ML20148U296
| ML20148U296 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/02/1997 |
| From: | Trimble D NRC (Affiliation Not Assigned) |
| To: | Hinnant C CAROLINA POWER & LIGHT CO. |
| References | |
| TAC-M97243, TAC-M97244, NUDOCS 9707100147 | |
| Download: ML20148U296 (138) | |
Text
{{#Wiki_filter:T July 2, 1997 Mr. C. S. Hinnant, Vice President
, Carolina Power & Light Company !
Brunswick Steam Electric Plant , Post Office Box 10429 ! Southport, North Carolina 28461
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL ' SPECIFICATION CHANGE REQUEST TO CONVERT TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR THE BRUNSWICK STEAM ELECTRIC PLANT, ! UNITS NO. 1 AND 2 (TAC NOS. M97243 AND M97244)
Dear Mr. Hinnant:
By letter dated November 1,1996, you submitted a request to convert the , current Technical Specifications (TS) for the Brunswick Steam Electric Plant, > Units 1 and 2, to be consistent with the Improved Standard Technical ! Specifications (ISTS) in NUREG-1433, " Standard Technical Specifications - General Electric Plants, BWR/4," Revision 1, dated April 1995. To complete our review, we need additional information requested in the enclosed table. To support the NRC staff's review schedule, your written response to this j request for additional information is expected withia 30 days of the receipt . of this letter. Should you have any questions, do not hesitate to contact me i at (301) 415-2019. Sincerely, ! (Original Signed By) , , David C. Trimble, Project Manager Project Directorate 11-1 i Division of Reactor Projects - I/II ; Office of Nuclear Reactor Regulation l Docket Nos. 50-325 and 50-324
Enclosure:
As stated p{ ' cc w/ enclosure: See next page NRCg@MBCM Distribution ' Docket File W. Beckner $ PUBLIC OGC )g PD 11-1 RF ACRS i S. Varga J. Johnson, RII I M. Reinhart D. Clark ! M. Weston l FILENAME - G:\BRUNSWIC\BR97243.RAI . l OFFICE PM:PDII-1 LA:PDII-1 PD:PDII-N - NAME DTrimblb Dunnin[tk VRooneyk DATE 7/ 2-/97 7/A/O 7/'t797 COPY ke)/No Te's'/ho s Yesho 0FFICIAT RECORD COPY p D pg 24 llll...lllllll.lll,6(llll(lKlll
l . Mr. C. S. Hinnant Brunswick Steam Electric Plant ; Carolina Power & Light Company Units 1 and 2 cc: . Mr. William D. Johnson Ms. Karen E. Long !
- Vice President and Senior Counsel Assistant Attorney General ;
Carolina Power & Light Company State of North Carolina '
- Post Office Box 1551 Post Office Box 629 i
; Raleigh, North Carolina 27602 Raleigh, North Carolina 27602 i
1 Mr. Jerry W. Jones, Chairman Mr. Robert P. Gruber ! Crunswick County Board of Commissioners Executive Director Post Office Box 249 Public Staff - NCUC Bolivia, North Carolina 28422 Post Office Box 29520 J i Raleigh, North Carolina 27626-0520 'l Resident Inspector . ! U.S. Nuclear Regulatory Comission Mr. W. Levis i 4 8470 River Road Director i i Southport, North Carolina 28461 Site Operations l l Brunswick Steam Electric _ Plant , Regional Administrator, Region II Post Office Box 10429
- U.S. Nuclear Regulatory Comission Southport, North Carolina 28461
- Atlanta Federal Center {
j 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. William H. Crowe, Mayor City of Southport l l Mr. Nel Fry, Acting Director 201 East Moore Street !
- Division of Radiation Protection Southport, North Carolina 28461 i l N.C. Department of Environment, ;
- Health and Natural Resources Mr. Dan E. Sumers .
l 3825 Barrett Dr. Emergency Management Coordinator l
- Raleigh, North Carolina 27609-7721 New Hanover County Department of i
! Emergency Management
- Mr. R. P. Lopriore Post Office Box 1525 l l Plant Manager _
Wilmington, North Carolina 28402 i l Carolina Power & Light Company i Brunswick Steam Electric Plant Ms. D. B. Alexander i l Post Office Box 10429 Manager
- Southport, North Carolina 28461 Performance Evaluation and i Regulatory Affairs 4
Public Service Comission Carolina Power & Light Company , State of South Carolina 412 S. Wilmington Street i Post Office Drawer 11649 Raleigh, North Carolina 27601 l Columbia, South Carolina 29211 Mr. K. R. Jury Mr. Milton Shymlock Manager - Regulatory Affairs U. S. Nuclear Regulatory Comission Carolina Power & Light Company Atlanta Federal Center Post Office Box 10429 3 61 Forsyth Street, SW, Suite 23T85 Southport, NC 28461-0429 Atlanta, Georgia 30303
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BNP ITS 3.4.1 RECIRCULATION LOOPS OPERATING - 1
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i ITEM # DOC . CTS /STS L DESCRIPTION OF ISSUE-. DATE. _ A D'TE) -l COMMENTS [ ' or1 REFJ
- OPENED: CLOSED:
JFD#! 3.4.1-1 None CTS 3.4.1.1.a The referenced CTS requirements Acceptance of the CTS 3.4.1.1.b address various topics related to total changes are contingent CTS 3.4.1.1 core flow, THERMAL POWER, upon NRC approval of Action a, line associated Action Statements, and an TSC 96TSB03. ! 2&3 APRM/LPRM baseline neutron flux CTS 3.4.1.1 surveillance. ITS deletes these Action b line requirements from the CTS based on 2,3,4,5 the statement " Deleted by TSC l CTS 3.4.1.1 96TSB03". Action c + CTS 14.1.1.3 3.4.1-2 JFD4 CTS 3.4. i .1 CTS 3.4.1.1 ACTION b. allows 2 Acceptance of CTS ! Action a hours, with both recirc loops not in changes are also ! , L.1 operation, to reduce thermal power contingent upon NRC ; CTS 3.4.1.1 and 12 hours to restore to two approval of TSC - ;
- Action b recirculation loop operation or the plant 96TSB03. i i
must be in Hot Shutdown within the l ITS 3.4.1 next 12 hours. STS 3.4.1 Action A.1 Action A provides 24 hours to return to two ; i loop operation or to make required i STS 3.4.1 adjustments for single loop operation. l Action A ITS allows 6 hours to return to two ! loop operetion or to make the required ! adjustments. The discussion is unclear ! as to why the 24 hours of the STS to .! make the redjustments for single loop [ operation cannot be justified and if it ! ! can't why then the 2 hours of the CTS I should not be maintained. j i
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E BNP ITS 3.4.1 RECORCULATION LOOPS OPERATING , ITEM # !DOC CTS /STSi l DESCRIPTION 'OF ISSUE - DATEil: :DATE- :COMMENW ! or' REF 4 OPENED . CLOSED ' ._ l Jpop. r 3.4.1-3 None ITS 3.4.1 The intended meaning of "when the Action A.1 pump speeds between the two t
- Bases recirculation pumps ..." is unclear. !
Should it be "when the difference in i the pump speeds..."? ! i 3.4.1-4 None ITS 3.4.1 LCO What is the benefit of including cycle ! and Applicable specific comments in the Bases and l Safety what will ensure that such comments ! Analyses Bases are regularly updated, if included? ! 1 . i I i 1 l f 1 i i' i !
1 BNP ITS 3.4.2 JET PUMPS , .lTEM # DOC CTS /STS DESCRIPTION OF ISSUE : DATE DATE - COMMENTS- ! # ori. 'REF- OPENED CLOSED I JFD1 ; I
# f 3.4.2-1 LA.1 CTS 4.4.1.2.2 The CTS 4.4.1.2.2 requirement to Provide identification cf .
demonstrate Operability of jet pumps the plant procedure to ! prior to entering MODE 2 are moved to which CTS 4.4.1.2.2 is plant procedures. ITS 3.4.2, ITS SR moved to. 3.4.2.1, and ITS SR 3.0.1 requirements ;
' ensure mainteining the jet pumps i OPERABLE prior to entering MODE 2.
The plant procedure to which this : requirement is moved was not identified but change control is specified as 10 CFR 50.59. i i I
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i i t;NP ITS 3.4.3 SAFETY / RELIEF VALVES (SRVs) ITEM # - ' DOC 1 CTS /STS --- DESCRIPTION OF ISSUE :f .DATE~. DATE ' COMMENTS
- or; IW _
OPENED: CLOSE. JFDjl~ . . , ; Di _ j g; w. .a .- 3.4.3-1 JFD CM 3.4.2 CTS 3.4.2 and STS 3.4.3 requires the Acceptance of the CTS j 10 safety function of all (11) reactor and STS changes are !
!TS 3.4.3 coolant system safety / relief valves contingent upon NRC i OPERABLE. ITS 3.4.3 requires only 10 approval of TSC !
STS 3.4.3 (of 11) relief valves OPERABLE. This 94TSB16. .j deviation from CTS and STS , requirements is changed by TSC ~ 95TSB16.' 3.4.3-2 JFD CTS 3.4.2 CTS 3.4.2 requires the lift settings of Acceptance of the CTS 1 the safety / relief valves to be within +/- changes are contin 0ent > JFD ITS 3.4.3 1% of the CTS specified values. ITS SR ' upon NRC approval of , 9 3.4.3.1. changes the lift setpoints of all TSC 94TSB16. : STS SR SRVs and increases the tolerance to +/- l 3.4.3.1 3%. This deviation from CTS 3.4.2 , ! requirements is changed by TSC j 95TSB16. I 3.4.3-3 none CTS 3.4.2 CTS Action a, b, c specify the required I A; w Aus ci the C S l Action a & b actions for one, two or more l r.nd STS changes are ! CTS action c INOPERABLE safety / relief valves. ITS :cmingent upon NRC j 3.4.3 deletes CTS Actions a & b, and 'arepreval of TSC . ITS 3.4.3 modifies CTS 3.4.2 action c to address 94TSB16. ! ACTION A "one or more required" INOPERABLE , l safety / relief valves. This change from 8 [ STS 3.4.3 CTS requirements r.nd deviation from : ACTIONS A & STS regeirements is changed by TSC i i B&C 95TSB16 and is a more restdctive change. i l r a ; 5 i
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.t BNP ITS 3.4.3 SAFETY / RELIEF VALVES (SRVs)
ITEM '# - DOC. CTS /STS' DESCRIPTION OF ISSUE 5 DATE- DATE? ? COMMENTSi
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or. .REFi . OPENED > CLOSE:: . JFD:
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3.4.3-4 Non SR 3.4.3.1 With 11 valves listed and only 10 e required, the interit of the SR becomes unclear. If a valve h not one of the 10 -
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, required at that particular time does it have to be tested? 3.4.3-5 Non SR 3.4.3.1 CTS 4.4.2 indicates the surveillance is e IAW TS 4.0.5. ITS SR 3.4.3.1 indicates ; the SR is done IAW the ISTP. There is t no DOC referenced for this change. 3.4.3-6 JFD CTS 4.4.2 ITS SR 3.4.3.2 is added which requires 10 the SRVs manually actuated every 24 and- ITS SR 3.4.3.2 months. This requirement does not i 11 exist in the CTS. STS SR 3.4.2.2 requires this test each "18 months on a - STS SR staggered test basis for each valve 3.4.3.2 solenoid." ITS 3.4.3.2 changes the ; SRV test interval from that of the STS. Since this requirement is not in the CTS, it is unclear what in the licensing basis ; supports the deviation from the STS or ! why the bracketed item is not applicable to the plant.
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BNP ITS 3.4.4 RCS OPERATIONAL LEAKAGE ITEM # - DOC ~ CTS /STS DESCRIPTION OF ISSUE ~ DATE DATEL COMMENTS or-' REF OPENED CLOSE JFD D 3.4.4-1 Non ITS 3.4.4 in 3.4.4 References it is NUREG 71/067 e Bases and in 3.4.5 it is 71/067. References 3.4.4-2 Non ITS 3.4.4 Second para,last sentence should be e Background RCPB rather than RCS oressure boundarv. 3.4.4-3 Non ITS 3.4.4 While IGSCC is probably the most likely e Bases Actions cause, why is discussion limited to that? B-1 and B-2 i a h
BNP ITS 3.4.5 RCS LEAKAGE DETECTION INSTRUMENTATION ITEM # DOC'I CTS /STS . DESCRIPTION OF ISSUE - DATE DATE- COMMENTS or '. REF OPENED : CLOSED JFD . R 3.4.5-1 i.E.1 ITS SR 3.4.5.3 Surveillance interval increased from 18 GL 91-04 update, to 24 months contingent on NRC acceptance during instrumentation review. , l a b i t
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BNP ITS 3.4.6 RCS SPECIFIC ACTIVITY ITEM #- . DOC CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS or. REF OPENED : CLOSED. , JFD-g~ 3.4.6-1 LA.1 CTS Table CTS Table 4.4.5-1 Item 5 requires Provide identification of 4.4.5-1 Item 5 performing an offgas isotopic analysis the plant procedures to for xenon and krypton once per 31 which this CTS days. These requirements are moved to requirement is moved to. plant procedures but the plant procedures are not identified. , b t i L
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BNP ITS 3.4.8 RHR SHUTDOWN COOLING SYSTEM - COLD SHUTDOWN ITEM # DOC CTS /STS '. DESCRIPTION OF ISSUE DATE- DATE? ' COMMENTS ' or REF OPENED . . CLOSED. JFD - ! R: 3.4.8-1 Non ITS 3.4.8 The intent of "... decay heat must be , e Bases removed int maintaining ..." is unclear. . Background Should it be "in order to maintain"? i i s L t 4 i i f k I
BNP ITS 3.4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS ITEM # DOC CTS /STS . DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPENED ' CLOSED JFD-3.4.9-1 A.2 CTS 3.4.6.1 With any RCS pressure / temperature ACTION limits exceeded, CTS 3.4.6.1 ACTION requires " performing an engineering ITS 3.4.9 evaluation to determine the effects of Required the out-of-limit condition on the fracture ACTION A.1 toughness properties of the RCS; and C.2 determine that the system remains acceptable for continued operations." STS 3.4.10 With any RCS pressure / temperature Required limits exceeded, ITS 3.4.9 Required ACTION A.1 ACTION A.1 and C.2 requires and C.2 " Determine RCS is acceptable for continued operation." This change deletes the specific requirement for performing the engineering evaluation on fracture toughness without discussion or justification and is not contained in the ITS 3.4.9 Bases. Adding a discussion to the Bases that fracture toughness will be a topic of the continued operation determination would clarify the issue if the intent is to combine the two CTS requirements into one in the ITS.
t l BNP ITS 3.4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS i ITEM # DOC CTS /STS1 '
' DESCRIPTION OF ISSUEi DATE! DATE' ' COMMENTS ~
or) . REF . OPENEDi . CLOSED.- [ JFDQ c - l 3.4.9-2 A.4 CTS 3.4.1.3 CTS 3.4.1.3.a specifies a differential i temperature limit between the " reactor ! ITS SR 3.4.9.4 coolant within the dome" and the ! ITS SR 3.4.9.5 " bottom head drain line". ITS SR l 3.4.9.4 specifies this differential [ temperature limit as between the STS SR " reactor pressure vessel (RPV) coolant j 3.4.10.3 temperature" and the " bottom head ! STS SR coolant temperature". This terminology . 3.4.10.4 is different. No discussion is provided - to establish the equivalency of these j two differential temperature t measurements or justify the difference. t i 3.4.9-3 M-2 ITS 3.4.9 (1) M-2 discussion - do not exceed the l minimum? : (2) Granted that the 30 minute and 12 l hour frequencies are more restrictive i requirements but are they sufficiently j restrictive at this plant to accomplish ! the intended purpose? , f 3.4.9-4 Non ITS Figures Minimum reactor vessel metal temp as i e 3.4.9-1,2,3 measured where? On the limiting and 4. component for that portion of the j curve? 3.4.9-5 A.1 ITS Figures Curves modified Contingent on NRC l 3.4.9-1,2,3, acceptance of TSC l and 4. 95TSB06. (91in conversion cover letter) l 1
t BNP ITS 3.4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS ITEM # DOC- CTS /STS - DESCRIPTION. OF ISSUE 4 DATE .DATE:. ' COMMENTS or ' REF:
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OPENED . CLOSED. JFD j
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u 3.4.9-6 LA.3 CTS 3.4.1.3.c CTS 3.4.1.3.c specifies recirculation ; system operational limits based on ITS SR 3.4.9.5 differential temperature, and operating loop flow values. ITS SR 3.4.9.5 STS SR requires that the differential temperature f' 3.4.10.4 limits be maintained, but deletes the single loop operating flow limits. This operation limit is moved to plant procedures but the procedures are not i identified. i r I [ i i t I i i
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BNP ITS 3.5.1 ECCS - OPERATING - j i ITEM # DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE( . 1 COMMENTS , . or- . REF= OPENED- CLOSED l- ,.
-JFOR : -
3.5.1-1 LD.3 CTS 4.3.3.3 CTS 4.3.3.3 requires RESPONSE TIME GL 91-04 update, contigent i TESTING for the ECCS functions every 18 on NRC acceptance dunng l JFD.10 ITS 3.5.1.12 months. ITS 3.5.1.12 requwes RESPONSE instrumentation review. TIME TESTING for the ECCS injection / spray subsystem every 24 months. This change extends the surveillance test interval from [ 18 months to 24 months. I 3.5.1-2 A.2 CTS 4.3.3.3 CTS 4.3.3.3 requires RESPONSE TIME TESTING for the ECCS functions. ITS ITS 3.5.1.12 3.5.1.12 exempts ECCS instrumentation from respc ise tinte testing and allows using ! the design instrumentation response time in ! determining the ECCS RESPONSE TIME. The ECCS instrumentation was deleted based on the NEDO-32291-A, " System :* Analysis for Elimination of Selected Response Time Testing Requirements" results. Is this justification consistent with the NRC's most recent approval of the use of the topical report for Brunswick?
i BNP ITS 3.5.1 ECCS - OPERATING ITEM # ' DOC # CTS /STS .. DESCRIPTION OF ISSUE. 'DATE DATEL COMMENTS ~ or REF OPENED CLOSEDc JFD# 3.5.1-3 L.2 CTS 3.5.1 ITS 3.5.1 adds Required Actions G.1, Beyond scope, seperate > G.2, E.1, E.2, H.1, and H.2, not included in NRC review required. ^ CTS 3.5.2 the CTS for en inoperable ADS valve j coincident with an inoperable low pressure ECCS injection / spray system; an inoperable t HPCI System coincident with an inoperable low pressure ECCS injection / spray ' subsystem; and an inoperable ADS valve t coincident with the HPCI System. ITS 3.5.1 Actions E.1, E.2, G.1, G.2, H.1, and H.2 all have Completion times of 72 hours, CTS 3.5.1 and CTS 3.5.2 require entering l CTS 3.0.3 for the same conditions. CTS ! 3.0.3 requires placing the plant in HOT SHUTDOWN in 6 hours and COLD j SHUTDOWN within the following 30 hours. These changes were implemented based on l NEDC-31624P, " Brunswick Steam Electric I l t Plant Units 1 and 2 SAFER /GESTR-LOCA i Loss-of-Coolant Acck.i Analysis," ' Revision 2, July 1990. The Completion Times are based on a reliability study (Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC), " Recommended interim Revisions to LCOs for ECCS Components," December 1,1975. , i i i t [ l
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_ _ _ _ _ _ _ _ . . ~ . ._ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - _ _ - . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ BNP ITS 3.5.1 ECCS - OPERATING i ITEM # DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPENED CLOSED JFD# 3.5.1-4 JFD.3 STS 3.5.1 ITS 3.5.1 adds Required Actions H.1 and Beyond scope, separate H.2 that provide Actions when one required NRC review required. ADS valve is inoperable with the HPCI
- system inoperable. This requirement is not included in the CTS or STS. Implementing these changes is based on the capability of mitigating design basis accidents and transients. Including these actions result in a single failure having the potential for failing a safety function. Including these .
