ML20141A073
| ML20141A073 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/11/1997 |
| From: | Dromerick A NRC (Affiliation Not Assigned) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| TAC-M97363, TAC-M97364, NUDOCS 9706200073 | |
| Download: ML20141A073 (132) | |
Text
- . - _ _ - . . - . - .
Mr. Charles H. Cruse .. June 11, 1997 Vice President - Nuclear Energy Baltimore Gas and Electric Company
'Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby MD 20657-470?
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 i 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 t
the enclosed recuest for information (RAI) that seeks to clarify the ITS Sections 3.7 anc 3.8. Please note that Section 3.8 does not include 3.8.4 .
3.8.5. and 3.8.6. These Sections are dependent on review and resolution of the Technical Specifications Task Force (TSTF) changes for battery testing.
These are the only sections missing to complete NRC comments on the entire Calvert Cliffs conversion submittal.
Section 3.8 hard copy includes comments on the ITS. the Bases, and NUREG-1432.
The electronic file name has been included on the hard copy to assist in locating each file when the electronic file is sent. In revising the !
electronic files we request that you change the file suffix from CC1 to CC2 l (i.e. CALVERT\TABL381.CC1 should be revised to CALVERT\TABL381.CC2). 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: i l
Alexander W. Dromerick. Senior Project Manager '
p Project Directorate I-1 l l Division of Reactor Projects - I/II '
Office of Nuclear Reactor Regulation ME Docket Nos. 50-317 and 50-318 /
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Enclosure:
RAI MN 1 /
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NUCLEAR REGULATORY COMMISSION ;
- WASHINGTON, D.C. 20666.0001
% # June 11, 1997 l
Mr. Charles H. Cruse' l Vice President - Nuclea,' Energy l Baltimore Gas and Electric Company l Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby MD 20657-4702 l l l
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 I the enclosed recuest for information (RAI) that seeks to clarify the ITS !
Sections 3.7 anc 3.8. Please note that Section 3.8 does not include 3.8.4 ,
3.8.5. and 3.8.6. These Sections are dependent on review and resolution of '
the Technical Specifications Task Force (TSTF) changes for battery testing. ;
These are the only sections missing to complete NRC comments on the entire Calvert Cliffs conversion submittal.
Section 3.8 hard copy includes comments on the ITS. the Bases, and NUREG-1432.
The electronic file name has been included on the hard copy to assist in locating each file when the electronic file is sent. In revising the electronic files we request that you change the file suffix from CC1 to CC2 (i.e.. CALVERT\TABL381.CC1 should be revised to CALVERT\TABL381.CC2). 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.
Sincere 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
Enclosure:
RAI cc w/ enc 1: See next page
Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas and Electric Company Units Nos. I and 2
- CC:
President Mr. Joseph H. Walter. Chief Engineer Calvert County Board of Public Service Commission of l Commissioners Maryland l 175 Main Street Engineering Division Prince Frederick. MD 20678 6 St. Paul Centre :
Baltimore MD 21202-6806 -
l James P. Bennett. Esquire Counsel Kristen A. Burger. Esquire l Baltimore Gas and Electric Company Maryland People's Counsel ,
P.O. Box 1475 6 St. Paul Centre i Baltimore MD 21203 Suite 2102 ;
Baltinore. MD 21202-1631 r 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. Prichet' Director Baltimore. MD 21218 :
NRM l
Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell l 1650 Calvert Cliffs Parkway NRC Technical Training ranter i Lusby. MD 20657-4702 5700 Brainerd Road l Chattanooga. TN 37411-4017 Resident Inspector U.S. Nuclear Regulatory Commission !
. P.O. Box 287 '
St. Leonard. MD 20685 L Mr. Richard I. McLean l Administrator - Radioecology Department of Natural Resources
! 580 Taylor. Avenue Tawes State Office Building. 83 Annapolis MD 21401 Regional-Administrator Region I J U.S. Nuclear Regulatory Commission
! 475 Allendale Road
. King of Prussia. PA 19406 l
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CCNPP ITS 3.8.1 AC SOURCES - OPERATING cac tymmABUS1.CC1 \;
3.8.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,L 1 L.5 Unit 1: SR 3.8.1.10 The proposed deletion of the The licensee should provide an adequate CTS constraint to conduct this SR during shutdown justification, or retain the CTS does not appear to be acceptable. The licensee has constraint.
not provided a convincing argument to demonstrate this SR can be conducted at power in a totally safe manner.
@GE Response:
2 L.2 Unit 1: SR 3.8.1.5 The proposed deletion of the CTS The justification should be revised to requirement to test DGs on a staggered test basis is include information regarding the impact (
acceptable. However, the justification is somewhat on plant safety of this change and less than adequate. reference to any generic studies that may have been conducted on the issue ,
of staggered testing.
BGE Response:
t 3 LA.2 Unit 1: CTS SR 4.8.1.1.2.d Relocation of the CTS The TRM or Maintenance Rule Program i requirement to inspect the DGs in accordance with are acceptable for relocation. The vendor recommendations at every refueling is licensee should revise the submittal ;
acceptable. However, relocation of this requirement to accordingly.
plar't ' rocedures is not acceptable. This is an r
- j. imp. Jnt part of maintaining EDG reliability and should
[ be incorporated into a document / program for which j l l controls have been established. ;
BGE Response:
i 4 M.1 Unit 1: Insert SR 3.8.1.1.7 The staff does not The licensee should provide a detailed '
understand why the DG from the other Unit is only discussion of what is intended by this required to be subject to 4 SRs. Why is the affected SR. ;
DG not required to undergo all SR testing?
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.______ _ ._ - __ __- _ _ . _ _ . _ _ - - _ - _ - _ _ _ _ . - , - ~ - . _ _ _ _ - - - - . - - - . , - - . _ - - - - . - _ . _ _ _ _ . . - _ _ _ _ _ . _ _ _ _ _ - _ _ _ - . _ _ . _ _ - _ _ , .. ._
CCNPP ITS 3.8.1 AC SOURCES - OPERATING CSCALVRMABL38 tCC1 $
3.8.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
CGE Response:
5 Unit 2: Action A for Unit 2 requires performance of SR Why is there a difference between Units 3.8.1.1. For Unit 1, Action A requires performance of 1 and 2?
SR 3.8.1.1 or SR 3.8.1.2.
CGE Response:
6 L.5 Unit 2: SR 3.8.1.10 The proposed deletion of the The licensee should provide an adequate CTS constraint to conduct this SR during shutdown justification, or retain the CTS does not appear to be acceptable. The licensee has constraint.
not provide a convincing argument to demonstrate this SR can be conducted at power in a totally safe manner.
CGE Response:
7 '
L.4 Unit 2: SR 3.8.1.5 The proposed deletion of the CTS The justification should be revised to requirement to test DGs on a staggered test basis is include information regarding the impact acceptable. However, the justification is somewhat on plant safety of this change and less than adequate. reference to any generic studies that may have been conducted on the issue of staggered testing.
CGE Response:
8 LA.2 Unit 2: CTS SR 4.8.1.1.2.d.1 Relocation of the CTS This is an important part of maintaining requirement to inspect the DGs in accordance with DG reliability and should be incorporated vendor recommendations at every refueling is into a document / program for which acceptable. However, relocation of this requirement to controls have been established. The plant procedures is not acceptable. TRM or Maintenance Rule Program are acceptable for relocation. The licensee should revise the submittal accordingly.
, CCNPP ITS 3.8.1 AC SOURCES - OPERATING CACALVRM ABL381.CC1 \
i 3.8.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
CGE Response: I 9 M.1 Unit 2: Insert 3.8.1.17 The staff does not understand The licensee should provide a detailed ,
why the DG from the other unit is only required to be discussion of what is intended by this subject to 4 SRs. Why is the affected DG not required SR.
to undergo all SR testing?
BGE Response:
10 JD.10 STS SR 3.8.1.10 requires verifying each DG, operating Provide justification for the STS at a power factori[0.9], does not trip, and voltage is deviation based on current licensing maintained 1 [5000] V during and following a load basis, system design, or operational rejection of 1 [4500] kw and 1 [50001 kw, every 18 constraints. '
months. ITS 3.8.1 does not include this STS requirement. There is inadequate justification of deleting this STS requirement.
CGE Response:
11 JD.10 STS SR 3.8.1.11 requi:r;. verifying on an actual or Provide justification t'or the STS simulated loss of offsite power signal: 1) De- deviation based on current licensing energization or emergency buses. 2) Load shedding basis, system design, or operation from emergency buses. 3) DG auto-starts from the constraints.
standby condition, loads, and maintains voltage and frequency for 15 minutes. ITS 3.8.1 does not include this STS requirement. There is inadequate justification for deleting this STS requirement.
BGE Response:
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. - - - . _ _ _ - . - . , _ - . _ _ . _ . _ _ . . _ _ . - . . . - - _ . _ - _ _ _ _ - - - . . - _ _ - . - - - - _ - - . _ _ _ _ .. - - _ _ . _ , - - - - . - - _ - . - . , - , .a , - m. -
CCNPP ITS 3.8.1 AC SOURCES - OPERATING cacAtvamastasi.cci S 3.8.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
12 JD.10 STS SR 3.8.1.14 requires verifying each DG, operating Provide justification for the STS at a power factor 1[0.91, operates for 124 hours0.00144 days <br />0.0344 hours <br />2.050265e-4 weeks <br />4.7182e-5 months <br />. deviation based on current licensing ITS 3.8.1 does not include this STS requirement. basis, system design, or operational There is inadequate justification for deleting this STS constraints.
requirement.
BGE Response:
13 JD.10 STS SR 3.8.1.15 requires verifying each DG starts and Provide justification for the STS achieves, in 1 (101 seconds, voltage 113740] V and deviation based on current licensing 1 [45801 V, and frequency 1 [58.81 Hz ar.d il61.2] basis, system design, or operational Hz. ITS 3.8.1 does not include this STS requirement.
constraints.
There is inadequate justification for deleting this STS requirement. !
BGE Response: ;
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CCNPP ITS 3.8.2 AC SOURCES - SHUTDOWN cacAtvtamastas2.cci .
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3.8.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 LA.1 Unit 1: CTS Action a.1 (Also Applies to LCO Justification LA.1 should be revised 3.8.3) Relocation of the CTS requirements accordingly.
regarding movement of heavy loads from TS is
< acceptable. However, the justification requires additional work. Specifically, endorsement of NUREG-1432 means that movement of heavy loads will be conducted in a manner that will preclude dropping of the load on irradiated fuel.
The statement in justification LA.2 that heavy loads are not initiators of any event is not entirely true - the fuel handling accident assumes an irradiated fuel assembly is dropped.
BGE Response:
2 LA.2 Unit 1: CTS Footnote * (Also applies to LCO The licensee should provide more 3.8.3) The proposal to move this footnote to details re: this annotation.
the Bases is not acceptable. The footnote modifies the TS required action and, as such, is not appropriate Bases material. The purpose of the Bases is to explain why something is in the l TS, not to establish requirements. In this case, the Bases should explain what constitutes a safe, conservative position, but the permissive j to establish a safe, conservative position prior to implementing the Required Actions must I remain in TS.
The CTS markup includes another LA.2 ;
annotation. However, it is not clear what if any '
change this annotation is associated with.
BGE Response: ;
t
CCNPP ITS 3.8.2 AC SOURCES - SHUTDOWN C3cALVERMABL381CC1 '
~
3.8.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3 L.3 Unit 1: CTS Action a.3 Moving this CTS The licensee should verify that these requirement from the AC sources TS to CTS requirements are reflected in refueling TS (3.9) is acceptable, and is an Section 3.9 of the ITS, and change Administrative change. However, deleting the this justification accordingly.
requirement in it:; entirety is not acceptable.
BGE Response:
4 L.2 Unit 1: SR 3.8.2.1 The staff does not agree This item requires discussion ;
with the licensee's concept of which SRs from between the staff and the licensee. '
LCO 3.8.1 are applicable in Modes 5 & 6 (Shutdown). See attached chart which provides the staff position regarding SRs that are 1) applicable and must be performed,2) applicable but are not regaired to be performed, and 3) are not applicable.
BGE Response:
5 LA.1 Unit 2: CTS Action a.1 Relocation of the CTS Justification LA.1 should be revised requirements regarding movement of heavy accordingly. ;
loads from TS is acceptable. However, the justification requires additional work.
Specifically, endorsement of NUREG-1432 ,
means that movement of heavy loads will be '
conducted in a manner that will preclude dropping of the load on irradiated fuel. The statement in justification LA.2 that heavy loads are not initiators of any event is not entirely I true - the fuel handling accident assumes an :
irradiated fuel assembly is dropped. ,
BGE Response:
i
CCNPP ITS 3.8.2 AC SOURCES - SHUTDOWN cacAtvenmAstas2.cci .-
~
3.8.2 DOC JFD CHANGE / DIFFERENCE _
COMMENT STATUS 6 LA.2 Unit 2: CTS Footnote
- The proposal to move The licensee should provide more this footnote to the Bases is not acceptable. details re: this annotation.
The footnote modifies the TS required action and, as such, is not appropriate Bases material.
The propose of the Bases is to explain why something is in the TS, not to establish requirements. In this case, the Bases should explain what constitutes a safe, conservative ;
position, but the permissive to establish a safe, conservative position prior to implementing the Required Actions must remain in TS.
The CTS markup includes another LA.2 annotation. However, it is not clear what if any change this annotation is associated with.
t BGE Response:
7 L.3 Unit 2: Moving this CTS requirement from the The licensee should verify that these AC sources TS to refueling TS (3.9) is CTS requirements are reflected in acceptable, and is an Administrative change. Section 3.9 of the ITS, and change However, deleting the requirement in its this justification accordingly.
entirety is not acceptable.
BGE Response:
CCNPP ITS 3.8.2 AC GOURCES - SHUTDOWN cacavmmAstas2.cci i 3.8.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 8 L.2 Unit 2: The staff does not agree with the Justification LA.1 should be revised licensee's concept of which SRs from LCO accordingly.
3.8.1 are applicable in Modes 5 & 6 (Shutdown). See attached chart which provides the staff position regarding SRs that are 1) applicable and must be performed, 2) applicable but are not required to be performed, and 3) are not applicable.
CGE Response:
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CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE Oll, AND STARTING AIR cacatvtametasa cci - !
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS .
1 A.4 Unit 1: LCO 3.8.3 Moving these CTS The licensee should consider revising requirements to SR is acceptable and this DOC to delete reference to the constitutes an Administrative change. Bases.
However, the justification indicates some j material may be moved to the Bases. This i is/would not be acceptable. In addition, moving any of these CTS requirements to the Bases I would not be an Administrative change. !
This comment is also applicable to Unit 2. -
CGE Response:
2 A.5 Unit 1: CTS Action f The proposed change is The DOC should be revised to l acceptable. However, the justification is correct this concern.
misleading. NUREG-1432 provides a period of j time to restore fuel oil level, only. Inoperability of the fuel oil storage system for any other !
reason results in the associated DG being '
declared inoperable immediately. DOC A.5 {
gives the impression that a period of time is j allowed to restore the fuel oil storage system to
- 1 OPERABLE status, regardless of cause of the :
inoperability. !
CGE Response 3 L.2 Unit 1: CTS Action f The justification makes Absent this discussion, the proposed !
an adequate case for deleting the CTS changes associated with DOC L.2 [
requirements relative to the volume of fuel oil. are not acceptable. i However, DOC L.2 does not discuss why it is acceptable to delete CTS requirements I associated with the flow path. l BGE Response: l i
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CCNPP ITS 3.8.3 DIESEL FUEL Oll, LUBE OIL, AND STARTING AIR C9,CALVERMABL383 CC1 8 3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS .
4 L.1 Unit 1: CTS Action f The CTS markup and The CTS markup should be revised DOC L.1 are confusing. The iTS reflects to reflect what the ITS will be, and NUREG-1432 and is acceptable. The latter part DOC L.1 should also be revised to ;
of DOC L.1 addresses the less restrictive eliminate any confusion, aspects of adopting the NUREG requirements regarding fuel volume, particulates, and new fuel quality, and is also acceptable. However y the CTS markup and the first half (approx) of ,
DOC L.1 address something totally different.
BGE Response:
5 A.6 Unit 1: CTS Action f The requirements of The proposed changes to the CTS CTS Action f include a requirement to go to are acceptable, but the justification shutdown if the fuel oil storage system is not must be changed to address the Less restored to OPERABLE status in the specified Restrictive aspects.
time frame. There is no intermediate step as in '
the NUREG and ITS (declaring associated DG inoperable). Therefore, moving the shutdown i requirements to the associated DG LCO results !
in a Less Restrictive change, not an Administrative change.
BGE Response:
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_ . - . , . _ . . . . - . _ - _ _ _ . - _ _ - - __ . _ . . . . . ~ . - . .. . _ _ _ . . - . . . _ - --,-.
CCNPP ITS 3.8.3 DIESEL FUEL Oll, LUBE OIL, AND STARTING AIR CACAMRMABW83 CC1 4, 3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 6 A.5 Unit 1: CTS Action g The proposed change is The DOC should be revised to Occeptable. However, the justification is correct this concern.
misleading. NUREG-1432 provides a period of time to restore fuel oil level, only. Inoperability of the fuel oil storage system for any other reason results in the associated DG being ;
declared inoperable immediately. DOC A.5 gives the impression that a period of time is allowed to restore the fuel oil storage system to OPERABLE status, regardless of cause of the inoperability.
CGE Response:
7 L.2 Unit 1: CTS Action g The justification makes Absent this discussion, the proposed ;
an adequate case for deleting the CTS changes associated with DOC L.2 ,
requirements relative to the volume of fuel oil. are not acceptable.
However, DOC L.2 does not discuss why it is acceptable to delete CTS requirements associated with the flow path.
CGE Response:
8 A.6 Unit 1: CTS Action g The requirements of CTS The proposed changes to the CTS Action f include a requirement to go to are acceptable, but the justification shutdown if the fucI oil storage system is not must be changed to address the Less restored to OPERABLE status in the specified Restrictive aspects.
time frame. There is no intermediate step as in L the NUREG and ITS (declaring associated DG inoperable). Therefore, moving the shutdown requirements to the as 'ciated DG LCO results -
in a Less Restrictive change, not an Administrative change. ;
BGE Response:
i
CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR cscatvmmastas3 cci !
