits on these curves, nor does ITS 3.4.3 provide reference to another document wherein specific limits may be obtained. ITS 3.4.3 merely requires RCS temperature and pressure ". . . maintained within limits."
STS 3.4.3 requires maintaining RCS temperature and pressure within the limits specified in the PTLR but, again, ITS 3.4.3 neither states nor references the specific required limits.
- CCNPP Response:
2 A.1 The Applicability of CTS 3.4.9.1 is stated as, "At all Add reference to criticality, and inservice -
times," but, within the text of CTS 3.4.9.1, this leak and hydrostatic testing in ITS 3.4.3. !
Applicability is further modified to, ". . . during or provide justification why it should nto heatup, cooldown, criticality, and inservice leak and be added. STS references PTLR which hydrostatic testing . . ." has this. Since you are not using PTLR, include all parameters in the LCO.
CCNPP Response:
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S CCNPP ITS 3.4.5 RCS LOOPS - MODE 3 3.4.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS l
Bases TSTF 177 (CEOG 83) pending Changes dependent upon completion of review of TSTF.
CCNPP Response:
1 LA.1 The details of CTS 3.4.1.2.a.1 and 3.4.1.2.a.2, Provide plant procedure (s) change conrol specifying precisely which two RCS loops shall be process. (50.59?)
OPERABLE, and how many reactor coolant pumps in {
each of these two RCS loops must be OPERABLE, )
are moved to plant procedures.
CCNPP Response:
2 A.1 CTS 3.4.1.2 Applicability is modified by footnote " Provide discussion and justification for which states that a reactor coolant pump shall not the more restrictive change, including, as be started with the RCS temperature s 365*F (Unit applicable, how CTS 3.4.1.2 footnote "
1), s 301 *F (Unit 2).
is interpreted by plant operators, why it is advantageous to use cold leg in ITS 3.4.5 NOTE 2, the term "RCS temperature" is temperature over other temperature changed to "RCS cold leg temperature." There is no sensor (s), how this enhancement discussion or justification for this change. improves plant safety, etc.
Specifying which RCS temperature is applicable in meeting the limit enhances the Technical Specifications by removing ambiguity which exists in CTS 3.4.1.2 footnote ". The enhancement constitutes an additional restriction not found in CTS 3.4.1.2; therefore, this is a more restrictive change.
CCNPP Response:
i CCNPP ITS 3.4.5 RCS LOOPS - MODE 3
=
3.4.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS t
! 3 STS 3.4.5 NOTE b includes a criterion that core Provide justification for the " generic outlet temperature is maintained at least l'J"F editorial". Was this a TSTF7 below saturation temperature.
Likewise, CTS 3.4.1.2.b footnote ' states that core outlet temperature is maintained at least 10 F below saturation temperature.
However, ITS 3.4.5 NOTE 1.b changes the phrase,
". . . at least 10
- F . . ." to ". . 2 10
- F . . ."
Placing the symbol meaning " greater than or equal to" and its associated numeric value directly adjacent to the word "below" causes the reader's mind to stumble. The intended meaning is more quickly grasped by using the phrase "at least 10 F below . . ."
The reason for this STS deviation is not clear, but it is justified by a handwritten comment in the STS 3.4.5 margin which states, " editorial generic."
CCNPP Response:
_ - - - " - '-'- " ~ - - - - - - - - - ' - - - - - '-
CCNPP ITS 3.4.6 RCS LOOPS - MODE 4 3.4.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1
1 LA.1 The details of CTS 3.4.1.3.a.1, .2, .3, and .4, Provide information describing the plant specifying precisely which two cooling loops of the orocedure(s) to which the details of CTS four RCS and SDC loops possible shall be 3.4.1.3.a.1, .2, .3, and .4 are moved.
OPERABLE, and how many RCPs in any defined and how the plant procedures are l OPERABLE RCS loop (s) must be OPERABLE, are controlled.
moved to plant procedures.
CCNPP Response: l l
4
- - . _ - . - - - . _ - - - - - - - = . . - - - _ _ = . . = . _ . _ . - . . - .
CCNPP ITS 3.4.6 RCS LOOPS - MODE 4 3.4.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2 STS 3.4.6 NOTE b includes a criterion that core Same as before.
outlet temperature is maintained at least 10'F below saturation temperature.
Likewise, CTS 3.4.1.3.b footnote " states that core outlet temperature is maintained at least 10*F below saturation temperature.
However, ITS 3.4.6 NOTE 1,b changes the phrase,
". . . at least 10* F . . ." to ". . 2 10'F . . ."
Placing the symbol meaning " greater than or equal to" and its associated numeric value directly adjacent to the word "below" can cause the reader to stumble. The intended meaning is more quickly grasped by using the grammatically correct phrase
". . . at least 10'F below . . ."
The reason for this STS deviation is not clear, but it is justified by a handwritten comment in the STS 3.4.6 margin which states, " editorial generic."
CCNPP Response:
CCNPP ITS 3.4.6 RCS LOOPS - MODE 4 3.4.6 DOC. JFD CHANGE / DIFFERENCE COMMENT _ STATUS 3 A.6 Footnote ' associated with CTS 3.4.1.3.a.3 and Correct or verify the "A.5" DOC 3.4.1.3.a.4, allows the normal or emergency power designator in the CTS markup for CTS source INOPERABLE for the SDC loops in MODE 5. 3.4.1.3.a.3 and 3.4.1.3.a.4.
ITS 3.4.6 does not include this allowance.
It is presumed that the handwritten "A.5" discussion of change (DOC) designator in the CTS markup for CTS 3.4.1.3.a.3 and 3.4.1.3.a.4 is in error, and was intended to be written "A.6." It is on the basis of this presumption that review of the a
A.6 change is performed.
if this presumption is incorrect, then the conclusion reached during the review of change A.6 must be re-addressed.'
CCNPP Response:
i
___. _ _ _.m_ _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _
- - . . . _ . _ _ _ _ _. __ __- _ - . _ - - . _ ~
CCNPP ITS 3.4.6 RCS LOOPS - MODE 4 3.4.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 4 A.5 CTS 3.4.1.3 Applicability footnote ' references CTS in the CTS markup, correct or verify the Special Test Exception (STE) 3.10.5. ITS 3.4.6 handwritten lines extending from the deletes the reference to STE 3.10.5. "A.5" designator to the footnote
handwritten lines extending from the "A.5" DOC designator to the footnote designator for CTS 3.4.1.3.a.3 and 3.4.1.3.a.4 are in error, and were actually intended to extend to the footnote '
designator for CTS 3.4.1.3 Applicability MODE 4.
it is on the basis of this presumption that review of '
the A.5 change is performed.
If this presumption is incorrect, then the conclusion reached during the review of change A.5 must be re-addressed.
CCNPP Response:
i e
_ _ _ - - _ - . - - _ . - - - - _ _ . - - _ - _ _ _ - - - - _ - - - _--__-__------ -_~n .
.----s-.- - --- -. e -- - - - - - - -
. - - . . . - . . - . . .- - . - - - . .. .- .- - . . . . ~ ~ . _ . .-
P CCNPP ITS 3.4.6 RCS LOOPS - MODE 4 i 3.4.6 DOC JFD~ CHANGE / DIFFERENCE COMMENT ~
STATUS !
5 M.3 CTS 3.4.1.3 ACTION b prescribes operator actions Provide discussion and justification for in the event that no coolant loop is in operation. the more restrictive change of adding the ITS 3.4.6 ACTION C includes the equivalent l Condition of required RCS or SDC loops Condition of no RCS or SDC loops in operation, but INOPERABLE to ITS 3.4.6 ACTION C. f also adds the Condition of required RCS or SDC loops INOPERABLE: the two described Conditions are linked by an OR statement. I The justification focuses on changing the one-hour i completion time of CTS 3.4.1.3 ACTION b to a i
completion time of immediately in ITS 3.4.6 ACTION C, but does not address the further enhancement of adding the Condition of required l RCS or SDC loops INOPERABLE. While reasoning for this enhancement may be intuitively obvious, the change must be discussed and justified in the !
license amendment submittal. '
i CCNPP Response: ;
- .i i
t 1
I i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ . . . _ _ _ . _ _ . . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . . _ . _ . . _ _ _ _ . . _ _ _ . . , . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _._______i
CCNPP ITS 3.4.7 RCS LOOPS - MODE 5, LOOPS FILLED i
i 3.4.7 DOC. JFD CHANGE / DIFFERENCE . COMMENT - STATUS 1 L.1 If credit is taken for RCS loop (s) OPERABLE for Provide additional discussion and ,
decay heat removal, then CTS 3.4.1.3.a.1 and justification for the changed CTS 3.4.1.3.a.2 stipulate at least one associated RCP requirement to quantifiably demonstrate ;
OPERABLE in the OPERABLE loop (s). adequacy of the SGs* combined heat sink capability, with both SG secondary .
In ITS 3.4.7, RCP OPERABILITY is not a side water levels at -50 inches, and ,
requirement, if credit is taken for the RCS loops as without forced RCS flow. Development i the backup decay heat removal method. of this justification should include !
analysis or verification, using the most The justification states that acceptability of this conservative case (full power history and change is based on: minimum time to get to MODE 5), of ;
- The large contained volume of secondary side heat transfer rates. The following items '
water providing a heat sink for the RCS, and should be addressed, as applicable:
- Forced RCS flow not necessary because natural j circulation is sufficient to remove the small decay - Maximum core decay heat generation i heat load generated by the reactor core until at least rate, !
one SDC loop is made OPERABLE and/or placed in - Total primary to secondary heat !
operation. transfer area, !
- Heat. transfer coefficient (s), ;
There is no specific information provided or - Relative applicable primary and i described upon which to measure acceptability of secondary temperatures, i the change. - Total natural circulation flow rate, k
- Combined SGs* ambient heat loss !
rate. ,
CCNPP Response:
~!
f f
CCNPP ITS 3.4.7 RCS LOOPS - MODE 5, LOOPS FILLED 3.4.7 DOC JFD- CHANGE / DIFFERENCE COMMENT STATUS 2 L.2 The requirements of CTS 3.4.1.3 stipulate both RCS Provide additional discussion for the less loops in operation if both SDC loops are removed restrictive change based on plant from operation while in MODE 5. operations. Address factors relating to backup (standby) cooling capabilities of ITS 3.4.7 NOTE 4 allows removing both SDC loops the SDC and RCS loops not in operation; from operation during planned heatup from MODE 5 the ability to restore one or both required to MODE 4 when at least one RCS loop is in SDC loops to operation if the decision to operation. This effectively reduces the CTS 3.4.1.3 achieve MODE 4 is reversed; the requirement from both RCS loops to only one RCS intended heatup path obviating the need loop in operation. for the same level of required decay heat removal capability as when no heatup is intended; and so forth, as appropriate.