Actions is not consistent with the CTS or I STS. 1 3.5.1-5 A.2 CTS 4.3.3.3 CTS 4.3.3.3 requires performing ECCS See comment #2 above. response time testing. ITS 3.5.1.12 adds a note that allows design instrumentation response time testing assumed for the instrumentation response time testing. STS 3.5.1 Surveillance Requirements do not , include this allowance. i I t _.__--._-__._.____.~_----_-.2- . _ . . _ - _ _ - - - . _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ - - _ _ - - - _ _ _ _ _ - _ _ _ . - - - . _ _ _ - . _ , - _ _ _ - - - - - - - - _ . . . _ _ - _ _ _ . - . - _ - . - - _ _ . _ - _ - _ _ . - _ - . - - _ . _ _ . _ _ _ - - - - - _ _ - - -
BNP ITS 3.5.1 ECCS - OPERATING ITEM # - DOC # CTS /STS DESCRIPTION OF ISSUE-' DATE DATE '- ' COMMENTS or -- REF OPENED CLOSED JFD#- 3.5.1-6 L.11 CTS 4.5.1.b CTS 4.5.1.b requires verifying the HPCI The upper pressure limit System capable of developing required flow change is accepted for a system head corresponding to a contingent on the NRC reactor pressure of a 1000 psig when accepting the TSC steam is supplied at 1000 + 20, -80 psig. 94TSB16 power uprate. ITS SR 3.5.1.7 changes the CTS requirements and requires verifying flow , with steam supply pressure at 1025 and with reactor pressure s 1045 psig and 2 945 psig, the HPCI pump unit capable of developing required flow against a system head corresponding to reactor pressure. The ITS changes the upper pressure limits from steam supply pressure of 1020 psig maximum to 1025 psig and reactor , pressure from a maximum of 1020 psig to 1045 psig based on TSC 94TSB16 power i uprate.
t BNP ITS 3.5.1 ECCS - OPERATING
. ITEM # - ' DOC # CTS /STS DESCRIPTION OF ISSUE . ' DATE . DATE: ~ ICOMMENTS or REF- OPENED ' CLOSED' JFD# - t 3.5.1-7 L.11 CTS CTS 4.5.1.c.2 requires verifying the HPCI 4.5.1.c.2 System capable of developmg required flow
' for a system head corresponding to a reactor pressure a 165 psig when steam is i supplied at 165 i 15 psig. ITS SR 3.5.1.8 requires verifying, with reactor pressure '
s 180 psig, the HPCI pump unit capable of developing required flow against a system , head corresponding to reactor pressure. ITS SR 3.5.1.8 Bases states reactor ; pressure should be greater than or equal to 150 psig. Is one, the other or both the limit and what is the basis for the limit? 3.5.1-8 LD.1 CTS 4.5.1.c CTS 4.5.1.c requires performing ECCS GL 91-04 update, system testing at least once per 18 contingent on NRC JFD.10 months. ITS SR 3.5.1.8 and SR 3.5.1.9 acceptanceduring instrumentation review. changes the frequency to every 24 months. , This is a change to the surveillance test interval. i
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I f i BNP ITS 3.5.1 ECCS - OPERATINC ITEM # DOC #f_ CTS /STS DESCRIPTION OF ISSUE DATE DATE= '
. COMMENTS ~ ~
i or. .REF 7 OPENED ~ CLOSED - JFD# 3.3.1-9 L.5 CTS 3.5.2 ITS 3.5.1 reduces the number of ADS Beyond scope, separate , valves required OPERABLE in CTS 3.5.2 NRC review required. from seven to six. This change is based on the analysis summarized in NEDC-31624P,
" Brunswick Steam Electric Plant Units 1 and 2 SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis," Revision 2, July 1990.
3.5.1-10 L.6 CTS 3.5.2 ITS 3.5.1 increases the pressure at which Beyond scope, separate ! ADS is required OPERABLE, as stated in NRC review required. CTS 3.5.2, from 113 psig to 150 psig. 1 This change is based on NEDC-31624P, -
" Brunswick Steam Electric Plant Units 1 and 2 SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis," Revision 2, July 1990.
i 3.5.1-11 LD.2 CTS 3.5.2 CTS 4.5.2.s and 4.5.2.b specify a once per !.i. 91-04 update contigent 18 months frequency for the ADS system .m NRC acceptance durinp I JFD.10 functional test and manual operation of e
- m.entdm review.
- each ADS valve. ITS SR 3.5.1.10 and ITS SR 3.5.1.11 specify a 24 month Frequency for these tests. This is a change in surveillance frequency.
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BNP ITS 3.5.1 ECCS - OPERATING ITEM # DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATEL COMMENTS or .REF= OPENED. CLOSED;- JFO#2 3.5.1-12 L.7 CTS 3.5.3.1 CTS 3.5.3.1 requires restoring an Contingent on PRA LCO CTS 3.5.3.2 inoperable CS subsystem OPERABLE in 7 time extension. : days if both LPCI subsystems are STS 3.5.1 OPERABLE or be in Hot Shutdown within 12 hours and Cold Shutdown in 24 hours.
- CTS 3.5.3.1 also requires Hot Shutdown in !
12 hours and Cold Shutdown in 24 if both CS subsystems are inoperable. CTS '- 3.5.3.2 requires the same actionn for the LPCI system if the subsystem or I.PCI ; pumps are inoperable. The ITS ct_anges the ; CTS requirements to require restoring inoperable subsystems OPERABLE in 7 days for one low pressure ECCS injection / spray subsystem inoperable or one LPCI pump in , each subsystem inoperable. The ITS also i adds Action B for cases when one LPCI pump is inoperable and one core spray subsystem is inoperable that allows 72 hours to return one component or ; subsystem OPERABLE. These changes allow more than one LPCI and Core Spray ; subsystem or pumps inoperable at the same time which deviates from the current licensing basis and the STS. l B I i
BNP ITS 3.5.1 ECCS - OPERATING ITEM # - DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE: COMMENTS or REF OPENED CLOSED JFD# 3.5.1-13 L.9 CTS ITS SR 3.5.1.6 revises the CTS 4.5.3.1.c.1 "ayond scope, separate
- 4.5.3.1.c.1 and CTS 4.5.3.2 h low pressure ECCS NRC review required.
4.5.3.2.b pump flow acceptance criteria from 17,000 ; gpm to 14.000 gpm for each LPCI loop (2 LPCI pumps) and from 4625 gpm to 4100 , gpm for each core spray pump. This ' change is based on the plant analysis summarized in NEDC-31624P, " Brunswick Steam Electric Plant Units 1 and 2 SAFER /GESTR-LOCA Loss-of-Coolant i Accident Analysis," Revision 2, July 1990. 3.5.1-14 LC.1 CTS 4.5.3.1.c.2 requires performing a CHANNEL 4.5.3.1.c.2 CAUBRATION on the core spray header AP instrumentation. ITS 3.5.1 deletes this ITS 3.5.1 requirement. This Surveillance is moved to : plant procedures. Changes to the i requirements in plant procedures are controlled according to 10 CFR 50.59. The ; justification does not identify the ! procedures containing the Surveillance . Requirement. 3.5.1-15 L.1 ITS SR The CTS required the SR during cold 3.5.1.5 shutdown. The ITS allows it to be performed prior to 25% RTP. Was there a specific reason CTS limited this SR to cold shutdown? l
BNP ITS 3.5.1 ECCS - OPERATING ITEM # - DOC # CTS /STS - DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPENED '~ CLOSED
-JFD# -
3.5.1-16 JFD.3 STS 3.5.1 The ITS adds a new ACTION B that was Provide justification for the not included in the STS. ITS 3.5.1 ACTION STS deviation based on B provides ACTION requirements for one current licensing basis. LPCI pump and one core spray (CS) subsystem inoperable. The ACTION allows 72 hours to return the LPCI pump or CS subsystem OPERABLE. This change was included to allow various combinations of ECCS subsystems and components inoperable for 72 hours. 3.5.1-17 None CTS 3.5.2.b CTS 3.5.2.b identify actions for two or See comment #9 bbove, more inoperable ADS valves. STS 3.5.1 STS 3.5.1 ACTION H requires action if one or more ADS valves and HPCI are inoperable. The , ITS changes the number of inoperable ADS valves to two before requiring action. The ITS decreases the number of required OPERABLE ADS valves from seven to six Implementing the two inoperable ADS valves changes the CTS requirements so that actions may be required when three or more ADS valves are inoperable. This change does not appear to be within the current licensing basis. l i
BNP ITS 3.5.2 ECCS - SHUTDOWN ITEM # DOC # CTS /STS DESCRIPTION OF ISSUE _ DATE' DATE. ~ COMMENTS [' or REF OPENED CLOSEDj ;
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'JFD#- .
3.5.2-1 L.2 CTS CTS 4.5.3.1.c.1 CS pump flow acceptance Beyond scope, also affects l 4.5.3.1.c.1 criterion is revised in ITS SR 3.5.2.5 from L.4 discussion. !
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4625 gpm to 4100 gpm for each required CS ITS SR pump. This change is imp 8emented based on ! 3.5.2.5 the plant analysis summarized in NEDC-31624P, " Brunswick Steam Electric Plant ; Units 1 and 2 SAFER /GESTR-LOCA Loss-of- l Coolant Accident Analysis," Revision 2, July i i 1990. I t 3.5.2-2 LD.1 CTS 4.3.3.3 CTS 4.3.3.3 specifies the frequency for Generic Letter 91-04 ECCS RESPONSE TIME testing as once every update, contmgent on NRC : ITS 18 months. In ITS SR 3.5.2.7, the acceptance dunng : SR 3.5.2.7 Frequency for ECCS RESPONSE TIME testing instrumentation review. [ is every 24 months. This change extends i the surveillance interval. .J 3.5.2-3 M.4 ITS 3.5.2 1) Explain why 20 feet 6 inches above spent ; fuel is more restrictive than 23 feet above j fuel in RPV. 2) Why is 21 feet 10 inches ! slightly more conservative and 3) in the 0 it .[ should be 1 and 1/16 not 1 and lif. ! l 3.5.2-4 L.3 ITS 3.5.2 ECCS injection into the vessel is prohibited in : CTS and allowed in ITS. L.3 does not f , explain why the specific prohibition was in ! there or why it is now ok to inject into the ; I vessel. . i f
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_ . . _ _ _ ____. _ . _ _ _.__ .. _ -. _ . _ .__ ...m._ _ i BNP ITS 3.5.2 ECCS - SHUTDOWN i i ITEM # ~ DOC # CTS /STS . , DESCRIPTION.0F ISSUE - DATE :. .DATE . L COMMENTS or; .REF: OPENED .. CLOSEDf - JFD#' 3.5.2-5 LD.2 CTS 4.3.3.3 CTS 4.3.3.3 requires performing ECCS GL 91-04 update, response time testing once per 18 months. contmgent on NRC ITS 3.5.2.7 adds requires ECCS design acceptance during instrumentation response time testing once instrumentation review. per 24 months. This is a change in the i surveillance test interval. 3.5.2-6 A.7 CTS 4.3.3.3 CTS 4.3.3.3 requires performing ECCS See comment #7 below. response time testing. ITS 3.5.1.12 adds a note that allows design instrumentation response time testing assumed for the instrumentation response time testing. STS 3.5.1 Surveillance Requirements do not include this allowance. l i i 3.5.2-7 A.7 CTS 4.3.3.3 CTS 4.3.3.3 requires RESPONSE TIME TESTING for the ECCS functions. ITS 3.5.2.7 exempts ECCS instrumentation from response time testing and allows using the design instrumentation response time in determining the ECCS RESPONSE TIME. The ECCS instrumentation was deleted based on the NEDO-32291-A, " System Analysis for , Elimination of Selected Response Time Testing Requirements" results. zls the
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justification consistent with the most recent NRC approval of the use of this topical report at Brunswick? t
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I BNP ITS 3.5.3 RCIC SYSTEM ITEM # DOC # CTS /STS DESCRIMION OF ISSUE : DATEL DATE; COMMENTS or. REFT OPENED. CLOSED JFD#. ! 3.5.3-1 JFD.9 CTS 4.7.4.b CTS 4.7.4.b requires verifying the RCIC The upper pressure limit System capable of developing required flow
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change is accepted ITS for a system head corresponding to a reactor contingent on the NRC l SR 3.5.3.3 pressure at operating pressure when steam is accepting the TSC - supplied at 1000 + 20, -80 psig. ITS 94TSB16 power uprate. ' SR 3.5.3.3 changes the CTS requirements i and requires verifying flow with reactor l pressure with reactor pressure s 1025 psig and 2: 945 psig and steam supply pressure equal to the reactor pressure. [ i The ITS changes the upper pressu e limits from steam supply pressure of 1020 psig j maximum to 1025 psig and the lower limit ; from 920 to 945 psig based on TSC ; 94TSB16 power uprate. The change to the pressure limits was based on a document not available for review. i 3.5.3-2 LD.1 CTS 4.7.4.c CTS 4.7.4.c requires performing RCIC GL 91-04 update, functional testing once per 18 months. ITS contingent on NRC l 3.5.3.4. and 3.5.3.5 requires RCIC testing acceptance during once per 24 months. This is a change in the instrumentation review. i surveillance test interval. t i
BNP ITS 3.5.3 RCIC SYSTEM M# DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS or ' REF OPENED - CLOSED JFD# 3.5.3-3 L.2 CTS CTS 4.7.4.c.1 requires verifying RCIC 4.7.4.c.1 System operation in a functional test once per 18 months. ITS SR 3.5.3.5 changes the test to take credit for actual demands as functional tests. The justification does not demonstrate the methods that assure required parameters and verifications are ; obtained and performed.
4 BNP ITS 3.6.1.1 PRIMARY CONTAINMENT ITEM . DOC // CTS /STS DESCRIPTION'0FIISSUE. DATE DATE].- COP 91ENTS . N0; JFDr - LCO:' OPENED CLOSED: , 3.6.1.1-1 A.4 CTS 4.6.1.2 CTS 4.6.1.2.1 requires 6/13/97 Licensee to update JFD 2 STS SR leak rate testing in submittal with regards Bases 3.6.1.1.1 accordance with the to 11/2/95 letter and JFD 3 ITS SR Containment Leakage updated TSTF 52 when + Bases 3.6.1.1.1 Rate Testing Program. OG provides revision JFD 9 and STS SR 3.6.1.1.1 or provide additional Associated requires the visual justification for Bases examination and leakage deviations. rate testing be performed in accordance with 10 CFR 50 Appendix J as modified by approved exemptions. ITS SR 3.6.1.1.1 modifies STS SR 3.6.1.1.1 to conform to . CTS 4.6.1.2.1. The STS is based on Appendix J , Option A while the , CTS /ITS are based on Appendix J, Option B. : Changes to the STS with regards to Option A versus Option B are ; covered by a letter from Mr. Christopher I. Grimes to Mr. David J. Modeen, NEl dated l 11/2/95 and TSTF 52. The ITS changes are not in conformance with the ! letter or TSTF 52 as modified by staff f comments. 1
~_ . - - . . - .- - -. . . - -- . . _ .
BNP ITS 3.6.1.1 PRIMARY CONTAINMENT
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ITEMi ~ DOC / ' CTS /STS: DESCRIPTION OF[ ISSUE :m. DATE:-
, DATEl . 'ComENTS) m' NO. . J0Di LCO - OPENED" CLOSED 2 3.6.1.1-2 A.8 CTS CTS 4.6.2.1.e.2 6/13/97 Delete this generic JFD 3 4.6.1.1.e.2 requires conducting a change. ;
STS SR drywell-to-suppression 3.6.1.1.2 chamber bypass leak i ITS SR test at an initial - 3.6.1.1.2 differential pressure of 1 psig. STS SR 3.6.1.1.2 specifies an initial differential pressure of 1 psid. ITS SR 3.6.1.1.2 specifies an initial differential pressure range of 2 1.00 psid and s 1.25 psid. The ITS addition of "and s 1.25 psid" is considered a generic change and is beyond the scope of review for this conversion. , 2
i BNP ITS 3.6.1.1 MIMARY CONTAllWENT
~ ITEM? .v DOC /IN ' CTS /STS.S~' ~ DESCRIPTION OFZISSUEi '
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DATE L.' , ^ DATESL C0fMENTS E ,W' NO. + % :JFD/ LC0 ' - ' - - OPENEDb CLOSEDi ~ 3' F ' ~ 4 3.6.1.1-3 M.1 CTS 3.6.1.2 CTS 3.6.1.2 ACTIONS, 6/13/97 Modify M.1 to reflect ! ACTIONS CTS 3.6.1.4 ACTIONS, the correct ! CTS 3.6.1.4 and CTS 3.6.2.1 ACTION interpretation of the ! ACTIONS c prevent reactor Action statements. i CTS 3.6.2.1 operation above RCS See Item Number < ACTION c temperature of 212* F, 3.6.1.1-4. ! if containment leakage, [ containment structural i integrity, and drywell i to suppression chamber ; leakage are not within limits. N.1 states that the CTS ACTIONS would allow a startup t and control rod ! withdrawal from cold ; shutdown (s 212* F) ! with Primary Containment structural integrity and leakage rates outside of limits. This N.1 i statement implies that -l operation can continue ! above 212*F which is not true. See Ites ; Number 3.6.1.1.4. ' 3 i
BNP ITS 3.6.1.1 PRIMARY CONTAINMENT ITEM .'. ' DOC /J CTS /STS DESCRIPTION.0F11SSUE' DATE= < DATEi . ;CoptiENTS; N0;
~JFD4' LCO ~ ' OPENED ^ CLOSEDi -
3.6.1.1-4 M.1 CTS 3.6.1.2 CTS 3.6.1.2 ACTIONS, 6/13/97 Provide additional ACTIONS CTS 3.6.1.4 ACTIONS, discussion and CTS 3.6.1.4 and CTS 3.6.2.1 ACTION justification for this i ACTIONS c prevent reactor less Restrictive CTS 3.6.2.1 operation above a RCS change. ACTION c temperature of 212' F ITS 3.6.1.1 if containment ACTIONS structural integrity , and leakage rates are outside limits. M.1 1 states the following:
"Should leakages above '
limits be discovered while operating, CTS ACTIONS are non-specific as to the appropriate action to take. Therefore, the i appropriate action would be to declare Primary Containment integrity not met and take the ACTIONS of CTS J.6.1.1." This is an incorrect statement. . Tne appropriate action to take is CTS 3.0.3. l Tlierefore ITS 3.6.1.1 ; ACTIONS are less [ Restrictive than the i CTS ACTIONS. ,
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BNP ITS 3.6.1.1 PRIMARY CONTAINMENT ITEM; -DOC /v. CTS /STS; DESCRIPTION l0FLISSUEs 'DATE . DATE!.. CONiENTSL , NO . - 'JFD " LCO ~ OPENED' CLOSED" 3.6.1.1-5 Bases ITS ITS B3.6.1.1 Bases SR 6/13/97 Revise the Bases JFD 3 B3.6.1 I 3.6.1.1.1 has an insert discussion to confom Bases- (insert B 3.6.1.1-2) to Amendment 181 and SR which specifies the 213 Bases / Program 3.6.1.1.1 exemptions to RGl.163 discussions or provide and NEI 94-01. additional discussion Amendments 181 for Unit and justification to I and 213 for Unit 2 that these exemptions implement 10 CFR 50 to the RG and NEI 94-Appendix J Option B at 01 were approved by Brunswick. Insert the staff. See Item B3.6.1.1-2 does not 3.6.1.1-1. conform to (insert item a) and contains additional exemptions (insert items b and c) not contained in the amendment TS changes, TS Bases changed, and ' associated staff safety evaluations. These changes may be beyond the scope of review items. See item Number 3.6.1.1-1. e 6
BNP ITS 3.6.1.1 PRIMARY CONTAINMENT ITEM- DOC /3 CTS /STS1 DESCRIPTION OF;ISSUEi .DATEf. DATEk$; 8009fENTS : , NO.- -
'JFD/ LCO.-
OPENED- CLOSED 3 -
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L 3.6.1.1-6 Bases STS STS B3.6.1.1 Bases- 6/13/97 Revise the statement JFD 7 B3.6.1.1 APPLICABLE SAFETY - accordingly. Bases- ANALYSES states APPLICABLE " Primary containment SAFETY satisfies Criterion 3 ANALYSES of the NRC Policy ITS Statement." ITS B3.6.1.1 83.6.1.1 Bases-Bases APPLICABLE SAFETY APPLICABLE ANALYSES changes this SAFETY by deleting "NRC Policy ANALYSES Statement" and replacing it with
" Reference 5." Ref. 5 is 10 CFR 50.36 (c)(2)(11). A similar change is made in all other sections of ITS B3.6. This change is incorrect; the correct change should replace "NRC Policy Statement" with "10 CFR 50.36 (c)
(2)(11)". Reference 5 in the references may be retained if desired. 6
BNP ITS 3.6.1.1 PRIMARY CONTAIMENT
- ITEM!. DOC /" -
/ CTS /STS. . DESCRIPTION OF;ISSUEi DATEE.. DATEh.. ComENTS9 NO. - JFD LCO -.' OPENED' CLOSED 9 3.6.1.1-7 Bases STS STS B 3.6.1.1 Bases - 6/13/97 Delete this change.