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
CGE Response:
9 L.2 Unit 1: CTS Action h The justification makes Absent this discussion, the proposed an adequate case for deleting the CTS changes associated with DOC L.2 requirements relative to the volume of fuel oil. are not acceptable.
However, DOC L.2 does not discuss why it is acceptable to delete CTS requirements ,
associated with the flow path.
BGE Response:
10 LA.3 Unit 1: CTS Action h The staff does not The licensee should review this DOC
- understand this DOC. The DOC indicates that in light of, the proposed ITS with the the material is being moved to plant procedures, intent to revise the DOC as but the ITS do not include any requirements for appropriate.
a permissives to align any specific DG to any specific fuel oil storage tank. In light of this, the staff questions how this CTS material could be used even if it was to be included in plant procedures.
l BGE Response:
11 L.1 Unit 1: Insert Action D DOC L.1 does not The licensee should review the ,
address anything that is included in proposed submittal and the DOCS for the Action D. purpose of identifying (or providing) the correct DOC for proposed insert >
D.
a BGE Response:
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. - . - - - ~ - . _ - - - - - - - - _ _ - - - - - _ _ _ _ _ ._ - - _ - - - - _ _ _ - _ _ - - - - - - - _ - - - - _ _ - _ _ _ . - . - -
t CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR CACALVERM ABOB3 CC1 1 3.8.3 DOC JFD CHANGE / DIFFERENCE - COMMENT STATUS .
12 L.5 Unit 1: SR 3.8.3.1 The proposed deletion of The DOC should address what the CTS requirement to conduct SRs on a staggered testing means, the Staggered Test basis is acceptable. However, absence of safety impact if it is i DOC L.5 could be improved. deleted, and any generic studies that [
may have been conducted on the subject.
BGE Response:
13 A.4 Unit 1: CTS LCO 3.8.1.2.b.2 Moving these The licensee should consider revising ;
CTS requirements to SR is acceptable and this DOC to deleto reference to the ;
constitutes an Administrative change. Bases. l However, the justification indicates some !
material may be moved to the Bases. This [
is/would not be acceptable. In addition, moving ;
any of these CTS requirements to the Bases would not be an Administrative change.
CGE Response: !
14 M.3 Unit 1: CTS Action b The CTS Action This is confusing, and the CTS l addresses inoperability or the No.11 fuel tank markup is also confusing. The ;
and requires demonstrating the OPERABILITY of licensee should review this part of [
the No. 21 fuel tank. The DOC addressees the markup with a view towards adding a restoration statement for the No. 21 eliminating confusion. j fuel tank, but the No 21 fuel tank is not the i' cause of being in the Action.
CGE Response: ,
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_.. _ _ . _ . _ _ _ _ _ _ . _ _ - _ _ _ _ _ _ _ _ - . _ _ . . _ . _ _ - - _ _ . _ . _ . _ _ _ _ _ _ _ _ . _ _ _ ______._____.__m_____.__*i-_.____m__ - - m. _ -- _ w _ . i n - - - . , - - -,m.
CCNPP ITS 3.8.3 DIESEL FUEL Oil, LUBE OIL, AND STARTING AIR CACALVERMABL383 CCI $
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
a 15 LA.3 Unit 1: CTS Action b.2 and c.2 The staff The licensee should review this DOC does not understand this DOC. The DOC in light of, the proposed ITS with the indicates that the material is being moved to intent to revise the DOC as plant procedures, but the ITS do not include any appropriate.
requirements for a permissives to align any specific DG to any specific fuel oil storage tank.
In light of this, the staff questions how this CTS material could be used even if it was to be included in plant procedures.
BGE Response:
16 LA.1 Unit 1: CTS Action c and d (Also applies to Justification LA.1 should be revised LCO 3.8.2) Relocation of the CTS requirements accordingly.
regarding movement of heavy loads from TS is acceptable. However, the justification required additional work. Specifically, endorsement of NUREG-1432 means that movement of heavy ,
loads will be conducted in a manner that will preclude dropping of the load on irradiate fuel.
- The statement in justification LA.2 that heavy r loads are not initiators of any event is not I entirely true - the fuel handling accident assumes an irradiated fuel assembly is dropped.
CGE Response: _
l L
9
CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR cacAtvmmABL383 c0 b 3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
17 L'A.2 Unit 1: CTS Footnote * (Also applies to LCO The licerisee should provide more 3.8.2) The proposal to move this footnote to details re: this annotation.
the Bases is not acceptable. The footnote i modifies the TS required action and, as such, is not appropriate Bases material. The purpose of the Bases is to explain why something is in the -
TS, not to establish requirements. In this case, the Bases should explain what constitutes a I
safe, conservative position, but the permissive to establish a safe, conservative position prior to implementing the Required Actions must remain in TS.
The CTS markup includes another LA.2 annotation. However, it is not clear what if any change this annotation is associate with.
BGE Response:
18 A.4 Unit 2: LCO 3.8.3 Moving these CTS The licensee should consider revising -
requirements to SR is acceptable and this DOC to delete reference to the i constitutes an Administrative change. Bases.
~However, the justification indicates some material may be moved to the Bases. This is/would not be acceptable. In addition, moving ,
any of these CTS requirements to the Bases l would not be an Administrative change. [
BGE Response:
h L
i i
o CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR cr.catvmmastsea cci i
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS , j 19 A.6, Unit 2: CTS Action f.1 A.6 comment: The The proposed changes to the CTS [
LA.3, requirements of CTS Action f include a are acceptable, but the justification L.1 requirement to go to shutdown if the fuel oil must be changed to address the Less !
storage system is not restored to OPERABLE Restrictive aspects.
status in the specified time frame. There is no intermediate step as in the NUREG and ITS (declaring associated DG inoperable).
Therefore, moving the shutdown requirements to the associated DG LCO results in a Less Restrictive change, not an Administrative i change. I Unit 2: CTS Action f.1 LA.3 comment: The The licensee should review this DOC staff does not understand this DOC. The DOC in light of, the proposed ITS with the indicates that the materialis being moved to intent to revise the DOC as plant procedures, but the ITS do not include any appropriate.
requirements for a permissives to align any specific DG to any specific fuel oil storage tank.
- In light of this, the staff questions how this CTS material could be used even if it was to be >
included in plant procedures.
Unit 2: CTS Action f.1 L.1 comment: The The CTS markup should be revised CTS markup and DOC L.1 are confusing. The to reflect what the ITS will be, and ,
ITS reflects NUREG-1432 and is acceptable. DOC L.1 should also be revised to
- The latter part of DOC L.1 addresses the less eliminate any confusion.
restrictive aspects of adopting the NUREG requirements regarding fuel volume, particulates, and new fuel quality, and is also ,
acceptable. However, the CTS markup and the first half (approx) of DOC L.1 address ;
something totally different.
i
CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR cacatvmmAeosa cci .
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
19 L.2 Unit 2: CTS Action f.1 L.2 comment: The Absent this discussion, the proposed continued justification makes an adequate case for changes associated with DOC L.2 !
deleting the CTS requirements relative to the are not acceptable.
volume of fuel oil. However, DOC L.2 does not discuss why it is acceptable to delete CTS t requirements associated with the flow path.
CGE Response:
I I
CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR CTALVEMABL383.CC1 1 3.8.3 DOC- JFD CHANGE / DIFFERENCE COMMENT STATUS . s 20 A.5, Unit 2: CTS Action f.2 A.5 comment: The The proposed changes to the CTS A.6 proposed change is acceptable. However, the are acceptable, but the justification justification is misleading. NUREG-1432 must be changed to address the Less provides a period of time to restore fuel oil Restrictive aspects, level, only. Inoperability of the fuel oil storage ,
system for any other reason results in the associated DG being declared inoperable immediately. DOC A.5 gives the impression e that a period of time is allowed to restore the fuel oil storage system to OPERABLE status, regardless of cause of the inoperability.
Unit 2: CTS Action f.2 A.6 comment: The The proposed changes to the CTS requirements of CTS Action f include a are acceptable, but the justification requirement to go to shutdoc.n if the fuel oil must be changed to address the Less stnrage system is not restored to OPERABLE Restrictive aspects. !
status in the specified time frame. There is no intermediate step as in the NUREG and ITS [
(declaring associated DG inoperable). ;
Therefore, moving the shutdown requirements to the associated DG LCO results in a Less Restrictive change, not an Administrative '
change. i i
k 6
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CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR cacAtvtamAstasa.cci i 3.8.3 DOC .JFD CHANGE / DIFFERENCE COMMENT STATUS ,
20 L.1 Unit 2: CTS Action f.2 L.1 comment: The The CTS markup should be revised continued CTS markup and DOC L.1 are confusing. The to reflect what the ITS will be, and ITS reflects NUREG-1432 and is acceptable. DOC L.1 should also be revised to The latter part of DOC L.1 addresses the less eliminate any confusion.
restrictive aspects of adopting the NUREG requirements regarding fuel volume, particulates, and new fuel quality, and is also acceptable. However, the CTS markup and the first half (approx) of DOC L. address something totally different.
BGE Response:
I CCNPP ITS 3.8.3 DIESEL FUEL Oil, LUBE OIL. AND STARTING AIR cacamanraeusicci .
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT . STATUS ,!
21 A.6, Unit 2: CTS Action g A.6 comment: The The proposed changes to the CTS l LA.3, requirements of CTS Action f include a are acceptable, but the justification :
L.2 requirement to go to shutdown if the fuel oil must be changed to address the Less j storage system is not restored to OPERABLE Restrictive aspects.
status in the specified time frame. There is no ,
intermediate step as in the NUREG and ITS .
, (declaring associated DG inoperable). [
Therefore, moving the shutdown requirements to the associated DG LCO results in a Less Restrictive change, not an Administrative change.
Unit 2: CTS Action g LA.3 comment: The The licensee should review this DOC staff does not understand this DOC. The DOC in light of, the proposed ITS with the indicates that the materialis being moved to intent to revise the DOC as !
plant procedures, but the ITS do not include any appropriate.
requirements for a permissives to align any i specific DG to any specific fuel oil storage tank.
In light of this, the staff questions how this CTS material could be used even if it was to be included in plant procedures.
Unit 2: CTS Action g L.2 comment: The Absent this discussion, the proposed justification makes an adequate case for changes associated with DOC L.2 deleting the CTS requirements relative to the are not acceptable. !
volume of fuel oil. However, DOC L.2 does not !
discuss why it is acceptable to delete CTS l requirements associated with the flow path.
L r
BGE Response:
o i
_ _ _ _ = _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . . . . . - _ . ~ . . - . - - . . _ .- _ _ _ _ -.-_-____-.__-_.a
_ _ - _ - _ _ - - = _ . - _ _ - - _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ - - _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . __- ___ _ __ _ _______ - _ - _ _ _ _-- ___ _ _ _ _ _ __
CCNPP ITS 3.8.3 D!ESEL FUEL DIL, LUBE OIL, AND STARTING AIR cacatwamastasa.cci i..
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
22 Unit 2: Insert Action D DOC L.1 does not The licensee should review the address anything that is included in proposed submittal and the DOCS for the Action D. purpose of identifying (or providing) the correct DOC for Insert D.
BGE Response:
23 L.5 Unit 2: SR 3.8.3.1 The proposed deletion of The DOC should address what the CTS requirement to conduct SRs on a staggered testing means, the staggered test basis is acceptable. However, absence of safety impact if it is DOC L.5 could be improved. deleted, and any generic studies that may have been conducted on the subject.
BGE Response:
24 A.4 Unit 2: CTS LCO 3.8.1.2.b.2 Moving these The licensee should consider revising CTS requirements to SR is acceptable and this DOC to delete reference to the constitutes an Administrative change. Bases.
However, the justification indicates some material may be moved to the Bases. This ;
is/would not be acceptable. In addition, moving any of these CTS requirements to the Bases would not be an Administrative change.
i BGE Response: !
i 25 M.3 Unit 2: CTS Action b The CTS Action This is confusing, and the CTS addresses inoperability or the No.11 fuel tank markup is also confusing. The and requires demonstrating the OPERABILITY of licensee should review this part cif ;
the No. 21 fuel tank. The DOC addressees the markup with a view to wards adding a restoration statement for the No. 21 eliminating confusion.
fuel tank, but the No. 21 fuel tank is not the i cause of being in the Action.
6 f
i
CCNPP ITS 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR cacAtvmmast2s3 cci i ,
3.8.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS , ,
26 LA.3 Unit 2: CTS Action b.2 and c.2 The staff does The licensee should review this DOC not understand this DOC. The DOC indicates in light of, the proposed ITS with the i that the material is being moved to plant intent to revise the DOC as procedures, but the ITS do not include any appropriate. '
requirements for a permissives to align any specific DG to any specific fuel oil storage tank. '
In light of this, the staff questions how this CTS ,
material could be used even if it was to be included in plant procedures.
BGE Response:
27 LA.1 Unit 2: CTS Action c (Also applies to LCO Justification LA.1 should be revised 3.8.3) Relocation of the CTS requirements accordingly.
regarding movement of heavy loads from TS is acceptable. However, the justification required additional work. Specifically, endorsement of NUREG-1432 means that movement of heavy loads will be conducted in a manner that will preclude dropping of the load on irradiate fuel.
The statement in justification LA.2 that heavy loads are not initiators of any event is not entirely true - the fuel handling accident assumes an irradiated fuel assembly is dropped.
BGE Response: ,
I i
I i
. . _ _ _ . - _ - - _- .- - _-- - - n .. .- .-- -w... - - - _ . _ - - - - . . - . _ _ . _ _ - _ =
l t is CCNPP ITS 3.8.7 INVERTERS - OPERATING cdCALWRMABW87CC1 [
j 3.8.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS -
1 A.3 Units 1 & 2. CTS action b.2 As proposed, the The licensee should revise the i ITS for inverters could be interpreted as follows: submittal to retain the CTS at time zero, an inverter fails, and efforts begin requirements. [
immediately to power the AC vital bus from the backup bus; after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />., the affected AD vital The addition of the Note is. !
bus cannot be powered from the backup bus, acceptable because it does not alter and the applicable Condition of LCO 3.8.9 is any requirements. The Note serves entered; after an additional 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the as a reminder that loss of any I affected AC vital bus is still not energized, and inverter could very well mean that a plant shutdown is started. multiple conditions are entered. !
The above interpretation is not correct. For the -
same scenario, at the moment the inverter fails, l the AC vital bus is deenergized. At this point in 1 time, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> clock for the inverter is started, and entry into the applicable Condition I of LCO 3.8.9 commences. If the affected AC l vital bus is not energized within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (from the backup bus or the inverter) a shutdown is started.
l The above possible confusion could be eliminated by retaining te CTS requirement to power the vital bus from i e oackup bus connect'ed to the equipment to restore the ;
inverter by an AND. This will alert all !
interested parties that these Required Actions i i
have concurrent time clocks. It also establishes beyond question what power sources are acceptable for powering the AC vital bus. !
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k CCNPP iTS 3.8.8 INVERTERS - SHUTDOWN c:scAtvtanTAet3ss.cci 3.8.8 DOC JFD CHANGE! DIFFERENCE COMMENT STATUS .
No comments on 3.8.8 I
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CCNPP ITS 3.8.9 DISTRIBUTION SYSTEMS - OPERATING cacnvmmasues cci .
3.8.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
1 A.3 This addition to the TS is acceptable. However, The staff has rejected TSTF-16 it should be noted that the concerns regarding which was intended to compliment LCO 3.0.3 when 2 or more electrical power proposed Action E. Consequently, distribution subsystems are inoperable are not two or more inoperable electrical resolved by this change. power distribution subsystems that do not result in a loss of function will still invoke LCO 3.0.3. .
CGE Response:
2 The changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution of TSTF-115. :
BGE Response:
i 3 The changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution of TSTF-115. I CGE Response:
4 The changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution of TSTF-115. .
BCE Response:
5 The changes associated with the DC electrical i power distribution subsystems have not been reviewed pending resolution of TSTF-115. ;
i BGE Response: !
t
CCNPP ITS 3.8.10 DISTRIBUTION SYSTEMS - SHUTDOWN cncatvenmastasto cci .
3.8.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ~f 1 LA.1 Units 1 & 2: LCO 3.8.10 DOC LA.1 is not The DOC is not correct, is not acceptable. The CTS requirements for offsite acceptable, and the changes
- power and DG backup are not reflected in the associated with DOC LA.1 are not Bases as stated in this DOC. acceptable. A substantia! revision of the submittal in this area is required.
CGE Response:
2 LA.2 Units 1 & 2: LCO 3.8.10 DOC LA.2 is not The DOC is not correct, is therefore acceptable. The CTS requirements regarding not acceptable, and the changes 4160 VAC and 480 VAC busses, and 120 VAC associated with DOC LA.2 are not vital busses are not included in the Bases as acceptable. A revision to the indicated by this LCO. submittal is required.
BGE Response:
[ 3 l LA.3 Units 1 & 2: CTS Action a.1 Footnote
- to this The Footnote is a modification (a l CTS requirement should be retained in the TS. permissive) to the CTS completion !
The Bases is not the appropriate place for this time of "Immediately" and should be i material. The Bases are intended to explain retained in the TS.
what is in TS, not to establish or modify requiremetns.
CGE Response:
l t
i i
?
, . _ , , - . . - - . - , . -4 . _ . - . . . . - . . . . .
CCNPP ITS 3.8.10 DISTRIBUTION SYSTEMS - SHUTDOWN cs.catvmnustasio cci .
3.8.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1
4 LA.4 Units 1 & 2: CTS Action a.1 Relocation of the DOC LA.4 should be revised CTS requirements regarding movement of heavy accordingly (see Section 5 of loads from TS is acceptable. However, the NUREG-1432). -
justification requires additional work.
Specifically, endorsement of NUREG-1432 means that movement of heavy loads will be -
conducted in a manner that will preclude dropping of the load on irradiated fuel. The statement in justification LA.4 that heavy loads are not initiators of an event is not entirely true
- the fuel handling accident assumes an irradiated fuel assembly is dropped.
