ML20141B944

Forwards Response to 970507 RAI Re LAR to Convert to Improved TS Section 5.0 for Administrative Controls

ML20141B944
Person / Time
Site:	Calvert Cliffs
Issue date:	06/18/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-M97363, TAC-M97364, NUDOCS 9706240210
Download: ML20141B944 (20)

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. i CHARI.ES II. CRtJSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 l

June 18,1997 1 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information Regarding the License Amendment Request to Convert to the Improved Technical Specifications LTAC Nos. M97363 and M97364)

REFERENCE:

(a) Letter from Mr. A. W. Dromerick (NRC) to Mr. C. H. Cruse (BGE),

dated May 7,1997, Request for Additional Information Regarding the License Amendment Request to Convert to the Improved Technical Specifications (TAC Nos. M97363 and M97364)

The referenced letter transmitted questions regarding Sections 4.0 and 5.0 of Baltimore Gas and Electric Company's application to convert to the Improved Standard Technical Specifications. The responses are attached. Changes to the application described in the responses will be reflected in a future revision to the application. If the revision contains changes which differ from these responses, those differences will be identified.

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. Doctiment Control Desk June 18,1997 Page 2

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Should you have further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

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STATE OF MARYLAND  :

TO WIT: I q COUNTY OF CALVERT  :

I, Charles H. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this response on behalf

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of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

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Sy'4LfLM)bscribed f and

, thissworn

/(LUdaybefore me, a Notary of &vho) Public in and for the State of Maryland and

,1997.

h WITNESS my Hand and Notarial Seal: [ LtuA> J b ')ML L >

Notary Public My Commission Expires: b '

!9 Ciate CHC/JV/dtm Attachments: (1) Response to Questions, Calvert Cliffs Improved Technical Specification Section 4.0 (2) Response to Questions, Calvert Cliffs improved Technical Specification Section 5.0 cc: R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC A. W. Dromerick, NRC R.1. McLean, DNR Director, Project Directorate 1-1, NRC J. H. Walter, PSC

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! ATTACHMENT (1) l l

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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION i CALVERT CLIFFS NUCLEAR POWER PLANT l

i IMPROVED TECHNICAL SPECIFICATIONS i

SECTION 4.0 DESIGN FEATURES i

Baltimore Gas and Electric Company June 18,1997

ATTACHMENT (1) .

CCNPP ITS 4.0 DESIGN FEATURES .

4.0 DOC JFD' .' CHANGE / DIFFERENCE .COMMENTE STATUS  ;

1: 2 STS 4.2.2 includes details specifying the control element Provide . additional f discussion and j

' assembly control material. lTSl4.2.2 deletes this' detail, justificatN>n for the STS deviation, based on  !

resulting in an STSldeviabon Adequate justification is not system design, operabonalLconstraints, or provided for the deviation current licensing basis l BGE Response.

On March 14,1995, the Nuclear Regulatory Commission approved an amendment to the Calvert Cliffs Technical Specifications which adopted  !

Design Features that were generally consistent with the format and content of the improved Standard Technical Specifications for Combustion  !

Engineering plants, NUREG-1432, Revision 1. In our December 8,1993 and March 2,1995 letters requesting the amendment, we justified not  !

l including the control element assembly (CEA) materials in the Design Features, as the CEA materials were not in our Technical Specifications i prior to this amendment. The Nuclear Regulatory Commission accepted this,' and the issued amendment did not include the CEA materials. In I the improved Technical Specifications conversion submittal, Baltimore Gas and Electric Company has retained our current Design Features requirements, with only editorial changes. As we stated in the Discussion of Deviation 2, this information is contained in the Updated Final  !

Safety Analysis Report and controlled under 10 CFR 50.59, which is an adequate method of controlling this information.  :

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ATTACHMENT (2)

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4 j-RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION CALVERT CLIFFS NUCLEAR POWER PLANT IMPROVED TECHNICAL, SPECIFICATIONS l SECTION 5.0 ADMINISTRATIVE CONTROLS I

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Baltimore Gas and Electric Company June 18,1997

ATTACHTENT (2) -

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

5.0 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS - .

1 A.5 CTS 6.2.1.a requires plant specific titles of personnel Acceptance of this change to CTS 5/5/97 TSTF-65 still fulfilling the responsibilities of the positions delineated in requirements is based on the NRC pending. -

the CTS documented in the Updated Final Safety Analysis acceptance of TSTF45.