JFD 8 B3.6.1.1 SR 3.6.1.1.1 states Bases- that failure to meet SR MSIV leakage (STS SR 3.6.1.1.1 3.6.1.3.13) does not ITS necessarily result in a B3.6.1.1 failure of STS SR f Base 3.6.1.1.1. ITS , SR 83.6.1.1 Bases- SR
- i 3.6.1.1.1 3.6.1.1.1 deletes this item. However STS SR 3.6.1.3.13 is retained !
in the ITS as ITS SR ; 3.6.1.3.9. Therefore, : tv %1etion is ; unt 4eptable. t r i 7 . i
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BNP ITS 3.6.1.2 PRIMARY CONTAINMENT AIR LOCK LITEM DOC / a CTS /STSL DESCRIPTION,0FISSUEi ' DATEE .DATE6 COMENTSi ~ NO.' & 'JFD.' LC01 OPENED CLOSED ~ w 3.6.1.2-1 A.4 CTS See Item Number 3.6.1.1-1 6/13/97 See Item Number JFD 2 4.6.1.3.b 3.6.1.1-1 JFD 3 ITS SR 3.6.1.2.1
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Bases JFD 1 and Bases Associated JFD 3 Bases 3.6.1.2-2 L.3 CTS CTS 3.6.1.3, ACTION a.1 6/13/97 Provide additional 3.6.1.3 requires " maintaining" at discussion and , ACTION a.1 least the OPERABLE air justification for ITS lock door closed and this More 3.6.1.2 either restore the Restrictive change. RA A.1 inoperable air lock door to OPERABLE status within 24 hours or lock the OPERABLE air lock door closed. ITS 3.6.1.2 RA A.1 requires " verifying" the OPERABLE door is closed within 2 hours. The CTS does not require that the door is verified closed within 2 hours. ! The additional ! requirement to verify the ) OPERABLE door closed within 2 hours is a More Restrictive change. 1 _ _ _ . _ - _ _ _ . _ . . - . _ _ _ . _ _ _ _ . _ _ . _ _ . _ _ _ _ . _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . __.______m__ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ . _ _ . _ _ _ _ . _ _ _ . _ _ . - - _ _ _ _ _
_- - .- . - . . -.... _ _ __ _ . . . . - _ . - _ _ . _ _ - _ _ _ .~ . - _ BNP ITS 3.6.1.2 PRIMARY CONTAINMENT AIR LOCK ITEM- DOC /) CTS /STS DESCRIPTION OF ISSUE DATE' DATE~, COMMENTS. No. JFD LCO OPENED- CLOSED 3.6.1.2-3 Bases ITS ITS B3.6.1.2 Bases SR 6/13/97 Revise the Bases JFD 1 B3.6.1.2 3.5.1.2.1 has an insert discussion to Bases Bases- (Insert B3.6.1.2-1) which conform to Amendment JFD 3 SR spec *fies the exemption 181 and 213 3 $ 1.2.1 to RG 1.63 and NEI 94-01. Bases / Program Amendment 181 for Unit I discussions. See and 213 for Unit 2 Item Number 3.6.1.1-implemeats 10 CFR 50 1 and 3.6.1.1-6. Appendix J Option B at BNP. Insert B3.6.1.2-1 does not conform to the i amendment TS changes, TS , Bases changes, and associated staff safety evaluation. See Item Numbers 3.6.1.1-1 and 3.6.1.1-6. , 3.6.1.2-4 Bases STS SR STS SR 3.6.1.2.2 requires 6/13/97 Licensee to update JFD 6 3.6.1.2.2 verifying only one door submittal to be in and in the air lock will open accordance with TSTF Associated at a time at six month 17 or provide Bases intervals. The interval additional ITS SR is modified in the ITS SR justification for 3.6.1.2.2 3.6.1.2.2 from 6 months the deviations. and to 24 months. This Associated modification is in Bases accordance with TSTF 17; i however, the Bases changes are not in accordance with TSTF 17. 3.6.1.2-5 Bases ITS See Item Number 3.6.1.1- 6/13/97 See Item Number JFD 7 B3.6.1.2 6. 3.1.1-6. Bases . ! APPLICABLE SAFETY ANALYSES 2 i
BNP ITS 3.6.1.2 PRIMARY CONTAINMENT AIR LOCK ITEM-:: m DOC / CTS /STSL . DESCRIPTION.0F : ISSUE . DATEi DATEJ. .C0tWENTSJ
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NO.. JFD: LCO- OPENED- CLOSED: - 3.6.1.2-6 Bases STS STS B3.6.1.2 Bases- 6/13/97 Delete the change. JFD 9 B3.6.1.2 ACTIONS states the Bases following: "The ability ACTIONS to open the OPERABLE ITS door..." ITS B3.6.1.2 B3.6.1.2 Bases-ACTIONS changes Bases " ability" to " allowance". ACTIONS The justification cited is for typographical / grammatical errors. The staff does not believe this is a typographical / grammatical error. 3.6.1.2-7 Bases STS STS B3.6.1.2 Bases- 6/13/97 Delete this change. JFD 9 B3.6.1.2 ACTIONS states the Bases- following: " Pursuant to ACTIONS LCO 3.0.6, actions are ITS not required..." ITS B3.6.1.2 B3.6.1.2 Bases-ACTIONS Bases capita 11zes the word ACTIONS " Action". Based on the sentence, the word
" action" in this case is not the defined ters
, which would require capitalization.
t 3
BNP ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)
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ITEM) DOC / CTS /STS DESCRIPTION [0FISSUE- DATE D . _ . :DATEL.. ..COPMENTS NO.- JFDL LCO ' OPENED? CLOSEDi - ' 3.6.1.3-1 M.2 STS SR ITS SR 3.6.1.3.8 is a new SR 6/13/97 Provide < JFD 3 3.6.1.3.11 that has been added to BNP additional Bases ITS SR ITS. The frequency for this discussion and JFD 8 3.6.1.3.8 SR is "In accordance with the justification on and . Inservice Testing Program". ITS SR 3.6.1.3.8 Associated STS SR 3.6.1.3.11 is the STS frequency Bases equivalent to ITS SR deviation from 3.6.1.3.8. The frequency for the STS. this SR is "18 months on a :' STAGGERED TEST BASIS." Inadequate justification is provided with regards to the changing of the SR frequency from "18 months on a STAGGERED TEST BASIS" to "In i accordance with the IST , Program." The staff cannot , determine if the two frequencies are equivalent, l or More Restrictive or less Restrictive as compared to Ieach other. l l i 1
. _ _ . _ _ -_ _ _ . _ _ _ _ _ _ _ . . . _ . . . . _ _ - . _ _ __ -_ . _ . . _ _ _ _ _ . . . . . ~- -_ .
BNP ITS 3.6.1.3 PRIMARY CONTAINNENT ISOLATION VALVES (PCIVs) ITEM! DOC / - CTS /STS DESCRIPTIONIOF ISSUE "~ ~ DATE L DATE9 , :COPMENTS No.~ : 'JFDr LCO ' - OPENED- CLOSEDi - 3.6.1.3-2 N.3 CTS CTS 3.6.1.2 specifies the 6/13/97 Delete this JFD 9 3/4.4.7 MSIV leakage limits and generic change. Bases CTS remedial actions to take upon See Item Number ! JFD 8 3.6.1.2 discovery of leakage rates 3.6.1.3-3. . CTS 3.6.3 exceeding specified limits. ACTION a CTS 3/4.4.7 provides STS additional operability 3.6.1.3 requirements, remedial ACTION D actions and associated times and in which to complete the ! Associated repairs and retests Bases associated with an inoperable ! ITS MSIV due to anything but 3.6.1.3 leakage. The repair time per ACTION D CTS 3/4.4.7 is 8 hours. ITS and 3.6.1.3 Condition D changes Associated STS 3.6.1.3 Condition D from Bases " Secondary containment bypass
- 1eakage rate not within limit to "One or more penetration ;
flow paths with NSIV leakage not within limits." Based on STS B 3.6.1.3 Bases RA D.1 > discussion, STS 3.6.1.3 Condition D includes both secondary containment and , NSIV leakage. Therefore, the proposed change to Condition D is acceptable. However, + the change of the Completion . Time ! l l i
i BNP ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs) ITEM DOC /h CTS /STSi . DESCRIPTION'0FilSSUE^ DATE4 DATEL . .COPMENTS -~ - . No. JFD; -LCO-OPENED: -CLOSED: t1 associated with RA D.1 from 4 hours to an ITS time of 8 hours is not adequately justified. The justification used is consistency with the Completion Time of CTS 3.4.7 ACTION, CTS 3.6.3 ACTION a, and ITS 3.6.1.3 RA A.I. In addition this change in + Completion Time is less Restrictive than current j licensing basis (See Item
> Number 3.6.1.3-3). The Completion Time associated with STS 3.6.1.3 RA D.1 takes into account the safety i significance of containment ;
leakage versus valve inoperability. Thus the STS Completion Time for leakage is less than the Completion , Time for an inoperable MSIV. 1' In addition, the staff finds this change to be generic and beyond the scope of review for a conversion. 3.6.1.3-3 M.3 CTS See Item Numbers 3.6.1.1-3 6/13/97 See Item Numbers 3.6.1.2 and 3.6.1.1-4 3.6.1.1-3 and ACTIONS 3.6.1.1-4. 3.6.1.3-4 LD.3 CTS See Item Number 3.6.1.1-1 6/13/97 See Item Number JFD 2 4.6.1.2.2 3.6.1.1-1 Bases ITS SR JFD 1 3.6.1.3.9 Bases and JFD 3 Associated Bases 3 t _ _ - - _ _ _ . - _ _ _ _ _ - - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - - - _ _ - - _ _ _ - _ . - - - - --,e-a- . -.- <-,- -< - - - ~
BNP ITS 3.6.1.3 PRIMARY CONTAIMENT ISOLATION VALVES (PCIVs)
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' ITEMS ~ d 00Cjk/b CTS /STSi DESCRIPTION (OF) ISSUE] DATEJ .
OPENE0, :DATEY[ [- ltofMENTS$^~W
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NOR JFD~ - LCO , ' s '
^ -
4 CLOSEDi - < " 3.6.1.3-5 JFD 7 STS STS 3.6.1.3 ACTIONS Note 4 6/13/97 Delete this 3.6.1.3 requires entering applicable generic change. ACTIONS Conditions and Required Note 4 Actions of ITS 3.6.1.1, ITS " Primary Containment," when 3.6.1.3 PCIV leakage results in ACTIONS exceeding overall containment Note 4 leakage rate acceptance criteria in MODES 1, 2, or 3. ITS 3.6.1.3 ACTIONS Note 4 deletes the Note applicability restriction of "in MODES 1, 2, or 3." The STS Note applicability , restriction was added to i clarify that the Note only applied in MODES 1, 2, and 3 and not to the full STS ! APPLICA8ILITY of MODES 1, 2, ' and 3 and "when associate ! instrumentation is required . . to be OPERABLE per LCO 3.3.6.1, which could include MODES 4 and 5. ITS 3.6.1.3 i APPLICA8ILITY includes all STS APPLICABILITY. ITS LCO 3.3.6.1 " Primary Containment i Isolation Instrumentation," ; adds a MODE 4 and 5 requirement to the RHR Shutdown Cooling System isolation valves. ' OPERABILITY of these valves i precludes an inadvertent ! draindown of the reactor vessel through the shutdown cooling isolation valves and i e f 4 , . _ _ _ . _ _ _ _ . . . _ _ _ _ _ _ ______ _ _ _ .__._-___.___....m_ _ _ . _ _ _ - __ ..._.__._.____mm._._=.__________.m._____..___________m.____._______m_.__.________.______.___m______ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ .
l t BNP ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs) j
. . . ..? . . .
CofflENTSj ,;f,
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ITEM). . , DOC /t CTS /STS .. DESCRIPTION 0F!!SSUEi - DATE h DATEfati , i No. JFD ^ LCO ~ . OPENEDM CLOSEDO lowering reactor vessel level to the top of the fuel. , Because of this, the Note clarification "In MODES 1, 2, ! i or 3" needs to be retained. In addition, the wording of the justification (JFD 7) ! would make the change a i generic change which is i beyond the scope of review for this conversion. j 3.6.1.3-6 JFD 12 STS SR STS SR 3.6.1.3.2 requires 6/13/97 Provide ! Bases 3.6.1.3.2 that each containment purge additional JFD 8 STS SR valve be verified closed on a justification 3.6.1.3.15 31 day frequency. STS SR and discussion : and 3.6.1.3.15 requires that to show why Associated certain containment purge these two STS i Bases valves be restricted or SRs should not I 1 blocked from fully opening so be included in that they can be closed the ITS. automatically within the
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appropriate closure time. t The ITS does not include j these two SRs. The Bases for i their deletion was a staff SER dated 9/18/84, which found the valves were demonstrated to be OPERABLE. However, ITS B3.6.1.3 Bases states that the purge valves
- are normally closed. Based . !
on this statement it seems that STS SR 3.6.1.3.2 should be included and also possible SR 3.6.1.3.15. i 5
BNP ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)
- DESCRIPTION OF? ISSUE' DATE i DATE: m C0tWENTS ITEMi DOC / b CTS /STS NO . - .JFD LCO 1 ' OPENED? -CtOSED-
^
3.6.1.3-7 JFD 15 STS STS 3.6.1.3 Condition I 6/13/97 Delete this 3.6.1.3 defines the acronym OPDRVs in generic change. ACTION I Condition I. ITS 3.6.1.3 ITS ACTION F removes the phrase 3.6.1.3 " Operation with a potential ACTION F for draining the reactor vessel (OPDRVs) fron. Condition F and places it in RA F.1 in place of *0PDRVs." The justification str.tes that it is consistent with the format of the ITS and it is the first use of the term in NUREG-1433. The first use is in the Condition not the RA. The staff has determined that this is a generic change which is beyond the scope of review for this conversion. 3.6.1.3.8 Bases ITS ITS B 3.6.1.3 Bases SR 6/13/97 Provide JFD 6 B3.6.1.3 3.6.1.3.3 states that the SR additional Bases may be performed by discussion and SR verification of absence of justification 3.6.1.3.3 alarms. The justification for this change. (Bases JFD 6) is a general editorial justification which does not apply to this addition. The absence of alarms does not constitute a verification of continuity in the explosive charge - particular.If the alarm is inoperable. This also could be considered a generic i change. 6 l f
BNP ITS 3.6.1.3 PRIMARY C \INMENT ISOLATION VALVES (PCIVs) ITEM.-i DOC /? CTS /STS DESCRIPTION l0F' ISSUE DATE2 . DATEl Com1ENTS' NO . - JFD
- LCO OPENED:: CLOSED' 3.6.1.3-9 Bases ITS See Item Number 3.6.1.1-6 6/13/97 See Item Number JFD 7 B3.6.1.3 3.6.1.1-6 Bases APPLICABLE SAFETY i ANALYSES 3.6.1.3-10 None CTS 3.6.3 ITS 3.6.1.3 Condition A and 6/13/97 Provide a ITS Condition B Note requires discussion and 3.6.1.3 this Condition be applicable justification Condition to penetration flow paths for this A with two PCIVs. This administrative Note requirement is not included change.
ITS in the CTS. There is no 3.6.1.3 discussion or justification ' Condition this administrative change. B Note and Associated Bases 3.6.1.3-11 None CTS 3.6.3 ITS 3.6.1.3 Condition C Note 6/13/97 Provide a Cond! tion requires this Condition is discussion and , C applicable to penetration justification i Note flow paths with one PCIV. for this and This requirement is not administrative Associated included in the CTS. There change. Bases is no discussion or justification for this administrative change. 7 ,
BNP ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)
. ITEM $ . DOC /?~' CTS /STS. DESCRIPTION.'0FLISSUEi DATE: . . . DATEl . .C0f91ENTSi NOL - A JFD ~ -
LCO' OPENEDL CLOSED' 3.6.1.3-12 None CTS CTS 4.6.1.1
- Note provides an 6/13/97 Provide a 4.6.1.1 exception for valves, blind discussion and
- Note flanges, and deactivated justification !
ITS automatic valves which are for including 3.6.1.3 located inside the the requirement RA A.2 containment, MSIV pit, RWCU of verification Note Penetration Triangle room, or for isolation , ITS TIP Room and are locked, devices by 3.6.1.3 sealed, or otherwise secured administrative RA C.2 in the closed position. ITS means. Note and 3.6.1.3 RA A.2 Note and ITS Associated 3.6.1.3 RA C.2 Note requires Bases. verifying isolation devices in high radiation areas by using administrative means. This note encompasses more than the
- footnote valves.
There is no justification for requiring this validation by administrative means. 6 t 4 k b 8
BNP ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)
' ITEM- 00C/) CTS /STS; : DESCRIPTION 0Fl ISSUE- DATEj.s 'DATE c ' ' COMMENTS .:.