BGE Response:
5 L.2 Units 1 & 2: CTS Action a.3 The proposed These CTS requirements are included change is acceptable. However, the in ITS Section 3.9 and need not be !
justification appears to be needlessly repeated in Section 3.8. This could j complicated. also be an Administrative change.
CGE Response:
6 LA.1 Units 1 & 2: SR 3.8.10.1 Units 1 & 2: LCO The DOC is not correct, is not 3.8.10 DOC LA.1 is not acceptable. The CTS acceptable, and the changes requirements for offsite power and DG backup associated with DOC LA.1 are not ;
are not reflected in the Bases as stated in this acceptable. A substantial revision of DOC. the submittal in this area is required.
CGE Response:
7 Units 1 & 2: The changes associated with the ,
DC electrical power distribution subsystems '
have not been reviewed pending resolution of TSTF-115.
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CCNPP BASES 3.8.1 AC SOURCES - OPERATING cacAMEBASES38tCC1 $
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS , ,
3.8.1 ____
Bases 5 Insert B. 3.8.1 Backaround The last paragraph of the The licensee should provide an Commer.. insert includes RG 1.9 as a reference. In the list of appropriate justification, or include
- 1 references, this RG (1.9) is listed as Reference 3, but the appropriate description.
the list is annotated to indicate that the reference is the Draft version of RG 1.9, Rev. 3, published in April 1992. A draft of a RG is not an official NRC document and should not be used as a reference or for any other purpose. Is it the licensee's intent to reference Rev. 3 to RG 1.9 dated July 1993. Also since the licensee proposes to retain Safety Guide 9 as a reference, the licensee should provide details of what parts of RG 1.9, Rev. 3 are applicable, what parts of Safety Guide 9 are applicable, and any conflicts between the two documents.
The deleted NUREG narrative includes a discussion of what an offsite circuit is. The proposed Background material does not include a similar discussion, but no justification for the omission has been provided.
BGE Response:
Bases 1 Applicable Safety Analysis The justification provided The licensee should provice an ,.
Comment (1) for deletion of "or all onsite AC power" is appropriate justification for this
- 2 inappiopriate. change that reflects the design basis for the plant (i.e., it is not designed to be capable of safe shutdown if the DGs become inoperable). ,
BGE Response:
I i
CCNPP BASES 3.8.1 AC SOURCES - OPERATING cacAtvtaneAsrsasi.cci . r s
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.1 Bases 3 LCO (two olaces) In the event of a LOCA, are safety The licensee should provide a i Comment loads block loaded to offsite power? The CCNPP detailed description of the three
- 3 description of the offsite circuits lacks the details qualified offsite circuits and how included in the NUREG model. they relate to each other, or provide a detailed justification on why in the third paragraph of the LCO Bases, the term inclusion of such materialis
" Frequency" appears to be partially lined out. Is it the inappropriate at CCNPP. ,
licensee's intention to delete this term? If so, why? Justification 3 does not address the issue.
BGE Response: !
Bases LCO The Bases markup appears to indicate that Comment automatic start of the DGs is not required in Modes 4-6.
- 4 is this correct? If the licensee is of the opinion that this is the licensing basis for the plant, the licensee should provide specific references and documentation, as appropriate, that the staff has, and continues to accept this as the CCNPP design / licensing basis.
BGE Response:
Bases 6 LCO The Bases section dealing with DGs in test mode The licensee should provide an Comment reverting to running standby in the event of a LOCA is adequate justification, or retain the i
- 5 deleted. However, justification (6), which is annotated Bases material. '
adjacent to the deleted material does not address the issue.
BGE Response:
CCNPP BASES 3.B.1 AC SOURCES - OPERATING cacnwar,asstsasi cci .
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.1 Bases 9 Insert B 3.8.1 How is the DG in LCO 3.8.1.c made This deletion is acceptable on the Comment available when required to provide power to the CREVS, basis that this is not the CCNPP
- 6 CRETS, and H2 Analyzer? design. However, nothing has been provided to describe how the The licensee has opted to delete the Bases material transfer from one offsite circuit to which addresses fast transfer capability in the last another is accomplished. The paragraph of the LCO Bases. licensee should provide this information.
BGE Response:
I Bases 1 Applicability What is unique to the CCNPP design such '
Comment that deletion of the term " abnormal transients" is
- 7 acceptable?
BGE Response:
Bases 8 Action A.2 Does the CCNPP design include any single Comment train systems that are not covered by or are exempt
- 8 from this Required Action?
BGE Response:
Bases 10 Surveillance Reauirements Justification 10 states that The licensee should provide a Comment the Bases information cannot be verified against the detailed response to the staff's
- 9 CCNPP design. Does this mean that the licensee has no concern.
idea what, if any voltage drop was considered in the design of the CCNPP AC distribution system and cannot provide any assurance that the minimum required AC voltage to all plant equipment is available at all times?
How does this justification affect the loss of voltage and degraded voltage setpoint and allowable values established in Section 3.3 of the ITS?
______.___.___.__..__.___._____-_.___m_ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ . . _ _ _ _ _ . - - _ _ _ _ _ _ _ . -- ._ e --+-
1 CCNPP BASES 3.B.1 AC SOURCES - OPERATING cacatvenneasessai.cci i
i BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS , ,
3.8.1 BGE Response:
Bases 9 SR 3.8.1.3 and SR 3.8.1.9 The Bases change is not ,
Comment acceptable because the related ITS change is not ;
- 10 acceptable.
BGE Response:
i Bases 20 SR 3.8.1.4 The load values stated for SR 3.8.1.4 and The licensee should provide an Comment SR 3.8.1.11 are identical. In the case of SR 3.8.11, the adequate justification for this
- 11 stated load values are adequate to verify DG capability proposed change.
of accepting loads equal to or rather than expected I accident loads. However, these same load values, when used in SR 3.8.1.4 are not adequate to verify the >
exact same DG capability. The staff does not understand this proposed Bases change, and justification 20 does not help.
BGE Response:
Bases 9 SR 3.8.1.4 Deletion of NUREG Note 3 is not '
Comment acceptable because the corresponding ITS change is not
- 12 acceptable. ,
BGE Response:
- f. Bases 11 SR 3.8.1.4 is the purpose of this justification to state ,
Comment that CCNPP does not attempt to include a lagging i
- 13 power factor as part of the monthly DG surveillance? If so, what is the rationale for not doing so?
BGE Response:
i
CCNPP BASES 3.8.1 AC SOURCES - OPERATING cscatvenneasesasi.cci i BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ' :
3.8.1 Bases 1 SR 3.8.1.4 Deletion of NUREG Note 3 is not Comment acceptable because the corresponding ITS change is not >
- 14 acceptable. ,
BGE Response:
Bases 9 Insert SR 3.8.1.8 The part of the change dealing with Comment deleting Mode restrictions is not acceptable.
- 15 ;
i BGE Response:
a Bases 9, 3 SR 3.8.1.10 The proposed changes to the Bases are ;
Comment not acceptable because the corresponding ITS changes i
- 16 are not acceptable. ;
BGE Response: ,
Bases 9 Insert SR 3.8.1.11 and SR 3.8.1.12 The proposed !
Comment Bases is not acceptable because the ITS changes are
- 17 not acceptable.
l BGE Response:
Bases 1, 9, ER 3.8.13 The proposed changes to the Bases are not t Comment 3 ecceptable because the ITS changes are not acceptable. ;
- 18 BGE Response:
Bases 9 NUREG SR 3.8.1.10 See comments re: deletion of this Comment SR in comments to LCO 3.8.1. ,
- 19 l BGE Response:
i
CCNPP BASES 3.8.1 AC SOURCES - OPERATING CACALVERDBASES381.CC1
! BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS '
3.8.1 1
Bases 9 NUREG SR 3.8.1.11 See comments re: deletion of this Comrrent SR in comments to LCO 3.8.1.
- 20 l
BGE Response:
l l Bases 9 NUREG SR 3.8.1.12 See comments re: deletion of this
, Comment SR in comments to LCO 3.8.1.
i #21 BGE Response:
l Bases 9 SR 3.8.1.14 See comments re: changes to SR l Comment 3.8.1.14 (ITS) in comments to LCO 3.S.1.
- 22 l BGE Response:
Bases 9 NUREG SR 3.8.1.14 and NUREG SR 3.8.1.15 See Comment comments re: deletion of these SRs in comments to
- 23 LCO 3.8.1.
BGE Response:
l Bases 9 SR 3.8.1.15 See comments re: changes to this SR in Comment staff comments to LCO 3.8.1.
- 24 BGE Response:
Bases 9, 1, NUREG SR 3.8.1.17 See comments re: deletion of this Comment 3 SR in staff comments to LCO 3.8.1.
- 25 BGE Response:
o -
CCNPP BASES 3.8.1 AC SOURCES - OPERATING CACALVEREBASES381.CC1 $
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.1 Bases 4, 1, SR 3.8.1.16 See comment re: changes to this SR in ,
Comment 3 staff comments to LCO 3.8.1.
- 26 '
BGE Response: I Bases 9 Insert SR 3.8.1.17 See comments re: this SR in staff Comment comments to LCO 3.8.1.
- 27 BGE Response:
Bases 9 NUREG SR 3.8.1.20 See comments re: deletion of this Comment SR in comments to LCO 3.8.1
- 28 BGE Response: i i
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O CCNPP BASES 3.8.2 AC SOURCES - SHUTDOWN cacAtvemsastsas2.cci t BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.2 Bases 1, 3, LCO See comments re: changes to the LCO in Comment 4,12 staff comments to LCO 3.8.1.
- 1 QGE Response:
Bases 12 Applicability See staff comments re: changes Comment to Applicability in comments to LCO 3.8.2.
- 2
@GE Response:
Bases 12 _ Actions The proposed change to the Bases is Comment not consistent with the proposed ITS.
- 3 BGE Response:
Bases 9,21 SR 3.8.2.1 See staff comments re: SR Comment 3.8.2.1 in comments to LCO 3.8.2.
- 4 With respect to justification 21, why is it necessary to parallel the EDGs with offsite power whenever the EDGs are run?
BGE Response:
l
CCNPP BASES 3.8.3 DIESEL FUEL OIL, LUBE Oil, AND STARTING AIR cncatvtaneastsasa.cci t BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.3 Bases 9 LCO See comments re; deletion of lobe oil Comment and starting air from this LCO in staff
- 1 comments to LCO 3.8.3.
CGE Response:
Bases Backaround The Background section of 3.8.3 Comment Bases may have to be revised as a function of
- 2 resolution of staff comments to LCO 3.8.1.
Also note that deletion of the term "and impurity level" from the 3rd paragraph of the ,
Background is not consistent with the LCO Actions.
BGE Response:
- Bases 9 Action A.1 The proposed Bases is inconsistent Comment with the justifications for changes to the LCO. '
- 3 Specifically, the numerical values for fuel oit quantity are proposed to be moved to the Bases, but these values are not included in the -
Bases for Action A.1.
BGE Response: j Bases 9 Action D.1 See comments re: Action D.1 in Comment staff comments to LCO 3.8.3. Also Note that !
- 4 > 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> should be > 6 days. ,
BGE Response: ;
- . _ _ _ . - . - _ - - - . . . - - - - _ - _ . - - _ - - - - - - - , . _ - - . _ - - _ - _ - _ . - - - - - - - - - - - - - - , - - - , . , _ - _ _ - - - ___va- ,,. _
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CCNPP BASES 3.8.3 DIESEL FUEL OIL. LUBE OIL, AND STARTING AIR cacavennsasesiss cci i BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.3 Bases 1, 2, SR 3.8.4.2 What is the justification for Comment 3 changing the Bases numbers for absolute
- 5 specific gravity and API gravity? these changes are not discusses in justifications 1,2, or 3.
Are 1988 and 1981 the latest revisions of ASTM D4057 and D975, respectively? What is the ASTM standard for determining water and sediment in the new fuel?
BGE Response:
Bases 3, 2, SR 3.8.3.2 What is the justification for Comment 5 deleting some of the NUREG materialin the
- 6 second paragraph on this page. The deletion is not addresses in justifications 2,3, and 5?
BGE Response:
Bases SR 3.8.3.2 What is the rationale for deleting Comment the Bases reference to ASTM D2276 in the 4th
- 7 paragraph on this page? Justifications 1,2, and 3 do not address this change.
CGE Response:
, .-. - . , - -___.__,,w. r -.. .. -. ,-n , nn,,., ---,.--,--n-- - - - -- .em- n _,..,,.,.c, _ - . - . , , , . , + . - , , , . ,
CCNPP BASES 3.8.7 INVERTERS - OPERATING cacxwnr.sastsas7.cci t BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS >
I 3.8.7 Bases 15 Backaround The proposed change is nc.
Comment acceptable. To be OPERABLE (and not i an
- 1 Action) an inverter must be connected to its respective station battery. any other inverter alignment (i.e., constant voltage transformer or battery changer) is only allowed for a limited :
time and only in response to the LCO condition !
of an inverter inoperable. The discussion regarding battery chargers belongs in the Bases section for Action A.1.
BGE Response:
Bases 16 LCO The proposed new paragraph is Comment confusing. What is a " twin inverter"? How ,
~
- 2 many of them are there? Can one inverter power two AC vital busses? The licensee should revise the submittal to more clearly '
describe the inverter arrangement at CCNPP.
L' BGE Response:
Bases 1- LCO Note that the 3rd paragraph on this page Comment ( B 3.8-71) is not consistent with proposed
- 3 changes to the Background section.
CGE Response:
Bases 16 Action A.1 This proposed change and the The licensee should identify which of f Comment associated justification (16) are not consistent the changes reflects the CCNPP
- 4 with the proposed change and associated licensing basis and make appropriate justification (15) to the Background section. corrections to the submittal.
BGE Response:
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t CCNPP BASES 3.8.8 INVERTERS - SHUTDOWN CaCALVEREBASES388 CC1 I BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.8 Bases 9 Apolicability The proposed Bases change is Comment not acceptable because the associated ITS i
- 1 change is not acceptable.
CGE Response: ;
Bases 12 Actions the proposed change may or many not Comment be acceptable. However, addressing the issue
- 2 only in the Bases (and not in the LCO) does not make the change acceptable. The Bases are for ,
the purpose of explaining the TS, not for establishing requirements or limitations. If the t limitation on fuel handling is indeed limited to i the containment, this must be stated in the appropriate LCO Action (s). The Bases should ,
explain why this limitation is acceptable (e.g., ;
language from SE for Amendment 155 and i 135). i BGE Response:
Bases 9 SR 3.8.8.1 See comment regarding deletion of Comment the frequency requirement from this SR in i
CGE Response:
t
CCNPP BASES 3.8.9 DISTRIBUTION SYSTEMS - OPERATING cscAtvenrisAses38s cci !
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS i 3.8.9 Bases 17 Backaround The proposed deletion of Bases The submittal should be revised to Comment material regarding transfer from the preferred include an appropriate discussion.
- 1 offsite source to the alternate source is understandable. However, the licensee has not proposed a substitute for the deleted material which addresses the CCNPP design. !
BGE Response:
Bases 17 Backaround The proposal to dekte Table Comment 3.8.9-1 is not acceptable. The licensee should -
- 2 provide the Table, or retain the CTS listing of AC, DC, and AC vital bus subsystems in the body of LCO 3.8.9.
BGE Response:
Bases 18 Backaround Justification 18 is presented as a The licensee should provide a Comment reason for deleting Table B 3.8.9-1. The detailed discussion of the CCNPP
- 3 discussion includes a statement regarding shared systems and DC sources i shared systems and shared DC sources. LCO along with the proper justification for !
3.8.1 in the ITS is the only place that " shared why this is not included in the ITS.
systems" are identified, and is limited to DG support from the other unit for Control Room i Ventilation and H, monitoring. Nothing is said about opposite unit support for AC vital bus and DC electrical power subsystems. If the shared systems and shared DC sources are so complex ;
as to make creating Table B 3.8.9-1 !
complicated to the point of being impractical, why is none of this system and DC source i interdependency not included in the ITS?
l
CCNPP BASES 3.8.9 DISTRIBUTION SYSTEMS - OPERATING cscatventisastsass cci :
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS '
3.8.9 ,
CGE Response:
Bases 17 LCO The substitution of FSAR Fig. 8-9 for The licensee should explain why this Comment Table B 3.8.9-1 is not acceptable as discussed lack of consistency in language is
- 4 above. Also, the proposed language in the LCO acceptable, or revise the submittal to is not consistent. In the Background section, have consistent languags.
the licensee uses systems, subsystems, and channels. In the LCO section of the Bases, the i terminology " load groups" is used.
CGE Response:
Bases 1, 3 LCO This portion of the LCO Bases reverts to Comment subsystems and channels as opposed to load
- 5 groups. This is the same consistency question as addressed above. ;
BGE Response: t Bases Action A.1 The changes associated with Comment TSTF-16 are not acceptable because TSTF-16
- 6 has been rejected.
l BGE Response: .
I i
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a CCNPP BASES 3.8.9 DISTRIBUTION SYSTEMS - OPERATING cacatvansAscsass cci : ,
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.9 Bases Action B.1 The changes associated with Comment TSTF-16 are not acceptable because TSTF-16
- 7 has been rejected.
The Bases markup for this Action is confusing and appears to be inconsistent with LCO 3.8.7.
LCO 3.8.7 allows an AC vital bus to be powered from a constant voltage AC source for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, whereas this Bases section requires the bus to be powered from an inverter -
within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Which LCO is correct?
BGE Response:
Bases Action C.1 The changes associated with Comment TSTF-16 are not acceptable because TSTF-16
- 8 has been rejected.
BGE Response:
Bases The changes associated with TSTF-16 are not [
Comment acceptable because TSTF-16 has been rejected.
- 9 BGE Response:
l Bases 18 Table 3.8.9-1 See previous comments Comment regarding deletion of Table B 3.8.9-1 and
- 10 justification 18. ;
BGE Response:
i
[
i
CONPP BASES 3.8.10 DISTRIBUTION SYSTEMS - SHUTDOWN cacatvtansasusto cci :
BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.10 Bases 9 Applicability The proposal to delete "during Comment movement of irradiated fuel assemblies" from
- 1 the LCO Applicability does not appear to be acceptable. This issue is discussed at length in the staff comment regarding the Applicability of LCO 3.8.2.
