ML20196D001
| ML20196D001 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/23/1998 |
| From: | UNION ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20196C989 | List: |
| References | |
| NUDOCS 9812020133 | |
| Download: ML20196D001 (200) | |
Text
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- DEFINITIONS -
i l [ . AVERAGE DISINTEGRATION ENERGY
- 1: T shc11 be the average (weighted in' proportion to the concentration of I 2
each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gama energies per disintegration (in MeV) for isotopes, other than iodines, with half-lives greater than 15 minutes, making up at , least 95% of tne total noniodine activity in the coolant. l (Eff) V ENGINEERED SAFETY FEATURES RESPONSE TIME i: The ""0IN :Z: "AF:T" I:A : SF RESPONSE TIME shall be that time l ! interval from when the monitored parameter exceeds its ESF Actuation Setooint i at the channel sensor until the ESF equipment is capable of performing its /-4/-A l safety function (i.e., the valves travel to their required positions, pump ) discharge pressures reach their required values. etc.). Tiines shp j diesel generator starting and sequence loading delays where a i1 cable.g S//4 I e ,~,,u..n.u....m._~, v n , ,, , , %A06A*I~l-l~0 i _ _ 9 9 A PM PMf tPainv me em p * ? Mit 3
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> >w' L gnat; Ch:11 n rra ; = d t; th; int;rni; d;'i= d '- ';.t h ' 1.
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! DEu :"'"; LEAKAGE S #* A* /~I < 'T ',' \ L&D9K.A GE..r4*//.Le
, ,. . . . . ._ .. .-_ : . . . /-//-A
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... 5,. a 7 LearAce teaxACs, i
i f /,4- Lu k;;; 'u n gt C0"T"0LL"O LU "JCE) int; Ci n ;d ;y;t.x ,*such as & f /,v., pump sealtor valve packinguini; th;t er; captured and conducted to l c,//aeden .ryr/ew or a sump s.aAxAceor collecting tankg Mrf er-- cesey+reaek cae/*.+ fag /c6.rea/sJee ,' 2,4:- Lnic;;Vinto the containment atmosphere from sources that are both I '*N j specifically located and known either not to interfere with the i operation of Leakage Detection Systems .or not to be "" 5!""" 90""DA*v LEAKAGE; or j (gct) LEAKACK r** cr*** ledD \ ' V 10.L.; through a steam generater te the
.~f. .e,- Reactor Coolant System g j
. C N f6 Kr~ /,/- E 5econdary ;;i..n. SystemJ (Is) i MASTER RELAY TEST
& Qr.
t cen.rir+of . reyir.e) l-pj-)) ! -1.10 A MASTER RELAY TEST shallh energiE((n of eachYmaster relay and /-JQ l veri '=ti;,a ef OPERABILITY of eacMlay. The MASTER RELAY TEST shall include a co inui,ty check of each associated slave g relay.~7'Xe /MATTEA g TffT d /,/"/ Q'.Ne reguired de f*dermed meant "E"EE C7 ~": '""L: .
*nf to rie.r s S .c pa,gJg__,,__,
heelyyo , se-hk / eispe, i.iT = =?.; ) 07 T = ru L:: Shal' in;;.d; ;11 p;T; n; h; ;r; n t n np;- \
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;f =; 'i;;a;;;, it; ;;atre;nr; er .;ader;. A h ; n : h d;d fr;- thi; nt;;; y
- r: p:rn= ah: :nter the sit :: ::rvi : : ip.. nt er :: = h: d:'.iv:ri= .
Thi" ;;'.;;;ij dei; inci.d; pira;a h; ; p;rti;T.; Of the ".it; f,7 r;;"'n tieni , ;n p;ti n .1, ;r ;th;r p.rpan .= Cnctict;d ith +50 p'"* - a CALLAWAY - UNIT 1 1-3 Amendment No. 75, 75', 58 9812O20133 981123 E PDR ADOCK 05000483 p PDRy - - - - ~~
.-- - . _ _ _ - - _ _ . . - - . - - . - - _ . _ . - - - - . = . . - _ . _ .
h INSERT 1.1-C rn**ru eed ' The response time may be N5y means of any series of sequential, /-of-A overlapping, or total ste isN f?/,/--f-I measured. .r,n loeu &ps so that the entire response le time veriNad A,- tolac/wol com,vnenh mearu ressn+, ynvo-ded HJ h4a e acompnenroJ sj o n s e 4 % a m ay / m *Hodakyy A- ver$cdan han leen pews .rp **Wewed ad
*y<aved 'Ay na wa . -
- SERT 1.' D e,m_u..,a n
Q 14. / .?
- 5. m :im;; 11:ve b!: pirj ::29.~.::: hia;;; :::, L., ddl be --/ !0 4 0.209',. of pH-j ::::n' 2::: ;i v/d;;ht p:- day : th: 66::d pen err +irer pm;;m (",). - .
( 0 l INSERT 1.1-E ! l l l
- b. Unidentified LEAKAGE f ff-A !
All LEAKAGE (except RCP seal water leakoff) that is not identified l LEAKAGE;
- c. Pressure Boundarv LEAKAGE LEAKAGE (except SG LEAKAGE) through a nonisolable fault in an RCS component body, pipe wall, or vessel wall.
1
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l
/-3
DEFINITIONS , l 7.s OUADRANT POWER TILT RATIO (&fTg) HP-A (g) J .25 "UA02^NT "CWER TILT RAT:prg/4 hall be the ratio of the maximum upper excore }
. detector calibrated output to the average of the upper excore detector cali-brated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, which-ever is greater. Wi'th one excore detector inoperable, the remaining three detectors shall be used for computing the average.
RATED THERMAL POWER (4f/.) Krf 1.25 "AT:0 Tu:RFAL POWER"shall be a total core heat transfer rate to the /-el-lA reactor coolant of 3565 MWt.
. (AT0 Y
. REACTOR TRIP SYSTEM-RESPONSE TIME i RT.T C /-pF-A
-kff- The- R: ACTOR TR:P SYS~rE# RESPONSE T] ME shall be the time interval from l when the monitored parameter exceeds itsYIrip SetfoTnt athannel s until loss of stationary gripper coil voltage SNTEg7-/./-G $/,/4 e.-.c o. n_ e. ._r.n.e , r_ e_ m. -
^
1.2S A Pd ORTAOL: ":NT :h:11 b; :ny of th :: conditic"! !?er'#4^d 4" l S :tica 50.72 :: 10 CF" P:rt 50. t
. bn.. "IE'"IC'EU ""U 0"E"*"IO" /-27-M
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' 29 "E!~P.!CTIO AIO OP: RATION (RAT 00) limite ths AXIAL TL"X 0:TI:REN : (AM)-- l to a '?" target band about the t: ; t flux di#ferent: :nd re:trict: p m.'e r levil? t; be: cen APL"O cnd cither APL'8"M ;r 100t RATED THEP"AL "0HE",
which;ver i: 1:::. APL"" :nd APL"^r M ;r; d; fined in Sp::i'ic: tion: 2.2.' g.d ".2. ".2, r;;p;;ti v;ly. "AIOC rey b; ntcred :t the di: r tier Of the SHUTDOWN MARGIN [.fbM) JbM 1- con +n i ( (gccAr) ;- y 1.20 5""~00"N " ARC:K!shall be the instantaneous amount of reactivity by which j the reactor is suberitical or would be suberitig al from its present condition assuming .all # 1'- 1:ngth rod clustervassemblies"(:h tdan ;nd ;;ntr;it are fully inserted except for the sing 1 Od cle:t r :::;-bly-of highest reactivity worth which is assumed to be fully thdrawn. 3/VIEgr /,/-N KCCA
- e. r. ~. e. e nnu. . n_s.ev
/-2+-A 1.21 Th; ::T: 00cNOARY 3he:1 Le th;; iin; b;y;nd .<hi:h th: 1:nd i: neith:r j Ortned, ner le::dd, nor other i:: :ent ell:d by th: licen:::.
SLAVE RELAY TEST , Conrid*E in "f"' / l--A
-M+ A SLAVE RELAY TEST shal1% thE energiz:t$:n ;f eachVslave relay and -A veri '::ti:n ;P OPERABILITY of each relay. The SLAVE RELAY TEST shall includ /-/
a ce tinuit check 1: 2 ~4"4T 55 i dAtestable actuation devicee yT3-fke j j (f t u V* W'Q ps , 1-5 Amendment No. U , KB, 25,58 l CALL A - UNIT 1 e,./ , Y
~
Y Y# # "{ "'*NJ
l gs INSERT 1.1-G N-l l ~
,na,,,,.af ,
f The response time may be 42ESB8%y means of any series of sequential, /-0E-A l l overlapping, or total steps so that the entire response time is 4EiWiiib d /-/4 l mearued. rn /reu oPmeatursmed, respnea -line my 4a ya,;,Q-g Ae releeksi copede frovdad +ha+ -Ha cony,na,Jr an,( 1 theNeololog Nafe,NRc, verrA ca fr3n lave ie en ,onvintf reviewJ aJ
*/frovd y _
INSERT 1.1-H With any RCCA not capable of being fully inserted , the reactivity worth of /-MM the RCCA must be accounted for in the determmation of SDM. In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures. ! b I i
- O
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a mwr
.. . . . - _ . . - . . . - . - . . - - - - . - . . - . = . - . ~ . - - . . - - . - . - . - - . . . - . . . - d CHANGE !
; NUMBER HStiC DESCRIPTION 1 06 LS 1 The current TS definit' ion for Core Alteration is modified i consistent with NUREG 1431 Rev. 1 to qualify a Core
~
Alteration as movement of fuel, sources, or other , reactivity control components. This proposed change is less restrictive since the current TS definition defines . the movement of any couponent within the reactor vessel wi i fuel in the vessel as a Core Alteration " r:r p/,
/ e the proposed definition would limit Co Alterations
/-3 i o those manipulations that could affect co reactivity, the proposed change is acceptable from the ta
- 4+ of the health and safety of the public. EMN#T '
TA-2A i 1 07 - Not applicable to Callaway. See Conversion Compari Table (Enclosure 38). 8 l by n i r -/// i
'1-08 A The current TS definitions for Engineered Safety Je Response Time and Reactor Trip System Response Tine are fg modified to be consistent with NUREG-1431 Rev.1(4e- _
a o the ers asu "i repi ea - T1 t ist wit the ir f1 ro /
.3.1 6 and 3. 2.10 ov fv caa t i
[3 ' thin imits N addition of the statement that y j (V ) y_J response time may be M y means of any series of sequential, overlapping, or total steps so that th; c. tire i I response time is*6 is administrative in nature. This is consistent with the methodology presently { described in the current TS Bases for demonstrating total channel response time. 2Nie#i 74-2 8 k / 1 09 A The current TS definition for Frequency Notation (and Table 1.1, Frequency Notation) is' deleted to be consistent with NUREG-1431 Rev. 1. 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. 1 10 -A- - Tinition for max 1mm allowable primary con i leakage ) is added to the i to be consistent with . . This addition has beer determined to administra n the basis l that finition has simply been [copi i rrent TS 6.8.4.g] to the definitions. A4+ a. red. Q r.4./-4
\
j DESCRIPTION OF CHANGES TO CURRENT TS 2 5/15/97
,,,- __ ~n - * - - -
~,&4e*A Aerr
J I n INSERT 3A-28 Q 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.
/ %d D
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jm p k._ CONVERSION CONPARISON TABLE - CURRENT TS 1.0 Page 1 of ( j TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 4 1 01 These definitions are reworded to be consistent with Yes Yes Yes Yes A NUREG-1431 Rev. 1. The proposed rewording included in this category does not involve any changes of a technical nature. - l 1 02 The CPSES definitions for Analog Channel Operational Test No - do not have Yes No - do not have No
- Digital" is A and Digital Channel Operational Test are conbined 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 RTDs or thermocouples. 1-04 This definition is no longer used and the specifications in Yes Yes Yes Yes: see also
/_ G Section 3.6 are revised accordingly. The current TS ITS 5.5.6 and definition for Containment Integrity is deleted. h f hf!g*[8fM p gg[peda [ E dy& p as/ U 5.5.16. g y,g,f j 1 05 The current TS definition for Controlled Leakage is deleted. Yes Yes No. See Change No. See Change A Nunber 1-28-LG. Number 1-28-LG.
1 06 The current TS definition for Core Alteration is modified to No - already in Yes -Wee /%.h Yes LS-1 qualify a Core Alteration as movement of fuel, sources, or CTS. /Of rnee other reactivity control components. g 7,fg f 7-f % ,/r % 1-07 The location of the thyroid dose conversion factors used for Yes No - already in CTS Ho-already$nCTS No - already in CTS A DOSE EQUIVALENT I-131 has been added. 1-08 The current TS definitions for Engineered Safety Features Yes Yes Yes Yes A Response Time and Reactor Trip System Response Time are modified na iti .t te me urea sr ac py [
"ve 1 t c si nt th r reme so d/,/4 ro dT R3 .1 SR .2. to if es se i is thi it' s.j 1 09 The current TS definition for Frequency Notation (and Yes Yes Yes Yes A Table 1.1. Frequency Notation) is deleted. The acronyms defined in Table 1.1 Frequency Notation, are no longer used in NUREG 1431 Rev. 1.
CONVERSION COMPARISON TABLE - CURRENT TS 5/15/97 _ - _ _ _ - _ = _ _ .. .. .. _. . . _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ - _ _ _ _ _ - . _ - _ _ _ - _ _ - _ -
INDUSTRY TRAVELERS APPLICABLE TO SECTION 1.0 ( (1 TPAVELER # STATUS DIFFERENCE # COMMENTS TSTF 19. Rev. 1 @ Incorporated @ /, /-/2 @ NRC approved, apomwrMica< a+ _ N/#~#A
.a ~
TSTF SPABIB9D Incorporated f..1-9
<-a) p /, /-/
l M D $/,1-2 ) 2prano d2i33RD G!ab $/ l-1 , TSTF 111. Incorporated 1.1 5 Rev. $--- f / M /'/~Y ( 2 "#G'3Ts3BPb Incorporated 1.1 6 ggC ,fpr,y,/, f /,/-f N Incorporated 1.1-3 8 /,f-/ l TJ7F-NA pit. Incorporated 1.1-11 8/,I-/ T.TrF-S2,Rev. I Lesejen4rJ /, I-/3
&s.t. l-4 /%
U (t MARK UP OF WOG STS REV 1 (NUREG 1431) 5/15/97
Definitions 1.1
/
[m ()
\ 1.1 Definitions DOSE EQUIVALENT I 131 calculation shall be those listed in [Whwp unmt; 3.p3 (continued) asu.g p a c a ayne - 4_ 4 etira Jnanwisw2MWM Tumh ncwaaa ...usMeq er thcx listcd in Tabic " 7 of Rc;ulatory Guid: 1.100, Rcv. 1, "RC, 1977 ,or IC!'I' OO, Cuppicacat t; Port 1, pesc 102 212, Tebic titicd, "Comittcd Ocx ".;uivalent in Torget Org;ns or Tissun per Intokc of " nit Activity".
E AVERAGE E shall be the average (weighted in proportion to the DISINTEGRATION ENERGY 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 HeV) for isotopes, other than iodines, with half lives
> g minutes, making up at least 95% of the total B~
noniodine activity in the coolant. ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its ESF actuation TIME setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the g.T valves travel to their required positions, pump discharge g nra""res *^ed their redred vahm a+c ) Tlags,sha V include diesel generator starting and sequence loading delays, where applicable. The response time may be gd 2;n;ured @by means of any series of sequential, d.1 ) overlapping, or total steps so that the entire response i C time is z V rs:M. ZMrGET Ll-3 A bl4
- t er ellNdlepri=ry x di rt1rb; rete.