NO .1- JFD LCO ^ OPENEDi CLOSED: 3.6.1.3-13 None ITS SR The Bases for ITS SR 6/13/97 Add Note to ITS 3.6.1.3.9 3.6.1.3.9 refers to a Note 1 3.6.1.3.9 and and while ITS OR 3.6.1.3.9 does retain Bases Associated not show a note. Therefore, description of Bases the Bases discussion on the Note. Provide Note was deleted from the additional ITS. This is an error. The justification Note should be added to ITS and discussion SR 3.6.1.3.9 and the to support this discussion retained in the change. See Bases. This Note deals with Item Number leakage limit applicability 3.6.1.1-5. and is associated with ITS 3.6.1.3 ACTIONS Note 4. Also, BWR 16 C.5 corrected this error. See Item Number 3.6.1.1-5 with regards to changes to this note. t i i t 9
BNP STS 3.6.1.4 DRYWELL PRESSURE I
~
ITEMi DOC /! CTS /STS: DESCRIPTION 0F ISSUEL DATES .DATE5 , . CONtENTSI No.- JFDE LCO OPENED : CLOSEDh - 53.6.1.4-1 L.1 CTS 3.6.1.5 CTS 3.6.1.5 specifies the 6/13/97 Provide JFD 16 STS 3.6.1.4 Primary Containment justification Bases and internal pressure limits. for the STS JFD 12 Associated STS 3.6.1.4, Drywell deviation based ; Bases Pressure, is deleted for on current the ITS. The ITS is licensing basis, system renumbered such that ITS 3.6.1.4 is Drywell Air design, or Temperature. The operation , discussion and constraints, or ! Justification for retain the STS deleting the primary 3.6.1.4 and containment internal Associated pressure STS requirement Bases. does not address the current licensing basis, system design, or operational constraints. The justification is ; based on a recent GE evaluation on containment pressure. The justification used virtually the same words as Browns Ferry and Duane Arnold for deleting this : requirement from their ' respective amendments. ' The justification references GE Report-
- NEDC - 32466P Supplement I and a BNP power uprate amendment. The topical ;
report has not been > reviewed and approved by i 1
BNP STS 3.6.1.4 DRYWELL PRESSURE ITEM. DOC /? CTS /STS; DESCRIPTION.OF ISSUE; ' DATEL DATE4 COMENTSi NO.' : - JFDJ .LCO. OPENEDi CLOSED 4 the staff. Therefore, ; the justification based on this report would constitute a generic change to the STS and would be beyond the scope 4 of review for a conversion. i I - 1 o 6 [ i l' i i 2 i
..__s _._._._. _ _....___.m.. _ _.__ _ . _ . _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _______m._.____ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ . _ _ . _ _ _ . _ . _ _ _ _
BNP ITS 3.6.1.4 DRYWELL AIR TEMPERATURE
- ITEM i : : DOC / CTS /STS1 DESCRIPTION OF. ISSUE- DATEL . DATE: s C0ftlENTSi NO. - ~JFD 1 LCO ~ OPENED: CLOSED 1 "
3.6.1.4-1 JFD 16 ITS 3.6.1.4 The renumbering of ITS 6/13/97 See Ites Bases and 3.6.1.4 and succeeding Number JFD 8 Associated specifications will S3.6.1.4-1. Bases depend on the resolution of Item Number S3.5.1.4-i l- . 3.6.1.4-2 Bases STS B3.6.1.5 STS B3.6.1.5 Bases R' 6/13/97 Delete this JFD 6 Bases- A.1 states the generic RA A.1 following: "The 8 *m or change. ITS B3.6.1.4 Completion Time is . Bases acceptable, considering RA A.1 the sensitivity of the i analysis to variations in this parameter...." ITS B3.6.1.4 Bases RA A.1 adds the words
" Allow significant" between "to" and
" variations" Bases JFD 6 is a clarity .
justification. The additional words changes the meaning of the sentence and restricts the variations. This would be considered a , generic change. 3.6.1.4-3 Bases ITS B3.6.1.4 See Ites Number 3.6.1.1- 6/13/97 See Item , JFD 7 Bases- 6 Number APPLICABILITY 3.6.1.1-6. SAFETY ANALYSES 1
BNP ITS 3.6.1.5 REACTOR BUILDING-TO-SUPERESSION' CHAMBER VACUUM BREAKERS ITEML + DOC /l; CTS /STS; DESCRIPTION OF?-ISSUE. DATEl .. DATEJ .. ComENTS) NOv < JFD ~ LCO ' ~ OPENED / CLOSED 3.6.1.5-1 A.2 CTS ITS 3.6.4.2 ACTIONS 6/13/97 Provide additional 3.6.4.2 Note allows Separate discussion and ITS Condition entry for justification for 3.6.1.5 each line. This this Less Restrictive ACTIONS allowance is not change. See Item Note included in the CTS, Number 3.6.1.5-2. nor is it implied in . the CTS 3.6.4.2 ACTIONS as it is in CTS 3.6.3 " Primary Containment Isolation Valves. " Also, the refetence to L.2 is incorrect (See Item i Number 3.6.1.5-2). Therefore, the ~ justification is inadequate and incorrectly labeled , for this less Restrictive change. ! h i. 1
.. __ _ . . _ __ . ~._ _ _ _ _ . . . _. _ _ _ _ . ._ _. _ _ . _ . __._ _. . _ _ . _ . ._ .- . BNPITS3.6.1.5R'EACTORBUILDiNG-TO-SUPPRESSIONCHAMBERVACUUMBREAKERS ITEMJ 1 000 6 CTS /STS DESCRIPTION (0F? ISSUE / DATEi,.. DATEE:. .CofMENTS! . N0p J JFD- ' LCO ? , OPENED: CLOSED" - 3.6.1.5-2 L.2 CTS CTS 3.6.4 ACTION a 6/13/97 Provide additional 3.6.4.2 specifies the actions discussion and ACTION a. to take with one justification for ITS Reactor Building-to- this Less Restrictive 3.6.1.5 Suppression Chamber change. ACTION B vacuum breaker inoperable for opening. If more than one vacuum breaker is inoperable for opening, CTS 3.0.3 would require a' plant shutdown. . Justification L.2 only addresses both vacuum breakers in a line inoperable (ITS 3.6.1.5 Action B). I It does not cover the Less Restrictive change of more than 2 ! vacuum breakers Inoperable whicn *- t also covered by.ITS 3.6.1.5 ACTION B. i r s 2 m_ _ _ . _ _ _ _ . _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ . . . _ _ _ _ _ _ _ _
BNP ITS 3.6.1.5 REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS
~ ITEM,. 00C/3 CTS /STS' DESCRIPTION OF ISSUE DATE=. DATE1.. CONtENTSi~
JFD ' CLOSEDi < ' - NO . .- LCO .' ' OPENED 2 . 3.6.1.5-3 JFD 9 , STS SR Due to the addition 6/13/97 Correct this 3.6.1.7.1 of plant specific discrepancy.
. ITS SR SRs, STS SR 3.6.1.7.1 3.6.1.5.2 was changed to ITS SR 3.6.1.5.2. The number change is .
designated JFD 9. JFD 9 deals with MSIV leakage not reactor Building-To- , Suppression Chamber Vacuum Breakers. 3.6.1.5-4 JFD 16 ITS See Item Number 6/13/97 See Item Number Bases 3.6.1.5 3.6.1.4-1 3,5.1.4-1. JFD 1 and Bases Associated - JFD 8 Bases. *
- b 3
_.-.-____.___2____.--._______.-_-________._________.____-___________._____-_._m-_. __ _ . _ _ _ _ _ . _ _ _
. _ _ _ . _ _ _ _ .- _ _ _ _ _ _ _ _ _ _ . _ . - - - __ .~. . . __ . . . _ _ _ . - - _ _ _ _ .
BNP ITS 3.6.1.5 REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS ITEM - DOC /J CTS /STS5 . DESCRIPTION 0F ISSUEJ .
.DATEi . DATE2 .
COMMENTS} Noir 'JFD1 LC0t OPENED' CLOSED;' 3.6.1.5-5 JFD 29 CTS CTS 4.6.4.2.1.b 6/13/97 Provide additional 4.6.4.2.1. verifies the opening discussion and b setpoint of the justification for STS SR vacuum breakers to be this CTS change or 3.6.1.7.3 s 0.5 psid. STS SR delete the change. ITS SR 3.6.1.7.3 uses 3.6.1.5.4 basically the same words: " Verify the , opening setpoint of each vacuum break is s 0.5 psid." ITS SR 3.6.1.5.4 changes the CTS and STS wording to say " Verify the full open setpoint of i each vacuum breaker - t is s 0.5 psid." This , change changes the i meaning and l interpretation of the CTS to require the vacuum breaker to be fully open at 0.5 ! psid. Inadequate justification is provided for this change and the change i could be considered generic. 3.6.1.5-6 Bases ITS See Item Number 6/13/97 See Item Number I JFD 7 B3.6.1.5 3.6.1.1-6 3.6.1.1-6. , Bases APPLICABLE SAFETY ANALYSES t 4
i BNP ITS 3.6.1.5 REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUN BREAKERS itTEND 7 00C/3g-N0P % 'JFD s ' ~ " - CTS /STS[ LC0i' DESCRIPTION'0FlISSUEl
, ** m DATE4 ,,
OPENED 3 DATEsif CLOSED 6 CON 1ENTS?' ;'w w-* >
;[ W t
3.6.1.5-7 Bases STS STS B3.6.1.7 Bases-- 6/13/97 Either retain the STS ' JFD 13 B3.6.1.7 APPLICABLE SAFETY wording, provide Bases ANALYSES specifies plant-specific ! APPLICABLE the five cases that wording, or i SAFETY were considered in appropriate plant i
, ANALYSES the safety analyses specific references ITS to determine the for each of the five i B3.6.1.5 adequacy of the STS cases or the i
; Bases external vacuum plant-specific cases. ;
I APPLICABLE breakers. ITS Provide additional i SAFETY B3.6.1.5 Bases- discussion and ANALYSES APPLICABLE SAFETY justification as ! ANALYSES deletes this necessary. ! information entirely. i The justifications (Bases JFD 13) states . i that the appropriate , analyses are in the UFSAR, and that the ; discussion in the Bases is not needed. ! This is incorrect. I The discussion is needed in the Bases i to provide a degree [i
- of understanding on -
how these technical concerns were addressed at BNP. i t i f i I 1 5 , I
BNP ITS 3.6.1.6 SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS fiTEMk 00Ch My . CTS /STS': DESCRIPTIONiOF.ilSSUE-}
- LDATES ComENTSF N5 I E N0;(
)JFDj' f""l .LCOi'
-4: ,s
'DATE?*h" OPENEDf CLOSE3
'x-
- g am '
ty' s . %.gn; w g s , w; 3.6.1.6-1 A.4 CTS CTS 3.6.4.1 ACTION b 6/13/97 Provide discussion 3.6.4.1 requires with one drywell- and justification for ACTION b suppression chamber vacuum the More Restrictive ITS breaker in the open change of not 3.6.1.6 position, the provision of allowing MODE changes ACTION B CTS 3.0.4 are not applicable with a vacuum breaker and operation may continue open. under certain conditions. ITS 3.6.1.6 does not retain the requirement for CTS 3.0.4 not applicable. This change is classified as an Administrative change when in fact MODE changes are not allowed in MODES 1, 2, 3 when a vacuum breaker is open, per ITS 3.6.1.6 Action B. This is a More Restrictive change. A l i I
BNP ITS 3.6.1.6 SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS ITEML DOC / CTS /STS. DESCRIPTIONOFLISSUE DATE-; DATEL. COPMENTS NO. JFD : ' LCO ' s OPENED- CLOSEL *'^ a Di 3.6.1.6-2 LA.1 CTS CTS 4.6.4.1.a requires 6/13/97 Delete this generic L.7 4.6.4.1.a demonstrating each drywell change. Provide JFD 23 STS SR suppression chamber vacuum additional discussion Bases 3.6.1.8.1 breaker is closed at least and justification for JFD 8 ITS SR once per 14 days and the More Restrictive 3.6.1.6.1 "within 2 hours after any change for the and discharge of steam to the additional conditions Associated suppression chamber from which would cause the Bases any source." This second vacuum breakers to requirement is not open when the i retained in ITS SR differential pressure 3.6.1.6.1 and is moved to 2 0.5 psid. See Item plant procedures. STS SR Number 3.6.1.6-4. 3.6.1.8.1 requires verifying each vacuum . breaker closed (1) every 14 days. (2) within 2 hours after any discharge of steam to the suppression chamber from the safety / relief valves or (3) any operation that causes the drywell-to-suppression chamber ' differential pressure to be reduced by 2 [0.5] psid. STS SR 3.6.1.8.1 covers all aspects of CTS 4.6.4.1.a as well as any ; other unexpected event . which would reduce the i differential pressure j
BNP ITS 3.6.1.6 SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS
'ITEN :~ - DOC /:! " CTS /STS$ DESCRIPTIONOFilSSUEt DATEi -DATE'- ComENTS! -
N0.;;+ >
~JFDL ~ LCO f ,
, OPENEDT CLOSES D~ ,
and open the vacuum breaker. Therefore the staff considers the proposed change / relocation ! as a generic change and beyond the scope of review i
; for this conversion. See .
l Item Number 3.6.1.6-4.
, 3.6.1.6-3 JFD 16 ITS See Item Number 3.6.1.4-1 6/13/97 See Ites Number , Base 3.6.1.6 3.6.1.4-1 JFD 8 and ,
Associated Bases , I l b l l 3 !
.-~ . , . . . . . .- ..~ _-. . _ . - . . - . _ . . . . - - - ._ - . - .. . . . - - . . . . - . . _ . - - . - - . . - . - . - - - .-
BNP ITS 3.6.1.6 SUPPRESSION CHAMCER-TO-DRYWELL VACUUM BREAKERS
~
ITEM-
'. DOC /: '
-4
' CTS /STS: DESCRIPTIONOF[ ISSUE - DATER..' DATE:I ~COPMENTS i
^
.NO. -
- JFD: ' .LCO E OPENED '
CLOSEf '
. ~' "
*~ '
D? 3.6.1.6-4 JFD 21 CTS CTS 4.6.4.1.d.1 verifles 6/13/97 Provide additional 4.6.4.1.d. the opening setpoint of discussion and 1 the vacuum breakers from justification for STS SR the closed position to be this CTS change or 3.6.1.8.3 s 0.5 psid. STS SR delete the change. ITS SR 3.6.1.8.3 uses basically 3.6.1.6.3 the same words: " Verify the opening setpoint of each vacuum breaker is s 0.5 psid." ITS SR 3.6.1.6.3 changes the CTS and STS wording to say
" Verify the full open setpoint of each vacuum ,
breaker is s 0.5 psid." This change changes the meaning and interpretation of the CTS to require the ' vacuum breaker to be fully open at 0.5 psid. No , adequate justification is provided for this change, i and the change could be considered generic. . l b 1 4
BNP ITS 3.6.1.6 SUPPRESSION CHAMBER-TO-DRYWELL. VACUUM BREAKERS w . s . .. , , ~ . . ,. DOC /!:QJ . CTS /STS- ,
. DESCRIPTION OF2 ISSUES '^ DATEf.af DATEL Cole 1ENTSW , -
& u l?!TEMW N0ix emp e
'JFD $w '-
LC0 . x
,'u o -y OPENEDF CLOSE3 ua , ys s
.a
- r +w# a
, gg 3.6.1.6-5 JFD 24- CTS CTS 4.6.4.1.b requires 6/13/97 Delete this generic '
Bases 4.6.4.1.b exercising each change. Provide JFD 8 STS SR suppression chamber-to- additional discussion 3.6.1.8.2 drywell vacuum breaker and justification for : ITS SR through one complete cycle the More Restrictive '! 3.6.1.6.2 at least once per 31 days change for the e,'d and after any discharge of additional conditions , Associated steam to the suppression which would cause the Bases chamber from any source. vacuum breakers to l STS SR 3.5.1.8.2 requires - open. See Ites perierming a functional Number 3.6.1.6.2. : test of each vacuum breaker (1) every 31 days, (2) within 12 hours ofter - any discharge of steam to the suppression chamber , from S/RVs, and (3) within l 12 hours following an operation causing any of the vacuum breakers to i open. The functional test is defined in the Bases as one complete cycle. ITS SR 3.6.1.6.2 requires ; performing a functional i test of each vacuum ; breaker every 31 days, and within 12 hours after any discharge of steam i t t i 5 i
BNP ITS 3.6.1.6 SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS lITEM:-M DOC /L , CTS /STSi DESCRIPTION 0F: ISSUE.:
~
DATES DATEst- COtMENTSj y, JFDT ' No. ; ..LCO 7 0PENED; CLOSE4 D .' to the suppression chamber from safety / relief valves. It deletes the third frequency. STS SR 3.6.1.8.2 covers all aspects of CTS 4.6.4.1.b as well as any other unexpected event which would open the vacuum breakers. The justification (JFD 24) refers to an internal staff memo dated 9/92. This memo was , reviewed and factored into 1 Rev. I of NUREG-1433 which ' was the basis for this conversion. Therefore, the staff considers the proposed change as a generic change and beyond the scope of review for this conversion. See Item Number 3.6.1.6-2. i f t t 6 +
BNP ITS 3.6.1.6 SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS
- ITEM) 100C/fg ' CTS /STS) DESCRIPT10N10F; ISSUE:; DATEi DATEi. COMENTSb s s -
JFD! LCO; ' s ' OPENED / CLOSE# ss N0 1 ^'
~
~Dc 3.6.1.6 Bases STS STS B3.6.1.8 Bases-RA B.1 6/13/97 Delete these changes.
JFD 1 B3.6.1.8 states the following: "An i Bases Bases open vacuum breaker allows JFD 6 RA B.1 communication between the Bases ITS drywell and suppression JFD 11 B3.6.1.6 chamber air space and, as a Bases result, overpressurization RA B.1 due to..." ITS B3.6.1.6 Bases RA B.1 changes this statement to the following: :
"With one vacuum breaker not t closed communication !
between... airspace could occur and, as a result,...for primary containment overpressurization d m - to..." The justific.-Lion used were general type justifications for consistency, editorial clarity, plant specific , nomenclature, etc. The j staff has reviewed these ; changes and finds that the , STS wording is correct and l that the changes do not - clarify, are not editorial and changes the intent of l the Bases discussion. ! 7 i
BNP ITS 3.6.1.6 SUPPRESSION CHAMBER-TO-DRYWELL VACUUM BREAKERS TITEM DOC /; . CTS /STS! DESCRIPTION.0F ISSUE?' s-- 6ATEL, [DATEl COP 9 TENTS .. . NO.5 JFDF LCO : M: OPENED CLOSES J
> 'D r 3.6.1.6-7 Bases ITS See Item Number 3.6.1.1-6 See Ites Number JFD 7 B3.6.1.6 6/13/97 3.6.1.1-6 Bases-APPLICABLE -
SAFETY ANALYSES , t I i i t t b i I i s t I 8 l
.- -.-. - .-.- - .- - .-.- -. - -~.-._~ - -.-.-...----_. - - .- - ---..-.~.-
d BNP ITS 3.6.2.1 SUPPRESSION POOL AVERAGE. TEMPERATURE i iTEMi W tDOC/s e
~
CTS /STS M ; DESCRIPTION 10FjISSUEf DATEi.3: DATEL COMENTSd , J,,.1 i ie ?JFDA E e R NO. ' 'LCO'" - -* 2 OPENEDL CLOSED L >- u I 3.6.2.1-1 A.2 CTS CTS 3.6.2.1.a.2 requires a 6/13/97 Provide JFD 26 3.6.2.1.a.2 maximum average additional Bases ITS LCO suppression chamber dinession and ' JFD 8 3.6.2.1.a temperature of 95'F during . justification for . ITS LCO' OPERATION CONDITION 1 or this Less j 3.6.2.1.b 2. CTS 3.6.2.1.a.2.a Restrictive ; and requires a maximum average change. See Item j Associated suppression chamber Numbers 3.6.2.1- l Bases temperature of 105* during 2, 3.6.2.1-3, I
- testing which adds heat to 3.6.2.1-4. j the suppression chamber. i
, ITS 3.6.2.1.a requires - suppression pool average . l temperature is s 95'F with ; THERMAL POWER > 1% RTP and l performing no testing that i adds heat to the ! suppression pool. ITS ! 3.6.2.1.b requires ! ! suppression pool average ; temperature s 105*F with ! , THERMAL POWER > 1% RTP and ! testing that adds heat to [ the suppression pool. } Adding a specific THERMAL l POWER level limits to i these CTS LCOs is a Less i Restrictive change and was i not discussed or l Justified. See Item i Numbers 3.6.2.1-2, ! 3.6.2.1-3, 3.6.2.1-4. i i t i i 1 ! e _ _ _ _ _ ._. . _ . _ _ . _ . _ . . _ . . . . _ . - _ _ . . _ . ...__..._________________m___ . _ _ _ _ _ _ _ . _ _ . - . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _*___u. ..___ _ _ . - - . - . _ _ . _ _ _ - - - ~ _ _ _ _ _ _ _ _ _ .__m
. - ~ - . . . . . . . - . . . . .-. . . . - . .. . . .