BGE Response:
Bases 12 Actions See comment re: justification 12 and Comment its associated change in staff comment on
- 2 Actions for LCO 3.8.8 Bases.
BGE Response:
i
e CCNPP NUREG 3.8.1 AC SOURCES - OPERATING cacavtanwntcasi.cci : l NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS '
3.8.1 NUREG 1 SR 3.8.1.3 The justification does not make an The sentence should be retained as Comment adequate case for deleting the second sentence of Note part of the Note.
- 1 3 in this SR.
BGE Response:
NUREG SR 3.8.1.3 The term "from standby condition" has The licensee should provide an Comment been deleted from the SR, but no justification is appropriate justification, to retain
- 2 provided. the NUREG wording.
BGE Response:
NUREG SR 3.8.1.4 Proposed Note 1. to this SR does not make The Note serves no purpose and i Comment sense. The licensee has chosen to use the symbol for should be deleted.
- 3 " equal to or greater than " for the loading requirements of this SR. By definition, there is no " load range."
BGE Response:
NUREG 18 SR 3.8.1.4 NUREG Note 3 is proposed for deletion. The licensee should revise the 4 Comment Justification 18 states that CCNPP is not currently submittal to retain NUREG Note 3
- 4 restrained from testing more than one DG at a time, and to this SR since it reflects the proposes to retain their "right to do so." The staff CCNPP current licensing basis.
disagrees with the licensee's position. CTS SR t 4.8.1.1.2.a prefaces all DG SRs by stating they will be conducted on a staggered test basis. Requiring staggered testing eliminates the possibility for simultaneous testing, and justification 18 is wrong. -
BGE Response:
o CCNPP NUREG 3.8.1 AC SOURCES - OPERATING c:4.catvmntmaastect i !
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ~
3.8.1 NUREG 1 SR 3.8.1.4 The licensee has opted to retain the The staff requests that the licensee Comment CCNPP CLB with regard to DG loading requirements. provide such insight to aid the staff
- 5 Specifically, the loading requiremente are stated in" in understanding the licensee's terms of " equal to or greater than" a specified value. choice.
The staff does not understand why the licensee has not adopted the NUREG language which includes a load range, i.e.,1(kw) but _< (kw), and to which NUREG Note 2 is applicable. Justification 1 provides no insight into why this choice was made.
BGE Response:
NUREG 2 SR 3.8.1.7 The bracketed term " automatically" in the The licensee should revise this Comment NUREG is proposed to be deleted from the CCNPP ITS. justification to address the staff's
- 6 Does this mean that the DGs at CCNPP does not have concerns.
automatic transfer of fuel oil from the storage tank to the day tanks? If so, how is this accommodated in the accident analysis? If this is not the CCNPP design, why is the term " automatically" proposed to be deleted from the ITS?
BGE Response: :
2-
e CCNPP NUREG 3.8.1 AC SOURCES - OPERATING c .catvtarmustaasteci (
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 NUREG 1 Insert SR 3.8.1.8 The licensee proposes to move The staff will reconsider this Comment NUREG SR 3.8.1.18 to after ITS SR 3.8.1.7, and change following submittal of an
- 7 change the SR no. to 3.8.1.8. This is acceptable. The adequate justification by the licensee has also proposed to change the frequency licensee.
from 18 months to 31 days. No justification for this change is provided but the staff has no objection and this change is also acceptable. The licensee also proposes to delete the Note which precludes performing this SR in Modes 1-4. This latter change does not have a justification and is, therefore, not acceptable. NOTE:
TSTF-8 is acceptable.
BGE Response:
NUREG 6 SR 3.8.1.9 This licensee proposes to delete the The licensee should consider adding Comment voltage requirement of this SR but maintain the voltage as an acceptance criteria to
- 8 frequency requirement (60 Hz). The rationale in successfully conducting this SR.
justification 6 essentially states that voltage is not part of CCNPP CTS requirements. The staff acknowledges that the CTS only addresses reaching 60 Hz in less than or equal to 10 sec, but an acceptable voltage to allow loading in the same time frame is an inherent part of DG OPERABILITY. Since the 184 day fast start and the allowance for a modified start was added by amendment to the CCNPP license, it is highly probable that the omission of voltage requirements from this SR was an oversight.
BGE Response:
e CCNPP NUREG 3.8.1 AC SOURCES - OPERATING cacavtemwcasi.cci 0 NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS .
3.8.1 ,
NUREG 1, 2 SR 3.8.1.10 The SR is modified to delete the terms The licensee should provide Comment " automatic" and " manual" from the requirement to adequate justifications for the #
- 9 transfer from the normal to the alternate offsite circuit. changes.
However, the justifications annotated as being associated with this change do not address the change.
The licensee also proposes to change the frequency of <
this SR from 18 mo. to 24 mo. This proposed change is beyond the scope of the ITS.
The licensee also proposes to delete the Note which prohibits performance of this SR in Modes 1 and 2.
However, neither justification 1 nor 2 provide any ,
rationale for the proposed deletion. Therefore, this change will be considered.
BGE Response:
NUREG 9 SR 3.8.1.11 & SR 3.8,).12 Should the inclusion of I Comment these SRs in the ITS, to the exclusion cf other SRs be !
- 10 found acceptable for any reason, the 24 me. frequency :
is still beyond scope.
BGE Response-l i
CCNPP NUREG 3.8.1 AC SOURCES - OPERATING CACALVERT,NUREG381.CC1 $
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.1 NUREG 1, 2, SR 3.8.1.13 Changes to the NUREG SR (3.8.1.9) are Provide adequate justifications.
Comment 6 proposed as follows: 1) delete the Note which prohibits
- 11 performing this SR in Modes 1 and 2, 2) deletion of the Note directing the SR be conducted at a power factor of
.1[0.9], and deletion of the SR acceptance criteria for frequency and voltage. The licensee has not provided ;
an adequate justification for any of these changes.
Therefore, they will be considered not acceptable pending receipt of adequate justifications. Also, the change from 18 mo. to 24 mo. is beyond scope.
BGE Response:
NUREG 1 SR 3.8.1.12 (NUREG) The NUREG markup shows this Comment SR as being deleted. However, the indicated
- 12 justification (1) does not address this change at all.
Deletion of this SR will be considered not acceptable pending receipt of an adequate justification.
CGE Response: ,
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o CCNPP NUREG 3.8.1 AC SOURCES - OPERATING cacavtamunsaasi.cci NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.1 NUREG 1, 2 SR 3.8.1.14 The changes associated with this SR are Comment 21 as follows: 1) the Note prohibiting performance of this
- 13 SR in Modes 1 and 2 is deleted, 2) the NUREG language in the Body of the TS is deleted in favor of licensee proposed verbiage, and 3) the frequency is proposed to be changed from 18 mo. to 24 mo.
The first change is not acceptable because the The licensee should provide an justifications provided (1,2, and 21) do not address adequate justification, or retain the deleting the Note. Specifically, the justifications do not NUREG language. ,
establish why performing this SR at power does not constitute a risk to plant safety.
The proposed verbiage for the actual SR is not desirable The NUREG language should be because it does not adequately address the two parts of retained because it more accurately the NUREG SR; i.e., verifying that automatic trips that expresses the purpose of the SR.
are desired to be bypassed are in fact bypassed, AND automatic trips that are not desired to be bypassed are in fact not bvoassed. ,
The frequency change from 18 months to 24 months is beyond the scope of this ITS conversion.
BGE Response:
e CCNPP NUREG 3.8.1 AC SOURCES'- OPERATING cacaventwuercast.cci :
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.1 NUREG 20 SR 3.8.1.15 The licensee has proposed to revise the The staff recommends the licensee Comment language of this SR. The proposed revision deletes the review the proposed changes in
- 14- three part structure of the NUREG in favor of a single, light of staff comments with a view continuous, multipart requirement narrative. The towards retaining the NUREG revision also deletes part c of the NUREG SR in its format and language, as entirety. The justification for this (11) is that the DGs appropriate. i at CCNPP do not return to ready to load status. The staff is concerned that the proposed revision may be misleading. The NUREG organization for this SR is intended to convey the thought that there are 3 separate but sequential parts to this SR. The proposed :
single narrative defeats that purpose. In addition, justification 11 is not clearly understood. Once the safety bus loads are transferred to offsite power by opening the DG output breaker, what status is the DG in. Is it inoperable? Is the status indeterminate? Is the DG in runnir:0 standby ready to accept loads?
The frequency change from 18 to 24 months is beyond !
scope of the ITS conversion process.
BGE Response:
NUREG 1 NUREG SR 3.8.1.17 This SR is proposed to be deleted ,
Comment from the CCNPP ITS. The justification provided is 1. ;
- 15 Does the staff understand correctly that the DGs at CCNPP do not have a test override capability and wiTI continue to operate in Test Mode in the event of a DBA/ LOOP while the DG is undergoing testing? If this ,
is the CCNPP design, the DGs are inoperable during i testing. How is this handled at CCNPP? j BGE Response:
a i I
CCNPP NUREG 3.8.1 AC SOURCES - OPERATING cacavumnuntoastcci : ,
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.1 .
NUREG 20, SR 3.8.1.16 The licensee proposes to delete The staff recommends that the a Comment 6 frequency and voltage from the acceptance criteria of licensee reconsider the proposed
- 16 this SR. The justification (6) is that voltage and deletion of these acceptance frequency are demonstrated every 31 days, and need criteria.
not be repeated here. The staff does not agree with the licensee's justification. The voltage and frequency acceptance criteria in this SR are not demonstrated during the monthly test, and should be included as part of this SR.
The proposed change from 18 months to 24 months is i beyond the scope of the ITS conversion process.
BGE Response:
NUREG 20 NUREG SR 3.8.1.20 The licensee r,roposes to delete The licensee should provide a t Comment this SR from the CCNPP ITS. However, the justification revised justification for the '
- 17 (10) is not understood. The purpose of this SR is not a proposed deletion, or retain the SR common mode failure or reliability issue as discussed in in the CCNPP ITS.
the justification.
BGE Response: i NUREG 3 SR 3.8.1.17 This SR is added to address the DG The licensee should revise this SR Comment required by LCO 3.8.1.c, and requires performance of and justification (3) as necessary to -
- 18 SRs 3.8.1.3, 3.8.1.5, 3.8.1.6, and 3.8.1.7. The staff address the staff's concerns.
does not understand this SR. If a DG from another unit is required to support operation of the subject unit, why !
should the OPERABILITY of the other unit DG not be tied to successful perfermance of all the applicable SRs ,
for the DG in that unit? Why is it only required to "
perform the 4 SRs identified above?
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CCNPP NUREG 3.8.2 AC SOURCES - SHUTDOWN cacavmrunc3a2.cci :
f NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.2 NUREG 17 LCO 3.8.2 The staff does not understand The licensee should reconsider Comment justification 17. The reason for stopping deletion of "During movement of
- 1 movement of irradiated fuel when there is irradiate fuel assemblies" from the inadequate AC power sources is to preclude the LCO Applicability as well a occurrence of a fuel handling accident. It has justification 17.
nothing to do with equipment in the fuel handling building having emergency power. The concern is that the safety equipment necessary ,
to mitigate the consequences of a fuel handling accident could be without AC power, regardless of location.
CGE Response:
NUREG 2 SR 3.8.2.1 The SR should be revised to reflect !
Comment the Table prepared by the staff.
- 2 ;
BGE Response: ;
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CCNPP NUREG 3.8.3 DIESEL FUEL Oll, LUBE OIL, AND STARTING AIR cacatvennnuntc382 cci :
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.3 NUREG LCO 3.8.3 The licensee has opted to not The licensee should explain why this Comment incorporate the starting air and tube oil portions decision was made and is considered
- 1 of the NUREG LCO. However, no justification acceptable.
has been provided.
CGE Response:
NUREG 13,2 Condition A The staff does not agree with the The staff recommends retaining the Comment proposed revision to Condition A or Required NUREG format, even though this will
- 2 Action A.1. As proposed, the revised Condition result in a lengthy Condition A. In A does not simplify any issues, rather, it makes this way, Condition A, Condition D, the LCO more cumbersome. The NUREG is and SR 3.8.3.1 all tie together organized such that the requirements are without confusion.
completely stated in Condition A, and default Actions are contained in Condition D. As proposed, an operator does not have a direct t reference to what the LCO limits are. SR :
l' 3.8.3.1 provides some msight, but is not a direct reference to Condition A. Then, insert i A.1 directs the operator to Action D if there is !
less than 6 days supply of fuel oil in any tank, i but fails to state what that 6 day supply is. For i this value, an operator must refer to the Bases.
At best, this is cumbersome.
BGE Response: ;
NUREG 12 Condition 8 See comment / Note under LCO Comment 3.8.3, above.
- 3 BGE Response: !
CCNPP NUREG 3.8.3 DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR cacavrnnuunto3ereci :
i NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.3 NUREG insert Reauired Action A 1 Note The licensee Comment should consider providing a Table or a matrix in
- 4 the Bases to provide an explanation of the Fuel Oil Storage System at CCNPP. The Bases discussion of OPERABILITY should also ,
emphasize the single DG for the DBA unit, and the single DG for the shutdown unit.
BGE Response:
NUREG Condition E See comment / Note under LCO Comment 3.8.3, above.
- 5 BGE Response: l NUREG 13 Insert Condition D This insert is not necessary Comment if the NUREG format is followed. See ,
- 6 comments under Condition A, above.
BGE Response:
NUREG .2 SR 3.8.3.1 What do the specific gallon figures Comment represent? A 7-day supply? A 6-day supply?
- 7 Where is this information found? These '
questions would not be a problem if the NUREG format is retained.
BGE Response:
t NUREG 12 NUREG SR 3.8.3.2 and NUREG SR 3.8.3.4 i
Comment This is a subset of the comment under LCO
- 8 3.8.3, and the Note. ,
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CCNPP NUREG 3.8.7 INVERTERS - OPERATING cacAt.venamecastcci :
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.7 NUREG 1 SR 3.5.7.1 The justification does not The licensee should rev;se the Comment adequately address deleting the requirement to justification to specifically address
- 1 verify correct inverter frequency. why this deletion is acceptable.
CGE Response:
4 i
k t
e CCNPP NUREG 3.8.8 INVERTERS - SHUTDOWN cncatvtanwuntoasa.cci :
NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS .
3.8.8 NUREG 17 LCO Apolicability The licensee's proposal to Comment delete "During movement of irradiated fuel
- 1 assemblies" from the LCO Applicability does not appear to be acceptable. This issue is .
discussed at lenght in the staff comment regarding the Applicability of LCO 3.8.2.
BGE Response:
NUREG 1, 2 SR 3.8.8.1 The justifications do not The licensee should revise the Comment adaequately address deleting th requirment to justificaitons to specifically address
- 2 verify correct inverter frequency. why this ddeletion is acceptable.
CGE Response:
I
CCNPP NUREG 3.8.9 DISTRIBUTION SYSTEMS - OPERATING cacavtanwamastcci :
NUREG DOC- JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.9 NUREG Insert Action E A.3 This addition to the TS is Comment acceptable. However, it should be noted that
- the concerns regarding LCO 3.0.3 when 2 or more electrical power distribution subsystems are inoperable are not resolved by this change. .
The staff has rejected TSTF-16 which was intended to compliment proposed Action E.
Consequently, 2 or more inoperable electrical power distribution subsystems that do not result in a loss of function will still invoke LCO 3.0.3.
BGE Response:
i NUREG Pg 3/4 8-13 The changes associated with Comment the DC electrical power distribution
- 2 subsystems have not been reviewed pending resolution of TSTF-115.
BGE Response:
NUREG Pg 3/4 8-14 The changes associated with Comment the DC electrical power distribution l
- 3 subsystems have not been reviewed pending resciution of TSTF-115.
BGE Response: j e
1
CCNPP NUREG 3.8.9 DISTRIBUTION SYSTEMS - OPERATING cacavtarwtweses cci .
NUREG . f DOC 'JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.9 NUREG Pg 3/4 8-16 The changes associated with Comment the DC electrical power distribution
- 5 subsystems have not been reviewed pending resolution of TSTF-115.
CGE Response:
NUREG Condition A. Condition B. and Condition C Comment The changes associated with TSTF-16 are not
- 6 acceptable because TSTF-16 has been rejected.
CGE Response:
t NUREG 2 Condition B The staff does not understand Comment the proposed change. What is the difference
- 7 between an "AC vital bus" and an "AC vital bus subsystem"? Justification (2) does not provide any details that are directly applicable to this change and does not address the l staff's question. j CGE Response: l l
t
- - - , _ _ ....,---m- - - . -. - . - - - - - - . . - - , , - , - ,%_- --. - - - . _ _ -. , -- , ,, .- u - - - - -_-r
CCNPP NUREG 3.8.10 DISTRIBUTION SYSTEMS - SHUTDOWN cacavranmunasio cci 2 NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,
3.8.10 NUREG 17 LCO 3.8.10 Acolicability The licensee's Comment proposal to delete "During movement of
- 1 irradiated fuel assemblies" from the LCO Applicability does not appear to be acceptable.
This issue is discussed at length in the staff comment regarding the Applicability of LCO 3.8.2.
CGE Response:
NUREG Reauired Action A.25 The proposed change Comment is not acceptable because CEOG-86 has not
- 2 been accepted.
BGE Response:
ITS 3.7.1 MAIN STEAM SAFETY VALVES (MSSVs)
- r. .
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE bate- DATE COMMENTS-NO. JFD LCO OPENED CLOSED ,
3.7.1-1 A.3 ITS 3.7.1 ITS 3.7.1 ACTIONS contains a 5/30/97 Correct this ACTIONS Note which allows separate discrepancy.
condition entry for each MSSV.
CTS 3.7.1.1 ACTIONS do not contain this requirement. The Unit 1 CTS 3.7.1.1 markup designates the change as A.3.
The Unit 2 CTS 3.7.1.1 markup has no designation. ,
3.7.1-2 A.5 CTS CTS 4.7.1.1 and associated CTS 5/30/97 Delete this change.
