ML20196B490

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Proposed Tech Specs Pages & follow-up Items Re Proposed Conversion to TS Section 1.0,3.4,3.5 & 3.6,per 980828 RAI
ML20196B490
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 11/24/1998
From:
WOLF CREEK NUCLEAR OPERATING CORP.
To:
Shared Package
ML20196B486 List:
References
NUDOCS 9812010112
Download: ML20196B490 (175)


Text

.

6.0 USE AND APPLICATIO )

1.0f1)EFINITION l

DOSE EOUfVALENT l-131 4,4-4 DOSE EQUIVALENT l-131 shall be that concentration of I-131 (microCuriQgram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131,1-132,1133,1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table ill of TID-14844. " Calculation of Distance Factors for Power and Test Reactor Sites."

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E - AVERAGE DISINTEGRATION ENERGY a

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4,43 E shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half-lives greater than 15 minutes, making up at least 95% of the total noniodine activity in the coolant.

J ENGINEERED SAFETY FEATURESIf"E55F0 RESPONSE TIME 4,43 The ENC'NEEPED E.^ F"" "E^.TURES (ES"Py_S9 RESPONSE TIME shall be 408@ j that time interval from when the monitored parameter exceeds its ESF A@ctuation

^

^

i E@stpoint at the channel sensor until the ESF equipment is capable of performing its

)

safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel oenerntnr startina and seauence loadine delays where =#=W.fThe response time may be]

by means of any of sequential, overlapping, or total steps so that ]

_ Nl*N r

_J 1

veimponse time J,9;; g,,g og,ne ay,n.nt,,,,,p.ng,,, we

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.)

WesuredW.

i{ied fo. selecreA com nenh vided hi e9EO'r _ f- _ : -TICM comyeh aria, me otogg verWicahim have.

n previo% reviewA awk _o_ $ prove.d 103~h Mec.,

i 4.44 The FREQUEMCY MOT ^7?ON r;r?:: !s th: pinnM M Er;:x-ee eR3 09-A M o-q: :t the!! ^^~ rep ^^d te the Mter; !: deSed M 79'r * *

  • NE' N

flN

/

,Q -

+,

e maxi m all e prima containrp6ntleaka rate, L., aJd11 be 0.20 of C TSA' j

prima ontainm air wel t per dayft the cale sted pea,pcontainm

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re (P.).f(

f

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g,g,q incLfTic cr3 t c A # A f'*c

[LEAKAC,E shall *)

4,44(a. Identifled LEAKAGEkh !! be:

Isil-A7 h[LEAKAGEh?-kr:0 (trept COMT90LLED LE^X^GE} Mt: Wred :' ten, such aaRhet fron% pump sea $or valve packing [(except reactor coolant]

(pump (RCP) seal water inlection or leakoffhlooks that as(1,s) captured

~ d conducted tofcollection systems oda sump or collecting tank; er an

h. fLEAKAGE]Lerkr r into the containment atmosphere from sources that are ooth specifically located and known either not to interfere with the operation of Leakage Detection Systems or not to be P9 ESSURE SOUNDARY pressure boundary LEAKAGE; or
h. Reactor ant System [(RCS) LEAKAGEllaakage through a steam generato to the Secondary Coolant-Systerr.'

9812010112 981124 I

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PDR ADOCK 05000482i

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WOLF CREEK - UNIT 1 1-3 Amendment No. 61 Mark-up ofCTS 1.0 S/15/97

l (1.0 USE AND APPLICATIONl 1.9@EFINITION l

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onceetime onnunnov i cavane 7;agg '

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  • DU"E "OUO.^ DV ' C ^E^ ^ C '-M '^ '^ ' 7 ^"^^* -*.^-~ p-d^-

tu' ' e'r;e ^ u;'. e rent f-r: 'cu't M 2 P--~e-Cer'ent Syeter eerpenen*

u _2...:__...u

---J' rr- - - - - - ' - - - - - - - - - - - -

l omnrece enuvoni conceau i

?.22 The P ^^Ec5 CO

OL P"OOP_^Y (PCP) che!' cente!- ahe cr-en ferrr er.

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--.;Ex;, en:!y-. 'ee' xf ' :-- '- 't n: te be -- "- te en:ure "et N

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9; ef --"-' er :! "_ ': f e: ' c'M r;--te: 29! 5e ::--": Sed !-

c'M e ';;ry : te ---" c z.., ":.: r " 10 CF e"- 20, S t, trd ?*, e'-t

---+ tx, be".e! ; end ::7xxx::, end ether :- ei:xxx:: ;e= ' ; twe l'

'- ::e! ef re'd4adieselwo.weste.

l gayggr,gaWilfsHHi 7.945;M 9.

= -

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r 5.5ibbi25^d,~.^2,52 Ei.3,'d5-}[' "' 'Temperadaycs %m d

  • 24 UP.O E er UPC'"O che!! 5e eny ee.. :":f ;:: n:: ef "-'- ;in; cir er LCD 3. 4 "A 0^5.N5_2 3.-

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ccc> s.+.it, % T. m [, %

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f(NEW) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) l M ** "

The PTLR is the unit specific document that provides the reactor vessel pressure - gp

[j and temperature limite, including heetup and cooldown rates and the power operated relief valve llR settings and the Low Temperature Ca.,, :zure Protection (LTOP) System arming temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with the Admin _istrative Controls section.

Plant operation within thesejimits are addressed in"@C ' C

'#,,)% ),g 9 f

OUADRANT POWER TILT RATIOlgf rennh 1.25 0U.^.0 ^."7 60'^E" T!LT P^.T40lOPTR)shall be the ratio of the maximum

l[ld8iAj g upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater. With one excore detector inoperable, the remaining three detectors shall be used for computing the average.

RATED THERMAL POWERN5iPI) 4,26 P_^.TED T9EP?=^1 PC'.^fP.!RTP)shall be a tota (reactorJcore heat transfer

%.01%~'

rate to the reactor coolant of 3565 MWt.

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REACTOR TRIP SYSTEMiiETSlRESPONSE TIME 4,27 The c ^ CTOP "' SYSTE!.9TSiRESPONSE TIME shall be the time

' "108/AT interval from when the monitored parameter exceeds its Trip Setpoint at the channel sensor until loss of stationary gripper coil voltace.IThe response time g g, g,,

j "may means of any series of tial, overiapping, or total letops s a the entire response time i

,g g y

g g.,

g,:ne be j

ocono. yD*8%@

cri cAiiwselected campenents ided ph* %e compnenh oma. tvwhodo fo g r af m h m p q q vaveAig l

  • 28 ^ o.EPOPT^nLE EVE"T the!! be eny of *ere eene en::ree nee r.

11-19-A1 c Men 50.72 te 10 CFo Pe + 50.

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i WOLF CREEK - UNIT 1 1-5 Amendment No. 42, G1,69 Mark-up of CTS 1.0 S/1S/97

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CHANGE IMBEB MSIE DESCRIPTION l 41.1-3 i

fless stri ve ce t curr t TS finit' n def nes (t

mov t of ny c nent ithin e re tor v sel ith f i

e ve 1 as Core erat' n.

eve,

si t

ropose defini on wou limi core te tions Lot manip ations at cou aff core ea ivity. -

1 t ropos hange ' accept le fr the a

int of heal and sa y of t publ 1 07 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38).

1 08 A

The current TS definitions for Engineered Safety Features Response Time and Reactor Trio Svsta= Resoonse Time would )Gt.e-4 l

  1. "A b.'d be modified to be consistent with NUREG 1431*

n D N""

a di n, t term " asur "woujdberep ced b ified" to be onsis t wijYthe r reme of f mprov TS S

.3.1.

and SR 3.3.2 to v ify res6onse dime s wit n limi Ahe addition of the statement that response time may be%Fri74ep by means of any series of measureA-sequential, overlapping, or total steps so that the entire response time isl%@@, is administrative in nature.

This is consistent with the methodology presently described in the current TS Bases for demonstrating total channel response time.

(osscr 3A-Q 1-09 A

The current TS definition for Frequency Notation (and Table 1.1, Frequency Notation) would be deleted to be consistent with NUREG 1431. The acronyms defined in Table 1.1, Frequency Notation, are no longer used in NUREG 1431.

Surveillance frequencies are spelled out in NUREG 1431, thereby obviating the definition. This is a non technical change made to conform to NUREG 1431.

=

os.s.i.y l 1-10 g

T inition r ma al able primary tai nt leak rat (L, )

uld be dded t the imp ved TS t con stent ith NURE' 1431.

his g

ition h n

ermi to be admin trative h

change o he bas' tha his def ition s simpi

[ cop from SA nistrati Contr s Secti 6.8.41] \\

t he defin ions.

M uwd.

j 1 11 A

The current TS definitions for Identified Leakage.

Unidentified Leakage, and Pressure Boundary Leakage have been merged into one definition for Leakage. This is a nontechnical change since it will not alter the manner in which leakage is accounted for and treated from present WCGS-Description of Changes to CTS 1.0 2

S/15 M 7

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INSERT 3A-2a 0 1.1-4

-Likewise, the addition of the statement that response times for selected components may be verified by other means approved by NRC is also administrative in nature since it allows no response time testing change unless NRC approval has been first obtained.

This statement is consistent with Section 6.3.4 of IEEE 338 1977, traveler TSTF-111. and approved topical reports on response time testing verification methodology.

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CONVERSION COMPARISON TABLE - CURRENT TS 1.0 rage i of 4 l

APPLICABILITY TECH SPEC CHANGE l

DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY NUEER DESCRIPTION 2-01 These definitions would be reworded to be consistent with Yes Yes Yes Yes A

N'JREG-1431. The proposed rewording included in this category does not involve any changes of a technical nature.

1 02 The definitions for Analog Channel Operational Test and No - do not have Yes No - do not have No

  • Digital" is A

Digital Channel Operational Test would be combined into a the Digital Channel the Digital Channel not included in single definition of Channel Operational Test (C0T).

Operational test Operational test current TS.

definition.

definition.

1 03 The definition of channel calibration is reworded. The Yes Yes Yes Yes H

revised wording provides additional detail concerning calibration of instrument channels with RTD's or thermocouples,

/

1 04 This definition would no longer be used and the Yes Yes Yes Yes c

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specifications in Section 3.6 would be revised accordingly.

The current TS niti n for Containment Integrity would be'

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deleted.

mptoci. ioins 4he, new regssisM ntf lygvwe.dT5 3.L.t -ftw' conWenww d b k OPEM q 3.s.4.Q 1 05 The current TS definition for Controlled Leakage would be Yes Yes No. See Change No. See Change Number 1-28-LG.

Number 1-28-LG.

A deleted.

[b $4o. h d-hes 1 06 The current TS definition for Core Alterations would be No. Already in CTS.

Yes ic>s i A corporated L t.t-3 }

LS-1 modified to qualify a core alteration as movement of fuel.

ET:s smedQ./

sources or other reactivity control components.

107 A The location of the thyroid dose conversion factors used for Yes No. already in CTS No. already in CTS No already in CTS DOSE EQUIVALENT I-131 have been added in accordance with NUREG-1431. Rev 1.

1 08 The current TS definitions for Engineered Safety features Yes Yes Yes Yes A

Response Time and Reactor Trip System Response Time would be fd I 3-4 modified.Jina tion t term 7 meas

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Id r ac 15fver ied" be con sten ith r

r s

Ampro TS 3.3.1 and 3.

.10 ver)yr pd 4

ti is _ hin lim)ts.

5/15/97 tf *rre rne.,. evinse rne.mneir(nee Tur!>lo - m ! il

INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 TRAVELER #

STATUS DIFFERENCE #

COMMENTS TSTF-19, Rev. I hincorporated

.NA Ret NRC approved #o]f l ui o-cSJ 1 t-r2-p,i,,,,ogame, j

TSTF W,P7 Ihorated 1.1-9 @

gi :-G CTFr6#

is<ireWV X1C Eg.i-t1 (TJTr,,sr sparppr6etr 12 0 Loi.i-a \\

TSTF-111, Rev.hMorated 1.1-5

{o n.1-4 1

@,-#f M" Incorporated

.1-6

{9

[Gi I-F l h-MrRywr71 Incorporated UD.1-3

[al.4-h WM Incorporated

.1-11 1G14-11 TSrp-G2 Iwper> yea '

l.1-13 a

1 1

L os.t.t-c. I

%.O ine.o y <sted che p{ ORC c.cmmd i

4 i :a.

S/15/97

Definitions 1.1 1.1 Definitions (continued)

E - AVERAGE E shall be the average (weighted in proportion to DISINTEGRATION ENERGY the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives

^ B"4

> 15 minutes, making up at least 95% of the total noniodine activity in the coolant.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time FEATURE (ESF) RESPONSE interval from when the monitored parameter TIME exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable._gg,'q The response time may be meestee(SITRM)by means of any series of sequential, overlapping, or total steps so j y M1!LSM (usdrii-sh the entire response time is meesteHW y

The ximum lowa e pr' ary ntai nt lea ge r e.

. shall e 0.2 of imar contai nt a wei t per gG l

q day a e cal late peak ontai nt pre ure

,).

j LEAKAGE LEAKAGE shall be:

N3 b i-9 a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank:

2.

LEAKAGE into the containnent atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE: or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator (SG) to the Secondary (continued)

WCGS-Mark-up ofNUREG-1431 - ITS 1.0 1.13 S/15/97

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INSERT 1.1-3 0 1.1-4 I

In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been i

previously reviewed and approved by the NRC.

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Definitions 1.1 1.1 Definitions (continued)

PHYSICS TESTS b.

Authorized under the provisions of 10 CFR 50.59:

(continued) or c.

Otherwise approved by the Nuclear Regulatory Commission.

PRESSURE AND The PTLR is the unit specific document that TEMPERATURE LIMITS provides the reactor vessel pressure and REPORT (PTLR) temperature limits including heatup and cooldown i

^ ~bl%63 rates andltte power ~dper_ated;teUefJvalve lift settings' anGhe-L%hrature: Overpressure Ptotection%tTOP) SDtenrgarsrfag temperature,. for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with p,,,.., ;

Specification 5.6.6.

Plant operation within these limits g g d ggged in 6 1

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Ah./

y I. r " = "" =,.r, r r.....: r, =. n..c'd t

m....., u m

T@er;tur; Onipic;;urc Iret;; tier. (LTOP' 3;tc;;;."

QUADRANT POWER TILT QPTR sha'll be the ratio of the maximum upper RATIO (QPTR) excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the i

ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer (RTP) rate to the reactor coolant of. 3565 MWt-(BePSs REACTOR TRIP The RTS RESPONSE TIME shall be that time interval SYSTEM (RTS) RESPONSE from when the monitored parameter exceeds its RTS TIME trip setpoint at the channel sensor until loss of stationary gripper il voltage. The response time may be 5,;;;urcd by means of any series of 5N sequential, overlapping, or total _ steps so that the

$1 liSM entire response time is'.n;;ured @pTf@. QUseKr 1.1-bi.i.4g SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is suberitical or would be suberitical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCU. of highest reactivity worth, which is assumed to be (continued)

WCGS-Mark-up ofNUREG-1431 -ITS 1.0 1.1 5 S/1587

INSERT 1.1-5 0 1.1-4 In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC.

(

l DIFFERENCES FROM NUREG-1431 Section 1.0 This enclosure contains a brief discussion / justification for each marked-up technical change to NUREG 1431. Revision 1. to make them plant-specific to incorporate generic changes resulting from the Industry /NRC generic change process. The change numbers are referenced directly from the NUREG 1431 mark ups. For Enclosures 3A. 3B 4, 6A and

68. text in brackets "[]". indicates the information is plant specific and is not common to all the Joint Licensing Subcomittee (JLS) plants. Empty brackets inidcate that other JLS plants may have plant specific information in that location.

CHANGE NUMER JUSTIFICATION 1.1 1 The NUR - 431

.1 initio f Chan Calibr ion s es "The D C

CAL TION all e ass t entire annel nelud the I

uir

ensor, arm, i erlock,
splay, trip unctio s

.cha clarif what ompass the en e chan by r rdin initio o state The C EL CALI TION 11 e ass se compo

s. such s sensor, alarms display, and t p fu Cha[ns,/

o red to form the pecifi safety f tion

." T ration est, a rip Ac ting Dev'ce Oper tiona est d(finitions (aresi arly revi This change i consis t wi TSTF 64. tusEArp-Ib 1.1 2 Not used.

1.1 3 Adds new example to ITS 1.4 to clarify meaning of SR Notes of the type "Only required to be performe_d in _ HOD _E..."m This change is consistent with traveler @G44 4e#1T toi 4-i i 1.1 4 Not used.

1.1 5 The definition _s for ESF Response Time and RTS Response Time (Gt 14 \\

revise _d/tos stit the rd " erif "i lieu f "me 'ur'ed" "cpnfi en ith r

r s of E

431 3.3.16 SR 4.3

.1. Thi cha woul ens e co ste y bet nt def iti R ponse ime t

equ emen to, riodi. ally erifv es s

'1 is wi in 1 its.

his ang isfconsistent with traveler TSTF-3 111. Q 1.1 6 The definition of the Pressure and Temperature Limits Report (PTLR) would be revised to include the maximum allowable PORV lift settings and arming temperature associated with the [ Low Temperature Overpressure Protection (LTOP)] System, and to be consistent with the COLR definition. Improved Technical Specification 3.4.12 states that the PORV lift settings are specified in the PTLR. The current definition for PTLR does not identify these lift settings as being contained in the PTLR.

g WCGS-Differencesfrom NUREG-1431 - ITS 1.0 1

$/1587

INSERT 6A-la 0 1.1-4 The addition of the statement that response times for selected components may be verified by other means approved by NRC is administrative in nature since it allows no response time testing change unless NRC approval has been first obtained.

This statement is consistent with Section 6.3.4 of IEEE 338-1977, traveler TSTF-111, and approved topical reports on response time testing verification methodology.

fNSERT 6A-lb 0 1.1-2 The NUREG-1431 Rev. I definitions of Channel Calibration Channel Operational Test, and Trip Actuating Device' Operational Test use language to describe the scope of testing similar required sensor, alarm. interlock, display, and trip functions. The word " required" is ambiguous and subject to misinterpretation as to whether the list is inclusive or represer.;ative. This change clarifies what components are inicuded by specifying "all devices.in the channel required for channel OPERABILITY." A similar clarification is provided for

'the Actuation Logic Test. This change is consistent with TSTF-205.

l 1

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' CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 l' age I of 2 SECTION 1.0 DIFFERENCE FROM NUREG-1431 REV.1 APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMAlCHE PEAK WOLF CREEK CALLAWAY 1.1-1 Tis c Id clarif t

sses t ent1D Yes Yes Yes Yes cha 1b ewo ng defin on to st e"

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  • k I

TI st;all ss t ec nts in c nel uch as sors, a

, di ays.

ip ti

. that e requir to perf the r

s ift afety f tion (s)

The COT and T (definitonsare imila_rly evised.

1.1-2 Not used N/A N/A N/A N/A 1.1-3 Adds new example to ITS 1.4 to clarify meaning of SR Yes Yes Yes Yes Notes of the type. "Only required to be performed in PODE.. ~

1.1-4 Not used N/A N/A N/A N/A 1.1-5 The definitions for ESF Response Time and RT5 Respcase Yes Yes Yes Yes Time W evised.lo s titu t wor o

43 3.3

.1 nd L3. 3

.1 f 1.1-6 The definition of the Pressure and Temperature Limits Yes Yes Yes Yes Report would be resised to include the maximum allowable PORV lift settings and the arming tenperature associated with the system, and to be consistent with the COLR definition.

(MiA5h cliviido &=- defiWiboA of CHAddE1 cat _tBRAT1od, ccsr, ed.TADcrr b3 r=placqou a, bipoo.s. -kQ wHh

'* devic'as 6'the chmvudL regu.uud b cbmd oPEF.Aht.tW.

6 ACMN %ic. Test defam*ih 6 is.=ImMarb vevi$cd..

sasm wcas. con,ersi comparision raue-1rs1.o

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ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.4.9-3 APPLICABILITY: CP, WC l

REQUEST:

Difference 3.4.17 (Wolf Creek, Diablo Canyon and Comanche Peak)

Comment: TSTF-93 Rev. 3 was approved with a reviewer's note which says that for non-dedicated safety-related heaters which normally operate the frequency is 18 months and for dedicated safety-related heaters which normally don't operate the frequency is 92 days. Each of the plants is asking for the 18 month frequency but it is unclear from the submittals if they meet the criterion. Please provide information demonstrating consistency with the TSTF.

FLOG RESPONSE: (original)DCPP and WCGS have two-groups of non-safety related pressurizer backup heaters. The pressurizer heaters, together with the pressurizer spray valves, are used to control RCS pressure.

For DCPP, the NRC recently approved (6/5/98) changing the CTS SR 4.4.3.2 from 92 day to " Refueling Interval" in L:A 126/124.

i l

For Comanche Peak, the pressurizer heaters used to satisfy the pressure l

control function are comprised of one proportional control group and three l

backup groups. The design and operation is consistent with the basis for l

an 18 month surveillance described in Section 6.6 of NUREG-1366 (which l

was the basis for TSTF-93). The heater groups are normally connected to the emergency power supplies (two to each Class 1E train of emergency l

power) and normally operate. CPSES will revise the 3.4.9 BASES to reflect the NUREG-1366 basis for the 18 month frequency.

l FLOG RESPONSE: (supplement) TSTF-93, Rev. 2, contains the following Reviewer's Note, "The frequency for performing Pressurizer heater capacity testing shall be l

either 18 months or 92 days, depending on whether or not the plant has dedicated safety-related heaters. For dedicated safety-related heaters, I

which do not normally operate,92 days is applied. For non-dedicated l

safety-related heaters, which normally operate,18 months is applied." As l

used in this note, safety-related heaters means heaters which are powered from a class 1E electrical distribution bus. Normal operation l

includes operation during power operations, unit start-up and/or unit l

shutdown. Dedicated heaters are heaters wnor enly function is the mitigation of a design basis event. This is consistent with Generic Letter i

l 93-05, *Line-Item Technical Specifications Imreovements to Reduce Surveillance Requirements for Testing During Power Operation," which indicated that the capacity of pressurizer heaters should be tested once each refueling interval for those plants without dedicated safety-related heaters.

In all cases where a FLOG plant has used the 18 month frequency in the ITS for performing pressurizer heater capacity testing, the requirements of l

the Reviewer's Note identified above have been met.

j ATTACHED PAGES:

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ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.4.12-5 APPLICABILITY: WC, CA REQUEST:

Differences 3.4-18 and 3.4-45 (Wolf Creek and Callaway)

Comment: The justification for the 4-hour pump swap is inadequate. The STS allows 15 minutes. The CTS is used as justification however, finding a pump inoperable and l

then restoring it (which is the case covered by the CTS) is very different than simply switching from one operable pump to another.

FLOG RESPONSE: (original)Four hours is a reasonable time restriction for swapping l

centrifugal chargirig pumps (CCP) during the low temperature overpressure protection (LTOP)/ cold overpressure mitigation system (COMS) Applicability.

Current Technical Specification (CTS) 3/4.4.9 Bases state " Operation below 350F but greater than 325F with all centrifugal charging and Safety injection pumps OPERABLE is allowed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />..... Given the short time duration that this condition is allowed and the low probability of a single failure causing an cverpressure event during this time, the single failure of a PORV is not assumed. Initiation of both trains of Safety injection during this 4-hour time frame due to operator error or a single failure occurring during testing of a redundant channel are not considered to be credible accidents." Additionally, CTS 3.5.4 requires all Safety injection pumps and one CCP to be inoperable. If this requirement is not met, then four hours is allowed to return the pump (s) to an inoperable j

status.

l Performing CCP swap operations for maintenance activities requires both pumps to be capable of injecting for a limited period of time. During the time allowed for pump swap operation, the inoperable CCP must first be restored to OPERABLE status to meet ITS LCO 3.5.3 (MODE 4) and USAR/FSAR Section 16.1.2.3 (one OPERABLE CCP in boration flow path, MODES 4-6). Then the other CCP must be rendered capable of injecting. In order to render the other CCP incapable of injecting into the PN. N requirements of ITS SR 3.4.12.2 must be met. SR 3.4.12.2 sates that a pump is rendered incapable of injecting into the RCS t'

ns.an iemoving the power from the pumps by racking the breakers out under administrative controls. The Bases also state that an alternate method of cold overpressure protection control may be employed using at least two independent means to render a pump incapable of injecting.

Each method includes local actions (e.g., breaker racked out and tagged, valve closed and tagged). These actions for restoring the one CCP and then rendering the other CCP incapable of injecting into the RCS cannot i

be performed from the control room. Swapping of CCP trains is a short l

duration evolution but must be performed in a controlled manner especially when coordinating activities outside the control room. The 4 l

hour time allowance provides for normal operation of the plant and allows plant manipulations / evolutions to be performed in a time frame in which they can be safely performed.

j

Amsndment No.103 (Callaway) and Am:ndment No. 89 (Wolf Creek) revised current TS 3.5.4 to provide a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> AOT to restore one CCP to an inoperable status in MODES 5 and 6. This 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> AOT was specifically reviewed and approved by the NRC as noted in their safety evaluations for those license amendments. This portion of the COMS/LTOP Applicability is the most limiting, as it may involve water solid operation.

Current TS 3.5.3 (SR 4.5.3.2) allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to secure one CCP after entering MODE 4 from MODE 3. Current TS 3.5.2 requires both CCPs to be operable in MODE 3. Therefore, all of the ITS 3.4.12 Applicability is based on the current TS except for MODE 4 beyond 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after entry from MODE 3. NSHC LS-24 justifies 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for all of MODE 4.

FLOG RESPONSE: (revised) This is a modified response, which replaces the original response provided in Reference 3 of the cover letter, in order to respond to NRC reviewer comments.

Attachments 10 and 11 have been revised to reflect a limit of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for CCP pump swap operations, consistent with traveler TSTF-285. This is a i

more restrictive change except in MODE 4 beyond 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after entry l

from MODE 3. In addition to the CTS and ITS mark-ups, the attached i

pages contain revisions to DOC 9-17-LS-24 in Attachment 10 (3.4) and 1

l DOC 4-05-M in Attachment 11 (3.5). JFDs 3.4-18 and 3.4-45 do not l

require changes due to the general nature of their wording.

j i

ATTACHED PAGES:

Attachment No.10, CTS 3/4.4 - ITS 3.4 i

j Encl. 2 4-34 (insert 3.4.9.3-1)

Encl. 3A 18 Encl. 3B 13 Encl. 4 50 Encl. 5A 3.4-29 Encl. 58 B 3.4-67, B 3.4-68 Attachment No.11, CTS 3/4.5 - ITS 3.5 Encl. 2 5-9 Encl. 3A 7

Encl. 3B 6

1 1

4 i

t

q3.411-F \\

l h.u.c

=

(INSERT 3.4.9.31]

made 43.4.11-2.}

F "OTES

1. Two centrifucal' ha ing pumps may be capable of injectingd 9-17-LS-24

,1beitCJep4t r-for pump swap operations.

. r

2. Two safety injection pumps and two centnfugal charging pumps may be ca of injecting into the RCS:

{

C 14 a.4.614 l (a) in MODE 3 with iny RCS cold leg temperature < 368* F and ECCS pumps OPERABLE pursuant to LCO 3.5.2, "ECCS-Operating", and (b) For up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after entering MODE 4 from MODE 3 or until the temperature of one or more RCS cold legs decreases below 325'F, whichever comes first.

d l @ &4 12 -F_]

3. One or more safety injection pumps may be capab of injecting into the RCS in MODES 5 and 6 when the RCS water level is below the top of the reactor vessel flange for the purpose of protecting the_ decay heat removal

'"acSaa-g, % u ot e. r >

s ei m

4. Accumulator 7

__;L...,..,_Owhen accumulator pressure is Q 3.4.G - L }

(tharror.equaPfethe maximum RCS pressure for the existing RCS cold tog temperature allowed by the P/T limit curves provided in the PTLR.

Mark-up ofCTS3M.4 S/15/97

CHANGE Nt#EER tl21C DESCRIPTION acceptable period for performance of this COT and does not pose a significant ir. crease in risk. The channel calibration is still maintained current. This change is less restrictive and is acceptable as stated above.

9-13 A

Consistent with NUREG 1431. CTS Specificaiton 4.0.5 has been moved to the IST program in the Administrative Controls Section of the ITS (ITS 5.5.8).

j 9 14 H

In conformance with NUREG 1431 Rev.1 an additional surveillance is added to verify accumulator isolation when accumulator pressure is greater than or equal to the maximum RCS pressure for the existing cold leg temperature allowed by the P/T limit curves provided in the PTLR.

This change is consistent with adding the requirement for accumulator isolation to the LC0 (see CN 9 06 M). The addition of this surveillance requirement is a more restrictive change which is necessary to help ensure

[LTOP] analysis assumptions are maintained.

9 15 H

In conformance with NUREG-1431 Rev. 1. an additional action and corresponding SR are added for one or more SI oumps or more than one centrifugal charging pump capable of injecting into the RCS and subsequent actions for RCS depressurization and venting if necessary. [ ]

9 16 H

Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

9 17 LS 24 Three notes are added to LCO 3.4.9.3 to reflect current TS SR 4.5.3.2. LC0 3.5.4 ACTIONS a and b. and the LCO 3.5.4 Applicability note *, A fourth note is also added to LCO 3.4.9.3 to correspond to the accumulator Action added under CN 9 10 M.

The note regarding CCP pump swap operations represents a relaxatien since it would allow both CCPs to be capable of inject into the RCS for up O

tow:!kprX)throughout the [LTOP]

licability as further g

g l43Alz-51 discussed in LS 24.

10 01 LS 21 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

10 02 A

Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B).

WCGS-Description of Changes to CTS 3M.4 18 5/15/97

CONVERSION COMPARISON TABLE - CURRENT TS 3/4.4 Page 13 of 13 TECH SPEC CHANGE APPLICABILITY NVPEER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 9 17 Three notes are added to LCO 3.4.9.3 to reflect current TS No - See change No - CTS allows 2 Yes Yes LS 24 SR 4.5.3.2. LCO 3.5.4 ACTIONS a and b. and the LCO 3.5.4 9-08 LS-7.

CCPs to be Applicability note *. A fourth note is also added to LCO OPERABLE.

3.4.9.3 to correspond to the accumulator Action added under CN 9 10-M. The note regarding CCP pug swap operations Mp McDE.4ea$

{g,4,32-6

- - - ^ -

represents a relaxatiorfsince it would allow both CCPs to be

^

capable of injecting into the RCS for up to@

Q throughout [LTOP) Applicability 10 01 The surveillance requirements asscoated with the RCS No. Amen &ent Yes No - Amen hent 89 No - Amen hent 103 LS-21 Structural Integrity specification r e deleted.

98/97 relocated to relocated to USAR relocated'to FSAR Equipment Control Chapter 16. Also Chapter 16. Also Guidelines (ECG).

see Section see Section 6.8.5.b.

6.8.5.b.

10 02 The Reactor Coolant Pug flywheel inspection requirement has No. Amenhent Yes No Amen &ent 89 No - Amenhent 103 A

been moved to Section 5.5.7 in the igroved TS.

98/97 relocate:! RCP relocated to USAR relocated to FSAR fl3 wheel Chapter 16 and CTS Chapter 16.

surveillances to 6.8.5.b..

CTS 6.8.4.1.

l 10 03 The Reactor Coolant Pug Flywheel Inspection Program is No - See CN 02 Yes No - See CN 02 No - See CN-02 LS-37 revised to provide an exception to the examination LS-1 in the ITS LS-i in the ITS LS-1 in the ITS requirements in Regulatory Guide 1.14. Rev 1.

The exception Section 5.0 Section 5.0 Section 5.0 (to Regulatory Position C.4.b(1) and C.4.b(2)) allows for an package.

package.

package.

acceptable inspection method of either an ultrasonic volumetric. or surface examination. The *nspection would m

e M S*M I conducted at8' ten year intervals coinciding witti tne

$N -

Inservice Inspection schedule required by ASE Section XI.

11-01 Removes the reactor coolant system vents specification from No. Amenhent Yes - To be No - Amen hent 89 No - Amendment 103 R

the Technical Specifications. The requirements for the 98/97 relocated relocated to the relocated to USAR relocated to FSAR reactor coolant system vents will be relocated to a licensee requirement to TRM.

Chapter 16.

Chapter 16.

controlled document.

Equipment Control Guidelines (ECG).

S/1587 WCGS-Conuw a Comparison Tables - CTS 3M.4

IV.

SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-24 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IHPOSE LESS RESTRICTIVE REQUIREHENTS WITHIN THE TECHNICAL SPECIFICATIONS E%@

A note regarding CCP puno swap operations has been added to LCO 3.4.9.3.

This i

represents a relaxationlince it would allow both CCPs to be capable of injecting into the RCS for up to throughout the [LTOP] Applicability.

@3.4.17E tbw This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below:

"The Comission may make a final determination. pursuant to the procedures in 50.91. that a proposed amendment to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the facility in accordance with the proposed amendment would not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2.

Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3.

Involve a significant reduction in a margin of safety. "

The following evaluation is provided for the three categories of tN significant hazards consideration standards:

1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

Overall protection system performance will remain within the bounds of the previously performed accident analyses since no hardware changes are proposed. The initial conditions and assumptions for the [LT0P] mass addition and heat injection i

transients will be unchanged. Actions will be taken to insure that only one CCP is capable of injecting into the RCS during the [LTOP] Applicability. Current TS 3.5.4 provides 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> A0Ts if one SI pump and two CCPs are capable of injecting during the most critical portion of the [LTOP] Applicability (lowest RCS temperature and the j

plant may be water solid). The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> A0T for one SI pump is deleted, however.

WCGS-NSHCs-CTS 3M.4 50 5/158 7

LTOP System 3.4.12 3.4 REACTOR C00UNT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP) System LCO 3.4.12 An LTOP System shall be OPERABLE with a maximum of e.; hit.

p;;;;r; ir.j;; tier. 0;"D m zero safety injection ptmps and F.. '

  • one M charging pump capable of injecting into the RCS and the accumulators isolated and ;ither ; er b b;1w. ogg!f E

ty httelte O legabg M e]s Ta = r; lief v; w;; ;; fell s ;.

ig. Two power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR or i!b. Two residual, heat removal (RHR) suction relief valves with setpoints a 436J5 psig and s 463!5 psig, or NN E EM Sc.

One PORV with a lift setting within the limits specified

}'Q in the PTLR and one RlR suction relief valve with a setpoint 2 43(4 psig and s 463:5 psi 43.4.n.q bd. The RCS depressurized and an RCS vent of 2 ih47 2J square

))

inches.

g g,,,a, y

....... NOTES ----------

g- -

c hyd8n$ bh Il Wa MgjWridiargitu2:25ts' M

__ eTWTsp$g!uggn e Eera aalremmwrwwap3;;;;;;;. rag -

gg gg-m

\\u4.i2.-2-1 m

w tc y,2,.,3 2;

Teso7==enwada.negggirsM.,sentrifigal"ittarging P.EuPC1BK1MsEstbWofitUecting 1.nto thitFJOZin M..WU IU!Epstbrariyasfcouisj!giteserstur_e~Z41se epnd:socSfpumps WERABIE mitsueGoMElp2MCEMhung1ggi:;4ag:4tp 1REenitMhilutsNsihteM MEL1*.flIn.01IEZO54]IRD tiie tagigirstireisteurwra!reNmTdmiraseisa:ses.RTm 325*FHM!1hcomesIftrst; maAa.

p.4,q.s ]

31 OneMaiiri.;siigrt~fliMeig]ptagnfi jgiyhyipM.(;of iniectism:.intlo theiRCSln;fEDESEagpl6f.ghehlu!3CS'wat~er Ffs3$20%

leveltisM1ow theitap~ofZthe?reactorivesse[Tlange:for 2

the purpo_selofjprotecting;the_,decaylheatlmaT"functi_onj m

k m 3 e. u v6

  • ol
  • D S b

b!9-- M ^=693 20when acctmulator

$$!$f45$

14.

Accumulator h

pressure is p fff..._. r c r ' ;,the maximum RCS pressure for the existing RCS cold leg temperature allowed lM+i2.-21 by the P/T limit curves provided in the PTLR.

e WCGS-Mark-sqp ofNUREG-1431 - ITS 3.4 3.4 29 S/1SM7

LTOP System B 3.4.12 BASES APPLICABLE RCS Vent Performance SAFFTY ANALYSIS (continued)

With the RCS depressurized. analyses show a vent size of E:07 2M1 square inches is capable of mitigating the ;11cd l."'

MudUmsM everpresem transient. The capacity of a vent this size is greater th: the flow of the limiting transient for the LTOP configuratioi.. two o@!ntti.jepaTcharging pumps OPERABLE. maintaining RCS pressure less than the maximum pressure on the P/T limit curve.

The RCS vent size will be re evaluated for compliance each time the P/T limit curves are revised based on the results of the vessel material surveillance.

The RCS vent is passive and is not subject to active failure.

The LTOP System satisfies Criterion 2 of th; =0 l'clicy Statement-lIOMW363cg2)(ii)j LCO This LCO requires that the LTOP System is OPERABLE. The LTOP System is OPERABLE when the n+ meta minifmum coolant input oglpjt ggstlM_.ht@!st2assumedjpA5agalysesland required pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient.

Tolimitthecoolantinputcapability,theLCOrequiresthatla LuajgteiEmzero safety injection pumps and two onsTeer!ttMggel b3m-M

~

charging pumps"be! capable of injecting into the ROnd all ator discharge isolation valves b6 closed aht iussobilized h

acc lacetanulator pressure is greater than or equal to the max RCS pressu for the existing RCS cold leg temperature allowed in the.

(osA.i2-Fi wgommewd ylfour_mtesamteranows:t=6.centt1Aval char 3lLHDgrupUtol_, capable ofijnjectingliintoittjeJCS1 ftir 3%

@J7Aiornithe;.ptmp~susp;activitiers>OesrGMi.ps.w z l R8r48umpl8esEoperationsatrtsarovides; tere +neceses MER$!b!!Ble5Mf1Climtitime3Xi.30apleteGthe_ activities Mire;almaximunjf one~centrifega]ichargingEiLDup

.capablKof11rdecting.MDhisifs accomplishbd;tiy1 racking out"the" breaker for1one' pump;or, employing (continued)

WCGS-Mark-sqp ofNUREG-1431-Bases 3.4 B 3.4 67

$/1/5/97

LTOP System B 3.4.12 BASES MiE.".1tidependent:miea_nsitolretentia, pumpyattJ nlagconda!!yfMth 1

E M s.4.it-F }

Not & recognizesithe.?pplicabili"ylover[ap~tietaleren3I01sM332 tigaMammO*atethat taintsne gympirctierrsusimrnidissilo ggtrXugliT5122rgiyyitm!praayW'cepsbTeI6EJg3eicttWfewnire l

F1 redh6c (Q.%0cn-lj 1 (a)

In MODE 3 with any RCS cold leg temperature < 368* E and ECCS pumps OPERABLE pursuant to LCO 3.5.2, "ECCS-Operating", and (b]

ForatiW4ThourMhfter'entetijg[0EL4JTeam1MjDE7ar3he t~qujp]ggg!eT6fioneZonsore~RCS:c61ld;1jegshJbelbiit 3257Fil$LchWeFiconeslf'irst?