CCNPP Response:
3 L.2 The CTS 3.4.7 markup includes an insert for Provide discussion and justification for placement as ITS 3.4.7 NOTE 2, which allows this change from the CTS markup, removing one required SDC loop from operation for including why the term " train" is up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided the other SDC loop is preferable to the term " loop" in this OPERABLE and in operation.
- instance.
However, ITS 3.4.7 NOTE 2 changes the word Since, in some places in the ITS, the
" loop" to the word " train," so the last of the term train is left in, explain when there is sentence reads, ". . . provided the other SDC train is a difference.
OPERABLE and in operation."
The terms loop and train are not equivalent; there is no discussion or justification for this change from the CTS markup.
e
ITS 3.6.8 IODINE REMOVAL SYSTEM ITEM DOC / CTS /STS' DESCRIPTION OF. ISSUE DATE DATE . COMMENTS.
NO. JFD LC0~ OPENED , CLOSED 3.6.8-3 Bases STS 3.6.10 STS 3.6.10 Bases-SR 3.6.10.1 5/16/97 Provide a discussion JFD 8 Bases - states that the SR and justification for SR requirement to OPERATE each this deletion.
3.6.10.1 ICS train ensures that all ITS 3.6.8 trains are OPERABLE. "It-Bases- also ensures that blockage.
BACKGROUND fan or motor failure or ITS B3.6.8 excessive vibration can be Bases- detected for corrective SR 3.6.8.1 action." This last statement has been deleted from ITS B3.6.8 - Bases for SR 3.6.8.1. lhe justification (Bases JFD 8) provided does not correlate .
to this sentence, based on the system description
, provided in ITS B3.6.8 Bases-BACKGROUND.
CCNPP Response:
m.,
1
-. , q 3
.m--. - _ . _ _ _ _ - - - - _ . . . - , . - - - - _ _ _ _ . _ - . - _ _ - _ _ _ . - _ . - - . _ _ _ _ . . - - . . _ _ - - - - _ _ _ _ . _ _ _ . _ _ _ _ - - - - - _ _ _ _ _ _ . - --_______x.___- - - - _ - . _ _ _ _ . - __~-_-_____ ----- ____- _ - -.---- ~- - - ._i
l l
\
CCNPP ITS 3.4.9 PRESSURIZER 3.4.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS l
r 4 JFD.21 STS SR 3.4.9.3 is deleted. There is inadequate Provide discussion of the semming discussion and justification for this STS deviation. conflict between Discussion of Deviations from NUREG # 21 and 26.
Retain the SR.
CCNPP Response:
e
_ ,_ _m____- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -. _ _ __< _ ___ +_ _ _ _ _ _ _ - - , - -
- - - - - - - - - -_ -m , ___ m ___ _ _ _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ , _ _ _ _ _
CCNPP ITS 3.4.10 PRESSURIZER SAFETY VALVES 3.4.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 Change in Applicability. from MODES 1,2,3, and 4 Possible Beyond Scope issue.
Additional justification is needed to deviate from the STS. The STS has an -
LTOP specification also that covers a different temperature. MOPDE 4 in this LCO is > [285], while the LTOP LCO is < [285). Retain the LCO as is in the STS. Change Bases accordingly.
CCNPP Response:
2 JFD-8 CTS 3.4.2.1 LCO statement specifies the actual if the valve settings will be moved to pressurizer safety valves that shall be OPERABLE the SR, the As-Left Tolerences, which ;
and provides their respective As-Found and As-Left corresponds to the STS should be left tolerances as a percent function of their lift settings. in also.
ITS 3.4.10 LCO statement requires 2 pressurizer safety valves OPERABLE. The above details for
- each valve are moved into ITS SR 3.4.10.1.
CCNPP Response:
5 i
i r
O
CCNPP ITS 3.4.10 PRESSURIZER SAFETY VALVES 3.4.10 DOC JFD CHANGE / DIFFERENCE COMMENT- STATUS 3 M.1 The discussion of change states that ITS 3.4.10 Correct the discussion of change to adds an intermediate step to the shutdown track accurately reflect the content of ITS required by CTS 3.4.2.1. This is not the case. CTS 3.4.10.
3.4.2.1 requires shutdown to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with one pressurizer safety valve inoperable.
ITS 3.4.10 only requires shutdown to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reducing RCS cold leg ,
temperatures to s 365*F (Unit 1; s 301 *F Unit 2) '
within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.4.10 does not require further shutdown to MODE 4. Therefore, the shutdown to MODE 3 is not an intermediate step.
CCNFP Response:
4 L.1 CTS 3/4.2.1 contains a footnote specifying that Provide discussion and justification for both pressurizer safety valves may be removed in this change to CTS requirements.
MODE 5 provided that at least one valve is replaced Specify where this requirement is now by a spool piece which allows the pressurizer to located. Relocate to Bases?
relieve directly to the quench tank. This footnote is referenced to the L.1 discussion of change. ITS '
3.4.10 does not contain any mention of the ;
requirements contained in this footnote. There is no discussion or justification for this change.
CCNPP Response:
t
CCNPP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) 3.4.11 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 JFD.25 ITS 3.4.11 Required Action A.1 broadens the This May Be Beyond Scope applicability of CTS 3.4.3 Action a through a Note What does consistent with the current which allows delaying the Required Action for s licensing basis mean? Is it or is it not? l 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> if one block valve is inoperable and s Provide justification for the STS 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if two block valves are inoperable. deviation based on current licensing '
However, adding this Note to ITS 3.4.11 Required basis, system design, or operational Action A.1 is a deviation from the STS. There is constraints.
inadequate discussion and justification for this STS deviation.
CCNPP Response:
2 LA.1 CTS Surveillance Requirement 4.4.3.1.a requires Specify the controls for the change i performing a Channel Functional Test at least process. (50.597) once per 31 days in accordance with the Reactor Protective System (RPS) Pressurizer Pressure !
Surveillance Test Procedure. ITS SR 3.4.11.1 requires performing the CHANNEL FUNCTIONAL TEST, but does not specify that it be- done in accordance with the RPS Pressurizer Pressure Surveillance Test Procedure, thereby moving the CTS requirement outside of the ITS into licensee-
~
controlled documents. The discussion of change does not specify which licensee-controlled documents contain this requirement.
CCNPP Response: .
CCNPP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) 3.4.11_ DOC 'JFD- CHANGE / DIFFERENCE - COMMENT ' STATUS 3 JFD.12 CTS Surveillance Requirement 4.4.3.1.a requires Provide discussion based on current performing a CHANNEL FUNCTIONAL TEST once licensing basis, system design, or per 31 days. ITS SR 3.4.11.1 retains this CTS operational constraints.
requirement. However, adding ITS SR 3.4.11.1 is a deviation from the STS. There is inadequate.
discussion and justification for this STS deviation.
CCNPP Response:
4 L1 ITS 3.4.11 Action A relaxes the CTS 3.4.3 Action Provide additional discussion and a requirement of having one or more PORV(s) with justification for the CTS 3.4.3 Actions excessive seat leakage to one or more PORVs b and c changes.
inoperable and capable of being manually cycled.
CTS 3.4.3 Actions b and c specify Required Actions and Completion Times for one PORV NOTE: THIS LCO HAS TO BE (Action b) and both PORVs (Action c) inoperable REVIEWED IN ITS ENTIRETY BEFORE for causes other than excessive seat leakage. THE MAGNITUDE OF CHANGES ARE ITS 3.4.11 Actions B and D change these CTS ALL ACCEPTED.
requirements to one PORV (Action B) and two PORVs (Action D) inoperable and not capable of being manually cycled respectively. are briefly addressed. The only discussion and justification for these changes to CTS Actions is a reference to the ITS 3.4.11 Action A less restrictive change.
Although related to the ITS 3.4.11 less restrictive change, these changes are separate issues. There is inadequate discussion and justification for the CTS 3.4.3 Actions b and c changes.
CCNPP Response:
4
_ _ . _ . . _ . . . . _ _ _ _ _ . ___.m ___.._m. _ _ _ _ _ . _ _ _ . . - . _ . . _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ __ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ .
I P
CCNPP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) i .3.4.11 DOC JFD ' CHANGE / DIFFERENCE
' COMMENT - STATUS l 5 L.2 CTS Surveillance Requirement 4.4.3.1.a requires - This change is not necessarily i performing the PORV STE every 31 days. ITS SR .
acceptable simply because of the l 3.4.11.1 extends the SR-Frequency to 92 days. approval of the amendments. These i l The discussion of change states that the PORV have to be evaluated in their own right. !
actuation instrumentation is the same as that used
- for the RPS High Pressurizer Pressure Function.'
t The RPS High Pressurizer Pressure Function STE i Surveillance Frequency was decreased from 31 I days to 92 days in the RPS and ESFAS " monthly to quarterly" Technical Specification change j (approved in an NRC Safety Evaluation Report for ;
Amendments 193 and 170 for Units 1 and 2, respectively, dated August 24,1994). :
CCNPP Response:
I 6 JFD.12 CTS Surveillance Requirements 4.4.3.1.a and b Provide justification for the STS !
require performing a CHANNEL FUNCTIONAL. deviation based on current licensing ,
TEST once per 31 days, and performing a : basis, system design, or operational !
CHANNEL CALIBRATION once per REFUELING constraints. i INTERVAL respectively. ITS 3.4.11 retains these !
requirements by adding two SRs, ITS SR 3.4.11.1 and ITS SR 3.4.11.4. Adding these SRs is a !
deviation from the STS. There is inadequate j discussion and justification in for this STS deviation. ;
CCNPP Response: I 4
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.CCNPP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) l t
- 3.4.1 1. DOC. JFD ~ CHANGE / DIFFERENCE ' COMMENT STATUS l 7 JFD.11 STS 3.4.11 Action D requires shutting down to NOTE: THIS LCO HAS TO BE !
MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to be in MODE 4 in 12 REVIEWED IN ITS ENTIRETY BEFORE :
hours if the Required Actions and Completion THE MAGNITUDE OF CHANGES ARE ;
Times of Condition A, B, or C are not met. ITS ALL ACCEPTED. i 3.4.11 Actions do not contain this requirement; it - [
is deleted. Deleting this requirement in the ITS is a deviation from the STS. The justification for l a
this deviation includes reference to Amendments :
188 and 165 (for Units 1 and 2 respectively).
There is inadequate discussion and justification for this STS deviation.
l CCNPP Response: t I
8 JFD.11 STS 3.4.11 Action E specifies the Required Same j
- Actions and Completion Times for two PORVs inoperable and not capable of being manually ;
cycled. STS 3.4.11 Required Action E.3 and E.4 [
require shutdown to MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and be in i MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.4.11 Action D retains !
t this requirement. However, ITS 3.4.11 Action D i deletes the requirements of STS 3.4.11 Action !
I restoring one PORV to OPERABLE status in 72 i h
hours. This is a deviation from the STS. The ;
justification for this deviation includes reference to l Amendments 188 and 165 (for Units 1 and 2 f
, respectively). There is inadequate discussion and j justification for this STS deviation.
)
i
i CCNPP ITS 3.4.11 PRESSURIZER POWER OPERATED RELIEF VALVES (PORVs) i 3.4.11 . DOC JFD CHANGE / DIFFERENCE COMMENT STATUS r
CCNPP Response:
9 JFD.1 STS SR 3.4.11.4 is not included in the ITS 3.4.11 Provide justification for the STS SRs. It is deleted. Deleting this STS SR is an deviation based on current licensing l STS deviation There is inadequate discussion and basis, system design, or operational justification for deleting this STS SR. constraints. !
I CCNPP Response- t i
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CCNPP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM 3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 This LCO will has to BE looked at in its entirety What does "to make it consistent again for conformance to your licensing basis and with"? Was the amendment issued for current requirements. It is difficult to know what the particular change. Provide a is in the LCO because of amendments and what is detailed discussion of the changes there for other reasons. a road map would help. allowed based on the amendments stated, not those that were deemed consistent with other changes that were allowed. It is necessary to distinguish actual changes allowed by amendments from those inferred by the amendment. Identify each amendment with each change and state specifically what these amendments allowed. Additional questions may then be generated.
1 CCNDP Response:
L
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CCNPP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM 3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT -' STATUS 2 A.4 CTS 3.4.9.3 Action g actions are deleted in the Provide additional discussion and ITS 3.4.12 Actions because they are eddressed in justification for deleting the
~
other ITS requirements. Specifically, if excessive requirement to verify a P/T violation did flow is encountered, the LTOP System is declared not occur during an excessive HPSI inoperable and the appropriate Actions of ITS flow event. Specify where this 3.4.12 are entered. Similarly, if a P/T violation is requirement now resides.
found to have occurred, the appropriate Actions of ITS 3.4.3 are entered. The discussion of change also states that the CTS 3.4.9.3 Action g requirement to verify that the excessive flow did not raise pressure above the P/T fimits is addressed in ITS 3.4.3. This is not the case; ITS 3.4.3 does not require this Action. There is inadequate discussion and justification for deleting this particular element of the CTS 3.4.9.3 Action g requirements.
CCNPP Response:
3 LA.1 CTS 3.4.9.3 LCO statements b, c, d, and e; and Specify which portions of the CTS CTS 3.4.9.3 Actions e and f specify requirements 3.4.9.3 LCO statements b, c, d, and e; for HPSI pump operation when the LTOP System and CTS 3.4.9.3 Actions e and f l is applicable. ITS 3.4.12 does not contain these remain in ITS 3.4.12. Also state what l requirements. The discussion of change states goes to the Bases and what to Plant
- that these requirements are moved either fully or Procedures. Identify the change control
- partially into plant procedures. However, it process for Plant Procedures (50.597).
! remains unclear which portions of the CTS requirements remain in the ITS.
(
l CCNPP Response:
4 i
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I CCNPP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM i
3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT- STATUS 4 LA.1 CTS 3.4.9.3 LCO statements b, c, d, and e; and SAME AS ABOVE CTS 3.4.9.3 Actions e and f specify requirements for HPSI pump operation when the LTOP System is applicable. ITS 3.4.12 does not contain these requirements. The discussion of change states that these requirements are moved either fully or partially into plant procedures.
CCNPP Response: '
5 JFD.14 The CTS 3.4.9.3 LCO statement a.1 requires tow SAME AS COMMENT # 1.
, PORVs with a trip setpoint below the curve in i Figure 3.4.9-3. ITS 3.4.12 LCO statements a and '
b modify the CTS 3.4.9.3 LCO statement by adding the phrase "on or" to the CTS statement of "below the curve." This ITS 3.4.12 change to the CTS is a deviation from the STS. The .
discussion and justification for this STS deviation states that the changes are made to the STS to make it consistent with Amendments 188,171, 146, and 145 (Unit 1); and Amendments 178, 165, and 131 (Unit 2).
- CCNPP Response:
I
_ _ 1 .-. . -_ - _. . - . . . _ - . - -
l CCNPP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM !
l l 3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
6 JFD.14 CTS 3.4.9.3 Action c requires depressurizing and see communt # 1 venting the RCS and then maintaining the unit in -
the vented condition. ITS 3.4.12 Actions D and E retains the CTS 3.4.9.3 Action c requirement to depressurize and vent the RCS by requiring depressurizing and venting the RCS. However, ITS 3.4.12 Actions D is added to the STS 3.4.12 Actions, making this a deviation from the STS. .
The justification for this STS deviation states in part that the changes are made to the STS to ;
make it consistent with Amendments 188,171, 146, and 145 (Unit 1); and Amendments 178, 165, and 131 (Unit 21. -
CCNPP Response:
0 7 JFD.24 CTS 3.4.9.3 MODES OF APPLICABILITY requires Provide discussion regarding system RCS temperature s 365"F and the RCS vented to design. ;
< 8 square inches. ITS 3.4.12 MODES OF :
APPLICABILITY changes the CTS MODES OF APPLICABILITY to specify MODE 3 with all RCS cold leg temperatures s 365"F (Unit 1) and s 301 *F (Unit 2), and MODES 4, 5, and 6. This change in the CTS MODES OF APPLICABILITY is a deviation from the STS. '
CCNPP Response:
I i
_ _ . . _ _ _ _ . - - _ _ _ _ _ _ . _ _ _ _ _ _ - .-m_ _ _ _ _ _ _ _ _ _ _ .
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I CCNPP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM i _
3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 8 JFD.14 The CTS 3.4.9.3 MODES OF APPLICABILITY SEE COMMENT # 1 requirement that the RCS is vented to < 8 square inches is moved to a Note in the ITS 3.4.12 MODES OF APPLICABILITY. Adding this Note to the ITS 3.4.12 MODES OF APPLICABILITY is a deviation to the STS. The justification for this deviation states that the changes are n.ade to the STS to make it consistent with Unit 1 Amendments 188,171,146, and 145 and Unit 2 Amendments 178,165, and 131.
CCNPP Response:
9 JFD.14 in addition to the HPSI pump requirement, the SAME STS 3.4.12 LCO statement requires one charging pump capable of injecting into the RCS and having the SITS isolated. The ITS 3.4.12 LCO statement does not include the charging pump and SIT requirements. This is a deviation from the STS.
There is inadequate discussion and justification for this STS deviation. The justification for this deviation states that the changes are made to the STS to make it consistent with Unit 1 Amendments 188,171,146, and 145 and Unit 2 Amendments 178,165, and 131.
CCNPP Response:
CCNPP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM
, 3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS l
t 10 JFD.14 ITS 3.4.12 adds a new LCO statement requiring lSAME one OPERABLE PORV with lift setting on or below the curve in Figure 3.4.12-1 and RCS vent of 2:
1.3 square inches. This new ITS LCO statement is a deviation from the STS. The justification for ,
this deviation states that the changes are made to
- the STS to make it consistent with Unit 1 Amendments 188,171,146, and 145 and Unit 2 Amendments 178,165, and 131.
CCNPP Response:
11 JFD.14 ITS 3.4.12 adds a new Note to the LCO statements specifying HPSI pump restrictions and <
PORV lift settings when in shutdown cooling.
This new ITS LCO Note is a deviation from the STS. The justification for this deviation states that the changes are made to the STS to make it consistent with Unit 1 Amendments 188,171, -
146, and 145 and Unit 2 Amendments 178,165, and 131.
CCNPP Response:
1
4 .
CCNPP ITS 3.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM 3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT : STATUS 12 The STS 3.4.12 MODES OF APPLICABILITY Note Provide justification for the STS is deleted in the ITS 3.4.12 MODES OF deviation based on current licensing APPLICABILITY. The STS MODES OF basis, system design, or operational APPLICABILITY Note specifies SlT limitations constraints.
related to RCS cold leg temperatures and P/T limit curves. Deleting this Note in the ITS is a deviation from the STS. There is no discussion or justification for deleting this Note.
CCNPP Response:
13 JFD.20 STS SR 3.4.12.4 requires verifying RCS vent 2 Provide justi.fication for the STS *
[1.31 square inches is open once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for deviation based on current licensing ;
unlocked open vent valve (s) and once per 31 days basis, system design, or operational for locked open vent valve (s). This requirement in constraints.
contained in ITS SR 3.4.12.2. However, the ITS t SR changes the STS requirement by adding a Note Explain what the pressurizer manway to the 31 day Frequency specifying that the 31 has to do with this SR and why. l day Frequency is applicable to the pressurizer manway. This change is a deviation from the THIS MAY BE A BEYOND SCOPE ,
STS. There is inadequate discussion and ISSUE justification for this STS deviation.
CCNPP Response:
3
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CCNPP ITS 3.4.13 RCS OPERATIONAL LEAKAGE 3.4.13 DOC .JFD CHANGE / DIFFERENCE COMMENT . STATUS 2 A.2 IT3 3.4.13 does not contain the RCS leakage Specify the ITS Specifications that betrumentation referenced by CTS 3.4.6.2. The now contain these SRs.
discussion of change states that the deleted monitors are requred by other ITS Specifications, but does not specify which ones.