LA.1 4.7.1.1 Table 4.7-1 requires testing See Item Numbers CTS Table in accordance with CTS 4.0.5 3.7.1-5, 3.7.1-6, 4.7-1 and lists the MSSVs, lift and 3.7.1-7.
STS LCO settings and the orifice size, 3.7.1 respectively. ITS LCO 3.7.1 STS SR and ITS SR 3.7.1.1 modify STS 3.7.1.1 LCO 3.7.1 and STS SR 3.7.1.1 STS Table to delete STS Table 3.7.1-2.
3.7.1-2 This change is designated ITS CE0G-84. It is the staff's LCO 3.7.1 understanding that this change l ITS SR is not generic and has been 3.7.1.1 rejected by the generic review ;
and process. See Item Number Associated 3.7.1-5, 3.7.1-6 and 3.7.1-7.
Bases i
s b
b 1
ITS 3.7.1 MAIN STEAM SAFETY VALVES (MSSVs) ,
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED- CLOSED .
- Footnote allows 5/30/97 Delete this 3.7.1.1 entry into MODE 3 to determine change.
- Footnote OPERABILITY of the MSSVs. STS STS SR SR 3.7.1.1 has a Note which 3.7.1.1 allows entry into snd Note operation in MODE 3 prior to ITS performing the SR. ITS SR SR3.7.1.1 3.7.1.1 modifies the STS Note Note and to state that the SR is not ,
Associated required prior to entry into Bases MODE 3. This change is designated CF0G-71. It is the staff's understanding that this change is not generic and i has been rejected by the
- generic review process.
2
ITS 3.7.1 MAIN STEAM SAFETY VALVES (MSSVs)
ITEM DOC /; CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS .
NO. JFD LCO ' OPENED CLOSED ,
3.7.1-4 L.3 CTS CTS 3.7.1.1 ACTION b provides 5/30/97 Revise the 3.4.1.2 remedial actions if less than discussion and CTS the required number of MSSVs justification for 3.7.1.1 are OPERABLE in operating the deletion of ACTION b steam generator in MODE 3. CTS 3.7.1.1 ITS 3.4.5 L.3 states that inoperable ACTION b.
ITS 3.7.1 MSSVs are in the non-operating loop. It also states that "Although Section 3.4 allows only one Reactor Coolant System to be OPERABLE, it is very unlikely that Calvert Cliffs will operate in this configuration." This statement and the statements following it are in error.
CTS 3.4.1.2 requires both RCS loops to be OPERABLE with one .
in operation. The CTS 3.4.1.1 i ACTIONS with one loop inoperable are the same as ITS 3.4.5- restore within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or shutdown.
3
ITS 3.7.1 MAIN STEAM SAFETY VALVES (MSSVs) r i
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED CLOSED .
3.7.1-5 JFD STS 3.7.1 STS 3.7.1 Table 3.7.1.2 5/30/97 Provide a clear t 14 Table specifies the lift setting of description and Bases 3.7.1-2 the MSSVs with a tolerance ofi justification for JF03 ITS 3.7.1 3%. ITS 3.7.1 deletes this deleting the i 3%
ITS B3.7.1 table per CE0G-84 (See Item tolerance from STS ,
Bases Number 3.7.1-2). ITS 3.7.1 3.7.1 Table 3.7.1-2. [
SR 3.7.1.1 marks up STS 3.7.1 Table ;
3.7.1-2 to delete the i 3% Since CEDG-84 has tolerance using justification been rejected, what !
JFD 14. JFD 14 states that tolerance (s) is the i 3% does not apply to going to be .
CCNPP, but the allowable value specified in STS !
range is from i 3% to 3.7.1 Table 3.7.1-2 approximately i 6% depending in ITS 3.7.1.
on the value. In addition, Provide a discussion ,
the CCNPP procedures require and justification this as found valve to be i for the 3%. This is confusing. See tolerance (s). ,
Item Number 3.7.1-2. I Since ITS B3.7.1 Bases SR 3.7.1.1 ,
discusses the !
OPERABILITY of the MSSVs, provide additional discussion and justification for ,
changing the STS wording from "i 3% -
setpoint tolerance for OPERABILITY" to i "i 3% setpoint tolerance for as found valves in the '
plant procedures."
See Item Number ,
3.7.1-2.
4
ITS 3.7.1 MAIN STEAM SAFETY VALVES (MSSVs) 2 ;
ITEM. DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE' CDf9fENTS L NO. -1FD LCO- OPENED CLOSED , ,
3.7.1-6 JFD- STS SR STS SR 3.7.1.1 states that 5/30/97 Delete this -
17 3.7.1.1 following testing the MSSVs change in ITS SR ITS SR lift settings shall be within 3.7.1.1. See ^
3.7.1.1 i 1% ^.0 allow for drift. 'ITS Item Number and SR 3.7.1.1 deletes this 3.7.1-2. '
Associated requirement from ITS SR Bases. 3.7.1.1 but retains it in the Bases for SR 3.7.1.1. If the requirement is to be retained per JFD 17 in the Bases, it must be specified in the SR. i See Item Number 3.7.1-2.
3.7.1-7 Bases STS B3.7.1 STS B.3.7.1 Bases-BACKGROUND 5/30/97 Delete this JFD 7 Bases- states the following: "The change. See Item l BACKGROUND MSSV design includes staggered Number 3.7.1-2. :
ITS B3.7.1 setpoints, according to Table Bases 3.7.1-1, in the accompanying ;
BACKGROUND LCO,..." ITS B3.7.1 Bases- 7 BACKGROUND deletes the words "according to...LCO,". The Justification-(Bases JFD 7) states that the deletion is made to conform with changes made to the specification.
Since both tables are to be retained, the deletion is unacceptable. See Item Number 3.7.1.-2.
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ITS 3.7.1 MAIN STEAM SAFETY VALVES (MSSVs) t ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED CLOSED ,
3.7.1-8 Bases STS B3.7.1 STS B3.7.1 Bases - LCO states 5/30/97 Delete this JFD 7 Bases LCO the minimum required MSSVs change or provide ITS B3.7.1 required in MODES 1,2, and 3. additional Bases LCO ITS B3.7.1 modifies the STS discussion and writeup based on changes made justification to the specification (Bases based on current JFD 7). No changes made have licensing basis, been made to the specification system design or which would necessitate, the operational ITS proposed changes. constraints.
3.7.1-9 None STS B3.7.1 STS B3.7.1. Bases SR 3.7.1.1 5/30/97 Licensee to Bases states the following:
...a update the SR 3.7.1.1 minimum of 20% of the valves submittal with ITS B3.7.1 tested every 24 months." ITS regards to EDIT-Bases B3.7.1 Bases SR 3.7.1.1 18 when OG SR 3.7.1.1 changes this to: "
...a provides minimum of 20% of the valves revision.
be tested every 24 months." -
This change is designated as a generic editorial change. The staff has reviewed this change ;
under EDIT-18, and has modified the change.
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CNPP ITS 3.7.2 MAIN STEAM ISOLATION VALVES (MSIVs)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DAiE COMMENTS '
NO. JFD LCO OPENED CLOSED 3.7.2-1 A.5 CTS 3.7.1.5 CTS 3.7.1.5 ACTION, allows 5/30/97 Provide ACTION- an inoperable MSIV to be additional MODE 1 either restored to OPERABLE discussion and !
ITS 3.7.2 status or closed within justification RA A.1 four hours when in MODE 1. for this More ITS 3.7.2 ACTION requires Restrictive '
an inoperable MSIV to be change.
restored to OPERABLE status within eight hours. The ITS is More Restrictive :
than the CTS in that the CTS would allow continued .
operation in MODE 1 with the MSIV closed. It should be noted that the old STS i (NUREG-0212) only required restoring the MSIV to OPERABLE status not closing it. Thus CCNPP CTS is a plant specific TS.
3.7.2-2 A.6 CTS 3.7.1.5 CTS 3.7.1.5 ACTION MODES 2 5/30/97 Provide ,
ACTION and 3 refer to continued additional MODES 2 and 3 operation in MODES 1,2, and discussion and '
3 provided certain justification conditions are met. A.6 for this Less states that the reference Restrictive to MODE 1 will be deleted chaage. See because the ACTIONS do not Item Number apply to MODE 1. This is 3.7.2-1.
wrong based on Item Number 3.7.2-1. The change is Less Restrictive, not Administrative. See Item .
Number 3.7.2-1.
I
CNPP ITS 3.7.2 MAIN STEAM ISOLATION VALVES (MSIVs) t ITEM DOC /- CTS /STS DESCRIPTION OF ISSUE DATE DATE- COMMENTS .
NO. JFD' LCO OPENED CLOSED 3.7.2-3 M.3 CTS 3.7.1.5 CTS 3.7.1.5 ACTION-MODES 2 5/30/97 Correct this ACTION MODES 2 and 3 requires the plant to discrepancy.
and 3 be in MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ITS 3.7.2 RA when required actions and D.1 and 0.2 associated Completion Times cannot be met. ITS 3.7.2 i RA D.1 and D.2 requires the i plant to be 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 MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the RA A.1, RA >
B.1, RA C.1 and RA C.2 and associated Completion times cannot be met. The markup ,
for Unit 1 CTS 3.7.1.5 ACTION-MODES 2 and 3 shows this change. However the markup for Unit 2 CTS '
3.7.1.5 ACTION-MODES 2 and 3 deletes the requirement !
to be in MODE 4 (HOT !
SHUTDOWN) in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
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CNPP ITS 3.7.2 MAIN STEAM ISOLATION VALVES (MSIVs)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS- '
NO. JFD LCO OPENED CLOSED ,
3.7.2-4 LA.1 CTS 4.7.1.5 CTS 4.7.1.5 requires each 5/30/97 Delete this JFD STS SR 3.7.2.1 MSIV be demonstrated generic change.
15 ITS SR 3.7.2.1 OPERABLE by verifying full Bases and Associated closure in less than 5.2 JFD 7 Bases seconds. STS SR 3.7.2.1 also requires each MSIV. be demonstrated OPERABLE by verifying full closure in less than a plant specified time. ITS SR 3.7.2.1 does not retain this requirement but relocates it to the IST Program. This is unacceptable, would be considered a generic change and be beyond the scope of .
review for this conversion.
3.7.2-5 L.4 STS SR 3.7.2.1 STS SR 3.7.2.1 Note states 5/30/97 Delete this Note that the SR is "Only change.
ITS SR 3.7.2.1 required to be performed in Note MODES I and 2." ITS SR and Associated 3.7.2.1 changes this Note Bases to "Not required to be performed prior to entry into MODE 3." This change is designated CE0G-72 in the ITS markup. It is the staff's understanding that this change is not generic and has been rejected by the generic review process.
3
CNPP ITS 3.7.2 MAIN STEAM ISOLATION VALVES (MSIVs) ~
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS '
NO. JFD LCO OPENED CLOSED' 3.7.2-6 JFD 1 STS 3.7.2 STS 3.7.2 APPLICABILITY is 5/30/97 Either delete ,
Bases APPLICABIL-ITY MODE 1, MODE 2 and 3 except this generic JFD 1 and Associated when all MSIVs are closed change or Bases and de-activated. ITS provide ITS 3.7.2 3.7.2 APPLICABILITY deletes additional APPLICABILITY "and de-activated." The discussion and and Associated justification for both the justification Bases ITS change (JFD 1) and the based on current associated Bases changes licensing basis, (Bases JFD 1) is the system design or standard deletion of operational bracket removal constraints.
justification. However, the Bases markup also ,
states this is an generic editorial change. The ,
staff has not received this EDIT-X change for review.
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i CNPP ITS 3.7.2 MAIN STEAM ISOLATION VALVES (MSIVs) '
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE- DATE- COMMENTS NO. JFD LC0 OPENED CLOSED
. 3.7.2-7 Bases STS B3.7.2 STS B.3.7.2 Bases - RA A.1 5/30/97 Provide JFD Bases- contains a paragraph additional Il RA A.1 justifying the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discussion and ,
ITS B3.7.2 Completion Time rather than justification to Bases-RA A.1 the containment isolation show that the valve Completion Time of 4 MSIVs are not hours. The MSIV is containment considered a containment isolation isolation valve. ITS valves.
B3.7.2 BASES RA A.1 deletes Reference to this paragraph based on the UFSAR sections, justification that the licensee current licensing basis documentation does not consider the MSIV and associated as a containment isolation staff SERs or valve. letters will be sufficient to resolve this '
issue.
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_ m _ . _- _ __ - . _ - _ _ _ _ _ _ - _ _ _ _ _ - _ _ ._m _- _ =- .--_ _ _ _ _ . -
a CCNPP STS 3.7.3 MAIN FEEDWATER ISOLATIDN VALVES (MFIVs) AND MFIV BYPASS VALVES ITEM DDC/ CTS /STS DESCRIPTIDN OF ISSUE DATE DATE CDMMENTS NO. JFD LCO OPENED CLOSED ,
S3.7.3-1 JFD 7 STS 3.7.3 STS 3.7.3 is not 5/30/97 Provide Bases included in the additional -
JFD 7 CCNPP ITS. The discussion and justification (JFD justification to
- 7) states that these show that the valves are not MFIVs and MFIV containment Bypass valves are isolation valves and not containment are not credited in isolation valves the safety analysis. and that the ,
The staff considers additional safety the MFIV and MFIV functions bypass valves to specified in STS i have more than one B3.7.3 Bases are safety function in not performed by ;
addition to the CCNPP MFIVs containment and MFIV bypass 1su'= tion. Thus a valves. If they separate do, include STS .
specification, which 3.7.3 in the addresses these CCNPP ITS.
Other safety Reference to functions as UFSAR sections, specified in STS licensee ;
B3.7.3 - Bases documentation and APPLICABLE SAFETY associated staff ANALYSES and LCO is SERs or letters I provided. may be sufficient i to resolve this issue.
I
CCNPP STS 3.7.4 ATMOSPHERIC DUMP VALVES (ADVs) i
- 1 ITEM DOC / CTS /STS DESCRIPTIDN OF DATE DATE COMMENTS NO. JFD LCO ISSUE OPENED CLOSED ,
S3.7.4-1 JFD 8 STS STS 3.7.4 is not 5/30/97 Provide additional Bases 3.7.4 included in the discussion and JFD 7 CCNPP ITS. The justification to show justification (JFD that the additional
- 8) states that the safety functions ADVs are not specified in STS credited in the B3.7.4 Bases are not Safety Analysis. performed by the CCNPP The staff considers ADVs. If they do the ADVs to have include STS 3.7.3 in more than one CCNPP ITS. Reference safety function, to UFSAR Sections, and are considered licensee documentation ,
the primary valves and Associated staff that are used SERs or letters may be during a SGTR sufficient to resolve event. Thus a this issue.
separate specification, which addresses these other safety functions as specified in STS B.3.7.4- Bases-APPLICABLE SAFETY ANALYSES and LCO, i ,
is provided. [ !
l 1
CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM .,
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS.
NO. JFD LCO OPENED CLOSED .
3.7.3-1 A.3 CTS 3.7.I.2 CTS 3.7.1.2 ACTION b.2 5/30/97 Correct this L.5 ACTION b.2 requires the other units discrepancy by JFD CTS motor-driven AFW pump be either adding a 10 4.7.1.2.a.3 verified OPERABLE, and that RA to ACTION C Bases ITS 3.7.3 valve 2-CV-4550 and 1-CV-4550 which verifies JFD 7 RA C.2 (for Units 1 and 2, that valves 2-CV-ITS SR respectively) be verified 4550 and 1-CV-3.7.3.2 that the valves were 4550 have been and exercised within the last 30 exercised within Associated days. ITS 3.7.3 RA C.2 the last 30 days Bases requires the motor-driven or change the SR pump from the other unit be frequency of ITS verified OPERABLE but does SR 3.7.3.2 from not require the verification 92 days to 31 that the valves were days. Provide exercised within the last 30 additional days. The justification discussion and (A.3) states that the justification to exercising the valves support the requirement is moved to ITS proposed change.
SR 3.7.3.2 and this is done See Item Number every 31 days. The 3.7.3-2.
justification (L.5) for the Surveillance Requirement states this Frequency is 92 days. In addition, if a unit is shutdown, the SRs would not need to be performed on that unit's AFW components.
Thus, ITS SR 3.7.3.2 would not need to be performed over
! a 92 day frequency as required by the ITS SR or 31 day frequency as required by CTS 4.7.1.2.a.3. See Item Number 3.7.3-2.
i
t CCNPP.ITS 3.7.3 AUXILIARY FEEDWATER'(AFW) SYSTEM-ITEM' DOC /! CTS /STS. DESCRIPTION OF ISSUE ~- DATE DATE- CGMENTS: -
NO. JFD LCO' OPENED CLOSED ,f 3.7.3-2 A.3 CTS 3.7.1.2 CTS 3.7.1.2 ACTION b.2 5/30/97 Either clearly I L.5 ACTION b.2 requires verifying that the define operating !
JFD CTS cross-tie valves have been position in the !
10 4.7.1.2.a.3 exercised within the last 30 BASES or provide [
BASES CTS days. CTS 4.7.1.2.a.3 and a list of valves i JFD 7 4.7.1.2.a.4 ITS SR 3.7.3.2 require to be tested by I ITS 3.7.3 cycling each testable, ITS SR 3.7.3.2 in !
RA C.2 remote-operated valve that is the BASES. !
ITS SR not in its operating Provide [
3.7.3.1 position. These SRs are additional ITS SR confusing in that " operating justification and !
3.7.3.2 position" is not clearly discussion for !
and defined and may conflict with the proposed !
Associated the requirements of CTS change. !
Bases 4.7.1.2.a.4 and ITS SR !
3.7.3.1-verification of t valves in correct position. j In the case of the AFW cross- ,
tie valves the normal !
operating position would be j closed. Thus it is :
, conceivable that these valves i would never be cycled except l I
if CTS 3.7.1.2 ACTION b was entered.
3.7'3-3
. M.2 ITS 3.7.3 See Item Number 3.7.3-8 5/30/97 See Ites Number j Condition D 3.7.3-8 ;
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1 3
i CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM ,[
ITEM ~ DOC / CTS /STS' DESCRIPTION OF ISSUE DATE DATE ComENTS' ;
NO. JFD' LCO OPENED CLOSED .