Report (UFSAR). ITS 5.2.1.a is consistent with the CTS but also allows this information to be documented in the QA plan. This change to CTS requirements is based on TSTF-65.

BGE Response:

Baltimore Gas and Electric Company (BGE) has na action. We are awaiting Nuclear Regulatory Commission (NRC) approval of TSTF-65. TSTF45 was based on a letter from C.1. Grimes (NRC) to i_ee Bush (WOG), Brian Mann (CEOG), Clinton Szabo (B&WOG) and Andrew Maron (BWROG), dated November 10,1994, that recommended changes to the Administrative Controis section of the Technical Specifications.

2 A.27 CTS 6.2.2.b requires at least one licensed operator in the Acceptance of this change to CTS 5/5/97 TSTF-121 Ceritrol room when fuel is in the reactor and two licensed requirements is based on the NRC modified, not yet operators present in the Control room during reactor acceptance of TSTF-121. approved.

STARTUP, scheduled reactor shutdown, and during trip recovery. ITS 5.0 does not include this requirement. This deletion of CTS requirements is based on TSTF-121.

BGE Response:

On April 9,1997, in a letter from C.1. Grimes (Chief, Technical Specifications Branch, NRC) to James Davis (Nuclear Energy institute), the NRC proposed several generic changes to the Administrative Controls. One of those changes recommended by the NRC is identical to the changes recommended in TSTF-121. Specific approval of TSTF-121 may be included as part of the change generated from the referenced letter.

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS -

i5.0 ~ -DOC 1JFD' > CHANGE / DIFFERENCE.  ! COMMENT! LSTATUS? ,

i 2.a A.3 CTS 6.2.2d states that an individual qualified in radiation Acceptance of this change to the 5/5/97 TSTF-65 still ~ '

protection procedures shall be on site when fuel is in the CTS requirements is based on the pending. -

mactor. The ITS changes this position to a radiation NRC acceptance of TSTF-65.

r,.otection technician. The changes to the CTS .

requirements is based on TSTF-65 i

BGE Response:  !

Baltimore Gas and Electric Company has no action. We are awaiting NRC approval of TSTF-65. TSTF-65 was based on a letter from C. l. Grimes (NRC) to Lee Bush (WOG), Brian Mann (CEOG), Clinton Szabo (B&WOG) and Andrew Maron (BWROG), dated November 10,1994, that recommended ,

changes to the Administrative Controls section of the Technical Specifications.  !

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3 STS 5 2.2.f requires the [ operation manager or assistant F.avide justification for the STS operaticos manager] to hold an SRO license. ITS 5.2.2.f deviation based on current requires the operation manager to hold or have held an licensing basis, system design, or i SRO licensa at CCNPP. There is no discussion or operational constraints.

justification for this deviation from the STS requirement.

BGE Response:

The justification for this change is given in Section 5.0, Discussion of Deviation 1. The improved Standard Technical Specification (ISTS) Section 5.2.2.f states, "The [ Operations Manager or Assistant Operations Manager] shall hold an SRO license." The justification given was, This change incorporates

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the Calvert Cliffs-specific information into brackets." A Discussion of Deviation will be added to explain the specific qualifications for the operations l manager at Calvert Cliffs, and Discussion of Deviation 1 will be used to explain the change in title inside the brackets of Standard Technical Specification ,

(STS) 5.2.2.f.

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ATTACH;ENT (2)

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS 5.0 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 4 5 STS 5.2.2.g lists the Shift Technical Advisor (STA) Provide justification for the STS requirements. ITS 5.2.2.g replaces the requirements deviation based on current -

entirely with a different list of STA requirements. There is licensing basis, system design, or inadequate justification for the deviation from the STS operational constraints.

requirements for STAS.

BGE Response:

Proposed improved Technical Specification (8TS) Secticn 5.2.2.g contains the Calvert Cliffs Shift Technical Advisor (STA) requirements contained in current Technical Specifications 6.2.2.g. and S.'s.1. The combination of these two sections (manning and training requirements) are shown in the current Technical Specification (CTS) markup, page 3 of 61. As stated in Section 5.0, Discussion of Deviation 5, these changes are consistent with the Calvert Cliffs current licensing basis. The license amendment numbers approving these requirements (216 Unit 1,193 Unit 2) will be added to Discussion of Deviation 5.