CCNPP Response:
4 A.3 Most of the discussion focuses on the addition of TSTF 138 was rejected by NRC ITS SR 3.4.13.2 to the CTS 3.4.6.2 requirements. 4/11/97. Revise LCO accordingly.
However, at the end of the discussion, the focus changes to the addition of an "OR" statement to ITS 3.4.13 Action B. The discussion states that the "OR" statement is added to CTS 3.4.6.2 Action a ("With any PRESSURE BOUNDARY LEAKAGE, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."). The new ITS 3.4.13 Action B "OR" statement specifies "One or more SGs inoperable." to account for a Condition with one or two SGs inoperable. The new
^
ITS 3.4.13 Action B "OR" statement adds a requirement to CTS 3.4.6.2 and is therefore a more restrictive change. There is inadequate discussion and justification to support this more restrictive
- change. This more restrictive change is not consistent with the STS. Additionally, the STS markup for this change references TSTF 138.
CCNPP Response:
i
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CCNPP ITS 3.4.13 RCS OPERATIONAL LEAKAGE 4
-3.4.13 DOC JFD CHANGE / DIFFERENCE COMMENT - STATUS :
5 A.5 ITS SR 3.4.13.2 requires verifying SG tube integrity SAME AS ABOVE per the Steam Generator Tube Surveillance Program. ;
CTS 3.6.4.2 does not contain this requirement, nor '
does the discussion present issues associated with I CTS 3.6.4.2. Instead, the discussion focuses on CTS LCO 3.4.5, " Steam Generators," which requires each SG Operable, and specifies required SG tube i Surveillance Requirements. CTS 3.4.5 is incorporated into ITS 5.5.9, " Steam Generator (SG) Tube 1 Surveillance Program." Although ITS 3.4.13 neither -
l specifically requires the SGs Operable, nor specifies ,
SG tube SRs, it does place limits on RCS leakage; !
indirectly requiring the SGs Operable. CTS 3.4.5 is ,
included with the CTS 3.6.4.2 markup, and is the l location of the A.5 comment. The discussion states I that CTS 3.4.5 is incorporated into ITS 3.4.13. This is not the case. CTS 3.4.5 is incorporated into ITS -
5.5.9. ITS SR 3.4.13.2 adds a requirem'ent to the CTS and is therefore a more restrictive change. There ;
is no discussion or justification for this more restrictive change. Additionally, the discussion states f that SG OPERABILITY is determined by SG tube inspections per CTS 3.4.5 and ITS 5.5.9. However, l j
SG OPERABILITY includes other factors besides tube j inspections such as water level and temperature. The I discussion makes no reference to where those
! requirements have gone. Finally, the discussion states the change is consistent with TSTF 138.
i CCNPP Response:
I
- _ _ _ _ - _ - _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ - _ _ - _ _ _ _ - _ _ - _ _ _ - - _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ - - . - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ - . . _ _ . _ - - _ _ _ _ _ _ _ _ _
CCNPP ITS 3.4.13 RCS OPERATIONAL LEAKAGE 3.4.13 DOC JFD ' CHANGE / DIFFERENCE COMMENT STATUS 1
6 M.1 The discussion states that this more restrictive SAME AS ABOVE change is consistent with both the STS and TSTF 138. The STS markup contains a " cloud" with the STS 3.4.13 Condition B added "OR" requirement for one or more SGs inoperable. The STS does not contain this requirement. Additionally, this change is referenced to TSTF 138.
CCNPP Response:
7 L.1 The discussion of change focuses on the deletion of Are these same requirements in CTS Surveillance Requirements in ITS 3.4.13. Leakage Detetion?
However, the discussion and justification do not adequately describe how performing the RCS water inventory balance required by ITS SR 3.4.13.1 effectively replaces the monitoring functions performed by the CTS Surveillance Requirements.
CCNPP Response:
CCNPP ITS 3.4.14 RCS LEAKAGE DETECTION INSTRUMENTATION 3.4.14 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 L.6 Notes are added to ITS 3.4.14 Actions A.1 and B.1.2 Acceptance of this change is that allow waiting 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steady state contingent upon NRC approval of ,
conditicos are established before performing a RCS TSTF-116. !
inventory balance. CTS 3.4.6.1 does not allow this '
wait. The original STS 3.4.14 version does not contain these Notes either. The STS 3.4.14 markup inserts these notes with a reference to TSTF-116.
CCNPP Response:
2 CTS Surveillance Requirement 4.4.6.1 a references Provide discussion and justification ter the Frequencies specified in Table 4.3-3. There are the indicated changes. Specifically numerous changes to Table 4.3-3 with the only discuss how these requirements are change referenced to A.1. There is inadequate addressed by the ITS 3.4.14 SRs.
discussion and justification for the changes noted.
CCNPP Response:
3 The CTS 3.4.6.1 markup includes a Table 3.3-6 that Provide discussion and justification for contains several changes. The only reference to a the indicated changes on Table 3.3.-6.
discussion is A.1 and to see the discussion of change Specifically address how these for 3.3.3.1, " Radiation Monitoring instrumentation." changes relate to CTS 3.4.6.1 and ITS There is no discussion or justification for the noted 3.4.14.
changes in any of the discussion of change files for 3.4.6.1. In fact, CTS 3.4.6.1 does not reference Table 3.3.-6 at all.
CCNPP Response:
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CCNPP ITS 3.4.17 SPECIAL TEST EXCEPTION (STE)- MODES 4 AND 5 3.4.17 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 A.1 The markup for CTS Surveillance Requirement Provide additional discussion and l 4.10.5.2 changes the original wording of, "... prior to justification for this specific change suspending reactor coolant circulation." to "... prior to referenced by A.1. Specifically discuss suspending LCO 3.4.6, LCO 3.4.7, or LCO 3.4.8." the respective requirements of ITS This Surveillance Requirement is contained in ITS SR 3.4.6, 3.4.7, and 3.4.8 and justify 1 3.4.17.1 which requires verifying xenon reactivity is how suspending them does not affect i within limits once within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior to suspending plant safety. l LCO 3.4.6, LCO 3.4.7, or LCO 3.4.8. ITS 3.4.6, l "RCS Loops - MODE 4," ITS 3.4.7, "RCS Loops -
MODE 5, Loops Filled," and ITS 3.4.8, "RCS Loops -
MODE 5, Loops Not Filled," cach have notes allowing exceptions to their respective LCOs under certain conditions. Although this change is arguably an administrative change, it is not of the generic nature addressed by A.1. This change is consistent with the STS, but there is no discussion or justification for this specific element of the change.
CCNPP Response: -
CCNPP ITS 3.4.17 SPECIAL TEST EXCEPTION (STE) - MODES 4 AND 5 3.4.17 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS i
2 A.2 CTS 3.10.5.c requires verifying the shutdown margin Correct the discussion of change to per the requirements of CTS 3.1.1.2, " Shutdown accurately reflect the ITS 3.4.17 Margin - T, < 200*F," once per eight hours when contents.
no SDC pumps or RCPs are in operation. This requirement is moved to ITS SR 3.4.17.4. However, the discussion of change references two ITS SRs (i.e.,
ITS SR 3.4.17.4 and 3.4.17.5) that now contain the original CTS 3.10.5.c requirements, and two Notes that amplify and modify the ITS SRs. Neither the STS 3.4.17 markup, nor ITS 3.4.17 contain SR 3.4.17.5 or the referenced Note 1. ITS SR 3.4.17.4 does have i a Note that is the Note 2 referenced in the discussion of change. ITS 3.4.17 is consistent with STS 3.4.17.
This change is not adequately justified in the discussion of change.
CCNPP Response:
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_ _ . . - -m _ ,- r a w - .~e - - e +.~ .- -. - - ~ _ - . , ,--
,.,----,.-------4,g . , , , - - - . - - - - - _ - - - _ - - . - _ - , _ - - - - - -- _ - - - - _ _ - , - ,- ,,. - - - - _ -
CCNPP ITS SECTION 3.4 RELOCATED SPECIFICATIONS 3.4 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS No Comments i L
e f
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l RCS PlV Leakage 3.4.PlV DOC -JFD CHANGE / DIFFERENCE COMMENT STATUS PlV Leakage specification should be retained. LCO should be retained for consistency with the STS and also because there is nothing to preclude the inclusion of the LCO.
CCNPP Response:
9
CCNPP ITS 3.6.1 CONTAINMENT ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LC0 OPENED CLOSED 3.6.1-1 A4 CTS CTS 4.6.1.1.c. CTS 5/16/97 Licensee to update 4.6.1.1.c 4.6.1.1.d. and CTS 4.6.1.2 submittal with CTS require leak rate testing in regards to 11/2/95 4.6.1.1.d accordance with the Primary letter and updated CTS Containment Leakage Rate TSTF 52 when OG 4.6.1.2 Testing Program. STS SR provides revision or STS SR 3.6.1.1 requires the visual provides additional 3.6.1.1 examination and leakage rate justification for ITS SR testing be performed in deviations.
3.6.1.1 accordance with 10 CFR 50 and Appendix J as modified by Associated approved exemptions. ITS SR Bases 3.6.1.1 modifies STS SR 3.6:1.1 to conform to CTS 4.6.1.1.c. CTS 4.6.1.1.d.
and CTS 4.6.1.2 as modified by Amendment 219 for Unit I and Amendment 196 for Unit
C1anges to the STS with regards to Option A versus s Option B are covered by a letter from Mr. Christopher I. Grimes to Mr. David J.
Modeen. NEI dated 11/2/95 and TSTF 52. The ITS changes are not in conformance with the letter or TSTF 52 as modified by staff comments.
CCNPP Response:
1.
t 4
CCNPP ITS 3.6.1 CONTAINMENT.
- ITEMm 00C/1 CTS /STS DESCRIPTION OF ISSUE- DATE DATE COPMENTS ;
N0. JFD LC0 OPENED CLOSED !
3.6.1-2 A.4 CTS CTS 4.6.1.1.c which requires 5/16/97 Provide a discussion.
4.6.1.1.c verifying that each and justification for !
containment air lock is in this deletion. ;
compliance with the
. requirements of CTS 3.6.1.3 is deleted. No ,
justificatior, is provided -
for this deletion. A.4 only discusses the Containment .