BNP ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE
' ITEM 1 CTS /STS DESCRIPTION.0FLISSOEc -
DATE::. . DATEi A0ffiENTS1 DOC /c ^ m).e
^
JFD' LCOi OPENED CLOSED 3.6.2.1-2 A.2 CTS CTS 3.6.2.1.a.2 requires a 6/13/97 Delete tH s JFD 26 3.6.2.1.a.2 maximum average gencric change. Bases STS LCO suppression chamber See Ites Numbers JFD 8 3.6.2.1 temperature of 95'F during 3.6.2.1-1, 3.6. STS OPERATIONAL CONDITION 1 or 2.1-3, 3.6.2.1-4. B3.6.2.1 2. CTS 3.6.2.1.a.2.a Bases-LCO requires a maximum average ITS LCO suppression chamber . 3.6.2.1. temperature of 105'F i and during testing which adds Associated heat to the suppression Bases chamber. CTS 3.6.2.1.a.2.b requires a maximum average suppression chamber temperature of Il0*F with Thermal Power s 1% RTP. STS 3.6.2.1.a requires a suppression pool average temperature be s 95'F when any OPERABLE intermediate range monitor (IRM) channel is > 25/40 divisions of full scale on Range 7, while STS , 3.6.2.1.b and c require a suppression pool average g temperature be s 105'F when any IRM channel is l I 2 !
BNP ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE
~ -ITEN ?: ." D06// CTS /STSL :DsSCRIPTION OF:.ISSUEL ' DATEJ N M.TE L. COMENTS!
NO.: ' JFD .- LCO: OPENEDi CLOSED 1
> 25/40 divisions on Range 7 and s 110*F when all IRM channels are s 25/40 divisions on Range 7. ITS 3.6.2.1 changes the IRM criteria to 1% RTP. Both STS B3.6.2.1 Bases-LCO and i
JFD 26 state that 1% RTP , is not readily quantified with much accuracy. However, the Bases states ' that 25/40 divisions of full scale on IRM Range 7 is a convenient measure of ' when reactor is providing , power essentially equivaircJ to 1% RTP. Since 1% RTP cannot be readily quantified with much accuracy the STS specifies an acceptable means to determine this. Therefore the staff finds - ITS change unacceptable ; and generic. See Item ' Numbers 3.6.2.1-1, 3.6.2.1-3, and 3.6.2.1-4. 3 - i
BNP ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE ITEMI ~ DOC / CTS /STS4 DESCRIPTION 0F ISSUEJ ~ DATE! DATEL ..~ COPMENTS .. NO. - JFD" LCO- OPENEDL CLOSED-3.6.2.1-3 A.2 CTS CTS 3.6.2.1 ACTION b and 6/13/97 Provide JFD 26 3.6.2.1 ACTION b.1 require additional Bases ACTION b restoring the suppression discussion and . JFD 8 and CTS pool average temperature justification for 3.6.2.1 to less than or equal to this Less ACTION b.1 95'F within 24 hours or be Restrictive ITS 3.6.2.1 in at least HOT SHUTDOWN change. See Item RA A.2 within the next 12 hours Numbers 3.6.2.1-ITS 3.6.2.1 and in COLD SHUTDOWN 1, 3.6.2.1-2, and ! RA B.1 and within the following 24- 3.6.2.1-4.
- Associated hours. ITS 3.6.2.1 RA A.2
- Bases requires restoring .
suppression pool average ! temperature to $95'F in 24 hours and ITS 3.6.2.1 Required Action B.1 i reduces THERMAL POWER to
$1% RTP in 12 hours.
There is inadequate t justification for this l Less Restrictive change of changing the CTS Completion Time from COLD , SHUTDOWN in 36 hours to THERMAL POWER s1% RTP in ; 12 hours. See Item Number 3.6.2.1-1, 3.6.2.1-2, and ! 3.6.2.1-4. , 4 [
Bh9 ITS'3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE t
..~ ..;. .. s .m& 1
- s. .
v .. . . . .
.. "~"
!! TEN)~3 00C/!r DESCRIPTION;0F.'ISSUEi' is DATE:m. - .
DATER 7% .ColelENTS?
- epi? ~ !
CTS /STSil0 N02 'JFD: . LC0r !? - , -
^'
OPENED: CLOSEDA N t ~% ; t 3.6.2.1-4 A.2 CTS CTS 4.6.2.1.b requires 6/13/97 Provide i 4.6.2.1.b verifying the suppression additional chamber average water discussion and temperature at least once justification for i per 24 hours in this More ! OPERATIONAL CONDITION 1 or Restrictive i 2 be less than or equal to change. See Ites
! 95*F. ITS SR 3.6.2.1.1 Numbers 3.6.2.1-requires verifying .1, 3.6.2.1-2, and suppression pool average . 3.6.2.1-3.
temperature within applicable limits every 24 hours. There is.no justification fcr the More t Restrictive change of removing the CTS i , applicability requirement i for OPERATIONAL. CONDITION ! I or 2 to NODES 1, 2, and
- 3. ;
I i i t
?
. f I
i i ! 5 L I
BNP ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE
. i
- ITEM k .,':yd . DOC /h 4:m CTS /STS? .
' DESCRIPTION 40FjlSSUE!~ o ' ~
' DATES,, E ~'DATEC C0fetENTS@l N0;=+ Y '-
'~
JFDi W E ' LCO i ' 9 OPENED *.^ CLOSEDf-3.6.2.1-5 L.2 CTS ifs 4.6.2.1.c requires 6/13/97 Update the ITS to 4.6.2.1.c performing an external include this
. visual examination of the requirement.
suppression chamber enclosure emergency core cooling system suction line penetrations prior to , taking the reactor from COLD SHUTDOWN following safety / relief valve (SRV) operation with the ' suppression chamber water temperature greater than or equal to 160*F and reactor coolant system pressure greater than 200 psig. This requirement is not retained in ITS 3.6.2.1. However, based on the discussion in L.2, this requirement seems-to be plant specific and part of the current licensing basis for BNP. Changes to this requirement are therefore considered to be beyond the scope of review for this conversion. 3.6.2.1-6 Bases ITS See Item Number 3.6.1.1-6 6/13/97 See Item Number JFD 7 B3.6.2.1 3.6.1.1-6. Bases APPLICABLE SAFETY ANALYSES 6
BNP ITS 3.6.2.1 SUPPRESSION P0OL AVERAGE TEMPERATURE ITEM; LDOC/E CTS /STS: DESCRIPTION 10FRIS$dE? '. DATE2 .s DATEk, C009fENTS! - ! NOP :JFD r LC0 / 4 - OPENED CLOSED: 3.6.2.1-7 Bases STS STS B3.6.2.1 Bases- 6/13/97 Either retain the JFD 16 B3.6.
2.1 BACKGROUND
specified the STS wording, Bases technical concerns that provide plant-BACKGROUND lead to the development of specific wording, ' ITS the suppression pool or appropriate B3.6.2.1 average temperature plant-specific BASES- limits. ITS B3.6.2.1 references for BACKGROUND Bases-BACKGROUND deletes each of these- ! the technical technical ; justifications for the concerns. specific items listed in Provide STS B3.6.2.1. The additional i justification (Bases JFD discussion and
- 16) states that the justification as appropriate analyses are necessary. !
in the UFSAR and that the discussion in the Bases is not needed. This is !
- incorrect. The discussion ,
is needed in the Bases to provide a degree of - understanding on how these , technical concerns were addressed at BNP. l t P 7 '
BNP ITS 3.6.2.2 SUPPRESSION POOL WATER LEVEL ITEM' ~ DOC / CTS /STSI DESCRIPTION.'DF: 1SSUEi DATE ..- DATE f . . 'i-- COPMENTsP No;' ~JFD I LCO? ~ J OPENED CLOSED - 3.6.2.2-1 La.1 CTS CTS 3.6.2.1.a.1 6/13/97 Delete this change. JFD 3 3.6.2.1.a.1 specifies the ' Bases ITS LCO suppression pool JFD 5 3.6.2.2 water level volume and and level. The level Associated limits are retained i Bases in ITS LCO 3.6.2.2, however, the volume limits are relocated to the Bases. The volume limits in CTS 3.6.2.1.a.1 have been changed in the markup. The changes are justified in BNP Technical Specification change request 967S807 which has not been submitted to or reviewed by the staff. This Less , Restrictive change is a beyond scope of review for this conversion. 3.6.2.2-2 Base ITS See Item Number 6/13/97' See Ites Number 3.6.1.1-6 3.6.1.1-6
~
JFD 7 B3.6.2.2 Bases-APPLICABLE SAFETY ' ANALYSES l 1 {
BNP ITS 3.6.2.3 RESIDUAL HEAT REMOVAL (RHR) SUPPRESSION POOL COOLING w.
' tty DOC /1 CTS /STS : DESCRIPTION 0FxISSUEL DATE- . DATEJ.i ComENTSD W;
~
JFD ' LCO. OPENED? CLOSED? < 3.6.2.3-1 Bases ITS See Item Number 6/13/97 See Item Number JFD 7 B.3.6.2.3 3.6.1.1-6. 3.6.1.1-6. APPLICABLE SAFETY ANALYSES-3.6.2.3-2 Bases STS STS B3.6.2.3 Bases RA 6/13/97 Delete this change. I JFD 9 B3.6.2.3 A.1 states the i Bases following: "In this RA A.1 Condition, the..." ITS ITS B3.6.2.3 Bases RA B3.6.2.3 A.I decapitalizes the Bases "C" in " Condition". RA A.1 The justification is typographical /grammati cal. This is incorrect. The STS is correct since the sentence is talking about Condition A. 1
BNP STS 3.6.3.2 DRYWELL COOLING SYSTEM FANS ITEN- DOC /j CTS /STS- DESCRIPTION _0F ISSUE:.- DATE1 DATE' s COMENTS . N0;e JFD ' LCO -- OPENED 3 CLOSED-53.6.3.2-1 JFD 32 STS STS 3.6.3.2 specifies the 6/13/97 Provide Bases 3.6.3.2 requirements and additional JFD 12 and surveillances for Drywell discussion and Associated Cooling System Fans. The justification Bases ITS-does not contain this for this specification. The deletion based justification (JFD 32) used on current . states BNP does not assume licensing Drywell Cooling System Fans Bases, system - are available to assure design or adequate mixing. STS operational B3.6.3.2 Bases APPLICABLE constraints. SAFETY ANALYSES states that even though no credit for mechanical mixing is assumed in the analysis, the system does meet ' criterion 3 or 10 CFR 50.36 (c)(2)(ii), for other l' reasons. i 1
BNP ITS 3.6.3.1 PRIMARY CONTAINMENT OXYGEN CONCENTRATION ITEM' DOC /~ CTS /STS. DESCRIPTION OF ISSUEL DATE: DATE: COMMENTS' NO. JFD LCO OPENED. CLOSED 3.6.3.1-1 JFD 1 CTS 3.6.6.3.b STS 3.6.2.3 APPLICABILITY 6/13/97 Provide Bases STS 3.6.2.3 b is 24 hours prior to addition.6 JFD 8 APPLICABILITY b. reducing THERMAL POWER to discussion and Associated < 15% RTP prior to the justification Bases next scheduled reactor for the STS ITS 3.6.2.3 SHUTDOWN. CTS 3.6.6.3.b deviation APPLICABILITY b and ITS 3.6.2.3 Based on and Associated APPLICABILITY b is 24 current Bases hours prior to a scheduled licensing reduction of THERMAL POWER Basis, system to < 15% RTP. All three design or seem to say the same operational thing. There is constraints. inadequate justification for deviating from the STS APPLICABILITY. 3.6.3.1-2 JFD 32 ITS 3.6.3.1 and The renumbering of ITS 6/I3/97 See Item Bases Associated Bases 3.6.3.1 and succeeding Number JFD 8 specifications will depend S3.6.3.2-1. on the resolution of Item Number S3.6.3.2-1. 3.6.3.1-3 Bases ITS B3.6.3.1 See Item Number 3.6.1.1-6 6/13/97 See Item JFD 7 Bases Number APPLICABLE SAFETY 3.6.1.1-6. ANALYSES i 1
. - _ _ - . . - . . = . - . - - - . _ . -... . - -. . . . . - - . . . - . _ . . .. -
BNP ITS 3.6.3.1 PRIMARY CONTAINNENT OXYGEN CONCEhTRATION ITEM -' . D06/ W CTS /STS~ . DESCRIPTION'0F[ ISSUE ~
. DATE J DATE' ... CafetENTSi NO.- JFDJ >
LCO OPENED $ CLOSEDe 3.6.3.1-4 Bases STS B3.6.3.3 STS B3.6.3.3 Bases- 6/13/97 See Item JFD 8 Bases-BACKGROUND BACKGROUND specifies other Number . ITS'B3.6.3.1 STS which provide 53.6.3.2-1. Bases redundant and diverse BACKGROUND methods to mitigate events that produce hydrogen. ITS B3.6.3.1 Bases-BACKGROUND deletes these , STS references. This is ; incorrect. Resolution of this item is dependent on : resolution of Item Number S3.6.3.2-1. ! i t f I i k k 1 2
~BNP STS 3.6.3.4 CONTAINNENT ATMOSPHERE DILUTION (CAD) SYSTEM
^^
ITEN. -DOC / p CTS /STS ' DESCRIPTION OFlISSUEL DATED. DATE.: .. COMENTSc NO. JFD LCO- OPENED CLOSED S3.6.3.4-1 R.1 CTS CTS 3/4.6.6.2 specifies 6/13/97 Delete this generic , JFD 33 3/4.6.6.2 that requirements and change. Bases STS surveillances for the JFD 12 3.6.3.4 Containment Atmosphere , and Dilution System. STS - Associated 3.6.3.4 is deleted from Bases the ITS. STS B3.6.3.4 Bases-APPLICABLE SAFETY ANALYSIS states that the CAD system meets Criterion 3 of the Policy Statement /10 CFR 50.36 (c)(2)(11). No detailed justification is provided to show that the CAD System at BNP does not meet 10 CFR 50.36 (c)(2)(ii). . In addition, a NEDO report is referenced as part of the justifications (NEDO-22155) which does not seem to have been reviewed and approved by the staff. Based on the above, the staff ! considers this change ; to be generic and beyond the scope of . review for this ! conversion. [ S3.6.3.4-2 None STS See Item Number 6/13/97 See Item Number ! 3.6.3.4 3.6.3.1-2 3.6.3.1-2. ! i
~
_ . _ _ . _ . - _ _ . _ _ _ _- - - - - _ - _ - _ _ _ _ . - - - - . - - _ - _ . _ _ . ~ _ _ _ . _ _ _ . _ . - - _ _ _ - _ - . _ - - . _ _ - - _ - _ _ . - _ _ - . - - . - . _ _ - _ _ - .
BNP ITS 3.6.4.' LE;;0NDARY CONTAINNENT ITEMi-
~
~ DOC /
CTS /STSj . DESCRIPTION OF ISSUE 6 'DATEI . ~ DATET.. ComENTS7 JJ NO. JFD? LCO: ' ' OPENED-- CLOSED ~ 3.6.4.1-1 LA.1 CTS 1.0 CTS 1.0 DEFINITIONS 6/13/97 Include STS SRs JFD 34 STS SR defines secondary 3.6.4.1.1 through Bases 3.6.4.1.1 containment 3.6.4.1.3 and their JFD 8 STS SR integrity /0PERABILITY. Associated Bases in , 3.6.4.1.2 BNP current licensing ITS 3.6.4.1, and STS SR basis requires, based renumber succeeding 3.6.4.1.3 on this definition, SRs accordingly, and that the OPERABILITY Associated of secondary , Bases containment be verified on a periodic t basis. Even though the details of the definition can be relocated to the Bases, the requirements need to remain in the TS, as ; was similarly done for - primary containment. STS SRs 3.6.4.1.1, ! through 3.6.4.1.3 - specify these definition
- requirements and their surveillance ;
frequencies. 3.6.4.1-2 Bases ITS See' Item Number 6/13/97 See Ites Number JFD 7 B3.6.4.1 3.6.1.1-6 3.6.1.1-6. Bases-APPLICABLE SAFETY ANALYSIS i , , 1 i
BNP ITS 3.6.4.2 SECONDARY CONTAINNENT ISOLATION DANPERS (!CIDs) ITEM -DOC / CTS /STS1 DESCRIPTION OF'ISSOEl DATEi. DATE N < .CottfENTS2 NO. . JFD' 1 - LC- OPENED: ~ CLCSED7 3.6.4.2-1 JFD 1 STS STS 3.6.4.2 RA A.2 6/13/97 Provide additional Bases ' 6.4.2 requires verifying the discussion and JFD 8 RA A.2 affected penetration flow justification for ITS path is isolated once per the Less Restrictive 3.6.4.2 31 days. ITS 3.6.4.2 RA change STS deviation RA A.2 A.2 requires verifying based on current and the affected penetration licensing basis, Associated flow path is isolated system design, or Bases once per 92 days. The operational justification (JFD 1) constraints. used states that the change is consistent with current licensing basis. The CTS does not have an ACTION statement verifying the dampers are closed on a specified frequency, nor is there a surveillance verifying the dampers are closed. Thus, there is inadequate justification for this ; Less Restrictive change of extending the STS Completion Time from 31
- days to 92 days, in the ITS. ,
I 1 l
BNP ITS 3.6.4.2 SECONDARY CONTAINMENT ISOLATION DAMPERS ($CIDs) ITEM) 00C/j CTS /STS; DESCRIPTION OF;ISSUEV DATEi. DATEi.':..N COMMENTS / NOL a JFDE LCO- OPENED- CLOSED'- 3.6.4.2-2 JFD 21 STS SR STS SR 3.6.4.2.2 verifies 6/13/97 Licensee to update 3.6.4.2.2 "The isolation time of submittal with and each power operated and regards to TSTF-46 Associated each automatic SCIV is Rev. 1 or provide Bases within limits." ITS SR additional ITS SR 3.6.4.2.1 deletes the justification for 3.6.4.2.1 words "each power the deviations. and operated and" from the Associated STS SR. This change in , Bases. the SR and Associated - Bases are not in accordance with TSTF-46 Rev. 1. L 2
. _ _ - . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - _ _ - _ _ _ - _ - _ _ _ - _ _ - _ _ _ . ~ . .