,m made a 3.4 n-s 1 Noti S*stathCtfatZorWorfmoreisafety~1MectiorGxiusis~Ei MH1e 6C hiect 51 intoitheiRCS"in suut:EST:aVMVeherUthe'RCS r

it03ir3eeT]nWhilGlilMhe:1hpKttielslMi@otManieT28ereli'WiRhe wymangtge3qp :-- :;;gy rm Mag 31m

,Wpsuulager 1i g=,=e>

termicanauxrvessorsw.marm wr 51SmssureEarJine;,eJQslt @iCMMMM S32in'1'7T3WultMfpttivJdeid!irttN6MWshM ttie3ccumulatodistitarge isolation:valle3nrgelipance30 be perf6rmedwirandeGmes._e;Lmessureland7.temperatuniEcanditsens The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

e.

Tw; RCC r:11;f ::alv;;. ;; f;ll s ;.

-la.

Two OPERABLE PORVs: or A PORV is OPERABLE for LTOP when its block valve is open, its lift setpoint is set to the limit required by the PTLR and testing proves its ability to open at this setpoint.

and motive power is available to the two valves and their rear.(DS M M*t) control circuits.

u

\\QSG.Gm-t \\

Eb.

Two OPERABLE RHR suction relief valves; or i

g..

(continued)

WCGS-Mark-up ofNUREG-1431-Bases 3.4 B 3.4 68 S/1/587 l

EMERGENCY CORE COOLING SYSTEMS a

3/4.5.4 ECCS SUBSYSTEMS -T _ < 200*F i

j LIMITING CONDITION FOR OPERATION 3.5.4 All Safety Iniection pumps and one Centrifugal Charging Pump shall be : :;:--i':

(incapable of injecting erno me RCS)

]

APPLICABILITY: MODE S and MODE 6 with the Reactor Vessel head o#

j 1

ACTION i

a. With a Safety injo@on PumpAirtwo Centrifugal Charging pumps capable
  • Ep'!L%(Q'

~

a 1

Fofinjectinginto the RCS,:

^ "i nitiate action to verify a i

i maximum of aero Safety injection pumps and a maximum of one i

Centrifugal Charging Pump are capable of injecting into the RCS and

""~

j the p(e) to a condition incapable of injecting into the RCS 4

Ihow othenales, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressuttas the RCS and L estabHsh an RCS vent of 2 2 miuam inches {

{

i

{

]

2 4.es-t1

.y f

&3.4 81-S]5. ."_^'. 4t-C:._ '7. ' C'. -_.... ; P' g: O."__E". ^"LE, ~.

f p ?f Q ?$

_ _ ::: '.S gAgemgeg 3

r

.._ _, e_ m

_o m

e.<,-

2 u...

._y.'y'

--r-"--'-

r-

~,.

3

.m <.

1 J

SURVEILLANCE REQUIREMENTS t

4._5.4.1 All Safety injection pumps shall be demonstrated : :;:zi'_

j p _gqip Qes.g,g

.-,-..__._m__

___._m_m_______m.__

j

-' "- ' ;r; --- ?? i,;.@ capable of irgecting into the RCS at loest once]

Oier12 hours]

4.5.42 One Centnfugal Charging Pump shall be demonstrated : :;:- e?"

./

l

.2:,t; z' S. :

z: 5 5 :;: ;: * -. et

  1. "4tt3.M$*$

f7

': :^ z:: ?-- ? ? t, "ncapable of injecting into the RC5 at least once per]

Q2 hoursJ

....___.u..o..r.e...._.__,_.._,u.<__m_..m.__,m,,___._,..___,.___.um e,....

._7

.y.

--_,.,..__o._____.u.n.._oo,e.u...,_,_____,.___.:__m..

oe

_ _ uy g

y m, m.

____y

.._..,....._..w-.

..... __ ___.. u

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- _,, _,... - - _ ___.a___

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--r-'r---,-------'-'

e' "-" -' W -

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f M "=- ';. ;; -' 5 -'_-- '.
: i : : ': T - - f 5- "- R"* / : ^' :

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  • ':'" :';; T. ;: z 21: :d !- z M :5; ^': _., c' b : zz2:!

.2 i e_ _..u.____..__2 __..m. r-- WOLF CREEK-UNIT 1 3/4 5-9 Amendment No. 36,89 Marksgr ofC753M.5 $/1537

~ - _ - CHANGE NUMBER R$liC QESCRIPTION l 4 01 LS 4 In conformance with NUREG-1431 Rev. 1, the LCO requirement to satisfy cold overpressure analysis assumptions on ECCS injection sources by rendering pumps inoperable has been revised to preclude those ptaps from injecting into the RCS. This change revises the LCO Action Statements, and Surveillance Requirements and allows deletion of the note dealing with testing and accumulator filling. This change is less restrictive on the configuration of the ECCS ptmps but does not result in a less conservative operational position as flow to the RCS is still precluded. 4 02 H In conformance with NUREG 1431 Rev.1, the action required if ECCS pumps in violation of the cold overpressure analyses are capable of injecting into the RCS has been changed to require imediate action initiation. Otherwise, if precluded from compliance, to depressurize the RCS and establish the necessary vent path within 8 hours. This change is more restrictive regarding the entry into the immediate action. 4 03 H This change in accordance with NUREG-1431 Rev.1, req 0 ires the verification that the disallowed ECCS pumps are not capable of injecting to the RCS on a 12 hour frequercy. Previously a 31 day verification on breaker position was required. The increased frequency is more restrictive, however, the verification can now be performed using control room indication and administrative controls, as discussed in Bases for ITS SR 3.4.12.1 and 3.4.12.2, in contrast to field verification. There is no decrease in assurance that the pumps will remain incapable of injecting into the RCS. 4 04 A The Applicability Note regarding SI pump operability in Modes 5 and 6 to protect the decay heat removal function has been moved to Applicability Note 3 of improved TS 3.4.12 _-b 434.12-6 (" 4 05 H The 4 hour A0T for completing actions to make one CCP incapable of injecting, per current licensing basis, has been moved to improved,TS 3.4.12. LCO Note 1. The four hour ADT for the SI pumps has been deleted. This is Gefwidefo@more restrictive because the new Required Action in improved TS 3.4.12 Condition A specifies that imediate action must be taken; whereas, the CTS provides a 4-hour A0T. This change also supports CN 9-17-LS-24 in j the 3/4.4 package. 4 06 A Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). I WCGS-Description of Changes to CTS 3M.S 7 S/l5/97

CONVERSION COMPARISON TABLE - CURRENT TS 3/4.5 Page 6 of 6 TECH SPEC CHANGE APPLICABILITY NUPBER DESCRIPTION DIABLO CANYON COMANCHE pef:K WOLF CREEK CALLAWAY 4 03 This c'sange requires the verification that the disallowed No - DCPP does not Yes Yes Yes M ECCS pumps are not capable of injecting to the RCS or. a 17. have this TS. hour frequency. Previously a 31 day verification on bretxer position was required. 4 04 The Applicability Note regarding SI pump cperability in No - DCPP does not No - CPSES CTS does Yes Yes A Modes 5 and 6 to protect the decay heat removal l'ua'. tion has have this TS. not have this note been moved to Applicability Note 3 of improver! IS 1.4.12. 4 C.; The 4 hour A0T for coupleting actions to inake one CCP No DCPP does not No - CPSES did not Yes Yes M incapable of injecting, per current licensing basis, has have this TS. include this A0T. been moved to inproved TS 3.4.12 LCO Note 1. The four hour A0T for the SI punps has been deleted. /_(and. decreasalle I Q .9 34 I2 ~6 4-06 The existing requirement to verify that the safety injection No - DCPP does not Yes No See change No. No See change No. A pump's motor circuit breakers are secured in the open have this TS. 3 12-A. 3 12 A. position within 4 hours after entering MDDE 4 from MODE 3 is no longer necessary. 5-01 The completion time to restore boron concentration or No The 8 hour Yes Yes Yes LS 7 borated water temperature to within limits is increased from restoration time is 1 to 8 hours. already part of current TS 5 02 The shutdown requirement for inoperable RWST would require No - Already part Yes No - Already part Yes LS-10 achieving MODE 3 within "the next" 6 hours. of current TS. of current TS 5-03 This change converts the DCPP RWST volume requirement from Yes No No No A gallons to the equivalent percent tank level. 5-04 This change modifies the ACTION Coupletion Time to restore Yes No - Already part No - Already part No Already part LS 12 RWST water temperature from 1 to 8 hours. of current TS of current TS of current TS S-os ICP.3.5-co2. ] A WCGS-Conversion Conparison Table - CTS 3M.5 5/15/97

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.5.5-2 APPLICABILITY: CA, WC REQUEST: Section 3.4 DOC 6-28 LG CTS 3.4.6.2.e & 4.4.6.2.1.c STS 3.5.5 This change is a change to both the CTS and the STS and is beyond the scope of the conversion review and is generic. In addition, it is not consistent with the conversion submittals for Comanche Peak and Diablo Canyon. Comment: Please revise the conversion submittal to include an LCO equivalent to STS 3.5.5, " Seal Injection Flow." The information provided in DOC 6-28 is not sufficient justification for moving these requirements to a licensee controlled docurnent. Also, please see comment 3.5.5-1 related to ITS 3.5.5 for Comanche Peak and Diablo Canyon to assist in preparing the specification for sealinjection flow. FLOG RESPONSE: (c,riginal) Union Electric Company and Wolf Creek Nuclear OperMing Corporation disagree with this RAl's assertion that DOC 6-28-LG, and the choice to not adopt ISTS 3.5.5, is a change to the current Technical Specifications (CTS) with generic implications. Further, consistency with the Comanche Peak and Diablo Canyon conversion submittals is not a prerequisite for our conversion to the ITS. The ISTS seal injection LCO was not adopted based on our CTS definition of CONTROLLED LEAKAGE which refers to seal water flow from the seals, i.e. seal leakoff, whereas Comanche Peak and Diablo Canyon define that term as seal water flow to the seals. Further, the Callaway and Wolf Creek RCS Operational Leakage CTS LCO 3.4.6.2.e and SR 4.4.6.2.1.c are also based on sealleakoff, not sealinjection. Our definition of CONTROLLED LEAKAGE, as well as the structure of our CTS LCO 3.4.6.2.e, SR 4.4.6.2.1.c, and SR 4.5.2.g.2), was accepted by NRC in a meeting between the SNUPPS utilities (UE, KGE, and SNUPPG Staff), Westinghouse, Bechtel, and NRC Staff (F. Anderson, J. Holonich, and D. Brinkman) on December 13,1983, prior to initial operating license issuance for both plants. CONTROLLED LEAKAGE, defined to be seal leakoff in our CTS, is intended to ensure proper RCP seal performance. Sealinjection flow rate does not provide an indication of proper seal performance, whereas No.1 sealleakoff does. Our CTS do not have a separate RCP seal water injection LCO because proper throttle valve position is ensured when we i perform CTS SR 4.5.2.g.2) every 18 months. The seal water injection l throttle valves, BGV0198 through BGV0201, and the seal water return l throttle valve, BGV0202, as well as the other ECCS throttle valves are set to ensure proper flow resistance and pressure drop in the piping to each injection point in the event of a LOCA. Once set, these throttle valves are secured with locking devices and mechanical position stops. These devices help to ensure that the following safety analyses assumptions remain valid: (1) both the maximum and minimum total system resistance; l

(2) both th3 maximum end mMmum branch inj:ction lins resistrnce; and (3) the maximum aN mud.am ranges of potential pump performance. These resistanc% and pump performance ranges are used to calculate the maximum and minimum ECCS flows assumed in the LOCA analyses of FSAR Section 15.6.5. The function of the RCP shaft seal assembly is to provide a pressure breakdown from RCS pressure conditions to ambient pressure, and thus maintain reactor coolant leakage along the pump shaft to a minimum. During normal operation, high pressure seal injection flow from the CVCS enters the pump through a connection on the thermal barrier flange at a rate of approximately 8 gpm per pump. About 5 gpm of this injection water flows downward through the main radial bearing and the thermal barrier heat exchanger into the primary system. The remaining 3 gpm flows up the shaft and enters the No.1 seal. The No.1 sealis a hydrostatically-balanced, film-riding face seal that has approximately 2200 psi of pressure drop across it. The No.1 seal is referred to as a " controlled leakage" seal because the leakage through the sealis predetermined by ensuring that the gap between the seal ring and the seat runner is held to a constant j value via a stable balance of hydrostatic forces on the seal ring. The No. 2 seal is a rubbing-face seal located above the No.1 seal. The No. 2 seal i backpressure forces most of the water leaving the No.1 sealinto the CVCS seal water return line. It is this No.1 seal leakoff flow that is surveilled to meet the CONTROLLED LEAKAGE requirement in the CTS. The No. 3 sealis also a rubbing-face seal, located above the No. 2 seal. The No. 3 seal backpressure, provided by the RCP seal standpipe, forces approximately 3 gph leakoff from the No. 2 seat into the Reactor Coolant Drain Tank via the No. 2 seal leakoff connection. No. 3 seal leakoff ] (approximately 400 cc/hr) is sent to the normal containment sump. The CONTROLLED LEAKAGE LCO limit ensures that the No.1 seal leakoff does not exceed 8 gpm per pump. This is a more proper gauge of RCP seal performance. In addition to the above CTS basis for not adopting ISTS 3.5.5, some of the DOCS and JFDs in Sections 1.0,3.4, and 3.5 (as well as a Bases insert ITS for SR 3.5.2.7) have been revised to provide additional justification for the proposed change by adding the following information: Add the following to DOC 1-28-LG in Section 1.0, Enclosure 3A: " CONTROLLED LEAKAGE as defined in the CTS has nothing to do with the performance of the ECCS system. That definition relates only to the proper performance of the RCP seals. Facility performance and operational details are required to be described in the FSAR by l 10CFR50.34. It is therefore acceptable to move the RCP seal water return flow limit to the FSAR since that return flow limit does not satisfy any of the four criteria in 10CFR50.36 and since that type of detailed information will be adequately controlled in the FSAR. Therefore, it is appropriate to delete the CONTROLLED LEAKAGE definition and maintain seat leakoff limits in the FSAR. See also DOC 6-28-LG in Section 3.4." l l

i Rsvise DOC 6-28-LG in S:ction 3.4, Enclosura 3A to road es follows: "The current TS definition of CONTROLLED LEAKAGE is deleted as discussed in DOC 1-28-LG in Section 1.0. The RCP seal water retum flow limit is moved to a licensee controlled document. Seal injection limitations are established by the throttle valve position surveillance in CTS SR 4.5.2.g.2) which la moved to ITS SR 3.5.2.7. This surveillance ensures that the ECCS analyses remain valid. Since facility performance and operational details of the type embodied by the RCP seal water return flow limit are required to be described in the FSAR per 10CFR50.34, it is acceptable to move the requirements of CTS LCO 3.4.6.2.e and CTS SR 4.4.6.2.1.c to the FSAR." l Revise Section 3.5, Enclosure SA, "NUREG-1431 Specifications That Are i Not Applicable" sheet, to read as follows for ISTS 3.5.5: " Seal injection flow rate limitations, consistent with ensuring the LOCA analysis assumptions for safety injection delivered to the core are met, will be ensured by the throttle valve position surveillance in ITS SR 3.5.2.7." l Revise JFD 3.5-9 in Section 3.5, Enclosure 6A to add the following: "The positions of the RCP seal injection and return throttle valves ensure that the assumptions used in the ECCS analyses to calculate the j maximum and minimum ECCS flows remain valid." Revise ITS SR 3.5.2.7 Bases to add the following: "The ECCS throttle valves and the seal water injection throttle valves are set to ensure proper flow resisiance and pressure drop in the piping to each injection point in the event of a LOCA. Once set, these throttle valves are secured with locking devices and mechanical position stops. These devices help to ensure that the following safety analyses assumptions remain valid: (1) both the maximum and minimum total system resistance; (2) both the maximum and minimum branch injection line resistance; and (3) the maximum and minimum ranges of potential pump performance. These resistances and pump performance ranges are used to calculate the maximum and minimum ECCS flows assumed in the LOCA analyses of Reference 3." FLOG RESPONSE: (revised) This is a modified response, which replaces the original response provided in Reference 4 of the cover letter in order to respond to NRC reviewer comments. Union Electric Company and Wolf Creek Nuclear Operating Corporation continue to maintain that our CTS definition of CONTROLLED LEAKAGE, which refers to seal water flow from the seals, i.e. seal leakoff, does not meet any of the four criteria in 10CFR50.36(c)(2)(ii). Therefore, wo maintain that deleting that definition and moving RCS Operational Leakage CTS LCO 3.4.6.2.e and SR 4.4.6.2.1.c to a licensee controlled document are justified changes and are entirely separate from the issue h. m-

of wh:th:r a szl inj:ction LCO is adopt:d. In light of NRC reviewer comments, we have chosen to adopt the attached ITS 3.5.5 which reflects our safety analysis and retains the same 18 month Frequency in ITS SR 3.5.5.1 as in our CTS SR 4.5.2.g.2). We consider the movement of CTS SR 4.5.2.g.2) to ITS SR 3.5.5.1 to be an administrative change since the same Frequency is maintained (see new DOC 2-06-A in the attached pages). The attached pages include all the pages included in the original response, with markups to reflect the adoption of ITS 3.5.5, as well as the new Specification and Bases. There are no changes to the ITS 1.0 attached page from what was submitted in Reference 2. It is attached here for completeness. The following new changes are attached:

1. Revise DOC 6-28-LG in Section 3.4, Enclosure 3A to read as follows:

"The current TS definition of CONTROLLED LEAKAGE is deleted as discussed in DOC 1-28-LG in Section 1.0. The RCP seal water return flow limit is moved to a licensee controlled document. Seal injection limitations are established by the throttle valve position surveillance in CTS SR 4.5.2.g.2) which is moved to ITS SR 3.5.5.1. This surveillance ensures that the ECCS analyses remain valid. Since facility performance and operational details of the type embodied by the RCP seal water return flow limit are required to be described in the FSAR per 10CFR50.34, it is acceptable to move the requirements of CTS LCO 3.4.6.2.e and CTS SR 4.4.6.2.1.c to the FSAR."

2. Add new DOC 2-06-A to Section 3.5 to read as follows:

" Surveillance of the seal injection throttle valves will be performed under ITS SR 3.5.5.1 and will retain the 18-month surveillance Frequency." l

3. Add new DOC 2-20-M to Section 3.5 to read as follows:

) "A new LCO is added to CTS 3/4.5 to impose limitations on seal injection flow. This is considered to be a more restrictive change since it imposes a new limitation on the manner of plant operation."

4. Revise Section 3.5, Enclosure SA, "NUREG-1431 Specifications That Are Not Applicable" to delete the citation of ISTS 3.5.5.
5. Delete the seal injection throttle valves from ITS SR 3.5.2.7 and revise the ITS SR 3.5.2.7 Bases to add the following:

"The ECCS throttle velves are set to ensure proper flow resistance and pressure drop in the piping to each injection point in the event of a LOCA. Once set, these throttle valves are secured with locking devices and mechanical position stops. These devices help to ensure that the

i following siftty analys:s assumptions ramtin valid: (1) both ths maximum and minimum total system resistance; (2) both the maximum and minimum branch injection line resistance; and (3) the maximum and minimum ranges of potential pump performance. These resistances and i pump performance ranges are used to calculate the maximum and minimum ECCS flows assumed in the LOCA analyses of Reference 3."

6. Add new ITS 3.5.5 and Bases.

I

7. Revise JFD 3.5-9 to read:

l

  • lTS 3.5.5 has been revised to reflect the safety analysis and to retain the same 18 month Frequency in SR 3.5.5.1 as in CTS SR 4.5.2.g.2). The positions of the RCP seal injection and return throttle valves ensure that the assumptions used in the ECCS analyses remain valid."

i ATTACHED PAGES: Attachment No. 4, CTS 1.0- ITS 1.0 i Encl. 3A 6 Attachment No.10, CTS 3/4.4 - ITS 3.4 Encl. 3A 14 Attachment No.11, CTS 3/4.5 - ITS 3.5 Encl. 2 5-5, new LCO (Seal Injection) Encl. 3A 3, 4 Encl. 3B 2, 3 Encl. 5A NUREG-1431 Specifications That Are Not Applicable sheet Encl.5A 3.5-7, 3.5-12 (new), 3.5-13 (new) Encl. 5B B 3.5-20, B 3.5-33 through B 3.5-36 (new) Encl.6A 2 Encl. 68 1 l l t i l l i ).-

CHANGE MNER giHC DESCRIPTION l improved TS. The proposed changes are administrative in nature and by themselves are not technical changes, incorporating travelersQgG44,'"5f)OO6PD. N'#-I WTs: -Zd,7 ud. TsTF-2.70) 1 27 Not app,11 cable to WCGS. See Conversion Comparison Teble (enclosure 38). 1 28 LG The current TS definition of CONTROLLED LEAKAGE is deleted to be consistent with NUREG 1431. Rev. 1. The RCP seal water return flow limit is moved to a licensee controlled document. % 34 7.i>.f o a.s.s-z.f 1 29 Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 1-30 A Consistent withNA the definitions of Channel Operational Test (C0T). [ ] and Trip Actuating Device 2 %Tk Operational Test (TADOT) is expanded to include the j he. 8*3 est, details of acceptable performance methodology. 1 T Performance of these tests in a series of sequential, overlapping, or totallrMhnt9 steps provides the necessary l i( assurance of appropriate opera _ tion of thefeiifRSjchannel. ) ] This change also makes the COT,+[ ] and TADOT definitions consistent with the current TS and the NUREG 1431 definition of channel calibration which already contains similar wording. @sW, ^ 9=,'w*F wh]. t i t o Se versWn40mpari o s.t q 1 31 l 1 32 A The definition of channel calibrations, and TADOT is @ i.t-2 1 [ h reworded to be consistent with i:>itT@to clarify the phrase " entire chcnnel" thus reducing the potential for inconsistent I interpretation of the phrase as experienced by a r==har of plants simitw c.tav rRcaten h pewvi As.4 fv Actustum] l .g st. Tesh (_ 1 33 {J-Th pi se he in ion f re it ati ns ~ i Gelet or ni atio a c ser ti ns tei w 1 wo a s in ' fi ti e nt and eti the rds oes t,ter mea ng ft de niti. th>t a.pplicabtA.D ldCb'5. See Conysrsob Cow,p ari s'awT.a44.4 (.Onclosww. 32), y _ ~ ( 34 Mot'applic2Wa. 4t> @S, see Conw s emComysvmob t.5-2. =- - y ~TaLA. (Enciesuna. Sed, Voc. 1-35 +d5-41 lusstr 3A g [.se-cheb 3.6 9 Al.s ] I. i. WCGS-Description of Changes to CTS 1.0 6 5/15M7 t 4

1NSERT 3A-6a 0 3.5.5-2 CONTROLLED LEAKAGE as defined in the CTS has nothing to do with the performance of the ECCS system. That definition relates only to the proper { performance of the RCP seals. Facility performance and operational details i are required to be described in the USAR by 10CFR50.34. It is therefore acceptable to move the RCP seal water return flow limit to the USAR since that l return flow limit does not satisfy any of the four criteria in 10CFR50.36 and since that type of detailed information will be adequately controlled in the USAR. Therefore, it is appropriate to delete the CONTROLLED LEAKAGE definition l and maintain seal leakoff limits in the USAR. See also DOC 6-28-LG in Section 3.4. 3 INSERT 3A-6b 0 1.1-7 l Definitions of specific plant systems which are defined by the plant design are deleted consistent with NUREG-1431. The definitions contained in ITS 1.0 are intended for definitions that are necessary for the understanding of the specifications and can be generically defined for most plants. Definitions of I systems' that are not used in the specifications. or are specific to a particular plant (or only a few plants) are no longer defined in this section. j Where necessary, such terms are defined in the Bases for the applicable specifications. h t I i l l I l l i +. t 4

CHANGE Nu!BER 161E DESCRIPTION 6-25 LS-26 The Operational Leakage LC0 has been modified to change the allowed leakage limit for reactor coolant system pressure isolation valves for consistency with NUREG 1431 Rev. 1. The RCS pressure isolation valve LC0 permits system operation in the presence of leakage throggh valves in amounts which do not compromise safety. @nt* 3A-l+MGs.4.lS-li 6 26 LS 30 The CTS surveillance requirement for performing an RCS water inventory balance is modified to allow deferral of the water inventory balance such that it would be performed in within 12 hours after achieving steady state conditions. The RCS water inventory balance must be perfonned with the reactor at steaily state conditions as discussed in the ITS Bases. This change is in conformance with traveler TSTF 116. 1 6 27 A RCS leakage detection system descriptions are revised for consistency with current TS LC0 3.3.3.1 and USAR Sections 5.2.5.2.2 and 11.5.2.3.2.2. 6 28 LG IThecur ~ t iS nitio f LLED 1 delet ~ h to consis with G1 Rev.. The R seal i j er re n flow mit is ved t 11cen contro ed Idoc Se inject limit ons are stablis by ECCS bala test pr edures ed from S ' 4.5.2 o a 11 see cont led do nt (ref ence 1 of En sure 3A 1 the ECCS onversio ackage and (bythet _H45ER.T 3A-14y ttle valv positio urveilla in IT R ~ 44 3.5.5 2.g 3.5.2 7-01 R Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). i 8 01 LS 16 This change in conformance with NUREG-1431 Rev.1, revises the applicability of the specification to MODES 1, 2, or 3 with (T,,,) a 500*F. The change deletes the requirement to perform an isotopic analysis for Iodine every 4 hours in Modes 4 and 5 and in Mode 3 below 500 F, whenever the reactor coolant exceeds its Dose Equivalent I 131 limit. In addition, this change deletes the requirement to perform the once per 4 hour surveillance for Dose Equivalent I-131 in the event the gross specific activity limit is exceeded, in accordance with industry traveler TSTF 28. The latter is an unnecessary requirement since r. WCGS-Description of Changes to CTS 3M.4 14 SM587

+-

6-29 1.5 3 8 145ERT 3A-14 f G3.4.l43] 6-30 A NSECr 3A -l&d.y i

t i CHANGE ~ DESCRIPTION NUlBER gitE 6 25 LS 26 The Operational Leakage LCO has been ciodified to change i the allowed leakage limit for reactor coolant system i pressure isolation valves for consistency with NUREG 1431 Rev. 1. The RCS pressure isolation valve LC0 permits system operation in the presence of leakage throggtt valves in amounts which do not compromise safety. %Af Sh-l%).{45.4.lS-li 6 26 LS 30 The CTS surveillance requirement for performing an RCS water inventory balance is modified to allow deferral of the water inventory balance such that it would be performed in within 12 hours after achieving steady state conditions. The RCS water inventory balance must be performed with the reactor at steady state conditions as discussed in the ITS Bases. This change is in conformance with traveler TSTF 116. 6 27 A RCS leakage detection system descriptions are revised for consistency with current TS LCO 3.3.3.1 and USAR Sections 5.2.5.2.2 and 11.5.2.3.2.2. 6 28 LG fThecur t TS niti f LLED i delet h to consis wit. G1 Rev.. The R seal j er re flow mit is ved t licen contro ed Idoc nject limit ons are stablis by ECCS bala test p edures ed from I 4.5.2 o a 11 see con led t (ref ence 1 of En sure 3A i he ECC onversio acka and by the t ttle valv positio urveilla in IT (3.5.2 _tNSEn.T 3A-14y ^-- R4 3.5.5-11 7-01 R Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 8 01 LS 16 This change in conformance with NUREG 1431 Rev.1, revises the applicability of the specification to NODES 1, 2. or 3 with (T, ) x,10*F. The change deletes the requirement to perfom an isotopic analysis for Iodine every 4 hours in Modes 4 and 5 and in Mode 3 below 500*F, whenever the reactor coolant exceeds its Dose Equivalent I 131 limit. In addition, this change deletes the requirement to perform the once per 4 hour surveillance for Dose Equivalent I-131 in the event the gross specific activity limit is exceeded, in accordance with industry traveler TSTF 28. The latter is an unnecessary requirement since n, WCGS-Descr4 tion ofChanges to C153M.4 14 5/1587 m fe, zC ' t.s-se msee 34-w

e. h os.4.i431 A

NSE Cr 3A - 14 d. (6-30 H

INSERT 3A-14a 0 3.5.5-2 The current TS definition of CONTROLLED LEAKAGE is deleted as discussed in DOC 1-28-LG in Section 1.0. The RCP seal water return flow limit is moved to a licensee controlled document. Seal injection limitations are established by the throttle valve position surveillance in CTS SR 4.5.2.g.2) which is moved to ITS SRJ@h5}f23. This surveillance ensures that the ECCS analyses remain valid. Efnce Tacility performance and operational details of the type embodied by.the RCP seal water return flow limit are required to be described in the U! AR per 10CFR50.34, it is acceptable to move the requirements of CTS LCO 3.1.6 2.e and CTS SR 4.4.6.2.1.c to the USAR. 2.s.s.D INSERT 3A-14b 0 3.4.13-1 The RCS is isolated from other systems by valves. During plant life these interfaces can produce varying amounts of reactor coolant leakage through either normal operational wear or mechanical deterioration. Increasing allowed leakage limits from 1 gpm up to 5 gpm for the pressure isolation valves will not challenge the pressure relief capacity of interfacing systems. This amount of leakage is considered negligible when compared with the capacity of the pressure relief valves. Pressure isolation valve leakage limits apply to leakage rates for individual valves. l The basis for this LCO is the 1975 Reactor Safety Study (NUREG-75/014)) which identified potential intersystem Loss of Coolant Accidents (LOCAs) as a significant contributor to the risk of core melt. A subsequent study (NUREG-0677) evaluated various pressure isolation valve configurations to determine the probability of intersystem LOCAs. This study concluded that periodic leak testing of the pressure isolation valves can substantially reduce intersystem LOCA probability. l l The previous criteria of 1 gpm for all valve sizes is considered arbitrary and is not an indicator of imminent accelerated deterioration or potential valve j failure. A study (EG&G Report, EGG NTAP-6175) concluded allowable leak rates based on valve size was superior to a single allowable value. The single i value imposes an unjustified penalty on the larger valves without providing information on potential valve degradation. In addition, enforcing the single - value criteria resulted in higher personnel radiation exposures because larger valves must be repaired in place." L e 1

.~. - - ~. ~ i i EMERGENCY CORE COOLING SYSTEMS I SURVEILLANCE REQUIREMENTS (Continued)

2) A visual inspechon of the containment sump and verifying that the subsystem suchon inlets are not restricted by debris and that the sump wT.penii,* (trash racks, screens, etc.) show no s

evidence of structural distress or abnormal corrosion.

e. At least once per 18 months, dunng4hutdown,- by-kk N k j
1) Verifying that each automatic valve $ hat is not locked, sealed, or) pg.ggggg j

C u -.._ _ escured in position)in the now oath actuates IMiew ' N to its correct postbon ongn actual or simulated test signal; and) p*12 Mil l%

? _'_ -, !-l: :0 :

t- ' ;:; ' cz '.':: -.^ ^ - -. ^=: r 1 c.r: *- ~"* C._:.- ." Trr ";;..- "^.E L: :: tr Le :::- :'d:-' 9 i

  • '_-; ' ;- ^'r tE !;.:!; :nd kM.N i

4

2) Verifying that each of the following pumps start automabcally upon receipt ofpn actual or simu" ^ $ * '_ ; '-l- :- "" --

$$1(3tMyx my~n m gg,;gg a) Centnfugal charging pump, j b) Safety injechon pump, and 4 1 c) RHR pump.

f. By 1:f;ir; ?. * -- '. ef 5 ' '::.f ; pur;; d:r ':;: 5 : -9:d

..hhgggyg l'"_;clZ ;.r:rr n _. ' :-- *r ri:n ^::^:1 pu r O

  • : :* - ^'-- 4.0.5:An accordance with the IST Program, verify ch ECCS pump's developed head at the test flow point is

~ greater than or equal to the required developed head.

1) C:... '_;f :' _....; -"--

' 24^^ ;9d. 2) _'_.; !-;::t :. -" ; ' "15 ; ", 2nd e

2) R HE H nanp

' 195 9d. 7 )

g. By venfying the correct posnion of each mechanical position stop for the following ECCS throttle valves:

)

1) '_^?t!- '_her ',-::: f ; ::r;': :. Of -- '_v6: :::E: ;

@g$Q1CyM i _ _ _ _. -., - - -_.-_______m._m._.m_ m c r c e,, &_... _ _ _ e3 a gga 1 _L. _' L. D i_ _ _'E_ G6'n W &,~.3_ ~ ~ ' ~ ~ ~ ~ ' ' ' ' - - ~ ' ~ ~ ~ .m 2) .^t least once per 18 months. HPSI System CVCS System Valve Numbers Valve Numbers EMV095 EMV109 BGV 198 2,.d:,. A EMV096 EMV110 BGV-199 [ 3 3 g g 2_] EMV097 EMV089 BGV-200 EMV098 EMVO90 BGV-201 ~~ EMV107 EMV091 BGV-202 EMV108 EMV092 c WOLF CREEK-UNIT 1 3/4 5-5 Markup ofCTS3M.S S/l587

'M ' * ' Seal Injection Flcw 3.5.5 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) dahbie ikA gg.g.q M Seal Injection Flow Q'F@ue. 3.5.5-1 geg LCO 3.5.5 Reactor coolant pus) seal injection flow shall b[ ] 48 e 1 p f APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Seal injection flow A.1 Adjust manual seal 4 hours not within limit. injection throttle g valves to give a flow h thin *lin % h a s Lee r pr sur h O si an co ro of #igue 3.S.S-Q B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. 6tEl B.2 Be in MODE 4. 12 hours a e

Seal Injection Flow 3.5.5 SURVEILLANCE REQUIRENENTS n s.s.s-2 J SURVEILLANCE FREQUENCY SR 3.5.5.1


NOTE--------------------

Not required to be performed until.4 hours after the Reactor Coolant System pressure s 2255 psi g. $2215 psig and stabilizes it 2( Verify manual seal injection throttle Q valves are adjusted to give a flow within

  • b limir 1 en i aga c n -

a e ea r pr s e [ fi e ch nt e u(1

  • @ Fip 7c.3.6.5-h

("b ] a s.s.s-2.( 260 i n 250 10.3 3 240 10.12 9.6 Q- > ACCEPTABLE l

  • REGION v)

O 210 9.47 200 9.24 19 0 9.00 18 0 8.76 16 0 8.2 0 UNACCEPTABLE ON 14 0 7.73 y y v O U 13 0 7.45 a.2 D 12 0 7.16 o a 7 85 z 11 0 6 10 0 6.53 I O 90 6 7 8 9 10 11 SEAL INJECTION FLOW (GPM) Figure 3.5.5-1 (page 1 of 1) Sealinjection Flow Limits

s. j 4 CHAME MER fGiG DESCRIPTION i acceptable because the requirement to submit a report is j j sufficiently addressed by the reporting requirements j contained in 10CFR50.73. I l 2 05 LS 3 This change revises the LCO applicability note to allow operation in MODE 3 pursuant to LCO 3.5.3 until "all" cold i j legs exceed the RCS temperature setpoint in lieu of "one i or more." The previous allowance was [within 4 hours or 1 prior to the temperature of "one or more" of the RCS coid I legs exceeding 375T. whichever comes first). The 375Y 'is I l a nominal temperature selected to give time to restore the pump operability without delaying startup. The four hour limit is unchanged. Changing "one or more" to "all" is still bounded by the 4 hour limit. This change is j consistent with M G 1431 Rev. 1. 1 Wd,q m sat Kpkk s dte valm, 2 06 h h.i igu be -- is.= r" ne iTs sa s.5 5.1 ad @tilfet$m NJ8-m.4, atm.HM Fregq. ~ 2 07 A Consistent with MG 1431 Rev.1, this change revises the surveillance to make it clear that " listed" valve position is the concern and not indicated position in the control room. The surveillance can be satisfied using indicated position in the control room but may also be satisfied using local observation. This is an administrative change since the surveillance acceptance criteria are not changed. 2 08 A Not applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 2 09 LG The visual inspection surveillance performed when establishing containment integrity is moved to _a 11_censee controlled document.l Mov' th r orregtfira... ul [sensisjefft g%G _1 lesq SA-Sa _/ ~ 54 3.5.2-2.] 2 10 A Consistent with M G 1431 Rev. 1, the current TS SR for verifying interlock action of the RR system is moved to improved TS SR 3.4.14.2. 2 11 TR 1 Consistent with M G 1431 Rev. 1, the ECCS pump and valve actuation SR is changed to allow the use of an actual i signal, if and when one occurs, to satisfy surveillance requirements. The specific signals used to actuate the puuns and valves have been moved to the Bases.