5 LA.3 CTS 6.5.1.c.2 requires +anges to the Offsite Dose Provide discussion for this change 5/5/97 TSTF-65 is Calculation Manual (ODCM) be reviewed by the onsite to CTS requirements to include the still pending.

review function and the plant manager. ITS 5.5.1.c.2 specific procedures that will control requires changes to the ODCM be reviewed by the plant the requirement. Acceptance of manager. The CTS requirement for the onsite review this change to the CTS function to review ODCM changes is moved to unspecified requirements is based on the NRC plant procedures. This change to the CTS is based on acceptance of TSTF-65.

TSTF-65.

BGE Response:

The issue raised is unrelated to TSTF-65. TSTF-65 addresses the change from *[ Plant Superintendent] to " plant manager." TSTF-65 does not address the elimination of the CTS requirement to have cht.nges to the ODCM reviewed by the onsite review function.

Calvert Cliffs License Amendments 216/193, dated August 26, 1996, relocated the list of requirements for the onsite review function to the Quality Assurance Policy. Discussion of Change LA.3 will be modified to state that the onsite review function to review ODCM changes will be moved to the Quality Assurance Policy. The Quality Assurance Policy will be modified to include the detail.

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ATTACHZENT (2) -

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

1 5.0 - LDOC: .JFD: CHANGE / DIFFERENCE- COMMENT' . STATUS - ,

j 6,7,8,9, 3 The ITS 5.4.4, Radioachve Effluent Controls Program, has Revise the CTS markups changed l

, 10,11, been modified in accordance with CTS amendments 197 by amendments 197 and 217 and -

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] 12 and 217. Amendment 217 was approved October 18, replace the pages i 1996, and amendment 197 was approved March 7,1997.  ;

BGE Response: 3 s t

. Current Technical SpeGc.aGen Amendments 217 (Unit 1),194 (Unit 2), approved on October 18,1996, which implemented changes to the Radiological

Effluent Controls Program, were used in the markup of the CTS. Note the amendment number in the lower right hand comer of each page on CTS markup

pages 7,8, and 9 of 61 in the Unit 1 CTS markup and pages and 7,8, and 9 in the Unit 2 CTS markup. j Current Technical Specification Amendments 221 (Unit 1),197 (Unit 2), approved on March 7,1997, rnodified the Technical Specifications to allow use of j

blind flanges in Modes 1 - 4 in the Containment Purge System instead of purge valves. As described in Volume 1, Attachment (2), " Outstanding i Amendments and Generic Changes," of our submittal, this amendment was shown in our CTS markup. The CTS changes aswiahwi with this amendment  !

request were marked in the CTS and indicated with the label"NRC 96-042." See pages 51 and 52 of 61 of the Unit 1 CTS markup and pages 47 and 48 of 57 of the Unit 2 CTS markup. The approved amendment accepted the proposed CTS changes without modification, so the CTS markup is not affected by the approval of the amendment. We intend to modify Attachment (2) to describe the approved amendments incorporated in the submittal with the l amendment numbers and approval date.

i 13 CTS 4.7.6.1.e.1 requires verifying that the pressure drop Provide discussion and justification across the combined HEPA filters and charcoal absorber for the addition of the prefilters to  !

banks is < 4 inches Water Gauge while operating the the CTS requirement.  !

ventilation system at a flow rate of 2000 cfm i 10%. ITS  ;

i 5.5.11.d requires the same verification but adds the Classify this change as a More prefilters to the HEPA filters and charcoal absorber bank. Restrictive change.  :

There is no discussion or justificabon for the change to CTS requirements.  ;

BGE Response:

l A more restrictive change will be included in a supplemental amendment request to the ITS application adding the prefilters to the. CTS 4.7.6.1.e.1 requirement, and also CTS Sechons 4.6.3.1.d.1,4.6.6.1.d.1,4.7.7.1.d and 4.9.1.2.d.1.  !

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ATTACHMENT (2) '

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

5.0 ~ DOC JFD CHANGE / DIFFERENCE COMMENT STATUS- .

14 STS 5.5.11.c requires demonstrating for each of the ESF Provide justification for the STS systems that a laboratory test of a sample of the charcoal deviation based on current absorber, when obtained as described in [ Regulatory licensing basis, system design, or Guide 1.52, Revision 2], shows the methyl iodide operational constraints.

penetration less than the value specified below when tested in accordance with [ ASTM D3803-1989] at a temperature of 5 [30*C] and greater than or equal to the relative humidity specified as follows. ITS 5.5.1.1.c has the same requirements but adds (elemental iodine for Iodine Removal System (IRS)) and (103*C for IRS). There ,

is no discussion or justification for the deviation to the STS.