L,. M e!' M _ . ef pri=ry n .t:inxt :.1 t:ri? P A FS dry et t M rel =1;ted pxk cr+? W t prr rr: ' P,' , /,/-/3 LEAKAGE LEAKAGE shall be: A T.C./-4
- a. 7dentified LEAKAGE
- 1. LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (PP) seal water injectica er leakoff), 1.1 10 that it captured and conducted to collectim systems or a sump or collecting tank:
C '\ i
\
(contin .d_) . MARK UP OF WOG STS REV 1 (NUREG 1431) 1.1 3 5/15/97 mu
9.m.-._ . _ x.. ._ _ t t .' 1 !- INSERT 1.1-3 Q1.1-4 1: l i % gp: 3-In lieu of measurement, response time may be verified for selected components i- provided that the components and methodology for verification have been previously }. reviewed and approved by the NRC, I i 1 e s 3 4-l p I. l ~. I 1 ? i
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Definitions 1.1 ( t, wt
! 1.1 Definitions PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:
- a. Described in Chapter B hitici Tat Progrerm of B.ps the FSAR
- b. Authorized under the provisions of 10 CFR 50.59: or
- c. Otherwise approved by the Nuclear Regulatory ,
Commission. ' PRESSURE AND The PTLR is the unit specific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates 6 1.1 t s j.ngy wr n x .. ._....9 f. . , i . for the PS current reactor vessel fluence- period. These pressure and temperature limits shall be determined for each fluence Plant period operation in accordance within with Specification these ;- rating;"Timits is 5.6.6. Eg7 , addr re~ve 7.4.OCS7 1,; ; j K n = u = c =~ .; u ntzc = = t:. =d = :.4.r. 3 J-h-rkc M "
-- rcturc Ourpicnurc Prctatica (=P; 5 !
"LaColol Tlverfrestare Mrky d ron yf.ek (comr)7t;r, ." " d /./--6~
QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore RATIO (QPTR) 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. j whichever is greater. l RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to B PS (RTP) the reactor coolant of 2093 3555 MWt. REACTOR TRIP The RTS RESPONSE TIME shall be that time interval from SYSTEM (RTS) RESPONSE when the mnn*rM narameter exceeds its RTS trip setpoint TIME the channel sens7unt11 loss of statT67ia^ry gri coil voltage. The response time may be n au- " 1.1-5 DSS by means of any series of sequentialkof*+) ) l over'apping, or total steps so that the entire response 4 /, /--y L time is n- urcd @ .~CNTEXT'/,/-6'~ Net) (~w) V w 7 - (continued) MARK UP OF WOG STS REV 1 (NUREG 1431) 1.1-5 5/15/97
wv u INSERT 1.1-5 Q1,1 4
> ~,.s in lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.
v e s
JUSTIFICATIONS FOR DIFFERENCES FROM NUREG-1431 Section 1.0 3 This enclosure contains a brief discussion / justification for each marked-up technical change to the NUREG-1431 Revision 1 to make them plant specific or to k 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, 38, 4, 6A. and 6B. text in brackets "[ ]" indicates the.information is plant specific and is not comon to all the Joint Licensing Subcomittee (JLS) plants. Empty brackets indicaAtat nthar 11 S 0 1 ve plagt_.spes.1 fir - information in that location.FTXe urre/"// aW,juser (3 C hnn,/ er,A /
*^ mirinh adah i 7).rf ans/ - )) l d CHANGE *!"l1k'
- er ~Ne r .bevree ljrerah)c y soa)'
NUMBER JUSTIFICATION '"N#IV8 #F '-e/rvera _ e , , ,jj, 1.1 1 The NUREG 1431 Rev.1 definitihf hannel Calibratio-we p(a ** N he itntire channel, including the ;
/^ l i ' "all/evre y.r#/"f in a.g required sensor. alarm, interlock, display, and trip functions."& This cnsnge clarifies whatVyn a e t e re an i oy ew din O /'/~~A M*aas/
0$are /
"/Mr J n :, e -T e L TI s 1e o ss ose
. nt , s ns s, la s, isp ys, and ip nct~ ns l A r/mr/ar c=4 1r to r s if' d fet fun ion )." The ha 1
> /t/revr/4/ e Me r on T t ri w mH n na ice oer ion Te d in' ions; i l
drh Ls sim' ar r is [ This change is consistent with TSTF- @ 2d f ! 1.1 2 Not used. I 3. 1.1-3 Adds new example to ITS Section 1.4 to clarify the meaning of SR notes q* of the type "Only required to be performed in H0DE...." This change is consistent with travelerdDBRL-res. D ~7JTF a?. S / f-/ 1.1 4 Not used. 1.1-5 The definitions for ESF _ Response Time and RTS Response Time are revised rd er' ie i li of me sur , or, t t th $/,/ ir n of -14 S 3. 1.1 an SR .3 .10 .is a ur co is ncy t n he fi ti sfrR se a t r ir nt to ri ic y ri R e T' 5/sw'hi mi s. his an i consistent with traveler TSTF-111,gg E- .rWTE)tT~$/}-} 1.1 6 The definition of the Pressure and Temperature Limits Report is revised to include the maximum allowable PORV lift settings and arming temperature associated with the [ Cold Overpressure Mitigation System (COMS)], 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. The [COMS] arming temperature was added to the PTLR, since changes in the heatup/cooldown figures could change the arming temperature. This f\ change corrects the PTLR definition to be consistent with all of the requirements contained in the PTLR. Referenced methodologies for the PTLR contain the methodology used to develop the heatup and cooldown JUSTIFICATION FOR DIFFERENCES TS 1 5/15/97 I l
..na I
n INSERT 6A-1 g Q1.1-4 e )
"L; )
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. l J c)- l l i j l 1 f V ,
O O y I- K2 widi Oh O (v)
%crr, e,J TAwrJy., .s 3ijce ? k tv.
i -Ite ekeI r<g"hool-4.- chamaI . O/E/ff) . ltMVtRSION COMPARISON TABLE FOR NUREG-1431 DIFFERENCES Page 1 of 2 SECTION 1.0 DEFINITIONS DIFFERENC( FROM NUREG-1431 APPLICABILITY NUMBER l DESCRIPTION / DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY -
/ A 1.1-1 This change c1 rifies ':t .,.::::: : :-t' r ;t. ..J Yes Yes Yes Yes by - ~ m..yhe definiti :t:tc. ~" N HANNEL CALIBRAT10L 2:" : :7 :_ _ 2;;; m.v-.l; . J. ;; -
g !~ ,
-:- :r . -
d" f C:. : d *- T ' - t' - q '-M b p: 'n W :;;;f '!:d mty N.A..m . - ThenT ;..d - t
-4ABef-definitionp4eegimilarly revised. C/kQgh ,, -fip/.
1.1-2 Not used bl# N/A N/A N/A N/A 1.1 .1 Adds new example to ITS Section 1.4 to clarify the meaning Yes Yes Yes Yes of SR Notes of the type "Only required to be performed in HDDE. 1.1 4 Not used N/A N/A N/A N/A 1.1-5 The definitions for ESF Response Time and RTS Response Time
^ ~
Yes Yes Yes Yes are_ revised.3u 3 su e tje u er n in te r co st t h r ui so NL [ /. [4 , i 1.1 6 The definition of the Pressure and Tegerature Limits Yes Yes Yes Yes Report is revised to include the maximum allowable PORY ; lift settings and the arming temerature associated with the system. and to be consistent with the COLR definition. 1.1 7 The definition of Channel Functional Test in the current TS Yes No - Not part of No - Not part of No - Not part of will be retained in the igroved TS. This definition is not current TS. current T5. current 15. in NUREG-1431 Rev 1. , i 1.1 8 gatebisrevisedtorefertothe'Requiredreactorvessel -Yes- A[g -Ves-M -4eef/, Yes head closure bolts fully tensioned
- and note c is revised [/,/-9 to read " Required reactor vessel head closure bolts less than fully tensioned."
ej L a (a//aW -efacIhecd CONVERSION COMPARISON TABLE - NUREG-1431 5/15/97 i
- - - - _ - - . - . - - - - - . - . - . . . a_ __-_--__-_L__._ _ - _ _ _ _ _ _ - - _ _ - - - _ _ - - - _ _ _ - _ _ _ - - _ - - _ _ . - - - - . _ _ _ - - - - _ - _ _ - - - - - - - - - . - _ - - - _ _ _ _ - - _ _ _ - . _ _ _ _ . - _ . - _
l l l i ADDITIONAL INFORMATION COVER SHEET l !Q h ADDITIONAL INFORMATION NO: Q 3.4.12-5 APPLICABILITY: WC, CA l l l l REQUEST: Differences 3.4-18 and 3.4-45 (Wolf Creek and Callaway) f
- 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 then restoring it (which is the case covered by the CTS) is very different than simply switching from one operable pump to another. i FLOG RESPONSE (original): Four hours is a reasonable time restriction for swapping ! centrifugal charging pumps (CCP) during the low temperature overpressure protection l (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 l up to 4 hours. . 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 (^x Injection pumps and one CCP to be inoperable. If this requirement is not met, then four hours l 1 (J) is allowed to retum the pump (s) to an inoperable 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 i operation, the inoperable CCP must first be restored to OPERABLE status to meet ITS LCO l 3.5.3 (MODE 4) and USAR/FSAR Section 16.1.2.3 (one OPERABLE CCP in boration flow l 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 RCS, the requirements of ITS SR 3.4.12.2 l must be met. SR 3.4.12.2 Bases states that a pump is rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative controls. The Bases also state that an altemate 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 l 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 be performed from the control room. Swapping of CCP trains is a short duration evolution but must be performed in a controlled manner especially when coordinating activities outside the control room. The 4 hour time allowance provides for normal operation of the plant and allows plant l manipulations / evolutions to be performed in a time frame in which they can be safely t performed. Amendment No.103 (Callaway) and Amendment No. 89 (Wolf Creek) revised current TS 3.5.4 to provide a 4 hour AOT to restore one CCP to an inoperable status in MODES 5 and 6. This 4
/ ) hour AOT was specifically reviewed and approved by the NRC as noted in their safety C/ 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 l
l
l l hours to secure one CCP after entering MODE 4 from MODE 3. Current TS 3.5.2 requires both I CCPs to be operable in MODE 3. Therefore, all of the ITS 3.4.12 Applicability is based on the l [] current TS except for MODE 4 beyond 4 hours after entry from MODE 3. NSHC LS-24 justifies j 'Q 4 hours for all of MODE 4 l 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 hour for CCP pump swap operations, consistent with traveler TSTF-285. This is a more restrictive change except in 1 MODE 4 beyond 4 hours after entry from MODE 3. In addition to the CTS and ITS mark-ups, the attached pages contain revisions to DOC 9-17-LS-24 in Attachment 10 (3.4) and DOC 4-05-M in Attachment 11 (3.5). JFDs 3.4-18 and 3.4-45 do not require changes due to the general nature of their wording. ATTACHED PAGES: Attachment 10, CTS 3/4.4 - 3.4 Enclosure 2, page 3/4 4-34 (Insert B) Enclosure 3A, page 16 Enclosure 3B, page 12 Enclosure 4, page 47 ! A Enclosure SA, page 3.4-24 I Enclosure SB, page B 3.4-71 Attachment 11, CTS 3/4.5 - ITS 3.5 Enclosure 2, page 3/4 5-9 Enclosure 3A, page 7 Enclosure 3B, page 5
iw INSERT A FOR PAGE 3/4 4-34 I with a maximum of zero safety injection pumps and one centrifugal charging 9.-st-Af f-/s_pf pump capable ofinjecting into the RCS and the accumulators isolated or depressurized below the allowed RCS pressure per the PTLR INSERT B FOR PAGE 3/4 4-34 l
# ^ NOTES- --
fL/ 7-/_J . fn de. '
- 1. Two centrifugal charging p ay b# capable ofinjecting Me te RCS & T.4/2-2 j for $6 for pump swap ope 'ons. !
4
/ /wue 02+.I2-C l
- 2. Two s ety mjecdon pump 3 aud two centrifugal charging pumps may be @ g/a I
! /nele capable ofinjecting,it i; RCS. i l r s (a)In MODE 3 with any RCS cold leg temperature 5368 F and ECCS pumps OPERABLE pursuant to LCO 3.5.2, "ECCS-Operating", . and (b)For up to 4 hours 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. g
- 3. One or more safety injection pumps mayvbe capable ofinjecting L-:: i: 4 s:t/2-2
-RC-&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 function. ,,,, j, ,,,,,,pg,j
- 4. Accumulator bel;'ic; b caly r;quir:!when accumulator pressure is g j,_3 gerr i= cr cqu;l - the maximum RCS pressure for the existing RCS cold leg temperature owed by the P/T limit curves provided in the !
PTLR. ( /a.r.e +1wn b.9 ____ _ __________ ________ __ ____ _____ I [ tU 1 1
i
,._.s CHANGE NUIEER HSBC DESCRIPTION
/
( ,)
\
9 12 LS 20 In conformance with NUREG-1431 Rev. 1, an allowance has been included which provides for performance of the Channel Operational Test on the PORV actuation channels within 12 hours after entering the applicability. Previously this was required to be performed prior to entry and was an unnecessary burden on plant operation. As stated in the Bases, the 12 hour time frame is an i acceptable period for performance of this COT and does not ) pose a significant increase in risk. The channel I calibration is still maintained current. This change is less restrictive and is acceptable as stated above. 9 13 A Consistent with NUREG 1431 Rev.1, CTS Specification 4.0.5 has been moved to the IST Program in the Administrative Controls Section of the ITS (ITS 5.5.8). 9 14 M 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 RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR. This change is consistent with adding the
- l. N requirement for accumulator isolation to the LC0 (see CN 9 06 M). The addition of this surveillance requirement v ) is a more restrictive change which is necessary to help ;
ensure [COMS] analysis assumptions are maintained. l 9 15 M In conformance with NUREG 1431 Rev. 1, an additional l action and corresponding SR are added for one or more SI l pumps 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 - Not applicable to Callaway. See Conversion Comparison Table (Enclosure 38). 9 17 LS 24 Three notes are added to LC0 3.4.9.3 to reflect current TS SR 4.5.3.2. LCO 3.5.4 ACTIONS a and b, and the LCO 3.5.4 Applicability note *. A fourth note is also added to l LCO 3 %3 to cvii e:,purt.to_tha e m anlator Action added er CN 9-10-M. The note regarding CCP p swap , I operations represents a relaxation since it would allow 1 both CCPs to be capable of inject 9 into the RCS for up {' ; to #3Biih.throughout the [COMS] pplicability, as further l
\ / in O b6~4 anlp
'(v} 10 01 LS 21 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 3B). f DESCRIPTION OF CHANGES TO CURRENT TS 16 5/15/97 i
p ,, -g i i x.m./ M l'4 V
)
(vt). } CONVERSION COMPARISON TABLE - CURRENT TS 3/4.4 Page 12 of 13 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 9 14 An additional surveillance is added for verification of Yes Yes Yes Yes M accumulator isolation. 9-15 An additional ACTION and corresponding surveillance are Yes No - Different LTOP Yes Yes M added for one or more SI pugs or more than one centrifigual design. charging pug capable of injecting into the RCS and subsequent actions for RCS depressurization and venting if necessary. [ ] 9-16 Increases the frequency for verification of RCS cor.ditions Yes No - 30 minute No - 30 minute No - 30 minute H during heatup, cooldown and testing from once every hour to surveillance surveillance surveillance once every 30 minutes. interval already in interval already in interval already in current TS. current TS. current TS. 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. L O_1 E A arW D, ano tne LCirA!i L.--4 57. CCPs to be ity note *. A fourth note is also added to QRABLE. 0 3.4.9.3 to correspond to the accumulator Action added %-- - m under CN 9-10 M. The note regarding CCP puno swan - m MdMYsn/ 3 operations represents a relaxationr5Tnce it would allow both CCPs to be capable of injecting into the RCS for up to [ 7.4./2-f j q$5JigA) throughout the [COMS] Applicability.
~ ~
/h_ - -
~'
10-01 T surveHlance requ1rements associated with the RCS No - Amendment Yes No - Amendment 89 No - Amendment 103 LS 21 Structural Integrity specification are deleted. 98/97 relocated to relocated to USAR relecated to FSAR Equipment Control Chapter 16. Also Chapter 16. Also Guidelines (ECGS). see Section see Section 6.8.5.b. 6.8.5.b. I 10-02 The Reactor Coolant Pump flywheel inspection requirement has No - Amendment Yes No - Amendment 89 No - Amendment 103 A been moved to Section 5.5.7 in the igroved TS. 98/97 relocated RCP relocated to USAR relocated to FSAR flywheel Chapter 16 and CTS Chapter 16 and surveillances to 6.8.5.b. CTS 6.8.5.b. CTS 6.8.4.1. I CONVERSION COMPARISON TABLE - CURRENT TS 5/15/97
,_. IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS N NSHC LS-24
\ 10 CFR 50.92 EVALUATION ! FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS 18 Mobe+on/p, A note regarding CCP pfp swap operations has been added to LCO This 3.4.9.3. represents a relaxatiorr'since it would allow both CCPs to be capable of injecting [J'.f.#6 into the RCS fer up to/FJRER>throughout the [COMS] Applicability.