Leakage Rate Programs.
CCNPP Response:
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CCNPP'ITS 3.6.1 CONTAINMENT ITEM DOC /. . CTS /STS DESCRIPTION OF-ISSUE' DATE DATE COPMENTS NO. JFD LCO OPENED CLOSED 3.6.1-3 A.5 CTS Unit 1 CTS 3.6.1.6 ACTION b 5/16/97 Provide additional Bases 3.6.1.6 requires an engineering .
discussion and 2
JFD 7 ACTION a evaluation that assures the justification .for and b. structural integrity prior this Administrative ITS B3.6.1 to increasing RCS change. See Item Bases temperature > 200 F when the Number 3.6.1-4 and Sk 3.6.1.2 containment is'not in 3.6.1-5.
conformance with CTS 4.6.1.6.2-End Anchorages and i Adjacent Concrete Surfaces and 4.6.1.6.3-Containment Surfaces. A.5 equates this Action with CTS 3.6.1.6' ACTION a which requires a shutdown to MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This comparison is incorrect. CTS 3.6.1.6 allows 90 days to restore integrity or perform the engineering evaluation, but it only applies if containment integrity does not meet the criteria'of CTS 4.6.1.6.1-Containment iendons. If the criteria of CTS 4.6.1.6.2 and CTS 4.6.1.6.3 are not met when i
the RCS temperature is >
200 F. then an immediate entry into CTS 3.0.3 is required. Thus the justification is wrong. A justification similar to A.3 would be more appropriate.
See Item Numbers 3.6.1-4 and 1
3.6.1-5.
i' 3'
_ _ _ _ _ .._____ _ _.___~ _ . _ . . _ _ . . _ _ _ _ _ _
CCNPP ITS 3.6.1 CONTAINMENT - !
ITEM DOC /- CTS /STS DESCRIPTION OF-ISSUE DATE DATE -CO E NTS !
NO. JFD. LCO OPENED CLOSED l
CCNPP Response:
f 3.6.1-4 LA.1 CTS Unit 1 CTS 3.6.1.6 FTION a 5/16/97 Either delete this t L.1 3.6.1.6 allows 90 days to. restore requirement and l Bases ACTION a. containment' tendon integrity provide discussion .
JFD7 ITS B3.6.1 or perform an engineering and justification.for Bases-SR evaluation that assures the this deletion (More >
3.6.1.2 structural integrity when Restrictive (M)), or ;
the containment tendons are provide-the ;
not in conformance with CTS .
appropriate i 4.6.1.6.1. This requirement Conditions. ras and ;
is being moved to ITS B3.6.1 Completion Times in i BASES - SR 3.6.1.2. The ITS 3.6.1 as-well as l-relocation of this appropriate requirement to ITS B3.6.1 discussion and BASES SR 3.6.1.2 is justification for unacceptable. ITS 3.6.1 this administrative ACTIONS recuire containment change. See Item :
be restorec to OPERABLE Numbers 3.6.1-3 and- i status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or. 3.6.1-5. ,
shutdown to MODE 5 in 36 l hours. It does not allow 90 days to restore or perform '
an engineering evaluation.
Therefore, the 90 days is considered as an Allowed Outage Time (A0T) specific -
to Unit 1 CCNPP and would .
require appropriate l Conditions. ras and !
Com)letion Times. See Item .
Num)ers 3.6.1-3 and 3.6.1-5. '
CCNPP Response: !
1 4
L i
., - - - . - - . -. . -.-~~..,-.,...-...,--..n. . . . _ ~ . ~ . . . . . ~ . . - .....,...~.._m .. - -. - ,...
E CCNPP ITS 3.6.1 CONTAINMENT ~
l :
ITEM DOC / CTS /STS DESCRIPTION OF-ISSUE ~DATE DATE COPetENTS :
NO. JFD LC0 OPENED- CLOSED-3.6.1-5 LA.1 Unit 1 Unit 1 CTS 3.6.1.6 ACTION a- 5/16/97 Either delete this- j L.1 CTS allows 90 days to restore requirement and Bases 3.6.1.6 containment tendon integrity provide discussion l
~JF07 ACTIONS a or perform an engineering and justification for !
and b evaluation that assures the this deletion (More !
Unit 2 structural integrity when Restrictive (M)) or l CTS the containment tendons are -provide, only for i 3.6.1.6 not'in conformance with. CTS Unit 1 containment ;
ACTION 4.6.1.6.1. This requirement tendons inoperable. !
- ITS B3.6.1 is being moved to:ITS B3.6.1 the appropriate i BASES- Bases-SR 3.6.1.2. The Conditions. ras and 'l SR 3.6.1.2 unacceptability of the Completion Times as :
relocation'is discussed in well as appropriate l Item Number 3.6.1-4.- discussion and !
However retention of this justification for :
, requirement in the ITS in this !
the form it is now is Administrative /Less. ,
unacceptable. . Unit l*s Restrictive change. ;
current licensing basis has See Item Numbers i this A0T requirement 3.6.1-3. and 3.6.1-4. !
applying only to containment !
tendons (CTS 3.6.1.6, ACTION .[
4 a/ CTS 4.6.1.6.1) not to end !
anchorages and adjacent concrete surfaces (CTS i i
3.6.1.6 ACTION b/ CTS !
4.6.1.6.2) and containment !
surfaces (CTS 3.6.1.6 ACTION b/ CTS 4.6.1.6.3) and see Item Numbers'3.6.1-3. In addition. Unit 2 CTS 3.6.1.6 t ACTION does not include this i requirement. Unit 2 CTS !
3.6.1.6 ACTIONS allows 24 l
hours to restore integrity. !
not 90 days. Furthermore. !
Unit 2 changes the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i !
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_ _ , _ _ . _ _ . . _ . . _ . _ _ _ _ .-. - .. _ . - _ . _ . _ . _ . ..~ - . . _ . _ .. . _ m . . . _ . . 1 i
CCNPP ITS 3.6.1 CONTAINMENT
.i ITEM. DOC / CTS /STS: ~
DESCRIPTION OF ISSUE. DATE DATE~ COPtiENTS. ._
NO.' JFD ~ LCO OPENED CLOSED l
change. Therefore, to >
implement this change as proposed would require a staff evaluation with ,
regards to CTS 3.6.1.6
- ACTION b and Unit 2 CTS 3.6.1.6 ACTION. .This is I beyond the scope of review '
for this conversion.
CCNPP Response: t I
3.6.1-6 None CTS CTS 4.6.1.1.d was added by 5/16/97 Correct this i 4.6.1.1.d Unit 1 Amendment No. 221 and discrepancy. !
ITS Unit 2 Amendment No. 197 to !
5.5.1.6 allow use of blind flanges :
for the Containment Purge !
System instead of the two i outboard 48 inch isolation !
valves during MODES 1 to 4. !
Insert A in the CTS markup '
differs from the staff {
approved amendments (197 and i 221) and the insert 5.5.16 in ITS 5.5.1.6.
CCNPP Response:
l' 3.6.1-7 Bases ITS 5.5.6 ITS B3.6.1 Bases-REFERENCES 5/16/97 Correct this i None ITS B3.6.1 lists Reference 4 as discrepancy. (
Bases Regulatory Guide 1.35 >
REFERENCES Revision 0. while ITS 5.5.6 specifies Revision 2 of the i same document.
l CCNPP Response:
e
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6 _
CCNPP ITS 3.6.2 CONTAINMENT AIR LOCK ITEM DOC / CTS /STS DESCRIPTION DE ISSUE DATE DATE COMMENTS NO. JFD LC0 OPENED CLOSED 3.6.2-1 A.5 CTS See Item Number 3.6.1-1 5/16/97 See Item Number 4.6.1.3a 3.6.1-1.
ITS B3.6.2 BASES CCNPP Response:
3.6.2-2 L.2 CTS CTS 3.6.1.3 ACTION b 5/16/97 Provide additional-3.6.1.3 requires that when an air justification and ACTION b lock is inoperable as a discussion for this ITS 3.6.2 result of an inoperable door More Restrictive ACTION A gasket. that the OPERABLE change. See Item and C and door of the air lock be 3.6.2-3.
Associated maintained locked closed and Bases sealed, and the air lock restored to OPERABLE status within 7 days. L.2 states that the appro)riate ACTION to follow in t1is case is ITS 3.6.2 ACTION A. This is incorrect. The appropriate ACTION to enter in this condition is ITS 3.6.2 ACTION C. The basis for this is found in ITS B3.6.2 BASES RA C.1. Thus the change becomes a more restrictive change. See Item Number 3.6.2-3.
CCNPP Response:
1
= _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . - . .. - - - - - - - _ . . . - - . . _ . - . - _ . - . _ __
CCNPP'ITS 3.6.2 CONTAINMENT AIR LOCK e ITEM DOC /- CTS /STS DESCRIPTION OF ISSUE. DATE DATE COPMENTS' I
NO. JFD LCO OPENED CLOSED i 3.6.2-3 L.4 CTS ITS 3.6.2 ACTION RA A- 5/16/97 Provide 3.6.1.3 contains a Note 2 which additional i ACTION B allows entry and exit into justificati ;
ITS 3.6.2 containment for seven days on and RA A under administrative discussion Note 2 controls if both air locks for this ;
are inog rable. The Less i justification L.4 uses CTS Restrictive 3.6.1.3.b as part of the change. 1 basis for adding this !
Note. Bases on Item Number !
3.6.2-2. L.4 is incorrect. l CCNPP Response:
3.6.2-4 None STS 3.6.2 Changes are made to STS 5/16/97 Licensee to I Bases B3.6.2 Bases SR 3.6.2.2 to update SR 3.6.2.2 bring it into conformance submittal -
ITS B3.6.2 with TSTF-17. The changes with i Bases made do not conform to the regards to ;
SR 3.6.2.2 approved version of TSTFO- 'TSTF-17 or
- 17. provide additional- I discussions ,
and justificati .
ons for the i deviations. *
- CCNPP Response
l 2 l
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CCNPP ITS 3.6.3 CONTAINMENT ITEM DOC / CTS /STS' DESCRIPTION OF ISSUE DATE- DATE COPfiENTS NO. JFD LCO OPENED CLOSED 3.6.3-1 A.5 CTS ITS 3.6.3 will contain an 5/16/97 Provide additional .