BGE Response:

As shown on page 5.0-13 of the ISTS markup, the lodine Removal System (IRS) requirements moved to the Ventilation Filter Testing Program (VFTP) are taken from CTS Surveillances. The specification of elemental iodine and the 130*C test temperature is given in CTS Surveillance 4.6.3.1.b.3 as shown in the Unit 1 CTS markup page 43 of 61 and Unit 2 markup page 39 of 57. Therefore, these requirements are consistent with the current licensing basis. The Discussion of Deviation associated with this difference from ISTS 5.5.11 states, "This change incorporates Calvert Cliffs-specific information into brackets."

While the test temperature is bracketed in the ISTS, the form of iodine is not. Therefore, this description is not entirely accurate. We will create a new Discussion of Deviation which will state, "This change incorporates the current Calvert Cliffs requirements for the lodine Removal System into the Ventilation Filter Testing P.sgram. This requirement is consistent with the Calvert Cliffs

• current licensing basis.*

15 STS 5.5.12 requires determining the liquid radwaste Provide justification for the STS quantities in accordance with [ Standard Review Plan, deviation based on current Section 15.7.3, " Postulated Radioactive Release Dee to licensing basis, system design, or Tank Failures"]. ITS 5.5.12 does not include this STS operational constraints.

requirement. There is no discussion orjustification for this STS deviation.

BGE Response:

Discussion of Deviation 11 explains that Calvert Cliffs does not have any outdoor liquid radwaste tanks and, therefore, ISTS Section 5.5.12.c, which applies to such tanks, is being deleted. The deleted information discussed in your question describes the method used to determine the quantity of liquid radwaste in such tanks. Therefore, the information is not needed. For clarity, we will add a reference to Discussion of Deviation 11 to the subject paragraph.

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ATTACHZENT (2)

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

5.0 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS -

16 None STS 5.5.12.b requires a surveillance program to ensure Provide justification for the STS that the quantity of radioactivity contained in [each gas deviation based on current storage tank and fed into the offgas treatment system] is licensing basis, system design, or less than the amount that would result in a whole body operational constraints.

exposure of > 0.5 rem to any individual in an unrestricted area, in the event of [an uncontrolled release of the tanks' contents]. ITS 5.5.12.b requires a survedlance program to ensure that the quantity of radioactivity con'ained in each gas storage tank is less than or equal to E8,500 curies noble gases (considered Xe-133). There is no discussion or justification for this deviation to the STS requirements.

BGE Response:

As shown in Unit 1 markup page 47 of 61 and Unit 2 markup page 43 of 57, the ITS 5.5.12.b limit on the quantity of radioactive material contained in each gas storage tank was taken from CTS LCO 3.11.1.2. Therefore, this deviation from the ISTS is consistent with the current licensing basis. We will add a Discussion of Deviation to Section 5 describing the deviation from the ISTS. Currently, this deviation is justified as a change incorporating Calvert Cliffs specific information into brackets, which is incorrect.

17 12 STS 5.5.13.a.3 requires verifying the fuel oil has a clear 5/5/97 The CCNPP Project 5/5/97 Closed and bright appearance with proper color. ITS 5.5.13.a.3 Manager confirmed that FSAR changes this requirement to verifying water and sediment Section 3.4.1, page 8.4-8 states

<0.05%. that sonp!ing of incoming fuel oil is r.cfzed for water and sediment.

CCNPP does not utilize a c' ear w:d bright :,5i Mc ve ?.e This is in the CCNPP design basis.

diesel fuel oil is dyed, and CCNPP contains a CTS SR which allows the interval for determining particulates in the stored diesel generator fuel oil to be 92 days.

BGE Response:

None 1

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ATTACHMENT (2)

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS 5.0 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS -

17.a M.4 Relative to ITS 5.5.13, DOC M.4 could be improved by Revise DOC M.4 to more more completely addressing the additional requirements completely address the additional associated with the Diesel Fuel Oil Program. requirements associated with the Diesel Fuel Oil Program.

BGE Response:

Discussion of Change M.4 will be enhanced in a future supplemental amendment request to the ITS application, to include the fact that the program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable American Society for Testing Materials (ASTM)

Standards. Discussion of Change M.4 will also be combined with Discussion of Change M.5 to help clarify the explanation of the change.