/ b-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:
I "The Conmiission may make a final determination, pursuant to the procedures in 50.91 that a proposed amendment to an operating license for a facilit., 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? l Overall protection system performance will remain within the bounds of the previously perfonned accident analyses since no hardware changes are proposed.
The initial conditions and assumptions for the [COMS] mass addition and heat injection transients will be unchanged. Actions will be taken to ensure that only one CCP is capable of injecting into the RCS during the [COMS] Applicability. Current TS 3.5.4 provides 4 hour A0Ts if one SI pump and two CCPs are capable of injecting during the most critical portion of the [COMS] . Applicability (lowest RCS temperature and the plant may be water solid). The l 4 hour A0T for one SI pump is deleted: however, that A0T is used to justify a hour pump swap allowance for the lower flow CCPs. This pump swap allowucef)$,/2-5 y also justified for the higher temperature [COMS] Modes which. by virtue of
/
[b \ their higher initial temperature. have greater margin to Appendix G limits. The proposed change will not affect the probability of any event initiators NO SIGNIFICANT HAZARDS CONSIDERATION 47 5/15/97
ps . i .- LU Sy;;t;; { 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 4 3.4.12 L;w T; g ratur; PS Over,,7G;;;r; ." ret;;ti;;r, 'L"" Sy;t;;;; LCO 3.4.12 Ar, LT Sy;;tc.; - shall be OPERABLE with a maximum of :PSc and .- - i . capable of rB PS? injecting into the RCS and the accumulators isolated and citMr a 37 t b;;;;, x3.4 49:
;. Tw;; %S rc14cf velv;;;. ;;; f;11r,w;;.
4 1- 3 Two power perated relief valves (PORVs) with lift settings J within the limits specified in the PTLR, or E- E Two residual heat removal (RE) suction relief valves with setpoints a psig and ; psig, or B-3- 3 One PORV with a lift setting within the limits specified in the PTLR and one Rm suction relief valve with a setpoint a ' psig and s psigM s s85 4 : b E The RCS depressurized and an RCS vent of a E M square B PS? inches.
- 3.4 45 m f m mede E . -:3'. 4 18 :a Q 3.4./2-2 3 3.4 18=
inde M A Q 2.412-2 M M l g .. .. . .. .. . .. .. . 1, . , ., c. s, 3.4 20-
.. .. g g 3
.r .a.... . . . . . . . , . . . . - . .....:.... . . ..
.n
* [ -', g . ,.'
'e' , s's r l [ e ., .
(continued) MARK UP OF WOG STS REY 1 (NUREG 1431) 3.4 24 5/15/97
- a. s v. .ry .n e i B 3.4.12 BASES APPLICABLE RCS Vent Performance SAFETY ANALYSES (continued) With the RCS depressurized, analyses show a vent size of : 2-97 square inches is capable of mitigating the M eWwed-L40P overpressure transient. The capacity of a vent this size is greater than the flow of the limiting transient for the t#BP - -
configuration, s;. lT: ; - e. 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 L T Sy;t s satisfies Criterion 2 of t.'.; = Pclicy Statement-LCO This LCO requires that the LT Sy.;ts M is OPERABLE. The LT Sy;ts is OPERABLE when the s+matar M coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference i limits as a result of an operational transient. To limit the coolant input capability, the LCO requires
- e. .: lT: ;---
capable of injecting into the RCS and all acctmulato ischarge isolation valves E closed and g
" N ilized4 accumulator pressure is greater than equal to the maxi RCS pressure for the existing RCS cold leg i temperature allowed in the PTLR OMr*[g l YI$a l bour- tQ 2.4, ID-S
_ _ (continued) MARK UP OF NUREG 1431 BASES B 3.4 71 5/15/97 4
. = . __ _ - - . . - . _ _ _ - . _ _ _ _ . . - - - . - . . . -- __-
x N
- EMERGENCY CORE COOLING SYSTEMS w 3/4.5.4 ECCS SUBSYSTEMS - Tm s 200*F LIMITING CONDITION FOR OPERATION 3.5.4 All Safety Injection pumps and one centrifugal charging pump shall 4-Cal-LS be in:; rtit. io,eyJ/e oSinjee+;y.
1 APPLICABILITY: MODE 5 and MODE 6 with the reactor vessel head on.* ee+iy
~
I (map f
*He
/mA*//*hl o+- inj/atfrab} ~
4-o/-LJ ACTION: La c +im 4* y. hyg one or mor a
- a. With .# Safety Injection puiidO":"'"LC," restore all Safety 4-#M 4-^ae-s'- stite' d tH ' 5:urs.
Injection pumps tog}4.+de a incofeLle o.P injec+ing . .:1 A/.rsAY 3/f.f-9A
- b. With centrifugal charging pumps ^^:'J"LC,yestore one of 4& gf_tg the ten rifugal charging pumps tq,:n 'n:;;re : :tMu: within cg 4-0f-M pso ')
LGy* Ale of injecHf
&3.4.f>Sl hour. . ~ - -
h immedi=4ely in?+fah
'rNnsery CAA % ets+urinfc an L a eft,a -h in sekm,c#,,, j SURVEILLANCE RE0VI EMENTS 4fe _ _ _
g_g 4.5.4.1 All Safety Injection pumps shall be demonstrated-i-ep--e'-** by V:rifyin; th:t the m:t:r cir;;it bre:h r: 2r returedifhepean
.ry.rE#1~
f cy-g
,? :itie :t 1:::t :::: per 21 d:yr.
' 3/+S y 4-D/-LS 4.5.4.2 One centrif Jgal charging pump shall be demonstratedV w'
4 9 per21:** by /crifyir.g th:t th; m:ter circuit bre:hcr: Or: ::: r:d i- 9
--the epen positien et icest cr. : per 31 d:y:. g py Af
{
- Wnen the RCS water level is below the top of the reactor vessel M-A flange, both Safety Injection pumps may be OPERABLE for the purpose of protecting 'the decay heat removal function.
** ^d neptr:ble pump ::y bc ncrgi: d for tt: ting er fer #4in; M2.-45
-- 3tc*r previded the di :h:rg :t the pump h:: beer 15:12ted
" ' = '1
#ron the "CS by : :1c::d isciatica valv with pcw:r r ::ved frc: the g dl-/ I
- v:'": Oper:tcr, or by a menuei ucietica velve secured in the cic;ed pt:itier
, 3.n . -:
t- 'aa (m ' Amendment No 42,103 CALLAWAY - UNIT 1 3/4 5-9
- . - . - - - . . . - - -. . . = . . _- -.- - . - - - . - . - -
l
^
l CHANGE NUMBER HSBC DESCRIPTION I \ ("/ ' note dealing with testing and accumulator fillir.g. This change is less restrictive on the configuration of the ECCS pumps but does not result in a less conservative operational position as flow to the RCS is still i precluded. 4 02 M 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 immediate action initiation. Otherwise, if precluded from compliance, depressurize the RCS and establish the necessary vent path within 8 hours. This change is more restrictive regarding the entry into an immediate action. , 4 03 M This change, in accordance with NUREG-1431 Rev.1, requires the verification that the disallowed ECCS pumps are not capable of injecting into the RCS on a 12 hour frequency. Previously a 31 day verification of breaker position was required. The increased frequency is more l restrictive; however, the verification can now be performed using control room indication and administrative l controls as discussed in the Bases for ITS SR 3.4.12.1 and p/ s 3.4.12.2 in contrast to field verification. There is no N6 c 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 LC0 Note 3 of improved TS 3.4. 4 05 H The 4 hour A0T for completing actions to make ono CCP - incapable of injecting, per the current licensins basis, has been moved to improved TS 3.4.12, LCO Note 1r The 4 hour A0T for the SI pumps has been deleted. This is 'M l d5MEEFID more restrictive because the new Required i Action in improved TS 3.4.12 Condition A specifies that I immediate action must be taken: whereas, the current TS provides a 4 hour A0T. This change also supports CN 9 17 LS 24 in the 3/4.4 package. ; 4-06 - Not applicable to Callaway. See Conversion Comparison Table (Enclosure 3B). , [.$ 5 01 LS-7 Consistent with NUREG 1431 Rev.1. the Completion Time to restore boron concentration or borated water temperature to within limits is increased from 1 to 8 hours. Changes , in boron concentration and temperature are slow and this ' l DESCRIPTION OF CHANGES TO CURRENT TS 7 5/15/97
~
T w ',v v afgg gg_g CONVERSION COMPARISON TABLE - CURRENT TS 3/4.5 Page 5 of 6 - TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3-11 The minimum RCS temerature limit for DCPP below which the Yes No No No LG CCP and SI pumps must be demnstrated incapable of injecting is replaced by the statement "the minimum low temperature / pressure value specified in the pressure temperature limits report (PTLR)." 3 12 The SR to verify that no more than one centrifugal charging No - see CN 4 06-A. No - see CN 4 06-A. Yes Yes A pump and no SI pugs are capable of injecting into the RCS and the SR exception for 4 hours after entering PODE 4 from H0DE 3 or until the tewerature of one or more RCS cold legs decreases belos 325*F, whichever comes first, are moved to improved TS SR 3.4.12.1, SR 3.4.12.2, and LCO 3.4.12 Not e 2. 4 01 The requirement for having ECCS pump injecticr. sources in No DCPP does not Yes Yes Yes LS 4 excess of that allowed by cold overpressure analysis have this TS. assumptions be rendered inoperable has been revised to peclude those pumps from injecting into the RCS. 4-02 The action required if ECCS pumps in violation of the cold No - DCPP does not Yes Yes Yes I H overpressure analyses are capable of injecting into the RCS have this TS. has been changed to require imediate action initiation. Otherwise, if precluded from cogliance, depressurize the RCS and establish the necessary vent path within 8 hours. 4 03 This change requires the verification that the disallowed No - DCPP does not Yes Yes Yes H ECCS pumps are not capable of injecting into the RCS on a have this TS. 12 hour frequency. Previously a 31 day verification of breaker position was required. 4 04 The Applicability Note regarding SI pump operability in No - DCPP does not No - CPSES CTS does Yes Yes A Modes 5 and 6 to protect the decay heat removal function has have this TS. not have this note. been moved to LCO Note 3 of improved TS 3.4.12. 4 05 The 4 hour A0T for completing actions to make one CCP No - DCPP does not No - CPSES did not Yes Yes H incapable of injecting. per the current licensing basis, has have this TS. include this A0T. been moved to improved TS 3.4.12 LCO Note The 4 hour A0T for the SI pumps has been deleted. a,J da cnaad 6 / ha, . A ** 4 I^' " CONVERSION COMPARISON TABLE - CURRENT TS 5/15/97
ADDITIONAL INFORMATION COVER SHEET l ADDITIONAL INFORMATION NO: O 3.5.5-2 APPLICABILITY: CA, WC l l REQUEST: Section 3.4 DOC 6-28 LG i CTS 3.4.6.2.e & 4.4.6.2.1.c l 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 l justification for moving these requirements to a licensee controlled document. Also, i 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 seat injection flow. FLOG RESPONSE: (original) l Union Electric Company and Wolf Creek Nuclear Operating Corporation disagree with this l 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, i consistency with the Comanche Peak and Diablo Canyon conversion submittals is not a l prerequisite for our conversion to the ITS. The ISTS seal injection LCO was not adopted l based on our CTS definition of CONTROLLED LEAKAGE which refers to seal water flow from the seals, i.e. seat 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 seal leakoff, 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 SNUPPS Staff), Westinghouse, Bechtel, and NRC Staff (F. Anderson, J. Holonich, and D. Brinkman) on j 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. Seal injection flow rate does not provide an indication of proper seal performance, whereas No.1 seat leakoff does. ur CTS do not have a separate RCP seal water injection LCO because proper throttle valve position is ensured when we perform CTS SR 4.5.2.g.2) every 18 months. The seal water injection throttle l valves, BGV0198 through BGV0201, and the seal water retum throttle valve, BGV0202, < l as well as the other ECCS throttle valves are set to ensure proper flow resistance and l pressure drop in the piping to each injection point in the event of a LOCA. Once set, l these throttle valves are secured with locking devices and mechanical position stops. l 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 l of potential pump performance. These resistances and pump performance ranges are used to calculate the maximum and minimum ECCS flows assumed in the LOCA l I 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 l
into ths prim:ry syst:m. Ths rsmiining 3 gpm flows up the shift and entsrs 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 sealis referred to as a
" controlled leakage" seal because the aakage through the seal is predetennined by ensuring that the gap between the seC ring and the seal runner is held to a constant value via a stable balance of hydrostatic forces on the seal ring. The No. 2 sealis a rubbing-face seallocated above the No.1 seal. The No. 2 seat backpressure forces most of the water leaving the No.1 sealinto the CVCS seal water retum 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 seal into the Reactor Coolant Drain Tank via the No. 2 seat 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 sealleakoff 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 ana 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 10CFR50.34. It is therefore acceptable to move the RCP seal water retum 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 sealleakofflimits in the FSAR. See also DOC 6-28-LG in Section 3.4."
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. Sealinjection limitations are established by the throttle valve position surveillance in CTS SR 4.5.2.g.2) which is moved to ITS SR 3.5.2.7. 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."
Revise Section 3.5, Enclosure SA, *NUREG-1431 Specifications That Are 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."
Revise JFD 3.5-9 in Section 3.5, Enclosure 6A to add the following:
"The positions of the RCP sealinjection and retum throttle valves ensure that the assumptions used in the ECCS analyses to calculate the maximum and minimum ECCS flows remain valid."
_ _ _ _ - m.. _ _ . . . _ _ _ . _ _ _ _ _ _ . . _ _ _ _ _ . _ _ . _ _ _ _ Rsvisa ITS SR 3.5.2.7 B:sss to add tha following: l "The ECCS throttle valves and the seal water injection throttle valves are set to ensure ! l proper flow resistance and pressure drop in the piping to each injection point in the event , l' 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 l resistance; (2) both the maximum and minimum branch injection line resistance; and j (3) the maximum and minimum ranges of potential pump performance. These ' l resistances and pump performance ranges are used to calculate the maximum and l 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.
- r !
L Union Electric Company and Wolf Creek Nuclear Operating Corporation continue to j i- rnaintain that our CTS definition of CONTROLLED LEAKAGE, which refers to seal water ' l flow from the seals, i.e. seal leakoff, does not meet any of the four criteria in l 10CFR50.36(c)(2)(ii). Therefore, we 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 i document are justified changes and are entirely separate from the issue of whether a seal injection LCO is adopted. 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 l 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 l to reflect the adoption of ITS 3.5.5, as well as the new Specification and Bases. There ! l are no changes to the ITS 1.0 attached page from what was submitted in Reference 4. It ! l is attached here for completeness. t The following new changes are attached: l i 1 Revise DOC 6-28-LG in Section 3.4, Enclosure 3A to read as follows: i t
"The current TS definition of CONTROLLED LEAKAGE is deleted as discussed in l DOC 1-28-LG in Section 1.0. The RCP seal water retum flow limit is moved to a licensee !
l controlled document. Seal injection limitations are established by the throttle valve l l- 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 ; l and operational details of the type embodied by the RCP seal water retum 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 I and will retain the 18-month surveillance Frequency." , t
,--J, , . . ,,. , . _ _ ,--m . . . , ~ , - . - - - - . - . _ -~L- __ , _- -~ . . - - _ _ _ - . ,
- 3. Add nsw DOC 2-20-M to S:ction 3.5 to read as follows:
"A new LCO is added to CTS 3/4.5 to impose limitations on seat 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 sealinjection 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 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; (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."
- 6. Add new ITS 3.5.5 and Bases.
- 7. Revise JFD 3.5-9 to read:
"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 sealinjection and retum throttle valves ensure that the assumptions used in the ECCS analyses remain valid."