  • O*8 HAT @C-_3kD 1 o.s.s. 2. - 3 1 2 12 LG The ECCS pump performance is revised to be consistent with NG 1431 Rev.1. The test method and specific data required to verify pump performance are moved to licensee controlled documents. Specification 4.0.5 no longer exists WCGS-Description ofChanges to CTS 3N.5 3

SMSM7

CHANGE NUMBER HSBHC DESCRIPTION 4 in the improved TS: however, the requirement for an Inservice Testing (IST) Program is moved to Section 5.5.8 of the improved TS. The IST Program is referenced directly for the frequency of testing. Q T34 4 g os,g,2 4l 2-13 TR 3 The CTS allowance, which permits the ECCS throttle valves to be declared OPERABLE without verifying ECCS throttle j valve stop position for 4 hours following valve stroke testing or maintenance is deleted from the current TS consistent with NUREG 1431 Rev 1. The ECCS throttle valves are manual valves and plant procedures governing post-maintenance test requirements specify verification of correct throttle position prior to declaring the valves l OPERABLE. Explicit post maintenance TS surveillance requirements have been deleted because these requirements are adequately addressed by administrative post-maintenance programs. l 2-14 A Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 2-15 LG The surveillance requirement for the flow balance test following ECCS modifications is moved to a licensee controlled document. This requirement is not included in [gf 34 4g q3,g,2.gj NUREG 1431 Rev. 1. 2-16 LG The specific means by which the ECCS piping is assured to be full of water is moved to the Bases. This level of detail is not included in the ISTS and is consistent with the kind of information contained in the Bases. ) ] @ r h o3.s.2-5.I 1 2-17 A Adds the phrase "that is not locked, sealed, or otherwise secured in position" with regard to which valves require actuation testing. This change is merely a cla.-ification. Valves that are secured in place are secured in r.he position required to meet their safety function. The actuation testing ensures that valves can move to the position that meets their safety function. If the valves are secured in the position that meets their safety function, no testing is necessary. 2-1B LG Not applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 2-19 LG Consistent with NUREG 1431 Rev. 1. this change moves the requirement that the 18 month verification of automatic ECCS valve actuation and ECCS pump actuation be performed during shutdown to the Bases. itT]JA}4 a].Q 35.2-ed (2 Ao M WMAT 3 AM-f o 3.5.=a 2.] WCGS-Description ofChanges to CTS 3M.S 4 SMS/97

I IINSERT 3A-4e 0 3.5.5-2 A new LCO is added to CTS 3/4.5.to impose limitations on seal injection flow. This is considered to be a more restrictive change since it imposes a new limitation on the manner of plant operation. 'l 4 l 4 l 1 {

.-~ i CONVERSION COMPARISON TABLE - CURRENT TS 3/4.5 Page 2 of 6 f i TECH SPEC CHANGE APPLICABILITY [ NUISER DESCRIPTION DIABLO CANYON CONANCIE PEAK WOLF CREEK calla RY l 1-08 The accumulator volume for DCPP expressed in cubic feet is Yes No No No A replaced by

  • tank vohsse. Also, the surveillance solution j

volume is revised from it tank volume (101 gallons) to 5.6% narrow range indicated level, equivalent of li tank volume. j r 2-01 The LCO and ACTION a are revised from subsystem to train Yes Yes Yes Yes i LG and the descriptive information in the LCO moved to the BASES. 2-02 Allows isolating both SI injection flow paths for up to 2 Yes Yes Yes Yes l LS-1 hours to perform PIV testing in MODE 3 without declaring either SI train inoperable. 1 ?' 2-03 Revises Action a to address circumstances where 1001 of the Yes Yes Yes Yes LS-2 ECCS flow equivalent to a single OPERABLE ECCS train is available. I 2-04 The requirement to submit a Special Report within 90 days of Yes Yes Yes Yes TR-2 an ECCS actuation and injection event is deleted. 2-05 Allows operation in PODE 3 pursuant to the LCO for ECCS No - This note is Yes Yes Yes j LS-3 Subsystems 1350'F until "all" cold legs exceed the RCS not in the current temperature setpoint in lieu of *one or more'. TS. l 2-06 ant.lilanu. a4 tha. seal A}ct* tow +vottt. p No M e cts a,4. et 6 mg m h ] Q a s.5-2 } l 4 f m -._e LTs s.S.G.1 valves taitt w. ene.A. c-, s l 2 07 Clarifies that the surveillance can be satisfied using Yes Yes Yes-Yes l l A indicated position in the control room but may also be } satisfied using local observation [ ? 1 2-06 The accumulator discharge valves and their note are No - This note is Yes No - This note is No - This note is } A functionally part of the ECCS accumulator sissystem covered not in the current not in the current not in the current I by improved TS 3.5.1. TS. TS. TS. l 2-09 The visual inspection surveillance performed when Yes - Moved to the Yes - Mo# to the Yes - Moved to Yes - Moved to FSAR j LG establishing containment integrity is moved to a licensee FSAR. TRM. Chapter 16 of the Section 16.5 controlled document. USAR. l I L WCGS-Conntsion Conparison TnMe - CTS 3M.5 SMSAF7

CONVERSION COMPARISON TABLE - CURRENT TS 3/4.5 Page 3 of 6 TECH SPEC CHANGE APPLICABILITY NUPEER DESCRIPTION DIABLO CANYO*f COMANCHE PEAK WOLF CREEK CALLAWAY 2 10 The current TS SR for verifying interlock uion of the RfR No - This SR is not Yes Yes Yes A system is moved to i groved TS SR 3.4.14.2. in current TS. 2-11 The ECCS pug and valve actuation SR is changed to allow the Yes Yes Yes Yes TR-1 use of en actual signal to satisfy surveillance requirements. 2-12 The test method and specific data required to verify ECCS Yes Yes Yes Yes LG pug performance is moved to the Bases. 2-13 The CTS allowance, which permits the ECCS throttle valves to Yes Yes Yes Yes TR 3 be declared OPERABLE without verifying ECCS throttle valve stop position for 4 hours following valve stroke testing or maintenance is deleted from the current TS. 2-14 The note providing a one time SR extension is deleted. No Not in CTS Yes No - Not in CTS Yes A 2-15 5 The surveillance requirement for the flow balance test Yes - Moved to FSAR Yes Moved to TRM Yes Moved to USAR Yes - Moved to FSAR i LG following ECCS modifications is moved to a licensee Chapter 16 Section 16.5 controlled document. 2-16 ice method for ensuring the ECCS system is full of water is Yes Yes Yes Yes i LG mo d to the Bases. 2-17 Adds the phrase "that is not locked, sealed, or otherwise Yes Yes Yes Yes A secured in position" with regard to which valves require actuation testing. 2-18 The CPSES requirement fo; venting the ECCS pug casing and No Yes No No LG piping following maintenance or activity which drains portions of the system is moved to the Bases. 2-19 Moves the requirement that the 18 month verification of No - DCPP does not No CPSES does not Yes Yes LG automatic ECCS valve actuation and ECCS pu g actuation be have this have this performed during shutdown to the Bases, restriction restriction 2-2o sustFAS-AS 3.6.s-2-j i M __./ WCGS-Conversion Comparison Table - CTS 3M.5 5M537 I

i [ I t INSERT 3B-3a 0 3.5.5-2 TECH SPEC CHANGE APPLICABILITY i NUMBER DESCRIPTION DIABLO CANYON' COMMANCHE PEAK WOLF CREEK-CALLAWAY f 2-20 A new LCO is added to CTS 3/4.5 to impose No - not in No - not in Yes Yes M limitations on seal injection flow. CTS CTS i i i ? I 1 I I i P P [ L t i f t b I

NUREG-1431 SPECIFICATIONS THAT ARE NOT APPLICABLE Specification # Sandfication Title. Comments i q3. s.s-2 I ffE %pecEiM Sealin] n flow e tati ~ cons' eut with lice mgb for suring t Aa sisa m ons for s elive to core a ill asuref f t C

  1. flo p

at g2.p-g ap 6 c g d pti -1 n ur 4)g maSiBt le y on su nee S 3.5.6 Boron Injection Tank Based on current licensing basis the BIT (BIT) has no safety significance; it is assumed to contain the same boron concentration as the RCS from BOL to EOL. 5/158 7

ECCS-Operating 3.5.2 i SURVEILLANCE REQUIREMENTS (continued) i 1 SR 3.5.2.5 Verify each ECCS automatic valve in the flow 18 months p;ggg pg path that is not locked, sealed, or otherwise i secured in position, actuates to the correct i position on an actual or simulated actuation ) signal. SR 3.5.2.6 Verify each ECCS pump starts automatically on 18 months @$$1 M an actual or simulated actuation signal. (Ga s.s-2.l SR]$_1_2g Verify, for each ECCS throttle NT 18 months pggyp N7 valve listed below, each SEgittja position stop is in the correct gg;g y 3 g g j position. NWeWr lWEW95 W? g EV0g9 IE]- IB19D kQ366'23 i HEEEE 3:55R8 W:Vo090 Ali-15599 $E8VSt*1 13 5 597 EIRRED9 E VUO91 _ Mm B H E L18 EEERO EMjy0092 I urmtsgr 3mu SR 3.5.2.8 Verify, by visual inspection, each ECCS train 18 months

GR5Wai containment stap suction inlet is not restricted by debris and the suction inlet trash racks and screens show no evidence of structural distress or abnormal corrosion.

L WCGS-Mark-up ofNUREG-1431 -ITS 3.5 3.5 7 5/158 7

Seal Injecticn Flow 3.5.5 3.5 EMERGENC.Y CORE COOLING SYSTEMS (ECCS) ,= l J A n N b'm A 3.5.5 Seal Injection Flow op pgue. 3.s.s.: gqas.s.2.} LCO 3.5.5 Reactor coolant pus) seal injection flow shall b6 ]~ pm APPLICABILITY: MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Seal injection flow A.1 Adjust manual seal 4 hours not within limit. injection throttle [os.s.s-2.] g valves to give a flow h thin *1is & h s =(r 4 r pr sur O si an co ro M1, / of #ifue 3.S.S-Q B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AN_Q B.2 Be in MODE 4. 12 hours d.. l 1 l was Mukup of 444E&-1431-175 3.5" W%SrTS 3.5 Re1DW1f4077h5

Seal Znjection Flow 3.5.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.5.1


NOTE--------------------

lqs.s.s 2.] Not required to be performed until 4 hours after the Reactor Coolant System pressure s 2255 psig. (j2215 psig and stabilizes it 2 T Verify manual seal injection throttle @j valves are adjusted to give a flow within * ,,,5,3 b limit *gri en i ga c r ng (g a e en r pr s e _ [2 d e ch g gfo ntr 1. QF@us3.O vacces mn MRea-ast - rrs s.s 3.5@ ,y y,,,,,,

4 260 9 250 A 240 230 220 9.69 + Q- > ACCEPTABLE

  • REGION mo 210 9.47 200 19 0 E

18 0 87 170 8 52 MM7 ~26 16 0 8 o 15 0 8.00 GO 14 0 7 s %W .73 13 0 7.45 3 12 0 7.16 z 11 0 6.85 5 Y 10 0 7'6.53 x I o 90 6 7 8 9 10 11 SEAL INJECTION FLOW (GPM) Figure 3.5.5-1 (page 1.of 1) ] Seallnjection Flow Limits 4 -,,,,_ m e - - - -, -

l ECG-Operating B 3.5.2 BASES on an actuoier dmulateel hu6TMIM.25 ell i Leve.1 Lao.Laa i Atenutic.Tramfee 0" SURVEILLANCE SR 3.5.2.5 and 3.5.2.6 9 "" 3 REQUIREMENTS -~ l (continued) These Surve111ances demonstrate that each automatic ECCS valve I actuates to the required position on an actual or simulated SI signal" and that each ECCS pump starts on receipt of an actual or simulated SI signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need ~ 1 to perform these Surve111ances under the conditions that apply during a plant outage and the potential for unplanned plant transients if the Surve111ances were performed with the reactor at power. The 18 month ) l Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipmen}t [W 3.5-E03 (The actuation logic is tested as part of ESF Actuation System testing. and equipment performance is monitored as part of the Inservice Testing Program. 2 3.5.2.7 {Q s.ss.2.] ".nli..-..; Thelposition of throttle valves Camd4shfN,. j @n the flow path ca = 0! ;ig al is necessary for proper ECC5- ~ perfomance. These valves-4wwe are necessary tc :tep t: ;11;; pigr pesM4enferfor restricted flow to a ruptured cold leg, ensuring that the other cold legs receive at least the required minimum flow.-Thts Surnill;re; i; 7;; 7;;;ir;d f;r pl=t;.;ith fl;; li;;;itin; erifix;. The 18 month Frequency is based on the same reasons as those stated in i SR 3.5.2.5 and SR 3.5.2.6. hkh _ Q 3.s.5-L] SR 3.5.2.8 Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition. The 18 month Frequency i; Mnd cr. tM r;;d t; p. fe ; thi; Surnill;;;

.d,.c tk ;;ditier; tMt ;p,,1y durir.; ; pist ;;t;;;. Or, tM ri;d t; Mx ;as
; t; tk 1; stix ;.r.d ka;n ;f tk stati;l f;r =

=pl; rad tr;rai,.r.; if tM Surailla;; 27; grfes d with the T s ;ter et g n. ";i; fregar;3 has been found to be sufficient to 1 i-detect abnormal degradation and is confirmed by cperating experience. (continued) I WCGS-Mark-up ofNUREG-1431 - Bases 3.5 B 3.5 20 5/1SAF7 l

INSERT B 3.5 0 3.5.5-2 The ECCS throttle valves g)V!IeMtdMWWctTNa.luels are set to ensure proper flow resistance and pressure drop in the piping to each injection point in the event of a LOCA. Once set, these throttle valves are secured with locking devices and mechanical position stops. These devices help to ensure that the following safety analyses assumptions remain valid: (1) both the maximum and-minimum total system resistance; (2) both the maximum and minimum branch injection line resistance: and (3) the maximum and minimum ranges of potential pump performance. These resistances and pump perfo.mance ranges are used to calculate the maximum and minimum ECCS flows assumed in the LOCA j analyses of Reference 3. ) 1 i i ) l l

Seal Injection Flow B 3.5.5 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) {a 3.s.s 2-} B 3.5.5 Seal Injection Flow ( M -Yon 98 +hre 4 BASES "1M function of the seal injection throttle valves &during an accident is similar to the function of the ECCS throttle valves in that each restricts flow from the centrifugal l charging pump header to the Reactor Coolant System (RCS). 1 The restriction on reactor coolant pump (RCP) seal injection flow limits the amount of ECCS flow that would be diverted from the injection path following an accident. This limit is based on safety analysis assumptions that are required because RCP seal injection flow is not isolated during(SIl @ dicch d APPLICABLE All ECCS subsystems are taken credit for in the large SAFFTY ANALYSES break loss of coolant accident (LOCA) at full power (Ref. 1). The LOCA analysis establishes the minimum flow for the ECCS pumps. The centrifugal charging pumps are also credited in the small break LOCA analysis. This analysis establishes the flow and discharge head at the design point for the centrifugal charging pumps. The steam generator tube rupture and main steam line break event analyses also credit the centrifugal charging pumps, but are not limiting in their design. Reference to these analyses is made in assessing changes to the Seal Injection System for evaluation of their effects in relation to the acceptance limits in these analyses. This LCO ensures that seal injection flow offf ) f 1 p J wiii De sutt' cient for RC ' seal integrity but limited so that the ECCS trains will be capable of delivering sufficient water to match boiloff rstes soon enough to minimize uncovering of the core following a large LOCA. It also ensures that the centrifugal charging pumps will deliver sufficient water for a small LOCA and sufficient boron to maintain the core subcritical. For smaller LOCAs, the charging pumps alone deliver sufficient fluid to overcome the loss and maintain RCS inventory. Seal I"'M Y (continued) touss.nwhof k!@w-K31-Baes. 3.5 k 8 3.5 )d 5, 941bTd'95'

INSERT B 3.5-33 0 3.5.5-2 Figure 3.5.5-1 was developed using a conservative combination of plant data to establish a maximum flow rate for the seal injection line versus delta pressure between the RCS and charging pump header pressure. Based on the conservative data, Figure 3.5.5-1 ensures adequate flow to the reactor coolant pump seals while ensuring the safety analysis assumption for minimuim ECCS flow is maintained while avoiding charging pump runout conditions. 1 l c 2 l l l

Seal Injection Flow B 3.5.5 i BASES NS SM l l APPLICABLE injection flow satisfies Criterion 2 of NM / SAFETY ANALYSES (continued) g heF 2.b (U2-XE LCO The intent of the LCO limit on seal injection flow is to make sure that flow through the RCF seal water injection line is low enough to ensure that sufficient centrifugal charging pump injectson flow is directed to the RCS via the injection points (Ref. 2). @sreras.s.E l The LC0 is not strictly a flow limit, but rather a flow l limit based on a flow line resistance. In order to establish the proper flow line resistance, a pre re and flow must be known. The flow line resistance i dete ned (byas in hat e RCS ressure s at af erat g pr ure nd t the ntrifu char gp dis rge ess is eater an or al to le val spe ied in thi CO. he ce ifugal ugin ump di charg header { essur emain essenti

con ant thr gh al the appli le S of th LCO.

reduct n in 5 pres re wo resul in mor l',w be g diver d to t e RCP s al jectio ~ine th at no 1 opera ng pre ure. T e valve setti establ hed et e presc ed'ce rifugal hargin f pu dischar header ressure sult in conser ative ve posi on shou RCS pre ure dec ase. T addit nal i modifie of this 0, the trol va e (char ng flow or I fou oop unit and air erated s injec 'on for ree units) ing full pen, is r quired ce the alve i I signed fail op for the cident ndition With discha pressu and contro valve sition spec < ed by t LCO, a limit is stabli ed. It s this Plow (11 t that i sed in the cciden analyses y The limit on seal injection flo(c ine' tKechakin o e c r La e faust )e met to render the ECCS OP MBLE. If conditio not met, the ECCS flow assumed in the acc ent analyses. g = APPLICABILITY In MODES I, 2, and 3, the seal injection flow limit is dictated by ECCS flow requirements, which are specified for 5~ (continued) l l tec45-t%k-up af M LARM-L41bb 3M wassrs B 3.5 Jktsf D 04/077Fs

INSERT B 3.5-34 0 3.5.5-2 established by adjusting the RCP seal injection flow in the acceptable region of Figure 3.5.5-1 at a given pressure differential between the charging header and the RCS. The flow limits established by Figure 3.5.5-1 ensures that the minimum ECCS flow assumed in the safety analyses is maintained. l l

1 1 Seal Injection Flow l B 3.5.5 J (Q 3.S.G4 \\ i BASES 1 APPLICABILITY MODES 1, 2, 3, and 4. The seal injection flow limit is not (continued) applicable for MODE 4 and lower, however, because high seal injection flow is less critical as a result of Me lower initial RCS pressure and decay heat removal requirements in these MODES. Therefore, RCP seal injection flow must be limited in MODES 1, 2, and 3 to ensure adequate ECCS performance. ACTIONS Al i With the seal injection flow exceeding its limit, the amount of charging flow available to the RCS may be reduced. Under this Condition, action must be taken to restore the flow to below its limit. The operator has 4 hours from the time the C flow is known to be above the limit to correctly position M9 the manuaPyalves and thus be in compliance with the i bA accident analysis. The Completion Time minimizes the i potential exposure of the plant to a LOCA with insufficient injection flow and provides a ',easonable time to restore seal injection flow within limits. This time is conservative with respect to the Completion Times of other ECCS LCOs; it is based on operating experience and is sufficient for taking corrective action's by operations personnel. B.1 and B.2 When the Required Actions cannot be completed within the required Completion Time, a controlled shutdown must be initiated. The Completion Time of 6 hours for reaching MODE 3 from MODE 1 is a reasonable time for a controlled shutdown, based on operating experience and normal cooldown rates, and does not challenge plant safety systems or operators. Continuing the plant shutdown begun in Required Action B.1, an additional 6 hours is a reasonable time, based on operating experience and normal cooldown rates, to reach MODE 4, where this LCO is no longer applicable. (continued) exas.%q,f 44ge-1431-hses 3.s 83.5 & Be9 %s 041D1795 MtV28

l Seal Injection Flow B 3.5.5 M M' BASES (continued) SURVEILLANCE SR 3.5.5.1 te b REQUIREMENTS Verification every M that the manual seal injection throttle valves are adjusted to give a flow within the limit ensures that proper manual seal injection throttle valve %= = position. and hence, proper se tion flow, is maintained.* The Frequency of is based on = @= c"'@.N engineering jt:dgment'and is consisten with other ECCS valve

  • * # "' N Surveillance Frequencie The Frequency has proven to be d_% ***

acceptable through ope xcerience. .. sov., n,: 4 ov 9 **dh*U

As.noted, the Surveillance is r)pt. required to be performed until 4 hours after the RCS pressure has stabilized within a i 20 psig range of normal operating pressure. The RCS pressure requirement is specified since this configuration will produce the required pressure conditions necessary to assure that the manual. valves are. set correctly. The exception is limited to 4 hours to ensure that the Surveillance is timely.

4A' .IfJQ 10 34: . J"I Q 1. REFERENCES 1. FSAR, Chapter [6] and Chapter [15]. 2. 10 CFR 50.46. e {% ms-wk.upc4 Wes-M3\\ - bcs 3.G' Mlp45 B 3.5 h Rev 1, 04/07/95

INSERT B 3.5-36 0 3.5.5-2 To verify acceptab'le seal injection flow, the following is performed: differential pressure between the charging header (PT-120) and the RCS is determined and the seal injection flow is verified to be within the limits of Figure 3.5.5-1. ) i

CHANGE NUMBER JUSTIFICATION 3.5 7 Not used. 3.5 8 Noves the Notes from the " APPLICABILITY" for ITS 3.5.2 to the "LC0". Also revises the wording in Note 2 from " declared inoperable" to "made incapable of injecting". The wording change makes the note consistent with the wording used in LCO 3.4.12. I These changes are consistent with TSTF 153. ~ ] 3.5 9 he seal injec n/re val # (BGV V0202) are neluded in ITS SR. 2.7 'nce are in ed in CTS .2.g.2). l These ves e th led po ons to be v fied sim to t CCS otti .alves w are list n the SR NUREG-431__ ev. gThe. i hn s. 4 RC.P e.cties w

((

4 vatm am & tha Msu / u 4m weA si le culate.1 m a fim ~ l flou.o reman've id- / / A m' 4 m e es 7 $ fs.S-L [6A-Q 3.5.G I } l l l WCGS-Differencesfrom NUREG-1431 - ITS 3N.S 2 $/1587 4

l t I INSERT 6A-2a 0 3.5.5-2 l ITS 3.5.5 has been revised.to reflect the safety analysis and to retain the same 18 month Frequency in SR 3.5.5.1 as in CTS SR 4.5.2.g.2). The positions j l of the RCP seal injection and return throttle valves ensure that the i assumptions used in the ECCS analyses remain valid. I I I \\ l 1 i. 1 I l

i CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431, SECTION 3.5 Page 1 of 1 l TECH SPEC CHANGE APPLICABILITY l IM SER DESCRIPTION DIABLA CANYON COMMCE PEAK WOLF CREEK CALLAlRY l 3.5-1 Replaced " pressurizer pressure" with "RCS pressure." Yes Yes Yes Yes f 3.5-2 The Completion Time of LCO 3.5.1. C01EITION B is chaaged No Not part of No - flot part of /k D Yes - Current TS l I per OL Amendment from I hour to 24 hours to reflect the current TS. current TS current TS I i ( ggQ f_ No. 9L M 3.S.1-2, 3.5-3 Adds the word " mechanical" with regard to throttle valve Yes Yes Yes Yes position stop consistent with the current TS. t 3.5 4 This change increases the RCP seal injection flow Coupletion Yes Yes 110 - LCO 3.5.5 is No - LCO 3.5.5 is Time from 4 to 72 hours with a new added verification that not applicable not applicable at least 100% of the assumed charging flow remains available. ~ I 3.5-5 Deleted reference to centrifugal charging pump discharge Yes Yes No Not part of No - Not part of header pressure to reflect current TS. current TS current TS l 1 3.5-6 SR 3.5.3.1 Note is moved to the LCO per traveler TSTF-90. Yes Yes Yes Yes f f 3.5 7 Not used. M M M M 3.5 8 Moves the Notes from the " APPLICABILITY" to the "LC0". Also No - Not part of Yes Yes. Yes f revises the wording in Note 2 from " declared inoperable" to current TS. [ "made incapable of injecting". ( i 3.5-9 1 t'i ret val ( M current TS. current TS. No - Not part of ago. Not part of Yes Yes n SR d - N5'" ES -' _ u .p 3.s.s-2. ) i WCGS-Conversion Congparison Tame-ITS3.5 5/15/97 i

INSERT 68-la 0 3.5.5-2 ITS 3.5.5 has been revised to reflect the safety analysis and to retain the same 18 month Frequency in SR 3.5.5.1 as in CTS SR 4.5.2.g.2). The positions of the RCP seal injection and return throttle valves ensure that the assumptions used in the ECCS analyses remain valid. i [ l l l l l l F p, {-*

i ( ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.1-6 APPLMABILITY: DC, CP, WC, CA REQUEST: DOC 2-05 LG DOC 2-06 A JFD 3.6-1 CTS 4.6.1.1.c (Wolf Creek) CTS 4.6.1.1.d (Callaway) CTS 3/4.6.1.2 (Diablo Canyon and Comanche Peak) STS SR 3.6.1.1 ITS SR 3.6.1.1 and Associated Bases CTS 4.6.1.1.c/d and 3/4.6.1.2 require leak rate testing in accordance with the Containment Leakage Rate Testing Program which is based on the requirements of 10 CFR 50 Appendix J, Option B. STS SR 3.6.1.1 requires the visual examination and leakage rate testing be performed in accordance with 10 CFR 50 Appendix J as modified by approved exemptions. ITS SR 3.6.1.1 modifies STS SR 3.6.1.1 to conform to CTS 4.6.1.1.c/d and 3/4.6.1.2 as modified in the CTS markup. The STS is based on Appendix J, Option A while the CTS and 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 11/2/95 and TSTF-52. While the ITS SR 3.6.1.1 differences from STS SR 3.6.1.1 are in conformance with the letter and TSTF 52 as modified by staff comments, the changes to the ITS Bases as well as ITS 3.6.2 and ITS 3.6.3 and their associated Bases are not in conformance. See Comment Number 3.6.3-28 for additional concerns with regards to CTS 4.6.1.2.c and 4.6.1.2.d at Comanche Peak. Also see Co nment Numbers 3.6.0-2,3.6.2-5,3.6.3-27, 3.6.3.28 and 3.6.3-37. Comment: Licensees should revise their subm!9als to conform to the 11/2/95 letter and TSTF-52 as modified by the staff. See Comment Numbers 3.6.0-2,3.6.2-5,3.6.3-27, 3.6.3.28, and 3.6.3-37. FLOG RESPONSE: (original)The 11/2/95 letter from C. Grimes (NRC) to D. Modeen (NEI), TSTF-52 proposed Revision 1 (which includes the changes proposed by the staff) were reviewed fer incorporation into the ITS. Based on this review, the ITS Bases have been revised to incorporate proposed Revision 1 of TSTF-52. Revision 1 addresses the NRC comments on Revision 0 of this TSTF but has not been approved by the Tech Spec Task Force. The FLOG will continue to evaluate any NRC/ industry approved revisions to TSTF-52 and willincorporate applicable changes into the ITS submittal as appropriate. FLOG RESPONSE: (supplement) As discussed at the meeting on October 13-14,1998 and in a conference call on November 19,1998, the NRC reviewer provided plant specific comments that have been incorporated into this supplementai sponse. The FLOG understands that with these changes the NRC staff opproves incorporation of TSTF-52 into the ITS.

ATTACHED PAGES: Attachment No. 4, CTS 1.0 - ITS 1.0 Encl.6A 3 Encl.68 2 ~ Attachment No. 6, CTS 3/4.0 - ITS 3.0 Encl. 5B - B 3.0-12 Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl.5A Traveler Status page, 3.6-17,3.6-18 Encl. 58 B 3.6-1, B 3.6-4, B 3.6-7, B 3.6-27, B 3.6-28

CHANGE MitEE JUSTIFICATION that 1) the SR 3.0.2 extenstion of 1.25 times the specified frequency applies to the specified Frequency, and 2) that the interval allowed to perform a missed Surveillance by SR 3.0.3 applies. SR 3.0.2 is clear that the 1.25 extension may be applied to "the interval specified in the Frequency." so the proposed change does not change the intent of the Specifications. SR 3.0.2 applies if a Surveillance is not performed within the "specified Frequency." Again, the example does not change the intent of the Specifications but only makes clear the application of SR 3.0.2 and 3.0.3 to Surveillances with Frequencies tied to plant conditions. This change will eliminate confusion and misapplication of the ITS and will ensure consistent application of SR 3.0.2 and 3.0.3 to these types of Surveillance Frequencies. This change is consistent la 1.4-1 \\ Ql-12. tuSEA.T GA -3 l M t O-00Q tusee rd-*}l p s.6.t _g j .1-is e-WCGS-Dafferencesfrom NUREG-1431 - ITS 1.0 3 5/15/97

1 INSERT 6A-3a TR 1.0-006 1.3-12 The definition of CHANNEL CALIBRATION is revised per TSTF-19 to 'l move details of RTD and thermocouple calibration to the ITS 3.3 Bases associated with calibration of the components. INSERT 6A-3b 0 3.6.1-6 [Q 2.u-t. \\ 1.1-13 Traveler TSTF-5 6 M d s dn F$ deletes the definition of La. Since La is defined in 10 CFR 50, Appendix J and ITS Section 5.5-16, Containment Leakage Rate Testing Program, it is redundant to include La as a definition. As described in NUMARC 93 03, " Writer's Guide for the Restructured Technical Specifications," Specification 1.1 is a list of defined terms and corresponding definitions used throughout the Technical Specifications. La is not used throughout the Technical Specifications and is defined in Section 5.5-16. u

Page 2 of 2 ' CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 SECTION 1.0 APPLICABILITY DIFFERENCES FROM NUREG-1431 REV. 1 NUPBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY [n a, Callausag-spa.cfc.4Q] 1.1 7 The definition of Channel Functional Test in the Yes No - Not part No - Not part No - Not part current TS will be retained in the improved TS. This of current TS. of current TS. of current TS. definition is not in NLREG 1431 Rev 1. 1.1-8 Note b is revised to refer to the " Required reactor kN ' ~ .Vgfr tdo Vfs 00] Yes (Gt.t-9 ( vessel head closure bolts fully tensioned" and note c is revised to read " Required reactor vessel head closure bolts less than fully tensioned." Yes_ Yes Yes The definition of Channel Operational Test (C0T).i[ ] W aIwr Q Lat, a g,g_g g 1-1-9 and TADOT are expanded to include the details of acceptable performance methodology. Performance of @tave. N3H a t, this test in a series of sequential, overlapping, or of appropriate operation of the%hanne,{yur nee, cata3, total W teps provides the necessary ass 'ly a. resgch@] dh c 1.1-10 This change is based on the current TS definition of No - Not part No Not part No - Yes CONTROLLED LEAKAGE This change is a clarification of current TS. of current TS. Maintaining ISTS wording. L: only and does not affect the way RCS water inventory balances are performed. 1.1-11 Adds new example to ITS Section 1.4 to clarify Yes Yes Yes Yes surveillance frequencies that are contingent on both a specified frequency and plant conditions. tuSEKT [ TVL 1-o -o0 G } (1.1-13 satr GB -.:D1[ q.:3.c..i_ c } S/15M WCGS-Conversion Contparision Table-ITS1.0 ..... m m .m. ...m

L INSERT 6B-2a' TR 1.0-006 I TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY I 1.1-12 The definition of CHANNEL CALIBRATION is Yes Yes Yes Yes revised per TSTF-19 to move details of RTD l and thermocouple calibration to the~ITS 3.3 Bases associated with calibration of the components. ) INSERT 6B-2b 0 3.6.1-6 [ t TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 1.1-13 Traveler TSTF-52CAfr>fCM6 deletes Yes Yes Yes Yes the definition of La. Mnce La is defined fois.i-c. \\ in 10 CFR 50, Appendix J and ITS Section i 5.5-16, Containment Leakage Rate Testing Program, it is redundant to include La as a definition. l ,+ l c t i [ [ l i t f l

~ SR Applicability B 3.0 4 BASES f-canas is.tc.

difi;dby;ppia;d;;..,,t';n;."barIquiac..~

I SR 3.0.2 Q=;;ul;tiera_t_4;ir;;;denklicr'ttiTS.BtfTSc;nretin;ndof (continued) c;va cxt;nd ; tc;t intervei W f;;fi;d in the r;guistiers @ Q W : M Rar;ferc,ther;i; r ; :e ; in tre ficqare., ::::;r.g. ,... 1; ret appli abic." As stated in SR 3.0.2, the 25% extension also does not apply to i the initial portion of a periodic Completion Time that. requires performance on a "once per..." basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular i Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner. i The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Survo111ance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified. SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours or up to the limit of the specified Frequency, whichever is less, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met. This delay period provides adequate time to complete Surveillances that have been missed. This delay period pennits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance. "Thereferc,idnen o.4est Merval. is speciWed A +he.re[uMions,*e.ted inkrNl h7 a.h-E 5Rs~t ectue a Note sa 4ht Pe\\usna3 stn%,et be en+.cmaea b cann 3 "58 s.o.2. 6 mot appJtica ? An e.xample, ed an exc4pticm wh h tot SAterva l si no t spu i fd.d A h. re'5"l**' '" i" *** *3*** # " C*"*#"'" *"* . i.es%, Ihte. Testvh3 Proya.m, "t.A. 3.o.2. is not app {sch." Thi s f excetiem i owictA<L tos.cm. ~- %. mqravn alr4 inc.L.ui.to] (continued) kextemoien M -te x. ve,ta-vM s. %r ,gg WCGS-Mark-up ofNUREG-1431 - Bases 3.0 8 3.0 12 S/158 7

INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 l TRAVELER # STATUS DIFFERENCE # COMMENTS TSTF-19, Rev. I hincorporated NA % NRC approved;urof lmod 1.1-rL yplepotogdste. TSTF Q J J Ihorsted 1.1-9 @ kvi.i-i 1 l (TFifg I g rppr6 [ X143 to i. t-2. ] QS3Y.SY IpectipufMtf W2 @s.n-s \\ TSTF-111, Rev.hMorated 1.1-5 [oi.1-4 l l @jfrTM Incorporated ~*d.1-6 '-Q [Gt i-Fl %.74 Rp. fl Incorporated UD.1-3 [ol.4-il r %OCT.9lf(Bavn i Incorporated .1-11 \\@.'-t 1 Tsrp-s2 inc yorated. ~ 1.1-13 epy1 l 4 \\as.L.t-a,t f %.o tyy.o p e%ed, ch>p N C.pr*mNa I r i s f-a l S/15/97 1

r-Containment Isolaticn Valvss ('.1.p.cric. Sube6eperic. != Cer.dcr.;cr. er.d Ouel) yg;g 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY To1c.118 \\ SR 3.6.3.6 ?er;Mriell.takagp_ratemtestingifor contai..nmen..t. 24 =nnt w t,g,g m,' stedewrrpurgE:yalves'with resilient septs @ = - - ' Iand u m d,ed .1 {qsA.S-241 =; ;,rgac al}rf[.y TGa [p..7_ .-g ic,,,_ c 1 ' 9P_ */ , f)efftJAgajr LagTe "i" Lyc;c car..;ck. cr spr:ng ;;;ted Ceck 85u velvc tc;t;bic during epcr; tier threugh ene-ec;;;picte cycic of full tr;;;1. xd Fol]Dwinnegt! %8;P51tN verify cah cred v;1vc r;xin; cic;;d when reimt31JpgD_n tre dificrcr.tiel pressure ir, the diration of"theibl.Lnd of fic.; is s [1.2] psid end oper.; wher, the fTange dificicatiel pris;urc ir, the diration of m flew is 2 [1.23 paid ad : [5.0) paid. r 2 21 Q3.r5o-) -. n.:- -- -... y ~, p~ly vquireA -te, be @bwYdoe on e cA. I l wher c,n+gn men + a i _ _ _ __._ _ bhnd Flanges am Nstalled., purge, vatw ,gg I m n, m.._ a vou v (continued) WCGS-Mark-up ofNUREG-1431-ITS3.6 3.6-17 S/15M

1 Containment Isolation Valv;s (M; ;4;ric, c..L_ m __L._,_ ,_m____ ,..m,._,,.., g...yyggg ) __2 r,~..w. .ww w..~w...~. 3.6.3 ' SURVEILLANCE REQUIREMENTS (continued) l SURVEILUNCE FREQUENCY y~-. only rS_ uired te.m. we. perfwmed for *c. cemta s'nment shtdan.I 93 k'3*'11 } P_e9c

  • h* 5_.wl2* ^_S 2.Sec.. lee.4 b_!ind__fi_w353 gys_mona.

R 3.6.3.7 7 i- _h - jli -- ati ipa _ _js.1_la _ f y; tla s,wala beiedhncA . ed ie,iMic24 > g. 2;,.