, BNP ITS 3.6.4.2 SECONDARY CONTAINMENT ISOLATION DAMPERS (SCIDs)
ITEM- DOC /. CTS /STSL DESCRIPTION OF'ISSUEl DATE' - DATE' COMMENTS 1 NO. ^ JFD- LCO. OPENED CLOSED - 3.6.4.2-3 JFD 36 STS SR STS SR 3.6.4.2.1 verifies 6/13/97 Include STS SR JFD 37 3.6.4.2.1 that each secondary 3.6.4.2.1 and the Bases and containment isolation references to manual JFD 8 Associated manual valve and blind valves and blind Bases flange that is required flanges in STS ITS to be closed during B3.6.4.2 Bases-B3.6.4.2 accident conditions is BACKGROUND and LCO Bases- closed on a 31 day Sections in ITS BACKGROUND frequency. The ITS l 3.6.4.2 and ITS i deletes this SR and the ITS B3.6.4.2 Bases or B3.6.4.2 reference to manual provide additional Bases-LCO valves and blind flanges discussion and in STS B3.6.4.2 Bases- justification as to : BACKGROUND and LCO why it should not be Sections based on the included. Correct premise that these items the discrepancies, are not in the current licensing basis. However, CTS change L.3 for ITS 3.6.4.2 RA A.1 and RA B.2 allows penetrations to be isolated using blind ' flanges. If blind flanges are used in the ITS ras, then it can be assumed that they are permanently installed. l Therefore, STS SR l 3.6.4.2.1 should be included in ITS 3.6.4.2. Also JFD 37 has nothing to do with these changes. 3
BNP ITS 3.6.4.2 SECONDARY CONTAINNENT ISOLATION DANPERS (SCIDs)
. ITEM _ ' DOC / . CTS /STS: DESCRIPTION OF ISSUE: DATE. . DATE '. .. " C0fmENTS:i s N0i. JFD? LCO: >
OPENED Cl0 SED 1 3.6.4.2-4 Bases ITS See Item Number 3.6.1.1-6 6/13/97 See Item Number Jr' 7 83.6.4.2 3.6.1.1-6 Bases-APPLICABLE SAFETY ' ANALYSES 3.6.4.2-5 None CTS CTS 3.6.5.2 ACTION 6/13/97 Provide discussion 3.6.5.2 requires with one or more and justification ACTION secondary containment for this isolation dampers Administrative inoperable, operation my change. continue and the provisions of CTS 3.0.4 . are not applicable, provided at least one isolation damper is maintained OPERABLE in each affected penetration that is open. ITS l 3.6.4.2 does not address l CTS 3.0.4 as not applicable. A justification was not ! provided for the
~
administrative change of removing the requirement that CTS 3.0.4 is not applicable. i 4
BNP ITS 3.6.4.3 STANDBY GAS TREATMENT (SGT) SYSTEM
^
ITEM- DOC /i [ f ' CTS /STS; DESCRIPTION OF' ISSUE: ~ ' D4TEf ~ ' 'DATEL.. ' COP 91ENTSY N05 - ~ M
'JFD T LCO D ~
OPENED? : CLOSED 2 3.6.4.3-1 A.3 CTS CTS 4.6.6.1.a operates the 6/13/97 Delete this Bases 4.6.6.1.a SGT sub-systems for 2'10 change and JFD 5 STS hours with the heaters on provide 83.6.4.3- automatic control. STS additional
, Bases-SR B3.6.4.3 Bases-SR discussion and l 3.6.4.3.1 3.6.4.3.1 states that justification ! ITS operation with the heaters for the B3.6.4.3 on (automatic heater relocation of Bases-SR cycling to maintain the automatic 3.6.4.3.1 temperature) for 2 10 control continuous hours requirement to eliminates moisture on the the Bases.
adsorbers and HEPA filters. ITS B3.6.4.3 Bases-SR 3.6.4.3.1 deletes the requirement for automatic heater cycling to maintain temperature. - Justification A.2 states , that no change in actual operating practice or, the CTS requirement is intended. However the Bases changes could be , interpreted that automatic ~ t control is not required for this SR. I _ _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ m_____._.___-
BNP ITS 3.6.4.3 STANDBY GAS TREATMENT (SGT) SYSTEM ITEM- DOC /f CTS /STS: DESCRIPTION OFL.ISSUEl- DATE!. DATE4 ComiENTS NO.- JFDJ LCO - OPENED- CLOSED 3.6.4.3-2 JFD 38 CTS CTS 3.6.6.1 ACTION b.1 6/13/97 Even though the Bases 3.6.6.1 requires a shutdown within CTS is More JFD 8 ACTION b.1 36 hours with two SGT Restrictive than STS subsystem inoperable in the STS and is 3.6.4.3 MODES 1, 2, or 3. ITS acceptable, ACTION D 3.6.4.3 ACTION B also provide any and requires a shutdown within additional Associated 36 hours with two SGT discussion and Bases subsystems inoperable in justification ITS MODES 1, 2, or 3. STS other than 3.6.4.3 3.6.4.3 ACTION D requires current ACTION B. entry into STS/ITS LCO licensing basis and 3.0.3 with two SGT as to why the Associated subsystems inoperable. slightly more Bases STS 3.6.4.3 ACTION D was lenient STS deleted from the ITS. requirement was STS/LCO 3.0.3 requires a not used. shutdown within 37 hours. The CTS is more restrictive than the STS. + I i 2
BNP ITS 3.6.4.3 STANDBY GAS TREATMENT (SGT) SYSTEM j ITEM 1, -DOC /? e^ CTS /STS$ . DESCRIPTIONOFlISSNE9 DATEL ' DATEL ' COPMENTSN " : No.: JFD- - LCO T < OPENED CLOSED;'7 l 3.6.4.3-3 Bases CTS STS B3.6.4.3 Bases-SR 6/13/97 Reinsert the STS JFD 1 4.6.6.1.b 3.6.4.3.2 states that statement and CTS "The... filter tests are in reference to RG 4.6.6.1.c accordance with Regulatory 1.52 in the ; STS Guide (RG) 1.52) (Ref.3)." appropriate B3.6.4.3 ITS B3.6.4.3 Bases-SR place in ITS : . Bases 3.6.4.3.2 deletes this 83.6.4.3 Bases- ; i SR statement and Ref. 3 from SR 3.6.4.3.2 and 3.6.4.3.2 ITS B3.6.4.3 Bases- ITS B3.6.4.3 : ITS REFERENCE Section. The Bases-B3.6.4.3 Bases for this deletion is REFERENCES. Bases the general plant-specific ! SR nomenclature, etc., ! 3.6.4.3.2 justification. ITS 5.5.7 ; ITS states that the VFTP test , B3.6.4.3 shall be done in : Bases accordance with R.G. 1.52, REFEREMCES Rev. 1. Also CTS 4.6.6.1.b and 4.6.6.1.c ! also reference RG 1.5.2 ! Rev. 1. Therefore, the ; justification Bases JFD 1 ' is wrong, and the STS ! statement and Reference 3
. should be reinserted into !
ITS B3.6.4.3.2 Bases SR ! 3.6.4.3.2 and ITS B3.6.4.3 - Bases-REFERENCES, respectively. - Furthermore, the staff would consider this change < as a generic change. j l [ r 3
BNP ITS 3.6.4.3 STANOBY GAS TREATMENT (SGT) SYSTEM
-' ITEM:- ~ - DOC /I CTS /STS DESCRIPTION OF/ ISSUE DATE;. 7 DATEk; COP 9fENTSi
~
NO .' .
-JFDi LCO-
- --. a OPENED' CLOSED' <
3.6.4.3 Bases ITS See Ites Number 3.6.1.1-6, 6/13/97 See Item Number JFD 7 B3.6.4.3 3.6.1.1-6. Bases APPLICABLE SAFETY ANALYSES r t l l 4 t
- I
_ _ _ _ _ . _m__-_____ .-_.2-_.__ ______..__--_-.___.--__-__._______.._-__.-____-u _._-____m--_ - _ - _ _ . - - . - _ _ _- _ __- __ _ _ w - * --'
.- . . - . . . - - . . . - . - - . - . - . ~ - - . . . - - - - - . . . . - . . . - - -..--- . - . - _-..
i i BNP ITS 3.7.1 RESIDUAL HEAT REMOVAL SERVICE WATER (RHRSW) SYSTEM ISSOE # L DOC # CTS /STS DESCRIPTION OF ISSUE! DATE DATE COMMENTSD or . REF. OPENED.' CLOSED JFD # ! i 3.7.1-1 JFD1 CTS 3.7.1.1 CTS 3.7.1.1 Action b and ITS Action B 5/26/97 Discuss and justify the ; Action b, allows Mode cha was with one LCO 3.0.4 exemptions
- inoperable RHRSW subsystem. Since for Conditions A and B. !
STS LCO two RHRSW pumos are need for a l 3.7.1 subsystem to be operable (achieve Action B 100% flow) and each subsystem has only two pumps, exempting LCO 3.0.4 , for Condition B seems hard to justify. l Exempting LCO 3.G 4 for Condition A, ! in which one pump it inoperable, is only slightly more understandable, in both instances the ITS (and CTS) are ; not in conformance with the STS. Are these conditions at all addressed and justified by a risk-based analysis (such as GENE-B2100565-09, Technical
- Specification improvements to the Emergency Core Cooling System for the Carolina Power and Light i Brunswick Steam Electric Station Units !
1 and 2, Revision 1, October 1996). l Insert to Bases, B 3.7.1-3, on ; redundant capabilities of the operable ; subsystem, appears to be incorrect. ' BNP RESPONSE , i - -- - _ _ _ _ - _ _ _ _. . _ _ _ . . _ _ . .. _= _
BNP ITS 3.7.2 SERVICE WATER (SW) AND ULTIMATE HEAT SINK (UHS) s ISSUE # g - DOC #l CTS /STS : DES'CRIPTION OF ISSUE ~ DATE" 'DATE COMMENTS 2 or- REF: ' OPENED- CLOSEDi JFD # ' 3.7.2-1 L.1 CTS The ACTIONS contained in CTS 5/26/97 These changes to the ; JD6 3.7.1.2.a 3.7.1.2.a.1.a, CTS 3.7.1.2.a.2.a, CTS CTS ACTIONS are based l 3.7.1.2.a.4.a, and CTS 3.7.1.2.a.4.b on licensee amendment are not included in ITS 3.7.2. ITS requests. Accepting 3.7.2 extends the 72 hour Completion these changes is ; 1 Time for CTS 3.7.1.2.a.2.b and CTS contmgent on accepting i 3.7.1.2.a.4.c to 7 days. the TS License l Amendment requests. l These changes are based on SW - Extending these CTS System hydraulic analyses documented Completion Times are j in PCN GOO 50A-10, "BSEP Unit No.1 outside the scope of the i Service Water System Hydraulic STS conversion review. l Analysis," Rev. 6,07/29/93, and PCN These changes are not j GOO 50A-12, "BSEP Unit No. 2 Service consistent with the STS. !
; Water System Hydraulic Analysis,"
Rev. 5,08/11/92. These issues are < the subject of TS Amendments 164 (Unit 1) and 195 (Unit 2). l 7 i BNP RESPONSE 3.7.2-2 LD.1 CTS CTS 4.7.1.2.b specifies verifying that 5/26/97 This extension of the 4.7.1.2.i automatic components servicing CTS Surveillance Test [ safety-related components actuate to . Interval is based upon ; the correct position every 18 months. NRC review of BNP -l' change from 18 to 24 > ITS SR 3.7.2.5 extends this month refueling cycle- t Surveillance Frequency to 24 months. pending. i BNP RESPONSE ; i I i
i BNP ITS 3.7.2 SERVICE WATER (SW) AND ULTIMATE HEAT SINK (UHS) ISSUE #.L DOC #i CTS /STS . DESCRIPTION OF ISSOE . DATE.. DATE i ' COMMENTS ! !
. Wl4 ori _
.REF,; OPENED' CLOSEDT _
~
'JFD #;
3.7.2-3 LA.3 CTS. CTS 4.7.1.2.b requires venfying 5/26/97 Provide the document 4.7.1.2.b automatic components during (TRM) that will contain - shutdown. ITS SR 3.7.2.5 does not this plant procedure, that l include the words "during shutdown;" is to be incorporated into I this requirement is moved to plant the UFSAR and
- procedures in accordance with the controlled the 50.59 guidance of Genenc Letter 91-04. process. !
The justification provided states that , the plant procedure will be controlled via the 10 CFR 50.59 process. BNP RESPONSE 3.7.2-4 JFD7 ITS 3.7.2 The UHS temperature condition is new 5/26/97 Condition G should ! Conditions to both the CTS and STS, and justified include an explicit F&G " plant specific analyses." Condition F statement, "With UHS ; lists required actions if the temp is water temperature ;
< between 895 and 92*. If the temp > 92 5." i rises above 92' the intent apparently is j to enter Condition G, however, at +
above 92* Condition F is not violated. j BNP RESPONSE i i I k - _ - _ _ _ _ - - _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ - - _ _ = _ - _ _ _ - - _)
BNP ITS 3.7.3 CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE DATE ~DATE COMMENTS! or' REF OPENED CLOSED-JFD # 3.7.3-1 L.2 CTS 3.7.2.a CTS 3.7.2., 3.7.2.b, and 3.7.2.c, 5/26/97 This extension of CTS JFD11 CTS 3.7.2.b require a plant shutdown if the CTS Completion Time is JFD12 CTS 3.7.2.c requirements are not met. ITS 3.7.3.B beyond the scope of the JFD13 has been added to the STS which STS conversion review. allows continued plant operation for 92 The NRC staff is days if the Chlorine Protection Mode is reviewing the change, initiated within 1 hour. This is an extension of the CTS (and STS) Completion Time of 7 days. BNP RESPONSE 3.7.3-2 LD.1 CTS CTS 4.7.2.d.2 requires testing the 5/26/97 This extension of CTS 4.7.2.d.2 CREV diverts its inlet flow through the Refueling Surveillance HEPA filter and charcoal adsorber Test Interval is under banks upon initiation of a CREV high NRC staff review. radiation test signal at least once per 18 months. ITS SR 3.7.3.4 requires this testing at least once every 24 months. This is an extension of the CTS Refueling Surveillance Test Interval. BNP RESPONSE
BNP ITS 3.7.3 CONTROL ROOM EMERGENCY VENTILATION (CREV) SYSTEM ISSUE # . DOC # CTS /STS ; DESCRIPTION OF ISSUE - DATE DATE COMMENTS or. REF' OPENED CLOSED-JFD'# 3.7.3-3 R.1 CTS 3/4.7.2 CTS 3/4.7.2 includes Required Actions 5/26/97 is the TRM a specific - and Surveillance Requirements for the document? Provide , Smoke Protection and Chlorine additional discussion Protection Modes of the CREV. The listing the licensee ITS relocates these requirements to "a" controlled document Technical Requirements manual. containing this requirement. BNP RESPONSE b 1 _ _ _ _ . _ _ _ _ _. - _ _ _ = _ _ _ _ _ - -_._._______ ________.___.__.._.______ _.___. _ _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
BNP ITS 3.7.4 CONTROL ROOM AIR CONDITIONING (AC) SYSTEM ISSUE #, DOC # CTS /STS - DESCRIPTION OF ISSUE . DATE DATE.. COMMENTS . or REF OPENED CLOSED : JFD # , No comments on this section. t 4 l l I L
BNP ITS 3.7.5 MAIN CONDENSER OFFGAS ' ISSUE #J DOC # . CTS /STS DESCRIPTION OF ISSUE DATE. DATE COMMENTS or REF. OPENED CLOSED' JFD # No comments on this section. I
+
I I
. . . - ~ . . .. - . . . . .. __ . - . - - . . _ . _ _ . .. . . .
BNP ITS 3.7.6 MAIN TURBINE BYPASS SYSTEM ISSUE # DOC # CTS /STS ' DESCRIPTION OF ISSUE DATE DATE COMMENTS or REF OPENED CLOSED-JFD #. 3.7.6-1 JFD 17 STS 3.7.6 ITS 3.7.6 adds STS 3.7.6 ACTION A. 5/26/97 P. tain STS CT of 2 ACTION A STS 3.7.6 Action A specifies a hours or, provide - COMPLETION TIME of 2 hours. ITS additional justification for t 3.7.6 ACTION A revises the this CT extension based COMPLETION TIME to 4 hourn. Having on operational limits or a CT that is more limiting than the plant design. APLHGR and MCPR cts is not wrong or necessarily illogical. This is an extension of the STS COMPLETION TIME that lacks adequate justification. BNP RESPONSE ,. i
BNP ITS 3.7.7 SPENT FUEL STORAGE POOL WATER LEVEL ISSUE # DOC # CTS /STS DESCR'IPTION OF ISSUE DATE DATE. COMMENTS. or REF' OPENED CLOSED JFD # .- No comments on this section. t 3
BSEP ITS 3.9.1 REFUELING EQUIPMENT INTERLOCKS ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE . DATE -: DATE COMMENTS or REF. OPENED - CLOSED JFD# 3.9.1-1 JFD 1 CTS 3.9.1 A clarifying phrase has been added to the STS 5/30/97 Submit a TSTF A.5 LCO and Applicability; that the interlocks are change request. cnly those " associated with the refuel position Approval of addition i of the reactor mode switch," consistent with is pending the the current licensing basis. This is added to approval of TSTF eliminate confusion that exists in the STS. change. BNP RESPONSE b F
BSEP ITS 3.9.2 REFUEL POSITION ONE-RCD-OUT INTERLOCK , ISSUE # DOC # CTS /STS DESCRIPTION ON ISSUE 'DATE : DATE. COMMENTS ' or REF. OPENED ^ CLOSED.- JFD#. No Comments on this Section. i t b P h
BNP ITS 3.9.3 REFUELING OPERATIONS CONTROL RODS POSITION ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE - DATEl- DATE- COMMENTS or ' REF. OPENED : ~CLOSED; JFD#. No Comments on this Section. P I E t i
S T N E M M O C N
.. D '
O I
- .E' T E S '~
A TO" AL~ C I DC D N I N D O E~ I T ' EN I TE' S AP O DO P D O R L O R T N O C S N n O I o T it _ A c - R E e _ E U S _ P S s O S I i h t G F n N I O o L s E N t U O n F I T' e E P' m R I m R o 4 C~ C S 9 E o - 3 D N - S . T I P S E T _ S S _ B / . SF - TE CR' C' #D O rF DoJ : E U S S I
BNP ITS 3.9.5 REFUELING OPERATIONS CONTROL ROD OPC1 ABILITY - REFUELING 1 ISSUE # - DOC #' CTS /STS DESCRIPTION' OF' ISSUE DATE DATEf -COMMENTS J~ or' REF.- OPENEDI CLOSED ( JFD#- 3.9.5-1 LC.1 CTS 4.1.- CTS SR 4.1.3.5.b requires a Channel Functional 5/30/97 Provide discussion 3.5.b Test of leak detectors and Channel Calibration and justification of pressure detectors at least once per 18 identifying the plant months. The ITS does not include these re- procedures that quirements. The CTS requirements are moved includes the CTS re-to unspecified plant procedures. quirements. BNP RESPONSE
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i e t I t [ i l i i I t l
BNP ITS 3.9.6 REFUELING OPERATIONS REACTOR PRESSURE VESSEL (RPV) WATER LEVEL ISSUE # DOC #- CTS /STS ' DESCRIPTION OF ISSUE DATE. DATE: LCOMMENTS
- OPENED .' CLOSEDi JFD#
No Comments on this Section. I i I i i
- . . . , , . - . _ . ., . . ..., ...,.,..._.. .m.s...=_._.., .- . _ , , . . . , . - . . . . . . . .- . . . _ . , _ . . . .._,....,.4 --. .._ . - _ . . . . . -_ . _ . _ . , . _ . . . . . . . _ ,,.-._.t_ ,. - , _ . . , , . , , , - - , -
BNP ITS 3.9.7 REFUELING OPERATIONS RESIDUAL HEAT REMOVAL (RHR) - HIGH WATER LEVEL ISSUE #- DOC # CTS /STS . DESCRIPTION OF ISSUE DATE- DATE COMMENTS . : or. REF. OPENED CLOSED-JFDL No Comments on this Section. L i i ei 4 i l
t BNP ITS 3.9.8 REFUELING OPERATIONS RESIDUAL HEAT REMOVAL (RHR) - LOW WATER LEVEL ISSUE #. DOC # CTS /STS DESCRIPTION OF ISSUE DATE DATE. COMMENTS or REF. OPENED CLOSED. , JFDF No Comments on this Section. I _ . . . . _ . _ ._._.____..__.______._.m_ ________.._________m________ _ _ _ _ _ ___ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ . _ _ _ _ . ._- , _ _
t BNP ITS 3.9.9 WATER LEVEL - SPENT FUEL STORAGE POOL ISSUE # DOC # CTS /STS DESCRIPTION OF ISSUE' DATE- DATE- COMMENTS or REF. OPENED CLOSED-JFD# < No Comments on this Section. t
l)NP ITS 3.10.1 INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION ISSUE # - DOC CTS /STS I DESCRIPTION .OF ISSUE DATE : D' ATE COMMENTS'
# OR ' REF OPENED CLOSED ,
JFD # 3.10.1-1 L.1 CTS Table No CTS requirements are provided for review 1.2 comparable to the Inservice Leak and Hydro-static Testing Operation requirements of STS STS 3.10.1. 1) How are test exceptions for ! 3.10.1 inservice or hydrostatic tests presently han-died? 2) Are the analyses discussed in L.1 part of the licensing basis or previously re-viewed by the NRC7 i [ t f I i i f L
BNP ITS 3.10.2 REACTOR MODE SWITCH INTERLOCK TESTING :
' ISSUE # D O C l- CTS /STS - DESCRIPTION OF ISSUE DATE DATE: ; COMMENTS
# OR REF- OPENED- CLOSED JFD # ;
3.10.2-1 JFD STS Bases if being technically qualified is not to be 4 10 SR 3.10.- defined by the discussion in the STS basis, 7.1 what makes a person " technically qualified" - and ITS ANSI? The CTS use the term but does not
; SR 3.1- define it either. What is the present stan-0.2.1 & .2 dard?