ATTACHED PAGES: Att. 4 CTS 1.0 - ITS 1.0 Encl. 3A page 6 Att.10 CTS 3/4.4 -ITS 3.4 Encl. 3A pages 12 and 13 Att.11 CTS 3/4.5 -ITS 3.5 Encl. 2 page 3/4 5-5 and new sealinjection LCO Encl. 3A pages 3 (new DOC 2-06-A) and 4 (new DOC 2-20-M) Encl. 3B pages 2 and 3 Encl. 5A NUREG-1431 Specifications That Are Not Applicable Sheet Encl. 5A pages 3.5-7, 3.5-12 (new), and 3.5-13 (new) Encl. SB pages B 3.5-22 and B 3.5-34 thru 8 3.5-37 (new) Encl. 6A page 2 Encl. 6B page1
.- CHANGE-NUMBER N2iG DESCRIPTION addressed by the definition of the term Mode. This definition stipulates that fuel be in the vessel in order to be in a " MODE." These changes are administrativeA m hn, 1 26 'A New sections 1.2.1.3. and 1.4 are incorporated into the improved TS to be consistent with NUREG 1431 Rev. 1.
Section 1.2 provides specific examples of the use of the logical connectors AND and QB and the numbering sequence associated with their use in the improved TS. Section 1.3 deals with the proper use and interpretation of Completion Times and specific examples are given that will aid the user in understanding Completion Times. Section 1.4 deals with the proper use and interpretation of surveillance frequencies. Specific examples are given that will aid the user in understanding surveillance frequencies as they appear in the improved TS. . The proposed changes are administrative in nature and by themselves are not technical changes incorporating travelers N M ,3 H1a nod 1 TM-2t~1. & /A-/ 1 27 M The definitior, of Restricted AFD Operation (RAFDO) is deleted from the current TS. in accordance with NUREG 1431 Rev. 1. See CN 1-15 M in the 3/4.2 package. 1 28 LG The current TS definition of CONTROLLED LEAKAGE is deleted to be consistent with NUREG 1431 Rev. 1. The RCP seal watae n tr-a Qow limit is moved to a licensee controlled
~
*f* R gg_g, & r.'s.r-2 1 29 LS 3 m rr. .uausa w ca naway. '.we ConvefsiolIcomparisD Table (Enclosure 38). _
1 30 A Consistent withMMthe definitions of $ /,/-/ Channel Operational Test (C0Tk [ ] and Trip Actuating j //eder 88/d7 % d m >evice Operational Test (TAUU ) are expanded to include 3 the details of acceptable performance methodology. NdV8 I'!'/ > l Performance of these tests in a series of sequential, overlapping. or totalooeration ssurance of appropriate @ steps provides of the6 channel,nthes necessary
,/evree,refeed'af.This change also makes the COT *[ ] and TAD 0T definitions consistent with t definition of Channel Calibration which already cent ns similar wording.
A e m + T f ao d N
- AIM A'6 G ~ / Y 3'I DESCRIPTION OF CHANGES TO CURRENT TS 6 5/15/97
. . - . . . . . -. - . - .. .. . . - . _- -.~.... . - . _ - . - - .. _ - -..-.- - INSERT 3A-6 O CONTROLLED LEAKAGE as defined in the CTS has nothing to do with the performance of $ 75f .2 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 10CFR50.34. It is therefore acceptable to move the RCP seal water ratum flow limit to the FSAR since that retum 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 sealleakoff limits in the FSAR. See also DOC 6-28-LG in Section 3.4. O l 1 l j l 1
\ I 1
CHANGE I NUMBER EiliC DESCRIPTION
}.
RCS hot leg suction isolation valves from inadvertently (V) opening when RCS pressure exceeds the interlock setpoint. Upon failure of the interlock, the current TS permits continued operation for 72 hours for restoration of the affected subsystem. The improved TS requires action within 4 hours to isolate the affected RHR subsystem. Thus the new ACTION decreases the probability of an intersystem LOCA upon failure of the interlock. This is a more restrictive change and the new ACTION is in LC0 3.4.14 Condition C of the improved TS. 6 23 LS 25 Specification 3.4.6.1 (Leakage Detection Systems) is revised such that the provisions of Specification 3.0.4 are not applicable. This will allow entry into the applicable MODES with only one of the Leakage Detection Systems OPERABLE, subject to the requirements of the ACTION statements. This change is consistent with NUREG 1431 Rev.1 and traveler TSTF-60 and is acceptable because of the diverse means available to detect RCS 1eakage. .Th/JFA1~ 2A-/9A &2A/&I gw. 6 24 M ACTION c of Specification 3.4.6.2 (Operational Leakage) is wd revised for consistency with NUREG 1431 Rev. I to require going to Cold Shutdown rather than going to Hot Shutdown f')N ( with an RCS pressure less than 600 psig. -This is e mie-cc at ri c;.i n a . _ ,, , , . . -... . . 29V4697 S&- /DB 0 3.+, /+- + 6 25 LS-26 Not applicable to Callaway. See Conve.sion Comparison Table (Enclosure 3B). 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 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 Rev.1. 6 27 A RCS leakage detection system descriptions are revised for consistency with current TS LC0 3.3.3.1 and FS.Q Sections 5.2.5.2.2 and 11.5.2.3.2.2 6-E LG rrent TS definition of CONTROLLED L eleted to be co i nt with NUREG-143 . . The RCP seal' water return flo 8 moved to a licensee controlled document. S Jection ' tions are established by thy .ow balance test procedur ed from
.rhtscAY~ SA-/DC ~
Q .v.s.c .2 DESCRIPTION OF CHANGES TO CURRENT T5 12 5/15/97
CHANGE f,- NUMBER f$liC DESCRIPTION
! j CT . licensee controlled doc nce Q 9, 5. 5,:2 CN 2-15 LG of Enclosur A-4 conversion package) and by the thr e position lance in TTS SR ...
7-01 ZNfCAY SA-13' & 3% /f-3 Not applicable to Callaway. 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 MODES 1, 2, or 3 with (T,,) 2 500*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 the ACTION requires the plant to exit the LCO's revised Applicability. This change is F acceptable as offsite release of radioactivity in the l' h>ik event of an SGTR is unlikely for operation below 500*F, as the saturation pressure of the reactor coolant is below (V ) the lift pressure settings of the main steam safety and [SG atmospheric steam dump] valves. 8 02 LS 17 This change, in conformance with NUREG 1431 Rev.1, adds an exception to LC0 3.0.4 when oper.ating in ACTION a, which is not in the CTS. This would allow H0DE changes under conditions that the plant is anticipating a return to acceptable activity levels within the 48 hour A0T. This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to, power operation. 8 03 LS 18 This change, in conformance with NUREG 1431 Rev.1, revises the sample frequency from 72 hours to 7 days for performance of a gamma isotopic analysis. The 7 day frequency is acceptable based on the low probability of a gross fuel failure occurring which would significantly alter the analysis results. 88-04 H Consistent with NUREG 1431 Rev. 1, the CTS requirement to measure Iodine including I-131. I 133 and I 135 is i DESCRIPTION OF CHANGES TO CURRENT TS 13 5/15/97
1 INSERT 3A-12C Q3.5.5-2 The current TS definition of CONTROLLED LEAKAGE is deleted as discussed in DOC 1 LG in Section 1.0. The RCP seal water retum flow limit is moved to a licensee controlled l 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 S 5.2.7. This surveillance ensures that the ECCS analyses remain valid. Since facility perform nce and operational details of the type embodied ; by the RCP. seal water return flow limit are r' quired to be described in the FSAR per ' i 10CFR50.34, it is acceptable to move the quirements of CTS LCO 3.4.6.2.e and CTS SR i l 4.4.6.2.1.c to the FSAR. t l J.S.5./, o i i I I I l l
- i o
I l l-l i l l 4 '3-- y. = * * *'w-a'r
I i jh 1 (
! EwERGENCY CORE COOLING SYSTEMS 4
i i SURVEILLANCE REOUIREMENTS (Continued) . 1
- 2) A visual inspection of the containment sump and verifying that
- the sunsystem suction inlets are not restric*.ad by Aebris anc .
4 that the sump components (trash racks, screens, etc.'.) show no l evidence of structural distress or abnormal corrosion. l ,
- s. At least once per 18 months [:-' ; "tdr , by:
Verifying that each automatic valve in the flow path actuates y[ Y 2-/f-l G 2-/7-A j 1) i to its correct positiorbs :. ___ 0 '_;t, ____. hj;:th;
, _ _ . .t;t .,isa;.1 ;;..:/;r %ll-Q
~ . . . _
.e..s.__ ......
. . . . . . _' :r ' ; =i n:id=t ci". u n ta hj: ^' = 2:t :';;:1; and l
l 2 Verifying that each of pc following pumps start automatically 2-/NA j
'-t c' : !:":t; :tient::t:ign:} pjj g l a) Centrifugal charging pump, fg f
b) Safety Injection pump, and g pg , , c) .RHR pump. .. l 4 IA/ TEXT 4 , .m . ___& _, . ,_,, .,__ _ _ _ 2_.._,___ .u _ .,__m '
,>-f2-LG 1 3,4 S;; $ c . ,...__2.,_. . . , . . . , _ . . . . . . . . . . . . . . - . . . , , _ _ . . . . , -
a cxi . ;.htix : - tx e:=d p;r:x:: = l d'_ __~. .r.:.tn_h :
,.r,....r; l r..~........m.
_ . _ _ . . .,__,2 \ as aum ...,.. ~.. .u, v.-r ;,, . . . . r.., i. , . r.
. a+. -. . . . , . . . __ . ,,,a __,2 __s g .g; .y s> .m . n, . u n. . . . ,. ,. ;_ .. .. , . . . , -- - .
.... m ,er
- m~; .:, . .,- .., ,._,.
.,.1s.._ ,
. ~ l h g. By verifying the correct position of each mechanical position stop j for the following ECCS throttle valves %
, _ , , _ . , _ _ ___ , .,__ .,___m ...,... ...
.,m.._ -
..,..._a.
,m__
o
. s, .. . . .
m .._ ,.._ . _ __ or_.m___d /7_"TR
.y....... . - . . . . . . . . . . . ... .. ..... ...... -.. -
4 ___.1__;
. . . . . , . . . . . .__ m. .. . sa. .n .t*n. a_n t_t- , ___,. -
j , . , ,
, 43- /t least once per 18 months:A. .
? 2
- HPSI System CVCS System a -
valve Numoers valve Numoers ., 2.d4.f EMV095 EMV109 BGV-198 l EMV096 ENV110 BGV-199 f EMV089 BGV-200 O'8 M~~2 i EMV097 EMV098' EMV090 ENV091 BGV-201
-202
)
l EMV107 i D4V108- EMV092-i t i
- "~2: ;;;;Pi:d 1.". 2 t'. ' ; ;2 j xy 5: ;:h-d S- Cich ! ,.. .-:ded tM 2-/f.A.
j rr ::'"- :: S ;;rt rnd ; 2:r *- --:t -t # r " " ; + " #8 --t --12:' ; t x ..,... x ;; er _.s.....,...............r...........
.' c.; 1, '000, _r.ir.;;;r
_. , __ __ ;x ___ r. ___"_r;t.
*h F . . i .tx .'
...m.........
j .v 4 )p .CALLAWAY - UNIT 1 2/45-5 Amendment flo. S i i 4
'O . \
i 1 i 4- 1
, .. .- =-
( y g y c7 f l_CO) 2-20-/k) Ac1 Injection Flow
$ 3. 5 5~.2 3' 'S G 3. 55-:2
- g y 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)
[ 3.5.5 Seal- Injection Flow g, b e c4 Act re,,I zskas " N 1 l. LCO 3.5.5 Reactor coolant pump seal injection flowVshall be [?0 gpm
~: 2?GF- with -{ cent *i#"; 1 ch:r-4n; ;"- ditch:rst header' pr;ssu]V ra _ )
.~R.
- _i[?'80 psig and the harging flow $ control valve full 5'. 5~-4 open.
/:
l N j j Ne c +S~ -2)fst a/05(A*r hhfereeh"* l lek e *n f osder and R C,.C7 ver.ruve APPLICABILITY: MODES 1, 2, and 3 N g7 i . ACTIONS
-~
- CONDITION REQUIRED ACTION COMPLETION TIME A. Seal injection flow A.1 Adjust manual seal 4 hours I not within limit. injection throttle
- valves to give a flow within limit with4
[a/cq+p2 4N [ cent-4 #uge' chargin;
- e; dischargc
/// //M"ea ~I 3,6v,,,, ./f e
'5' -100d0r) pr0000i;
% s romen, em ~4~-and the c/s,7f * /,,,/,r
- cm and Ec.r/ wave Jcharging flow 8-ocontrol valve ) full
. open.
7 B. Required Action and 8.1 Be in MODE 3. 6 hours associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours i
$AW"Ub 0 0$ NS $EV l fAlUfEG-j4Jj}
- EC ST: 3.5[l3 -Rev 1, 04/07/00
l [NEW CT.T L C4) 2-DO Seal Injection Flow f):P,5l5 2, 3.5.5 Q 3. 7S--2 l
,) SURVEILLANCE REQUIREMENTS d I
- SURVEILLANCE _
FREQUENCY l
?
SR 3.5.5.1 -------------------NOTE-------------------- 1" ! Not required to be performed until 4 hours - after the Reactor Coolant System pressure
,j"r/
fof(+r
// '"aM.a} / stabilizes at 2 2215 psig and
[_2255psigp. 1 Ja ka a, -H,a _______ l cL ,3 /,,,,/,r / Verify manual seal injection throttle ~2 ,r_.g an/y#c.r / valves are adjusted to give a flow within -21 My: Nis
/t man-greee w-c. } limit with*[mtrifugi' 6rghg p;;;;p
/ d uch;rg; h;; der] prassur; i [2.400] paig-and the harging flog control valve full open. g - '
6 l a 5.j .. .- F, . e i J
/
j thAMX-W of~N06 E'T*f XEV / (AlukEG-H3th 3.; 1, C'lC7lC5
- ucc sT s-- 3 5- 0
p CHANGE I I NUMBER HSliC DESCRIPTION s restore the pump operability without delaying startup. L The four hour limit is unchanged. Changing "one or more" to "all" is still bounded by the 4 hour limit. Tht change is consistent with NUREG 1431 Rev.1. $ 3.5.5-2 l 2 06 A M % verflance of .HeA,ma sa)/ u,i)n, xeehan /haHla r r rg 3:s:s. i l< valvp w,itreh and Will saDe, J,e It-mn-IA surve;//enea _f>.epency, i 2 07 A Consistent with NUREG 1431 Rev.1, this change revises Ine < ' surveillance to make it clear that the " 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 - Not applicable to Callaway. See Cor. version Comparison Table (Enclosure 3B). 2-09 LG The visual inspection surveillance performed when
, establishing containment integrity is moved to a licensee Q controlled document. "ci t t H E t g cf requir m rt B h[,h a nnekte t "ith unngg 7 3; g , ;, f g fgg y yA , 34 g f.5,2-2 / \i f
U/ 2 10 A Consistent with NUREG 1431 Rev. 1. the current TS SR for verifying interlock action of the RHR system is moved to improved TS SR 3.4.14.2. 2 11 TR-1 Consistent with NUREG-1431 Rev.1, .the ECCS pump and valve actuation SR is changed to allow the use of an actual signal,~ if and when one occurs, to satisfy' surveillance requirements. The specific signals used to actuate the pumps and valves have been moved to the Bases. ZNTEM SA-3B & ' *
- 3 2 17. LG The ECCS pump performance is revised to be consistent with NUREG 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 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.
14SEAY 3A-SC Q2.S.2-+ 2-13 TR 3 The current TS allowance, which permits the ECCS throttle valves to 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 to be consistent with NUREG 1431 Rev. 1. The ECCS DESCRIPTION OF CHANGES TO CURRENT TS 3 5/15/97
.%e
CHANGE NUMBER E DESCRIPTION throttle valves are manual valves and plant procedures governing post maintenance test requirements specify verification of correct throttle position prior to declaring the valves OPERABLE. Explicit oost maintenance TS surveillance requirements have been deleted because these requirements are adequately addressed by administrative post maintenance programs. 2 14 A The note providing a one time extension of surveillance intervals is administrative 1y. deleted since it is no longer applicable. 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 NUREG 1431 Rev. 1. EA/IEg7 3'/)-4A S F. 5 .2 - 5 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.A Q y.4 D-6 ;
rN rERY 3A-+8 g 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 clarification.