3.6.4.1 ACTIONS Note 2 which allows discussion and ITS 3.6.3 separate condition entry for justification for each penetration flow path. this Administrative CTS 3.6.4.1 ACTIONS do not change.
contain this requirement. >
The justification states that the Note is consistent with the intent of the CTS ACTIONS for the containment air locks. This is !
incorrect. The '
justification needs to be consistent with the CTS for containment isolation valves since the same !
change was done for containment air locks. ,
CCNPP Response:
l I
1 1
_ _ _ . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ ~ .-_ -c-- - - . . - - , - , ,-v . , - . -m = e- . --
-.w... e.,a . . . . . .- ,-
t CCNPPLITS-3.6.3 CONTAINMENT- j 4
ITEM DOC /J CTS /STS DESCRIPTION OF: ISSUE' '
DATE' DATE- CONMENTS. '
1 NO. JFD LCO OPENED CLOSED i
3.6.3-2 M.2 CTS 3.6.4 ITS 3.6.3 RA B.2 contains 5/16/97 Licensee to update !
BASES ACTIONS requirements to verify the submittal in .
JFD 6 ITS 3.6.3 affected penetration flow accordance with TSTF- ;
RA B.2-and path is isolated once per 31 145 as modified by Associated days' for isolation devices the staff or provide -t BASES outside Containment. ITS additional discussion 4 3.6.3 RA B.2 contains an and justification for !
additional requirement for the deviations.
isolation devices inside .
Containment.to verify the !
affected penetration _ flow ;
path is isolated prior to ;
entering MODE 4 from MODE 5, 1 if not performed within the .!
)revious 92 days. :ITS 3.6.3 1 M B.2 is modified by a Note-allowing isolation devices ,
in high radiation areas !
verified admimstratively. !
CTS 3.6.4.1 does not contain !
this allowance. The STS !
markup for ITS 3.6.3.B.2 !
references TSTS-145 as i justification for adding l B.2. The changes to ITS !
B3.6.3 Bases-RA B.1 and B.2
- is not in accordance with . --.!
TSTF 145 as modified by the i staff. I f
CCNPP Response:
3.6.3-3 M.3 CTS See Item Number 3.6.7-1 5/16/97 See. Item Number i L.5 -3.6.1.1 3.6.7-1 !
JFD 5
- Footnote !
BASES !
JFD 6 i i
2 y
CCNPP ITS 3.6.3 CONTAINMENT ITEM DOC / CTS /STS- DESCRIPTION OF ISSUE- DATE - DATE COMMENTS NO. JFD- LC0 OPENED CLOSED CCNPP Response:
3.6.3-4 LA.2 CTS The post-maintenance testing 5/16/97 Provide a description 4.6.4.1.1 required by CTS 4.6.4.1.1 is of the plant .l not contained in ITS 3.6.3. procedures to which Rather. this requirement is -the post-maintenance
- moved into plant procedures. testing requirements This_ places requirements are relocated and the outside of the ITS into change control
' Licensee controlled process for these .
documents. There is not an procedures. t i adequate discussion and justification of how
. specific post-maintenance testing requirements are addressed and controlled by plant procedures. '
CCNPP Response:
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l CCNPP ITS 3.6.3 CONTAINMENT l
ITEM. 00C/ CTS /STS- DESCRIPTION OF. ISSUE DATE' DATE- COMENTS- !
NO. JFD LCO OPENED CLOSED :,
3.6.3-5 L.3 CTS- CTS 4.6.1.1.a requires 5/16/97 Provide additional-.
4.6;1.1.a verifying once per 31 days discussion and -
and that all penetrations not justification for ,
Associated capable of being closed by adding the phrase ,
- Footnote OPERABLE containment "and are not-locked.
ITS SR automatic isolation valves, sealed, or otherwise !
3.6.3.2 but that are required to be- secured" to CTS i ITS SR closed during accident 4.6.1.1.a. See Item ;
3.6.3.3 conditioris. are closed by
~
Number 3.6.3-13. .
and valves, blind flanges, or Associated deactivated automatic valves Bases secured in their positions. :
Footnote ** to CTS 4.6.1.1 i excepts those valves.. blind flanges.. or deactivated
. automatic valves located inside containment from the ;
31 day verification ;
frequency. but specifies that they must be verified .
during each MODE 5 if not i performed in the prevjous 92 days. ITS SRs 3.6.3.2 and i 3.6.3.3 require performing ;
the same verification.
However, they are modified '!
by a Note which allows i verifying valves, blind. i flanges, or equivalent in high radiation areas by
inserts t1e phrase "and are j i not locked. sealed, or :
otherwise secured." There is no discussion or justification provided for 4
.-. -_ _ _ _ _ _ _ . _ - - _ _ - _- - - _ - - - - _ _ .. . _ _ _ - _- _ ..: _.. .. - _ _ -..a - - . . - . . - . .
CCNPP ITS 3.6.3 CONTAINMENT.
-t ITEM DOC / CTS /STS' DESCRIPTION OF ISSUE.- DATE- . DATE COP 91ENTS ;
l NO. JFD LC0 ODENED CLOSED ;
i inside containment: not all valves or valves outside ,
containment which is not the focus of L.3. See Item Number 3.6.3-13. >
CCNPP Response: -
l 4 3.6.3-6 L.6
! CTS CTS Surveillance Requirement 5/16/97 Delete this change. !
L.7 4.6.1.1.a 4.6.1.1.a requires all -
t CTS mnetrations not capable of 3.6.4.1 ming closed by OPERABLE :
ACTION C CIVs. and'are required !
ITS 3.6.3 closed during accident r RA A.1 conditions, are verified !
ITS 3.6.3 closed by valves, blind RA B.1 flanges, or deactivated .
i ITS 3.6.3 automatic valves secured in :
3.6.3.2 ITS 3.6.3 RA C.1. ITS SR l' ITS SR 3.6.3.2 and ITS SR 3.6.3.3 3.6.3.3 allow penetrations to be and isolated by an equivalent l Associated isolation device. The STS i Bases markup for this change !
references CEOG-112. CEOG- !
112 is TSTF 1% which has '
been rejected by the staff.
f CCNPP Response:
3.6.3-7 Bases ITS ITS B3.6.3 Bases- RA C.1 and 5/16/97 Correct this !
JFD 3 B.3.6.3 C.2 last paragraph has no discrepancy. !
Bases- changes associated with it. !
RA C.1 and Yet it is marked with Bases !
C.2 JFD 3.
)
CCNPP Response:
5 ;
i
- . - . . . , _ _ . _ . _ , _ _ . - . ..--_-__.m. . . _ . . _ _ . . . . . . . . . , _ . . _ . . . _ . . . , - . . _ . - . ~ . . _ - . _ _ . , - . . . ~ _ - . - . - , . . - . . _ . _ . , . _ . _ _ . - . _ . . _ . ,
CCNPP ITS 3.6.3 CONTAINMENT I
ITEM 00C/ CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LOO OPENED CLOSED 3.6.3-8 None CTS CTS 3.6.4.1 ACTIONS adds a S/16/97 Provide a discussion 3.6.4.1 Note to bring the CTS into and justification for ACTIONS conformance with ITS 3.6.3 this administrative
. ITS 3.6.3 Conditions A and B. No change.
Conditions justification is provided A and B for this administrative and change.
Associated Bases.
CCNPP Response:
3.6.3.9 None CTS CTS 3.6.4.1 ACTIONS adds a 5/16/97 Provide a discussion 3.6.4.1 Note to bring the CTS into and justification for ACTIONS conformance with ITS 3.6.3 this administrative ITS 3.6.3 Condition C. No change. See Item Condition justification is provided Number 3.6.3-12.
C and for this administrative Associated change. See Item Number Bases 3.6.3-12.
CCNPP Response.:
3.7.3-10 None CTS CTS 4.6.4.1.1 # Footnote is 5/16/97 Provide a discussion 4.6.4.1.1 being moved from CTS 3.6 to and justification for
- Footnote ITS 3.3.7 " Containment this administrative Radiation Signal." No change.
justification is provided for this administrative ;
change.
CCNPP Response:
3.6.3-11 None CTS CTS 4.6.1.1.b. 4.6.1.1.c. 5/16/97 Provide a discussion } '
4.6.1.1.b. and 4.6.1.1.d are being and justification for 4.6.1.1.c. moved from CTS 3.6 to ITS this administrative and 5.5.16. No justification is change.
4.6.1.1.d provided for this administrative change.
6
r CCNPP ITS 3.6.3 CONTAINMENT ITEM DOC / CTS /STS DESCRIPTION OF. ISSUE DATE DATE COMENTS NO. JFD LCO- u OPENED CLOSED CCNPP Response:
, 3.6.3-12 None STS 3.6.3 ITS 3.6.3 Condition C 5/16/97 Provide a discussion 4 Condition modifies STS 3.6.3 Condition and justification C C'and associated Note to based on current ITS 3.6.3 include more than one licensing basis.
Condition containment isolation valve system design, or C and in a closed system. The operational ,
Associated change is designated CE0G- constraints.
It is the staff's Bases 106. t understanding that this change is not generic and has been withdrawn from the generic review process, but will.be submitted as a plant !
specific change.
CCNPP Response:
3.6.3-13 None STS STS SR 3.6.3.3. SR 3.6.3.4 5/16/97 1.icensee to update SR 3.6.3.3 and their associated Bases submittal in i STS have been modified by TSTF accordance with TSTF SR 3.6.3.4 45 Rev. 1. ITS SR 3.f.3.2 f 45 Rev 1 or provide i and and SR 3.6.3.3 have additional discussion Associated incorporated TSTF 45. and justification for Bases However, their associated the bases deviation.
ITS bases are not in accordance SR 3.6.3.2 with TSTF-45.
ITS SR 3.6.3.3 and Associated l Bases CCNPP Response: !