3.10.2-2 None ITS 3.10.2 The intent of the addition "... or testing that i Bases must be performed prior to entering another i Applicabili- MODE" is unclear given that all the discus-ty sion that follows it is about interlock testing. l 3.10.2-3 M.1 CTS Table CTS Table 1.2 does not contain requirements 1.2 equivalent to the Required Actions, associat- l ed Completion Times or Surveillance Require- i ments of ITS 3.10.2. The justification is l based on that the requirements are not in- ! ciuded in the CTS and that they are added to the ITS making the change More Restrictive. The justification does not contain discussion , which provides why the added actions are appropriate or adequate to accomplish the ; intended purpose. l [ , l i L
-- - - - - _ . _ . -_ . _ _ _._..i
BNP ITS 3.10.3 SINGLE CONTROL ROD WITHDRAWAL - HOT SHUTDOWN LISSUE # DOC CTS /STSO DESCRIPTION OF ISSUE : DATEl .
.DATE .. COMMENTSh
# OR REF. -OPENED CLOSED.
~
y y; ,
.c ,
3.10.3-1 M.1 CTS Table CTS Table 1.2, Footnote * * *, allows placing 1.2 the reactor mode switch in the Refuel posi-tion while moving a single control rod provid-ing the one-rod-out interlock is OPERABLE. Under the same conditions, ITS 3.10.3 al-lows placing the reactor mode switch in the Refuel position while moving a single control i rod providing the requirements of ITS 3.9.2, One-Rod-Out interlock, are met. ITS 3.10.3 also applies the addifonal restrictions of j ensuring all other control rods are fully in-sorted; meeting the requirements of ITS i 3.9.4 and; either meeting the requirements of ITS 3.3.1.1, 3.3.8.2 and 3.9.5 or ensur-ing all rods within a 5 by 5 array are dis-armed. The justification does address why added requirements are appropnate or ade-quate to ensure the additional safety margin '- sought during single rod withdrawal. a 4 u : ~ +- .w ~ - ,.. . . - __a
BNP ITS 3.10.4 SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN
' ISSUE # DOC CTS /STS - DESCRIPTION OF ISSUE: .DATE. DATE : COMMENTS -
OR REF OPENED CLOSED JFD # 3.10.4-1 L.2 CTS CTS 3.9.10.1 does not contain re-3.9.10.1 quirements equivalent to ITS 3.10.4.b.2, ITS 3.10.4.c.1, ITS SR 3.10.4.1 or ITS SR 3.10.4.4. The justification identifies the added ITS requirements but does not indi-cate why adding these new requirements are less restrictive. Additionally, while L.2 explains what the new requirements are designed to accomplish, the discussion does not address why, even though they are less than what was in CTS, they are in fact adequate. 3.10.4-2 L.2 CTS CTS 3.9.10.1.c requires the CTS 3.1.1 3.9.10.1 SDM requirements satisfied PRIOR to the removing the control rod. ITS 3.10.4.c.2 allows that if the control rods in a five by five array are disarmed, SDM MODE 4 re-quirements are changed to allow assuming the single control rod to have the highest worth. The ITS 3.10.4.c.2 requirement is not equivalent to the CTS 3.9.10.1.c (and or 3.9.10.d) requirement. No discussion or justification is provided for deleting the CTS requirement for satisfying the SDM require-ments.
. . , . _ _ = _ _ . . - _ . . - - - _ --..... - - _.- . _ - _ - . . - - - - - - . - - . - - _ . . _ . - . - - _ . - .
t i BNP ITS 3.10.4 SINGLE CONTROL ROD WITHDRAWAL - COLD SHUTDOWN ISSUE # DOC? . CTS /STS .- . DESCRIPTION OF ISSUE DATE) DATE COMMENTSi OR REF OPENED: CLOSED-JFD # ! i l i t 3.10.4-3 None CTS CTS 3.9.10.1 specifies the requirements of : I
. 3.9.10.4 CTS 3.0.3 are not applicable. ITS 3.10.4 ACTION does not contain this exception. No discus-sion or justification is provided for this deleted CTS requirement. -
t 3.10.4-4 None CTS CTS 4.9.10.1.c requires verifying the CTS , 4.9.10.1 .c 3.1.1 SDM requirements at least every 24 hours and CTS 3.9.10.1 requires that the SDM of CTS 3.1.1 be satisfied prior to the removal of the control rod. Neither ITS 3.10.4.c.2 nor ITS 3.10.4.1 appear to i require SDM of ITS 3.1.1 to be done prior . to removal of the control rod or at any < other interval associated with this LCO. (contrary to the discussion in L.3). ! t [
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I i l
. - , . . . , - . , . . - . . . - _ ~ _ _ _ . , , . . - . _ . , - . . ~ _ - . - _ , . . - . . - , . . . _ . ~ , , . _ . . - , . . - - . . _ . . . ~ , ..-__,,,r. .
g .r f BNP ITS 3.10.5 SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING . , . ISSUE # DOCI CTS /STS - DESCRIPTION OF ISSUE L DATE DATE2 COMMENTS- - .l
# OR! REF; OPENED; . CLOSED)
JFD # , 3.10.5-1 L.1 CTS Both Discussion of Change M.1 and L.1 state l M.1 3.9.10.1.a . the one-rod-out interlock is inoperable under ITS : 3.10.5 conditions and the interlock requirement ! is replaced by the ITS 3.10.5.c requirement to : insert a control rod withdrawal block. DOC L.1 l
- justifies removal of the one-rod-out interlock i and M.1 justifies inserting the rod withdrawal block requirement. Both state that the actions ,
taken " compensate" for the inoperable one-rod- ! out interlock. If both compensate for the inter- ! Iock how can one be more restrictive and one ! less restrictive? Unlike M.1, L.1 does not even try to justify why it less restrictive. . I 1 i l l 3.10.5-2 None CTS CTS 3.9.10.1.c states the SDM requirements 3.9.10.1.c of CTS 3.1.1 must be satisfied prior to the i removal of the control rod. ITS 3.10.5.c [ requires inserting a rod block and changing the l SDM MODE 5 requirements allowing the single i control rod assumed to be the highest worth. l The ITS 3.10.5.c requirement is not the same ! I as the CTS 3.9.10.1.c requirement. No dis- f cussion or justification is provided for this delet- ; ed CTS requirement. i' i F
-i F
T _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ , - ~ . . _ - . - -
BNP ITS 3.10.5 SINGLE CONTROL ROD DRIVE (CRD) REMOVA L - REFUELING ISSUE # DOC' CTS /STS DESCRIPTION OF ISSUE DATE: DATE COMMENTS
# OR -REF OPENED CLOSED JFD #
3.10.5-3 None CTS CTS 3.9.10.1.d requires all other control rods 3.9.10.1.d in a five by five array centered on the control rod being removed are fully inserted and dis-armed. ITS 3.10.5.b requires all other control rods in a five by five array centered on the con- , trol rod being withdrawn are disarmed The ITS 3,10.5 requirement does not require inserting the control rods and is not the same as the CTS 3.9.10.1.d requirement. No discussion or ; justification is provided for the changed CTS requirement. 3.10.5-4 A.4 CTS CTS 3.9.10.1.e requires inserting all other 3.9.10.1.e control rods or removing the surrounding four fuel assemblies. ITS 3.10.5 allows for only inserting all other control rods. Isn't his a more restrictive requirement and why is it neces-sary/ justified? 3.10.5-5 A.5 CTS CTS 3.9.10.1 Applicability is Condition 5. ITS See comment #7 3.9.10.1 3.10.5 Applicability is MODE 5 with ITS 3.9.5 for a related issue. not met. A.5 states the Applicability addition "is derived from the intent of CTS 3.9.10.1 which says "... its associated control rod drive mechanism may be removed from the reactor pressure vessel." Given that the ITS contains a similar statement as the one relied on, it is not clear how it can also be the justification for the change in Applicability.
.. .-. ~ . . . - _ . . _- -_ . . . _ _ - - _ - _ ___ -- -_ . _ _ _ - .
BNP ITS 3.10.5 SINGLE CONTROL ROD DRIVE (CRD) REMOVAL - REFUELING ISSUE #. DOC- CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS
# OR REF OPENED CLOSED JFD #
3.10.5-6 None CTS CTS 3.9.10.1 states the requirements of CTS 3.9.10.1 3.0.3 are not applicable. ITS 3.10.5 does not Action contain this exception. No discussion or justifi-catior; is provided for this deleted CTS require-ment. _ 3.10.5-7 None ITS ITS 3.10.5 allows removing a single CRD 3.10.5 "...from a core cell containing one or more fuel assemblies." This statement which is also in the bases is not contained in CTS 3.9.10.1. Is the definition of a " core cell" the control rod and the surrounding four fuel assemblies?
BNP ITS 3.10.6 MULTIPLE CONTROL ROD DRIVE WITHDRAWAL - REFUELING ISSUE #L DOC CTS /STST DESCRIPTION OF ISSUEL - DATE. ._ DATES. . dCOMMENTS .
. # OR i REF. : OPENED CLOSED. '
JFD # !" ; 3.10.6-1 A.5 CTS CTS 3.9.10.2 Applicability is Condition 5. 3.9.10.2 ITS 3.10.6 Applicability is MODE 5 with ITS 3.9.3, 3.9.4, or 3.9.5 not met. Given ITS that the ITS contains words similar to those 3.10.6 taken from the CTS to justify the new Appli-cability, Fow is the justification adequate? i 3.10.6-2 M.1 ITS CTS 3.9.10.2 requirements comparable to 3.10.6.c ITS 3.10.6.c which requires fuel assemblies i loaded in compliance with an approved spiral ! reload sequence, do not exist. The justifi-cation is inadequate as it does not explain ! the purpose of the new requirement or how , it is accomplished by the requirement.
^
3.10.6-3 None CTS CTS 3.9.10.2.a states the "one-rod-out" 3.9.10.2a interlock may be bypassed. The CTS mark- , up indicates this requirement is contained in
- ITS ITS LCO 3.10.6. ITS 3.10.6 only states the ;
3.10.6 " full-in" position indicators may be bypassed.
- No discussion is provided to justify this charge. !
l I 4 i I
. . _ - _ _ . _ . _ . - - - _ - = - - _ .
BNP ITS 3.10.6 MULTIPLE CONTROL ROD DRIVE WITHDRAWAL - REFUELING ISSUE # ' DOC CTS /STS DESCRIPTION OF ISSUE DATE DATE '- ' COMMENTS
# OR REF_ OPENED CLOSED = j JFD #
CTS 3.9.10.2.d requires all other contro! 3.10.6-4 None CTS 3.9.10.2d rods fully inserted. The CTS markup indi-cates this requirement is relocated to ITS ITS LCO 3.10.6.b. However, ITS 3.10.6.b only < 3.10.6.b requires all other control rods in core cells containing one or more fuel assemblies fully 5 inserted. No discussion or justification is i provided for the changed CTS requirement. i 9 1 6 0 l 1
BNP ITS 3.10.7 CONTROL ROD TESTING - OPERATING ISSUE # DOC- CTS /STS DESCRIPTION OF ISSUE DATE DATE _ COMMENTS -?
# OR ' REF OPENED - CLOSED:
JFD # 3.10.7-1 JFD STS SR in accordance with the CTS or the licensing Similar comment to 10 3.10.7.1. basis who is qualified to perfrom the verifica- 3.10.2-1. Bases tion of ITS 3.10.7.b? I t i r t i
?
i [ i
. - . _ _ _ _ - _ _ _ _ _ _ _ _ - _ - - - _ - - _ - _ _ _ _ _ . _ _ _ - _ - _ _ _ _ _ . - _ - _ _ _ _ _ _ .__ - . _ _ _ _ _ _ . _ _ _ _ _ _ _ - . . -_, . - . _ . . . , . . ~ ~ , - - - - -
-i f
BNP ITS 3.10.8 SHUTDOWN MARGIN (SDM) TEST - REFUELING i
' ISSUE #' DOC. CTS /STS t DESCRIPTION OF ISSUE > DATEj f DATE ICOMMENTS L ,
# OR . REF OPENED?- CLOSED JFD # f i
I
't i
3.10.8-1 L.4 CTS SR CTS 4.10.3 requires verifying Surveillance t ] 4.10.3 Requirements within 30 minutes (Unit 1) or 1 within 2 hours (Unit 2) prior to starting SDM testing. ITS 3.10.8 does not contain the i above times requirements. The justification i states that the verification was just a " paper-check" that the surveillance was current and that now now the test will have to actually be performed. However, isn't the ITS SR requirement also just a " paper-check"? The , SR requires performance of the SR " Accord- ' ing to the applicable SRs" which have no special requirement to perform the SR while i in LCO 3.10.8. 3.10.8-2 JFD.8 ITS ITS 3.10.8 Condition C requires action if one This STS deviation is 3.10.8 control rod is not coupled to its associated contingent on NRC ap-Cond C CRD. The justification states this Condition proval of the Generic was added by Generic Change BWR-01 A and Changes. removed by Generic Change BWR-18. , 1 t _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _____._-i
i-BNP ITS 3.10.9 Recirculation Loops - Testing BNP iTS 3.10.10 Training Startups i
- lSSUE # DOC CTS /STS DESCRIPTION OF ISSUE - -DATE DATE COMMENTS
#. OR REF' OPENED ' .CLOSEDJ JFD #
3.10.9-1 I JrD.9 STS The requirements of STS 3.10.9 and 3.10.- 3.10.10-1 3.10.9 10 are deleted from the BNP iTS based on , 3 A O.10 the fact that the requirements are not need- t ed. A short discussion of why each re-quirement is not needed should be provid-ed I t t_ _ _ _ -._, . _ _ . _ _ _ _ _ _ . .__.__ _________-__i_________ w_____.___ _ _ _ _ _ _ _ _ . _ __ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ -
- - . - + - . - _ _ _ _ _ _-_________-m_._______m_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
BNP ITS 5.1 RESPONSIBILITY lSSUE # DOC # CTS /STS . DESCRIPTION OF ISSUE DATE- DATE'. : COMMENTS - or- REF '- OPENED - CLOSEDL JFD'# - 5.1-1 LA1 CTS CTS 6.1.1, 6.5.2.5, and 6.5.2.7 require the 5-31-97 Provide discussion 6.1.1, General Manager - Brunswick Plant to approve and justification for 6.5.2.5, proposed tests, experiments, etc. ITS 5.1.1 this less restrictive 6.5.2.7 requires the plant manager to approve proposed change. tests, experiments, etc. The justification is inadequate for this apparently less restrictive change of lowering the responsibility from the General Manager to the plant manager. There is no discussion or justification to equate the General Manager position to the plant manager position. " General Manager - Brunswick Plant" is plant specific, while " plant manager" seems very generic. BNP RESPONSE 5.1-2 M1 CTS CTS 6.5.2.5 and 6.5.2.7 require approval of 5-31-97 Provide discussion 6.5.2.5, proposed tests, experiments, etc. which are and justification for 6.5.2.7 determined to not involve an unreviewed safety changes in the 10 question or a change to the CTS. ITS 5.1.1 CFR 50.59 review requires approval of proposed tests, and approval experiments, etc. that affect nuclear safety. process. There is no discussion of the USO (10 CFR 50.59) review and approval process before and after the adoption of the new requirement. BNP RESPONSE t _ _ _ _ _ . . _ _ _ . _ _ _ . _ _ . . . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ .._______________________n_____________________ _ _ _ _ _ _
k BNP ITS 5.1 RESPONSIBILITY ISSUE # - DOC # - ' CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS ' or- 'REF OPENED ' CLOSED JFD # 5.1-3 JFD 3 STS 5.1.2 STS 5.1.2 requires control room command 5/31/97 include STS 5.1.2 functions to reside with the Shift Supervisor requirements in the (SS). Absences from the control room during ITS. MODES 1,2, or 3 require the SS to designate an active Senior Reactor Operator (SRO) license holder to assume the command function. 1 Absences from the control room during MODES 4 or 5 require the SS to designate either an active SRO or Reactor Operator license holder to assume the command function. ITS 5.1 does not retain these requirements. , BNP RESPONSE i t t i
_. ._ . . .m . . .. . . . . . . . . _ _ ._ . . _ . ~ . . . . _ - - _ _ _ _ . . . _ _ . . _ _ _ _ ._ _ . _ , . . I i BNP ITS 5.2 ' ORGANIZATION 1 ISSUE #'. DOC # . CTS /STS - Dl!SCRIPTION OF ISSUE ~ DATEI DATEf MOMMENTS J . or' REFc ' OPENED" Ct.OSED e
- 'JFD# ,
5.2-1 LA.4 CTS CTS 6.2.1.b requires the General Manager - 5/31/97 Prcvide discussion 6.2.1.b Brunswick Plant responsible for overall unit and justification for ' safety, etc. ITS 5.2.1.b requires the plant civsnging this CTS manager responsible for overall unit safety. mimagement There is no discussion or justification to equate requirement. the CTS General Manager position to the ITS , plant manager position. BNP RESPONSE . 5.2-2 LA.4 CTS CTS 6.2.1.c requires the Senior Vice President 5/31/97 Provide discussion 6.2.1.c - Nuclear Generation corporately responsible for and justification for overall plant nuclear safety, etc. ITS 5.2.1.c changing this CTS requires a specified corporate officer management corporately responsible for overall plant nuclear requirement. ! safety. There is no discussion equating the
. CTS Senior Vice Presider't - Nuclear Generation position to the ITS "specified corporate officer position.
i BNP RESPONSE 5.2-3 JFD 4 STS STS 5.2.1.a requires documentation describing 5/31/97 Retain STS 5.2.1.a 5.2.1.a facility authority include functional descriptions requirements on of departmental responsibilities and organizational relationships, and job descriptions for key structures. personnel positions. ITS 5.2.1.a does not retain these requirements. i BNP RESPONSE i
f I { BNP ITS 5.2 ORGANIZATION
- r ISSUE #- DOC ( CTS /STS'. ' DESCRIPTION 0F IS5UEJ DATG[ (DATE .. '
. COMMENTS
- or .REFi OPENED ^- . CLOSED .