Valves that are secured in place are secured in the 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 18 - Not applicable to Callaway. See Conversion Comparison Table (Enclosure 38). 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. INfERT 7A-fc Q y.5.2-P h M ZAuteT 3A-4E 47 35"S;-2 3 01 LG Consistent with NUREG 1431 Rev.1. the LCO is revised to replace the word " subsystem" with the wofd " train" and the descriptive information in the LC0 is moved to the BASES. Whereas there is no technical change associated with the replacement of the term " subsystem", " train" better > describes that all parts of the required system (e.g., j
) piping. instruments. controls etc..) must be OPERABLE to support the required safety functions. ,
SNTER7 2A-+b & 3.C.3-I DESCRIPTION OF CHANGES TO CURRENT TS 4 5/15/97
- i. .. :
J INSERT 3A-4E Q 3.5.5-2 1 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. , r t f i i. F 3 1 i i i i 4 l 4 i h [ i l
Q )-Q) J(%.f 'J V@ (m v Page 2 of 6 CONVERSION COMPARISON TABLE - CURRENT TS 3/4.5 TECH SPEC CHANGE APPLICABILITY DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY NUMBER DESCRIPTION Yes Yes Yes 2-01 The LCO and ACTION a are revised from " subsystem' to " train" Yes LG and the descriptive information in the LCO is moved to the BASES. Yes Yes Yes ; 2-02 Allows isolating both SI pum flow paths for up to 2 hours Yes LS-1 to perform PIV testing in MODE 3 without declaring either SI train inoperable. Yes Yes Yes Yes 2-03 Revises Action a to address circumstances where 100% of the LS-2 ECCS flow equivalent to a single OPERABLE ECCS train is available. Yes Yes Yes Yes 2-04 The requirement to submit a Special Report within 90 days of TR-2 an ECCS actuation and injection event is deleted. No - This note is Yes Yes Yes 2-05 Allows operation in MODE 3 pursuant to the LCO for ECCS _ the RCS not in the current LS-3 Su pbs ado"6 cold 1 ?_ _7
~
N ' N g myerature setpoint in lieu of "one or more". _
" ~'"-' $ W Y s Y **0eW N Ns4.?s.1 Wa%.wA cR,7%, -wA- 2 g g.%.,-7, -ws-yar ++-yaz g g.s .s !
205A Yes Yes Yes / Clarifies tha It"he1t$rIeb $ c N N a D ie[ u Y 7 ' Yes s_ ! A M & t Q ion in the controi roo Qmt may also be % satisfied using soca ooservation. No - This note is Yes No - This note is No - This note is 2 08 The accumulator discharge valves and their note are not in the current not in the current not in the current A functionally part of the ECCS accumulator subsystem covered TS. TS. TS. by igroved TS 3.5.1. Yes Moved to Yes - Moved to the Yes Moved to Yes - Moved to FSAR 2-09 The visual inspection surveillance performed when Section 16.5. TRM. Chapter 16 of the LG establishing containment integrity is moved to a licensee FSAR. USAR. controlled Am=*nt. No - This SR is not Yes Yes Yes i' 2-10 The current 13 SR for verifying interlock action of the ElR A system is moved to i g roved TS SR 3.4.14.2. in current TS. Yes Yes Yes Yes 2-11 The ECCS ptmp and valve actuation SR is changed to allow the TR-1 use of an actual signal to satisfy surveillance , requirements. 5/15/97 CONVERSION COMPARISON TABLE - CURRENT TS
CONVERSION COMPARISON TABLE CURRENT TS 3/4.5 Page 3 of 6 IECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 2-12 The test method and specific data required to verify ECCS Yes Yes Yes Yes LG pump performance are 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 cu: Tent Yes No Not in current Yes A TS. TS. . 2-15 The surveillance requirement for the flow balance test Yes - Moved to the Yes - Moved to TRM. Yes Moved to t!SAR Yes Moved to FSAR LG following ECCS modifications is moved to a licensee FSAR. Chapter 16. Section 16.5. controlled document. , 2-16 The method for ensuring the ECCS system is full of water is Yes Yes Yes Yes 3 LG moved to the Bases. 2-17 Adds the phrase "that is not locked, sealed, os otherwise Yes Yes Yes Yes A secured in position" with regard to which valves require actuation testing. [ 2-18 The CPSES requirement for venting the ECCS pum 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 Noves the requirement that the 18 month verification of No - DCPP does not No - CPSES does not Yes Yes t LG automatic ECCS valve actuation and ECCS pug actuation be have this have this performed during shutdown to the Bases. restriction. restriction. l 3-01 The LCO is revised from " subsystem" to
- train" and the Yes Yes Yes Yes LG descriptive information moved to the BASES.
i 3-02 Low te m erature overpressure protection limitation on ECCS Yes Yes Yes Yes LS-4 pug s and related surveillances are moved to Section 3.4.12 ' in the igroved TS. The prescriptive wording related to pump operability is changed to wording specifically l addressing the pug s* capability to inject into the RCS. U I D .fta h c , f 3 CONVERSION COMPARISON TABLE - CURRENT TS 5/15/97
( NUREG 1431 SPECIFICATIONS THAT ARE NOT APPLICABLE C Soecification # Soecification Title Coments e m , ., ,_u1, - _ -, _ e_., ,_2__m.__ , , _ . . __1_
..s.... . . - . osu 14 n.n.k__$_.._
s&_ k. nm e , am*-,A=L _L
.,-.I-
*L an?""d-a th^ LOCA onolyaia "r"-ti r.: for 3efet,
<_,._ :__ x, . . . . .. -
- i i ag. . w a vs . us a 6 VUI UW bV bias cc-^ :r; at. ill b; cc,Lred Luiac,cu b; *"- Y "_",'u.,
____a..__ _ _-
. -r.n Q 3.5*5
.3.
- ya _ _ - _ _ - _ _ .w ....sw.g. wv s wrws en 1 <r i _t -
- u. .or es . - s ., . ......,m
,g_ ._ _x2__ n ,e ee >
___v.
.r--- ** "u we r__,__..__ , , "s _m m u_
, . . . . . . . . w . . . , .... .,,, . . . .
7 15. Vbb3. .u.YL grv., g 4. 3 v. , m........ 2._.. ,.r. e en
,e -
-.. .u.i.
. 3.5.6 Boron Injection Tank (BIT) The BIT has no safety-G.j*,,,iO "c " : 4*"'"
s retired in place,
,f \
t MARK UP 0F WOG STS REV 1 (NUREG 1431) 5/15/97
ECCS Operating 3.5.2
, ~( SURVEILLANCE REQUIREMENTS (continued) \g)
I SURVEILLANCE FREQUENCY SR 3.5.2.5 Verify each ECCS automatic valve in the flow 18 months r~ m8 u path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal, SR 3.5.2.6 Verify each ECCS pump starts automatically on 18 months teWBmA an actual or simulated actuation signal. Q 3.SP2 SR]l5#23 Verify. for each ECCS throttledilBSib 18 months menx amm66 valve listed below, each tE325:3 a
. cal. position stop is in the correct Valve >=har EesatSs
( ) ENV0095 ENV00% ENV0107 EMV0108 ENV0089 ENV0090 VN
$2 /)
8 7# #~2
~
ENV0097 ENV0109 E55051 l 00 ENVO.098 ENV.0110 ENV0_092 _. _ . 1 02 SR 3.5.2.8 Verify, by visual inspection, each ECCS train 18 months wasnsa containment sump suction inlet is not restricted by debris and the suction inlet trash racks and screens show no evidence of structural distress or abnormal corrosion. MARK UP OF WOG STS REV 1 (NUREG 1431) 3.5 7 5/15/97
Seal Injection Flow 3.5.5 a3.5s-a g
~
3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) [ 3.5.5 Seal- Injection Flow h eac4 sci ruI zs*as LC0~ 3.5.5 Reactor coolant pump seal injection flowVshall be [iO]Vgpm with [centrife;21 ch:r~i gn pu=p disch:rg; headcr] pr;ssure _ _ t [2d 0] psig and the harging flow $ control valve full 7. 5d , open. f
+S APPLICABILITY:
-H e e a /DS(Aor)
MODES 1, 2, and 3 N g t a,Je< ond f 7 M c,rprenure2)fst l ACTIONS
=
- CONDITION REQUIRED ACTION COMPLETION TIME
~
A. Sea njection flow h.1 Adjust manual seal 4 hours not within limit. injection throttle 4
' valves to give a flow within limit with4
_. [ centr 4 fugal cha ; h; - [ a "fog //N"'a
+q-2~I *
- " p d Sch:rg; (J,1w,,x -/f e i]1 t
. 0;d0r] pr0000iG f a,/,r ,
tu ' s renon, --" an fcha[ging"fiowped the of,]7[#/*"""l
#^
Mcontrol valve full open.
/
4 B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion I Time not met. AND B.2 Be in MODE 4. 12 hours l fr1MK-Ul* OfW0&f7's fgy l (Nate g_jq S00 ST 3.5 [ p "eV 1, C4/07/ W
. - -. . - . - . - - - .. - . _ _ - . . ~ . - - . . _ _ - . . - _ , . ; Seal Injection Flow i
3.5.5 Q 3'. r s:-p
+ ?
[% n
\ SURVEILLANCE REQUIREMENTS , s 4
i SURVEILLANCE _ FREQUENCY SR 3.5.5.1 -- -
-----------NOTE--------------------
Not required to be performed until 4 hours after the Reactor Coolant System pressure i 1 stabilizes at h $2215 psig and
, u/gf(+r/,< .2 <mh) / s 2255 psig3.
i q ______ A___g __________ ______________ [Je + ween die 1 ] c6 r3 /,,/,* / Verify manual seal injection throttle ~y g g on ges / valves are adjusted to give a flow within -31
/fday:mo,rM r
; gre.r.r a-c. limit with*[ca-tH f'2;21 6:qh; p;;.p I
- ] dh:h;rg; h;; der] pressur; i [2000] piis- )
and the harging floq control valve full l
; open. p 1
i.m p ::,q
~g.
l l O
\x .J -
thAKK-W WkoG h"J KEV / (A/uges-ll.1i) l3 *) j ',, ^0 ';T5 - 3.5- . V 1, 04/07/05 (
ECCS Operating 8 3.5.2 l BASES SURVEILLANCE SR 3.5.2.7 REQUIREMENTS (continued) "c;11,. cr.t M of M valves in the flow path cr. ;r. 01 mgnet is necessary for proper ECCS performance. These valves have M stops to allow proper positioning for restricted flow to a ruptured cold leg, ensuring that the other cold legs receive at least the required minimmi flow. Tt.i; 0;r;;illere; is ret required for pier.ts 'itt r; li;itir,;; erific;;. The 18 month Frequency is based on the same reasons as those stated in SR 3.5.2.5 and SR 3.5.2.6. 2'NTEg7~ g 3', E-22 S 3', 6 ~ 1 l l l SR 3.5.2.8 l Periodic inspections of the containment sump suction inlet ensure that it is unrestricted and stays in proper operating condition. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, on the need to have access to the location, and because , of the potential for an unplanned transient if the Surveillance l were performed with the reactor at power. This Frequency has j bj V been found to be sufficient to detect abnormal degradation and is confirmed by operating experience. i REFERENCES 1. 10 CFR 50, Appendix A. GDC 35.
- 2. 10 CFR 50.46.
- 3. FSAR Section M (reJ he)
- 4. FSAR, Chapter " Accident Analysis." l 3' #'S-I
- 5. RC Memorandum to V. Stello, Jr., from R.L. Baer, "Reconnended Interin Revisions to LCOs for ECCS
, Components." December 1,1975.
- 6. IE Information Notice No. 87 01.
E N g cas o m.! s o r I g x - .1. ,$. f _s gj r a v .- o , MARK UP OF NUREG 1431 BASES B 3.5 22 5/15/97
)
i
INSERT B 3.5-22 I 4
-k The ECCS throttle valvesNMeWrt4Mr6InefaNd5 are set to ensure proper gyA5:.2 flow resista;e.e and pressure drop in the piping to each injection point in the event of a LOCA.
Once set, th?se 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. U O
Seal Injection Flow t l B 3.5.5
/"' . B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) h ?.G5-2 B 3.5.5 -Seal Injection Flow I
BASES. BACKGROUND This LCO is applicable only to those units that utilize the centrifugal charging pumps for safety injection (SI). The 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 charging pump header to the Reactor Coolant System (RCS). I ) The restriction on reactor coolant pump (RCP) seal injection i 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 SI. APPLICABLE All ECCS subsystems are taken credit for in the large SAFETY ANALYSES break loss of coolant accident (LOCA) at full power L
.q (Ref. 1). The LOCA analysis establishes the minimum flow for the ECCS pumps. The centrifugal charging pumps are also . I credited in the small break LOCA analysis. This analysis Q' i O
establishes the flow and discharge head at the design point for the centrifugal charging pumps. The steam generator tube-rupture and main steam line b ak event analyses also ! credit the centrifugal charging p s, but are not limiting in their design. Reference to th e analyses is made in assessing changes to the Seal Inj ction System for l evaluation of their effects in r ation to the acceptance limits in these analyses. ,74ggg7 g g ,6_yg. l This LCO ensures that neal in.iection flow lif [40 pm, , l 4 s d o ve 1 n, ) l will >e suff' cient for RC ) seal integrity but limited so that the ECCS trains will 'be capable of delivering , sufficient water to match boiloff rates soon enough to i l minimize uncovering of the core following a large LOCA. It i also ensures that the centrifugal charging pumps will , ( deliver sufficient water for a small LOCA and sufficient boron to maintain the core suberitical. For smaller LOCAs, the charging pumps alone deliver sufficient fluid to ! overcome the loss and maintain RCS inventory. Seal , (continued)
'~~
f WOG STS B 3.5fN Rev 1, 04/07/95
- g. r-! -g .,y 4 , y .m ..---w- --..,.-& -
INSERT B 3.5-34 Q 3.5.5-2 r (x The safety analyses make assumptions with respect to: (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 ranges of pump performance are used to calculate the maximum and minimum ECCS flows assumed in the safety analyses. The CCP maximum total pump flow SR in FSAR Section 16.5 ensures the maximum injection flow limit of 550 gpm is not exceeded. This value of flow is comprised of the total flow to the four branch lines of 469 gpm and a sealinjection flow of 79 gpm plus 2 gom for instrument uncertLinties. The Bases for LCO 3.5.2, "ECCS - Operating," contain additional discussion on the safety analyses. r (x l I l l l l 1
- l
! l i e 4 w i l l - . . . - - - - - . .
- 1
Seal Injection Flow B 3.5.5 :
~ 9 2.r..r-2
%Q i( BASES V
'~' :
APPLICABLE of SAFETY ANALYSES injection
-St:t;;=t. flow satisfies3T
/4 cFA'527. Criterion (c)(O 2(77)the NRC "cli;y (continued)
LCO The intent of the LCO limit on seal injection flow is to make sure that flow through the RCP seal water injection line is low enough to ensure that sufficient centrifugal charging pump injection flow is directed to the RCS via the injection points (Ref. 2). rNtee y-f~ f.r.s-SS The LC0 is not strictly a flow limit, but rather Ia flow limit based on a flow line resistance. In order' to establish.the proper flow line resistance, a pre: sure and flow must be known. The flow line resistance isF&te=4aad by =: ria; th:t th; "CS prn = r: i: it aarm1 anar=+4a; prz = = .ad th:t th: =ntrifusel chtr 4ac r"=a disch r;:- prette-- 1: ;riter th= er ;.;=1 t; th: v:lut :;=ified in thi- LOO. The centrifugal charging pump discharge header pressure remains essentially constant through all the applicable MobF.! of this LCO. A reduction in RCS pressure would result in more flow being diverted to the RCP seal (eN. injection line than at normal operating pressure. The valve / 3 settings established at the prescribed :::trif ;:1 :hr;in; #/Md/a/-
* - 7" r ditchr;; hndr pressure result in a conservative valve position should RCS pressure decrease. Th; ;.dditieuel-
- di'f r cf thi: LCO, the ceatrel J:lv: (chr;ing fle.i fer
-feur '.re; : it: rd :ir :;:nt:d :n1 ir.jectic fu thn:
-100; c:it:) 5 ing f ll ;ps, i; requir d eiace the i;in i:
-dai; rd te fai' :;= fu th: =:id;.at e.aditien. "ith the
- d!: 9 2 ge peace"*e ,:-d ::tr: 1 4:1-_<,Je pe;itiea.e; ;;nifi d
<.<_,,o _ , , _ .. ._ __ >
, . . . . _ , . . . . . . .... 4
- n. .2 wii. . - .. v.,
-li it th:t i: an d in the ex id st a ;1.7;e..