17.b M5 Relative to ITS 5.5.13, DOC M.5 could be improved by a Revise DOC M.5 to directly discuss more direct discussion of the testing performed on fuel oil fuel oil testing and why such testing and why such testing provides better assurance that the provides better assurance that the EDGs will function and is, therefore, a safety EDGs will function.

enhancement. The fact that these tests are currently performed as non-TS activities does not have the impact as the approach discussed above.

BGE Response:

Discussion of Change M.5 will be enhanced and combined with Discussion of Change M.4 (see issue 17.a above) in a future supplemental amendment request to the ITS applicatica. The combined Discussion of Change will be M.4 and will include the fact that the program is to establish: acceptability of new fuel for use prior to addition to the storage tanks; within 31 days following addition of the new fuel oil to the storage tanks, verify that the properties of the new fuel, other than those addressed prior to use, are within limits for ASTM 2D fuel oil; and total particulate concentration of the stored fuel oil, determined by gravimetric analysis, is less than or equal to 10 mg/l when tested every 92 days.

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ATTACHZENT (2) '

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS 5.0 .. DOC. JFD- . CHANGE / DIFFERENCE COMMENT 7 STATUS" .

17.c A.26 DOC A.26 is not correct CTS SR 4.8.1.1.2.b requires Revise DOC A.26 to include '

verifying DG operability "At least once per 92 days by deleting the 92-day requirement as [

verifying that a sample of diesel fuel from the fuel storage a Less Restrictive change and tank is within the acceptable limits specified in Table 1 of justification for the 31-day SSTM D975-81 when checked for viscosity, water and requirement sediment" l

The corresponding ITS 5.5.13.b requires, "Within 31 days following addition of the new fuel oil, other than those addressed in a., above are within limits for ASTM 2D fuel oil; and..." The change, which involves deleting the 92 day requirement, is a Less Restrictive change. ,

BGE Response: '

Discussion of Change A.26 will be withdrawn and L.3 will be written to address elimination of the tests on the diesel fuel from the fuel storage tank every 92  !

days for viscosity, water and sediment, and replacing the sed: ment test with a particulate test Plant history has shown that the viscosity of the fuel oil does not change with time, and no additional water appears in the oil in the fuel storage tank with time. Improved Technical Specification Surveillance '

Requirement 3.8.3.3 also checks for and removes accumulated water from each fuel oil storage tank every 92 days. As fuel breaks down, it forms solids, which can be measured as particulate or sediment Testing fcr particulates is a more sensitive means of testing for fuel breakdown than testing for sediment. The test for fuel breakdown will continue to be performed every 92 days, but using a more sensitive test t

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- ATTACHZENT (2) - 3 CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS -

5.0 DOC- JFD CHANGE / DIFFERENCE COMMENT STATUS' 18 12 STS 5.5.13.c requires verifying total particulate Provide justification for the STS concentration of the fuel oil is 510 mg/l when tested every deviation based on current 3 31 days in accordance with ASTM D-2276, Method A-2 or licensing basis, system design or i A-3. The corresponding ITS 5.5.13.c requires verifying operational constraints.  ;

total particulate concentration of the fuel oil is 510 mg/l when tested every 92 days when determined by gravimetric analysis. JFD 12 contains no justification for this deviation of STS testing methods.

BGE Response:

Discussion of Deviation 25 will be modified to explain that ASTM D-2276 Method A.3 is a gravimetric analysis, but the testing performed at Calvert Cliffs does not match all the detail contained in Method A.3. Among the differences at Calvert Cliffs, the reagents used are different, a filter reagent is not used, and the preoaration of apparatus portions are not used. Method A.2 is for fuel systems under pressure, which is not used at Calvert Cliffs because there are '

not any systems in that category. The total particulate test requirement is replacing the CTS sediment test requirement for fuel oil breakdown indication.

L 19 12 STS 5.5.13.c requires verifying total particulate This justification should be revised .

concentration of the fuel oil is 510 mg/l when tested every to justify the 92 day interval l 31 days in accordance with ASTM D-2276, Method A-2 or between testing for impurities on its A-3. The corresponding ITS 5.5.13.c requires verifying own merits, or retain the STS total particulate concentration of the fuel oil is 510 mg/l frequency of every 31 days.  !

when tested every 92 days when determined by Provide justification for the STS gravimetric analysis. This extends the STS STI from 31 deviation based on current days to 92 days. licensing basis, system design, or operational constraints.