==.-. ~~w. =. : :::.,...... ~ bru.keteA.SR ,gg. 34 .a 184 days Perform leakage rate testing for

  1. 3;6fl9?

containment m1MpurgegCvalves with resilient 6til J R'

P Within l

92 days ama. skux aoum e e. t?3 <- 8 -c 1 after l opening the valve SR 3.6.3.8 Verify each automatic containment isolation 18 months .s valve that is not locked, sealed or otherwise $tg BE P secured in position actuates to the isolation position on an actual or sia'.: lated actuation signal. I F#^ valv; not tCst bic durir ep;retica g B4PS2 < CyCIC COCh WCisht Or Spring 10GdCd ChCCk 1" a.Onth; 3.6,D. 2. AL_-.._L ____1_A. _..1_ _s s.11 A..1 6 sin wwyis view wuny a w ww wywsw va sus 64 uvus, Orr VCriff CCCh C dCk v0 vi iC CeIs3 ClC36

.hcr. th; differential prc ;ur; in th; I

direction of fica i; s [1.2] psid end spens when the differ;ntial pressur; in the dirc;tica of flow is 2 [1.2] psid and re n, __2; .' ga..; yasu. l I 6n h r Ej i n t r _ _2 s.. .L r 9 .r _ L ___A 2-.___A gawa swia6ssa rgnq ___AL. su v.w.w.aw wus say w w ws e L J isiwis ww a 6 u s s auw. e 6 ym yw volv i; blocked to rcstrict thc valv; frea. ^ B PS : ( 143.6b-2-3 mr. 2. _s_. r e n.2,. ., - us (continued) WCGS-Mark-up ofNUREG-1431-ITS3.6 3.6 18 S/15/97

1 Containment (Ata;pteri;) B 3.6.1 B 3.6 CONTAllMENT SYSTEMS B 3.6.1 Containment (Atr;;ptari;) 'l BASES to 3.(.. \\-c._\\ NoF CoolL+ BACKGROUND The containment consists of the concrete reactor bt:11 ding, its steel liner, and the penetrations through this structure. The structure is designed to contain radioacti mater 1 that may be i released from the reactor core following s1 $ is' Accident @. Additionally, this structure provi shie ding from the ffssion products that may be present in the containment atmosphere following accident conditions. The containment is a @jist[MiAfreinforced concrete structure with a cylindrical wall, a flat foundation mat Iggm2a.sjg2pr M 381sscM an, and a :h:11ew (Riigerjuf done roof. The inside surface of the containment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions. I Ter centeirant; with urgreat;d ter. den;, t Em cylinder wall is prestressed with a post tensioning system in the vertical and horizontal directions, and the done roof is prestressed utilizing a thre; w;y p;;t t;n;ienir; ;y;t;;;; tiinN,alerti. cal j 6tGEBliglilReMBRRGamGilie [^? N ps.u 5) The concrete reactor building is red for structural integrity of the containment unde nditions. The steel liner and its penetrations establi leakage limiting boundary of the contairunent. Maintaining the containment OPERABLE limits the leakage of fission product radioactivity from the containment to the environment. SR 3.6.1.1 leakage rate requirements comply with 10 CFR 50, Appendix J. Mon] (Ref.1), as modified by approved exemptions. The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier: a. All penetrations required to be closed during accident conditions are either: (continued) WCGS-Mark-up ofNUREG-1431 - Bau 3.6 B 3.6 1 S/1S/97

Containment "-,A r;c) B 3.6.1 BASES (continued) ACTIONS L.1 In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The 1 hour Coupletion Time provides a period of time to correct the problem comumensurate with the importance of maintaining' containment during MODES 1, 2, 3 and 4. This time period also ensures that the probability of an accident (requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal. B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant sust be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SLRVEILLANCE SR 3.6.1.1 REQUIREENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test _ requirements of @g 3,5,i _ q t N( _1x[W f. . _a _ fied appro ex ion allure to p,,,g,t m meet air lockgnG purge val _ve with resilient seal]eakage limits g -_ ] J y g ~" spec 11'1ec In Lw J.b.7.@nd LCO 3.6.3Jioes not invalidate the v

  1. rm acceptability of these overan leakage determinations unless

(%Q ud their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required 10 C'",50. @idin J. .;1. ,,...,3 M2 3 m,1~ leakage test is required to be < 0.6 r coeined nd C lea lo24.1-Q .75 for overall 'ype 193 41-G J r times required age rate tests. (continued) WCGS-Mark-q ofNUREG-14.fi - Bannur 3.6 8 3.6-4 5/158 7 ~

Containment Air Locks ' L ;.paric, Di+ 6 ;p.;ri;, ::: C;r.ir.;;r, ;rd :%.;1) B 3.6.2 ,e {g s.s,.i-Q o.2o% f unwnment ryd#tP"~h-APPLICABLE The DBAs that results in a release of radioactive material SAFETY ANALYSES within containment are is a loss of coolant accident ;.74 : rd

5 ti;. c.;;; i./. (Ref. 2). In the analysis of ;;;h ;f these W accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled l

by the rate of containment leakage. The containment was designed with an allowable leakage rate of 3 of containment air weight per day (Ref. 2). This leakage rate is defined in 10 CFR 50, Appendix JM3(Ref.1),'M - @ ;f r~..;;ir. :.;

ir.;M.; Fr ty, the maximum allowable containment leakage rate at the calculated peak containment internal pressure;

[,MM P = g psig; followirg a BBA im ih ow(. This allowable leakage rate forms the basis for the acceptance criteria imposed on the SRs associated with the air locks. The containment air locks satisfy Criterion 3 of tt; OC relicy Statement M _ R g(D. LCO Each containment air lock forms part of the containment pressure boundary. As part of the containment 6, the air lock safety function is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event. Each air lock is required to be OPERABLE. For the air lock to be considered OPERABLE, the air lock interlock mechanism must be OPERABLE, the air lock must be in compliance with the Type B air i lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air _ loc _k to be opened at one time. ggWingMaibn Q3.t. 2.-ti l ( ~ - ~ " - 711s provision ensures that a gross o a nment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into and tg exit from containment. APPLICABILITY In MODES 1, 2, 3 and 4 a DBA could cause a release of radioactive material to containment. (continued) WCGS-Mark-qp ofNUREG-H31 - Baser 3.6 B 3.6-7 S/15/97

1 1 i. Containment Isolation Yalv:s ,;.u p.;s-2, f - - -- w idets wp.;-k. k; O.d;;.x, as.d N s') L,%e. ideyh +sds wwh a muihm att.etc. t.,

e. vate. &

B 3.6.3 containment sWtdown p.r$c sadg w en%4.t u.i l in vale NW1 i q i ett tac envg in4cui&n oF re ed materM. set degrutdon onA wm tiow opprtumq 4 reger befva. gro.6 lamasc. fattares cosa Acep. i ) SURVEILLANCE SR 3.6.3.6 (continued) I43A 3 21I l REQUIREENTS i s .^ : '.c : w,. ;.. j f ' l> ;...... ? **... m e.., ' ^. ~.'~g* 1 is., 9, e ..}'.. 4 l[ ~ l~l* ~  : A '?~ ~ _g r ' - ~ ~ ' ^ - ' ' ^ ' y j ,8 - ( ______[.0 ' E' i.; ' 4r,,. ' ~ '... k J. f.'e. i ' ' ~ ~, ,,./ ~~ f. = f,,u =.. i e p f - _ [. '.., _.. '. _ * ' s y _* g t ' ' ' f .,L f s,.. g,4 i-... g;. 4.. ..s .. 4,p. ..N.. ,.g. 7,, ,7 s ' 3. k yf,,;. '5 '.I p. Valvt.3nd'th -- m. 9,' 650C.t'AI'edj l , k ' ' I, f, L '.. - 7., .c.ac c g, - w Q 3.6.3 -u. ~ [r J?L

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h_-___ .1---- L 2-- ,.1..- L-A1__ & 5 serb e Wswh uwep=saFy a a wyl uBIs s wqu a s useuse s u b a v3 yas5yw bbdbua5y wia u hA J. F"--_.--_-.. he. cornbmid \\esbgc, rde.6r ibe. catthinmed -- wui 5 -w~ ~i-l Aen pressur'ited +pp% and exhauHsoldidn alws.,o 'Pa shed um pur$e a SR 3.6.3.7, gg g;g g g gy,g g, For contai6 valves with resilient seals, additional,os.i.93 C __ leakage rate testing Deyond the test requirements of 10 CFR 50. Appendix J, R M B is required to ens,ur,e OPERABILITY. eniniwpqc. amd. ohuhn pw'$*fo s.r 3.u I (continued) WCGSMark-up ofNUREG-HD -Bau 3.6 8 3.6 27 MM7 A-

1 4 Containment Isolation Valvis (M. .p.;.. ;;, S M ~ p.;ric. I;; Ceri;racr. c.74 M ) B 3.6.3 2 BASES SURVEILLANCE SR 3.6.3.7 (continued) REQUIREMENTS a Operating experience has demor.strated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path i between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of)tulttMigg AR$f0p NP B 20. " Containment Leakac'. Due to SeaA Deterioration" (Ref. {-_- 1 ' @p m.2 i p3,,,3, g y j Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing a that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) isra fo3,g.i.c) prudent measure after a valve has been ooened -. syem' c AwgwW-

  • w n

p,M E@k II )43.6.311 l ^ l SR 3.6.3.8 i j Automatic containment isolation valves close on a containment j isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic l containment isolation valve will actuate to its isolation i position on a containment isolation signal. This surveillance is ] not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. l The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed withthe reactor at power. Operating i experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. /The SR. is mo= tinea ha a-etc. eA; cahn$ + hat h SR 6.g regE d. c,, ~7 q g g g,.m.a. f., +h. c.ntdn ment shad *wn pr$a vale wNa h kn_% crated. blihet fl>ne l's rar'wwM j Tw Gs teskup rate for exk c m+>e- -+ mini e-$* s"tfb d enhM lG2 ' 3-31 ) l is.lgiin v4w wim resilie dt = cab c.tc..hn o.os1.4. wwn puurwigue 'Pu. The comb;w te>%s ra**. fw iha. c.ntai,n ment shta.wnMg 9p3 [o3.6.3-2l oma. =hmst ii lati&n valves, iohen pressunacA -to Fu,2 A inc.t wh 1 (continued) a.ti rv.e s e A. c o.n.+ atens i* fe h Got-4.. 1 WCGS-Mark-up ofNUREG-H31 - Bases 3.6 B 3.6 28 5/15/97 1 ) I

ADDITIONAL INFORMATION COVER SHEET l ADDITIONAL INFORMATION NO: O 3.6.2-6 APPLICABILITY: DC, CP, WC, CA REQUEST: JFD 3.6-2 STS SR 3.6.2.2 l ITS SR 3.6.2.2 and Associated Bases STS SR 3.6.2.2 requires verifying only one door in the airlock will open at a time at six month intervals. The intervalis modified in ITS SR 3.6.2.2 from 6 months to 24 months. This modification is in accordance with TSTF-17; however, the Bases changes are not in accordance with TSTF-17. Comment: Revise the ITS Bases to be in accordance with TSTF-17 or justify the deviations. FLOG RESPONSE: (original) The ITS Bases for SR 3.6.2.2 has been modified to conform to TSTF-17, Revision 1, and reads, "..used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 24 months. The 24 month Frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage and the potential for loss of containment OPERABILITY when the Surveillance is performed with the reactor at power. The 24 month Frequency for the interlock is justified based on generic operating experience. The Frequency is based on engineering judgement and is considered adequate given that the interlock is not challenged during the use of the air lock." FLOG RESPONSE: (revised) The ITS 3.6.2 Bases have been revised for the associated surveillance requirements consistent with TSTF-17, Rev.1. l ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 58 B 3.6-13 l l

1 A i l Containment Air Locks (At;;;;p.;ric. Subt. g.cric. I;; Cenir.;;r ;r.d Du;1) B 3.6.2 BASES i fonibe nend.h perform thn, ssedlianc4. ~ (continued)l wnder the. condthbn that apeg dur' 3 m SURVEILLANCE SR 3.6.2.2 ' a. Plant e,dag' A k-1 REQUIREMENTS Nie stM@@rjuge3#76dopentJ3D:,l4s.c. 2-c.1 v 4 1 this test is only required to te perfonned spa enteria;; er aitin;; ; ;,atei;ac.t ;ir 1;,1 bt i;..et r;qai.ed ;;.;r; fr;Watly thr. scry 1"_4 iy;Md-- -- uC Mangth i i k q3,qft g = ~,_-__ _ _ =sm e \\ f }Q3.(.2-(-I er requency is ba on engineering judgement and is MN-k l consideFed adequate ir, vis ;f eth;c ir.dic;tien; cf deer c.r. i interied ;;;br.i;;;; ;t;ta; =;ildl; te eg ; tion; inr;;,anci MWeavw3R2iF36tEYirfiot~dsfrHingNegtqPimRFEthe RJflBER. The. 24 mone Fracgushc.3.Er h shterlock. 6 patifiid ba. sect on c3=n.Ac. oper a,+ibg ex.peridnca_. 4 ) l REFERENCES 1. 10 CFR 50. Appendix JEMonJ. l 2. RISAR Section28@2;3arur15. 1 { _"'"pfJ"1 *lh wc 3.(,- E D l i WCGS-Mark-up ofNUREG 1431 - Bases 3.6 B 3.6-13 S/1587

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-1 APPLICABILITY: CP, WC REQUEST: DOC 1-04 A (CTS 1.0) DOC 1-01 LG CTS 1.7.a (1.8.a for Diablo Canyon) CTS 3/4.6.1.1 CTS 4.6.1.1.b ITS SR 3.6.3.1, SR 3.6.3.2, SR 3.6.3.3, SR 3.6.3.4, SR 3.6.3.8 and Associated Bases CTS 1.7 (1.8 in Diablo Canyon) defines CONTAINMENT INTEGRITY. A markup of CTS 1.7/1.8 is provided in the CTS markup of CTS 1.0. DOC 1-04 A (CTS 1.0) states that the definition of CONTAINMENT INTEGRITY is deleted from the CTS /ITS. DOC 1-01 LG in CTS 3.6 states that the definition requirements have been relocated to the Bases for ITS 3.6.1. Both of these justifications are incorrect. CTS 1.7.a (1.8.a in Diablo Canyon) specifies that all penetrations required to be closed during accident conditions are either capable of t>eing closed by an OPERABLE containment automatic isolation valve system or closed by manual valves, blind flanges or deactivated automatic valves secured in their closed positions. This requirement has been relocated to the Bases of ITS 3.6.1, but it is also the basis for ITS SR 3.6.3.1, SR 3.6.3.2, SR 3.6.3.3, SR 3.6.3.4 and SR 3.6.3.8. No justification is provided for this Administrative change in CTS 1.0. Comment: Revise the CTS markup and provide a discussion and justification for this Administrative change. j FLOG RESPONSE: (original) DOC 1-3t: A (CTS 1.0) has been added to read; " CTS 1.7.a (1.8.a for Diablo Canyon) specifies that all penetrations required to be closed during accident conditions are either capable of being closed by an OPERABLE containment automatic isolation valve system or closed by manual valves, blind flanges or deactivated automatic valves secured in their closed positions. Consistent with ) NUREG-1431, this requirement from the definition of CONTAINMENT INTEGRITY would be included in the Bases of ITS 3.6.1 and would be addressed by the combination of surveillance requirements ITS SR 3.6.3.1, SR 3.6.3.2 (not applicable to CPSES), SR 3.6.3.3, SR 3.6.3.4 and SR 3.6.3.8. This change would be classified as Administrative (A) because the requirements of CTS 1.7.a/1.8.a would be retained in the combined surveillance requirements of ITS 3.6.3, " Containment Isolation Valves." Also, see the FLOG response to Comment 3.6.1-1 regarding the relocation of the CONTAINMENT INTEGRITY definition requirements. FLOG RESPONSE: (supplement) As discussed at the meeting on October 13-14,1998, WCGS is providing a revised CTS mark-up to reflect the correct DOC numbers. For CPSES, this Comment will be resolved with the resolution of Comment Number Q 3.6.3-14.

. ~. - I i ATTACHED PAGES: Attachment No. 4, CTS 1.0 - ITS 1.0 Encl. 2 1-2 i i l l l I [ 1 I i t 5 i l l l l I

{t1.0 USE AND APPLICATIONl 1.ChEFINITION enura nm9 cut '"'"#"V g(W f oL6.s-sl 4y courn. .-uv iurgeorrv geg-... 5:n.

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^ ^ ~ #^7'II pupip eeals \\ CORE ALTERATION 4.0 CORE ALTERN'lOf4 shall be the woment er ---If:: of an I $f lY 48*I-33

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[ sources, or roastrytv contro ts within re' actor vessel w' e l vessel he ved and the vessel. naion of COR 'ERATION 33F " shall reclude compi of move f a component t afe senservatwe/ "A f on. CORE OPERATING LIMITS REPORThCOLRh i 444 The COLR is the unit-specific (i*il41~A* document that provides(cyc6e specific param_2;x; --- :'t; limits for the current eposaling reload cycle. These cycle-specific::= :;:_ J+rametedlimits shall be determined for each reload cycle in accordance with Spec.ification 6.9.1.9. Plant operation within these operating limits is addressed in individual Specifications. _g-(1.9 OcAE AL.TERATioeJ 361l W h m.w. ment of g Q i f l som 4, or ve>ch'vi h covrtrarf. c:oyneh w&A h. reac. tar vr.ssel wl b th e. Ve:ssel A.a.ad. re. mon.d oad._ . [ fu.al i h asseI. Susysidn of CORE At.restAvip+4 shall not prta clucie. ca*P 88 +'8" *i- '* * *" * ^Y **' *- corre.u +o a. safe posibe.n. WOLF CREEK-UNIT 1 1-2 Amendment No. 64, SG, Mark-up of CTS 1.0 5/15/97

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.6.3-4 APPLICABILITY: CP, WC, CA REQUEST: DOC 7-03 A CTS 4.6.1.7.1 ITS SR 3.6.3.1 and Associated Bases CTS 4.6.1.7.1 requires the purge valves to be verified locked closed or blank flanged at least once per 31 days. The CTS has been modified to provide an allowance for one purge valve in the flow path to be open to repair excessive leakage while in the ITS Action for an inoperable purge valve due to excessive leakage. This change designated DOC 7-03 A is characterized as an Administrative change. This is incorrect. The CTS does not currently have this allowance and the change cannot be characterized as Administrative because of consistency with another Less Restrictive change. The change is a Less Restrictive change. See Comment Number 3.6.3-5. Comment: Provide a discussion and justification for this Less Restrictive change. l FLOG RESPONSE: (original) DOC 7-03 A has been revised to be DOC 7-03 LS-26 and the I discussion and justification for this Less Restrictive change has been provided. This Comment is no longer applicable to DCPP based on response to Comment Number 3.6.3-5. l FLOG RESPONSE: (supplement) As discussed at the meeting on October 13-14,1998, the l CTS mark-up has been revised to reflect the revision of DOC 7-03-A to l DOC 7-03-LS-26. ATTACHED PAGES: l Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-12 i f l l l l

,_m._ CONTA!NMENT SYSTEMS New i With one or more penetration flow paths with two isolation valves inoperable g.gggg ] for any reason other than leakage, isolate the affected penetration flow path heds/A within 1 hour by use of at least one closed and de activated automatic valve, closed manuel or blind flange,'otherwise be in HOT STANDBY within the nort g hours and COLD SHUTDOWN within the next 30 hours. SURVEILLANCE REQUIREMENTS closed. 4*47 r---- sea b ach36-ineh 4.6.1.7.1 E shutdowr purge and exhaustisolaton -01.ui-2( valve (sP shall be nk flanced rI*'- =" at least once per 31 days. 1 Soto (from ITS SR 3.4.3.1): Not required for one purge valve in a penetration path) 3.63 4\\ 2 Iyrhile in Action c.f_ 4.6.1.7.20EadL containment shutdown purge supply and exhaust isolation y valve (sne{ofils maaaa=8 art blank flan 3e shall be leak tested at least once per "j 24 E.w e _-- ~_' _ .,/ L.1. C; tan p -- 9 ^

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_ :n 6t:: r'-." :.x: fc" h xf :! '- " xx --- ? f:;:ffertfy each containment mini-purge-valve es] g ggg' f:^:-

fclosed except when the containment mini purge valves are open for pressure g,gs.c j E'+~ control ALARA or air quality considerations for personnel entry, or for surveillances that require that valves to be open at least once per ) g$194Alid$. { Q3.63-l 4.6.1.7.4 At less once per 3-months (84 days AND within 92 days after opening] ff fthe valve)each muu-purge supply and exhaust isolation valve with N6444J ressleont matens'h rate 5 ': _: r;;. a ^" L. ;.t; ;::-- _" :" t P,(in accordance) 4 11 be demonstrated OPERABLE by verifying that the measured leaka Qvith the Contal unent Leakage Rate Testing Program.) QQM3 1 w 3.t.-oc4 CrO) fisolation devices in high radiation areas may be vertfled by use o)f MMi 3;;Q 1 heAbsud ( administrative meanye i 'Except valves and flanges which are located inside containment. These valves shall be verified to be closed with thew @nk flanges installed prior to ""g* { M entry into MODE 4 following each COLD SHUTDOWNQf not completed in the] [ previous 92 days.) "This surveillance is not required when the penetration path is isolated by a leak) "$7Il%%{} tested blank flayf wh he bidd Eqc. i allest, fel 3 ccLcbcinStaMil h g,3 2.5 ~ c4 the bivnd f Lge, av each containment sW4cAoe yp ~ K.49% Ed e.Aheast" vahr shalt be leak testcA at least on<.a.,O" g y g,g., y , per evert 3 IS4 eqs,. qith "the. btwiet fin removw.<t.. M w' . 92. ela ab ogoeng the. valw. wi Maj-w d. fl% -- i Qmo = ~ WOLF CREEK UNIT 1 3/4612 Amendment No. 89. 97 Mark-up ofCTS3/4.6 $/ ISM 7 m

~__ ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-10 APPLICABILITY: DC, WC, CA ) REQUEST: DOC 11-11 A JFD 3.6-3 CTS 3.6.3 STS LCO 3.6.3 ITS LCO 3.6.3 Note and Associated Bases ITS LCO 3.6.3 contains a Note not contained in CTS 3.6.3 or STS LCO 3.6.3. This Note states that ITS LCO 3.6.3 is not applicable to the Main Steam Safety Valves (MSSVs), Main Steam Isolation Valves (MSIVs) Main Feedwater Isolation Valves (MFIVs), Main Feedwater Regulation Valves (MFRVs), their associated bypass valves, and Atmospheric Steam Dump, Relief or Dump Valves. The justifications for adding this Note (DOC 11-11 A and JFD 3.6-3) state that it is consistent with current licensing basis, the valves are not considered containment isolation valves, and that they have separate ITS LCOs that provide appropriate required actions in the event these valves are inoperable. Nothing in the CTS states or implies that these valves are exempt from this LCO. Furthermore, the staff considers these valves to be containment isolation valves. In addition, the proposed change was submitted to the staff as a generic change to the STS (TSTF-44) and was rejected. The staff considers this change to be a generic change that is beyond the scope of review for this conversion. See Comment Number 3.6.3-24. l Comment: Delete this generic change. FLOG RESPONSE: (original) DCPP, Callaway, and Wolf Creek continue to pursue this change. The justification in DOC 11-11-A and JFD 3.6-3 have been modified to state: t "A Note is added to the containment isolation specification that the LCO is not applicable to main steam safety valves (MSSVs), main steam isolation valves (MSIVs), main feedwater isolation valves (MFIVs), [ associated by-pass valves and steam generator atmospheric relief valves (ARVs)]. The current licensing basis for these valves exempts them from playing a role in establishing or maintaining containment integrity. This is based on 10 CFR 50.36 c.2 and c.3 and 10 CFR 50, Appendix J. There are no surveillances associated with LCO 3.6.1.1 or LCO 3.6.3 which are applicable to these valves. [These valves are currently not considered to have a containment isolation function.) This Note is consistent with current licensing basis." The application of LCO 3.6.3 to these valves (MSSVs, MFIVs, ADVs (DCPP), ASDs (Callaway), ARVs (Wolf Creek), etc.) would result in two similar LCOs l being applicable to the same equipment yet having different ACTION times. The role of ITS LCOs 3.6.1,3.6.2, and 3.6.3 are to establish containment leak tight integrity through the containment leak rate program l and then maintain it during plant operation. These valves are more l complex and have safety functions which require them to be open while l containment integrity is established. The isolation functica would be required as a result of conditions different from those generally requiring i containment isolation. The applicable ITS 3.7 LCOs recognize these conditions and provide appropriate actions. These LCOs require valve operability and provide ACTIONS similar to containment isolation but

mors cons:rvctivs for an inoperrabis valva. An inoperablo MSSVs (normal operable condition is closed) under ITS LCO 3.7.1 would require restoration or a power reduction within 4 hours (valve fails to open). An inoperable MSIV under ITS 3.7.2 would require restoration within 8 hours for DCPP and 72 hours for Wolf Creek and Callaway or close the valve (in Mode 2) and then proceed to Mode 4. An inoperable MFIV under ITS 3.7.3 would require closure within 72 hours for DCPP and 4 hours for Wolf Creek and Callaway and verification every 7 days or the plant would proceed to Mode 4. An inoperable ADVs (DCPP), ASDs (Callaway) or ARVs (Wolf Creek), (normal operable condition is closed) under ITS 3.7.4 would require restoration within 7 days (failure to open). The most conservative applicable operational requirements are found in the associated ITS 3.7 LCO. Plant Specific Discussion: For Wolf Creek, USAR Section 6.2.4 discusses the Containment Isolation System. Figures in Section 6.2.4 provide a figure of each penetration and the containment isolation valves in that penetration. For the MSIVs and bypasses and MFIVs and bypasses, the figures show the penetration and these valves with a note stating this penetration is included for figure completeness and none of the valves shown are considered containment isolation valves. USAR Section 6.2.4, Safety Evaluation Seven, identifies that there are no penetrations which are subject to GDC-57. The containment penetrations associated with the steam generators are not subject to GDC-57, since the containment barrier integrity is not breached. The boundary or barrier against fission product leakage to the j environment is the inside of the steam generator tubes, the outside of the j steam generator shell, and the outside of the lines emanating from the steam generator shell side. USAR Section 6.2.4.3, further indicates that the valves associated with the piping systems connected to the secondary side of the steam generators isolate the steam generators and are not considered containment isolation valves and are, therefore, not leak tested. l Prior to Amendment No.108 (which relocated the CIV Tables out of the TSs), TS Table 3.6-1 listed the MSIVs and MFIVs with a footnote that stated "These valves are included for table completeness. The requirements of Specification 3.6.3 do not apply; instead, the requirements of Specification 3.7.1.5,3.7.1.7 and Specification 3.3.2 apply to the Main Steam Isolation Valves and Main Feedwater Isolation Valves, respectively." Note that Amendment No. 89 added Specification 3.7.1.7 for the MFIVs and resulted in changing the note to reference 3.7.1.7. Enclosed are current TS pages from license issuance and Amendment No. 89. FLOG RESPONSE: (supplement) For WCGS and Callaway, further review has determined that the licensing basis for MSIVs, MFIVs, MSSVs, and ARVs/ASDs is provided in the SAR. This note is deleted. Callaway is adding an additional reference to B 3.6.3 LCO to the containment isolation valve table.

For Di;blo C:nyon, ths LCO nota in ITS 3.6.3 has be:n r:mov:d; however, the Bases discussion regarding the MSSVs, MSIVs, MFIVs, and ADVs remains. The following discussion is provided to address NRC staff questions during the October 13-14,1998 meeting relative to containment isolation valves. The ITS LCO 3.6.3 Bases is revised with a note stating that this LCO does not apply to the MSSVs, MSIVs, MFIVs, and ADVs. These valves currently have an additional but similar LCO providing generally equal or more conservative ACTIONS. This change would leave a single LCO for each group of valves that would assure the required safety functions. Each of the effected valves is a GDC-57 containment isolation valve associated with a closed system in containment. LCO 3.6.3 ACTION C provides the only applicable ACTION other than a unit shut down for failure to meet ACTION C. LCO 3.6.3 provides no applicable surveiliances to assure OPERABilliY for any of these valves. The function of these valves is more complex than this since they have safety functions that require them to be open while containment integrity is established. The applicable ITS 3.7 LCOs recognize these conditions and provide appropriate ACTIONS and SURVEILLANCES for the required open functions as well as isolation. The following Table provides a comparison of the applicable ITS 3.7 LCOs to LCO 3.6.3, ACTION C: LCO MODES Normal Safety Function ACTIONS Position LCO 3.6.3, 1-4 N/A Provide GDC-57 closure to assure Close within 72 ACTION C containment integrity following failure hours. Verify every of the closed system in containment. 31 days LCO 3.7.1, 1-3 Closed to Open to provide over pressure One unable to open (MSSVs) assure protection of the secondary side upon demand - pressure then re-close. immediately reduce boundary power LCO 3.7.2, 1-3 Open Close to isolate the steam generator Restort or close (MSIVs) during HELB, Feedwater line break within 8 hours. or SGTR Verify every 7 days. LVO 3.7.3, 1-3 Open Close to isolate the secondary plant Close within 72 (MFIVs) from the steam generator. hours. Verify every 7 days LCO 3.7.4, 1 -3, & Closed to Open to provide energy removal Restore all valves (ADVs) 4(*) assure when the RHR is not available then in 7 days, (assure 2 pressure re-close. operable within 24 boundary hours, assure 3 are operable within 72 hours). (*) Required in MODE 4 if steam generators relied on for heat removal. None of these valves are associated with piping systems providing direct communications between the containment atmosphere or the RCS and the outside atmosphere. There is no credible transient that would challenge the integrity of the closed system within centainment or require

cny of these valvrs to operata in MODE 4,5 or 6 oth:r th n thm ADVs. j Steam generator energy levels are low in MODES 4,5,and 6. i j in sLmmary, the action statement provided for these valves outside of ITS 3.6.3 provide assurance that both the containment integrity (closed) function and process (open) functions are maintained. l ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-16 Encl. 3A 12 [ Encl. 3B 10 Encl.5A 3.6-8 Encl. SB B 3.6-17, B 3.6-18 Encl. 6A 1 Encl. 6B 1 f d a h l 1 l

CONTAINMENT SYSTEMS /-07_4, [43.I.0-/] 3/4 S3 CONTAINENT ISOLATION VALVES i LIMITING CONDITION FOR OPERATION 3.e;_3M isolabon valve shall be OPERABLE. / p 3,(..S-to { {LCO /- d-2-- 3 ~' g, ,_ M [ V F p -r ,and /._. :+ _. w &w /,._ /- / APPLICABILITY. MODES 1,2,3, and 4. AGIlONb mh one or moron----:. now eethe wah onees conisinment i.oimbon a*ye em vadve inoperabletexcept for w ^__ - :- ; purge valve leakage not within ilmit,)

  • d

{ maintain at least one isoisbon valve vrt:MABLE in each aNected penetrabon thatis open and: i

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.$;;.;,,4 hours, -b, Isolate each aNected penetraborfflow d;f".? ' 5-by use of at least (( }] one deschvated automatic valve secured in the isolaban position, or c.' "- --. " ^ " ;: 1 - : .r. ' h_ by use of at least one closed manuel valve or blind flance, P valve with flow ] 1 UM.f y@ Through the valve secured AND verWy the aWoceed penetration flow '~ I path is isolated once per 31 days "* for loolation devices outside AA: ~ ' Wgg containment and prior to entering Mo44 from Mode 5 If not i LT :1 i f 9 K 4% twithin the previous 92 days for isolabon devices inside _ containment, orj

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d. Be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

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NEW. With one or more penetration flow paths with two isolation valves) inoperable for any reason other then leakage, isolets the affected penetration flow path within 1 hour by use of at lasst cne closed and deactivated automatic valve closed manuel valve or blind flange othenmies be in HOT STAND 8Y within the next 6 hours and COLD 1 SHUTDOWN within the next 30 hours. )

    • leolation devices that are locked, aeoled, or otherwise secured may be verifie]d
  • INSERT (see nextpage)

{ 'f93= by adeni,de ilve mee.. [+ administrathe meens. j @"^" "] leolation devices in high radiation areas may be verified by use of SURVEILLANCE REQUIREMENTS ,,,m_ m,_,___ __.,__._..__.._m___<_u 5-i_ 5 5"*EE;St t !:,,M -S'E::'--[^N 5.EEx, F(INTj@Ti! MMMN _ __. u;;w;". 5 ;_i:. :I -- M :r;: -- "_ -- - - ^ f -",", -'-, ,...._..._..__._._c__,._,,.. _. _ ~ - -. ._.._y e ] WOLF CREEK-UNIT 1 3/4 6-16 Amendment No 33,89 Mant-ap ofCTS3N.6 MSM7

= CHANGE NUMBER MStiC DESCRIPTION Specification while the identification of the applicable actuation signals is moved to the Bases. 11 08 TR 1 The actuation surveillance is revised consistent with NUREG 1431 to clarify that an actual signal as well as a test signal may be used to verify actuation. The actuation signal is moved to the Bases. (Sdtr.3ATfa') ~ - L{ es.6.3-2.7 ] 11 09 A Consistent with NUREG 1431 and industry traveler TSTF~46, the isolation time surveillance is revised to delete the reference to verifying "each power operated" containment isolation valve and only require verification of each " automatic isolation valve." Containment isolation valves which are power operated (i.e. can be remotely operated) but do not receive a containment isolation signal, do not have an isolation time assumed in the accident analyses since they require operator action. Therefore, deleting the reference to power operated isolation valve time testing is a clarification that reduces the potential for misinterpreting the requirements of this SR while . maintaining the assumptions of the accident analysis. l 55.uxr op.<=tc.A. cames mar *j [ e s.s..s-e ] 11-10 A Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). [cP3.G.3-toj 11-11 A te 's a t -ont nt la ns fi ion ha not ppli le t SV, MSI, MF s, so t y pa Val s and eam nera r s r ef ves. Cons' tent th t curr t 1 cens g . {us@efdA -i2.y lcp.s.s..s - s o i NotLlwA., bas 1 l 11 12 A The phrase " flow path" is added for clarification and consistency with NUREG 1431. This specification is based on GDCs 55, 56, and 57 which address the proper isolation i for each "lir.e" that penetrates containment. It is recognized that multiple lines can share the same penetration. Licensees have always been required to assure that proper protection is provided for each line or l flow path that passes through containment even if multiple flow paths share the same penetration. In this specification, the term " penetration" has always meant each flow path that penetrates containment. Adding the words " flow path" to the specification clarifies this meaning. 11 13 LS 22 Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). w WCGS-Description ofChanges to CTS 3N.6 12 5/15/97

t SERT- -12 ~ w Q34.3-lO A ote i dded to e contai ent isol ion speci cation th the LC0 s not pplicabl to main eam safe valves ( SVs), main -team l 1 sol ion valv (MSIVs) main fe ater isol ion valve (MFIVs), f sociated y-pass v ves and eam gener or atmosp ic relie valves I kARVs)]. he curre licens g basis fo these val s exempt hem from playin a role i establis ng or mai aining co ainment i egrity 'This s based 10 CFR .36 c.2 a c.3 and CFR 50. ppendi ET e are n surveill ces assoc ed with 3.6.1. or LC0 .6.3 'which ar pplicabl to these lves. [T se valv are c enti not consid ed to ha a contai ent isola on funct n.] T s Not is cons' stent wi current 1 censing b s. ~ INSERT 3A-12a i In several specifications throughout the TS, operability of certain equipment is demonstrated by ensuring that the equipment performs it safety function upon receipt of a simulated test signal. The intent of a

  • simulated
  • signal was to be able to perform the required testing without the occurrence (or without causing) an actual signal generating event. However, the unintended effect was to require the performance of the surveillance (using a test signal) even if an actual signal had previously verified the operation of the equipment.

This change allows credit to be taken for actual events when the required equipment actuates successfully. While the occurrence of events that cause actuation of accident mitigation equipment is undesirable, the actuation of mitigation equipment on an actual signal is a better demonstration of its operability than an actuation using a test signal. Thus the change does not reduce the reliability of the equipment tested. The change also improves plant safety: by reducing the amount of time the equipment is taken out of service for testing and thereby increasing its availability during an actual event; and by reducing the wear of the equipment caused by unnecessary testing. t -q- .-y yep-+& e-

CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 10 of 12 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY hN ~ ) (s- { { Q a t,. W l 11 11 e s ot rmen solati speci at W M/A t a s app able Vs. MS

s. FI o

r [ s at b s va si a, steam at rel f [ Q s. Moi-Lised j 11 12 The phrase " flow path" is added for clarification and Yes Yes Yes Yes A consistency with NUREG-1431. 11-13 This change revise the DCPP contairment Ventilation Yes No No No LS 22 Isolation valve surveillance frequency from 30 months to every 184 days and from 24 hours to 92 days. I

  1. 9s-9/A M N/A Xes N/4) 11-14 TA

'thapisno al. or sp A secu in iti s for arif at ir regsfd g43.G;3-51 l whi alve ire 1a ti te ng. tt ttha L,[ 11 15 A Callaway specific note to 3.6.3 regarding testing is No No No Yes A deleted based upon ITS LCO 3.0.5. 11-16 Even though it is not specified in ITS 3.6.3 Required Yes Yes Yes Yes A Actions, the Action to restore the inoperable valve stated in CTS 3.6.3.a is understood as always the primary objective and a continuous option to be performed during any Completion Time. 11-17 Not used. NA M NA NA -MM 'Y'D 8h the. 'IT.S sg J.6. 3b 3 2ses,) A Q.;d 0: j T_ g the COLD SHUTDOWN" or

  • REFUELING MODE" h I

11-18 The words "durin No - not in CTS. No - not in CTS. Yes Yes _ ens.IK g pH(g g gay (pdTM D ! et 3.6. 3-331 l 12-01 Consistent with NLREG-1431. the hydrogen monitoring Yes Yes No - CTS Hydrogen No - CTS Hydrogen A specification is moved to ITS section 3.3.3 concerning Post monitoring monitoring Accident Monitoring Instrumentation (PAM). requirements are requirements are not in this not in this section. section. WCGS-Conversion Cons;parison Table - CTS 3/4.6 S/1SAF7

~. Containment Isolation Valvas (AL;peric. S ic W ;p.c.ic !cc Ccr.dcr.;cr..r.d 021) DNPSFM 3.6.3 3.6 CONTAINMENT SYSTEMS i i 3.6.3 Containment Isolation Valves (AL;peric. ",se.L;p.cric !cc Gs. _..-.... gg j LCO 3.6.3 Each containment isolation valve shall be OPERABLE. _-(43.63-C\\ _ _ _ _ _ _. --. I, ~ ( ,I I..r i k NN W 3 n- --aam me

m-.,a m

---r- _ = _ m-APPLICABILITY: MODES 1. 2. 3. and 4. ACTIONS ..................................... NOTES -- ----- -- ---- ---- - -- ----- - 1. Penetration flow path (s) egipE@jr 42[tantairallint.shutdoen,pisrae? valve 16w ggygg $=Jii may be unisolated intermittently under administrative controls. ~ ' ~ 2. Separate Condition entry is a'ilowed for each penetration flow path. 3. Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves. 4. Enter applicable Conditions and Required Actions of LCO 3.6.1. " Containment." when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria. i WCGS-Mark-qp ofNUltEG-1431-H53.6 3.6-8 5/158 7

Containment Isolation Valves (r_;paric. Subst;r.;;paric. k; Cer.dc..xr. er.d 021) B 3.6.3 l 5 j BASES APPLICABLE The containment isolation valves satisfy Criterion 3 of th; OC-SAFETY ANALYSES I;11;ySt;t;.x..t10TFR;Mr.N(2H,57). (continued) l LCO Cortainment isolation valves form a part of the containment boundary. The containment isolation valves' safety function is j related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA %c. lou 2M Q SAS-ui. The automatic power operated isolation valves are required to ~ l have isolation times within limits and to acti ate on an automatic isolation signal. The 36 inch Um u.2 - 2M-purge valves must be maintained sealed closed < Dr h;n blx'; ir.;telled t; pr;u..t full ep,.r.ir.;]. ~.nx';; a pu.,,. nivu ;1 2 nta t; er. er, st a ti; ;i;.r.l.] The valves covered by this LCO are listed along with their associa_ted stroke times in the USAR (Ref. 2). Q 1i a ra y e. h tall.A]. The normally closed TagliftigliFqEisolation valves are considered OPERABLE when manual valves are closed, automatic valves are de activated and secured in their closed position, blind flanges are in place, and clos _ed systems _are incacW.;x pasiv; undelete. (in1;ti;r.j;ln;/'. sic;; er tg1i;ted ir..t'ere.eee-J-(O -N M~$ ~ ODetEWdAMPurge valves with resilient seals " ' ----- ' -- -.t:17...^. b3p;; nia;] must meet additional leakage rate requircaents. The other containment isolation valve leakage rates are addressed by LCO 3.6.1 " Containment." as Type C testing. This LCO provides assurance that the containment isolation valves and purge valves will perform their designed safety functions to minimize the loss of reactor coolant inventory and establish the containment boundary during accidents. 3, r Eth1M 4 I., .l M 23 ,.3 585 .. $...[ [ (continued) WCGS-Mark-sp ofNUREG-1431 - Bases 3.6 8 3.6 17 5/158 7

Containment Isolation Valv s 0't.i~$cric, Metr;;speric, k; Cerd;racr. ord 5;" B 3.6.3 BASES continued) APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In H0 DES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these HUDES. Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LCO 3.9.4, " Containment Penetrations." ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths, except for 3,6 inch htaineert PuroeFhn_dhst ptege s valve penetrati>n fiow paths, to be unisolated intermittently undar admidtrative controls. These assinistrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a__need for containment isol_ation is indicated, _Due to the Sice ;f tW ""M*+*- ~ undelete. - 7,;;; ,; ; = retr;tii 24

  • fact that g

gpthosepenetrationsexhaust rect y from the containment atmosp1ere to the environmentf the penetration flow path containing these valves may not be opened under administrative controls. A single valve in a penetration ) flow path may be opened to effect repairs to an inoperable valve.] l as allowed by SR 3.6.3.1'. Q.ge unnyeng A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable contairunent isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions. The ACTIONS are further modified by a third Note, which ensures appropriate remedial actions are taken, if necessary. (continued) WCGS-Mark-up ofNUREG-1431 - Bases 3.6 8 3.6 18 S/158 7

I DIFFERENCES FROM NUREG 1431 Section 3.6 This enclosure contains a brief discussion / justification for each marked up technical change to NLREG 1431, Revision 1, to make them plant specific or to incorporate generic changes resulting from the Industry /NRC generic change process. The change ntabers are referenced directly from the NUREG 1431 mark-ups. For Enclosures 3A, 38, 4, 6A, and 6B. text in brackets "[ ]" indicates the information is plant specific and is not common to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that location. CHANGE Nl#EER JUSTIFICATION 3.6 1 This change supports implementation of the 10CFR50 Appendix J Option B for performance based leakage rate testing by referencing the Containment Leakage Rate Testing Program described in the Administrative Controls section. This change is consistent with the CTS and Traveler TSTF 52. 3.6 2 Consistent with Traveler TSTF 17, this change would extend the testing frequency of containment airlock interlock mechanisms from 184 days to 24 months and delete the SR Note per l implementation of Appendix J. Option B. SR 3.6.2.2 would be revised to require testing of the air lock door interlocks at an interval of 24 months. Typically, the interlock is installed after each refueling outage, verified operable with this surveillance and not disturbed until the next refueling outage. If the need for maintenance arises when the interlock is l required, the performance of the interlock surveillance would be required following the maintenance. In addition, when an air lock is opened during times the interlock is required, the operator first verified that one door is completely shut and the i door seals pressurized before attempting to open the other door. Therefore, the interlock is not challenged except during actual testing of the interlock. Consequently, it should be sufficient to ensure proper operation of the interlock by testing the interlock on a 24 month interval. 3.6-3 Consistent wit he curr TS a not s been dded to iarify that the v es list e not a essed in 3.6. These l I valve ilize t eam gene ors and iat iping as el system side of ainment. se y es also e eparate s that pro the a riate ired A onyin .the e t these val s are i rabl. - = fN5 4 -l G3 6 3-lOl u.m c.M 6wcres..sa.e X u \\ convea ( cm u i n A.(Ends wu.w h WCGS-Differencesfrom NUREG-1431-053.6 1 5/15/97

l l INSERT GA-1 p l (Not s ad to e con inment i ation ecifica on that e LCO l ' app cable o ma steam afety va es (MSS ), main team iso ation v ves I ( IVs) main eedwate isolatio valves FIVs), [ sociate by-pass valves and s am g erator mospheri relief v ives (AR )]. Th current icensing l l iba s for ese v ves exemp them fr playin a role establ hing or l f intai ng con inment in grity. is is ba d on 1 CFR 50. c.2 and .3 and 1 CFR 50 Appendix There e no sur illance associa ed with 0 3.6 .1 or 0 3.6.3 ich are a licable t these alves. hese va es ye c rrently ot consi red to ha a contai ent is ation f ction.] ThiVNote s consi tent wit current i ensing b is. l l t l l a

CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431, SECTION 3.6 Page 1 of 4 TECH' SPEC CHANGE APPLICABILITY l r NUlBER DESCRIPTION DIABLO CANYON CONANCHE PEAK 10LF CREEK CALLAWAY I I 3.6-1 This change supports implementation of 10 CFR 50. Appendix Yes Yes, in current TS. Yes Yes Approved as i J. Option B approved in November 1995. Testing 1s performed Amendment #111 l in accordance with the Containment Leakage Rate Testing Program as described in the Administrativ e Controls section. This change is consistent with current TS and in i accordance with industry traveler TSTF-52. 3.6-2 This change would extend the testing frequency of Yes Yes Yes Yes I containment airlock interlock mechanisms from 184 days to 24 L months. This change is in accordance with TSTF-17. (Ido Qa 6.'l-W >l l \\eS M 3.6 3 Consistent with thehurrent TS, a note has been added to J Yes f clarify that the valves listed are not addressed in LCO CN 3.6.3. These valves utilize the steam generators and l associated piping as a closed system inside of containment. l These valves also have separate LCOs that provide the i appropriate Required Actions in the event these valves are inoperable. 3.6-4 This change would extend the Completion Time for a closed Yes Yes No - Wolf Creek No - Callaway does k system flow path with an inoperable isolation valve to 72 does not have GDC not have GDC 57 hours. This change is in accordance with TSTF 30. 57 valves. valves. l 3.6-5 ThischangewouldreviseSR3.6.3.3andSR3.6.3.4to Yes Yes Yes Yes [ specify that only containment isolation valves that are not locked, sealed, or otherwise secured are required to be verified closed. This change is in accordance with TSTF-45. 3.6-6 Consistent with the current CPSES 15. this change would add NO Yes No No [ a note to SR 3.6.3.4 to clarify that the blind flange on the fuel transfer canal need not be verified closed except after i each drainage of the canal. [ I l i l WCGS-Conversion Converison TnMe-ITS3.6 5/158 7 i i h

l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.6.3-11 APPLICABILITY: DC, CP, WC, CA REQUEST: DOC 11-14 A DOC 1-06 LS-19 DOC 11-07 LG JFD 3.6-11 JFD 3.6-12 CTS 3.6.1.7 ACTIONS CTS 3.6.3 ACTIONS CTS 4.6.3.3 ITS 3.6.3 RA A.2 Note 2, RA C.2 Note 2, RA D.2 Note 2, SR 3.6.3.5 and Associated Bases CTS 3.6.1.7 ACTIONS, CTS 3.6.3 ACTIONS, ITS 3.6.3 RA A.2, ITS 3.6.3 RA C.2 and ITS 3.6.3 RA D.2 have been modified by a Note that states the following: " Isolation devices that are locked, sealed or otherwise secured may be verified by administrative means". CTS 4.6.3.3 and ITS SR 3.6.3.5 have been modified by the phrase "that is not locked, sealed or otherwise secured in position" to clarify which valves require isolation time testing. These changes are characterized in JFD 3.6-11 and JFD 3.6-12 as a generic change designated WOG-91. The staff has not received this change through the STS generic change process (TSTF) and therefore considers this change to be beyond the scope of review for this conversion. See Comment Number 3.6.3-12. Comment: Delete this generic change. See Comment Number 3.6.3-12. FLOG RESPONSE: (original) WOG-91 has recently been designated TS1 F-269. While we recognize that this is a generic change to the STS, the change was approved by the Westinghouse Owners Group over 18 months ago and was expected to have been approved by this time. We expect the TSTF committee to forward TSTF-269 to the NRC in the very near future. We believe the technical merits of the change, which supports NRC approved TSTF-45, Rev 1 by providing additional clarification, should justify rapid approval by the NRC. This TSTF is of sufficient value in precluding confusion, LERs, and inspection findings that should we be required to remove it from our submittal, an LAR would be submitted upon NRC approval of the TSTF. We believe that it would be cost effective for all concerned to retain this change within the submittal pending NRC review of TSTF-269. FLOG RESPONSE: (supplement) TSTF-269 has been approved by the NRC. The approved version does not contain all the changes proposed by the original WOG-

91. The following changes have been made to make the FLOG l

submittals consistent with the approved traveler. The exclusion which stated that response time testing does not apply to automatic valves that are locked, sealed or otherwise secured in position has been removed from the CTS and ITS markups. As a result DOC 11-14-A and JFD 3.6-12 are no longer used (note that for Callaway, WCGS and DCPP, changes made to SR 4.6.3.2 under DOC 11-14-A have been reassigned DOC 9-04-A). The traveler list in Enclosure SA has also been updated.