The limit on seal injection flow,Y r iind with the
-c==+ru";=1 chaegi ; ; ; di;;terge header pranr: li::M-
- 2nd 2 c;e- Mde crediti ,
f th: :hr;in; fic = tr;,1 niv:, must be met to render the ECCS OPERABLE. If these conditions are not met, the ECCS flow will not be as assumed in the accident analyses. APPLICABILITY In MODES 1, 2, and 3, the seal injection flow limit is dictated by ECCS flow requirements, which are specified for (continued)
}
WOG STS B3.5 7 Rev 1, 04/07/95
~wT
INSERT B 3.5-35 Q 3.5.5-2 l
- v established by adjusting the RCP seal water injection throttle valves (BGV0198, BGV0199,
- BGV0200, BGV0201, and BGV0202) such that flow to the RCP seals is limited to 20 gpm per pump in the event of a large break LOCA. This accident analysis limit is met by positioning the l valves so that the flow to each RCP seal is 7.5 0.5 gpm with a 105 (+5, -2) psi differential l between the charging header and RCS pressure with BGFCV0121 full open. 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 ! L maximum and minimum total system resistance; (2) both the maximum and minimum branch j injection line resistance; and (3) the maximum and minimum ranges of potential pump l performance. These resistances and pump performance ranges are used to calculate the
- maximum and minimum ECCS flows assumed in the LOCA analyses of Reference 1.
l t I l l i Q l
\
} l L !
l l
)
i i l k l I i l a+ - . > + -s
.m, ,y. .
y e - --
- - -w 'T-
Seal Injection Flou B 3.5.5
$ 3. C~- 2
(' BASES h APPLICABILITY (continued) MODES 1, 2, 3, and 4. The seal injection flow limit is not applicable for MODE 4 and lower, however, because high seal injection flow is less critical as a result of the lower initial RCS pressure and decay heat removal requirements in these MODES. Therefore, RCP seal injection flow must be limited in MODFS 1, 2, and 3 to ensure adequate ECCS performance. ACTIONS A.d 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 ge, /J flow is..known to be above the limit to correctly position injee#en-&dn, the manual + valves and thus be in compliance with the accident analysis. The Completion Time minimizes the potential exposure of the plant to a LOCA with insufficient injection flow and provides a reasonable time to restore seal injection flow within limits. This time is conservative with respect to the Completion Tims of other [; -g ECCS LCOs; it is based on operating experience, and is f .--
\ sufficient for taking corrective actions by operations EW; 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 safet'r rystems or operators. Continuing the plant shutd',wn btgun 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. (v (continued) ; v WOG STS B 3.5- [ a Rev 1, 04/07/95
Seal Injcction Flow B 3.5.5 Q 3. S. 5-2 BASES (continued) d %./ SURVEILLANCE SR 3.5.5.1
/f men O j# *'g#
REQUIREMENTS Verification every-31 d;ysV that the man al seal injection throttle valves are adjusted to give a low within the limit ensures that proper manual seal inject'on throttle valve
.rNTEg position, and hence, proper seal injec ion flow, is maintained.+ The Frequency of-31 d;ys.is based on 8 7.f-77 engineeringjudgmentan41:::::i:tentwith ether Eccs v:lv:
Surv:ill:r.:: Fr;;n acie . The Frequency has proven to be acceptable through ope ting experience'
.H,e con heitlf *cedon N* f"ihW As noted, the Surveillance is not required to be performed g'fy*#-
until 4 hours after the RCS pressure has stabilized within a 20 psig range of normal operating pressure. The RCS pressure requirement is specified since this configuration will produce the required pressure conditions necessary to assureuthat the manual valves are set correctly. The exception is limited to 4 hours to ensure that the Surveillance is timely. f% REFERENCES 1. FSAR,-Ch:pt:r [6] :nd Ch:pt:r [15]. Te che,,, l.7,,,/ /G.E. .( )g) 2. 10 CFR 50.46. m ( WOG STS B 3.5[.r7 Rev 1, 04/07/95
~
INSERT B 3.5-37 Q 3.5.5-2 (b \ The seat water injection 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. The seal injection flow line resistance is established by adjusting the RCP seal water injection throttle valves (BGV0198, BGV0199, BGV0200, BGV0201, and BGV0202) such that flow to the RCP seals is limited to 20 gpm per pump in the event of a large break LOCA. This accident analysis limit is met by positioning the valves so that the flow to each RCP seal is 7.5 0.5 gpm with a 105 (+5, -2) psi differential between the charging header and RCS pressure with BGFCV0121 full open. Once set, these throttle valves are secured with locking devices and mechanical position stops. b j f v
-. _ . _. . . - - - . ~- -
- - - - - - - - - - - -- "' ~" ~-~
l, i CHANGE i( n' NUMBER JUSTIFICATION i
- incapable of injecting." The wording change makes the Note consistent
lC l with the wording used in LC0 3.4.12. These changes are consistent with traveler TSTF 153. 1 3.5 9 [ ~ in ' tion /r urn va s (BGV BGV02 are uded ITS i S .5.2. since y are cluded CTS 4. . .g.2). hese lves ! i ave t ottled sitio to be v ified s' lar to e ECC thrott ' lv which re lie in t R per N G 1431 ev. 1. TNTE W 4A-2. & s s .s -- 2 1 l l 1 qr w g a 1 f nby l m JUSTIFICATION FOR DIFFERENCES - TS 2 5/15/97
-~ _..__ _.__ _ _,_ ,_ _ ,_,_, ,_, ._ --- ._ _ _ ,_.,_._ ,_ _ _ _ _
l l I v"" - INSERT 6A-2 Q 3.5.5-2 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. 1 j l l P. i I l
>* Wop -p,%,m,,
,-yv 4, -
, , - - - _ _ - -_ q ., .- , - . - - y- ,.--.. - -r,.,,7 ,_ _ ,, .,
(C
)
V { J-l} V _> CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431. SECTION 3.5 Page 1 of 1 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION OIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.5-1 Replaced " pressurizer pressure" with "RCS pressure." Yes Yes Yes Yes 3.5-2 The completion Time of LCO 3.5.1. CONDITION B is changed No - Not part of No - Not part of Y:: L'..... Yes - Current TS from i hour to 24 hours to reflect the current TS. current TS. current TS. per OL Amendnent yf k.._ . *E
- h. _/.. No. 91. LQ 3.C. l - 2.
3.5 3 Adds the word " mechanical" with regard to throttle valve Yes Yes Yes Yes position stop consistent with the current TS. 3.5-4 This change increases the RCP seal injection flow Yes Yes No - LCD 3.5.5 is No - LCG 3.5.5 is Co gletion Time from 4 to 72 hours, with a new added not applicable. not applicable. verification that at least 100% of the assumed charging flow remains available. 3.5-5 Deleted reference to centrifugal charging pum discharge Yes Yes No - Not part of No Not part of header pressure to reflect current TS. current TS. current TS. 3.5-6 SR 3.5.3.1 Note is moved to the LCO per traveler TSTF-90. ; '-p Yes Yes Yes 3.5-7 Not used. l x, < N/A N/A N/A
-W 3.5 8 Noves the Notes from the Applicability for ITS 3.5.2 to % l" Not part of Yes Yes Yes LCO. Also revises the wording in Note 2 from " declared ; t trent TS.
inoperable" to "made incapable of injecting." . p 3.5-9 A :::'
- t' ':n '. A ., f;;: "'"^!^" "'""'"? ? :-- i 'b - Not part of No - Not part of Yes Yes
'n:Ed:d '- IT, S 3. .2.7 f.-;; N e 'n:hf.d '- current TS. current TS.
-cts : .", . i. g .D . .7_"Aff'G'W $ g.-l 0 S S*S2.
l CONVERSION COMPARISON TABLE - NUREG-1431 5/15/97
)
INSERT 68-1 Q 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.
.. g. h++.
ADDITIONAL INFORMATION COVER SHEET q ADDITIONAL INFORMATION NO: Q 3.6.1-6 APPLICABILITY: DC, CP, WC, CA
}
REQUEST: DOC 2-05 LG DOC 2-06 A JFD 3.6-1 CTS 4.6.1.1.c (Wolf Greek) 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 1. 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 concems with regards to CTS 4.6.1.2.c and 4.6.1.2.d at Comanche Peak. Also see Comment Numbers 3.6.0-2,3.6.2-5,3.6.3-27, O 3.6.3.28 and 3.6.3-37.
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Comment: Licensees should revise their submittals 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) was reviewed for 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 will incorporate 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 supplemental resoonse. The FLOG understands that with these changes the NRC staff approves incorporation of TSTF-52 into the ITS. For CPSES, the incorporation of TSTF-52 negates changes made under licensee initiated change CP-3.6-005 and thus CP-3.6-005 is withdrawn. O k ATTACHED PAGES: Sec.1.0, Encl. 2 Sec.1.0, Encl. 3A Page 2 Sec.1.0, Encl. 3B Page 2
r Src.1.0, Encl. 5A Travtlsr Strtus Pags,1.1-3 Sec.1.0, Encl. 6A Page 3 Sec.1.0, Encl. 6B Page 2 Sec. 3.0, Encl. 5A Traveler Status Page Sec. 3.0, Encl. 58 8 3.0-10 ' Sec. 3.6, Encl. 5A Traveler Status Page,3.6-7 Sec. 3.6, Encl. 58 8 3.6-1, B 3.6-2, and B 3.6-3 Sec. 5.0, Encl. 5A Traveler Status Page, 5.0-30 ATTACHED PAGES: (Supplemental): ' Att. No. 4 CTS 1.0 -ITS 1.0 Encl.6A 3, Insert 6A-3 2, insert 6B-2 { Encl. 6B Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 2 3/4.6-12 ; Encl.5A Traveler Page 3.6-16,3.6-17 ' Encl. 5B B 3.6-4, B 3.6-5, B 3.6-7, B 3 6-29, and B 3.6-30 l j l (' ( j
l CHANGE NUMBER SU5TIFICl. TION s makes clear the application of SR 3.0.2 and SR 3.0.3 to surveillances j with frequencies tied to plant conditions. ! This change will eliminate confusion and misapplication of the ITS and l will ensure consistent application of SR 3.0.2 and SR 3.0.3 to these , , types of Surveillance Frequencies. This change is consistent with l traveler W M A T.Pr f 25~1 0 / 4-/ ' l- l-/2 74e }e4,,7.jgn ,$ cypy4:_7_c ,(gg , y ,., ,_, y,,,, ,. TMF-14 -f,18e ye de.h,,-j, ,.y g73 ,,) Oe*-mecoy/e 'rR-/,6-m4
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ZMTERr~ t'A-3 g ,, , l i ( 1 , e l ! l l i i I l l i ~ v JUSTIFICATION FOR DIFFERENCES TS 3 5/15/97 l . l
. . . ..- .-- . . . ~ . - - - . . - - . . ~ . . . ~ . . . .. . . ...-. .- . . - . - - . _ - .
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l Traveler TSTF-52,L...,vi. 7, deletes the definition of L.. Since L. is defined in 10CFR50, Appendix J, and ITS Section 5.5.16," Containment Leakage Rate Testing Program," it is redundant to include L. 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 i Specifications. L. is not used throughout the Technical Specifications and is defined in l Section 5.5.16. 1 l i i t f 4 s l j l . . . . . - . _-
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j i lx ti i s,,,/ xw,,/ ,F w< .H-CONVERSION COMPARISON TABLE FOR NUREG-1431 DIFFERENCES Page 2 of 2 SECTION 1.0 DEFINITIONS DIFFERENCE FROH NUREG-1431 APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY - r314arfsr Behy Tir+I flave felay va.r+, 1.1-9 The definitions of Channel Operational lest (CDT)Y[ ] and Yes Yes Yes Yes Trip Actuating Device Operational Test (TADOT) are expanded to include the details of acceptable performance methodology. Performance of these tests in a series of h['!'! sequential, overlapping, or total 6 steps provides the necessary assurance of arpropriate operation of the 8 channe1 r t3 ley ,o r Cre Vice , v 4 f fi c${ve ly , 1.1-10 This change is based on the current T5 definition of No - Not part of No - Not part of No - Haintaining Yes CONTROLLED LEAKAGE. This change is a clarification only current 15. current TS. 1515 wording. and does not affect the way RCS water inventory balances are performed. 1.1 11 Adds new example to ITS Section 1.4 to clarify survelliance Yes Yes Yes Yes frequencies that are contingent on both a specified frequency and plant conditions. CHANNEL CALzd M T3Dal /,{-/2 ~7~$e Ytb~ni'liehJ rr misJ 7a r.rn=-iHa ~v< dal=rir fer fe.r fer ler 7 R-/.e- M ' a-f Crb onol flersheewfi n t*lIbralfahl* Y*- m2.s jasar a.r.rocra-ledwell cals%1ron '
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CONVERSION COMPARISON TABLE - NUREG-1431 5/15/97 [ i
l__.__._....._._...._._...__.-__._._.__.._._______._--.._._._ l l l INSERT 68-2 $ jes.s.u-s] g 3 f,,/ ,/ !
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' Traveler TSTF-52, P. ;Lu 1, deletes the definition of L., Since L. is defined in l 10CFR50, Appendix J, and ITS Section 5.5.16, " Containment Leakage Rate Testing l Program," it is redundant to include L. as a definition.
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CONTAINMENT SYSTEMS hJ W/ SURVEILLANCE REQUIREMENTS - 3. G . 3 - 2N ) MJ /-o 4-LS
%, ~1 - c'l- L6 4.6.1.7.1 Each-25 in:F-containment s down upply and exhaust isolation valve (s)* shall be verifi fl anged -and- ci st 7- H-L5 once per 31 days, .snsert A n x e, E -m^
7- o 5 -t.3-2 c 4.6.1.7.2 Each " ...:.. urge containment shutdo( Q ua 2fY-o.1c.) stpey-antvxhust- , 7 4,u ' isolationonce valv per[i pits g.t y l 7-17-M least -
- nd associated fell eing each blank flange "a47:t:lhtien shell
- f the ti;ak Meak f;,4 test
- 3. u.3 -2 ) , ,,:rg:ehenprer:r!: nth:
- d t: P , is.1 p:ig, :nd ver4fy4r ; that wh;n the g ,5,3_u
.-=c::ered leakage rate fer th,::: -/:h:: :nd ihng::, inciding stas 7- i l -h ;k;;e, is edded je 'the l ';r h:k:g: raterTyp:
;11 ether dete-B 4saded C pursuant-ttr pen:tr:tiens,' the I l
Saeci'icatien 4.0. ch hined h:k:ge - 'han 0.00 L,.5-y g g 3u,9 q hu..'3-zgj
- ' 5.I.7.3 The r"= =tiva +4 thn+ =11 19 4 n>-h coat = 4 a---t -i n' purgM _' ". , g 1 -
- pply 2nd erh.ust isciation v:l" : haua baaa open during & c&lenda. 2.ip
-shall he do+=~i ,;d :t b::t :n:: per 7 d:ys. g 3J,,3-g3 J -
Y ra n.1 n r 4.6.1.7.Mt least once pe@ 3 nath: each 13 'n:h containment mini-purge *** * \ supply and exhaust isolation valve with resilient material seals shall be 'M'", demonstrated OPERABLE by verifying -thet the measured leakage rate,i h: 1 l -then 0.05 L, hin presesrized t: P,. g ) a 3.5, t-q 3 f, l84 daP uk Uh.;, 9t b.p d opeme A u Q3.6.3-17] i 1-o B.)K ( Mt.4 .ruert D t s,-u a 3.e.3-n t l l l i i 1 I ( et
- Except valves and flanges which are located insid containment.