BGE Response:

Discussion of Deviation 12 will be modified to clarify the connection between sediment and particulate testing, and justify the 92-day frequency. Fuel oil breakdown results in solids in the fuel oil, which may be measured as particulate or sediment. Testing for particulates is a more sensitive way of testing for fuel oil breakdown. CTS 4.8.1.1.2.b requires the test for fuel oil breakdown (sediment) be performed every 92 days on diesel fuel oil from the fuel storage tank. The test for particulates will become the test for fuel oil breakdown, and will be performed at the same 92-day frequency that sediment is tested for.

Changes to the ITS application will be ii.cluded in a future supplemental amendment request. l l

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ATTACHMENT (2) -

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS -

5.0 - DOC JFD ~ CHANGE / DIFFERENCE _ COMMENT- STATUS' 20 LA.6 CTS Surveillance Requirements 3/4.6.1.1.c requires Acceptance of this change to CTS 4/11/97 TSTF plans verifying the equipment hatch is closed and sealed prior requirements is based on the NRC to submit a revision to entering MODE 4 by performing a Type B test, and acceptance of TSTF-52. of TSTF-52. 5/3/97 3/4.6.1.1.d. requires verifying containment purge blind TSTF-52, R.1 not yet flanges are installed and sealed prior to entering MODE 4 received.

by performing a Type B test. These surveillances are not included in the ITS, but are moved to the Containment Leakage Rate Testing Program. This change to CTS requirements is based on TSTF-52.

BGE Response:

The change to CTS requirements is based on justification provided in Discussion of Change LA.6, which discusses the movement of details on  ;

components that require Type B testing to the Containment Leakage Rate Testing Program. TSTF-52 does add the Containment Leakage Rate Testing Program to the STS, but is not related to this removal of details from the CTS. Discussion of Change LA.6 describes movement of details regarding Containment Integrity to the Containment Leak Rate Testing Program. Discussion of Change LA.6 will be retracted, and a less restrictive Discussion of Change will be developed to eliminate aspects of the program that are addressed by Regulatory Guide 1.163, which is referenced in the specification.

21 M.1 ITS 5.5.17, Battery inspection Program (BIP), is added to Acceptance of this change to CTS TSTF-115 withdrawn the CTS requirements. The BIP requires battery tests requirements is based on the NRC by TSTF and <

recommended by IEEE-Std-450-1995, and is acceptance of TSTF-115. replaced with  ;

implemented by ITS SR 3.8.6.1. This change to CTS TSTF-198,199, 200,  !

requirements is based on TSTF-115. 201, and 203.

5/5/97 these TSTFs are under NRC review.

BGE Response: .

Changes associated with TSTF-115 will be withdrawn because TSTF 115 has been withdrawn We will not implement TSTFs 198 through 203, because they are not expected to be approved prior to issuance of the Calvert Cliffs ITS SER. The submittal will be changed to be consistent with NUREG 1432,  ;

Revision 1, and the CTS, unless justification is provided for a change.

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ATTACHMENT (2) -

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

- 5.0 DOC 'JFD ^ CHANGE / DIFFERENCE COMMENT: STATUS:- ,

22 CTS 6.6.1, Footnote *, requires reporting occupational Provide discussion and justification dose from the independent Spent Fuel Storage Installation for deleting the CTS requirement (ISFSI) separately. The ITS does not include this for reporting exposure from the requirement. There is no justification for this change to ISFSI separately.

CTS requirements.

BGE Response:

A Discussion of Deviation will be added to explain that the CTS requirements are being retained. The changes will be incorporated in a future supplemental license amendment request.

23 14 STS 5.6.1 requires, in part, that the dose assignments to This change was made to reflect 5/5/97 Closed various duty functions may be estimated based on pocket the actual mechanisms used at dosimeter, thermoluminescent dosimeter (TLD), or film CCNPP to measure dose rates.

badge measurements. ITS 5.6.1 changes the mechanisms to measure dose rates by adding electronic personal dosimeter and deleting 88m badge measurements.

BGE Response None 24 16 STS 5.6.2 contains s [acketed statement that requiring Clarify the deviation from the STS the report shall identify the TLD results that represent described in JFD.16.

collocated dosimeters in relation to the NRC TLD program and the exposure period associated with each result JFD.16 states that this information is not adopted because the information is not consistent with CCNPP design or current licensing basis. However, this requirement is included in the CTS and ITS. This deviation of requirements requires clarification.