3.7.3-4 M.3 CTS 4.7.1.2.b CTS 4.7.1.2.b requires the 5/30/97 Provide a
! ITS SR AFW flow path to be verified discussion and 3.7.3.7 and from the CST to the SGs prior justification for Associated to entering MODE 3 after this Less ,
Bases being in MODE 5 for a Restrictive !
specific period of time. ITS change. -
SR 3.7.3.7 will require the i AFW flow Path to be verified prior to entering MODE 2 ,
after being in MODE 5 or 6 for a specific period of I time. No justification has f been provided for the'Less Restrictive change of going from " prior to entering MODE 3" in the CTS to " Prior to !
entering MODE 2" in the ITS.
3.7.3-5 LA.2 CTS 3.7.1.2 CTS 3.7.1.2 ACTION a.2.b 5/30/97 Provide the ACTION a.2.b requires the inoperable procedure or ITS 3.7.3 steam-driven pump restored to plant document to :
RA A.2 standby status or automatic which the initiating status if the information is other steam-driven pump is moved and the ;
place in standby. ITS 3.7.3 document change RA A.2 requires the steam- control.
driven pump restored to OPERABLE status. The ,
requirement to place the pump, upon restoration, in I the standby or automatic initiating status is moved to plant procedures, controlled i according to the plant change control process.
3
o B
CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM ITEM DOC /~ CTS /STS DESCRIPTION OF ISSUE- DATE DATE- COMMENTS NO. JFDL LCO OPENED CLOSED- ,
3.7.3-6 LA.4 CTS 3.7.1.2 CTS 3.7.1.2 ACTION C allows 5/30/97 Modify ITS LCO JFD 9 ACTION C AFW trains to be removed from 3.7.3 Note as BASES ITS LCO 3.7.3 service during periodic specified.
JFD 7 Note and testing, provided a dedicated Provide Associated operator is stationed at the additional Bases local stations with direct justification and communications to the control discussion for room. Upon completion of the the change. See testing, the trains are Item Number restored to their proper 3.7.3-6.
status and verified by an independent operator check.
which only states that the AFW trains are allowed to be i removed from service during periodic testing. This Note is incomplete, in that CCNPP's current licensing basis requires that the removal be done under certain administrative controls. The details of the administrative control may be moved to the Bases but the Note must contain the words "under administrative controls."
This change mimics ITS 3.6.3 !
ACTIONS Note 1. See Item Number 3.7.3-6. ,
4 ,
-_______-____ -____ ______ _ _______- -___ _ ________ - _- . __ _ __ _ ___ - ___ ____ 2
F CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM ,
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE C009 TENTS NO. JFD LCO OPENED CLOSED' .
3.7.3-7 LA.5 CTS CTS 4.7.1.2.a.1 & a.2 5/30/97 Provide the Plant 4.7.1.2.a.1 contains specific values for Procedure to CTS dynamic head and Reactor which the 4.7.1.2.a.2 Coolant System temperature in information is the Surveillance Requirements moved and the to verify the AFW steam- procedure change driven and motor-driven pumps control.
develop a certain dynamic '
head. ITS SR 3.7.3.3 does not contain the specific :
values for dynamic head testing. The specific values are moved to plant procedures ,
and/or Bases.
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CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM ,
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE- DATE DATE . CoaWENTS- !
j NO. JFD LCO OPENED CLOSED .:
~
r 3.7.3-8 JFD I STS LCO 3.7.5 STS 3.7.5 APPLICABILITY 5/30/97 Delete this }
JFD 2 Note states that the AFW system is change and update t JFD STS 3.7.5 OPERABLE in MODE 4 when steam the submittal to !
10 APPLICABILITY generator is relied upon for include the MDDE j Bases STS 3.7.5 heat removal. STS LCO 3.7.5 4 requirements in .
JFD I Condition B Note, STS 3.7.5 Conditions B, the added ITS [
Bases STS 3.7.5 D, and E and STS SR 3.7.5.3 Conditions and i JFD 3 Condition D Note 2 and SR 3.7.5.4 Note 2 SRs, or provide .
Bases STS 3.7.5 specify the requirements and additional l JFD 7 Condition E conditions within STS 3.7.5 justification and l STS SR to which the MODE 4 discussion for [
3.7.5.3 APPLICABILITY applies and any deviations i Note 2 does not apply. The ITS based on current ;
STS SR counter parts to the STS licensing basis, j 3.7.5.4 items specified (ITS LCO system design or :
Note 2 3.7.3, ITS 3.7.3 operational i ITS LCO 3.7.5 APPLICABILITY, ITS 3.7.3 constraints. See ,
ITS 3.7.5 Conditions D and F, and ITS Item Number :
APPLICABILITY SR 3.7.3.4 and ITS SR 3.7.3-15. .
ITS 3.7.5 3.7.3.5) delete these !
Conditions A, requirements and conditions 1 B, C, D, and and modifies the Bases t F accordingly. STS 3.7.5 i ITS SR Condition E is also deleted. I i 3.7.3.4 These proposed changes were Note 2 reviewed and rejected by the !
ITS SR staff in TSTF-29. In short, !
3.7.3.5 th hasis for the rejection l Note 2 was thai., at the OG's ITS SR insistence, the switch from !
3.7.3.6 AFW to RHR/SDC did not occur- I and exactly at the MODE 3 to MODE Associated 4 interface but carried over Bases into MODE 4 for a short E
. . .__ - - - - - . - . - ~ _ - - . . - - - - . --_!
v CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM 2
ITEM DOC / CTS /ST5 DESCRIPTION OF' ISSUE DATE DATE COMNENTS l ,
NO. JFD LCO OPENED CLOSED l .
duratior.. Therefore, for these requirements and conditions are required. In addition, ITS 3.7.3 Conditions A, B, and C and ITS SR 3.7.3.6 may need to be revised to include these requirements and conditions.
See Item Number 3.7.3-15.
3.7.3-9 JFD 2 ITS 3.7.3 and The renumbering of ITS 3.7.3 5/30/97 See-Item Numbers Bases Associated and succeeding specifications S3.7.3-1 and JFD 2 Bases will depend on the resolution S3.7.4-1.
Bases of Item Numbers S 3.7.3-1 and JFD 3 S 3.7.4-1.
3.7.3-10 JFD STS 3.7.5 STS 3.7.5 ACTION A describes 5/30/97 Include this 10 ACTION A the RA, and Completion Time Condition, RA and Bases. ITS 3.7.3 for when the steam supply to Completion Time JFD 3 ACTIONS and the steam driven AFW pump (s) in ITS 3.7.3.
Bases Associated is inoperable. ITS 3.7.3 Revise ITS 3.7.3 JFD 7 Bases does not contain this ACTION. Condition E and No justification is given for Associated Bases its deletion. Based on the accordingly.
description of the steam supply provided in ITS B3.7.3 Bases - BACKGROUND, which uses the STS wording, the staff believes this Condition, RA, and Completion ;
Time are necessary at CCNPP.
m 7
- _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ - - _ - - _ . _ _ _ _ _ _ - - _ - _ _ -_ - _ m -A-i % -,- = m v -= -- -e- *_ 'a _-- e+->4 w- _ ___-___m - - - --
v CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM 2
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED CLOSED .
3.7.3-11 JFD ITS 3.7.3 ITS 3.7.3 RA A.2 and RA B.2 5/30/97 Provide t 10 RA A.2 Completion Time has an discussion and ,
ITS 3.7.3 additional requirement not justification for RA B.2 and addressed in the CTS. The this More j Associated additional Completion Time is Restrictive Bases to restore an AFW pump to change. l OPERABLE status 10 days from .
discovery of failure to meet the LCO. There is no justification for this additional More Restrictive Completion Time. l 3.7.3-12 Bases STS B3.7.5 STS B3.7.5 Bases - RA D.1 5/30/97 Provide JFD 3 Bases states that with all AFW additional RA D.1 trains inoperable, there is discussion and ITS B3.7.3 "only a limited means for justification for >
Bases conducting a cool down with this deletion.
RA F.1 nonsafety grade equipment.
ITS B3.7.5 Bases RA F.1 deletes this statement. The justification provided states that it is deleted to make the statement more understandable or to conform to the CCNPP design or safety analysis. Based on the Bases description, the justification does not seem !
to apply to this deletion.
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.o CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM J
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD. LCO OPENED CLOSED .
3.7.3-13 Bases CTS 4.7.1.2.b STS B3.7.5 Bases - SR 3.7.5.5 1 5/30/97 Delete this t JFD 3 CTS states that the SR requires a change.
4.7.1.2.c.2 verification of minimum flow STS B3.7.5 capacity of 750 gpm at 1270 Bases psi to ensure that the flow SR 3.7.5.5 path from the CST to the SG ITS B3.7.3 is properly aligned. ITS Bases B3.7.3 Bases SR 3.7.3.7 SR 3.7.3.7 deletes this requirement. No justification is provided.
Yet CTS 4.7.1.2.b which is the CTS counterpart to STS SR 3.7.5.5/ITS SR 3.7.3.7 requires a flow test and CTS 4.7.1.2.c.2 specifies the minimum gpm as 300 gpm.
3.7.3-14 None STS B3.7.5 STS B3.7.5 Bases - RA D.1 5/30/97 Delete these Bases describes the RA, and changes.
RA D.1 Completion Times for the ITS B3.7.3 condition of all AFW trains Bases inoperable in MODES 1, 2, and RA F.1 3. ITS B3.7.3 - Bases RA F.1 modifies the STS wording.
The modifications are designated CEOG-76 and CEOG-
- 77. It is the staff's understanding that these changes are not generic and have been rejected by the i generic review process. ,
9
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CCNPP ITS 3.7.3 AUXILIARY FEEDWATER (AFW) SYSTEM 2
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS ,
NO. JFD LCO OPENED CLOSED . ,
3.7.3-15 None CTS CTS 4.7.1.2.c.1 requires 5/30/97 Provide 4.7.1.2.c.1 verification that the AFW discussion and ITS SR valves and pumps actuate to justification for 3.7.3.5 and their correct position on a tte More Associated test signal. ITS SR 3.7.3.5 Restrictiva Bases requires verifying the AFW change. See Item pumps start automatically on Number 3.7.3-8. -
a simulated signal or with an actual signal when in MODE 1, 2, or 3. There is no discussion or justification ,
for adding the More !
Restrictive requirement of MODES 1, 2, or 3. This change will be dependent on the resolution of Item Number 3.7.3-8. The inclusion of '
MODE 4 APPLICABILITY / Note would require the retention of "in MODES 1, 2, or 3, while the deletion of MODE 4 APPLICABILITY / Note would require the deletion of "in MODES 1, 2, or 3."
10 1
..____.__m___ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _
CCNPP ITS 3.7.4 CONDENSATE STORAGE TANK (CST)
ITEM DOC /- CTS /STS. DESCRIPTION OF ISSUE DATE DATE C0f#iENTS NO. JFD LCO OPENED CLOSED .
3.7.4-1 LA.1 CTS 3.7.1.3 CTS 3.7.1.3 lists the 5/30/97 Provide the plant ITS 3.7.4 specific CST numbers procedure to which and the specific the information is backup water supply moved and the tank numbers in the procedure change LCO, ACTIONS, and SRs. control.
ITS 3.7.4 does not list the specific numbers. The specific component numbers will be listed in the plant procedures.
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ITEM DOC /;; CTS /STS DESCRIPTION OF ISSUE DATE- DATE COMENTS NO. JFD- LCO _
OPENED- CLOSED._ ,
3.7.4-2 LA.2 CTS 4.7.1.3.2 CTS 4.7.1.3.2 requires 5/30/97 Provide the plant
'ITS 3.7.4 the backup CST be procedare to which RA A.1 demonstrated OPERABLE the information is once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by moved and the ,
verifying the tank procedure change contains a minimum of control.
150,000 gallons of water, and the flow path for taking suction from this tank is OPERABLE with the i manual valves in this ficw path open.
ITS RA A.1, second Completion Time, requires the availability of the i backup water supply be '
verified once per 12 ;
hours. Verifying the ,
tank contains the minimum water and the flow path operability ;
details are moved to t plant procedures.
3.7.4-3 JFD 2 ITS 3.7.4 and See Item Number 3.7.3- 5/30/97 See Ites Number BASES Associated 9 3.7.3-9 JFD 2 Bases ,
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e CCNPP ITS 3.7.4 CONDENSATE STORAGE TANK (CST)
ITEML DOC /- CTS /STS DESCRIPTION OF ISSUE. DATEI DATEL COMMENTS; NO.- JFD- LCO ' OPENEDJ CLOSED: ,
3.7.4-4 JFD 3 ITS 3.7.4 Changes made to'ITS 5/30/97 See Item Number BASES APPLICABILITY 3.7.4 APPLICABILITY, 3.7.3-8.
! JFD 1 ITS 3.7.4 ITS 3.7.4 RA B.2, and BASES BASES- Associated Bases are JFD 7 APPLICABILITY made in accordance ITS B3.7.4 with TSTF-29. These BASES changes are RA B.1 and unacceptable. See B.2 Item Number 3.7.3-8.
3.7.4-5 None STS SR STS SR 3.7.6.1 5/30/97 Delete this change.
3.7.6.1 requires verifying CST ITS SR level is 2 150,000 3.7.4.1 and gal . ITS SR 3.7.4.1
- Associated and Associated Bases Bases requires verifying CST level is 2 150,000 gal. per unit. The change is justified by TSTF-140. This change is not in accordance with TSTF-140.
3.7.4-6 None STS B3.7.6 STS B3.7.6 BASES-RA- 5/30/97 Licensee to update Bases A.1 and A.2 describes the submittal in RA A.1 and the ras and Completion accordance with A.2 Times for when the CST TSTF-174.
ITS B.3.7.4 is inoperable. ITS BASES B3.7.4 Bases RA A.1 RA A.1 and and A.2 modifies the A.2 STS wording based on CEOG-79 (TSTF-174).
The modifications are not in accordance with TSTF-174.
3
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- CCNPP ITS 3.7.5 COMPONENT COOLING WATER (CCW) SYSTEM ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMENTS =
NO. JFD' LCO ~ OPENED CLOSED" ,
3.7.5-1 A.I CTS CTS 3/4.7.5 is entitled - 5/30/97 Correct this
! JFD 2 3/4.7.5 " Component Cooling Water discrepancy.
ITS 3.7.5 System." The CTS markup changes this to " Component Cooling Water (?.CW)
System." ITS 3.7.5 is
- entitled " Component Cooling (CC) System."
3.7.5-2 LA.2 CTS CTS 4.7.3.1.b requires 5/30/97 Provide the plant-4.7.3.1.b verifying each automatic procedures to which ITS valve actuates to its the information is 3.7.5.2 correct position on a moved and the Safety Injection Actuation procedure change signal. ITS SR 3.7.5.2 control.
requires verifying CCW OPERABILITY on an actual or simulated actuation signal. The specific test signal requirement is moved to plant procedures.
The plant procedures and associated controls are not identified.
3.7.5-3 JFD 2 ITS 3.7.5 See Item Number 3.7.3-9 5/30/97 See Item Number Bases and 3.7.3-9 4
JFD 2 Associated Bases l
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CCNPP ITS 3.7.5 COMPONENT COOLING WATER (CCW) SYSTEM t
ITEM DOC / CTS /STS- DESCRIPTION OF ISSUE DATE DATE _CormENTS:
NO.- JFD ^ LCO OPENED: CLOSED- t 3.7.5-4 None ITS SR ITS SR 3.7.5.1 Note states 5/30/97 Provide discussion -
3.7.5.1 isolation of CCW flow'to and justification .
individual components does for this Less not render the CCW System Restrictive change. !
inoperable. This Note is not in the CTS. There is ;
no discussion or ;
justification for !
including this Note in ITS i SR 3.7.5.1.
3.7.5-5 None ITS B3.7.5 ITS B3.7.5 Bases- 5/30/97 Provide additional.
Bases- BACKGROUND states "In the discussion and BACKGROUND event of a CC passive justification to failure during a LOCA, the clarify this CCW Service Water System statement. 'See i provides redundant decay Ites Number 3.7.6-1 heat removal. Based on the and 3.7.7-3.
Bases descriptions (see !
. Item Numbers 3.7.6.1 and !
3.7.7-3) for the Service -
2 Water System and the ,
Saltwater System, it seems that this statement may be j in error.
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_.m_____________.___._________._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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i CCNPP ITS 3.7.6 SERVICE WATER (SRW) SYSTEM ITEM DESCRIPTION OF ISSUE DATE. DATE : CopMENTS-- :
DOC / CTS /STS JFD CLOSED-
~
NO. LCO OPENED ,
3.7.6-1 A.4 STS 3.7.8 STS 3.7.8 RA A.1 5/30/97 See Item Number. -
. JFD 11 RA. A.1 contains a Note 2 which 3.7.5-5. :
, Bases ITS 3.7.6 states " Enter ;
JFD 3 RA A.1 and applicable Conditions ,
Associated and Required actions of 1 Bases LCO 3.4.6 RCS loops i MODE 4," for shutdown -
cooling made inoperable by SWS. ITS 3.7.6 RA i.
A,1 deletes this Note.
As a result of Item Number 3.7.5-5 the deletion of this Note ;
may be in error. :
3.7.6-2 LA.1 CTS CTS 4.7.4.1.b lists the 5/30/97 Licensee to update ,
. 4.7.4.1.b type of test signals the submittal to :
ITS SR (safety injection specify that the SRW ;
3.7.6.2 actuation signal and valves also actuate ;
containment spray to the correct j actuation signal) to position on a ,
ensure that the system containment spray !
- valves actuate to their actuation signal. ;
correct position. ITS SR 3.7.6.2 does not ;
specify the actual i i signals. LA.1 states i that these details have t been relocated to the :
Bases. ITS B3.7.6 does not specify tnat the !
actuation signal )
actuates the valves to i their correct position.
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e CCNPP ITS 3.7.6 SERVICE WATER (SRW) SYSTEM ,
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE~ COMMENTS NO. JFD LCO OPENED CLOSED .
3.7.6-3 JFD 2 ITS 3.7.5 See Item Number 3.7.3-9 5/30/97 See item Number Bases and 3.7.3-9.