These valves shall be verified to be closed with [.h:f r blank f i
. installed prior to entry into MODE 4 following each COLD SHUTDOWN, QNt pformc6 in previous 97. kp
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&N D WAT E' y 45 p p -ti-CALLAWAY - UNIT 1 3/4 6-12 Amendment o. & 103 Q 5.I,>.&
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bi , j INDUSTRY TRAVELERS APPLICABLE TO SECTION 3.6 TRAVELER # STATUS DIFFERENCE # COMMENTS TSTF 17 Rev. 1 Incorporated 3.6 2 NRC Approved TSTF 30, Rev. y l.- Incorporated 3.6-4 Ot eppi kabic iv Elf C.eek T'E TSTF 45, Rev. 1 ad C:lloway. A/EC $rP>W/ Sf] Incorporated 3.6 5 NRC Approved TSTF 46. Rev.1 Incorporated 3.6-7 NRC Approved 1 TSTF 51 Not Incorporated NA Not NRC Approved as of 1 Traveller entnff date TSTh2j Eno f Incorporated 3.6 1 ( kd '^3 , W #~~ #) fG3 ' I-la TSTF- Not Incorporated NA Not NRC Approv J as of Traveller cut f date E 014 Incorporated 3.6 11 @ y e a [ f g,,-_ _ 2 h 34.3-//l rf7F 2.'9 [ G < 14 n o-r..a W pu , . -- w_ _ ,. ---
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1 i. 4 U 5/15/97
_. - - ~ . - . . . . - -- . -. . - ~ _ . . - _ . - -. . . - . . . _._- - -. .. .. Containment Isolation Valv2s 'Ata;pheric. Subet;;.;;ph;ric. In Cendca;;r. end Ou;l) PS 3.6.3 A SURVEILLANCE REQUIREMENTS (continued) 4, SURVEILLANCE FREQUENCY
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og...fn ' 4 c hypto ##J ^ m =, n : = , - : =1 r o 3.g,3 2 ( l L -- n 3 . c, ,! 3, m.. lam Perform leakage rate testing for contai valves with resilient seals. 184 days
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3.6-19 B.PS . Alf _ w
' ' / Within 92 days k
{Q 3.c. i-Q d4 after opening
%_ _ the valve SR 3.6.3.8 Verify each automatic containment isolation E months -B valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation
( .. signal . Z 0.0.0.0 Cyci; ;sh .;;ight er .;pria; leaded ;teck velv; 10 Enth; B PS-
.et t;;t;bi; duria; ep;ietien thra;'. ;a; 3epict; cyci; cf full ti;;;1. ;ad verify ext
; tack velv; r; ;ia; cis;d A. tre differenti;l pr;;;ur; in tra diration of '10.;
i; s [1.2 p;id end ;Fn; ahca tre diff;rcatiel prs;;r; in tre diration of fia i; a [1.2 p;id ;nd : [5.0; p;id. - Z 2.0.0.10 '!;rify G;h [ ] irch cent;inant purg velv; i; [10 7.enth; B PS blak;d
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te intrict tre v;1v; fre egnia; L.sv g g . (continued) l MARK UP OF WOG STS REV 1 (NUREG 1431) 3.6 17 5/15/97
Containment Isolation Valves (Atzspreric. Substa;pteric. In 0;r.dcr.xr, r,d Dual' ps 3.6.3 SURVEILLANCE REQUIREMENTS (continued)
\ SURVEILLANCE FREQUENCY SR 3.6.3.5 Verify the isolation time of cut. p;n- TMiltXNtlR#d 3.6 7 epcret-d r.d each automatic .
_ R4ltl4RIE s containmant isolatinn va y , y ng cf.m. 31gglg $2 = ( ~ 1s 7.-y . , +i%sf3. G .~5 -II') within limits. ' cr 22 deis B-P5 s [G3.c.a r,. ( [G u P _N 7 .
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_ .a > ..... . r vuja eb (continued) 1 MARK UP OF WOG STS REV 1 (NUREG 1431) 3.6 16 5/15/97 l l l
Containment (Atr.cph;.-i;) . B 3.6.1
- BASES (continued) ;
ACTIONS- L1 i i In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The 1 hour Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining containment i 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
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l E If containment cannot be restored to OPERABLE status within the i required Completion Time, the plant must be brought to a MODE in I 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 l within 36 hours. The allowed Completion Times are reasonable, ,
' based on operating experience, to reach the required plant j conditions from full power conditions in an orderly manner and [
without challenging plant systems. l SURVEILLANCE SR 3.6.1.1 l REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the wW visual examinations and leakage rate test requirements of ggg ! Q 3.G.1- Gj '10 Cy 50. APP;.. dix 6 Ob6 L.. ..
. - . , , . , , , , . . . . . - _ . . . . . . , < Failure to meet l L air lock and purge valve with resilient seal leakage limits !
l ( ;p;;ifi;d ir. L;0 3.0.2 e..d LCO ~;.0.hs not invalidate the
< - ' 3h I~ acceptaD111ty of these overall leakage determinations unless l
- their contribution to overall Type A. B, and C leakage causes l L that to exceed l 1[ame3lER3B g , M li;its. As left leakage prior to the first gg j startup after performing a required 10 0"R 50- t.cr. dix J. ;
ContahinentRRiinlNWe@M5iTdsttigfrogEamjieakage' test is requi ! to be < 0.6 L, for combined Type'B and C leakage M C3 C l-la 3Trr between required leakage rate tests, the acceptance criteria is ; based on an overall Type A leakage limit of s 1.0 L,. At ! 4 O i .V (continued) L MARK UP OF NUREG 1431 BASES B 3.6 4 5/15/97 1 9 !. I
Containment (Atresphcric) B 3.6.1 1 O) sp# BASES SURVEILLANCE SR 3.6.1.1 (continued) REQUIREMENTS s 1.0 L, the offsite dose consequences are bounded by the assumptions of the safety analysis. SR Frequencies are as required by Appcadix 0, es redified by ;---- " -- "--- the Nwirn nvrawraarnate~Te~strn~g7 Prog Tl.us. SR 3.u.2 (wnicr bdh: fr;qwncy extenaiens) does uvi apply.fiiie's'e'pri suuic testing requirements verify that the containment leakage rate ~kC* l4 ~ does not exceed the leakage rate assumed in the safety analys1s. 3.6.1.2 for ungreuted, pest tcasier.cd tcadcas. This SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4).
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REFERENCES 1. 10 CFR 50. Appendix FLCptfon]. (O & ] g 3,g o
.u) , 2. FSAR, Chapte 15.
- 3. FSAR ction 6.2. '~
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-p wcm (o s MARK-UP OF NUREG-1431 BASES B 3.6 5 5/15/97
Containment Air Locks (At ;;pheric. 02;t:;.;;pheric, I;; C;nden;;r, ;nd cu;l) B 3.6.2 BASES (continued) h APPLICABLE The DBAe that result in a release of radioactive material within : l SAFETY ANALYSES containment see is a loss of coolant accident end ; red ;jection
;;;ident (Ref. 2). In the analysis of ;;d of tW; ttHt l
accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 952% of containment air weight bl-a- Der day (Ref. 2). This leakaoe rate is defined in 10 CFR 50 Appendix JM (Ref.1)}as4, = [0.1*] ef ;;nteira]ntg 3 c,, p. (, J eir night p;r ;;j,Athe maximum allowable containment leakage , rate at the calculated peak containment internal pressures P =[Y3d]M i following a BBA = -= 4 This allowable leakage rate - 1 l forms the basis for the acceptance criteria imposed on the SRs associated with the air locks. The containment air locks satisfy Criterion 3 of th; "",C "clicy Ot;t;a.t. 6 l LCO Each containment air lock forms part of the containment pressure ! n boundary. As part of 13 containment p_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 ! lock leakage test, and both air lock doors must be OPERABLE. The i interlock allows only one air lock door of an air lock to be ; opened at one time. This provision ensures that a gross breach ; of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each c c lock is l sufficient to provide a leak tight barrier following postulated l events. Nevertheless, both doors are kept closed when the air lock is not being used for normal entry into end or exit from containment. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. j % (continued) l MARK-UP OF NUREG 1431 BASES B 3.6 7 5/15/97
Containment Isolation Valves (Atzsphcric, substmsphcric, Icc Condcascr end Duel) B 3.6.3 O .w) ( BASES SURVEILLANCE SR 3.6.3.6 (continued) } Q 3.f '~' )
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REQUIREMENTS ' E nte i g L _,.,_ i , g,yal?e 1 ndtes's ated; i jg! y itel Cinin ~~ ~dancel- 'theTC
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Mi " oe Rh istfM ~ am/5)elcombined31eakage2AtelfogtM
-containmentFshutdoitnTpjue3upplylandlexhiDstTfsointioMWi1Vef IAIENRC1ssyrpeg.tolLTjModygludeANithT8BERT!EC p6netratibns7fsH#ssith4EU!6(PT.J In subetTc;phc. ic conteinants, the chcck velvcs that servc a contair.~,.t isoletion functi;n er; wcight er spring leedcd t; provide positivc closurc in the dircction of flew. This casurcs that thc;; crack valvcs will icnin ci; sed whcn tba insidc antain.~nt at=;ptarc rcturn; to subetzsphcric conditias following e 00A. 0" 2.0.0.5 ccquires vcrif tstion of the epcreti;n of th; chcck velvcs th;t arc testabic during unit spcreti;n. TFa "icqucacy of 02 days i; consistent with the Inscrvice Testing "r;; ret rcquircant for velvc testing on a
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i 3.4.P2h SR 3.6.3.7 i] Q 3.G,.0 -2. For gontainment aBrt3xarge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Opti j ngi! is required to ensure OPERABILITY. 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 j p the importance of maintaining this penetration leak tight (due to f h the direct path between containment and the environment), a Frequency of 184 days was established as part of the NRC resolution of MeltEfanEMonlNo? B-20. " Containment Leakage Due to Seal Deterioration" (Ref. 3 4). 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 prudent measure after a valve has been opened. O
\ l v (continued)
MARK UP 0F NUREG 1431 BASES B 3.6 29 5/15/97
. . _ . .___m ___ __ ._ __ __ _ _ _ _ _ . Containment Isolation Valvss 'Atr.cspheric. Subets.csphcric. !cc Condcaxr and Duci) B 3.6.3 A BASES MG 1./. 3 -2/ r4 JA- 3.6. L 7 a-SURVEILLANCE SR 3.6.3.7 (continued) / [O 3J .I-6] REQUIREMENTS [I p% _r- _,u-$. gnL1lJdef_ $aggf
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h 1cItieLaeBisM ILd490R8iiifMh7AntyttisintMrrr11ealiExiggy3pg1gigjs LaltgittBERhMBLEriliifentif;se&R?fsatSB'2han10_Mistien i E l a s.c.)-zij l &-#=Fjff^TE=7$&GfinDM ' fj_Wgeg _
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disfrNIo M[~ Mini L , Ar 3A 3. c., 3.7 b [T21.c. 3- 2./ } 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 A position on a containment isolation signal. RfesEgj!BE[cp I
- 9) N3M'J19LlaDMilag!WQgLRJ12MglERl[lar This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 3 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. Operating experience has shown that these components usually pass this Surveillance when performed at the IB month Frequency.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint. Sn 10. 3. (Not[Qsed);
!r. ;ub;t e;phcric cent;incents. the check valscs that scrv a conteiraant isolaticr. function ecc weight or spring icedcd to previd; positivc cissurc in the dircction of flow. This casures that th;x check valvcs will r;ccin cicxd whc.a th insidc conteiraent ots.csphcic rcturns to subets.capbcric conditions fcilowing ; OCA. SR 2.0.0.0 vcrifics the operation of '.hc chcck ,rx t
( (continued) MARK UP OF NUREG-1431 BASES B 3.6 30 5/15/97
ADDITIONAL INFORMATION COVER SHEET l ! A ADDITIONAL INFORMATION NO: Q 3.6.2-6 APPLICABILITY: DC, CP, WC, CA i 1 REQUEST: JFD 3.6-2 ' STS SR 3.6.2.2 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 interval is 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 j 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." i v FLOG RESPONSE (revised): The ITS Bases have been revised for the associated surveillance reauirements consistent with TSTF-17, Rev.1. l ATTACHED PAGES: I Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 5B B 3.6-12, B 3.6-13, insert SR 3.6.2.2 l 1 i
/ \
G i
- i L
1 l l l l j
Containment Air Locks (At;r.csphcric. Substir.ospheric. I;; Condenscr. and Dtten B 3.6.2 A BASES (continued) SURVEILLANCE SR 3.6.2.1 REQUIREMENTS Maintaining containment air locks OPERABLE requires compliance with the leakage rate test requirements of 10 C"" S0, Apgndix J (I,;f.1). es r;difi;d by eppiceed ca..vtiens MMCogtainme_nt
@Aage.Meletjpsgr.bgjem. This SR reflects the leakage rate testing requirements with regard to air lock leakage (Type B leakage tests). The acceptance criteria were established during initial air lock and containment OPERABILITY testing. The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall containment leakage rate. The Frequency is required by Apgndix J ("s;f.1).
;s redified by apprui d cx; vtiens. "ius. SPs 2.0.2 nihich clicas Ircquer.cy cat;nsions) decs not opply theyentainmentpeahnge]gtate ustsnrawn.
The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a g DBA. Note 2 has been added to this SR requiring the results to
\
be evaluated against the acceptance criteria of Mildh?i!;
.hjgBjic83GDoSR3.6.1.1. This ensures that air lock leakage is properly accounted for in determining the everall hM@eLHipe'B agg; containment leakage rate.
SR 3.6.2.2 The air lock interlock is designed to prevent simultaneous opening of both doors in a single air lock. Since both the inner and outer doors of an air lock are designed to withstand the maximum expected post accident containment pressure. closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports containment OPERABILITY while the air lock is being used for personnel transit in and out of the containment. Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely r.c;henical te]Iable
.a.._- _,m- maa .a ,,n,on +ha+ +ha i nt or1ru+ -o,-h e n 4 e-s ho l} Blenge t ai ih Ck A 3.G. 2.- L '
6 - 2 (continued) HARK UP OF NUREG 1431 BASES B 3.6 12 5/15/97
l Containment Air Locks (Atacsphcrit. Cubatmosphcric. Ice Condca;cr. and Duci' B 3.6.2 (m\ .(s/ BASES SURVEILLANCE SR 3.6.2.2 PIQUIREMENTS - i (continued) door is ,f required gteJdit_lentirytend?e&i,t o be performe upon entcring or exiti., this tep ;is onlyk contei.cqt air led y is ret rcqu, cd serc fic? cntly then very 104 d s
!Ll!Effi24I-%r..
-m---.
_e# .3iM
,9_,7;j
_ ~IE56'~nth
,. The 104 de-
-~n..- -. - - -
F quency fgi_ hMTMNriftstidddL_ MM
~
~-
ud ce3dp edcqdc~rg'vicwindicati of c~ ~ fdeerb is be:cd 3 nginccring k chenise se us eveilable '; ;peratir; pcisenaci
'ntcriecm
- m. jgt' hlhWR JMXIng!3ilf'3hape_, ., l@filig1##_f i Mili2h$eiNck*3 >
t - g i REFERENCES 1. 10 CFR 50, Appendix J'MM. 3 2. j FSAR, Section 3 Jag 6_~2;igiigf1]i. O f (v) l I uu & 4 m % n y n'.
,s a .
na 4 pec , em +A u s cre,Hae as n v4Anu-N* y,ss'ch & l+ c o & sas + a V dr / s,f sa K w 0 9Al/4"? \ Mte ,dte %rvei xx if f ' W w vK lAe hk&& + foW ' L sll 3 G 2 1 - MARK UP OF NUREG 1431 BASES B 3.6 13 5/15/97
. , _ . . .._.m..__..__, ._ _ __ _..._ _ _ .
I i i n SR 3.6.2.2 Insert: {
' nature of this interlock, and given that the interlock mechanism is not normally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to ningle door opening), this test is only required to be performed every 24 months. The 24 month l 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 if the Surveillance ! were 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. ; l
- ( ,
I i l I l i I l. l _ . . _ _ _ _ .. _ , _. - - _
ADDITIONAL INFORMATION COVER SHEET l 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 l l CTS 4.6.1.7.1 requires the purge valves to be verified locked closed or blank flanged at l 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 l Action for an inoperable purge valve due to excessive leakage. This change designated l DOC 7-03 A is characterized as an Administrative change. This is incorrect. The CTS l does not currently have this allowance and the change cannot be characterized as
- Administrative because of consistency with another Less Restrictive change. The l change is a Less Restrictive change. See Comment Number 3.6.3-5.