1 J Additionally, this item is related to Comment Number Q 3.6.3-56 for Diablo Canyon and Comanche Peak. No additional response is required for Comment Number Q 3.6.3-56. ATTACHED PAGES: i l Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-17 Encl. 3A 13 Encl. 3B 10 I l Encl. 5A Traveler Status page,3.6-10,3.6-13,3.6-16 j i Encl. 5B B 3.6-24, B 3.6-26 Encl. 6A 3 Encl.6B 2 i l I I l l l i -l l l* I I l d

i l CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Contmuod) .5

  • m 143.41Lu}

e = ? 1;=g_ 7 ---- - _._g,,,a.;isolabon valve [thatis notlocked) Casaled or olhensies secured in positionM f-_.-..___ f C""" ^ ?'_" i-:.., S C^'_ ""'*"."." ' - """' '"' 'T MQQE ar*"a8a= to its isolation E-: "' .E,.. en actual or simulated actuation o'gnai) U U~h atleast onm per 18 months by:

3. S - 2 4z lw%, g ;
. '!;ffz; ",_ ^ r : "..' :._ _*_^* *_ ,,,','._.,.._'_,::'_

m m _m. %g - mi_,__. .m..-_. gJ

5. '.';f;: ; ".:^ r : ".;':::_"_a* '-._. ' ^ - - '--* '.;. ;. ', : : ^

'!:f;!:; "- ' r : C - ^i- --._,."," ; '- ' _ ^ - - '--* :_;; ', _ - - ; -- ;., _ _; 3 _-_ -. 3 7 __ - - m y ineletiep ;::C:_. . user opera Q3.6.3-erl f~ '"?' q',6 isolabon time of each ;:1- :::. er automebc containment Cor w- ;;-' 2 2 _-- _~ TeO. Its li%when tested pursuant to ?;: *- ^'-- '.0.5 . p u:1.a ; s.oisson _ = :': w __::'- u m : = e (theinesfvios Testing Programl s 1 ) lNSERT PG. 314 ACTIONS NOTES:

  • 1. Penetration flow path (s) except containment shutdown purge valve flow

$39W48*13"3 ) { paths may be unisolated intermittently under administrative controls.

2. Se,a,ete Cor tior,.rdry a.o.ed,o, s.c., - tiow,eti,.

es~manga

3. Enter apsdicable Conditions and Required Actions for systems made i

~ inoperable by containment isolation valves.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1 when isolation valve leakage results in exceeding the overed containment leakage rate acceptence critoria.

J WOLF CREEK-UNIT 1 3/4 6-17 Mark-up of CTS.1M.6 $/1.$M

CHANGE NLDBER ! gig DESCRIPTION 11-14 A ben it REG - 31. phr se th is not 1 ed sea , or erwi sec in ition' ad or ar icati in r rd t hich ves r e f ol on t tes V ves th are sec ed in

ace, ar s in pos on r red to t thei saf y unc n.

1so ion ti testing sures at ve res to posi n that s the saf y I fu 'on i time sumed i saf a ysis. val s are s red in t positi that meets ir Qaf functi , no test is n ssary. t4ot ud 11-15 A Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 1 11-16 A Even though it is not specified in ITS 3.6.3 Required Actions, the Action to restore the inoperable valve stated in CTS 3.6.3.a is understood as always the primary objective and a continuous option to be performend during any Completion Time. 11-17 A Not used. 11 18 The EEtffO ~ cp 3,g,,3 33 12 01 A Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 12-02 H Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 12 03 LS 15 Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 12 04 M Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 12-05 LS 16 Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). l 12 06 LG Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 12 07 H Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). i 13-01 LS-17 A new Condition has been added to this specification. This condition describes the Required Action for two hydrogen i recombiners inoperable. Whereas in the current WCGS-Description ofChanges to CTS 3N.6 13 S/1587

. _ _. _.... ~ _ _. _ _. _ _... _ _ _ l i \\ INSERT 3A-13 0 3.6.3-33 11-18 LG The wordsduring the COLD SHUTDOWN or REFUELING MODE' in CTS SR 4.6.3.2 are deleted. Deletion of the specific wording is acceptable and can be considered as being moved to the ITS SR Bases since ITS SR 3.6.3.8 Bases state that the 18-month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the ' Surveillance were performed with the reactor at power. This SR is typically performed during plant shutdown, however, if for instance, an actual signal is ) generated while operating, results should be useable even'though the plant is not " shutdown" (See DOC 11-08-TR-1). Similarly,'if testing would.be required to j complete some repair or modification made while operating, a shutdown'should not be required. l l i I l ,y -e.n+a g. e,. n-_-

CONVERSION COMPARISON TAELE - CURRENT TS 3/4.6 Page 10 of 12 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY {y& W )Mir{ {Q1r.3-to} 11 11 FA e s ot con noen solati speci at

  1. p5-M/A t

a s app able Vs. MS

s. FI o

[ s at b s va s] a steam rat rel f [ Q s. 84ot- (1seef.- ~ j 11-12 The phrase " flow path" is added for clarification and Yes Yes Yes Yes A consistency with NLREG-1431. 11 13 This change revise the DCPP containment Ventilation Yes No No No LS-22 Isolation valve surveillance frequency from 30 months to every 184 days and from 24 hours to 92 days. 11-14 TA

  • t s no eal, or sy Vis 4 as-p/A yee WA

.Y#s N/b I A secu in iti s for arif at irregafd gq 3.4. 3-68l whi alve tre la ti te ng. t4aMLwl,,[ 11-15 A Callaway specific note to 3.6.3 regarding testing is No No No Yes A deleted based upon ITS LCO 3.0.5. 11-16 Even though it is not specified in ITS 3.6.3 Required Yes Yes Yes Yes A Actions. the Action to restore the inoperable valve stated in CTS 3.6.3.a is unkrstood as always the primary objective and a contiluous option to be performed during any Completion Time. NA NA NA NA 11-17 Not used. i%*p{ es the TT.S 54 3.6. 3h Bases) e A IThe words "during the COLD SHl!TDOWN" or " REFUELING MODE" d No - not in CTS. No - not in CTS. Yes Yes 11-18 D RN 23_M_3C3 M%NIdgdMMD !G34.~A-131 12-01 Consistent with NtREG 1431. the hydrogen monitoring Yes Yes No - CTS Hydrogen No - CTS Hydrogen A specification is moved to ITS section 3.3.3 concerning Post monitoring monitoring Accident Monitoring Instrumentation (PAM). requirements are requirements are not in this not in this section. section. 5/15197 WCGS-Conversion Comparison Table-CTS 3/4.6

Industry Travelers Applicable to Section 3.6 TRAVELER # STATUS DIFFERENCE # COMMENTS (UKc appr.hwc. u i1 TSTF-17, Rev.1 Incorporated 3.6-2 TSTF-30, Rev.1 Incorporated 3.6-4 Not applicable to Wolf Creek and Callaway. j6 m* O % wc1e TSTF-45, Rev.1 Incorporated 3.6-5 1 o. TSTF-46, Rev.1 Incorporated 3.6-7 I WRc. 9 reval k TSTF-51 Incorporated NA Not.^.pp". th :e "eb @M"D'IM8 w ,$.'[j[#j TSTF-52 Incorporated 3.6-1 gg.4 WOfbM Incorporated 3.6-11 (TJBC khed)i41f-L*L } f T5fF-2(o9 -Q 3.G. 3 il j 1 .) a.u.w S/15 8 7

Containment Isolation Valves (Atz;pteric. Sut.4%;pteric. Icc Cer.dcr.;cr. er.d 021) pggg:gg 3.6.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 I@ # I IYd:: Isolation devices in high radiation areas may be verified by use of adninistrative means. M$$IsMEl T.m 'Ri; M ' 3% ':. 1 :.. Y : JN 2: [ ' r.:L -ll').; '. 'W ; ^ ~MmM r + n ssinst Verify the affected Once per 31 days penetration flow path for isolation is isolated. devices outside containment htQ Prior to entering H0DE 4 from NODE 5 if not performed within the previous 92 days for isolation devices inside containment, (continued) l 1 4 WCGS-Mark-up ofNUREG-1431-1153.6 3.6 10 5/158 7

4 Containment Isolation Valves (.^1--_ l'.;..-k. 1 e.g.___ _7 _ s. ,..,._n-__ n..,, i. 3.6.3 3 ACTIONS (continued) l COWITION REQUIRED ACTION COMPLETION TIE E C. (continued) h IQ343-lih ec.2 ........norE......... 1. Isolation devices in R-'1 high radiation areas may be verified by use of akinistrative means. j Isolationdevicesthatf 2. i are locked, sealed, or ( dded 3 otherwise secured may / be verified by administrative means. i l i' Verify the affected Once per 4 penetration flow path 31 days for i is isolated. 1 solation l devices outside containment AlEl 't Prior to entering MODE 4 from MODE 5 if not performed within the l previous 92 days for isolation devices inside containment 8lEl EC.3 PerformSRE.@;3;&M Once per SR 3.6.3.7 for the R days ~ resilient seal purge 1. m valves closed to comply 'W with Required g' 4 Action C.1. (continued) ' WCGS-Mark-q ofNUREG-1431-ITS3.6 3.6 13 5/1597

Contairment Isolation Valves 'At;~g,;ric. Sist;~W.cric. I c Cerd;;.;;r. erd Ou;1' gggpsyg 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.3.4 - - NOTE Valves and blind flanges in hign radiation areas may be verified by use of akinistrative means. Verify each containment isolation manual valve Prior to and blind flange that is located inside entering NODE 4 containment 6 ;F4dtlM Cl W from MODE 5 if D.immm';) and required to be closed not pectormed $E6F5$. during accident conditions is closed, except within the for containment isolation valves that are ope previous 92 days under akinistrative controls. RCMRiN$4 SR 3.6.3.5 Verify the isolation time of ;;d ; cur h5neer i c4;r;t;d ;rd each automatic M M*EiEEi @3 6 3-il I containment isolation valvej WMEDL'!IE"E g C,:- - ^_3 Yff ;-W;~2m--.A_s MlMi ~- w Mn ' imits. Te!03 C 3ey m. isis P$^ d .rs. wwy e (continued) WCGS-Mark-up ofNUREG-1431-ITS3.6 3.6 16 $/1587

1 I Containment Isolation Valves (M, $ 1;. i Sd;1;p.;ri;, I;; Cr,rier.;;r. ;.-d ^.,e^ el) B 3.6.3 ] 7herefore,ihe pietraMlig 4 misalipmeytt oHheme. velw3 1

  • =p hm-been veif64 io we A ma. geogw p,ad;w, [g3;q3_il BASES

=- 4 ACTIONS E.1. E.2. and EC 3 (continued) s ]

  1. 2h 8 7 M laipcar4 B Ji g.R Kitsifs.

j @1 --um 23IedseODB!!!EDRd!b1L131s!IltamolitasitedC i i FD.1 and FD.2 I If the Required Actions and associated Completion Times are not j met, the plant must be brought to a MODE in which the LCO does a not apply. To achieve this status, the plant must be L.wght to ] at least MODE 3 within 6 hours and to MODE 5 l within 36 hours. The allowed Completion Times are reasonable, 1 based on operating experience, to reach the required plant l conditions from full power conditions in an orderly manner and i _ ithout chall_enging Dlant _ systems._ _ Q3.b/5-31] w ph 36irw.h conbi% ment shuta Par 3. s A Eshaud valvt. i Eac l ' ihside conta'inment must be verlf.~ed sea \\cd cl6 Sed ev' Md N7ost-j gnstailed priw +9 enteri Moog 4 fre n Moon s,C ---- ~- { R osamed %n 4'fl] M *ff"d* WA. p 3.6 3.tg, SLRVEILLANCE REQUIREMENTS e %.._f = -- i ; a si. g,W,& Each 5 inch gentainment SbgBpi Burge L reouired to be verified sealed closed at 31 day intervals.*This Surveillance is designed o ensure hat a gross breach of containment is not caused by an inadvertent or spurious opening of a gontainment StitiRpni3 urge valve. Detailed analysis of tt.; rg g valves failed to conclusively demonstrate y their ability to close during a LOCA in time to limit offsite [h y W doses. Therefore, these valves are required to be in the sealed closed position % n- - -tring MODES 1, 2, 3, and 4. A Tw.a gontainment Sh valve that is sealed closed must have p 3, g,.3.tg. motive power to the valve operator removed. This can be accomplished by de energizing the source of electric power or by removing the air supply to the valve operator. In this application, the tem " sealed" has no connotation of leak tightness. The Frequency is a result of an EC initiative 03A.3-5$ h~ pknt a ons. In he vent Ive q'8, leakage requires entry into Condition 7the Surveillance permits opening one purge valve in a penetra on flow path to perfom repairs. C (K.,3.6-ED} 9[ 3ali.3:2 This SR ensures that the minipurge valves are closed as required or, if open, open for an allowable reason. (continued) WCGS-Mark-aqp ofNUREG-1431 - Baser 3.6 83.624 5/158 7

l Containment Isolation ValvGs 'M,g.;;;c. em - m _ m ,_,.__2_ _,._n B 3.6.3 l BASES SURVEILLANCE SR 3.6.3.4 REQUIREENTS (continued) This SR requires verification that each containment isolation l manual valve and blind flange located inside containment sM i W E. Wp#35keMi[0seM and required to be closed during%:1 dent conditions is closed. The SR helps to ensure l that post accident leakage of radioactive fluids or gases outside of the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of

  • prior to entering MODE 4 from MODE 5 if not perfomed within the previous 92 days" is appropriate since these contairment isolation valves are operated under administrative controls and the probability of their misalignment is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during l

the time they are open. c -- >. x- , -..%. b. GT " M^Qw

a. u
,1 : E.' '[ -

w 6 b_ l B+sReiote N allows valves and blind flanges l located in high radiation areas to be verified closed by use of l administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3. and 4. for ALARA l reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position. is small. SR 3.6.3.5 Verifying that the isolation time of each F.;;r 74;r;ted ;.r.d MSN l automatic ainment isolation valve W ]M is within Units s requ' n m. 1 solation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. -t The isolation time and Frequency of this SR are in accordance with the l Inservice Testing Program. ;r T dep.] l SEN3EI [cp3.6.32.ij (continued) WCGS-Mark-agp ofNUJtEG-1431 - Bases 3.6 B 3.6 26 $/1587

._ _..____ _ - _. _.. _ _ _ _ _ _ _ _ _. _... _ _. ~... _ _. _ _. _ _ _ _.. _. _ _ 1 CHANGE NIABER JUSTIFICATION ) repositioning, the periodic reverification should only be a verification of the administrative control that ensures that the component remains in the required state. It would be appropriate to remove the lock, seal, or other means of securing the component solely to perfom an active verification of the required state. 4c;a.O b) J l =- -= I l '3.6 12 st wi

3.. 8 which prov st act ion sitionl l

I st is tr red foVvalves ocked alu, or o rwi e1./ s red thei requi posit unde adai trati his nge ld p de tha isola t1 'testi is t ] 1 red aut ic neent solat n valv t aref I ocked

led, othe ed in heir r 1r position under adminis ative c trol. t&W used-

[ c@ns Il l l 3.6 13 ' A cl ying e1 o .6.3.7 t woul low t i 1 age et r neent val wit sil t 1 sea s ed the ratio ow is 1 ated a te bl fla The b fla prov s pt r ired lati and a ional sting of he va es if i l c.-p.<..&, T.Mta plic2W. t. MM creek, See conversieb { sary. 44 Ap me..me Gs). 1 j 3.6 14 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). l 3.6 15 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). 3.6 16 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). 3.6 17 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.6 18 Consistent with CTS 4.6.1.7.2, SR 3.6.3.6 is added to perform leakage rate testing for containment shutdown purge valves and associated blank flanges, once per 24 months when the blind g' flange is installe4-following each reinstallation of the blank J o 2Q

flange, 18nk r

y a ed._ is SR recognizes that cycling the valve could l_ introduce additional seal degradation beyond that occurring to a valve that has not been opened, and allows the use of a leak rate tested blank flange to isolate the penetration flow path. (change Js-cqoststent weth 53 #.t.3 1 rer tnp contajnseht~ n i WCGS-Differencesfrom NUREG-1431-ITS 3.6 3 S/158 7 J

CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431, SECTION 3.6 Page 2 of 4 TECH SPEC CHANGE APPLICABILITY NUPEER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CAltJNAY 3.6 7 This change would revise SR 3.6.3.5 to delete the reference Yes Yes Yes Yes to verifying the isolation time of "each power operated

  • containment isolation valve and only require verification of each " automatic. isolation valve._" This_ change is in b GS.G.S-61 accordance wr h TSTF-46 Trow ep*e= Test ecetaim__ as a 3.6-8 This change would revises the cospletion time for the Yes Yes No - CTS has I hour No CTS has I hour restoration of containment pressure from I hour to [8]

coupletion time. cospletion time. houes. The [8] hour completion time is consistent with the current TS. 3.6-9 These portions of the specification do not apply since a No Yes No No containment cooling system is not part of the CPSES plant design. 3.6-10 This change would replace the Chemical Additive Tank voltsee Yes Yes No - CTS in gallons No Callaway does not have this limits in gallons with tank level limits in percent. system. 3.6-11 This change would provide that the Required Action to Yes Yes Yes Yes periodically verify the affected penetration flow path is isolated does not apply to manual valves and blind flanges that are locked. sealed, or otherwise secured since these were verified to be in the correct position prior to locking. sealing, or securing. 3.6-12 @ ten 7th 3. .8. is 1 vi at .)W WA Vgle WA 385 N[A YW8 WA I i lat ti tes' i t Jir for t C con nme isol ion v that re lopEed, a r ]43(o.3-II) [ o rwi sec ed i he' requ ed positi r l\\_admi strat e co _rol. _ blot teed, __ 3.6-13 A clarifying note is added to SR 3.6.3.7 that would allow Yes Yes Ws do' lq15,32, } that leakage rate testing for containment purge valves with resilient seals is not required when the penetration flow path is isolated by a leak tested blank flange. S/lS M 7 WCGS-Conversion Comparison Table-ITS3.6

l l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-13 APPLICABILITY: WC, CA REQUEST: DOC 7-08 M DOC 7-04 R l CTS 4.6.1.7.3 ITS SR 3.6.3.2 and Associated Bases CTS 4.6.1.7.3 verifies at least once per 7 days the cumulative time that all 18 inch containment mini purge isolation valves have been open during the calendar year. This ] l surveillance not only verifies how long the valves have been open but also verifies that these valves are close_d. The corresponding ITS SR would be ITS SR 3.6.3.2. The CTS markup adds this ITS SR using DOC 7-08 M, and characterizes the change as a More Restrictive change. The staff believes that the change is a Less Restrictive change. The SR is already part of the CTS; the only change is going from a frequency of 7 days to a frequency of 31 days which is a Less Restrictive change. See Comment Number 3.6.3-15. Comment: Revise the CTS markup to reflect this Less Restrictive change and provide the appropriate discussions and justifications. See Comment Number 3.6.3-15. FLOG RESPONSE: (original) No changes. Callaway and Wolf Creek CTS conform to the format and content of Westinghouse STS in NUREG-0452 which provided no specific periodic requirement to verify the containment mini-purgo valves closed. The existing requirement to verify, every 7 days, the cumulative time that the valves have becn open during a calendar year does not constitute a verification of valve position every 31 days. The existing requirements of CTS 4.6.1.7.3 are being maintained in a licensee controlled document as described in DOC 7-04 R (revised to 7 04 LG per response to Comment Number 3.6.3-15). The CTS SR logs the time that the mini-purge valves are opened. Under the CTS SR, the valves could be open for several weeks continuously without affecting valve OPERABILITY. Therefore, the addition of a specific requirement (ITS SR 3.6.3.2) to verify the mini-purge valves closed every 31 days is a new requirement, not in the CTS. Thus, a more restrictive code for the DOC is appropriate. Further support for this conclusion is afforded by the Action Statements for these valves in CTS. The mini-purge valves have no Action associated with being open other than that associated with verifying the cumulative time the valves are open. FLOG RESPONSE: (revised) As discussed at the meeting on October 13-14,1998, WCGS and Callaway are proposing to eliminate tracking the cumulative time that the containment mini-purge valves have been open during a calender year. As noted in the response to Q 3.6.3-15, DOC 7-04-R has been changed to DOC 7-04-LG and is applicable only to DCPP. Therefore, in response j to this question, DOC 7-08-M has been revised to be "Less Restrictive - Specific," and its scope has been expanded to address all changes associated with valve closure status and tracking the cumulative time that

ths cont 2inmtnt mini-purg3 valv:;s havs be n open during a cal:ndar year. New DOC 7-08-LS-28 covers the following proposed changes: The surveillance Frequency for monitoring the position status of the containment mini-purge valves would be changed from once per 7 days to once per 31 days. The requirements associated with tracking the cumulative time that the containment mini-purge valves have been open during a calendar year would be eliminated. These requirements are the Surveillance Requirement to determine the cumulative time, the LCO statement imposing the time limit, and the Action Statement requiring a plant shutdown if the cumulative time exceeds the limit and the associated penetration cannot be isolated within 4 hours. These proposed changes will make the Callaway and WCGS ITS consistent wifn NUREG-1431, Rev.1, requirements for mini-purge valves. The ITS Ccaversion submittal has been marked up to replace DOC 7 M with new DOC 7-08-LS-28. ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-11, 6-12 Encl.3A 6, 7 Encl. 3B 4, 5 Encl. 4 1, new LS-28 i

CONTAINMENT SYSTEMS g.,cfl-A Q.3. 4.0- l l CONTAINMENT'!ET!L^7!ON SYSTEE' SOLATION VALVES) 47-OlWQ Wawwh } LlMITING CONDITION FOR OPERATION 3.6.17 Each containment pur;: b>;;'y end e'-"-' isolation valves shall be 374gM OPERABLE. and;

  • hMn 1)7111LS-25V

@k$

. Er '. SS !n x _ _. - ' d" '1--- pur;: er;;'; nd 25:r ' : ' :
';: 2:!! M '- rd :-d t!:n' a:

x ' - ': ;;r;5::';,;2nd 7- ~ ~ ~ ~ ' E TM 1B he x ^

'; ndenhaus4*eisteen

.i:(:) m:; M :;:- f^'"; t 2^'* 5:::: dur! g : 0 '^nder ;::r. '[ ] APPLICABILITY: MODES 1,2. 3, and 4. [_6b-1.5 2p-%34 3'G I 6CIl0B@

a. With anfinoperable) FNash containment purge supply and/or exhaust isolation

( valve (except for excess ":r C:;:n er n-* r n* " :_:d,close and/or 97 09-EdQ blank flangelhet valve or isolate the penetrationGlow patlQs) within 4 hours, fM2dy ~Qd5- [ Fand verify *' the affected penetration flow path isolated once por 31 days " ~ ~ " for isolation devices outside containment AND prior to entering MODE 4 from MODE 5 If not L11.:I within the previous 92 days for isolation 7-l3-M W3 t evices inside &,. "f 7 : *.JI5thenmee be in at least HOT STANDBY within the d next 5 hours and in COLD SHUTDOWN within the following 30 hours. / s tt '^!t '_h 1" in6 rntic-.:n* -- '.: pur;: r- '; n-"_r xt ;-' __ _K4g%--- m. _. _ m _,_, _ __m--__.m ,mnn u_,,_

m. 2

_ __._ m .. _ _ _. J,i.'7_r iJ l'. J.Z_ ~'s, C.-- m- _ n -_ J_T W# '_'_L'_ 2 m_.'_'~ n Z T G_ ;. __;'7 ~u.n_e. ev..nisau. Th ;;'_ _.._. S Mu-, _ d 5 C^Lr' S"'.' ".""' 15. 5 ' ": '- ; *a he".

c. With-o(One or more penetration flow paths with one or more]

$742-LS;93 O*Nd containment purge valve (s) haveg a measured leakage rate in excess of the limits of Specifications 4.6.1.7.2 and/or 4 6.1.7.4. : _^: ; - :-- : ' ': uc. 3.6-ED ]

' :: } te ^"E?_^"LE -'-^: " :"_": the affected penetration flow path 7-6(rL5p-

[by use of atleast one cloeod and deactivated automatic valve, closed \\ manual valve or blind fp_:.E ^? 24 hourshnd verify *

  • the affected penetration flow path isolated once per 31 daya for isolation devices 1-0-M 434.'5-35) r outside containment AND prior to entering MODE 4 from MODE 5 if not perform _edJvithin the previous 92 days fo_r isolation devices _inside_ con _tainment, rana vertW leen rate on au valves with restlept stelt uses to isolate tfie flow g g gg gg, g.gq JMith at least overv 92 days 6thenese be in at least HOT STANDBY within the next 1 6 hours and in COLD SHUTDOWN within the following 30 hours.

h 1. Penetration flow path (s) except containment shutdown purge valve ) ?l141;LS;131 flow paths may be unisolated intermittenly under administrative controls.

2. Separate condition entry is allowed for each penetration flow path.

"UI% [

3. Enter applicable conditions and required actions for systems made v

"I~ b '3 ' U_ inoperable by containment isolation valves.

4. Enter applicable cond6 bons and required actions of LCO 3.6.1 3-13-A ^ ;

" Containment", when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria. lsolation devices that are locked, sealed, or otherwise secured may be verified

  • i144-LS-lf N+

by administrative means. + lsolation devices in high radiation areas may be verified by use of 71 4 LS-19 administrative means. WOLF CREEK - UNIT 1 3/4 6-11 Mark-up of C153N.6 S/l$/97

CONTAINMENT SYSTEMS New With one or more penetration flow paths with two isolation valves inoperable 7"/-05E" for any reason other than leakage, isolate the affected penetration flow path dwe na within 1 hour by use of at least one clored and de-activated automatic valve, I closed manual or blind flange,'otherwise be in HOT STANDBY within the next (6 hours and COLD SHUTDOWN within the next 30 hours. SURVEILLANCE REQUIREMENTS closed. M) b ach36-inch 4.6.1.7.1 E ntainment shutdowr purge supply and exhaust isolation % 'Rp9-LGT v"lve(sP shall be ven tank flanged and(orflosed at least once per 31 days. / 7-03-A Wote (from ITS SR 3.6.3.1): Not required for one purge valve in a penetration path) 7.]}.Lg.25j iwhile in Action c.f_ g y >, 4 7-so-u-eo 4.6.1.7.21Eacit containment shutdown purge supply and exhaust isolation g7. gung $ valve $nd{ofts _ associated blank flange shall be leak tested at least once per ggg}':'- 24 monthg.; W.,.-.. _ _ _. cm 47 f @ r en pr r-i- " y to-R AS ^O; 22d 00f/h6IFCI Yl2'h0 P02ST^" b2t200TOIO'Of'h000 ~~ a V6:: 2nd "2 ;n - 'rdM; tie-hde; 5 edd^d te the !--50;; '-tr det -

--a -.....-.. e m = 2 e 4,.,,, n u, r..- o

-2 e -. I feUEe'EE-5559-hS :te 555E E"__bU,f EnSc'r.5[ciEnc'E.'withlbr. 7

  • 3 d'
  • 00'" N l

@ntain mz ni Lebha.4 c. Karta Te s+ Wcw3 ea ve. 4.6.1.7.3 TP rM-;: En th-' " 19 M6 rr/_::.. rf -bl pu ; r- 'y On"! : e9 r-* k9 'jer vie: 50/: been - n derm: : ti-d;r ;:: 9:!! be ggg j - dete--Med O! ' ::t ene --r ' day fVerify each containment mini-purge-valve is) q u Fclosed except when the containment mini-purge valves are open for pressure IQW15*28 1 ,.yg,,,3.c j ' c:ntrol ALARA or air quality considerations for personnel entry, or for surveillances that require that valves to be open at least once perj 4.6.1.7.4 At least once per 3 men'h:(84 days AND within 92 days after opening] $7 416-LS-IIP l Q 3.L.3 -l" fthe valvt)each ntainment truni-purge supply and exhaust isolation valve with d"dk g y resilient material seat 11 be demonstrated OPERABLE by verifying that the measured leakage rate le 5 !5 n 205 La h^ ;'r-rted ! P gn accordance e a (with the Contapment Leakage Rate Testing Program.) ]377-hG$.. SAC. 3 Ja-cCre Cn} + lsolation devices in high radiation areas may be verified by use of) j*lMLS;llh* administrative meanys

  • Except valves and flanges which are located inside containment. These valves shall be venfied to be closed wethew@ lank flanges installed prior to

$75111,$-25[ 1 cntry into MODE 4 following each COLD SHUTDOWN (if not completed in the) [ previous 92 days.)

    • This surveillance is not required when the penetration path is isolated by a leah $jD LS-92 ~

tested blank flange.f WWh he bivnd flm3c. Ushlie<4, and h>llowm3 each YeindaIldsb"__ 3 I* N 7.gi g.tg of Mc btvsd flye., ov each con +2inment s6tcAown pp MP$ M cA%st valvr sNLL be. leak testcA of least one.n. O~M I ~ , per ever3 I84 c%s wi & *c. blvnd fiawg remomt.,au.J., dth*" 7" % M L 92. c: lags aftm cye.ng the. valve d tG hJud. fl% - Qg ode.a.. /- WOLF CREEK UNIT 1 3/4 6-12 Amendment No. 89,97 i } e Mark-up ofCTS3M.6 S/2S/97 I I

CHANGE NUPBER NSE DESCRIPTION 5 01 LG The method for calculating containnwnt average temperature I and the locations where measurements are taken are moved to the Bases. This level of detail in the TS is not consistent wi NUREG 1431. The improved STS bases is licensee con olled under the bases control program in the Administrati Controls section of the improved STS. [N3RRT JA-@Q 3.6.'s-il l l 6 02 A Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 6-03 TR 2 Not Applicable to WCGS. See Conversion Comparison Table l (Enclosure 38). l l 6 04 M Not Applicable to WCGS. See Conversion Comparison Table j (Enclosure 38). I l 7 01 A Consistent with NUREG 1431, the LC0 and surveillance j requirements for containment ventilation / purge valves are j now included in section 3.6.3 for Containment Isolation ~ l Valves. 7 02 LS 9 Consistent with NLFIG 1431. the required actions for a 3 1 containment ventilation / purge valve with a leakage rate which exceeds the acceptance criteria is revised allows continued operation if the penetration flow path is isolated within 24 hours. This action is in lieu of requiring a shutdown if the valve leakage rate is not restored to an acceptable value within 24 hours. This is acceptable because with the associated penetrations isolated per the proposed Action requirements. no accident l as a result of the leaking valve is credible. 7 03 A change [for CTS 1. consistent with NUREG 1431 SR 43 b3-4) 3.6.3.1 is added to provide an allowance for one isolation -- valve in a penetration flow path to be open when performing the Required Actions for leakage not within limits. This is actually a consistency change which goes with the revised required actions (see 7 02 above). The required action allows continued operation with leakage not within limits and this change to the SR allows a v_alve to be opened to repair the excessive leakage.Q5EET 3A'-@ [ 7 04 The ti imit res ~ ions opening [ min purge i s y and ex. valves and the uir s to riodical __accumul a the ti at t alves e been n beP 2..;d to ensee ntrolled Ms. M Q#1.3- % I RT 3A - ? WCGS-Description ofCha es to CTS 3M.6 6 5/1587 l y i:ps.r.3.oj \\ w, u m a c e s.. w a - a - a,,ea, j TaH nale a ww. 310. ... ~.