JFD 2 Associated Bases 3.7.6-4 None ITS SR ITS SR 3.7.6.I Note 5/30/97 Provide discussion 3.7.6.1 states isolation of SRW and justification for flow to individual this Less Restrictive components may not change, render the SRW inoperable. This Note is not in the CTS.
There is no discussion or justification for including this Note in ITS SR 3.7.6.I.
2
CCNPP ITS 3.7.7 SALTWATER (SW) SYSTEM ,
ITEM DOC / CTS /STS. DESCRIPTION OF ISSUE DATE DATE COPMENTS .
NO. JFD LCO - OPENED CLOSED . :
3.7.7-1 LA-1 CTS CTS 4.7.5.1.b lists the 5/30/97 Licensee to update !-
4.7.5.1.b type of test signal the submittal to ITS SR (safety injection specify that the SW ,
3.7.7.2 actuation signal) to valves actuate to l ensure that the system their correct '
valves actuate to their position on a safety correct position. ITS SR injection actuation 3.7.7.2 does not specify signal, the actual signal. LA.I l states that this detail has been relocated to the l Bases. ITS B3.7.7 does not specify this detail.
3.7.7-2 JFD 12 ITS 3.7.7 See Item Number 3.7.3-9. 5/30/97 See Item Number [
Bases and 3.7.3-9.
- JFD 7 Associated Bases e
(
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- - - - - - - - _ - - - _ _ _ --__._____- - ___ _ - - _ _--___ w u---- _.a-___ ---- -------=-_--__-a-,----_-_-_--------___.__.___-x- -_-- ,--
CCNPP ITS 3.7.7 SALTWATER (SW) SYSTEM 2
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS-NO. JFD LCO OPENED CLOSED ,
3.7.7-3 JFD 12 STS 3.7.8 ITS 3.7.7 uses STS 3.7.8 5/30/97 Provide additional Bases RA A.1 as the basis for this CTS discussion and JFD 7 ITS 3.7.7 requirement. STS 3.7.8 RA justification based RA A.1 and A.1 has two Notes on the system design Associated associated with it. Note or operational Bases I deals with entering LCO constraints to show 3.8.1 when the DG is made that the Notes should inoperable by SWS be deleted. See Item inoperability and Note 2 Numbers 3.7.5-5 and does the same for LCO 3.7.6-1. :
3.4.6 for shutdown cooling. ITS 3.7.7 RA A.1 deletes both these Notes.
- Based on the ITS B3.7.7 Base-BACKGROUND system description as well as the Bases system description for the CCW system and SRW system, these Notes may have to be retained. See Item Numbers 3.7.5-5 and 3.7.6-1.
3.7.7-4 JFD 12 ITS SR ITS SR 3.7.7.1 Note states 5/30/97 Provide discussion 3
Bases 3.7.7.1 isolation of SW flow to and justification for individual components does this less Restrictive JFD 7 and Associated not render the SW change. ,
Bases inoperable. This Note is t not in the CTS. There is no discussion or .
justification for including this Note in ITS SR 3.7.7.1. l t
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CCNPP ITS 3.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) s':
~
ITEM DOC / - CTS /STS- DESCRIPTION OF ISSUE DATE DATE. COMMENTS' NO . . JFD LCO OPENED CLOSED- .
3.7.8-1 M.1 CTS 3.7.6.1 CTS 3.7.6.1 Insert: ACTION- 5/30/97 Correct these ,
JFD 2 Insert: G states for RA G.1 the discrepancies. '
Bases ACTION G following: " Place JFD 2 ITS 3.7.8 OPERABLE CREVS train in j
RA G.1 Control Room Recirculation Mode." M.1 states that ,
the CREVS.in this condition is to be place in the "Entrgency Radiation Fos,tection MODE..." whiie ITS 3.7.8 RA G.1 requires placing the OPERABLE CREVS train :
in recirculation Mode with i the POST-LOCA fans in service.
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CCNPP ITS 3.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
J ITEM DOC / CTS /STS- DESCRIPTION OF ISSUE DATE DATE: ComENTS1 NO. JFD LCO OPENED CLOSED 3.7.8-2 M.1 CTS 3.7.6.1 CTS 3.7.6.1 ACTIONS c, d, 5/30/97 Provide the JFD 3 ACTIONS c, and e specify the remedial appropriate Bases d, and e actiors to be taken when Conditions, ras, JFD 3 ITS 3.7.8 one air intake isolation and Completion Bases ACTIONS valve, one exhaust to Times for the JFD 7 A, B, C, atmosphere isolation specified and D and valve, and one toilet area Conditions or
. Associated exhaust isolation valve provide additional Bases are inoperable in MODES I discussion and through 4, respectively. justification to ITS 3.7.8 ACTION D show why they are-provides the Required not needed based Actions for 2 air intake on current isolation valves, I toilet licensing Basis, area exhaust isolation system design or valve and 2 exhaust to operational atmosphere isolation constraints.
valves inoperable during movement of irradiated fuel assemblies. The CTS and ITS do not provide Conditions, ras and appropriate Completion Times for the following conditions: a. One air intake isolation valve inoperable during movement of irradiated fuel assemblies. b. One exhaust to atmosphere 1 isolation valve inoperable
'during movement of assemblies.
2
CCNPP ITS 3.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) 2 ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE' DATE CotetENTS NO. JFD LCO OPENED CLOSED ,
- c. Two air intake or two exhaust to atmosphere i isolation valves inoperable during MODES 1, 2, 3, or 4. i 3.7.8-3 M.1 ITS 3.7.8 ITS 3.7.8 ACTION D 5/30/97 ITS 3.7.8 ACTIONS JFD 2 ACTION D provides the ras and to be rearranged JFD 3 and completion Times for and/or rewritten Bases Associated inoperable isolation upon resolution of JFD 3 Bases valves during movement of Item 3.7.8-2.
Bases irradiated fuel JFD 7 assemblies. This ACTION is incorrectly place in the sequence of ACTIONS.
It should probably be placed after ITS 3.7.8 ACTION F or G. See Item .
Number 3.7.8-2.
L 3
CCNPP ITS 3.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE~ DATE COMMENTS NO. .JFD' LCO OPENED . CLOSED - ,
3.7.8-4 M.1 CTS ITS B.3.7.8 Bases - RA D.1 5/30/97 Correct this Bases 3.7.6.1.c states the following: discrepancy.
JFD 3 CTS "When two control room 3.7.6.1.d outside air intake CTS isolation valves, the 3.7.6.1.e toilet exhaust isoi tion ITS B3.7.8 valve, or exhaust ;o Bases- atmosphere isolation RA D.1 valves are inoperable...".
This sentence is confusing. It either states that there are two of each type of valve or two intake valves, one toilet area valve and an indeterminate number of exhaust to atmosphere valves. CTS 3.7.6.1 c, d, and e, and ITS 3.7.8 Condition D specify the appropriate number of valves as two, one and two respectively.
4 4
CCNPP ITS 3.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
ITEM' DOC / CTS /STS1 DES'CRIPTION OF ISSUE- DATE DATE: . ColmENTS?
NO. JFD LCO OPENED CLOSED ,
3.7.8-5 LA.1 CTS CTS 3.7.6.1.a. 3.7.6.1.c, 5/30/97 Provide these 3.7.6.1.a
~
3.7.6.1.d, and 3.7.6.1.e details in either CTS requires the CREVS to be ITS B3.7.8 BASES-3.7.6.1.c OPERABLE with two filter BACKGROUND or ITS CTS trains, two isolation B3.7.8 BASES-LCO.
3.7.6.1.d valves in each control . i CTS room outside air intake 3.7.6.1.e duct, two isolation valves in the common exhaust to atmosphere duct, and one isolation valve in the i toilet area exhaust duct.
These details-are not
.specified in ITS 3.7.8, but are to be relocated to i the Bases. The details on i the isolation valves have 1
not been moved to the Bases. ITS B3.7.8 Bases-
- BACKGROUND and ITS B3.7.8 [-
Bases-LCO which describe i the components of an OPERABLE CREVS system do ,
not contain these details.
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CCNPP ITS 3.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS)
ITEM DOC /l CTS /STS DESCRIPTION OF ISSUE;. DATE DATE'. ColmENTS' NO.- JFD ~ LCO - OPENED CLOSED 2 3.7.8-6 LA.2 CTS CTS 4.7.6.1.e.2 requires 5/30/97 Define CRRS in ITS i 4.7.6.1.e.2 LA.3 that the CREVS B3.7.8 BASES--
Bases ITS B3.7.8 automatically switches BACKGROUND, and JFD 2 Bases- into a recirculation mode provide additional BACKGROUND of operation and the discussion and !
isolation valves close on justification to i a control room high show that this is radiation signal. ITS SR the Control Room 3.7.8.3 does not contain high radiation !
this detail. These signal specified !
details will be moved to in CTS ;
the ITS B3.7.8 BASES. ITS 4.7.6.1.e.2.
B3.7.8 does not seem to l have this infomation. i ITS B3.7.8 BASES- !
BACKGROUND states that !
"The CRRS initiates pressurization and ;
filtered ventilation of the air supply.to the control room. CRRS is an undefined term, which may be the radiation signal. ,
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CCNPP ITS 3.7.8 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) ,f
.I . .
ITEM; DOC /L CTS /STS DESCRIPTION OF ISSUE DATE. DATEL COMNENTS. t NO. JFD LCO - OPENED- CLOSED ~ .,
3.7.8-7 JFD 1 CTS CTS 4.7.6.1.e.2 requires 5/30/97 Delete this BASES 4.7.6.1.e.2 the verification that on a change. j JFD 1 ITS SR control room high '
3.7.8.3 and radiation signal the '
Associated system automatically Bases switches into a i recirculation mode of i operation. This surveillance is done on an 18-month frequency. ITS l SR 3.7.8.3 performs the !'
same verification except that it is done on a 24- t month frequency. The 1 change from 18-months to :
24-months is' justified using a generalized justification (JFD 1/ BASES ;
JFD 1) that incorporates .
CCNPP-specific information i into the bracketed t i
information. The justification used is i wrong. The change in l frequency is unacceptable, I i and is beyond the scope of ;
review for this !
conversion.
3.7.8-8 JFD 2 ITS 3.7.8 See Item Number 3.7.3-9. 5/30/97 See Item Number BASES and 3.7.3-9. I JFD 2 Associated Bases i
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CCMPP ITS 3.7.8 CONTROL ROON ENERGENCY VENTILATION SYSTEN (CREVS)- ,t L
ITEN DOC / CTS /STS 3ESCRIPTION OF--ISSUE.
DATE- DATE: .COPMENTS ;
NO .- JFD LCO OPENED CLOSED' .
3.7.8-9 BASES STS B3.7.11 STS B3.7.ll Bases-SR 5/30/97 Reinsert the STS JFD 13 Bases- 3.7.11.2 states that statement and i SR 3.7.11.2 '"The. . . filter tests are in Reference to RG l ITS B3.7.8 accordance with Regulatory 1.52~in the !
Bases Guide (RG).1.52) (Ref.3) ." appropriate place i
.SR 3.7.8.2 ITS B3.7.8 Bases-SR in ITS B3.7.X- !
ITS B3.7.8 3.7.8.2 deletes this Bases SR 3.7.X.2 Bases- statement and Ref. 3 from and ITS B3.7.X REFERENCES ITS B3.7.8 Bases-REFERENCE Bases-REFERENCES. l
- Section. The Bases for I this deletion is that it !
was performed to ensure ;
that the REFERENCES are !
applicable to CCNPP, and !
that not all the filter testing is in accordance !
with RG. 1.52. ITS 5.5.11 i states that the VFTP test !
shall be done in i accordance with R.G. 1.52, [
Rev. 2. Therefore, the ;
justification Bases JFD 13 !
is wrong, and the STS i statement and Reference 3 l should be reinserted into }
ITS B3.7.8 Bases SR :
3.7.8.2 and ITS B3.7.8 Bases-REFERENCES, !
respectively. ,
Furthermore, the staff would consider this change !
as a generic change. i A
e
CCNPP ITS 3.7.9 CONTROL ROOM EMERGENCY TEMPERATURE SYSTEM (CRETS)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE C0mlEhaS NO. JFD LCO OPENED . CLOSED .
3.7.9-1 M.1 CTS 3.7.6.1 CTS 3.7.6.1 Insert ACTION 5/30/97 Correct this Insert C states the following for discrepancy.
ACTION C Condition C: " Required ITS 3.7.9 Action and associated 4 Condition C Completion Time of Condition A not met in MODE 1, 2, 3 or 4." ITS 3.7.9 Condition C states the following " Required Action and associated i Completion Time of Condition A not met during movement of irradiated !
fuel assemblies." M.1 and
l 1
CCNPP ITS 3.7.9 CONTROL ROOM EMERGENCY TEMPERATURE SYSTEM (CRETS)
~
ITEM DOCf CTS /STS DESCRIPTION OF ISSUE DATE: DATE' . COMMENTSL NO. JFD LCO OPENED. CLOSED- .
3.7.9-2 LA.2 CTS CTS 4.7.6.1.a requires the 5/30/97 Provide the plant 4.7.6.1.a backup Control Room air procedures to which ITS SR conditioners de-energized the information is 3.7.9.1 prior to verifying that moved and the.
the emergency Control Room procedure change air conditioners can control maintain Control Room temperature in the recirculation mode of operation. ITS SR 3.7.9.1 requires verifying each CRETS train has the capability to maintain 3
control room temperature within limits every 24 months. The specifics on how to conduct the i Surveillance Requirement are moved to plant procedures. The plant procedures and associated controls are not identified.
3.7.9-3 LA.3 CTS 3.7.E.1 LA.3 adorasses changes to 5/30/97 Delete LA.3 from ITS ITS 3.7.8 and thus is not 3.7.9 justifications.
applicable to ITS 3.7.9.
i 2
_ _.__u.________________. -_ ___________.____m_ ____ __ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . - --- ___-__._m
___e e__m u- _________.er
-ew ___ - _ - _ --ww __ _ _ _ _ _ _ _ _ m________a
CCMPP ITS 3.7.9 CONTROL ROOM EMERGENCY TEMPERATURE SYSTEM (CRETS)
ITEM DOC / CTS /STS DESCRIPTIDN OF ISSUE DATE DATE COMMENTS NO .- JFD LCO OPENED CLOSED.
3.7.9-4 L.2 CTS CTS 4.7.6.1.a requires 5/30/97 Delete this change.
JFD 1 4.7.6.1.a maintaining CRETS Control Bases ITS Room temperature within JFD 1 SR 3.7.9.1 limits once per 62 days on and a STAGGERED TEST BASIS.
Associated ITS SR 3.7.9.1 requires Bases verifying each CRETS train has the capability to maintain control room temperature within limits every 24 months. The change 62 days on a STAGGERED TEST BASIS to 24 months is justified using a generalized justification (JFD 1/ Bases JFD 1) that incorporated CCNPP-specific information into the bracketed information. The justifications used are wrong and the change in frequency is unacceptable, and is beyond the scope of review for this conversion.
3.7.9-5 JFD 2 ITS 3.7.9 See Item Number 3.7.3-9. 5/30/97 See Item Number 3.7.3-Bases and 9.
JFD 2 Associated Bases 3
_ - = . . . . - - _
. . = - _ . . . . _ -.
o CCNPP ITS 3.7.10 EMERGENCY CORE COOLING SYSTEM (ECCS) PUMP ROOM EXHAUST FILT"ATION SYSTEM (PREFS)
>r ITEM DOC /: CTS /STS- DESCRIPTION OF ISSUE' .I DATE DATE. CONTENTS' NO. JFD LCO OPENED CLOSED ,
3.7.10-1 LA.1 CTS CTS 3.7.7.1 requires the 5/30/97 Revise ITS 3.7.10 LA.2 3.7.7.1 ECCS Pump Room Exhaust ACTIONS, ITS SR L.1 CTS Ventilation System 3.7.10.1 and JFD 1 3.7.7.1 OPERABLE with one HEPA Associated Bases to JFD 4 ACTION a filter and charcoal require that both CTS adsorber train, and two ECCS PREFS fans to be 4.7.7.1.a exhaust fans. CTS 3.7.7.1 OPERABLE.
ITS LCO ACTION a, requires with 3.7.10 one ECCS pump room exhaust ITS 3.7.10 fan inoperable, restore ,
ACTIONS the inoperable fan to i ITS SR OPERABLE within 7 days.
3.7.10.1 CTS 4.7.7.1.a requires at and least once per 31 days, by Associated initiating, from the Bases control room flow through '
. the HEPA filter and charcoal adsorber train -
and verifying that each i exhaust fan operates for at least 15 minutes. ITS LCO 3.7.10 does not address how many exhaust fans make up an ECCS PREFS .
train, but ITS B3.7.10 t
Bases-BACKGROUND states that ECCS PREFS consists of one train with two i independent and redundant .
fans. ITS B3.7.10 Bases-LCO states that one train 1
CCNPP ITS 3.7.10 EMERGENCY CORE COOLING SYSTEM (ECCS) PUMP ROOM EXHAUST FILTRATION SYSTEM (PREFS) s ITEM I DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED' CLOSED ~ ,
shall be OPERABLE and only one fan is required
. OPERABLE, instead of one train and two fans are required OPERABLE. ITS 3.7.10 does not retain the ACTION when one exhaust fan is inoperable, and ITS :
SR 3.7.10.1 does not require operation of both '
fans. The proposed change i would allow indefinite operation of the ECCS PREFS with one fan inoperable. This is not in accordance with current licensing basis and is unacceptable to the staff. -
There is inadequate justification for removing the CTS requirement for two fans OPERABLE. This ,
change is considered a beyond scope of review for this conversion.
t L
2
CCNPP ITS 3.7.10 EMERGENCY CORE COOLING SYSTEM (ECCS) PUMP ROOM EXHAUST FILTRATION SYSTEM (PREFS)
ITLM DOC / CTS /STS- DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED CLOSED ,
3.7.10-2 JFD 1 STS SR STS SR 3.7.13.5 verifies 5/30/97 Either include STS SR Bases 3.7.13.5 that each ECCS PREFS 3.7.13.5 in the ITS JFD 7 ITS filter bypass damper can or provide additional B3.7.10 be opened. ITS B3.7.10 discussion and Bases- Bases-BACKGROUND states justification based BACKGROUND during emergency on current licensing operations the ECCS PREFS basis, system design dampers are realigned to or operational initiate filtration. STS constraints to SR 3.7.13.5 is deleted justify the deletion from ITS 3.7.10 based on a of STS SR 3.7.13.5.
general justification on items not consistent with the CCNPP design. The justifications in this case are the wrong justification since the design does include bypass dampers.