'JFD# :
i 5.2-4 JFD 5 STS STS 5.2.2.b provides control room staffing 5/31/97 See attached TSB 5.2.2.b requirements. ITS 5.2.2.b provides staffing letter to NEl of , requirements that do meet the requirements of Apr 9,97, on work i i 10 CFR 50.54(m)(2)(iii). Attached TSB letter hours, staffing, etc. to NEl of Apr 9,97, on staffing requirements, Adopt proposed recommends deleting paragraph 5.2.2.b since it l requirements as
- . is redundant to 10 CFR 50.54(m)(1)(iii). g appropriate.
BNP RESPONSE 5.2-5 JFD 7 STS STS 5.2.2.e requires guidance on overtime See attached TSB 5.2.2.e usage by facility personnel. ITS 5.2.2.e letter to NEl of t relegates these overtime usage by facility Apr 9,97, on work personnel to working guidelines published by hours, staffing, etc. ; the Nuclear Regulatory Commission in Generic Adopt proposed Letter 82-12. There is no discussion or requirements as justification for this deviation from the STS. appropriate. BNP RESPONSE . 5.2-6 JFD 8 CTS The CTS requires the Operations Manager to 6/5/97 Revise the ITS to ; 6.2.2.e " hold or have held an STO license for either conform with the Brunswick or a similei p! ant." The STS STS. STS requires either the Operations Manager or his-
- 5.2.2.e assistant to hold an SRC license. The intent is that one of the managers in charge of the day-to-day operations of the plant shall hold an active SRO license for the plant they are 4
BNP RESPONSE
BNP ITS 5.2 ORGANIZATION ISSUE # DOC #- CTS /STS ' ' DESCRIPTION OF ISSUE . DATE' DATE' COMMENTS . or ' REF' OPENEDU CLOSED JFDF 5.2-7 JFD 9 STS STS 5.2.2.g requires the STA meet the 5/31/97 Provide discussion ; 5.2.2.g qualifications specified by the Commission and justification for Policy Statement on Engineering Expertise on this deviation from Shift. ITS 5.2.2.g does not include this the STS. qualification requirement. BNP RESPONSE 4
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i I l r ___-_..u -_________.___m_ _ _ - - _ - _ _ _ _ . __ __ __ -.__m___ __ - _ . - - - __________w .____- _ _-s
i BNO ITS 5.3 FACILITY STAFF QUALIFICATIONS f ISSUE #. DOCb LCTSISTS[ DESCRIPTION OF ISSUE; _ D'ATE = DATEi E; COMMENTS-or LCOL' OPENED CLOSED' JFD# , 5.3-1 LA.1 CTS The STS deletes Table 6.2.2-1 on crew staffing 5/31/97 See attached TSB [ 6.2.2-1 requirements, due to redundancy with 10 CFR letter to NEl of l l STS 50.54(m). 10 CFR 55.4 requirements on Apr 9,1997, on ; 5.2 qualifications refers to positions in the TS. To work hours, ensure that 10 CFR 55.4 is met, a new staffing, etc. Adopt ; paragraph 5.3.2 is proposed in the attached proposed i TSB letter to NEl of Apr 9,1997, on staffing requirements as i requirements. appropriate. ! BNP RESPONSE i 5.3-2 LA.1 CTS CTS 6.3.1 requires the Manager - 3/6/97 Provide additional i 6.3.1 Environmental & Radiation Control meets or discussion and l exceeds the qualifications of Reg. Guide 1.8, justification for ;
-September 1975. ITS 5.3.1 requires the changing the CTS -{
Manager of the radiation control function meets requirement. [ or exceeds the qualifications of Reg. Guide 1.8, i September 1975. There is no discussion or justification to equate the CTS Manager - Environmental & Radiation Control position and job functions to the ITS Manager of the ; radiation control function position and job function. BNP RESPONSE i t a i 4 1
) .
BNP ITS 5.5 PROGRAMS AND MANUALS
. ISSUE # L DOC CTS /STSj DESCRIPTION OF ISSUE - DATE~ ._ DATE- ICOMMENTS -
# or REF OPENED: CLOSED.
-JFD
~R 5.5-6 LD.3 CTS CTS 4.7.2.b and 4.7.2.d requires the Control 6/2/97 This change to CTS 4.7.2.b and Room Emergency Ventilation System HEPA Surveillance Test i 4.7.2.d filters tested every 18 months following Interval is under maintenance. ITS 5.5.7 requires a 24 month review.
testing frequency on the Contre! Room Emergency Ventilation System HEPA filters following maintenance. This is a change to CTS Surveillance Test Interval. BNP RESPONSE 5.5-7 JFD STS STS 5.5.2 does not contain provisions to 6/2/97 Propere and submit
- 13 5.5.2 apply SR 3.0.2 to ILRT requirements. ITS a TSTF change ;
includes a statement that the provisions of request, for this i ITS SR 3.0.2 apply to the 24 month generic change. frequency for performing integrated system leak test activities. There is no discussion or justification for the deviation from the STS surveillance frequency. BNP RESPONSE i 5.5-8 JFD STS STS 5.5.8.a requires the HEPA filter 6/3/97 Provide discussion 1 5.5.8.a penetration and bypass flow of <0.05%. ITS and justification for 5.5.7 requires the HEPA filter penetration and changing this STS bypass flow of <1.0%. There is no requirement. . l discussion or justification for changing this STS requirement. BNP RESPONSE i D i
.- - - _ _ . - . - - , - -- - - . - .. .0
-i BNP ITS 5.5 PROGRAMS AND MANUAL.S ISSUE # - DOC' CTS /STS - DESCRIPTION OF ISSUE- DATE DATEL . COMMENTS ^
# or REF'c OPENED CLOSEDL ,
-JFD-5.5-9 JFD STS STS 5.5.8.b requires an inplace test of each 6/3/97 Provide discussion ,
1 5.5.8.b charcoal filter of an ESF system with a and justification for penetration and system bypass <0.05%. ITS changing this STS j 5.5.7.b requires an inplace test of each requirement. 'l charcoal filter of an ESF system with a penetration and system bypass <1.0%.
- There is no discussion or justification for ;
changing this STS requirement. ; r BNP RESPONSE 5.5-10 JFD STS 5.5.8.c STS 5.5.8.c requires the testing each ESF 6/3/97 Provide discussion 22 system charcoal absorber in accordance with and justification for not incorporating
'[
ASTM 03803-1989 at a specified ! temperature. ITS 5.5.7.c does not contain this STS ; this requirement. requirement. ! BNP RESPONSE ! 5.5-11 JFD STS STS 5.5.8.d requires demonstrating the 6/3/97 Provide discussion ; 23 5.5.8.d pressure drop across the combined HEPA and justification for filters, the prefilters, and the charcoal changing these STS absorber of each ESF ventilation system is requirements. j less than the value specified in the table. ITS 5.5.7.d requires demonstrating the pressure [ drop across the combined HEPA filters, the , prefilter (SGT only), and the charcoal absorber i of each ESF ventilation system is less than l the value specified in the table. The ITS also - + deletes reference to RG 1.53 and ASME-510. t l BNP RESPONSE -
)
i i
1 j i , BNP ITS 5.5 PROGRAMS AND MANUALS 4 e ISSUE # DOC CTS /STS . DESCRIPTION OF ISSUE DATE DATE: :.COMMENTSI
# or' REF" OPENED' CLOSED? l JFD' l
.g ; - + r 5.5-12 JFD STS. STS 5.5.10.a requires new fue' oil to have an 6/4/97 Provide adequate !
27 5.5.10.a API gravity or an absolute 9ecific gravity . discussion and ! within limits, a flash poin'. and kinematic justification for ! M.4 viscosity within limits fw ASTM 2D fuel oil, changing this STS and a clear and bright appearance with proper requirement; or j color. ITS 5.5.9.a requires determining new retain the ' fuel oil not contaminated with other products acceptance criteria : during transit, thus altering the quality. Even in the SR. ' accepting a cetificate of compliance from the supplier does not necessitate the elimination of the specific criteria of significance from the . SR. The discussion and justification is inadequate for changing this STS requirement. ! t BNP RESPONSE ! 5.5-13 JFD STS STS 5.5.10.b requires testing fuel oil every 31 6/4/97 Provide discussion 27 5.5.10.b days after adding to storage tanks. ITS and justification for 4 5.5.9.b requites testing every 92 days. There the STS i is no discussion or justification for the Surveillance Test : deviation from the STS Surveillance Test Frequency Frequency, deviation. ; BNP RESPONSE i i t i I
BNP ITS 5.5 PROGRAMS AND MANUALS ISSUE # DOC . CTS /STS DESCRIPTION OF ISSUE DATE DATE- COMMENTS
# or REF OPENED CLOSED JFD- .
.y.
5.5-14 JFD STS STS 5.5.10.c requires testing fuel oil 6/4/97 Provide adequate i 27 5.5.10.c particulate concentration in accordance with discussion and ASTM D-2276, Method A-2 or A-3. ITS justification for 5.5.9.c requires testing fuel oil particulate changing this STS concentration in accordance with the requirement, and applicable standard. There is inadequate submit a TSTF discussion and justification for changing the change request. STS required testing standard. BNP RESPONSF i
.L BNP ITS 5.6 REPORTING REQUIREMENTS i
t ISSUE # DOC # CTS /STS LCO DESCRIPTION OF ISSUEi DATE DATE. ' COMMENTS ' i
- -or. OPENED ' CLOSED !
5 JFDF' s j 5.6-1 A L.1 CTS CTS 6.9.1.6 requires annually submitting 6/5/97 BNP can opt for l 6.9.1.6 the radiological environmental operating change of submittal reports prior to May 1 of each year. ITS date from May 1 to ! 5.6.1 requires annually submitting the May 15. . radiological environmental operating j reports prior to May 15 of each year. BNP RESPONSE L 5.6-2A A.5 CTS CTS 6.9.2 requires submitting numerous 6/5/97 Provide additional i 6.9.2 special reports to the Regional discussion on the Administrator or the Regional Office. ITS actual ultimate 5.6.4 does not retain this requirement, and location of these the justification implies that the reports are CTS requirements, , adequately addressed in other TS. Many and the controlling i j of these reports are actually removed from mechanisms. t TS. i BNP RESPONSE ! 5.6-3A STS JDC1 STS 5.6.2 requires the Annual Radiological 6/5/97 Provide discussion 5.6.2 Environmental Operating Report identify and justification for ' the TLD results that represent collocated not including this dosimeters, etc. ITS 5.6.2 does not STS requirement. i contain this requirement. .There is no discussion and justification for not including the STS requirement. i BNP RESPONSE
BNP ITS 5.7 HIGH RADIATION AREA ISSUE # DOC CTS /STS. DESCRIPTION OF ISSUE DATE DATE COMMENTS '
# or LCO OPENED CLOSED JFD 5.7-1 A L1 CTS ITS 5.7.2.a.1 requires keys to High Radiation 6/5/97 Suggest that the 6.12.2 Areas be under the administrative control of the phrase "or shift superintendent or the radiation control designated supervisor. representstive," be added after " shift superintendent or the radiation control supervisor."
BNP RESPONSE
BNP CTS 3/4.4.4 Ci1EMISTRY ITEM # DOC CTS /STS DESCRIPTION OF ISSUE DATE DATE ' COMMENTS or REF OPENED CLOSE JFD D-3-444-1 R.1 CTS 3.4.4 CTS 3.4.4, Reactor Coolant System CTS 4.4.4 Chemistry, and CTS 4.4.4, Surveillances, are relocated to a Technical Requirements Manual. There is no discussion of how the TRM and its changes are controlled. 1 I 6
BNP CTS 3/4.4.8 STRUCTURAL INTEGRITY ITEM # - ' DOC . CTS /STS ~ DESCRIPTION OF ISSUE . DATE DATE COMMENTS or REF. OPENED . CLOSED JFD 3-448-1 R.1 CTS 3.4.8 CTS 3.4.8, Structural integrity, and CTS CTS 4.4.8 4.4.8, Surveillances, are relocated to a Technical Requirements Manual. There is no discussion of how the TRM and its l changes are controlled.
BNP ITS 3/4.7 Relocated CTS ISSUE # DOC # ' CTS /STS ' DESCRIPTION OF ISSUE DATE DATE' COMMENTS or REF; OPENED CLOSED. JFD # 3/4.7 R.1 CTS 3/4.7 CTS 3/4.7 includes LCOs, Required 05/30/97 Provide additional Actions and Surveillance Requirements discussion listing the which may be relocated to a Technical licensee controlled Requirements Manual (TRM). The TRM documents containirs must be incorporated into the UFSAR the relocated and controlled via 10 CFR 50.59. requirements, and the method used to control these documents. l t i I
BNP CTS 6 RELOCATED REQUIREMENTS
^
ISSUE # DOC CTS /STS DESCRIPTION OF ISSUE DATE: DATE. COMMENTS-'
'# or. LCO OPENED CLOSED JFD-6-1 LA.1 CTS 6.5 The CTS sections on Review and Audits (6.5), 6/6/97 These requirements LA.2 CTS 6.6 Reportable Event Action (6.S), Procedure must be relocated CTS 6.8 Review and Approval Processes (6.8), Record to the OAP.
CTS 6.10 Retention (6.10), and PCP 1mplementation Provide a revised CTS 6.14 Procedures (6.14), all contain information to be copy of the QAP for i relocated to the OAP. NRC review prior to NRC issuance of the ITS license , amendment. BNP RESPONSE 6
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l l i t t' [ P _...____-.__m___________ _m _ _ _ . _ _ _ . - . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . - . _ - m - . - -m__. _m_ _ _ ___ _ _ _ . _ _______.-_ _ _-_ _ _ _ _ _ _ _ . _ . . _ _ ___._..._._.m ,m.-.-. . , ,+..- 4_ _. -_
BNP CTS 3.9.2 REFUEUNG OPERATIONS -INSTRUMENTATION ISSUE # DOC #- ' CTS /STS DESCRIPTION OF ISSUE DATE' DATE COMMENTS
.or REF. OPENED CLOSED JFD#
No issues Found Moved to ITS 3.3.- 1.2 h 4 l
BNP CTS 3.9.4 REFUELING OPERATIONS - DECAY TIME ISSUE # L DOC # CTS /STS- DESCRIPTION OF ISSUE DATE DATE- COMMENTS or. REF. OPENED CLOSEDj ; JFD#- 3.9.4-1 LA.1 CTS 3/4.- CTS 3/4.9.4 requires a decay time of 24 hours 5/30/97 Provide additional 9.4 before moving fuelin the RPV. This require- discussion identify- ; ment is moved to plant procedures (changes to ing the plant proce- l plant procedures are govemed by the BNP dures containing the . procedure control p ocesses). No discussion is CTS 3/4.9.4 requ-provided identifying the plant procedures. irements. This requirement shall be i relocated tc voce-dures incorporated into the UFSAR and controlled by 10 CFR 50.59. I t s I
~ .. . ._ - . _- .
BNP ITS 5.4 PROCEDURES ISSUE # DOC CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS
# or- REF- OPENED CLOSED
^
JFD 5.4-1 A.2 CTS 6.8.1 PCP Implementation procedures have been 5/31/97 Move PCP b/c/d, deleted; they should be moved to QAP. Implementation Procedures to QAP. STS 5.4.1 Submit revised QAP prior to issuance of ! ITS SER. BNP RESPONSE 5.4-2 A.3 CTS 6.8.1 The Security Plan and Emergency Plan 5/31/97 Move Security Plan ' d/e implementation Procedures have been deleted; and Emergency Plan they should be moved to their respective plans. Implementation Procedures to their respective plans. BNP RESPONSE
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BNP ITS 5.5 PROGRAMS AND MANUALS ! i i ISSUE # ~ DOC CTS /STS . DESCRIPTION OF ISSUE.. DATEl DATE COMMENTS" !
# or -REF. OPENED ? CLOSED. ;
Jpo - - ! 5.5-1 A.2 CTS CTS 6.8.3.1, 6.8.3.4, and 4.0.5.c do not 6/2/97 Provide discussion ; 6.8.3.1 contain the statement that "the provisions of and justification for .! 4 JFD 6.8.3.4 ITS SR 3.0.2 and ITS SR 3.0.3 are applicable, these less restrictive , 13 4.0.5.c etc." tTS 5.5.2, 5.5.6, 5.5.7. 5.5.8, 5.5.9, requirements. 1 and 5.5.12 contain the statement that "the Submit TSTF ! i n ovisions of ITS SR 3.0.2 and ITS SR 3.0.3 change request due l are apphcable, etc." The statement permits to generic nature of i , extendmg the frequency of the SR in order to proposed changes. , satisfy the requirements of the SR in a timely ' manner. These are less restrictive . requirement changes for which there is inadequate discussion or justification. BNP RESPONSE l 5.5-2 A.9 CTS CTS 4.8.1.1.2.c requires obtaining a sample 6/2/97 Provide discussion ! 4.8.1.1.2.c of diesel fuelin accordance with ASTM D270- and justification for ; 65 and the limits established by ASTM D975- these less restrictive !
- 74. ITS 5.5.9 does not contain the sampling requirements. !
requirement of ASTM D270-65 and changes [ the acceptance limit requirements document j to ASTM 2-D. This is a less restrictive [ requirement change for which there is ! inadequate discussion or justification.
- BNP RESPONSE l
l
+
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BNP ITS 5.5 PROGRAMS AND MANUALS ISSUE # DOC CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS for REF OPENED CLOSED JFD 5.5-3 LA.7 CTS CTS 4.8.1.1.2.c requires sampling the diesel 6/2/97 Provide discussion 4.8.1.1.2.c fuel storage tanks per ASTM-D270-65 and and justification for the fuel oil meet the quality requirements of changing this CTS ASTM D975-74. ITS 5.5.9, Diesel Fuel Oil quality standard Testing Program, does not contain the requirement. sampling requirements and require an oil quality standard of ASTM 2-D fuel oil. There is no discussion or justification of this less restrictive requirement that the quality standard of ASTM D975-74 equatss to ASTM 2-D fuel oil. BNP RESPONSE 5.5-4 LD.1 CTS CTS 6.8.3.1.2 requires the integrated leak 6/2/97 This change to CTS 6.8.3.1.2 test at refueling cycle intervals or less. ITS Surveillance Test 5.5 requires the integrated leak test at a 24 Interval is under
- month interval. This is a change to CTS review.
Surveillance Test interval. BNP RESPONSE 5.5-5 LD.2 CTS CTS 4.6.6.1.b and 2.6.6.1.d requires an 18 6/2/97 This change to CTS 4.6.6.1.b month testing frequency on the ventilation Surveillance Test and system HEPA filters following maintenance. Interval is under 4.6.6.1.d ITS 5.5.7 requires a 24 month testing review. frequency on the ventilation system HEPA filters following maintenance. This is a . change to CTS Surveillance Test Interval. BNP RESPONSE __}}