. _ - - _ = . _- _-.. -.-._~. l INSERT 3A-6 i i l These details are not necessary to ensure that the containment. air l temperature is maintained within limits. The requirements of ITS Specification 3.6.5 " Containment Air Temperature," and ITS SR 3.6.5.1 are adequate to ensure the containment air temperature is maintained within the limit. l INSERT 3A-6a l In the event one or more isolation valves in one or more penetration i flow paths are not within leakage limits, leakage must be reduced to l within limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve (this includes power l operated valves with power removed), or blind flange. Since these Required Actions ensure that the penetration maintains isolation, one leaking valve may be opened to affect repairs without significant reduction in the containment isolation capability. - {Q,3,(,,3 13 INSERT -6b is is sible ce DBA c ulations ume the pur e functiot ay be in se ce at e start of he accide Closure assured the re ndancy these val s and that ey are de ' ned to el e again A con ions. Thi combined w the low p bability a DBA w le j i hi ow path i n service es the total risk very small. / i i l I l

CHANGE BREE gile DESCRIPTf0N l 7 05 A Consistent with NUREG 1431, an action is added for two j valves inoperable in one penetration flow path. The change is achinistrative since the current TS would have relied on LCO 3.0.3 which has essentially the same requirements. 7 06 LS 11 Consistent with NUREG 1431, the leakage rate testing j frequency for containment isolation valves with resilient seals is revised to 184 days based on the NRC resolution of Multi-Plant Action No. B 20. " Containment Leakage Due to Seal Deterioration."/fe'st on a s agger est is ig j fnoTo r requ also a rfo lea test in 92 ys of i he i valv rec ze tha yeling valv ould roducy a itional al ation that curring to a / r M alve tha has no been _ r @ s G A:r 3 A -i Q 7 07 LG Consistent with NUREG 1431, the leakage rate test j acceptance criterion for containment isolation valves with ~ '~ resilient seals is moved to the Bases. This criterion is l appropriately moved to the Bases as this leak rate does j not directly tie to safety but indicates degradation of the resilient seals. ITS SR 3.6.1.1 is the leak rate which ties directly to the safety analysis.[ ] J 3 4.3 -G_j 7-08 .JP This sa day o veri mini rge valve osed t aut zed rea s. sa a j 33 st nt uir that i pprop ' ate f con nment i 8 u58" 3^ - 7c la valv and con ent w NUREE 143. l 7 09 LG The descriptive details regarding the valve size and i isolation requirements for the LCO have been moved to the ITS 3.6.3 Bases. [sTf 5 A@ { A 3.6. b -n.] 7-10 LS 9 A Note is added to clarify that leakage rate testing is not required for containment purge valves with resilient i seals when the penetration flow path is isolated by a leak tested blank flange. The purpost of the leak testing requirement is to ensure containment leakage integrity i during an accident, and thereby limit accident consequences. Isolation of the flow path with a leak tested blind flange accomplishes this safety function and additional leak testing of the valves in the flow path is i redundant and unnecessary. .7 11 LS 25 Removes the requirement from CTS 3.6.1.7 surveillance requirements to blank flange the containment shutdown i' \\. WCGS-Description of Changes to CTS 3N.6 7 5/15197 \\ _.. ~,, - - _ _ _ _ _ _.. _ _

INSERT 3A-7c 0 3.6.3-13 The surveillance Frequency for monitoring the position status of the containment mini-purge valves would be changed from once per 7 days to once per 31' days. Also, the requirements associated with tracking the cumulative time that the containment i.Jni-purge valves have been open during a calendar year would be eliminated. These requirements consist of the time limit that the valves may be open, and the Action Statement requiring a plant shutdown if the cumulative open time exceeds the specified limit and the associated penetration cannot be isolated within the next 4 hours, and the requirement to determine the cumulative time that the valves are open. These changes are consistent with the NUREG-1431, Rev.1, requirements for these valves. Changing the surveillance frequency from 7 days to 31 days is acceptable because this change would not constitute a change in the manner of maintaining the OPERABILITY of the valves. While the frequency of performing the verification would change, current requirements for the valves, as noted in CTS Bases, specify that the valves should be opened only for safety-related reasons. The proposed ITS SR 3.6.3.2 Bases specify that the valves would be inoperable if found open unless open for an allowable reason. The allowable reasons from ITS are synonymous with the safety-related reasons from CTS. These valves are operated in accordance with system operating procedures under the' direct control of the operating staff in the Control Room. Therefore, a change in surveillance frequency would have no effect on the position status of the valves during plant operation and is acceptable. Eliminating the LC0 limit on cumulative time, and its associated Action Statement and surveillance requirement, are acceptable changes because, as stated in the Bases for proposed SR 3.6.3.2, the new surveillance would assure that the mini-purge valves are closed as required or', if open, open for an allowable reason. Therefore, although the cumulative time limit requirements would not be in ITS, the mini-purge valves would continue to be governed by the requirement that they remain closed unless opened for an allowable reason. Operating the mini-purge system in this manner would not result in an excessive cumulative open time based on operating experience at Callaway and WCGS. For example, over the past five calendar years, the average cumulative time for both plants was 279 hours per year: and the maximum time for either plant was 535 hours in a' year. The current limit on cumulative open time is intended to reduce the likelihood of occurrence of a Design Basis Accident (DBA) that requires containment isolation while the valves are open. However, the mini-purge valves are designed to meet the requirements for automatic containment isolation valves and are capable of performing their required containment isolation function at any time following a DBA, even during a loss of coolant accident. Following a design basis accident, isolation of the mini-purge flow paths is assured by (1) the actuation of the valves to close on a safety-grade, phase-A containment or-i- . r ., i.-

.... _. -. _. ~. - -... . - ~ - INSERT 3A-7c (continued) 0 3.6.3-13 isolation signal. (2) the redundancy of these valves which assures the containment isolation function even with an assumed single failure of one valve, and.,(3) the qualification program for the valves which provides assurance that the valves can perform their safety function at l all times during plant life. The capability of the valves to perform their safety function has been demonstrated by a qualification program I based on testing and analysis required by NUREG-0737 Issue II.E.4.2, for pJrge valves intended for use during plant operation. Thus, containment isolation is assured by the design of the valves. Furthermore, the valves would continue to be used intermittently based on allowable reasons: thus, the probability of a DBA occurring during the limited time that this flow path is in service is very small. l Absent the plant shutdown requirement associated with exceeding the i cumulative time limit and failure to isolate the flow path, the mini-purge valves would continue to be governed by other containment isolation valve specifications and plant shutdown requirements should l the valves be inoperable. l [ a l l 1 I i l f

l CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 4 cf 12 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 06 01 Not used. NA NA NA NA 6 02 The insp xtion requirements associated with structural (W-Ves-No-sec. Yes No - (3.6.1.6 not No - (3.6.1.6 not A integrity of tM exposed accessible interior and exterior mM, t$ in CTS) in CTS) containment surfaces, are contained in Appendix J. Option B and in RG 1.163. 6-03 Reporting requirement for Containment Structural Integrity / -ut Yes No - (3.6.1.6 not No - (3.6.1.6 not TR 2 are deleted. (A m e a m.,4 i g g3 in CTS) in CTS) oc Au.-oot 6 04 A0T for Containment Structural Integrity not established N Wo-uc. Yes No - (3.6.1.6 not No - (3.6.1.6 not H decreased from 24 hours to I hour. Mm.,4 s 11Dllig in CTS) in CTS) oc-an-w 07 01 The LCO and surveillance requirements for containment Yes Yes Yes Yes A ventilation / purge valves are now included in section 3.6.3 for Containment Isolation Valves. 07-02 The required actions for a containment ventilation / purge Yes Yes Yes Yes LS-9 valve with a leakage rate which exceeds the acceptance criteria is revised to be stated on a per penetration flow path bases. T733 A clarification is added to allow one isolation valve in a Yes Yes Yes Yes .k-- penetration flow path to be opened for repairs when [Q 3.6.3 - 4.l 1.5-% performing the Required Actions for leakage rate not within limits. pl-Yes jelat o 07-04 The time limit restrictions on opening the [ mini purge Yes - relocated to No - CPSES does not es - 6. Crap ._16. / A-l_G-supply and exhaust valves) and the requ' ements to ECGS. have restrictions Ghapt- /*f 3 b 3 Ml periodically accumulate the time that the valves have been these valves. open would be relocated to licensee controlled documents. / 07-05 An action is added for two valves inoperable in one Yes Yes Yes f Yes A penetration flow path. k . _ vefer % 7-oS -LS- $QMS-13' WCGS-Conversion Comparison Table-CTSJM.6 S/15/97

CONVERSION COMPARISON 3 aCLE - C'URRENT TS 3/4.6 Page 5 cf 12 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 07-06 The leakage rate testing frequency for containment No - see 11 13 LS-Yes Yes Yes LS-11 isolation valves with resilient seals is revised to 184 22 nd i as est s is 1 d Q 3.6.3 -17. j age t wt n 92 s of i y o 07 07 The leakage rate test acceptance criteria for containment No - criteria Yes Yes Yes LG isolation valves with resilient seals is moved to the already moved from Bases. CTS. FAdds i to a ay Janee-to al No - CPSES does not Yes Yes 07 08 y p c1 of t ni-y is have any closure { Q 3.6 3-13 restrictions on ~. ( i.5 28 InstytT 3B-5b 3 kmAs,M C.Ts) this valves. 07 09 Details regarding the valve size and isolation requirements No - CTS does not No - This detail is Yes Yes LG have been moved to the ITS bases contain this not in the current requirement TS. 07 10 A note is added to clarify that leakage rate testing is not No - CTS does not Yes. Yes Yes LS 9 required for containment purge valves with resilient seals contain this when the penetration flow path is isolated by a leak tested requirement blank flange. 07-11 Removes the requirement to blank flange the containment No - That No - That Yes Yes LS 25 shutdown purge supply and exhaust isolation valves and requirement was not requirement was not revises the surveillance requirement for verification of part of CTS. part of CVS. the closed shutdown purge valves and flanges for inside containment. 08-01 The LCO references to suction flowpath and manual transfer Yes Yes Yes Yes LG of suction to containment sum have been deleted. These details are included within the operability requirements of the Containment Spray System as described in the Bases. IN - 8N88MI 36-hp(~Q3.c 3 -35 ] ^~ l Q.3.s.3 -nl WCGS-Conversion Comparison Table-CTS 3M.6 S/15M7

__ _ _.__...._. ~. - _ _ _ ~ t INSERT 3B-5b 0 3.6.3-13 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 07-08 The surveillance Frequency would be changed No - No - CPSES Yes Yes i LS-28 from once per 7 days to once per 31 days. Maintaining does not have ) And the requirements associated with-CTS any closure tracking the cumulative time that the restrictions r containment mini-purge valves have been on these open during a. calendar year would be valves. eliminated. [ 1 I h I e i I } l r i f F r i h I I .. ~.

l l NO SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC) n CONTENTS L I. Organization........................................ 3 II. Description of NSHC Evaluations...................... 4 III. Generic No Significant Hazards Considerations "A" Admi ni strati ve Changes......................... 6 "R" Relocated Technical Speci fications............. 8 i l "LG" Less Restrictive (Moving Information Out of l the Technical Speci fications)................... 11 "M" More Restrictive Requirements.................. 13 IV. Specific No Significant Hazards Considerations "LS" [ LS-1................................................ 16 LS.2................................................ W LAstA 4866-'il LS 3................................................ 20 LS 4................................................ 22 g LS 5................................................ 24 LS 6................................................ 26 i LS-7.,............................................... 28 i LS 8............. .................................. 30 LS 9................................................ 33 i LS 10........-................................Not Used LS 11............................................... 35 LS 12................................... Not Appl i cabl e LS 13............................................... 3 7 LS 14.................................... Not Appl i cabl e LS 15.................................... Not Appl i cabl e LS 16.................................... Not Appl i cabl e - LS 17............................................... 39 LS 18................. -.............................. 42 LS 19............................................... 44 LS 20..........................................Not Used ( LS 21..........................................Not Used l LS 22..................................... Not Appl i cabl e j LS 23............................................... 46 l LS 24.......................................... Not Used LS 25............................................... 48 L5 N%g lo3.r..s-4.l \\, ~ LS-28 F o 3.s. 3.i s j WCGS-NSHCs - CTS 3M.6 1 5/1587 l ( -. - _.,, ~. -.

INSERT 4-a 0 3.6.3-13 l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS l-NSHC LS-28 10 CFR 50.92 EVALUATION l FOR l TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS The proposed changes would decrease the frequency fer verifying position status of mini-purge valves from once per 7 days to once per 31 days and would eliminate the requirements associated with tracking the cumulative time that the containment mini-purge. valves have been open during a calendar year. These requirements consist of the surveillance to determine the cumulative time that the valves are open, the LCO statement that establishes a limit on the time that the valves may be open, and the Action Statement requiring a plant shutdown if the cumulative time exceeds the i specified limit and the associated penetration cannot be isolated within the next 4 hours. Changing the surveillance frequency from 7 days to 31 days is acceptable because this change would not constitute a change in the manner of maintaining the OPERABILITY of the valves. While the frequency of performing the verification would change, current requirements for-the valves, as noted in CTS Bases, specify that the valves should be opened only for safety-related reasons. The proposed ITS SR 3.6.3.2 Bases specify that the valves would be inoperable if found open unless open ( for an allowable reason. The allowable reasons from ITS are synonymous with the safety-related reasons from CTS. These valves are operated in accordance with -system operating prucedures under the direct control of the operating staff in the ~ Control. Room. Tnerefore, a change in surveillance frequency would have no effect on the position status of the valves during plant operation and is acceptable. Eliminating the LC0 limit on cumulative time, and its associated Action Statement j and surveillance requirement, are acceptable changes because, as stated in the Bases ] for proposed SR 3.6.3.2, the new surveillance would assure that the mini-purge valves are closed as required or, if open, open for an allowable reason. Therefore, i although the cumulative time limit requirements would not be in ITS. the mini-purge j valves would continue to be governed by the requirement that they remain closed unless opened for an allowable reason. Operating the mini-purge system in this manner would not result in an excessive cumulative open time based on operating i experience at Callaway and WCGS. For example, over the past five calendar years, ( the average cumulative time for both plants was 279 hours per year; and the maximum I time for either plant was 535 hours in a year. I The current limit on cumulative open time is intended to reduce the likelihood of occurrence of a Design Basis Accident (DBA) that requires containment isolation while the valves are open. However, the mini-purge valves are designed to meet the rec,uirements for autamatic containment isolation valves and are capable of 1 performing their required containment isolation function at any time following a i DBA, even during a loss of coolant accident. Following a design basis accident, j isolation of the mini-purge flow paths is assured by (1) the actuation of the valves ] j to close on a safety-grade, phase-A containment isolation signal, (2) the redundancy } of these valves which assures the containment isolation function even with an I i

-- -....=__~._ - - -. -_-.. -. - _ - - -.- 1 IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATION NSHC LS-28 (continued) assumed single failure of one valve, and (3) the qualification program for the valves which provides assurance that the valves can perform their safety function at all times during plant life. The capability of the valves to perform their safety function has been demonstrated by a qualification program based on testing and analysis required by NUREG-0737,_ Issue II.E.4.2, for purge valves intended for use during plant operation. Thus, containment isolation is assured by the design of the valves. Furthermore, the valves would continue to be used intermittently based on allowable reasons; thus, the probability of a DBA occurring during the limited time that this flow path is in service is very small. This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below: "The Commission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendment to an operating Ifcense for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3. Involve a significant reduction in a margin of safety." The following evaluation is provided for the three categories of the significant hazards consideration standards: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The change in surveillance frequency from 7 days to 31 days is consistent with NUREG-1431, Rev. 1. This change does not involve any hardware changes or any changes that would affect accident or transient initiators. Neither does it constitute a change in the manner of maintaining tne OPERABILITY of the valves. This change in surveillance frequency would have no effect on the position status of the valves during plant operation. Therefore, the change in surveillance frequency would not have any impact on the probability or consequences of an accident. The changes associated with tracking the cumulative time that the containment mini-purge valves have been open during a calendar year does not involve any hardware changes or any changes that would affect accident or transient initiators. So, the probability of an accident or transient is not affected. Also, these changes do not affect the OPERABILITY of the valves which are designed to mitigate previously 1 ~..., _.,

i IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATION NSHC LS-28 (continued) analyzed accidents by isolating containment as required. Thus, the consequences of accidents would not be adversely affected by the changes. i l Therefore, the proposed changes would not result in a significant increase in the l probability or consequences of a previously evaluated accident. I T. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes to surveillance frequency and elimination of the requirements l associated with cumulative time that the valves have been open do not involve any l physical alteration of the plant. No new or different types of equipment or i l_ components will be installed. Also, the proposed changes do not involve new methods i of operating plant systems or equipment or changes in the parameters used for plant operation. Therefore, this proposed change would not create the possibility of a new or different kind of accident. 3. Does this change involve a significant reduction in a margin of safety? The proposed changes to surveillance frequency and elimination of the requirements associated with cumulative time that the valves have been open do not involve l changes to accident analysis assumptions, initial conditions, or results. l The change in' surveillance frequency from 7 days to 31 days would have no adverse effect on valve OPERABILITY: therefore, the change would not reduce any margins of safety. The changes associated with tracking the cumulative time that the containment mini-purge valves have been open during a calendar year could eliminate possible plant shutdowns required by the CTS Action Statement whenever the cumulative time limit was exceeded and the flow path could not be isolated. When the plant is shutdown (outside the MODE of Applicability of the purge valve requirements), there is a reduced possibility of an accident requiring containment isolation. However, the mini-purge valves are designed to meet the requirements for automatic containment isolation valves and are capable of performing their required containment isolation function at any time following a DBA, even during a loss of coolant accident. Therefore, eliminating the shutdown requirement would have a negligible effect on margins of safety. Therefore, this proposed changes would not involve a significant reduction in a margin of safety. l l l l i w y e-m v m -wr --~. -a c- --r--- e w evWP Dv ee-*

y IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATION NSHC LS-28 (continued) NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LS-28" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c), and accordingly, a j no significant hazards consideration finding is justified. l

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.6.3-15 APPLICABILITY: WC, CA REQUEST: DOC 7-04 R CTS 3.6.1.7 (DCPP) CTS 3.6.1.7.b (Callaway and WCGS) CTS 3.6.1.7 ACTIONS (DCPP) CTS 3.6.1.7 ACTION b (Callaway and WCGS) CTS 4.6.1.7.2 (DCPP) CTS 4.6.1.7.3 (Callaway and WCGS) CTS 3.6.1.7, CTS 3.6.1.7 ACTIONS and CTS 4.6.1.7.2 for DCPP and CTS 3.6.1.7.b, CTS 3.6.1.7 ACTION b, and CTS 4.6.1.7.3 for Callaway and WCGS specify the cumulative time purge valves, vacuum / pressure relief valves and mini-purge valves may be opened per calendar year. The CTS markup shows these items as being relocated and justifies the relocation in DOC 7-04 R. The "R" designation is for technical specifications which do not meet the criteria of 10 CFR 50.36(c)(2)(ii) which applies to entire specifications, not individual LCO, ACTIONS or SRs. Based on Enclosure 3B " Conversion Comparison Table - Current TS 3/4.6," the change for Callaway and WCGS would be a Less Restrictive - Generic (LG) change since the information is relocated to the Safety Analyses Report; for DCPP the change would be either Less Restrictive - Generic (LG) or Less Restrictive - Specific (LS) depending on whether the "ECG" is controlled by 10 CFR 50.59 or not contrclied by 10 CFR 50.59 respectively. The DCPP document "ECG" is not defined in the submittal. In addition, no justification is provided as to why this information can be relocated. Comment: Revise the CTS markup to show this change as a Less Restrictive change and provide additional discussions and justification for this Less Restrictive change. The justification should include the reasons the individual items can be relocated. For DCPP describe the document "ECG" and the document change control process. FLOG RESPONSE: (original) DOC 7-04-R is revised to 7-04-LG since this information is being moved to a licensee controlled document (Callaway to FSAR, Wolf Creek to USAR and Diablo Canyon to ECG). DOC 7-04-LG has been modified to further clarify why containment purge supply and exhaust f,ow paths and for DCPP the pressure / vacuum relief flow paths and the requirements to periodically accumulate the time the valves have been open can be moved to a licensee controlled document. This is possible since DBA calculations assume the purge function may be in service at the start of the accident. Closure is assured by the redundance of these valves and that they are designed to close against DBA conditions. This combined with the low probability of a DBA while this flow path is in service makes the total risk very small. Diablo Canyon has Equipment Control Guidelines (ECGS) that are controlled by DCPP Department-Level Administrative Procedure (DUAP) OP1.DC16, " Control of Plant Equipment Not Required by the Technical Specifications." DCPP ECGS are similar to other plant's Technical Requirement Manual (TRM). Changes to ECGS are made under the provisions of 10 CFR 50.59, as required by DLAP OP1.DC16 and FSAR

Ch;pt:r 16. Tha NRC has aco:pt d ECGS as a licansu controllid document. This is confirmed most recently in License Amendment 120/118 dated 2/3/98, page 2 of the NRCs safety evaluation report. FLOG RESPONSE: (revised) Changes for Callaway and V/ CGS, that were previously addressed by DOC 7-04-R, have been integrated into new DOC 7-08-LS-28 as discussed in the response to Comment Number O 3.6.3-13. Therefore, the response to this question is applicable to DCPP alone; and the status of DOC 7-04-LG will be changed to "not applicable" for Callaway and WCGS. DOC 7-04-R is revised to 7-04-LG since this information is being moved to a licensee controlled document DOC 7-04-LG has been modified to further clarify why for DCPP pressure / vacuum relief flow paths and the requirements to periodically accumulate the time the valves have been open can be moved to a licensee controlled document. This is possible since DBA calculations assume the purge function may be in service at the start of the accident. Closure is assured by the redundance of these valves and that they are designed to close against DBA conditions. This combined with the low probability of a DBA while this flow path is in service makes the total risk very small. Diablo Canyon has Equipment Control Guidelines (ECGS) that are controlled by DCPP Department-Level Administrative Procedure (DLAP) OP1.DC16, " Control of Plant Equipment Not Required by the Technical Specifications." DCPP ECGS are similar to other plant's Technical Requirement Manual (TRM). Changes to ECGS are made under the provisions of 10 CFR 50.59, as required by DLAP OP1.DC16. The NRC has accepted ECGS as a licensee-controlled document. This is confirmed most recently in License Amendment 120/118 dated 2/3/98, page 2 of the NRCs safety evaluation report. ATTACHED PAGES: See the attached pages in the revised response to Comment Number Q 3.6.3-13.

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-17 APPLICABILITY: WC, CA REQUEST: DOC 7-06 LS-11 DOC 11-13 LS-22 JFD 3.6-18 JFD 3.6-19 CTS 4.6.1.7.2 CTS 4.6.1.7.3 CTS 4.6.1.7.4 CTS 4.6.3.4 ITS SR 3.6.3.6, SR 3.6.3.7 and Associated Bases CTS 4.6.1.7.2,4.6.1.7.3,4.6.1.7.4 and 4.6.3.4 require a leak rate test for the various types of containment purge valves with resilient seals at various specified frequencies. 1 in converting to the ITS these frequencies have been modified. In some cases, the frequency change is a Less Restrictive change (i.e.,24 hours to 92 days), while in others the change is More Restrictive (i.e.,24 months to 184 days), or Administrative (92 days to 92 days of opening valve). Considering the whole change, the staff cannot conclude i that the preponderance of the changes would result in the change being classified as Less Restrictive as specified in DOCS 7-06 LS-11 and 11-13 LS-22, rather than More Restrictive or Administrative. The converse is also true. In order to more accurately l reflect the changes made, each individual CTS should be reevaluated with regard to the changes and marked accordingly (Administrative, Less Restrictive or More Restrictive). See Comment Numbers 3.6.3-17,3.6.3-18,3.6.3-19,3.6.3-20 and 3.6.3-21 for additional i specific concerns with regards to this change. Comment: Revise the CTS as specified and provide the appropriate discussions and justifications for the Administrative, Less Restrictive and More Restrictive changes. See Comment Numbers 3.6.3-18, 3.6.3-19, 3.6.3-20, 3.6.3-21 and 3.6.3-22. FLOG RESPONSE: (original) This comnient deals with current surveillance requirements 4.6.1.7.2,4.6.1.7.3,4.6.1.7.4, and 4.6.3.4. The proposed changes associated with these surveillances, which deal with testing of valves with resilient seals, are addressed and justified as follows: ) 4.6.1.7.2 - For DCPP, this item is not applicable because it is not a leak test surveillance. For CPSES, the proposed changes delete STAGGERED TEST BASIS for the 184-day surveillance and add a new requirement to test within 92 days of opening the valve. The DOCS that support these changes are discussed in the response to Comment Number 3.6.3-19. In this response, CPSES has developed additional DOCS 7-14-M and 7-15-A and modified DOC 7-06 LS-11. For Callaway and Wolf Creek, the proposed changes involve allowing testing of the containment shutdown purge isolation valves with or without blank flanges installed. The DOC supporting the proposed changes (DOC 7-i1 LS-25) is discussed in the response to Comment Number 3.6.3-21 and 3.6.3-24. To further support the Callaway and Wolf Creek changes, DOC 7-11 LS-25 has been modified to employ the NUREG-1431 test frequencies of 184-day and within 92 days of opening as mitigating

f:ctors in the ov:rall relaxation of t:st r:quirem:nts for th3 containm:nt shutdown purge isolation valves. 4.6.1.7.3 - For DCPP, this item is not applicable because it is not a leak test surveillance. For CPSES, the proposed changes revise the testing frequency for pressure relief valves from 92 days to 184 days and within 92 days o) opening a valve. The DOCS that justify these changes are i discussed in the response to Comment Number 3.6.3-20. In responding 2 to Comment Number 3.6.3-20, DOC 7-06 LS-11 was used; and new DOC 7-16-A was prepared. For Callaway and Wolf Creek, this item is not applicable because it is not a leak test surveillance. 4.6.1.7.4 - For DCPP and CPSES, this is not applicable because this surveillance is not used. For Callaway and Wolf Creek, the proposed j chages revise the testing frequency for the mini-purge valves from 92 days to 184 days and within 92 days of opening a valve. The same DOCS (7-06 LS-11 and 7-16A) discussed in the response to Comment i Number 3.6.3-20 also are applicable to tr 9 pFposed changes for Callaway and Wolf Creek. 4.6.3.4 - For all the FLOG plants except DCPP, this surveillance is not used. For DCPP, the proposed changes revise the frequency of testing ventilation isolation valves from every 72 hours and within 24 hours of l cycling a valve to every 184 days and within 92 days of opening a valve. The DOC supporting the proposed changes is addressed in the response l to Comment Number 3.6.3-18. FLOG RESPONSE: (supplement) As discussed at the meeting on October 13-14,1998, the l paragraph for 4.6.1.7.4 in the original FLOG RESPONSE is modified to eliminate the reference to Comment Number 3.6.3-20 since that comment was not applicable to Wolf Creek or Callaway. This paragraph is modified j as follows: j l 4.6.1.7.4 - For DCPP and CPSES, this is not applicable because this surveillance is not used. For Callaway and Wolf Creek, the i proposed changes revise the testing frequency for the mini-purge l valves from 92 days to 184 days and within 92 days of opening a l valve. DOC 7-06-11 was used to justify the change from 92 days l to 184 days. DOC 7-16-A is used to justify adding "and within 92 days after opening the valve. ATTACHED PAGES: l None

n J

ADDITIONAL INFORMATION COVER SHEET l ADDITIONAL INFORMATION NO: O 3.6.3-21 APPLICABILITY: WC, CA REQUEST: DOC 7-06 LS-11 JFD 3.6-18 l CTS 4.6.1.7.2 ITS SR 3.6.3.6 and Associated Bases CTS 4.6.1.7.2 for Callaway and WCGS requires a leak rate test on the 36 inch containment shutdown purge valves and its associated blank flange at least once per 24 months and following each reinstallation of the blank flange. ITS SR 3.6.3.6 retains the CTS frequency for when the blank flange is installed, but adds the following frequencies for when the blank flange is removed: 184 days and within 9 Jays after opening the valve. The addition of 184 day /92 day frequencies is a More Restrictive change. The CTS characterizes this change as Less Restrictive, and the CTS markup for WCGS does not show the change. See Comment Number 3.6.3-23 for additional concerns in this area. Comment: Revise the CTS markup accordingly and provide additional discussion and justification for this More Restrictive change. See Comment Number 3.6.3-23. FLOG RESPONSE: (original) The basis for characterizing this change as less restrictive is that current LCO 3.6.1.7 requires the shutdown purge valves to be closed and blank-flanged. Any change that involves dispensing with the blank flange was deemed less restrictive as documented in DOC 7-11-LS-25. This is the case for adding proposed surveillance requirements for leak testing the valves alone - without blank flanges. CTS 4.6.1.7.2 provides requirernents associated with testing valves and blank flanges; while proposed ITS SR 3.6.3.6 provides more operational flexibility by providing the alternative of testing the valves without blank flanges. Therefore, the proposed change assigning a testing frequency to the valves alone also is considered less restrictive even though the testing is done more frequently. The more frequent testing (184 days and 92 days of opening) is considered to provide offsetting conservatism to help balance the alternative of operating without blank flanges. Nevertheless, the overall proposed change is considered to be less restrictive. The CTS markup for WCGS inadvertently omitted the additional Frequency of "184 days and within 92 days after opening" for these valves without blank flanges installed. The appropriate changes were made to proposed ITS SR 3.6.3.6 but were not reflected in the CTS markup. CTS 4.6.1.7.2 markups were revised to reflect this change. FLOG RESPONSE: (supplement) As discussed at the meeting on October 13-14,1998, a more restrictive DOC (7-17-M) has been developed to address changing the frequency of testing the containment shutdown purge valves to 184 l l days and 92 days after opening the valve with the blind flange removed. DOC 7-06-LS-11 addresses the frequency changes to CTS 4.6.1.7.4 for the containment mini-purge valves. DOC 7-11-LS-25 addresses removal l of the requirements to blank flange the shutdown purge valves. DOC 7-

10-LS-9 has been d;l:t:d for Wolf Crc:k and C llaway bas;d on n:w DOC 7-17-M and the changes to DOC 7-11-LS-25. The ITS SR 3.6.3.6 and SR 3.6.3.7 and associated JFD's have been revisec ss discussed at the meeting. This supplemental response supersedes the response to Comment Number 3.6.3-24. The proposed change to allow the 36-inch shutdown purge and exhaust penetrations to be isolated by either the shutdown purge valves or a combination of valves and blank flanges is acceptable for the following reasons:

1. The original serveillance requirements for the large,36 inch containment shutdown purge isolation valves (CTS 4.6.1.7.2) included an extended surveillance interval that was approved by the NRC staff provided blank flanges were employed. The Westinghouse STS (NUREG-0452) for containment ventilation valves required a 6-month surveillance (on a STAGGERED TEST BASIS) to determine leakage rate of these 36 inch shutdown purge valves. The extended test interval applied to Wolf Creek and Callaway was a 24-month leakage test requirement based on the use of a combination of closed valves and blank flanges.
2. The improved STS do not address the use of blank flanges on containment shutdown purge isolation valves. Improved STS apply to the use of isolation valves alone and require more frequent testing (184 days) than the current TS frequency of 24 months when blank flanges are used.

Improved STS also require the large purge isolation valves to be sealed closed, since they are not qualified to be open during MODES 1 through 4. The changes proposed by Callaway and Wolf Creek would allow the use of either the requirements from current TS or the requirements from the improved STS for the large containment purge isolation valves. Applying either the current licensing basis requirements for these valves or the generic requirements from the improved STS provides operational flexibility and outage flexibility based on plant design with no adverse impact on plant safety ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-12 Encl. 3A 7, 8 Encl. 3B 5 Encl. 4 1,33,34,48,49 Encl. 5A 3.6-17, 3.6-18 ' ncl. 5B B 3.6-26, B 3.6-27, B 3.6-28 Encl. 6A 3, 4 Encl. 6B 2, 3

CONTAINMENT SYSTEMS (New With one or more penetration flow paths with two isolation valves inoperable " 1 7-0$ W P for any reason other than leakage, isolate the affected penetration flow path s JhMm within 1 hour by use of at least one closed and de-activated automatic valve, I closed manual or blind flange, otherwise be in HOT STANDBY within the next (6 hours and COLD SHUTDOWN within the next 30 hours. S_URVEILLANCE REQUIREMENTS closcA M b ach 36-ench 4.6.1.7.1 E ntainment shutdowr purge supply and exhaust isolation @~f491DF _g,g,g valve (s)* shall be venfi tank 11anged and(o'rJ!!osed at least once per 31 days. ' Note (from ITS SR 3.6.3.1): Not required for one purge valve in a penetration path) gj g j g g M34) 'yrhile in Action c.f_ "'"~ y p; p-S,1D-lqs.a.2-4_l 4.6.1.7.2}EactL containment shutdown purge supply and exhaust isolation rg 7 4 g g,,, s A valvehnd{ofts associated blank flange shall be leak tested at least once per

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{ control ALARA or air quality considerations for personnelclosed ex L M1.&28 3 g,3. g j entry, or for surveillances that require that valves to be open at least once peh ad rv g 4 3 3. m.,,i 4 6.1.7.4 Atleas once r 3 men *h:684 days AND within 92 days after opening] $7-06-L5-113 fthe valv@each -. tainment minspurge supply and exhaust isolation valve with Ng a 6.'b2.1 l resilient materialfsealPshall be demonstrated OPERABLE by venfying that the measured leakage ratedtet: t' n 0.05 Lae'h:n;'r?* r".:^"!oP W M N k a (W9ptWent LysGuggef 8atre Testipg'Pfogram.) ~ jf{, M XM + isolation devices in high radiation areas may be verified by use of) d "% % i7[ 31 administrative meanys

  • Except valves and flanges which are located inside containment. These valves shall be venfied to be closed wetMhew@ lank flanges installed prior to 37QLS-25b entry into MODE 4 following each COLD SHUTDOWN (if not completed in the]

[ previous 92 days.) n / Msurye115ance not ired [n tMne pathisTsolad Q 3 6.3-2.1 } ( s%ian nge. f f e / ~ wHb he bidd Etoge. tolled, and followvn3 each re mstalMien G 'b 'Z4 7-t c4 the bivnd -flage., or eac.h containment s6ketoe pp '$n [ n MP$ MLcabaut vahr. shMt be. leak te-AcA cd le26f on< a-Q 3.h.3-2.1 per' ever3 IS4 cys wi+h the. blwid fNp rernov=<t,auJ. J.

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W !"* 7-17-M WOLF CREEK UNIT 1 3/4 6-12 Amendment No. 89. 97 n.3-21] Mark-up of CTS 3N.6 5/1587

CHANGE NUMBER HSliC DESCRIPTION l l 7 05 A Consistent with NUREG-1431 an action is added for two valves inoperable in one penetration flow path. The change is administrative sitxe the current TS would have relied on LC0 3.0.3 which has essentially the same requirements. 7 06 LS 11 Consistent with NUREG 1431 the leakage rate testing frequency for containment isolation valves with resilient l seals is revised to 184 days based on the NRC resolution l of Hulti Plant Action No. B 20. " Containment Leakage Due to Seal Deterioration "/fis? g on a s agger est D is is3 s fnoTo r requ nt also na f i rfo lea test in 92 ays of nin he i valv o reco ze tha ycling e valv ould troducy a itional al degr ation nd that ccurring to af V alve tha hasnotieenope . r@s err 3A-Q 03*O'N 7-07 LG Consistent with NUREG 1431 the leakage rate test I acceptance criterion for containment isolation valves with resilient seals is moved to the Bases. This criterion is appropriately moved to the Bases as this leak rate does t not directly tie to safety but indicates degradation of the resilient seals. ITS SR 3.6.1.1 is the leak rate l which ties directly to the safety analysis.[ ] l 4934 3-G 3 7-08 X Th fisn ds a day o veri mini urge valve 33 .crosed cept aut rea s. sa a e i st nt uir hat i pprop ' ate f con nment a usest r sA ic-1sola n valv nd cone ent w NURE 143. 7 09 LG The descriptive details regarding the valve size and l isolation requirements for the LCO have been moved to the l ITS3.6.3 Bases.[eW3A.]. { q a.r.. b -32.] 7 10 LS 9 % Note adde to el ify t t leak ge r te tes inMNEN d no equir for tai pur val s wit resilie t p O Mb% eals n the netr on f pat is is ted by leak PP see cmvuss bpm

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, equir nt is ens con nment akage tegri j dur' g an iden and t reby li t acc nt / ons ces. solat of th ow p with leak he flow [ path gi teJ bli flang ccompi es th safet funct1 andj additi al leak esting the va es in unnecessary 7 7-11 LS 25 Removes the requirement from CTS 3.6.1.7 surveillance requirements to blank flange the containment shutdown WCGS-Description ofChanges to CTS 3N.6 7 S/158 7 l L

INSERT 3A-7 This change moves details to the Bases that are not required to be in Technical Specifications to protect the health and safety of the public. Consistent with the content of NUREG-1431, Rev. 1, descriptive details regarding valve size are moved to the Bases Background section and OPERABILITY details are moved to the Bases LC0 section. INSERT 3A-7a CTS 3.6.1.7, Containment Ventilation System, requires the containment 7 shutoown purge supply and exhaust valves to be closed and blank flanged. In the event one containment isolation valve in one or more penetration flow paths is inoperable, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed and deactivated power-operated containment isolation valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured. The requirement to blank flange the containment shutdown purge supply and exhaust isolation valves was removed because these valves are isolation barriers that meet this criterion. l A provision "if not performed within the previous 92 days" is added to the footnote to CTS Surveillance Requirement 4.6.1.7.1. The footnote allows the containment shutdown peruge supply and exhaust valves and flanges, located inside containment, to verified closed (or flanges installed) prior to entering MODE 4 following each cold shutdown. The I NUREG - 1431 provision "if not performed within the previous 92 days" is based on engineering judgement and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility. jo34,3,gg j [Therevis surve)flance terval e ension (1 days) des ibed in 7-06 i LS-11 ove). modif by the ddition o and withi 92 days ter ope ng th alve." 'he like ood of 1 age is fu her red d by I opti the surv 11ance sting reg rements of REG-143 for se val with r lient s ts when r ing on th valves a ne t rovide i huerequi isolat funtion. l l The proposed changes permit using either current TS requirements or NUREG 1431. Rev.1. requirements for the shutdown purge supply and exhaust valves.