7 ,
. - - . . . _ _ - - . - - - - - _ - . . . _ , - - . - - - - - - _ . - - - _ - - - - _ . - - _ - - - - - - - - - - . . _ , _ . - ._- -.v .-,,-----w ,-- - - . , . - - - - a n ,.n --- - -
CCNPP ITS 3.6.4 CONTAINMENT PRESSURE ITEM DOC / CTS /STS~ DESCRIPTION OF ISSUE- DATE DATE C0tt1ENTS
~
NO. JFD LCO OPENED CLOSED No coments for 3.6.4 F
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CCNPP ITS 3.6.5 CONTAINMENT AIR TEMPERATURE ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE C0tt1ENTS NO. JFD LCO OPENED CLOSED 3.6.5-1 LA 2 CTS CTS 4.6.1.5 requires 5/16/97 Specify tile 4.6.1.5 determining the containment temperature ITS B3.6.2 average air temperature as indication locations BASES the arithmetical average of in ITS B3.6.5 BASES-
.SR 3.6.5.1 the temperature at the SR 3.6.5.1.
containment dome and the containment reactor cavity. Provide a description ITS SR 3.6.5.1 requires of the plant determining the primary procedure to which containment average air the temperature temperature, but does not indication locations specify temperature are relocated and the indication locations. The change control temperature indication process for these locations are moved into the procedures.
~
Bases and plant procedures.
ITS B.3.6.2 Bases-SR 3.6.5.1 does not specify the temperature indication locations, nor is it specified elsewhere in ITS B3.6.5. The specific, plant procedures and associated controls are not indicated.
CCNPP Response:
1
CCNPP CTS 3/4.6.5.1 HYDROGEN ANALYZERS ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE- DATE COPf1ENTS NO. JFD LCO OPENED CLOSED 3/4.6.5. None CTS CTS 3/4.6.5.1 is being moved 5/16/97 Provide a discussion 1-1 3/4.6.5.1 to ITS 3.3.10 " Post Accident and justification for Monitoring Instrumentation." this Administrative No justification has been change.
provided for this Administrative change.
CCNPP Response:
b O
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I
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CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS '
ITEM ' DOC / CTS /STS- DESCRIPTION OF ISSUE' DATE . DATE -. COPetENTS NO. JFD= LCO CPENED CLOSED' 3.6.6-1 A.1 CTS CTS 4.6.2.'1.a;1-and CTS 5/16/97 Provide cdditional LA.4 4.6.2.1. 4.6.2.1.b.1 specify the discussion and .
a.1 Containment Spray System justification for .
CTS alignment for various test these Less !
4.6.2.1.b. signals. LA.4 justifies the Restrictive (LA) and 1 relocetion of the test Administrative signals to the ITS Bases changes. i B3.6.6. The alignment characteristics are deleted l with no justification and replaced with the words !
" activates to the correct -
position." This change is designated A.1. A.1 is a ;
general reformatting justification, and is the !
incorrect justification for ;
this change. The deleted ':
alignment requirements t should be relocated to the t ITS Bases 83.6.7 (Less i Restrictive (LA) change) and 3 the replacement words ,
justifled (Administrative !
change). i CCNPP Response: ,
t 1 !
t
-_-- _ __ __ _ __ _ _ __ _ _ --_ _ __._ _ _ _ ----- _ _ ___ __-- _ . _ _ -___ . . . . . _ _ _ _ _ . _ . _ _ . . - _ _ _ _ _ _ . _ _ , . . _ _ . _ _ _ __.?
j ,
CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS. !
ITEM- DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE Cott1ENTS !
N0.' JFD LCO OPENED CLOSED '
3.6.6-2 A.5 CTS CTS 4.6.2.1.a.1. 5/16/97 Provide additional 1 4.6.2.1.a. 4.6.2.1.b.1. 4.6.2.1.c.1. discussion and i 1 4.6.2.1.c.2 and 4.6.2.2.b justification to i CTS require that valves actuate include the 4.6.2.1.c. to their correct-position Containment Cooling .
CTS and that,the containment System.
4.6.2.1.b. spray pump starts on 1 smcific test signals. !
CTS W111e this statement may be 4.6.2.1.c. for-the Containment Spray -
2 System. CTS 4.6.2.2.b deals CTS with the Containment Cooling .
4.6.2.2.b System. The Containment .
Cooling System according to ,
the ITS Bases and the CTS is '
an entirely different system not connected to the Containment Spray System.
CCNPP Response:
i
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2
_ _ . . _ . _ _ _ _ . _ _ - - _ . _ _ . _ - _ , _._._m_. _.m.___.-_ __ ________:____._________.___
_am ___m____ ._____ _ _ _ _ _ _ _ _ . _ _ _ . _ . . ___ .s- a ., e w-. m,.i_,.-,,=ww.--ws*r +- -.%. - -
em
CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED- CLOSED 3.6.6-3 M.1 CTS Amendments 218 for Unit 1 5/16/97 Provide additional L.4 4.6.2.1.a. and 195 for Unit 2 discussion and 1 rearranged CTS 4.6.2.1.a.1. justification for CTS 4.6.2.1.A.2. 4.6.2.1.B.1 this Administrative .
4.6.2.1.b. 4.6.2.1.b.2 and 4.6.2.1.c.2. change.
1 to 4.6.2.1.b.1. 4.6.2.1.a.1.
4.6.2.1.c.1. 4.6.2.1.c. and 4.6.2.1.d respectively. ITS SR 3.6.6.1 requires verification that each -
containment spray manual, power-operated, and automatic valve in the
'flowpath that is not locked, sealed. or otherwise secured in position is in the correct )osition. H.1 states tlat CTS 3.6.2.1 does not contain this requirement. The staff has determined that ITS SR 3.6.6.1 is encompassed by the new CTS 4.6.2.1.a.'1.
Thus'this part of the justification is an Administrative change.
CCNPP Response:
1 I
L n
i 3 l
CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS ITEM DOC / CTS /STS' DESCRIPTION OF-ISSUE- DATE: DATE COPMENTS.
NO. JFD LCO OPENED- CLOSED .
3.6.6-4 H.4 CTS ITS 3.6.6 ACTION A and C 5/16/97 Provide additionalL 3.6.2.2 contains a limit on the discussion and
! ACTION a- total combined duration of justification for ITS 3.6.6 operation for one this Less Restrictive j ACTION c containment spray train change. I (ACTICfi A) and one containment cooling train (ACTION C) inoperable of 10 days from discovery or failure to meet LCO. This will prevent continuous operation in a degraded condition by entering the two Actions repeatedly. -M.4 states that CTS 3.6.2.1 and 3.6.2.2 do not contain this limitarion. However. CTS 3.6.2.2'does have this limitation associated with '
4 it when one containment spray system is' inoperable. -
CTS requires 3.6.2.2 ACTION c initial 7 days from loss.to restore the systems.
Thus the change for CTS 3.6.2.2 is Less Restrictive not More Restrictive (7 days to 10 days). . .
CCNPP Response:
4
CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LC0 OPENED CLOSED 3.6.6-5 LA.3 CTS CTS Surveillance Requirement 5/16/97 Provide a description 4.6.2.2.a. 4.6.2.2.a.3 requires of the plant 3 verifying cooling water flow . procedure to which ITS SR when the flow service water the water flow 3.6.6.3 outlet valves are fully requirement is open. ITS SR 3.6.6.3 relocated and the requires verifying the flow change control rate. but does not specify process for this valve position. This procedure.
requirement is moved to plant procedures. ) lacing it outside of the Tec1nical Specifications into Licensee controlled documents.
resulting in a Less Restrictive technical change.
CCNPP Response:
5
CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS ITEM 00C/. CTS /STS DESCRIPTION OF ISSUE DATE DATE- COMMENTS NO. JFD LC0~ OPENED CLOSED 3.6.6-6 L.1 CTS CTS 3.6.2.1 ACTION requires 5/16/97 Modify the Completion 3.6.2.1 the plant in MODE 3 in 6 Time for ITS 3.6.6 RA ACTION hours, and in MODE 5 within B.2 to reflect the STS 3.6.6 the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> when actual time needed to ACTION B the Required Actions and exit the ITS 3.6.6 associated Completion Times APPLICABILITY.
ACTION B cannot be met. STS 3.6.6 Provide additional and ACTION B requires that the discussion and Associated )lant be in MODE 5 within 84 justification for ,
Bases lours. ITS 3.6.6 ACTION 8 this More/Less !
requires that the plant be Restrictive change. l in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in !
MODE 3 with pressurizer '
pressure < 1750 psia within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. The STS Completion Times for RA B.2 was based on the APPLICABILITY being MODES 1 through 4. Since CCNPP's APPLICABILITY only goes to MODE 3 with pressurizer pressure < 1750 psia. the Completion Times in the CTS (36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to MODE 5) and ITS (84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> to MODE 5) should be modified accordingly.
This change may be More Restrictive or Less Restrictive depending on the Completion Time.
CCNPP Response:
6
CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS -
ITEM DOC /' CTS /STS. DESCRIPTION OF ISSUE DATE DATE COPMENTS.
NO. JFD LCO OPENED CLOSED 3.6.6-7 L.4 CTS CTS Surveillance . 5/16/97 Provide addtional 9 4.6.2.1.a. Requirements 4.6.2.1.a.1 and discussion.
1 4.6.2.1.b.1 require- justification and CTS verification that the appropriate marked.up_
4.6.2.1.b. Containment Spray system CTS pages for this 1 (including RAS) valves and Administrative /Less ITS pumps to perform (actuate to Restrictive change.
SR 3.6.6.5 the correct position and ITS SR start, respectively) as 3.6.6.6 -required on an actuation signal once per 31: days and once per 92 days respectively. ITS SRs 3.6.6.5 and 3.6.6.6 require the test to be performed once per 24 months. ITS SRs 3.6.6.5 and 3.6.6.6 decrease the Frecuency from 31 days and 92 cays to 24 months.
Although the surveillance frequency is being decreased. verification that the valves actuate and pumps start when required will still be performed in conjunction with the ESFAS subgroup relay tests which require end device actuation every 92 days.
Justification L.4 does not state where this test is located. If it is located in ITS 3.3 then this portion of the change is an administrative change. If it is located in plant procedures or other licensee 7
1 CCNPP ITS 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS ITEM DOC /- CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS :
NO. JFD LCO OPENED: CLOSED controlled document then it is a Less restrictive (LA) '
change.
CCNPP Response:
3.6.6-8 JFD 6 ITS 3.6.6 JFD 6 states that a Note 5 5/16/97 Correct this ACTIONS has been added to ITS 3.6.6 discrepancy.
Note ACTIONS. ITS 3.6.6 ACTIONS ,
show only one Note being added. There is no Note 5.