BGE Response:

The Discussion of Deviation will be withdrawn and the information will be adopted in the ITS.

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ATTACHMENT (2) -

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

5.0 DOC JFD CHANGE / DIFFERENCE ~ COMMENT STATUS - ,

25 LA.8 CTS 6.6.3 includes a parenthetical statement emphasizing Provide discussion of specific that the submittal of the Radioactive Effluent Release procedures that include the CTS Reports must be no longer than 12 months, and footnote requirements.

" which allows a supplementary report to be submitted within 120 days. CTS 6.6.3 also includes information for reporting licensee initiated major changes to the Radioactive Waste Systems. The ITS do not contain these requirements which are moved to unspecified plant procedures.

BGE Response:

The parenthetical statement in CTS 6.6.3 emphasizing detail in 10 CFR 50.36a, that the time between submittal of the Radioactive Effluent Release Reports must be no longer than 12 months, is included in the requirement to abide by 10 CFR 50.36a. Discussion of Change LA.8 will be modified to state that requirements associated with reporting of changes to the Radioactive Waste Systems are contained in the ODCM and will be controlled by Secbon 5.5.1 of the ITS. The footnote " allows a supplemental report containing Sr" and Sr" analyses

• results to be submitted within 120 days after submittal of the Radioactive Effluent Release Report. To address this footnote, the phrase "as modified by approved exemptions

• will be added to the statement that the Radioactive Effluent Release Report covering the operation of the unit shall be submitted in accordance with 10 CFR 50.36a. The details regarding the exemption will be moved to the ODCM. Discussion of Change LA.8 will be modified to reflect these changes.

26 18 STS 5.6.6 contains the requirements for the Reactor CCNPP does not anticipate the 5/5/97 Closed Coolant System (RCS) and Pressure Temperature Limits temperature / pressure values to Report (PTLR). The ITS do not include ti.s requirement. change from cycle to cycle, which would negate the benefits of the PTLR. Therefore, CCNPP will retain the specific pressure /

temperature limits in the TS.

This is part of the CCNPP system design and therefore, the change is acceptable.

BGE Response:

None 12

ATTACHZENT (2) -

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS -

5.0 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS -

27 19 STS 5.6.7 includes the requirements for reporting Acceptance of this change to CTS 5/5/97 TSTF-37 Emergency Diesel Generator failures. The ITS do not requirements is based on the NRC rejected. TSTF-37, include this requirement based on TSTF-37. acceptance of TSTF-37. R.1 is pending.

BGE Response:

The Calvert Cliffs CTS does not include a Diesel Generator Failure Report. The STS 5.6.7 requirement is bracketed, which implies that it is plant specific.

Therefore, regardless of the outcome of TSTF-37, since the Diesel Generator Failure Report is not part of the Calvert Cliffs current licensing basis, we request that this new report not be included in the ITS.

28 A.17 CTS 6.6, Reporting Requirements, does not include the Reclassify this change to CTS Post Accident Monitoring Report. ITS 5.6.7 is added to the reporting requirements as a More CTS requirements, and requires submitting a report within Restrictive change and justify.

14 days when required by Condition B or G of ITS 3.3.11 Post Accident Monitoring Instrumentation. This change to CTS requirements is documented as an Administrative change. The change is a More Restrictive change.

BGE Response:

The change described in A.17 only applies to those post accident monitoring instruments for which a report is not currently required. The Discussion of Changes justifying the addition of the report, both more and less restrictive, are provided in the Discussion of Changes for Section 3.3.10. Therefore, the addition of this report in Section 5.0 is administrative. For clarity, Discussion of Change A.17 will be revised to clearly state why it is administrative. In addition, it was noted that some post accident monitoring instruments in the CTS already required a special report. For these instruments, the CTS markup (from Section 3.3.10) and Discussion of Changes for the current special reporting requirements will be added to the Section 5.0 CTS markup and Discussion of Changes. This results in two new Discussion of Changes being added to Section 5.0 (one more and one less restrictive change) because the Discussion of Changes for ITS 3.3.10 states that they are moved to Section 5.0, but Section 5.0 does not contain al1 the appropriate Discussion of Changes.