INSERT 3A-7 i This change moves details to the Bases that are not required to be in Technical Specifications to protect the health and safety of the public. Consistent with the content of NUREG-1431. Rev.1 descriptive details regarding valve size are moved to the Bases Background section and OPERABILITY details are moved to the Bases LCO section. i INSERT 3A-7a CTS 3.6.1.7 Containment Ventilation System, requires the containment shutdown purge supply and exhaust valves to be closed and blank flanged. In the event one containment isolation valve in one or more penetration flow paths is inoperable, the affected penetration flow path must be l isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed and deactivated power-operated containment isolation valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured. The requirement to blank flange the containment shutdown purge supply and exhaust isolation valves was removed because these valves are isolation barriers that meet this criterion. A provision "if not performed within the previous 92 days" is added to the footnote to CTS Surveillance Requirement 4.6.1.7.1. The footnote allows the containment shutdown peruge supply and exhaust valves and flanges, located inside containment, to verified closed (or flanges installed) prior to entering MODE 4 following each cold shutdown. The NUREG ' 1431 provision "if not performed within the previous 92 days" is based on engineering judgement and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility, jo343,g} [fherevis surve ance terval e ension (1 days) des ibed in 7-06 LS-11 ove) modif by the ddition o 'and withi 92 days ter i ope ng th alve." he like ood of 1 age is fu her red d by opti the surv llance-sting req 'rements of REG-143 for se val with r lient ts when r ing on th valves a ne t rovide h4e requi isolat funtion. The proposed changes permit using either current TS requirements or NUREG 1431 Rev.1 requirements for the shutdown purge supply and ( exhaust valves. i f a i l

f Cl%NGE i_ NulEER NSHC DESCRIPTION j 7-rf q LusECF 3A*S*3--l4#' 3~2'd ~ pu_rge supply and exhaust valvesf. nd r 'ises Ngg j { fo si (FwSenT 3A-Q-W. ' A~ lusecran-s p o s. 3. n) m.M 4 3.63-24J 2 8 01 LG Consistent with NUREG 1431 the LCO references to suction i flowpath and manual transfer of suction to containment sump have been deleted. These details are included within the operability requirement.s of the Containment Spray System (as required by SR 4.6.2.1 and as further described in the Bases). There is no technical change resulting from this deletion. 8 02 A Consistent with NLREG 1431 the action statement is revised by replacing the reference to restoring the Containment Spray System to operability within 48 hours or be in cold shutdown within the following 30 hours, with the requirement to be in cold shutdown within 78 hours. The time allowed to be in cold shutdown has not changed. The requirements of the action statement have also not changed, since as discussed in the Bases, the extended interval to reach cold shutdown allows 48 hours for restoration of the system operability and an additional 36 hours to achieve cold shutdown. 8 03 TR-1 The actuation surveillance is revised consistent with I NUREG-1431 to clarify that an actual signal as well as a _ test signal may be used to verify actuation. hERT 54-8cd - L The LCOs for containment spray system and containment +23.6. 6-al 8 04 A coolers are combined into LCO 3.6.6 to be consistent with NUREG 1431. 8 05 LS 12 Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 8 06 LG The details on flow testing for nozzle obstructions and specific actuation signals that apply for automatic actuations are moved to the Bases. This is acceptable as the. requirement to test remains in the Technical Specifications and this level of detail is not contained in NUREG.1431 specifications. 8 07 Not Used. 8 08 LG The specific 3mmo dischatge aressure value would be moved to t dfr;i : 0;;ti ; pr ;r = t :5 fte,J..Jt. CO-449t-lTS SR 3.6..G., 4 BIMuc.S IMSERT.3A Ob - - ~ ~ Lfos.k6.sl WCGS-Descr4 tion ofChanges to CTS 3N.6 8 5/15AF7

l INSERT 3A-8e 0 3.6.3-21 7-17 M CTS SR 4.6.1.7.2 is revised to include an additional requirement for the containment shutdown purge supply and j exhaust valves to be leak tested at least once per every 184 days with the blind flange removed and within 92 days after opening the valve with the blind flange removed. CTS SR 4.6.1.7.2 currently requires the containment shutdown i l purge valves and associated blind flange be tested on a 24 month frequency. The leakage rate testing criteria for containment isolation valves with resilient seals, with the blind flange removed, is revise to 184 days based on the NRC resolution of Multi Plant Action No. B-20 and is consistent with NUREG-1431. This change is considered a i more restrictive change, since the surveillance frequency i has been reduced from 24 months to 184 days, even though { the blind flanges are not installed. i i l l l

CONVERSION COMPARISON h8LE - CURRENT TS 3/4.6 Page 5 of 12 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 07 06 The leakage rate testing frequency for containment No see 11-13 LS-Yes Yes Yes LS-11 isolation valves with resilien_t seals is revised to 184 22 days, nd i as est s is 1 yQ 3.6.5 -L7. j equ r remen s al o per a age t wi n 92 s of i y = 07 07 The leakage rate test acceptance criteria for containment No - criteria Yes Yes Yes LG isolation valves with resilient seals is moved to the already moved from Bases. CTS. 07 08 FAdds ' ~1 to a ayglanee-to TS al a No - CPSES does not Yes Yes - JP v y cl e of t ini-vM is have any closure { Q 3.r. 3 - 13 restrictions on Ls-26 161 sert 38-5b tvuinbhey cJs) this valves. 07-09 Details regarding the valve size and isolation requirements No - CTS does not No - This detail is Yes Yes LG have been moved to the ITS bases contain this not in the current requirement TS. 07-10 A note is added to clarify that leakage rate testing is not No - CTS does not Yes LS 9 required for containment purge valves with resilient seals contain this when the penetration flow path is isolated by a leak tested requirement { Q16.3-2I q blank flange. ~ 07 11 Removes the requirement to blank flange the containment No - That No - That Yes Yes LS 25 shutdown purge supply and exhaust isolation valves, requirement was not requirement was not frevises su~ lanc ir ver ttation part of CTS. part of CTS. l Q 3.6.3 2.1] thje val nd fla s for i de teentet nt. 08 01 The LCO references to suction flowpath and manual transfer Yes Yes Yes Yes LG of suction to containment sump have been deleted. These details are included within the operability requirements of the Containment Spray System as described in the Bases. ~ -t5 - HssKr 36 l~q 34.3 -3s l a_ _- - {ord-- iws,ent as-sg _,4, WCGS-Conversion Conparison Tame-CTS 3M.6 5/1587 i4sent 3B-5 c]-\\ o 3.6.3-2.1 l il

n. l t i INSERT 3B-Sc-0 3.6.3-21' _ TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DI*BLO CANYON COMMANCHE PEAK WOLF CREEK' CALLAWAY-07-17 CTS SR 4.6.1.7.2 is revised to include'an No - not in No - not.in Yes Yes M additional requirement for the containment. CTS CTS I shutdown purge supply and exhaust valves to be leak tested at least once per every 184 days with the blind flange. removed and within 92 days after opening the valve with i the blind flange remcved. L P j e i i ? I f f I k i I l

NO SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC) CONTENTS l I. Organization........................................ 3 1 II. Description of NSHC Evaluations...................... 4 III. Generic No Significant Hazards Considerations "A". Admi ni strati ve Changes......................... 6 "R" Relocated Technical Speci fications............. 8 1 "LG" - Less Restrictive (Moving Information Out of the Technical Speci fications)................... 11 "M" More Restrictive Requirements.................. 13 i IV. Specific No Significant Hazards Considerations "LS" LS 1................................................ 16 LS 2................................................ J _LAwA 4366-4l LS-3................................................ 20 ~ LS 4................................................ 22 LS 5................................................ 24 i LS 6................................................ 26 LS 7................................................ 28 a s.'S -58 l LS 8................................. d.9................................

n. *..ff...b

....@/~ gg,ge, ( j .. 30 LS 10.......................................... N4M5 erd WSEKT 4 t LS 11............................................... 35 LS 12.................................... Not Appl i cabl e LS 13............................................... 3 7 LS 14.................................... Not Appl i cabl e LS - 15.................................... Not Appl i cabl e LS - 16.................................... Not Appl i cabl e l LS 17............................................... 39 l LS 18............................................... 42 i LS 19............................................... 44 l LS 20..........................................Not Used l LS 21..........................................Not Used LS 22.................................... Not Appl i cabl e LS-23............................................... 46 LS 24..........................................Not Used LS 25............................................... 48 LS N l o 3.r..S-4 ] %g 's-n mga LS-29 [ c 3,G,.3-g.S} WCGS-NSHCs - CTS 3M.6 1 5/15M7

De,\\de. {G 3.l-3 -2 \\ IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 9 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WIDlIN THE TECHNICAL SPECIFICATION 4 The required action for a containment ventilation isolation valv not within its leakage limit is revised to allow the penetration to be isolat using a closed and deactivated automatic valve, a closed manual valve or a blan flange and does not require the isolation valve to be restored to operable stat s. This is an option not explicitly available in the current TS. The Completi Time of 24 hours remains the same as in the current TS. If valves with resilient eals are used to isolate the flow path, the leak rate of these valves must be v ified at least every 92 days. If a leak tested blind flange is used to isola e the penetration flow path, the valves with resilient seals whose flow is isola by the blank flange are not required to be leak rate tested. Isolation of the low path with a leak tested blank flange provides the required leak barrier d additional leak testing of the valves in the flow path is redundant and unnece ary. This proposed TS change has been evaluated a it has been determined that it involves no significant hazards considerati This determination has been performed in accordance with the criteria et forth in 10 CFR 50.92(c) as quoted below: "The Comission may make a fin determination, pursuant to the procedures in 50.91 that a proposed amen nt to an operating license for a facility licensed under 50.21 (b) or 0.22 or for a testing facility involves no significant hazards consid ration, if operatior, of the facility in accordance with the proposed amen t would not: 1. Involve a signi cant increase in the probability or consequences of an accident previ usly evaluated; or 2. Create the assibility of a new or different kind of accident from any accident eviously evaluated; or 3. Involv a significant reduction in a margin of safety. " The following ev uation is provided for the three categories of the significant hazards consid ation standards: 1. Does he change involve a significant increase in the probability or co equences of an accident previously evaluated? The prpposed change does not result in any hardware changes. The role of these valves during an accident is to isolate containment. and thereby limit accident consequences. The proposed actions will not allow continuous operation such that containment leakage after an accident will exceed assumed values. With the associated penetrations isolated per the proposed Action requirements, no exident WCGS-NSHCs - CTS 3N.6 33 S/15/97

Q3. 6.3-2 t } I)Ak IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS 9 (continued) as a result of the leaking valve is credible. Further, with t ine isolated it cannot contribute to the consequences of a previously evaluat accident. Therefore, this change will not involve a significant incre e in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a or different kind of accident from any accident previously evaluated? The proposed change does not necessitate a phys al alteration of the plant (no new or different type of equipment will be instal ed) or changes in parameters governing normal plant operation. Thus, this change s not create the possibility of a new or different kind of accident from any a ident previously evaluated. 3. Does this change involve a si ificant reduction in a margin of safety? ^ The proposed change is acceptab since the isolated penetration provides protection equivalent to restoring the va e to operable status. Providing the option to isolate the penetration will minimize he potential for plant transients that could occur during a shutdown required by TS f the isolation valve could not be restored to operable status. In addition, isolation of the line (in accordance with the proposed Required Action) ensu s that leakage through the associated penetration is within limits. As such, an reduction in a margin of safety will be insignificant and offset by the benefit gai through avoiding an unnecessary plant transient. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on - above evaluation, it is concluded that the activities associated with NSHC "LS-9" esulting from the conversion to the improved TS format satisfy the no signif cant hazards consideration standards of 10 CFR 50.92(c): and accordingly, a no sig ficant hazards consideration finding is justified. WCGS-NSHCs - CTS 3N.6 34 5/158 7

IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-25 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS CTS 3.6.1.7. Containment Ventilation System, requires the containment shutdown purge supply and exhaust valves to be closed and blank flanged. In the event one containment isolation valve in one or more penetration flow paths is inoperable, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de activated automatic containment isolation valve. a closed and deactivated power-operated containment isolation valve, a closed manual valve. a blind flange. and a check valve with flow through the valve secured. The requirement to blank flange the containment shutdown purge supply and exhaust [GIM M isolation valves was removed because these valves are isolation barriers that meet _ _ q this_ criterion. This chance is consistent with NUREG 1431.ftn c4 ctim is9th " ( 2 k M,,* tg.+estp 53 densm myd cu3se mu,3.er, um optcA fsyt mese. v4 A provision "if not performed within the previou's 92 days" is added to the footnote to CTS Surveillance Requirement 4.6.1.7.1. The footnote allows the containment shutdown peruge supply and exhaust valves and flanges, located inside containment. to verified closed (or flanges installed) prior to entering H0DE 4 following each cold shutdown. The NUREG 1431 provision "if not performed within the previous 92 days" is based on engineering judgement and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility. This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below: "The Comission may make a final determination, pursuant to thl procedures in 50.91, that a proposed amendment to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no significant hazards consideration. if operation of the fac'.11ty in accordance with the proposed amendment would not: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2. Create the possibility or a new or different kind of accident form any previoulsy evaluated; or 3. Involve a significant reduction in a margin of safety. ' The following evaluation is provided for the three categories of the significant hazards consideration standards: WCGS-NSHCs - CTS 3M.6 48 5/15/97

l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-25 (continued) 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes do not result in any hardware changes. The role of these containment shutdown purge valves or blank flanges during an accident is to isolate containment, and thereby limit accident consequences. The proposed actions will not allow continuous operation such that containment leakage after an accident will exceed assumed values. With the associated penetrations isolated and verified per the proposed Action / Surveillance requirements, no accident as a result of the leakage valve credible. Further, with the line isolated it cannot contribute to the consequences of a previously evaluated accident. Therefore. this change will not involve a significant increase in the probability or consequences of an accident _ greviously evaluated.j 2. .Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The prcoosed changes do not necessitate a physical alteration of the plant (no new or diff6 rent type of equipment will be installed) or changes in parameters governing normal plant operation. Thus, this change does not create the possibility of a new or differEnt kind of accident from any accident previously evaluated. 3. Does P.his change involve a significant reduction in a margin or safety? The proposed changes are acceptable since isolating the penetration with a purge valve provides protection equivalent to isolating the penetration with a blank flange. Verifying the valves are closed or blank flanges installed prior to entry into MODE 4 fo11 ewing each COLD SHUTDOWN "if not performed in previous 92 days" for valves and flanges located inside containment is acceptable based on the inaccessibility of the isolation devices and the administrative controls that will ensure the isolation devices are in their correct position. In addition, the isolation of the lina (in accordance with the proposed Required Action) ensures that leakage through the associated penetration is within limits. As such, any reduction in a margin of safety will be insignificant and offset by the benefit gained through avoiding an unecessary plant transient. NO SIGhlFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LS-25" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c): and accoringly, a no significant hazards consideration finding is justified. Tb IAe ood. of akap. 4 3 adept' e w e' u. r e < 4cd reg eds c4 M - 14 U, 1,fw the atvu Jt esihed @ M S Zlj ~ rsly vai alme. b p< ida h is e- $W l WCGS-NSHCs - CTS 3M.6 49 5A587

= _. - Contairment isolation Valves (%;p.;.. i;. 0;ta^ ;peric !;; Ce.. den;;r a.d ";;l' pggggggl 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY \\asc.11s\\ SR 3.6.3.6 Perf6tu[LTeakagelate_ testing;for containment 2 ins;6F184 shistdown purge valveswith resilient sealt@ l ~~ c and nucid,d r tC ; ;,=..; J'; cr$rf - Tser-.w.pny--) e 1 {434.S-241 dim fMc3 (gypent @JW iagle Auf // 8 &g u,g g l Ly. c;;r..;;4.. Or pr^n; Mr.;;; cra;'a m velV; t;;t;bl; during ep;.; tier, thr; ugh u.; e,1;t; cyci; cf full tr;;;1. v.d Following:gesh gggypsg

rify ach chid v;1V; racir.; ci;;;d wtan refpstallagen the dif';. ;..ti;l pr;;;ur; in th; dirati;n of7the.bljnd of ;w i; s [1.23 p;id cr.d ep;n; when th; fiange differential pr;;;ur; in th; diration of M

.,...... r,s.,. n... ce..n,., .n... _s y u. y. 1 q u.s.a \\ =- - - - Hsm - - - - - - - - l IJlfd 1 oniy vquired % be pea tif _.- ww.r un+Mnmen+ shutdoe i purge, valve. bhhd flanqcs art'. tdstalltd.. M 1 i f I 2 _..J-e i n, .re w=Je v (continued) WCGS-Mark-up ofNUREG-1431-ITS3.6 3.6 17 S/15/97

1 l Containment Isolation Valvis (M ~sphcric. ,__m____ __2 c.a _.~ _ _ e _ _ 2. _.. ..,,s.._,s gggggg ., r. ~. 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FRE0VENCY p----~_ ( m - _{w.- - -.med fov tve cemhthment skddeum.f 93 ',.3 21 } only r% uke A w we. psv-vrae._ w s e c_a._. ws.a w-4.sm3 sa ~~a. R 3.6.3.7

2. G.{.,'. Q--

f.~. g......... ) j \\ Th._s . ei. a... i. s_.. isi.la n ir. r. y 1a sh uta bee 2h,ncA ati fT pat -iniMicate 2 te ed ,a ggg iM Nc.M-Y.

j............,......

184 days Perform leakage rate testing for 4 % 6;19 7 containmentmini-purgeg{valveswithresilient ANQ seals. n cor neepInI t,opel l ( a R Tesj;$fng: P raV Within 92 days ~ P34.8-<-1 omd. shui.doton l'"r e. after opening the volve SR 3.6.3.8 Verify each automatic containment isolation 18 months valve that is not locked, sealed or otherwise pejisBi s secured in position, actuates to the isolation position on an actual or simulated actuation signal. [ Cycic cad weight or spring iceded check M.caths v;1ve not tcstabic during opcratica 18'PS1 [}Qs.6.o.2.} i m. _u....~-.,,..i.._._,.._,__,,..,,__.._, end verify coch check velvc rc ; ins closed kr. the differential pres urc in the directica of ficw is m [t.2) psid ;nd opens @ir, the diffcicatial picssurc in the dircction of ficw is 2 [1.2] psid and . re n, __a - gs.v; yasu. b@h3 L.0 2-], 3. 5.3.1h. "crify c;d [ ] inch can'ai.. cat purge [103 enths l ^ volv is bicdcd to rcstrict the valvc fica. EB-PS4 ee,n,w_ .r.n...., - g va,. (continued) WCGS. Mark-up ofNUREG.1431-ITS3.6 3.6 18 S/1587

Containment Isolation Valv s (".t,;p.;ri;. Si;t-;p.;ri;. I;; Oer.dcr.;;r ;r.d ^~;U i B 3.6.3 BASES SURVEILLANCE SR 3.6.3.4 REQUIREMENTS (continued) This SR requires verification that each contairment isolation manual valve and blind flange located inside containment agigg EtMLM,"ggljprj@e3gEng and required to be closed ~ during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside i of the contairment boundary is within design limits. For containment isolation valves inside containment, the Frequency of " prior to entering MODE 4 from NODE 5 if not performed within the previous 92 days" is appropriate since these containment 1 solation valves are operated under administrative controls and j the probability of their misaligrlent is low. The SR specifies that containment isolation valves that are open under administrative controls are not required to meet the SR during the time they are open.

3x
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M

. n.#81; f,@ F 3i~.h.;eim -O.%.m V . E;? i 2 f Vggr(BadlW~ 1 R E!BI O N E M s E se~ ot M. c 4 l ThisEINote IBlEtijnn~88HGB allows valves and blind flanges i located in high radiation areas to be verified closed by use of i administrative means. Allowing verification by administrative j means is considered acceptable, since access to these areas is l typically restricted during NODES 1, 2, 3, and 4. for ALARA i reasons. Therefore, the probability of misalignment of these contairunent isolation valves, once they have been verified to be in their proper position is small. l l SR 3.6.3.5 l Verifying that the isolation time of each p.:r egr;td ;..d __NS'> 3-II) automatic f3"2=icontainment isolation valve eufAtsdEg z--1 _ _. = - -._-E==diiic K41 ?_= 31s within Units 'l requ1rea to osmonstrate UPE(AB LEnf. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. -f The isolation time and Frequency of this SR are in accordance with the Inservice Testing Program. er ^2 d;y;.] SR"SiE3:6' [cp3.E.3 2.1 I a - = (continued) WCGS-Mark-ngp ofNUREG-1431 - Bases 3.6 8 3.6 26 5(158 7

1 e } l 1 Containment Isolation Valv s (,'/ ai ;ric. 2 N Suhets;-heric. I;; "ende,.;;r. ;nd "sel) L s.Aqc. misy' y +nts wwh a mzwnwm sit.w.bte t,.2.

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b 'E BASES SURVEILLANCE SR 3.6.3.6 (continued) Q 3.43-21 I j REQUIREMElES i t i i 4 i t i l I l l [ 3

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r...,._. a i . N P*.' g l re ? '"w c 4mia re -ti pe;itiv; ;1;;;r; in tra direct,i;n ;' '.'_-.;. ".i - cr.;ures i r u .<_<____<__....,..__.a.,.,.._.......~..ic~_ ___2 1 ,__,2. gota,,., pe 3s.

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r;tica c' th; ch;;k v;1v;; th;t ;r; tc;tr. tic irin; unit

_____7,... m,, ~_,..,,.~__,.n,.o _x n_ x__x,__ 2_.._ e_ ,_____>_._..a.<_.........m..~ s____..,__=r._._.x,__...,..,,, _..,,.. _ -...... n___ __.2 l T NF IiWI~}- ha' corvamis \\cobgs ralc for ihc. conthintnctit l shu%uan pw'$e. sun and uhawsHsolabo'n valus., tAen pressurited +o ,and induacA w% all Type. 4 SR 3.6.3.7, 3gg ,4,,A u is bs ihm.@ k. i hl 3 5tl i g A m_ Q l For containmen valves with resilient seals, additional i F leakage rate testing yond the test requirements 01' 10 CFR 50 Appendix J. ORD E B is required to ens,ure OPERABILIT). w m'in'i pweg<. amd. shuldown pw'St a s.6,.3

2. )

(continued) i WCGS-Mark-up ofNUREG-1431 - Bases 3.6 B 3.6 27 5(15/97 1

1 Containment Isolation Valv;s (ALWaric, SdcMW,cric. Icc Cor.dcr.:;cr, cr.d ::JeB B 3.6.3 BASES SURVEILLANCE SR 3.6.3.7 (continued) REQUIREMENTS Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types. Based on this observation and the importance of maintaining this penetration leak tight (due to the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of)(ulti M)ng Action N6 B 20, " Containment Leakage Due to Seal Deterioration" (Ref. @f 'Opar,o-2 ) Additionally, this SR must be performed within 92 days after opening the valve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a Ya8/8.*Ma*/r*'d'a"gTANNInd @gitp@ prudent measure after a valve has been ooened. t [ I y erg s s t ne on fl -pat ist;i lit % 3 M by,a g ak-tes fla p2.c s.z[ ] SR 3.6.3.8 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a DBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 1B month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient 11 the Surveillance were performed withthe reactor at power. Operating experience has shown that these components usually pass this Surveillance when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. kbc SR. 6 ~s.4;6ed b3 %t w atc2 Q h t h. s R W.. g <a h d. ~* to b. performed. 6 +ha centaih raent shdA*wn f"$* val **' N **- 1 (4 @xeted blih4 fl>ny is removedj [The Lesbred. teekey rate. for ex.h c n+> n-s..,+ ant pqc W3 a.d.e hd [o2.4. 3-3i ) . idiin v4)vs w;ns resihewt seab i.tc..+bm o.es t.a. when pn 3,.u.n.us L +o R.. f "(Ths c.mb;nad lema rw.te. Gv th4. c,ntai,n m e.wr s Mta.wn cwd ahnst is tation vatw.3, when pres.wiseA-h,1%.,,na,a[c1ge. 9p-p 3.c 3 21) www 6 (e.. h.Go u. continued) ( <ui tvoe B % A. c o.n -tratie,ns WCGS-Mark-up ofNUREG-1431 - Bases 3.6 B 3.6 2B S/1587

CHANGE NUlBER JUSTIFICATION repositioning, the periodic reverification should only be a verification of the administrative control that ensures that the l component remains in the required state. It isould be appropriate to remove the lock, seal, or other means of securing the component solely to perform an active verification of the required state. iga.G.3-ti) ---m 3.6 12 st wi

3. :3.8 h prov st act ion sitionj st is tr red fo valves ocked al

, or o tw1 e1, / red thei requi posit unde adai trati his nge ld p de tha isola ti testi is t ired aut ic neent solat valv t aref ocked

aled, othe sec in heir i

posifion r adminis ative c rol. t*W S$ed-516 3 M l k[Ac1 3.6 13 y1 ei o S3X6.3.7 t woul low t 1 age et r co@efnment val wit sil sea s ed the rati ow is i ated l a te b1 flanc b fla prov sJta-1 red ~ 1ati and addi ional sting ofd he va es ti k( c.-p.ary& Tai,44.M Applic2Wa tm. tJMcv nsk.15me conveieb s a w..u.re. sm). 3.6 14 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 6B). 3.6 15 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). 3.6 16 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). 3.6 17 Not Applicable to Wolf Creek. See Conversion Comparison Table (Enclosure 68). 3.6 18 Consistent with CTS 4.6.1.7.2, SR 3.6.3.6 is added to perforn leakage rate testing for containment statdown purge valves and associated blank flanges, once per 24 months when the blind flange is installe$following each reinstallation of the blank - ng v f1 i ed. is SR recognizes that cycling the valve could additional seal degradation beyond that occurring to a valve that has not been opened, and allows the use of a leak rate tested blank flange to isolate the penetration flow path. (chpge,Jrtopststenty 53J:ti.31 Tor tnA.contajsseht-nV_ l WCGS-DifferencesfromNUJtEG-1431-ITS 3.6 3 5/15g7 \\ k A M 6, adAed ic AM c2Ye. -kA-lT.$ SR 3D-

c. song p a.% g,.,%ea ww. + c w -t awara.e pqc. v=We.s dvnd By mu ht.neA.

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i CHANGE MER JUSTIFICAT,1,G( p g, vel,ve g {4a6 3 z.1 ] 3.6 19 /'Cjo sist wi CT .6.1 .4. SR .6.3.7 revi to k te ~ Aes 1-val s in Arda with Co g y ka ate ti rogr fte.- ing r te e_each (1 ays with_ 92_ aft _ openi the v ve.j The leak rate test acceptance criterion for containment isolation valves with resilient seals does not directly tie to safety but indicates degradation of the resilient seals. 3.6 20 Not used. 3.6 21 Consistent with CTS 4.6.2.3.b. SR 3.6.6.3 is being deleted and included as part of SR 3.6.6.7. The current licensing basis only requires for the flow rate to be tested as part of the actuation test every 18 months not the 31 days frequency required in ITS SR 3.6.6.3. 3.6-22 This change deletes the Note to ITS 3.6.3 Conditions A and B. This change is consistent with Change Number 3.6 23 since Condition C is not applicable to Wolf Creek. 3.6 23 This change deletes ITS 3.6.3 Condition C. This condition does not apply since Wolf Creek does not have any penetration flow paths where this condition is applicable. 4,y, g Ts sR s.G.s.7 fs men 6ed 4o speci$ &c. c 7+2ibent Wm'i rearge. N i vaives amd. shuthn pu.rge valvt.s con sidq WW c. 3

4.G.t. 7. 2. ud 4. G. t.7 4. A nate. is mAA.A. t, ind ed. ate. thaf con +ainrnent Ltd.g requireA to be perfermed -fe,r N.,

ITS r,r2. 3.c.3;7 si on - per v4Wes A h ass.<-iated bW f.E9 t.", re M 4in da. tTs sR. 3.c. 3, c rgm ~ co I le:4 kage. raten tesiw,,3 4. h a.+ ooc.s h C A.B y are.inaialkA.. Leak 9 reshmg c4 h 4L..+Aaum p e y w h<d,. mesee'i>As. b.tuhMW on a 2A wn+b 4 ym{ c,,,,,W iAh CT.6, 4.G.I.*7. 2. WCGS-Dyferencesfrom NUREG-1431.ITS 3.6 4 5/15M7 l

CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431, SECTION 3.6 Page 2 of 4 TECH SPEC CHANGE APPLICABILITY NUPEER DESCRIPTION DIABLO CANYON COMANCE PEAK WOLF CREEK CALLAWAY 3.6-7 This change would revise SR 3.6.3.5 to delete the reference Yes Yes Yes Yes to verifying the isolation time of "each power operated" containment isolation valve and only re@ ire verification of each " automatic. isolation valve._" This_ change is in M GS6S-61 accordance with TSTF-46 'O p=_ e W est e__ta p

  • 3.6-8 This change would revises the cospletion time for the Yes Yes No - CTS has I hour No - Cl3 has I hour restoration of containment pressure from I hour to [8]

completion time. completion time. hours. The [8] hour coupletion time is consistent with the current TS. 3.6 9 These portions of the specification de not apply since a No Yes No No containment cooling system is not part of the CPSES plant design. 3.6 10 This change would replace the Chemical Additive Tank volume Yes Yes No - CTS in gallons No - Callaway does not have this limits in gallons with tank level limits in percent. system. 3.6-11 This change would provide that the Required Action to Yes Yes Yes Yes periodically verify the affected penetration flow path is isolated does not apply to manual valves and blind flanges that are locked. sealed, or otherwise secured since these were verified to be in the correct position prior to locking, sealing, or securing. 3.6 12 Consistent with SR 3.6.3.8. this change would provide that Yes Yes Yes Yes isolation time testing is not required for automatic containment isolation valves that are locked sealed, or otherwise secured in their required position under administrative control. {Ws d5 Je r p l q 1 5,9 3 } 3.6-13 A clarifying note is added to SR 3.6.3.7 that would allow Yes Yes that leakage rate testing for containment purge valves with resilient seals is not required when the penetration flow path is isolated by a leak tested blank flange. SMSR7 i WCGS-Conversion Congparison Table-ITS3.6

CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431, SECTION 3.6 Page 3 of 4 TECH SPEC CHANGE APPLICABILITY NUPEER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.6-14 This change would incorporate DCPP specific operability Yes No No No criteria for containment fan cooler units required to meet design functional requirements. 3.6-15 SR 3.6.6.7 would be modified to reflect Callaway's plant No No No Yes specific requirements for cooling water automatic functions as well as containment cooler functions. 3.6-16 Consistent with the current TS, this specification has been No No No Yes modified to reflect the Callaway Recirculation Fluid pH Control System. 3.6-17 The ACTIONS and SR's of ITS 3.6.3 are modified to reflect Yes No No No the DCPP current TS allowance to open at one time any 2 of the 3 DBA qualified 48 inch purge supply and/or exhaust valves and 12 inch vacuum / pressure relief valve. 3.6-18 Consistent with CTS 4.6.1.7.4 SR 3.6.3.7 is being revised No CTS does not No - CTS does not Yes Yes i to cover the leak rate testing for the 36 inch containment contain 24 month have the 24 month purge valves and associated blank flanges, once per 24 requirement. frequency. months and following each reinstallation of the blank flange. 3.6-19 /fons~ ~ ' h CTS .1.7.4 3.6.3.7 1 isch No DCPP does not No - Not in CTS. Yes Y es over le ate tes of t ni-val witt. have mini purge (a34 3-7,( { esi sea after ng f sting eac 84 ys) system. with 2 days. er . ng the val -y 3.6-20 Not used. k N/A N/A N/A N/A 3.6-21 Consistent with Wolf Creek CTS 4.6.2.3.b SR 3.6.6.3 is No No Yes No being deleted and included as part of SR 3.6.6.7. The current licensing basis only requires for the flow rate to be tested as part of the actuation test every 18 months not the 31 day frequency required in ITS SR 3.6.6.3. j 3.(. 3.5 si wedihed h> pdy h anbihened, mM.-pug Q u a _ m + .,.i.t a,.., crs 4. m. u m...i .A.. WCGS-Conversion Conparken Table-ITS3.6, A ute a> akJ += s' Mche %h SQ a v& %-g&& St15Ap7 ' b h sh<th p-y vaMs A A e *dahd MwN & removsk..

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-24 APPLICABILITY: WC, CA REQUEST: DOC 7-11 LS-25 CTS 4.6.1.7.1 ITS SR 3.6.3.1 and Associated Bases CTS 4.6.1.7.1 verifies that the containment shutdown purge isolation valves are blank flanged and closed. CTS 4.6.1.7.1 is modified by DOC 7-11 LS 25 to verify that either the valve is closed or blank flanged. The proposed change is unacceptable to the staff based on the reasons stated in Comment Number 3.6.3-P.3 above. The staff considers this change to be a beyond scope of review item for this conversion. See Comment Number 3.6.3-25. Comment: Delete this change. FLOG RESPONSE: (original) Wolf Creek and Callaway continue to pursue this change. However, changes have been incorporated to clarify that the proposed changes represent either the requirements from current TS or requirements from the improved STS. The proposed change to allow the 36-inch shutdown purge and exhaust penetrations to be isolated by either the shutdown purge valves or a combination of valves and blank flanges is acceptable for the following reasons:

1. The original surveillance requirements for the large,36 inch containment shutdown purge isolation valves (CTS 4.6.1.7.2) included an extended surveillance interval that was approved by the NRC staff provided blank flanges were employed. The Westinghouse STS (NUREG-0452) for containment ventilation valves required a 6-month surveillance (on a STAGGERED TEST BASIS) to detennine leakage rate of these 36 inch shutdown purge valves. The extended test interval applied to Wolf Creek and Callaway was a 24-month leakage test requirement based on the use of a combination of closed valves and blank flanges.
2. The improved STS do not address the use of blank flanges on containment shutdown purge isolation valves. Improved STS apply to the use of isolation valves alone and require more frequent testing (184 days) than the current TS frequency of 24 months when blank flanges are used.

Improved STS also require the large purge isolation valves to be sealed closed, since they are not qualified to be open during MODES 1 through 4. The changes proposed by Callaway and Wolf Creek would allow the use of either the requirements from current TS or the requirements from the improved STS for the large containment purge isolation valves. Applying j either the current licensing basis requirements for these valves or the generic requirements from the improved STS provides operational flexibility and outage flexibility based on plant design with no adverse impact on plant safety.

i I l l B sed on th3 abov3 discussion, DOC 7-11 LS-25 cnd JFD 3.6-18, th3 proposed changes to CTS 4.6.1.7.1 and 4.6.1.7.2 that would allow the I purge and exhaust penetrations to be isolated by either a blank flange consistent with current TS or OPERABLE purge isolation valves l consistent with the improved STS are justified. DOC 7-11 LS-25 has been revised to incorporate additional justification to support testing the shutdown purge isolation valves with or without blank flanges installed. The changes incorporated in response to this comment also render the proposed ITS revisions within the scope of NRC review. Also, see response to Comment Number 3.6.3-23. FLOG RESPONSE: (revised) This response is superseded by the response to Comment Number 3.6.3-21. 1 ATTACHED PAGES: See the attached pages in response to Comment Number 3.6.3-21. i i l l l i

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-28 APPLICABILITY: DC, CP, WC, CA l REQUEST: DOC 1-01 LG CTS 3.6.1.1 ACTIONS CTS 4.6.1.1.a ITS 3.6.3 ACTIONS l ITS SR 3.6.3.3, SR 3.6.3.4 and Associated Bases CTS 4.6.1.1.a verifies that all penetrations not capable of being closed by OPERABLE automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions. The corresponding ITS SRs for this CTS surveillance are ITS SR 3.6.3.3 for valves outside containment and ITS SR 3.6.3.4 for valves inside containment. IF CTS 4.6.1.1.a cannot be met, the ACTIONS of CTS 3.6.1.1 are entered which require restoration of valve OPERABILITY within 1 hour or shutdown within the following 36 hours. If ITS SR 3.6.3.3 or ITS SR 3.6.3.4 cannot be met, the ACTIONS of ITS 3.6.3 are entered which allows for one valve inoperable between 4 hours and 72 hours depending on the type of penetration to restore valve OPERABILITY before shutdown commences. This Less Restrictive change to the CTS is not justified. Comment: Revise the CTS markup to show this Less Restrictive change and provide the appropriate discussions and justifications. FLOG RESPONSE: (original) Diablo Canyon, Commanche Peak, Wolf Creek, and Callaway have evaluated this issue and have concluded that no change in requirements occurred, the content of CTS SR 4.6.1.1.a was moved to ITS SR 3.6.3.3 and ITS SR 3.6.3.4 with the required action time being moved to ITS LCO 3.6.3 ACTION B (see DOC 01-02-A). Additionally, some implicit valve OPERABILITY aspects of CTS SR 4.6.1.1.a were combined with CTS LCO 3.6.3 ACTION and are now shown as ITS LCO 3.6.3 ACTION A, B and C for DCPP. CTS SR 4.6.1.1.a was written to provide assurance that "all penetrations not capable of being closed. are secured." Containment OPERABILITY is associated with penetration flow paths per the CTS Bases 3/4.6.1.1 which states " CONTAINMENT INTEGRITt' ensures that releases.. will be restricted to those leakage paths.. assumed in the safety analysis." The flow path (penetration) must be unsecured for the condition of CTS SR 4.6.1.1.a to not be met. Under CTS LCO 3.6.3 - ACTION. one inoperable containment isolation valve (a valve unsecured /out of position for a penetration "not capable of being closed during an accident") wv;ld provide 4 hours to restore the valve or secure the flow path. This was not changed under ITS 3.6.3 l ACTION A. One " penetration" not mechng the conditions of CTS SR 4.6.1.1.a (two valves unsecured /out of position in the same flow path) l wouH provide one hour to secure one valve closed in order to restore i containment OPERABILITY. This was also retained under ITS 3.6.3 ACTIONS B. DOC 01-02-A will be revised to read " Conditions A, B, and C and Surveillance Requirements (SR) 3.6.3.3 and SR 3.6.3.4.' l l l

FLOG RESPONSE: (supplement) The original response provided for this comment continues to reflect the position of the FLOG members and is the understanding being used in the implementation of these specifications. The changes are still considered to be administrative. After discussion with the NRC staff and to facilitate the conversion review, an LS DOC and its associated NSHC are being provided. ATTACF#f' sGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-1 Encl.3A 1 Encl. 3B 1 Encl. 4 1, new LS-10 P 1 1 r

Q3,g,0 3 ) 3/4.6 CONTAINMENT SYSTEMS o 3/4.6.1 P"^9Y CONTAINMENT .pr gg,q CONTAINMENT-INTEGRITV LIMITING CONDITION FOR OPERATION 3.6.1.1 ' r r / CO"^ "".'EF" '"TEGP'"(C' ontainment]shall be @PERABLE) g= - q g, g,,, q ~ APPLICABILITY: MODES 1,2,3, and 4. ACTION '?!theu! ;"rr; CO"^ *"?EF"' '"TEGP'" rette e CONTAINME" '"TEGP'"

1. g=

4 3,g,g

}

(With Containment inoperable. restore containment to OPERABLE statuWwithin 1 hour or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. SURVEILI.ANCE REQUIREMENTS ho2. 13-MG3 6.3 -Zed 4.6.1.1 P"rry CONT ^""'CF '"EGP'"[ Containment)shall be demostrated l 141 %" ~jg3,g,g_g} (DPERABLE)

a. hat least once per 31 days by verifying that all penetrations not qgg7 capable of being closed by OPERABLE containment automatic isolation 71

~ C02-A - ' valves and required to be closed during accident conditions are - ~ ~ closed by valves, blind flanges, or deactivated automatic valves Q44-1.,S-1M] except ofCyalves that are open under administrative control as permitted by)} y py secured in their positionsfor check valve with flow through the valve secured ( L,,,,aj Specification 3.6.3;

b. By verifying that each containment air lock is in compliance with the M T.D$ @n a$

M requirements of Specification 3.6.1.3; NWe

c. By performing containment leakage rate testing in accordance with

}*%01{gy" the Containment Leakage Rate Testing Program of Specification ~~' 6.8.4.l; and

d. By verifying containment structuralintegnty in accordance with the Containment Tendon Sunreillance Program of Specification 6.8.5.c.
  • Except vatves, blind flanges, and deactivated automatic valves which are located inside the containment nr.d :: '^^4 hall be venfied closed dunne "d, ::c'rd, Or Serre10:- u'ed

" te c'errd prFr-These penetrations each@rlor to entering MODE 4 from) COLD SHUTDOWN except that such prification need not be phta.i4 more often than once per 92 days. m f' Penetrations that are isolated in the closed position by isolation devices that arf locked, sealed or otherwise secured may be verified by use of administrative means. " Isolation devices in high radiation areas may be verified by use of yf144-1,S-17 j *N"*

  • administrative means.

WOLF CREEK - UNIT 1 3/4 6-1 Amendment No. 89,97 (Next page is 3/4 6-4) 1 Mark-up ofCTS3M.6 SMSM7 l

... _ -... -... _ _ = -.. - -INSERT 3/4 6-1 0 3.6.3-28 With one or more penetration flow paths (applicable to flow paths with two containment isolation valves) with one containment isolation valve inoperable (except for containment purge isolation valves with resilient seals that are inoperable due.to leakage not within limits).. isolate the affected penetration flow path.within 4 hours by use of at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve -secured: or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following-30 hours. l.

l DESCRIPTION OF CHANGES TO CURRENT TS Section 3/4.6 This enclosure contains a brief description / justification for each marked up change to current Technical Specifications. The changes are identified by change numbers contained in Enclosure 2 (Mark-up of current Technical Specifications). In addition the referenced No Significant Hazards Considerations (NSHCs) are contained in l. Only technical changes are discussed: administrative changes (i.e., format, presentation, and editorial changes) made to conform to the improved Technical Specifications are not discussed. For enclosures 3A. 3B, 4, 6A and 6B. l text in brackets "[ ]" indicates the information is plant specific and is not comon to all the Joint Licensing Subcommittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that location. CHANGE NUMBER 85HC DESCRIPTION l 1 01 .W A C f0NTE I is lo r a defin t i NURE T eme for t o abil y, i cl n er r pre us fo i he C E EGR defi io, are T is ang(Je seu ed t l pan base the tai nt L i cojistent ith 1431. lHSEEET 3A -la p,4,p. i l 1 02 Consistent with NUREG 1431 this surveillance requirement l 1.5-to to verify the affected penetration flow path is isolated / is now addressed by ITS 3.6.3 Containment Isolation Lp34.3-2.ej Valves. Cotitions A. [=d C) and Surveillance Requiremer,ts SR 3.6.8.3 nd SR 3.6.3.4. 14 33'28 I s, and,c) 6gsutr 3A - tgp 1 03 A The action statements are revised to incorporate the NUREG 1431 equal alternative isolation method of a " check valve with the flow through the valve secured." This isolation method is provided in NUREG 1431 and is considered an acceptable variation of a de activated automatic valve. 1 04 LS 1 A note is added to valve and blind flange surveillance requirements consistent with NUREG 1431. The note allows verification of valves, flanges and isolation devices located in high radiation areas to be verified by use of administrative means. This change is less restrictive in l that the current TS SR 4.6.1.1 has an exception to valves. l blind flanges, and deactivated automatic valves which are located inside containment and are locked, sealed. or otherwise secured in the closed position. These valves shall be verified closed during each COLD SHUTDNN. 2;p$ However, under the current TS. if an area outside of / WCGS-Description of Changes to CTS 3M.6 1 S/IS/97

1 INSERT 3Aala i l Consistent with NUREG-1431. Improved TS 3.6.1 would retain requirements l currently specified in CTS 3/4.6.1.1. " CONTAINMENT INTEGRITY " [ ] The proposed change would no longer address containment leakage in a i separate specification. Meeting containment leakage requirements would I be made a direct condition of containment OPERABILITY through SR j 3.6.1.1. In addition, the term CONTAINMENT INTEGRITY has not been retained as a defined term in the ITS. The requirements for containment OPERABILITY, including the' requirements previously found in the CONTAINMENT INTEGRITY definition, would be placed in the' Bases for TS ) 3.6.1. (See the discLssion of the deletion of the defined term CONTAINMENT INTEGRITY in change description 1-04 of CTS Section 1.0.) [ ] These changes would be classified as Administrative (A). l i l l l

i INSERT 3A-lb 0 3.6.3 28 The CTS action associated with this specification says that without CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within I hour or shutdown. The ITS Required Actions which relate to this specification are 3.6.1. Required Action A.1 (which requires the containment be restored to OPERABLE status within one hour if inoperable). and 3.6.3 Required Action A.1 (which requires isolation of a penetration flow path within 4 hours if one of the two valves in that flow path is inoperable). Required Action B.1 ( which requires isolation of a penetration flow path within 1 hour if both of the two isolation valves in that flow path are inoperable), and Required Action C.1 (which requires isolation of a penetration flow path within 72 hours if the isolation valve is inoperable and the path has one isolation valve and a closed system). These ITS Required Actions are also derived, in part, from the Containment Isolation Valves specification in the CTS. The requirements of ITS 3.6.3. Required Action C.1 (the 72 hour completion time) is justified in DOC 11-05-LS and NSHC LS-14. The completion time in ITS 3.6.3 Required Action B.1 and ITS 3.6.1 Required Action A.1 are the same as the CTS. The completion time for ITS 3.6.3. Required Action A.1 (4 hours) is justified in NSHC LS-10. The completion time is considered the same as the CTS and is thus considered to be administrative: however, after discussions with the NRC staff and to facilitate the conversion review, the LS DOC and its associated NSHC are being provided.

i CONVERSION COMPARISON '1kdLE - CURRENT TS 3/4.6 - Page 1 ot a ~ t ' TECH SPEC CHANGE APPLICABILITY NUtBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK _ CALLAWAY l f i [ 01-01 MA is f1 n -j Yes Yes Yes Yes t } WA 1 s cent it. - {Q3.6.t-I l nc ing t requi ts ously n AI IllTE def ion. s in the i eqpa bases f the al L _. letsSLT 36-la. 01-02 This requirement to verify the penetration flow path is Yes Yes Yes Yes [ ted is addressed by 3.6.3 Centainment Isolation \\G3 6.3 -28 l 01-03 h equal alternative isolation method of a " check valve Yes Yes Yes Yes A with the flow through the valve secured

  • is added to the action statements.