CCNPP Response:
3.6.6-9 BASES ITS B3.6.6 ITS B3.6.6 Bases-BACKGROUND 5/16/97 Delete this change.
JFD 8 Bases- " Containment Spray System" BACKGROUND section second paragraph.
first sentence changes the j word " reduce" to " minimize."
This change was reviewed by the staff as ) art of EDIT-18 and rejected Jased on the fact that it was a technical change with insufficient justi fication.
CCNPP Response:
3.6.6-10 None ITS B3.6.6 ITS B.3.6.6 Bases-BACKGROUND 5/16/97 Provide a discussion Bases- " Containment Spray System" and justification for BACKGROUND section second paragraph, these deletions.
first sentence and third ;
paragraph deletes all reference to Spray Additive System. No justification is provided in this section for these deletions.
CCNPP Response:
8 -
- - - - . .. -. . . . . . . - . . - - . .,.- - .- _ . _. ._ _ _ _ _ . _. _ _ _ - . ._ ?
CCNPP CTS 3/4.6.6.1 PENETRATION R00H EXHAUST AIR FILTRATION SYSTEM i ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE- DATE C0tmENTS --
NO. JFD LCO' OPENED CLOSED 1
3/4.6.6. None CTS CTS 3/4.6.6.1 is being moved 5/16/97 Provide a discussion !
1-1 3/4.6.6.1 to ITS 3.7.12 Penetration and justification for Room Exhaust Ventilation this Administrative System. No justification change.
has been provided for this Administrative change. -
CCNPP Response: ,.
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L .ITS 3.6.7 tlYDR0 GEN RECOMBINERS. ,
ITEM: DOC /- CTS /STS DESCRIPTION'0F ISSUE. DATE . DATE C0PetENTS1 NO. -JFD- LC0 OPENED - CLOSED 3.6.7-1 L.1 CTS CTS 3.6.5.2 does not specify 5/16/97 Provide additional '
Bases 3.6.5.2 an ACTION when two hydrogen discussion and JFD 2 ITS 3.6.7 recombiners are inoperable. justification based ACTION B Therefore, if two hydrogen on current licensing s and recombiners are inoperable, basis. system design.
Associated a shutdown per LCO 3.0.3 is or operational :
Bases required. ITS 3.6.7 constrains as well as- i Condition B adds Required appropriate i Actions and Completicn Times documentation to show i for two hydrogen recombiners that ITS 3.6.7 ACTION }
- inoperable. However. B applies to CCNPP '
instead of requiring entry and the CTS is in ~
, into the LCO 3.0.3 shutdown error. '
track as in CTS 3.5.6.2. ITS 3.6.7 ACTION B allows 7 days i
to restore one hydrogen recombiner to OPERABLE !
status when two are inoperable. ITS 3.6.7 '
ACTION B also requires administratively verifying the hydrogen control ,
function within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after both hydrogen recombiners become ino wrable and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> t1ereafter. ITS ;
B3.6.7 Bases-RA B.1 and B.2 and justification L.1 state that the hydrogen control function is provided by i Containment Vent / Hydrogen
- CCNPP Response:
1
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_ -mo---_-_..__wm__.-____._ m-- _____m--'___L_ m__tw-P--*-_ _ - - --e-a'- u-2h.______w1me-P-*--_humi.a__A-A_a h___si-___i4e*-vwr= ==.--ee-
ITS 3.6.7 HYDROGEN RECOMBINERS ITEM 00C/ CTS /STS DESCRIPTION OF ISSUE. DATE- DATE COMMENTS NO. JFD LCO OPENED CLOSED Purge System. However CTS 3.6.1.1
- Footnote (justification M.3 in ITS 3.6.3) only allows the Containment Vent / Hydrogen Purge System to be open in '
MODES 1 to 4 for containment pressure control, airborne radioactivity control. and surveillance testing purposes. not for hydrogen i control functions. Thus it .
would seem that ITS 3.6.7 '
ACTION B does not apply to CCNPP.
CCNPP Response:
9 t
_m.__.__ .__.. . . __ _ _ . _.__m. _ . . _ _ _ . _ _ . .__ . .- _ _ . __._____m.____._.-._.___.,._.__.___..___._.._______m________.______.-___m -
__,,__,-.._.mm. -- m _- , ww v< --r- + ,= = = .- , - < . - - - ,~- . . .-r - ,
1
.ITS 3.6.7 HYDR 0 GEN RECOMBINERS: ,
i ITEM NO.
DOC /-
JFDE CTS /STS LCO ~ ~
DESCRIPTION OF ISSUE. DATE-OPENED
'DATE CLOSED C0leENTS-- 'f 3.6.7-2 L.2 CTS CTS 4.6.5.2.a requires 5/15/97 Provide additional l 4.6.5.2.a verifying that during a discussion and i STS functiondl test of the justification based i SR 3.6.8.1 hydrogen recombiner, the on current. licensing ,
and minimum heater sheath basis, system design :
Associated temperature increases to > or operational Bases 700 F within 90 minutes and constraints to' ITS is maintained for at least 2 justify the deviation SR 3.6.7.1 hours once per 6 months. from the CTS and STS.
and ITS 3.6.7 does not contain l Associated this requirement. Rather. !
Bases ITS SR 3.6.7.1 (hydrogen i recombiner functional test) i is a 24-month functional .
test which requires the ;
heater sheath temperature to ;
be increased to > 1200 F -t within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, and maintained for at least 4 i hours. No justification is ,
provided for changing the '
test parameters.from a t heater sheath temperature of !
>700* within 90 minutes and is maintained for at least 2
' hours to > 1200 F to within .
5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and maintained for .
at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. STS B3.6.8 Bases-SR 3.6.8.1 has a testing requirement ,
i similar but less restrictive t than CTS 4.6.5.2.a. It does t not maintain the temperature '
for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> but increases !
it to maximum for i approximately 2 minutes and verified to be >60 kw. ;
i
~
3 .
I i
ITS 3.6.7 HYDR 0 GEN RECOMBINERS ,
ITEM DOC /- CTS /STS DESCRIPTION OF ISSUE DATE- DATE COMMENTS NO. JFD- i LCO OPENED- CLOSED CCNPP Response:
3.6.7-3 Bases STS B3.6.8 STS B3.6.7 Bases RA B.1 and 5/16/97 Provide additional JFD Bases- B.2 has a reviewer's Note in discussion and
.10 RA B.1 and the text. ITS B3.6.7 Bases justification for the B.2 RA B.1 and B.2 deletes the deletion of the ITS B3.6.7 Note using justification . Reviewer's Note.
Bases Bases JFD 10. Bases JFD 10 RA B.1 and deals with the compliance of B.2 CCNPP to the General Design Criteria (GDC). The deletion of the Reviewer's Note has nothing to do with the GDC.
CCNPP Response:
t P
t I
L t
4
,,- - - - = <-e -= ww + = -a-' e = -e e--r-e*- rie.-,' ewe =wr -+e , -e,<. r ---e- m i - - - < - - - se -- -- > - - - - -- - - - - - - - ------- - - -- --
. _ _. . _ . . . . _. _ _ _ . . . _ . - _ _ . _ . . m . . _ _ _ _ . _ _ _ _ . .
ITS 3.6.8 IDDINE REMOVAL SYSTEM-ITEM DOC / CTS /STS :
DESCRIPTION OF. ISSUE. DATE DATE~ COPt1ENTS .
NO. JFD - LCO OPENED- CLOSED 3.6.8-1 BASES STS- STS B3.6.10 Bases for SR 5/16/97 Reinsert the STS JFD 3 B3.6.10. 3.6.10.2 states that "The statement and Ref. 3 BASES ICS filter tests are in into the appropriate SR accordance with Regulatory place in ITS B.3.6.8 3.6.10.2 Guide (RG) 1.52 (Ref. 3). Bases SR 3.6.8.2 and ITS B3.6.8 "ITS B3.6.8 Bases for SR ITS B.3.8 Bases Bases- 3.6.8.2 deletes this REFERENCES.
SR 3.6.8.2 statement and Reference 3 ITS B3.6.8 from ITS B.3.6.8 Bases BASES REFERENCE Section. The '
REFERENCES basis for this deletion is .
that it was performed to '
ensure that the references are applicable to CCNPP.
The testing requirements in' ;
CTS 4.6.3.1.b thru g ;
i reference RG 1.52 Rev. 2 and .
! are relocated to ITS 5.5.11. ,
ITS 5.5.11 states that the VFTP test shall be done in ;
accordance with RG 1.52 Rev.
- 2. Therefore, the , '
justification JFD 3 is !
wrong, and the STS statement and Reference 3 should be
- reinserted into ITS B3.6.8 .
Bases'SR 3.6.8.2 and ITS B.3.6.8 Bases REFERENCES. ;
respectively. Furthermore.
the staff would consider '
this change as a generic change. '
CCNPP Response: I i
1 t L
__.....t . _ _i_. u. _ _ _ ...-..__,2mn.m-~__.-__i.m.____.____m_______ - _ . _ _ _ _ _ __m___ _ - _ _ _ _ _ _ _ _ - < ~ .__m- _ _ _ . _ . , -m_ __m.-____.__.__m_n__._.________m___.a,_-= - -
- _,.. _. -- - . _ - , . -_ m _.-
ITS 3.6.8 IODINE REMDVAL SYSTEM
~
ITEM' DOC / CIS/STS- DESCRIPTION.0F ISSUEi DATE- DATE' CatmENTS i
NO. JFD LCO- OPENED CLOSED-3.6.8-2 Bases STS -
STS B3.6.10 Bases-LC0 states S/16/97 Provide a discussion JFD 8 B3.6.10 the following: "Two '
and justification for JFD Bases- separate, independent, and this deletion.
11 LC0 redundant trains..." ITS 3 ITS B3.6.8 Bases-LCO deletes the '
B3.6.8 words " separate, inde mndent .
BASES- and redundant." ITS 33.6.8 'i_t BACKGROUND BACKGROUND first sentence, ITS B3.6.8 second paragraph retains Bases these words. The LC0 justifications (Bases JFD 8 >
and JFD 11) deal with consistency with CCNPP -
specific number, system ,
i name, terminology, safety -
analysis, plant system ~'
i omration or design basis. ,
T11s deletion does not fall' -
i under any of these l categories.
CCNPP Response:
U 2
- _ _ . ~ _
-