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ATTACHIENT- (2)

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

' 5.0  : DOC. TJFD! -CHANGE / DIFFERENCE 1 COMMENT. 'l STATUS l - ,

29 A22 ITS 5.5.15 describes the Safety Funchon Detemiination Reclassify this change to CTS Program.' CTS does not include this requirement. T'as requirements as a More Restrictive change to CTS requirements is documented as -an change and provide discussion.

Administrative change. The change is a More Restrictive change.

BGE Response:

The Safety Funcbon Determination Program was added due to the change to CTS LCO 3.0.5 (ITS LCO 3.0.6). In the Discussion of Changes to Secbon 3.0, the addition of ITS LCO 3.0.6 was described as a less restrictive change. We also stated that a Safety Funcbon Determination Program was added as part of the ITS LCO 3.0.6 addition. Therefore, an Administrative Change was used to add ITS 5.5.15, since the less restrictive attributes are alread'/ discussed in Sechon 3.0. Discussion of Change A.22 will be modified to clarify why it is administrative and to cross-reference the less restrictive Discussion of Change in Sechon 3.0.

30 LA.5 The referenced DOCS justify moving informabon outside Provide additional discussion and LA.6 the ITS by referring to the plant change control process. justification including a complete LA.7 There is no description of this program or how changes to description of the Plant Change LA.8 the program, or procedures govemed by the program, are Control Process and how changes controlled. are controlled.

BGE Response:

Discussion of Change LA.5 describes movement of details regarding Gaseous Effluents Explosrve Gas Mixture and Gas Storage Tanks to the Explosive Gas and Storage Tank Radioachvity Monitonng Program. These details will be moved to the Technical Requirements Manual, which will be incorpciaiad by reference into the UFSAR.

Discussion of Change LA.6 dema,es movement of detads regarding Containment integrity to the Containment Leak Rate Testing Program. Dica ==ian of Change LA.6 will be retracted, and a less restnchve Dien_m=ian of Change will be developed to eliminate aspects of the of the ixc u rani that are addressed by Regulatory Guide 1.163, which is referenced in the 9;+ r _4R-i.

Discussion of Change LA.7 desenbes movement of details from several spedricistions to the Ventilabon Filler Test Program. Discussion of Change LA7 will be retracted. Some of the requirements that are addressed by Dien_mcian of Change I.A7 are CTS requirements that are incorpuiaicd into the ITS, and they will be marked appiepriately. No Discussion of Change is necessary for the retamed requirements, and appicpiiate Discussions of Deviation will be added where requirements differ from the ISTS. A less restnchve Discussion of Change will be developed to eliminate post-maintenance requirements, which are contamed in CTS 4.7.7.1.g,4.6.6.1.g, 4.6.3.1.a. and 4.9.12.g, but do not meet the entena for retention in the Technical S;+ST- st--is.

Discussion of Change LA.8 describes movement of three sets of details. The disposition of these details is described in the answer to Quesbon 20.

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ATTACHIENT (2)

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS .

5.0 DOC JFD CHANGE / DIFFERENCE ~COMMENTE . STATUS'- ,

31 L2 ITS 5.5.8.c, inservice Testing Program, adds a Change confirmed with the CCNPP 5/5/97 Closed requirement allowing ITS SR 3.0.3 to be applicable to Project Manager.

inservice testing activities. This requirement allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the Frequency, whichever is less, to perform inservice Testing upon discovery that inservice Testing requirements were not performed CTS 4.0.5 requires declaring the component inoperable if the Inservice Testing is not performed. This change is a relaxation from the CTS requirements.

BGE Response:

None 34 A.8 CTS 3/4.6.1.6 includes surveillance requirements for Provide additional discussion and monitoring tendon degradation. These requirements are justification reclassifying this moved outside the ITS to the Concrete Containment change from an Administrative to a Tendon Surveillance Program. ITS 5.5.6 describes the Less Restrictive Change including Concrete Containment Tendon Surveillance Program but how changes to the Concrete has no requirements or description of how changes are Containment Tendon Surveillance controlled. This change is listed as an Administrative Program are controlled.

Change but is a Less Restrictive Change.

BGE Response:

Discussion of Change A.8 only addresses the addition of a description of requirements already contained in the CTS.

CTS Surveillances 4.6.1.6.1,4.6.1.6.2, and 4.6.1.6.3 are moved to the Calvert Cliffs Tendon Surveillance Program, as documented in Discussion of Change LA.4. Discussion of Change LA.4 will be modified to state these details will also be moved to the Technical Requirements Manual. The Technical Requirements Manual will be modified to include the details.

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