01 04 A note is added allowing valves, flanges and isolation Yes Yes Yes Yes LS-1 devices located in high radiation areas to be verified by 7 use of administrative means. 01-05 This requirement is addressed by 3.6.2 Containment Air Yes Yes Yes Yes A Locks Required Actions. I f 01-06 Only containment isolation valves that are not locked. Yes Yes Yes Yes .l LS-19 sealed. or otherwise secured are required to be verified j closed. { 02 01 The Containment Leakage LCO is now addressed by a new 3.6.1 Yes Yes Yes Yes A Containment LCO. A 1 02-02 The wording " prior to increasing the Reactor Coolant Systeui) hMbet Yes No - (3.6.1.2 not No - (3.6.1.2 not { A tesperature above 200*F" is replaced by the equivalent ( Am M MI6 in CTS) in CTS) testing performed in accordance with the Containment ltr. Au,-M \\ requirement of " prior to the first unit startup following w j Leakage Rate Testing Program." 02 03 CPSES testing requirements for contairumnt air locks are No Yes No No A now provided in ITS 3.6.2 for Containment Air Locks. ofM IN3 EAT 36-l l Q3.6.0- 1 l WCGS-Conversion Conperison TnNe - CTS.W4.6 5/lSM7 h i

t i INSERT 38-1 r i i TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 1-07-A All reformatting, renumbering. and Yes Yes Yes Yes editorial wording is in accordance with the Westinghouse Standard Technicas t Specifications NUREG-1431. -i INSERT 38-la t TECH SPEC. CHANGE APPLICABILITY I NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY [ 1-01-A Improved TS 3.6.1 would retain requirements currently specified in CTS 3/4.6.1.1, " CONTAINMENT INTEGRITY [," as well as those currently speci' led in CTS 3/4.6.1.2, " CONTAINMENT LEAKAGE]." The proposed f change would no longer address containment leakage in a separate specification. i f i l t i k ~

NO SIGNIFICANT HAZARDS CONSIDEPATIONS (NSHC) CONTENTS I. Organi zati on........................................ 3 e II. Description of NSHC Evaluations...................... 4 r III. Generic No Significant Hazards Considerations "A" Achini strati ve Changes......................... 6 i l "R" - Relocated Technical Speci fications............. 8 ) "LG" Less Restrictive (Moving Information Out of the Technical Speci fications)................... 11 l "H" More Restri cti ve Requi rements.................. 13 IV. Specific No Significant Hazards Considerations ~LS" LS 1................................................ 16 LS 2................................................ 3 _ %*h $ SGL~4] LS 3................................................ 20 LS 4................................................ 22 LS 5................................................ 24 LS 6................................................ 26 LS 7................................................ 28 LS 8................................................ 30 g,g,7e, g LS 9................................................. 33 LS 10.......................................... N@2Wd WS E M' 4 f, LS 11............................................... 35 LS 12.................................... Not Appl i cabl e LS 13............................................... 3 7 LS 14.................................... Not Appl i cabl e LS 15.................................... Not Appl i cabl e LS 16.................................... Not Appl i cabl e LS 17............................................... 3 9 LS 18............................................... 42 LS 19............................................... 44 LS 2 0.......................................... Not U sed LS 21.......................................... Not U sed LS 22.................................... Not Appl i cabl e LS 23............................................... 46 LS 24.......................................... Not U sed i LS 25............................................... 48 i Ls % l..os.r..s-+] e LSW W Applicable. Lo-28 Eca 3. s 3-o ) WCGS-NSHCs - CTS 3M.6 i S/15/97 r l l

INSERT 4-c 0 3.6.3-28 IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-10 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS Consistent with NUREG-1431, the Containment Integrity surveillance requirement to verify the status of penetration isolation is addressed by ITS specification 3.6.3 Containment Isolation Valves, Conditions A, B and C and Surveillance Requirements SR 3.6.3.3 and SR 3.6.3.4 The CTS action associated with the Containment Integrity specification says that without CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within 1 hour or shutdown. The ITS Required Actions which relate to this specification are 3.6.1. Required Action A.1 (which requires the containment be restored to OPERABLE status within one hour if inoperable), and 3.6.3, Required Action A.1 (which requires isolation of a penetration flow path within 4 hours if one of the two valves in that flow path is inoperable), Required Action B.1 ( which requires isolation of a penetration flow path within 1 hour if both of the two isolation valves in that flow path are inoperable), and Required Action C.1 - DCPP and CPSES only - (which requires isolation of a penetration flow path within 72 hours if the isolation valve is inoperable and the path has one isolation valve and a closed system). These ITS Required Actions are also derived, in part, from the Containment Isolation Valves specification in the CTS. The requirements of ITS 3.6.3, Required Action C.1 (the 72 hour completion time), where applied, is justified in DOC 11-05-LS and NSHC LS-14. The completion time in ITS 3.6.3 Required Action B.1 and ITS 3.6.1 Required Action A.1 are the same as the CTS. ITS 3.6.3 Required Action A.1 must be completed within 4 hours. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. This completion time is consistent with the CTS allowed outage time in the Containment Isolation Valves specification, CTS 3.6.3, for each penetration with one containment isolation valve inoperable and at least one isolation valve OPERABLE. If a penetration has no functioning isolation device, the i one hour allowed outage time is appropriate because the capability to isolate that penetration flow path, without operator action, is lost. In the case where one valve is inoperable and one valve is operable, redundancy is lost but the function is not lost. Based on the low probability of an accident in combination with a non-detectable f ailure that would prevent the OPERABLE isolation valve from functioning. 4 hours is an acceptable completion time to either restore the inoperable valve to OPERABLE or to isolate the penetration. This proposed TS change has been evaluated and it has been determined that it involves no significant hazards consideration. This determination has been performed in accordance with the criteria set forth in 10 CFR 50.92(c) as quoted below: "The Commission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendment to an operating license for a facility licensed under 50.21 (b) or 50.22 or for a testing facility involves no

IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-10 (continued) significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not: i 1. Involve a significant increase l's the probability or consequences of an accident previously evaluated: cr i 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3. Involve a significant reduction in a margin of safety." l The following evaluation is provided for the three categories of the significant hazards consideration standards: 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? ] ITS specification 3.6.3 Required Action A.1 requires isolation of a penetration flow path within 4 hours if one of the two valves in that flow path is inoperable. In the case where one valve is inoperable and one valve is operable, redundancy is lost but the function is not lost. Based on the low probability of an accident in combination with a non-detectable failure that would prevent the OPERABLE isolation valve from functioning, 4 hours is an acceptable completion time to either restore i the inoperable valve to OPERABLE or to isolate the penetration. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident l from any accident previously evaluated? The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing i normal plant operation, and does not impose any new safety analyses limits.

Thus, l

this change does not create the possibility of a new or different kind of accident I from any accident previously evaluated. 3. Does this change involve a significant reduction in a margin of safety? The proposed change establishes the ITS completion time for a Required Actions in the Containment Isolation Valves specification to be consistent with the Westinghouse Standard ITS (NUREG-1431) and does not involve a significant reduction in a margin of safety. The proposed change has been developed considering the importance of the containment isolation valves in limiting the consequence of a design basis event and the reasonable time to perform repairs on a failed l containment isolation valve when the other isolation valve in the flow path remains operable. Considering the probability of an event that would challenge the containment boundary and the reliability of the OPERABLE valve, the proposed change

l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-10 (continued) l is acceptable and any reduction in the margin of safety would be insignificant and offset by the benefit gained through avoiding an unnecessary plant transient. l NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above evaluation, it is concluded that the activities associated with NSHC "LS-10" resulting from the conversion to the improved TS format satisfy the no significant hazards consideration standards of 10 CFR 50.92(c); and accordingly, a no significant hazards consideration finding is justified. i i

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-33 APPLICABILITY: WC, CA REQUEST: DOC 11-18 LG CTS 4.6.3.2 ITS B3.6.3 Bases - SR 3.6.3.8 CTS 4.6.3.2 requires that each containment isolation valve be demonstrated OPERABLE during COLD SHUTDOWN or REFUELING MODE at least once per 18 months by verifying that on a specified test signal the valve actuates to its isolation position. The CTS markup moves the "during COLD SHUTDOWN or REFUELING MODE" requirement to ITS B3.6.3 Bases - SR 3.6.3.8. DOC 11-18 LG states that the item is being moved, but does not provide a justification as to why it can be moved. Comment: Provide a justification for this Less Restrictive change. FLOG RESPONSE: (original) DOC 11-18-LG is being changed to DOC 11-18-A to indicate that the specific CTS words have been deleted since the ITS SR 3.6.3.8 1 Bases already contained similar wording. The description of DOC 11 A is changed to read: "The words 'during the COLD SHUTDOWN or REFUELING MODE' in CTS SR 4.6.3.2 are deleted. Deletion of this information is considered an administrative change since ITS SR 3.6.3.8 Bases state that the 18-month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power." FLOG RESPONSE: (revised) DOC 11-18-LG is revised to indicate that the specific CTS words have been deleted. The ITS SR 3.6.3.8 Bases do not specifically state "during the COLD SHUTDOWN or REFUELING MODE," however, the Bases indicate that the Frequency is based on the need to perform this Surveillance under the conditions during a plant outage. The description of DOC 11-18-LG is changed to read: i "The words 'during the COLD SHUTDOWN or REFUELING MODE' in CTS SR 4.6.3.2 are deleted. Deletion of the specific wording is acceptable and can be considered as being moved to the ITS SR Bases since ITS SR 3.6.3.8 Bases state that the 18-month Frequency is based i on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This SR is typically performed during plant shutdown, however, if for instance, an actual signal is generated while operating, results should be useable even though the plant is not " shutdown" (See DOC 11-08-TR-1). Similarly, if testing would be required to complete some repair or modification made while operating, a shutdown should not be required."

i i ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-17 Encl. 3A 13 Encl. 38 10 l Gr i I i i l I

l CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) = 4,8.Mi utomaticbntainment isolation valve [that is not locked.) [gg@I$ % Il Csealed or ..._: secured in positionM ggy L(, 2: ;;._. _ _f C"E"^?tE i:'..; ^^ COLO SM'EDO?^! c' ".EFL'EL'NG " ODE actuates to its isolation positior@n an actual or s6mulated actuation signal) j I-- O*U~Nl m- _, gg;jp atleast once per 18 months by: bg}jeamsud '!:f;: ; ^',_. '. =_ "..g' : _:s" A" '- ' '.': -- ' t : ;n-!, - - ' O. 3... _

a. g 7._n_,

.q _. W@w}awwan ig7 M M g u m __ m_. nu___.n.i__._.:--. ..:___i __a a: T s_.';_~:. '.' L '..L._ ':.. _. : :.;.; ' ?.'L'.~X L'. ',' _:::,...a_ _'!:f;!:; $2' ^. : Cet-!. T;

  • Pr:;; ' :' -- t et et :!,

__<_..___..__..__2 _.m_.:.,_..__.._,..___.___._a._ y_ _w isolation time of each :;;:~ C::: -I et automatic containment IlIMM isolaten v.: i '! h 1- --- ' :I!: h[that is not locked, sealed.)

C.11 14-A ' j Cor otherwise secured ialwithin its limigwhen tested pursuant to ?-
  • - " - i.0.5 (the inservice Testing Programl INSERT PG. 3/4-16 ACTIONS NOTES:
  • 1. Penetration flow path (s) except containment shutdown purge valve flow filMI S UI t

paths may be unisolated intermittently under administrative contro!s. ""##dd

2. Separate Condition entry is allowed for each penetration flow path.

@D%IQf7

3. Enter applicable Conditione and Required Actions for systems made inoperable by containment isolation valves.

Sf31 % E M $ JEd

4. Enter applicable Conditions and Required Actions of LCO 3.6.1 g)MhMl pgh when isolation valve leakage results in exceeding the overall containment
        • 8E leakage rate acceptance criteria.

d WOLF CREEK - UNIT 1 3/4 6-17 Mark-up ofCTS3N.6 $/15/97

l CHANGE l NUMBER RStfC DESCRIPTION 11-14 A Consistent with NUREG - 1431. the phrase 'that is not locked, sealed, or otherwise secured in position' is added for clarification in regard to which valves require isolation time testing. Valves that are secured in place, are secured in the position required to meet their safety function. The isolation time testing ensures that valves can respond to the position that meets their safety function in the time assumed in the safety analysis. If the valves are secured in the position that meets their safety function, no testing is necessary. 11-15 A Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 11 A Even though it is not specified in ITS 3.6.3 Required Actions, the Action to restore the inoperable valve stated in CTS 3.6.3.a is understood as always the primary objective and a continuous option to be performend during any Completion Time. 11-17 A Not used. 12 01 A Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 12 02 M Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 12 03 LS 15 Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 12 04 M Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 12 05 LS 16 Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 38). 12 06 LG Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 12-07 H Not Applicable to WCGS. See Conversion Comparison Table (Enclosure 3B). 13-01 LS 17 A new Condition has been added to this specification. This condition describes the Required Action for two hydrogen recombiners inoperable. Whereas in the current WCGS-Description ofChanges to CTS 3N.6 13 5/15197

INSERT 3A-13 0 3.6.3-33 11-18 LG The words 'during the COLD SHUIDOWN or REFUELING MODE' in CTS SR 4.6,3.2 are deleted. Deletion of the l specific wording is acceptable and can be considered as being moved to the ITS SR Bases since ITS SR i 3.6.3.8 Bases state that the 18-month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This SR is typically performed during plant shutdown, j however, if for instance, an actual signal is generated while operating, results should be useable even though the plant is not " shutdown" (See DOC 11-08 TR-1). Similarly, if testing would be required to complete some repair or modification made while operating, a shutdown should not be required. l l l i l 1

- CONVERSION COMPARISON TACLE - CURREP "~! 3/4.6 Page 10 cf 12 TECH SPEC CHANGE APPLICABILITY 1 NUPBER' DESCRIPTION DIABLO CANYON CONANCHE PEAK W0lf CREEK Call)MAY r 2 - _.- g 11 IA ~ solati i et alplF M/4 W[ )MRr { M 16.1-6 )[ e o [ b s va ] steam at rel f / f at e u.a.- 11 12 The phrase " flow path" is added for clarification and Yes Yes Yes Yes A consistency with IMIEG 1431. f l 11 13 This change revise the DCPP contairunent Ventilation Yes 10 0 10 0 llo LS 22 Isolation valve surveillance frequency fres 30 months to every 184 days and from 24 honrs to 92 days. 11 14 t s 1. or e@

  1. les - WA Joe WA

.1[s wM I A in iti *s for arif at i regdfd /p 3.6.3-SIj f i alve i la tier _ e ng.t4 5 thel, [ 11 15 A Callaway specific note to 3.6.3 regating testing is 10 0 10 0 flo Yes A deleted based upon ITS LCO 3.0.5. 11-16 Even though it is not specified in US 3.6.3 Required Yes Yes Yes Yes j A Actions the Action to restore the inoperable valve stated j in CTS 3.6.3.a is understood as always the primary objective and a continuous option to be performed during l any Cogletion Time. 11 17 Ilot used. 11 4 na 11 4 gen d

  • yl' s the TT.S34J.6. 3.6 Snes.)

f A f IThe words "during the COLD SitJTD0lse" or "IIEFLELIIIS WIDE" 100 - not in CTS. 10o not in CTS. Yes Yes 11 8 G -j R C --. M N M K d g d D ! st S.E.. "A-3 31 i 12 01 Consistent with IllREG-1431 the hydrogen monitoring Yes Yes llo - CTS Hydrogen 110 CTS Hydrogen A specification is moved to ITS section 3.3.3 concerning Post monitoring monitoring Accident Monitoring Instrumentation (PAM). requirements are requirements are l not in this not in this section. section. t S3537 WCGS-Conversion Co;; L:: TnMe-C153M.6 f i L

ADDITIONAL INFORMATION COVER SHEET i ADDITIONAL INFORMATION NO: Q 3.6.5-4 APPLICABILITY: DC,WC REQUEST: STS B3.6.5 Bases - LCO ITS B3.6.5 Bases - LCO ITS B3.6.5 Bases - LCO makes a number of changes to the STS B3.6.5 Bases - LCO. Since the ITS changes to the STS Bases were made based on changes to the STS, on plant specific system design or on current licensing basis as specified in the CTS, the changes to STS B3.6.5 Bases - LCO do not seem to fall into any of these categories. Comment: Provide a discussion and justification for these changes. 1 FLOG RESPONSE: (original) No change. The ITS B3.6.5 Bases - LCO changes were made to reflect the Wolf Creek and Diablo Canyon plant specific design, analysis, and terminology details. The STS Bases statement addresses only the containment design temperature which is considered to be the structural design temperature. In accordance with 10 CFR 50.49, the basis for containment temperature is to ensure the performance of safety-related equipment. Thermal analyses indicated that the time interval during which the containment air temperature exceeds the containment design temperature was a short duration such that the equipment surface temperature (including the sturcture) remained below the containment design temperature. The statement in the STS Bases - LCO is not strictly true. Wolf Creek and Diablo Canyon still desire pursue this change. FLOG RESPONSE: (revised) Based upon discussions with the NRC Staff October 13-14, 1998, the LCO Baces text is revised to clarify that an initial temperature consistent with this LCO assures that the temperature profile resulting from a DBA will not cause the containment structure to exceed its design temperature and that required safety related equipment within the containment will not exceed allowable operating temperatures. This response also addresses NRC Staff comments to DCPP on Q 3.6.5-3. ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 5B B 3.6-36

gContainment Air Temperature U/ap;c;; ;g = cpeenent umih co-w,m.a B 3.6.5A ~ 40 Peierm A a.ccident 4emperahre yref;(c. mees. BASES @'"* ***% ' -~-- c a 7

ht We con %;n-eA.h o.chcA.

VJampemtu.re saurQrna.*nbnca. LC0 During a DBA with an initial containment average air tempera less than or equal to the LCO temperature limit, the resultant .t_ qu5-4\\ t containment s gn m ra ure a pahaudo 6,armL-ns am s1 fL 10 5 APPLICABILITY In H0 DES 1. 2, 3. and 4. a DBA could cause a release of radioactive material to containment. In H0 DES 5 and 6. the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment average air temperature within the limit is not required in H00E 5 or 6. ACTIONS U When containment average air temperature is not within the limit of the LCO. it must be restored to within limit within 8 hours. This Required Action is necessary to return operation to within the bounds of the containment analysis. The 8 hour Completion Time is acceptable considering the sensitivity of the analysis to i variations in this parameter and provides sufficient time to correct minor problems. B.1 and B_2 If the containment average air temperature cannot be restored to within its limit within the required Completion Time, the plant must be brought to a W.)DE in which the LCO does not apply. To achieve this status, the plant must be brought to at least H00E 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR

3. 6. 8sA.1 REQUIREMENTS Verifying that containment average air temperature is within the LCO limit ensures that containment operation remains within the limit asstmed for the containment analyses. In order to o

(continued) WCGS-Mark-up ofNUREG-1431 - Bases 3.6 B 3.6 36 S/1587 g-f.

ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.6-13 APPLICABILITY: DC, WC, CA REQUEST: CTS 4.6.2.3a.1 ITS SR 3.6.6.2 and Associated Bases CTS 4.6.2.3.a.1 verifies that containment cooling fan units are started and operated for at least 15 minutes at least once per 31 days. The corresponding ITS surveillance is ITS SR 3.6.6.2. The CTS and ITS are not consistent with each other. CTS 4.6.2.3.a.1 for Callaway and WCGS requires the CTS surveillance be performed on "each non-operating fan group" while ITS SR 3.6.6.2 requires the SR be performed on "each required containment cooling fan" for WCGS and "each containment cooling fan" for Callaway. CTS 4.6.2.3.a.1 for DCPP requires the CTS surveillance be performed on each CFCU while the ITS requires it be performed on each required CFCU. Based on ITS B3.6.6 Bases - BACKGROUND description of the Containment Cooling System, the CTS to ITS conversion for this SR would be a More Restrictive change for WCGS and Callaway (CTS testing only non-operating to ITS testing of all fan units) and a Less Restrictive change for DCPP (CTS testing all CFCUs to ITS testing of a minimum of three CFCUs). No justifications are provided for these changes. Comment: Revise the ITS markup to conform to the CTS, or provide discussions and justifications for these Less Restrictive or More Restrictive changes. FLOG RESPONSE: (original) WCGS has reviewed the ITS and Bases and determined that j the bracketed ([)) word " required" can be deleted since the LCO requires all components to be OPERABLE. CTS 4.6.2.3.a.1 states: " Starting each non-operating fan group from the control room, and verifying that each fan group operates for at least 15 minutes." For WCGS and Callaway, the CTS SR 4.6.2.3.a.1 is performed by starting any non-operating fan unit and ensuring that it runs for greater than 15 minutes. For those fan units that are already operating when the SR is performed, surveillance procedures require that the operating fan units be verified that they are running for greater than 15 minutes. This is equivalent to the ITS SR 3.6.6.2 which would require starting any non-operating fan and verify operating for greater than 15 minutes and the operating fans are verified operating for greater than 15 minutes. Therefore, CTS SR 4.5.2.3.a.1 is considered equivalent to the ITS SR 3.6.6.2 and no justifications are needed. For DCPP, no change in the ITS is necessary. The CTS LCO 3.6.2.3 states that "at least four containment fan cooler units (CFCUs), or at least three CFCUs, each of the three supplied from a different vital bus" shall be OPERABLE. There are five installed CFCUs at each of the Diablo Canyon Units. The DCPP license has always implicitly contained the concept of " required." See response to 3.6.6-8 for description of changes made to JFD 3.6-14 which clarify and justify this arrangement. FLOG RESPONSE: (supplement) As discussed at the meeting on October 13-14,1998, the NRC interpretation of CTS 4.6.2.3.a.1 is that if a containment cooling fan

unit is opertting at the tima ths SR is perform;d, tha operating fan units are not required to be verified that they are running for greater than 15 minutes. Therefore, the NRC contends that converting from the CTS to the STS is a more restrictive change. A more restrictive DOC has been initiated to reflect this change to the CTS even though the surveillance testing performed at WCGS and Callaway meets the STS SR 3.6.6A.2 requirements. DOC 8-12-M has been initiated for WCGS and Callaway which states: " CTS SR 4.6.2.3a.1) is revised to indicate that each containment cooling fan unit is verified operating for at least 15 minutes. Based on the NRC reviewer interpretation, this change results in an additional requirement to verify that the operating fan units operate for greater than 15 minutes. However, the CTS surveillance requirement is performed by starting any non-operating fan unit and verifying it runs for greater than 15 minutes and verifying the operating fan units are running for greater than 15 minutes." For DCPP, the word " required" is removed from SR 3.6.6.2. ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-15 Encl.3A 9 Encl. 3B 7

~ CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM Pi$'WM$$ Lu hmed lJMITING CONDITION FOR OPERATION l 3.6.2.3 Two independentftrains)poups of containment cooling fans shall be OPERABLE d5 '-^ '. rie:=: te rer5 gr^"p. K10'efMI9 tamwd APPLICABILITY: MODES 1,2,3, and 4. ACTION

a. With one pe@of the above required containment cooling fans inoperable and both Contair. ment Spray Systems OPERABLE, restore the

~cp3,c.g-t4] inoperable you a(GEEof cooling fans to OPERABLE status within 7 days 11fg2 [and within 10 cavs from discovery of failure to meetDie be@)or - -- ' - ~ ' be in at least HOT STANDBY within the next 6 hours arjtl in COLD SHUTDOWN within the following 30 hours. (g[

b. With two(9aTrE)poups.of the above required containment cooling fans inoperable and both Containment Spray Systems OPERABLE, restore at least one(GoI@poup of cooling fans to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore both a required mc k k 31]4 9 e M 4 3. 6. 6 - M (trains)poupsof cooling fans to OPERABLE status withi s of initial s

loss or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. {

c. With one f the above required containtne t coohng fans inope and one Containment Spray System inopen ble, restore the

_m inoperable Containment Soray System to OPERABLE itatus within 72 hours 149@ [and within 10 dava from discovery of failure to meef#te4see3 Q3,(,,G.4{ or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore the inoperable moveof { train of containment cooling fans to OPERABLE status withi initial loss or be in at least HOT STANDBY within the next 6 h and in COLD SHUTDOWN within the following 30 hours. New Two Containment Spray trains inoperable or any combination of three ! "l 8-10-N ' "' " ' " ~ ~# or more containment spray and cooling trains inoperable enter LCO 3.0.3 ( immediately. SURVEILLANCE REQUIREMENTS 4.6.2.3 Each youp(EaIn')of containment cooling fans shall be demonstrated OPERABLE:

a. At least once per 31 days by-1
1) Qtartfrgesqb.e6n-ppefMMjh66fWerfoq;w1mpd) 8-l2-t1 0 3.6.6-13 1 venTying that each fan-poup[ unit operates for at least 15 minutes. -

j

2) Verifying that each valve (manual, power-operated, or automatic) 10-OLF. A dQ3.6.b-Illk in the cooling water flow path serving the containment coolers that is not locked, sealed, or otherwir,e secured in position, is in its correct position.

k b. At least once per 18 months by verifyingOn actual or simulated) $:$*IRf

S:M; M:Va==*eienmHMMano sterP^ def W er, i rperdr;, th51

$100244% e -'r r;r f 2% ---%; ::n:Se ree in-cre *- et 'ert '^ - ~ ~ ~ N ;~^ '^ !_^ ^^^'!" ;'^"". b n M S a dow M Ita h i-f+h2t mach contas* rneh cochn3 n o wd. a enihim'~ coc.1% waw A rate. 5:o es%h.,hed 143.6.G-9l on e acht. or.sivbbh cL ac.tuatio'n signal. j WOLF CREEK - UNIT 1 3/4 6-15 Amendrnent No. 38,50 Mark-up ofCTS3M.6 SMSM7 l

CHANGE NUMBER NSHC DESCRIPT10N 8 09 LG hThe r "du 9 tdown" as en rom e l it o form. 18 nth r 11 ce. his i syn ymous th e 18 n fr uen and i n ase the ES k th ord'ng 43 f.4-Gl (con sten wit UREG-31 di tNSEtr '3A-h 8-10 A A new Condition and Required Action consistent with ITS 3.6.6 Condition F has been added. This Condition specifies two containment spray trains or any combination of three or more trains inoperable to enter 3.0.3. Even though this condition is not specified in the CTS, 3.0.3 would be entered because the LC0 is not being met and does not have any required actions specified. Under these conditions, 3.0.3 is the rule consistent with NUREG 1431- _ f-{ Q 3.6.4-4 ) 8 11 LS-P P1 A "fr die over 4 ai re to e he 0" ov'lon] ad h ompi o me r in N c ai t a ooli sy s pe 1 CT /.6.2 (Co t ay) .6. Co i t i / st r ire t 'ng t i ra es em o rab sta w in e li st 3 ino rab' y an ati of se s tem to I ho s it vi a im f7 ays r ra or ng o gr po ool f to ra st sw e yth el is ra T ch ge i o dered Les estr' iv nt the d all t TS woudallow.) to tt L is gr ter ian t CT t e u x r.3 4 ca_ s { 9 01 A Not Applicable to WCGS. See Conversion Comparison Table j (Enclosure 3B). i 9-02 LG The descriptive information in LCO 3.6.2.2 regarding operability of the Spray Additive System is contained within the definition of operability as described in the ITS 3.6.7 Bases. This is consistent with NUREG 1431 and is acceptable because while the descriptive detail is moved to the Bases, the basic requirement is retained in the LCO. 9 03 A Consistent with NUREG 1431, the action statement is revised by deleting the reference to restoring the spray additive system to operability within 48 hours or be in cold shutdown within tne following 30 hours. The revised action statement contains a requirement to be in cold shutdown within 78 hours. The time allowed to be in cold shutdown has not changed. As discussed in the Bases, the interval to reach cold shutdown allows 48 hours for restoration of the system operability and an additional 36 hours to achieve cold shutdown. V(9'~ll U t US r c'T.3 A - 9 b ( G 3. 6. 6 - i3] WCGS-Description of Changes to CTS 3M.6 9 5/15/97 ~

-

~

INSERT 3A-9b 0 3.6.6-13 8 12 M CTS SR 4.6.2.3a.1) is revised to indicate that each containment cooling fan unit is verified operating for at least 15 minutes. Based on the NRC reviewer interpretation, this change results in an additional requirement to verify that the operating fan units operate for greater than 15 minutes. However, plant practice for the CTS surveillance j requirement is performed by starting any non-operating fan unit and verifying it runs for greater than 15 minutes and -verifying the operating fan units are running for greater than 15 minutes. i t 2

CONVERSION COMPARISON TadLE - CURRENT TS 3/4.6 Page 7 of 12 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 08 10 ITS Condition F specifies two containment spray trains or Yes No - CPSES has only Yes Yes A any combination of three or more trains inoperable to enter two Containment 3.0.3. Even though this condition is not specified in the Spray trains CTS. 3.0.3 would be entered. covered by this speciffcation. Loss of both trains is outside the CTS and 3.0.3 is automatically invoked. 08-11 A "f dis ery of 11 to theLC"provJsion as Yes No - CPSES current Yes Yes erfge. na to tion t for raip4f TS does not have a M c pra ling ens 1 ab1pr' Th cha containment cooler r ess Res ctive i at3hd10 sa specification. 1 not the LC s creater tha t woul allow. Ihj5ER.T.36-7 )---I Q3.G. G 44 l 09-01 The DCPP units for the spray additive tank volume limits Yes No No No A are changed from gallons to percent. 09-02 The operability of the spray additives eductors is Yes Yes Yes Yes LG contained within the definition of operability for the spray additive system as described in the Bases. 09-03 This change revises the ?ction statement by replacing the Yes Yes Yes Yes A reference to restoring the Spray Additive System to operable status within 48 hours or be in cold shutdown within the following 30 hcurs, with the requiretrent to be in cold shutdown within 78 hours. 09-04 This change adds the phrase 'that is not locked. sealed. or E 5 ;_lue,. Yes 7 06,_. No - Current ^ A otherwise secured in position

  • with regard to which valves

.1.sml,... CT3. p.d. ;c g.- CTS % practice per CTS SR require actuation testing. Jes - d.0.2.2< Nes 4.6.2.2. ps3.,.z. h:2._ [o 3.6.G-G] tusEKT 3B-WCGS-Conversion Comparison Table-CTS 3M.6 S/158 7

INSERT 38-7a 0 3.6.6-13 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY 08-12 CTS SR 4.6.2.3a.1) is revised to indicate No No Yes Yes M that each containment cooling fan unit is verified operating for at least 15 minutes.

1 l ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: WC 3.6-ED APPLICABILITY: WC REQUEST: (original)1) CTS markup, page 3/4 6-11, the inserted text included the wording " closed manual valve." The wording is being deleted as Wolf Creek has no manual valves that can be utilized for isolating a containment penetration.

2) ITS Bases - SR 3.6.3.1, the last sentence refers to Cond; tion E. Based on changes made to ITS 3.6.3, the correct reference is Condition C.

i

3) ITS Bases - SR 3.6.3.7, cis.rification is misspelled.
4) ITS Bases 3.6.2, Reference 3 is deleted since this reference in not used in i

this ITS Bases section.

5) ITS Bases 3.6.6, BACKGROUND, delete the "A" from ITS LCO 3.6.5A.
6) ITS Bases 3.6.6, APPLICABLE SAFETY ANALYSIS. remove the strike-thru from "not."
7) ITS Bases 3.6.8, Action A.1, remove the strike-thru from "(should on occur)."

]

8) ITS SR 3.6.3.7 and ITS Bases SR 3.6.3.7, changes blank flange to blind i

flange for consistency within the ITS and Bases. REQUEST: (supplement) As discussed at the meeting on October 13-14,1998, in item 1), the CTS markup provided in the original response did not indicate the subject text was deleted. The CTS page is provided with the text indicated as deleted. ATTACHED PAGES: Attachment No.12, CTS 3/4.6 - ITS 3.6 Encl. 2 6-11

._m l CONTAINMENT SYSTEMS l-cr[. A Q3.4.b-I{ CONTAINMENT V5M9L^90M SYSTSiSOLATION VALVES) 9'h01WQ A%>akkMt LIMITING CONDITION FOR OPERATION I 11

d. hy.4[ F 7 T

. 3.6.17 Each containment purg-rr;;'; 2nd ::">tt isolation valves shall be edisi OPERABLE. and; @@@4900 9 pur;: ;;'; --d =5 ce' 2:r':fr- )ljQ-25j N * "- :1.2nd k ~- wr =::::=: - : =;=;;'; =: =m

P :':) - :; M4pene e; *- 2aaa her derb; : ::':- " : ;:::.

{ ] APPLICABILITY: MODES 1,2,3. and 4. [_66-i.5 2 )8-%3.63l'a) ACTION @

a. With anfinoperable) 36-inch containment purge supply and/or exhaust isolation valvefoxcept for excess ::'s-2:;: ::

^_:x' ?c _- f,close and/or IQ.09 t GM blank flanoojhat valve or isolate the penetration 5 tow pattQs) within 4 hours. 3Qpt),,Qg fand verify "' the affected penetration flow path isolated once por 31 days "$1N~~26 ~~ # for isolation devices outside containment AND prior to entering MODE 4 from MODE 5 If not performed within the previous 92 days for isolation 7-IS* M 98'43-Vievices inside m 'z:.

..Aitherwise be in at least HOT STANDBY within the next 5 hours and in COLD SHUTDOWN within the following 30 hours.

/ /-

b. ".^t '_h: 15 591/_.c.c '_-M pur;: - ;;'; zi':: xt:r' _

%MS$ m._.. _.._m_,a____,_,___ .m __ onnn u..__ m m _ _ - _2 UU,~ ' d [; b S. 5 1 5 dS! E ~^ S U E _-d:T hafu,-g Q3.s,.53] _ r.: - ' h r-. :^' 2.-- _ : 5 5 -' ' - ^^ "^T "^ "a"Y n r '. 5.1 ^ S her-, ::d 5 T' D SM'.'TT"." 227. 5 '_- J ; '^ her. l

c. With-a(One or more penetration flow paths with one or more]

M42-L$.93 h*"#** containment purge valve (s) having a measured leakage rese in excess of the limits of Specifications 4.6.1.7.2 and/or 4.6.1.7.4, :- - _5 :. ::: :r-

r;:':) '- C""^"' E 7: _ ^ the affected penetration flow path _

1.66r.LS. iM. 3.6-ED \\ !by use of atjeest one closed and f--% _^_-I automatic valve wij larEnGui' 'N bilnd flangefwithin 24 hoursfand verify *

  • the anected

-3~,, T path isolated once per 31 days for isolation devices 7-0-M 43.43-35) ^ l outside containment AND prior to entering MODE 4 from MODE 5 if not perforntedjoithin the previous 92 days for isolation devices inside containment Mrtff leen rate on aII valves with reslient sesit uses to isolate the flow 4 g,gg 3,g,gp3 Jmth at least every 92 dayedtherwise be in at least HOT STANDBY within the next b 6 hours and in COLD SHUTDOWN within the following 30 hours. h 1. Penetration flow path (s) except containment shutdown purge valve ) [11461.513j flow paths may be unisolated intermittenly under administrative controls.

2. Separate condition entry is allowed for each penetration flow path.

9II422d@ b 03~ h 93*3~7!

3. Enter applicable conditions and required actions for systems made QI~

Inoperable by containment isolation valves.

4. Enter appilcable conditions and required actions of LCO 3.5.1 kgfAQ N"

" Containment", when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

  • loolation devices that are locked, sealed, or otherwise secured may be verified S*l44-I.5M3 k

by administrative means. + loolation devices in high radiation areas may be verified by use of

  • $*146-3 193 administrative means.

WOLF CREEK - UNIT 1 3/4 6-11 Mark-up ofCTS3M.6 5/15/97

ADDITIONAL INFORMATION COVER SHEET 1 ADDITIONAL INFORMATION NO: WC 3.6-006 APPLICABILITY: WC Q 3.6.7-7, O 3.6.3-21 REQUEST: (original) (1) Enclosure 2. CTS 3.6.2.2a should not be struck out and DOC 9 LG does not apply since this wording is in ITS SRs 3.6.7.2 and 3.6.7.3. This item is covered under Q 3.6.7-7. (2) CTS SR 4.6.1.7.2 and SR 4.6.1.7.4 were not correctly marked to reflect DOC 7-06-LS-11 (This item is covered under Q 3.6.3-21) and DOC 7-09-LG and 7, LG.. l REQUEST: (revised) As discussed with the NRC staff on October 13,1998, this licensee identified item is withdrawn. ATTACHED PAGES: None I

Att chment 2 to WO 98-0105 Page 1 of 1 l LIST OF COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation (WCNOC) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be comrnitments. Please direct questions regarding these commitments to Mr. Michael J. Angus, Manager Licensing and Corrective Action at Wolf Creek Generating Station, (316) 364-4077. COMMITMENT Due Date/ Event A supplement to Reference 5 will be provided at a later date. Prior to issuance of SER. x r., k i ~- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _}}