3.7.10-3 JFD 2 ITS 3.7.10 See Item Number 3.7.3-9. 5/30/97 See Item Number Bases and 3.7.3-9.
JFD 2 Associated Bases.
L l
3 4
CCNPP ITS 3.7.10 EMERGENCY CORE COOLING SYSTEM (ECCS) PUMP ROOM EXHAUST FILTRATION SYSTEM (PREFS)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMENTS NO. JFD LCO OPENED CLOSED .
3.7.10-4 Bases STS STS B3.7.13 Bases- 5/30/97 Provide additional JFD 11 B3.7.13 REFERENCES lists Reference discussion and Bases- 4 " Regulatory Guide 1.52 justification for the REFERENCES Rev. 2" and Reference 6 deletion of these ITS "NUREG-0800 Section 6.5.1, references. See Item B3.7.10 Rev. 2, July 1981"." ITS Numbers 3.7.8-9 and Bases- B3.7.10 Bases-REFERENCES ' 3. 7.10-5.
REFERENCES deletes these two references. The justification (Bases JFD
- 11) used to delete the references applies only to
See Item Numbers 3.7.8-9 and 3.7.10-5.
3.7.10-5 Bases STS See Item Number 3.7.8-9 5/30/97 See Item Number JFD 13 B3.7.13 3.7.8-9.
Bases Bases -
JFD 11 SR 3.7.13.2 ITS B3.7.10 Bases '
ITS B3.7.10 Bases REFERENCES L
r.
I i
4
CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILATION SYSTEM (SFPEVS)
ITEM' DOC / CTS /STS . DESCRIPTION OF ISSUE' DATE: DATE:. C0fmENTS v NO. JFD LCO OPENED CLOSED - .
3.7.11-1 LA.1 CTS 3.9.12 CTS 3.9.12 requires 5/30/97 Revise ITS 3.7.11 LA.3 CTS 3.9.12 SFPEVS OPERABLE with one ACTIONS, ITS SR i L.1 ACTION a HEPA filter bank, two 3.7.11.1, ITS SR !
JFD 3 CTS charcoal adsorbers, and 3.7.11.3 and .
JFD 16 4.9.12.a two exhaust fans. CTS Associated Bases to ;
Bases CTS 3.9.12 ACTION a, requires require both SFPEVS JFD 3 4.9.12.d.2 with one charcoal fans and charcoal ITS LCO adsorber bank or one adsorber banks to !
3.7.1. exhaust fan inoperable be OPERABLE. !
ITS 3.7.11 fuel movement may proceed l ACTIONS provided an OPERABLE l ITS SR exhaust fan is'in f
Bases requires at least once i per 31 days. by initiating flow through I the HEPA filter bank and ;
both charcoal adsorber banks and verifying that ,
each charcoal adsorber l bank and each exhaust fan i operates for at least 15 i minuets. CTS 4.9.12.d.2 ;
verifies that each i exhaust fan maintains the ;
spent fuel storage pool "
area at a measurable negative pressure +
relative to the outside i atmosphere i f
1 1
-. _ _ _ . . _ _ _ . . _ _ _ _ _ _ _ _ _ _ . . . . _ . _ . _ . _ _ _ . _ _ _ .-___m -_....___._ _ ___ _ _ _ _ ._ _ _____.__ _ m ..__,_,..._.,,.-4 ._.,m.._,._, . . - , y .~.._.__.___m ..m..m.., ,
O CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILATION SYSTEM (SFPEVS)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE' COMMENTS NO. JFD LCO OPENED CLOSED during system operation on an 18 month frequency.
ITS LCO 3.7.11 does not address how many exhaust fans or charcoal adsober banks make up an SFPEVS train, but ITS B3.7.ll Bases-BACKGROUND states that SFPEVS consists of one train with two independent and redundant fans, one cha coal adsorber section. ITS B3.7.11 Bases-LCO states that one train shall be OPERABLE and only one fan '
and one charcoal adsorber ,
section are required OPERABLE instead of one train with two fans and two charcoal adsorber banks are required OPERABLE. ITS 3.7.11 !
does not retain the ACTION if one exhaust fan or one charcoal adsorber bank is inoperable. ITS SR 3.7.11.1 does not ,
require operation of both fans and both charcoal adsorber banks. ITS SR l 3.7.11.3 does not require operation of both fans. ;
The proposed proposed change would allow indefinite operation of the SFPEVS with one fan :
2
i
- i CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILATION SYSTEM (SFPEVS) -l m
ITEM DOC / -CTS /STS DESCRIPTION'0Fl ISSUE' DATE- DATE COMMENTS: ,
NO. JFD' LCO OPENED CLOSED i and/or one charcoal adsorber bank inoperable.
This is not in accordance with current licensing i basis and is unacceptable ;
to the staff. There is i inadequate justification j for removing these CTS !
requirements and the !
change is considered a 'I beyond scope of review for this conversion. t 3.7.11-2 LA.2 CTS 3.9.12 CTS 3.9.12 ACTION b 5/30/97 Provide the plant ;
ACTION b. requires suspending all procedures to which operations involving the information is '
movement of fuel or crane moved and the i operation with loads over procedure change i
- the storage pool. ITS control.
, 3.7.11 does not retain the crane operation (;
requirement. The heavy load (crane) requirements are moved to plant !
procedures. The specific plant procedure is not {
identified nor how j changes to these ,
procedures are controlled t by the plant change _
i control process. i j l
I 3 !
l
CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILATION SYSTEM (SFPEVS) w ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE C0t9 TENTS NO. 'JFD LCO OPENED CLOSED 3.7.11-3 LA.3 CTS CTS 4.9.12.a requires the 5/30/97 Correct the Bases 4.9.12.a SFPEVS be initiated with to show this ITS SR flow through the HEPA requirement. See 3.7.11.1 filter and both charcoal Item Number 3.7.11-adsorbers. ITS SR 1.
3.7.11.1 does not retain this requirement. This requirement will be moved ,
to the Bases. The Bases does not contain this requirement. See Item Number 3.7.11-1.
t b
b l'
4
_ _ - . _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - - _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ - - _ _ = _ _ -_. -
CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILATION SYSTEM (SFPEVS)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE . COMMENTS NO. JFD LCO OPENED CLOSED' .
3.7.11-4 L.3 CTS CTS Surveillance 5/30/97 Delete this change.
JFD 1 4.9.12.d.2 4.9.12.d.2 requires Bases ITS SR maintaining the SFPEVS JFD 1 3.7.11.3 measurable negative and pressure relative to the Associated outside atmosphere once Bases per 18 months. ITS SR 3.7.11.3 requires maintaining the SFPEVS measurable negative pressure relative to the outside atmosphere once per 24 months. The change from 18 months to 24 months is justified based on operating history (L.3) and using a generalized justification (JF0 1/ Bases JFD 1) that incorporates CCNPP-specific information into the bracketed information. The latter justification used is wrong. The change in frequency is unacceptable and is beyond the scope of review for this conversion.
5
CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILATION SYSTEM (SFPEVS)
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMEN1N NO. JFD LCO OPENED CLOSED ,
3.7.11-5 JFD 1 STS SR STS SR 3.7.14.5 verifies 5/30/97 Either include STS Bases 3.7.14.5 that each FBACS filter SR 3.7.14.5 in the JFD 1 ITS bypass damper can be ITS or provide B3.7.11 opened. ITS B3.7.10 additional Bases - Bases-BACKGROUND states discussion and BACKGROUND that during normal justification based operation the charcoal on current adsorbers are bypassed licensing basis, and it is implied that system design, or ,
during emergency operational ,
operation the SFPEVS constraints to dampers are realigned to justify the initiate filtration. STS deletion of STS SR SR 3.7.14.5 is deleted 3.7.14.5.
from ITS 3.7.11 based on a general justification on items not consistent with the CCNPP design.
The justification in this case are the wrong justifications since the design does include bypass dampers.
3.7.11-6 JFD 2 ITS 3.7.11 See Item Number 3.7.3-9 5/30/97 See Item Number i Bases and 3.7.3-9.
JFD 2 Associated Bases 3.7.11-7 Bases STS See Item Numbers 3.7.8-9, 5/30/97 See Item Numbers JFD 11 83.7.14 3.7.10-4, and 3.7.11-8. 3.7.8-9, 3.7.10-4 Bases and 3.7.11-8.
REFERENCES ITS B3.7.10 Bases !
REFERENCES 6
- O CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILATION SYSTEM (SFPEVS)
~.
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMENTS -
NO. JFD LCO OPENED CLOSED 3.7.11-8 Bases STS See Item Number 3.7.8-9. 5/30/97 See-Item Number JFD 13 B3.7.14 3.7.8-9.
Bases Bases JFD 13 SR 3.7.14.2 ITS B3.7.11 Bases SR 3.7.11.2 ITS B3.7.11 Bases REFERENCES 7
l
I CCNPP ITS 3.7.11 SPENT FUEL POOL EXHAUST VENTILf~ ION SYSTEM (SFPEVS) e i DATE DATE COMMENTS ITEM DOC / CTS /STS DESCRIPTION OF ISSUE OPENED CLOSED ,
NO. JFD LCO CTS 3.9.12 ACTION b 5/30/97 Provide a 3.7.11-9 None CTS 3.9.12 discussion and ACTION b requires suspending all justification for ITS 3.7.11 operations involving the changed CTS ACTION A movement of fuel within the storage pool when the requirenent.
HEPA filter bank is inoperable, or with two charcoal adsorber banks inoperable, or with two exhaust fras inoperable. ,
ITS 3.7.11 ACTION A requires immediately suspending movement of irradiated fuel assemblies in the auxiliary building when SFPEVS is inoperable.
Components of the SFPEVS could be inoperable in the CTS and the whole system is inoperable in the ITS. There is no discussion or justification for removing the CTS ACTION requirements.
8 N
CCNPP ITS 3.7.12 PENETRATION ROOM EXHAUST VENTILATION SYSTEM (PREVS) w ITEM- DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE C(FMENTS NO. JFD- LCO OPENED CLOSED. ,
3.7.12-1 LA.1 CTS CTS 4.6.6.1.a describes 5/30/97 Include this 4.6.6.1.a the manner in which this information in ITS ITS SR surveillance demonstrated B3.7.12 Bases.
3.7.12.1 and the flow for the PREVS to Associated be OPERABLE. The special Bases manner in which the test is performed is not included ITS SR 3.7.12.1 but is relocated to the Bases. This information is not included in ITS B3.7.12 Bases.
I
_ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ = _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
CCNPP ITS 3.7.12 PENETRATION ROOM EXHAUST VENTILATION SYSTEM (PREVS)
~
\
ITEM DOC / CTS /STS DESCRIPTION OF ISS!)E DATE DATE- COMMENTS NO. JFD LCO OPENED CLOSED ,
3.7.12-2 JFD 1 CTS CTS 4.6.6.1.d.2 requires 5/30/97 Delete this change.
Bases 4.6.6.1.d.2 verifying at least once JFD 1 ITS SR per 18 months that PREVS 3.7.12.3 starts on a Containment ITS Isolation Test signal.
B3.7.12 ITS SR 3.7.12.3 requires Bases verifying that each PREVS SR 3.7.12.3 trains actuates on an actual or simulated actuation signal once per 24 months. The change from 18 ronths to 24 months is justified in the ITS Based on a generalized justification (JFDl/ Bases JFD 1) that incorporates CCNPP-specific information into the bracketed information. This justification is wrong.
In addition, the CTS markup does not show this change or provide a
. justification for it.
The change in frequency is unacceptable and is beyond the scope of .
review for this conversion.
2
4 CCNPP ITS 3.7.12 PENETRATION ROOM EXHAUST VENTILATION SYSTEM (PREVS)
ITEM DOC /~ CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD- LEO OPENED CLOSED ,
3.7.12-3 JFD 1 STS SR STS SR 3.7.15.5 verifies 5/30/97 Either include STS Bases 3.7.15.5 that each PREACS filter SR 3.7.15.5 in the JFD 1 ITS B3.7.12 bypass damper can be ITS or provide Bases- opened. ITS B3.7.12 additional BACKGROUND Bases-BACKGROUND states discussion and that "During emergency justification based operations, the PREVS on current licensing dampers are realigned..." basis, system design STS SR 3.7.14.5 is or operational deleted from ITS 3.7.12 constraints to based on a general justify the deletion justification on items of STS SR 3.7.15.5.
+
not consistent with the CCNPP design. The justifications in this case are the wrong justifications, since the design does include bypass dampers.
3.7.12-4 JFD 2 ITS 3.7.12 See Item Number 3.7.3-9 5/30/97 See Item Number Bases and Associated 3.7.3-9 JFD 2 Bases 3
CCNPP ITS 3.7.12 PENETRATION ROOM EXHAUST VENTILATION SYSTEM (PREVS) 2 r
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE C0t1MENTS ~
NO. JFD LCO OPENED CLOSED ,
3.7.12-5 JFD 3 CTS 3.6.6.1 CTS 3.6.6.1 ACTION 5/30/97 Provide discussion Bases ACTION requires restoring PREVS and justification JFD 3 STS 3.7.15 to OPERABLE status within for changing the CTS RA B.2 7 days or be in at least required shutdown ITS 3.7.12 HOT STANDBY within 6 from COLD SHUTDOWN RA B.2 and hours and COLD SHUTDOWN (MODE 5) to MODE 4.
Associated within the following 30 Provide Bases hours. Under the same justification for condition ITS 3.7.12 RA the STS deviation B.2 requires being in based on current MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and licensing basis, MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. STS system design, or 3.7.15 RA B.2 requires operational being in MODE 3 in 6 constraints.
hours and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. There is no discussion or justification for changing the CTS shutdown requirement from COLD SHUTDOWN to MODE 4 in ITS 3.7.12 RA B.2. n e change results in a STS deviation which could be considered as a generic change.
3.7.12-6 Bases STS B3.7.15 See Item Number 3.7.8-9 5/30/97 See Item Number JFD 13 Bases 3.7.8-9 3.7.15.2 ITS B3.7.12 Bases I SR 3.7.12.2 ,
4 i
a CCNPP ITS 3.7.12 PENETRATION ROOM EXHAUST VENTILATION SYSTEM (PREVS) 3 ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO. JFD LCO OPENED CLOSED 3.7.12-7 None CTS 4.6.6.1.a CTS 4.6.6.1.a requires S/30/97 Provide discussion ITS SR the PREVS be demonstrated and justification 3.7.12.1 OPERABLE at least once for this and Associated per 31 days on a Administrative Bases STAGGEP.ED TEST BASIS. change which changed ITS SR 3.7.12.1 requires CTS Frequency operating each PREVS requirement.
train for 2 15 minutes every 31 days. There is no discussion or justification for this Administrative change of removing the CTS requirement to demonstrate PREVS OPERABLE on a STAGGERED TEST BASIS.
S
O CCNPP ITS 3.7.13 SPENT FUEL POOL (SFP) WATER LEVEL 3
ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COP 91ENTS NO JFD LCO OPENED CLOSED 3.7.13-1 LA.] CTS 3.9.11 CTS 3.9.11 ACTIONS 5/30/97 Provide the Actions require crane operations plant with loads in the fuel procedures to storage areas to be which the suspended when the spend infomation is fuel level is not within moved and the limits. ITS 3.7.13 does procedure not contain this change control.
requirement. This requirement will be moved to plant procedures. The plant procedures and associated controls are not identified.
3.7.13-2 JFD 2 ITS 3.7.13 See Item Number 3.7.3-9 5/30/97 See Item Number Bases and 3.7.3-9 JFD 2 Associated Bases 3.7.13-3 Bases ITS B3.7.13 ITS B3.7.13 Bases- 5/30/97 Correct this JFD 2 Bases APPLICABILITY, ITS discrepancy.
APPLICABILITY B3.7.13 Bases-ACTIONS, ITS B3.7.13 and ITS B3.7.13 Bases-SR Bases- 3.7.13.1 do not show any ACTIONS changes. However they ITS B3.7.13 have a Bases JFD 2 Bases associated with them.
i 1
_ _ _ _ = _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ - - - - _ _ - _ . _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ - _ - _ _ _ _ _ _ _ - _ - - _ - _ _ _ _ _ __. . . .
4 CCNPP ITS 3.7.13 SPENT FUEL POOL (SFP) WATER LEVEL h
EM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS NO JFD LCO OPENED CLOSED 3.7.13-4 None CTS 3.9.11 CTS 3.9.11 requires a 5/30/97 Licensee to STS LCO minimum of 21 1/2 feet of delete this 3.7.16 water be maintained over change.
ITS LCO the top of irradiated 3.7.13 fuel assemblies seated in the storage racks. STS LCO 3.7.16 requires SFP water level shall be 2[23] ft over the top of irradiated fuel assemblies seated in the storage racks. ITS LCO 3.7.13 changes the STS requirement to "The SFP water level is within limits." This change is designated CE0G-116 in the ITS markup. It is the staff's understanding that this change has been withdrawn from the generic review process.
2
CCNPP ITS 3.7.14 SECONDARY SPECIFIC ACTIVITY ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE NO. JFD LCO OPENED CLOSED 3.7.14-1 LA.1 CTS Table CTS Table 4.7-2 contains 5/30/97 Provide the plant 4.7-2 a requirement to do a procedures to which ITS 3.7.14 gross activity the information is determination at least moved and the once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. ITS procedure change 3.7.14 does not contain control this requirement. The requirement for the gross activity is moved to plant procedures. The specific plant procedure is not identified nor how ,
changes to these procedures are controlled by the plant change control process.
3.7.14-2 JFD 2 ITS 3.7.14 See Item Number 3.7.3-9 5/30/97 See Item Number Bases and 3.7.3-9.
JFD 2 Associated Bases I
t I
__ _-. . - - __ _ ___