Comment: Provide a discussion and justification for this Less Restrictive change. FLOG RESPONSE (original): i DOC 7-03 A has been revised to be DOC 7-03 LS-26 and the discussion and justification i 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. O FLOG RESPONSE (supplement): v As discussed at the meeting on October 13-14,1998, the CTS mark-up has been revised to reflect the revision of DOC 7-03-A to DOC 7-03-LS-26. ATTACHED PAGES: Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 2 6-12 i l b o
4
/-0 7- 4 '
CONTAINMENT SYSTEMS h?5#d SURVEILLANCE REQUIREMENTS 3.G.3-23) MJ /-o4-t S down upply and exhaust 'l-o'l-L6 4.6.1.7.1 Each E in:F-containment s isolation valve (s)* shall be verifi . fl anged -aed- clq #3 ast 1-11-L5 once per 31 days, . Insert A n < ec _ _- - [m.c.) 'l [ 7.os-LS-2c
'a 4.6.1.7.2 Each Y ...:.. conmnmentTurge shutdo(
s G 3.caust-2 eak tested at s'. t y'
,T 7-17-M isolation valv least once per i :nth: pits:nd associated blank*ein:t:lhtien fellowing each flange s.11 :f theuebier.k fg 3 6 3 'U , :nge then pre::er I P , is.1 p:ig, :nd verifying th:t when the g,u,3_u
.ce::eredle:Macerd:dt:e for th,e:: v:h : :nd ihnger, in;leding sta: 7- '
1;;kegt, is ed3ed l Saeci'itatier t.0.fe' th: k k:ge d f;r raterTyp:
;11 ether d:t ~4nedB2 purssent-ttr i thbined h:k:ge - i 'han 0.00 L,.ugg"dp C pen:tr:tient,' t%h u..
3 u,ug
'.S.I.7.3
* -"= =tivo +4 +hn+ =11 M 4ach centeia==at rini psige - . , .
'~ " "
-rupply 2nd 0 h;ust iseletion v:h : h2= beea epen during & ;eleudas hF shall he rinta*=i ,:d :t h::t One; per 7 d;js. g 3,G,3 -[3> ,
l P ro wa-u ) 4.6.1.7.Mt least once per 3 4 := nth: each IS 49:h containment mini-purge ' * * ' supply and exhaust isolation valve with resilient material seals shall be *"fg - demonstrated OPERABLE by verifying -thet the measured leakage rate,i: k:- , 1
-ther. 0.05 L, when presasrized t P,. y ( a 3.r.. r-q y N _
3,(3-17j LB4daF ub u A h 92. kp .4 ope d,g A n 7 -o B-)< (Mtw) Inket D As-u l
~Q 3,41-l) {
of
- Except valves and flanges which are located insid containment.
These valves shall be verified to be closed "!th [2:f r blank fla installed prior to entry into MODE 4 following each COLD SHUTDOWN, Qtud pev$orme.6 in previous 91 h.y.,
\
j yGW) S NCE'M g I-o -L S Amendment [io. 44,10 CALLAWAY - UNIT 1 3/4 6-12 wQ L&.&
! 4 l l ADDITIONAL INFORMATION COVER SHEET ! l l n ADDITIONAL INFORMATION NO: O 3.6.3-10 APPLICABILITY: CA, DC, WC
\
(U 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 l 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 Se'aty Valves (MSSVs), l Main Steam Isolation Valves (MSIVs) Main Feedwater Isolation Valves (MFIVs), Main l Feedwater Regulation Valves (MFRVs), their associated bypass valves, and Atmospheric l 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. Comment: Delete this generic change. FLOG RESPONSE:
,m
[V } 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: "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 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 and then maintain it during plant operation. These valves are more complex and have safety functions which require them to be open while containment integrity is established. The isolation function would be required as a result of conditions different from those generally requiring 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 more conservative for an inoperable valve. An inoperable 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 p; (d 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
1 opan). Th3 most cons:rvativs applicabis op rational r:quiramcnts ara found in tha i associated ITS 3.7 LCO. Plant Soecific Discussion: V 1 The Containment Isolation System is discussed in Callaway FSAR Section 6.2.4. Figures of each penetration (and containment isolation valve) are included in Section 6.2.4. For the MSIVs, MFIVs and bypass valves, the figures show the penetration clarified by a note stating that this penetration is included for figure completeness and none of the valves shown are considered containment isolation valves. FSAR Section 6.2.4, Safety i Evaluation Seven states that there are no penetrations which are subject to the ! provisions of 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 environment is the inside of the steam generator tubes, the outside of the steam generator shell, and the outside of the lines emanating from the steam generator shell side. FSAR section 6.2.4.3 further states 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 the relocation of the Containment isolation Valve Table from the Technical l Specifications (Amendment No.113 moved Table 3.6-1 to the FSAR), the MSIVs and j MFIVs were listed 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.18 provided clanfication of (and restructured) the Technical
,. Specifications for the MSIVs and MFIVs. The approving NRC SER for this amendment
[s states: " Specification 3.6.3 pertains to containment isolation valves other than the MSIVs Q} and MFIVs and is applicable for Modes 1,2,3, and 4. Specifications 3.7.1.5 and 3.7.1.6 pertain to the MSIVs and MFIVs, respectively; apply to Modes 1,2, and 3; and have different action statements than 3.6.3. Thus, the effect of the licensee's proposed change is to clarify the appropriate limiting conditions for operation and associated action i statements for the MSIVs and MFIVs." FLOG RESPONSE: (supplement) For Wolf Creek and Callaway, further review has been 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 referei.ce to B 3.6.3 LCO to the containment isolation valve table. For Diablo Canyon, the LCO note in ITS 3.6.3 has been removed; 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 o 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 C] ( provides no applicable surveillances to assure OPERABILITY 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
l \ l ITS 3.7 LCOs recognize thasa conditions and provida appropriats ACTIONS and I SURVEILLANCES for the required open functions as well as isolation. The following l Table provides a comparison of the applicable ITS 3.7 LCOs to LCO 3.6.3, ACTION C: ! 'U/ LCO MODES Normal Safety Function ACTIONS l Position LCO 3.6.3, 1-4 N/A Provide GDC-57 closure to assure Close within ACTION C containment integrity following 72 hours. Verify failure of the closed system in every 31 ciays containment. LCO 3.7.1, 1-3 Closed to Open to provide over pressure One unable to (MSSVs) assure protection of the secondary side open upon demand pressure then re-close. -immediately boundary reduce power LCO 3.7.2, 1-3 Open Close to isolate the steam Restors or close IMSlVs) generator during HELB, Feedwater within 8 hours. , line break or SGTR Verify every l 7 days. ; LVO 3.7.3, 1-3 Open Close to isolate the secondary Close within (MFIVs) plant from the steam generator. 72 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 in 7 days, (assure pressure then re-close. 2 operable within boundary 24 hours, assure 3 are operable within ; 72 hours). j (*) 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 containment or require any of these valves to operate in MODE 4, 5 or 6 other then the ADVs. Steam generator energy levels are low in MODES 4, 5,and 6. In summary, 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. ATTACHED PAGES: Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 2 Insert B for Page 3/4.6-16 Encl. 3A 12, Insert 3A-12 Encl. 3B 9 Encl. 5A 3.6-8 Encl. 5B B 3.6-17, B 3.6-32 Encl. 6A 1 Encl. 6B 1 l (U
l l
)
( n t w, INSERT A FOR PAGE 3/4 6-16 (11-04 A) 1 1 l With one or more penetration flow paths with two containment isolation valves l I l inoperable, isolate the affected penetration flow path within 1 hour by use of at least one closed and deactivated automatic valve, closed manual valve, or blind flange, or be ; in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. INSERT B FOR PAGE 3/4 616
~a3.u-o$#)
i
# The uirements pecification 3 . do not ap for those v ves cov d b pecificatio 3.7.1.1, 3.7.1.5 a.7.1.6, an .7.1.7. /A //-A " 1 i
C) ## Penetration flow path (s), except for Contamment shutdown purge valve flow paths, may be unisolated intermittently under admmistrative controls.
/A #/-l 5
- Enter applicable Conditions and Required Actions for systems made inoperable
//- a-A by contamment isolation valves.
*** Separate Condition entry is allowed for each penetration flow path. / /-n -4
**** Fnter applicable Conditions and Required Actions of the " Containment" LCO men leakage results in exceeding the overell containment leakage rate. 3 -<3 -4
+ Isolation devices in high radiation areas may be verified by use of f ,v t 5 administrative means.
l 7"x l l
CHANGE NVHMD NpG QESCRIOTICN ,o 11 10 A Deletes [a note] [ waiving the surveillance that was only ('v') applicable until con.pletion of the first refuellrg outage] that is no longer applicable.
- - Nd h l . I3 t c.3-/ol s . nb W6 bl0, o .,
n n -o ,, +4. 5.C..& , w 54-iz m g) 11 12 A lhe pnrase flow patn' is acced for clarl 1caticn arc consistency with NUREG 1431. This specification is based on GDCs 55. 56, and 57 which adcress the proper isolation for each ~1ine~ that penetrates containment. It is recognited that multiple lines can share tne same penetration. Licensees have always been recuirec to l assure that proper protection is provided for each line or flow path that passes through containment even if multiple ficw paths share the same penetration. In this specification, the term " penetration ~ has always meant i each flow path that penetrates containment. Adding the 1 wcrds " flow path" to the specification clarifies this meaning. 11-13 LS-22 Not applicable to Callaway. See Conversicn Comparison , 'n ) Table (Enciosure 38). A/. 4- r1 > . 1 g 3,c,3 4g 1 11-14 Consistent with NUREG 1431. the phrase 'that is not locked. sealed. or otherwise secured in position' 1s added l for clarification in regard to which valves recuire isolation time testing. Valves tnat are secured in place. are secured in tne positicn recuired to meet their safety function. The isolation time testing ensures that valves can respond to tne cos" tion 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 func*icn. no testing is necessary. 11-15 A The note in CTS 3.6.3 addressing the RCP cooling automatic isolation valves and remote manual isolation bypass valves is celeted because ITS LCC 3.0.5 allows eculpment removed from service or ceclared inocerable to comoly w1:n Actions to be returned to service under acministrative control solely to perform testing recu1 red to demonstrate operability. 11 15 A Even thcugh not specified in ITS 3.5.3 Recuired Actions, tre Acticn :: rest re the incperable valve statet in CTS 3.5.3 a is uncerstccd as always tre ;rimary ::;ective ( ; anc a continuous ccti'n to be ;erformea curing any (/ Completicn Time. DESCRIPTION OF CHANGES TO CURRENT TS 12 5/15/97
i l Q 3.6.3-10 f' I. hv)INSERT 3A-12 s
\
l A ote is added the containment isolatio specification that the LC is not applicable o main ' stea safety valves MSSVs), main steam iso tion valves (MSIVs), mai feedwater isolati valves i FIVs),[associ ed by-pass valves and eam generator atmosph ic steam dump valves (A s)). The curre licensing basis for them valves exempts them m playing a role ' j establishing maintaining coqtainment integrity. Thi 1 based on 10 CFR 50. c.2 and c.3 ' and 10 CFR 5 , ppendix J. Th e are no surveillances ssociated with LCO 3. .1 or LCO 3.6.3 which e applicable to se valves. [Thesev es are currently not co idered to { have a containmen solation function. ! his Note is consisten ith current licensing b is. ; _ i 1 Q 3 .G. 5 -/ D 3 e. _k q
'N U
l f a
7 3
\ ' l*.e s
[ ( )
>,,m \
g.I
, w CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 9 of 11 TLCil SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CN1 YON COMANCHE PEAK WOLF CREEK CALLAWAY 11 06 lte current T5 surveillance requirement to demonstrate the Yes Yes Yes Yes 1R 3 operability of each containment isolation valve by performance of a cycling and isolation time test prior to returning the valve to service after maintenance. repair or replat.ement work on the valve or its associated actuator, control or power circuit. has been deleted.
11-07 The descriptive material regarding the required containment Yes Yes Yes Yes LG isolation valve actuation signals in the current 15 surveillance requirement is moved to the Bases, 11 08 The actuation surveillance is revised consistent with Yes Yes Yes Yes IR 1 NUREG 1431 to clarify that an actual signal as well as a test signal may be used to verify actuation. 11 09 The isolation time surveillance is revised to delete the Yes Yes Yes Yes A reference to verifying "each power operated" containment isolation valve and only require verification of each
" automatic
[p], ( (,, 3 - -6 p isolation valve.~ f,g j
,. _ 7 . . -
11-10 lhe note providing a [ waiver of the surveillance that was No - DCPP does not Yes No Wol f Creek Yes A only applicable until completion of the first refueling have this note does not have this outage) that is no longer applicable is deleted, note 11-11 An e is ded to
.C0 is conta nt iso tion sp ificat' n le to H s. MSI y t :1. a dy pirt Jes- -Vet-K at th t appli and 5t m gener or r FIVs ef e r= W .g M/
f(asso ated I ass valv '-Q 3. C. 3 /C) ' val s % y _ gg _g 11-12 lhe phrase " flow path" is added for clarification and Yes Yes Yes Yes A consistency with NUREG-1431. 11 13 This change revises DCPP cnntainment Ventilation Isolation Yes No No No L5 22 valve surveillance frequency from 30 months to every 184 days and from 24 hours to 92 days. 11-14 -W pi.i o se inat is not locaeu. se4it>u ur otnerwise h g Ves- pg egg e gA + tec 7 i pm : = i s %< rnr ci sri ncgien m g g - e yj ; g .; m r m i r e i , .a a i nn t im s eg, f/d M [d, .$4 3 -// f CONVFasintl rntiPARIS0tl lARIF e filRRFNT Ts r,fic m y
! l i Containment Isolation Valves (Atr,caphcric. Subctr,caphcric, Ic; canden;cr, and ;;ci) p3 3.6.3 i j 3.6 CONTAINMENT SYSTEMS i j 3.6.3 Containment Isolation Valves (Atr,caphcric Osbotas;phcric. Icc Condenacc. - ps l eri Ducl) l N N
^
T N i 1
-3.5 3:
l N/ i N \ \ \ S A.6 3-/o
' ic i ( s s s s s t W LCO 3.6.3 kachcontainment solation valve shall be OPb,
. ~ MODES 1, 2, 3, and 4. APPLICABILITY: [ I. ' - 5D i ACTIONS
- ........................................N0TES - - -- - - - -
l 1. Penetration flow path (s) c;1_'f +4Eyv.*dde^*<v W '- @ 2' " B PS^ I M may be unisolated intermittently under administrative controls. l 2. Separate Condition entry is allowed for each penetration flow path. ! 3. Enter applicable Conditions and Required Actions for systems made inoperable by l containment isolation valves. .i j 4. Enter applicable Conditions and Required Actions of LCO 3.6.1, " Containment," i when isolation valve leakage results in exceeding the overall containment j leakage rate acceptance criteria. ' j' .................................................................................... , (continued) 3 l
) m MARX-UP OF WOG STS REV 1 (NUREG 1431) 3.6-8 5/15/97
Containment Isolation Valves 'Ataspheric. Sub;ta;pheric, I;; Condenxr and Ouel) B 3.6.3 , f ' j( ? , BASES n i-
/gg ~
9 3.c.1- { ' 1 APPLICABLE following a LOCA. Therefore, eit.jhe e h of the Contairunejit; SAFETY ANALYSES StgglinggPurge andy-M5~ valves is uired to remain sealed (continued) closed during MODES 1, 2, 3. and 410bJgfEgngeJs amEtie 1qtt~a13 In this cesc th; singic failur; criterien r;nins [ epplicebi; t; th; cent;ir ~..; purg; velva due t; failur; in the
;;ntr;l circuit es;;;ieted with sch velv;. Ag;in. }he
>g c _ a u
/j mrge system valve design precludes a single
'&p .
failure from compromising the containment boundary as long as the gstem is operated in accordance with the subject LCO. l The containment isolation valves satisfy Criterion 3 of th; NRC P;1 icy St;t;nnt. BINSciDISE04@M LCO Containment 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 durin a DBA.
A f 3- ,. The automatic power operated is ion valves are required to l g have isolation times within li its and to actuate or. an automatic D n ained 1 s . c .o -2. [;r h;;; bieds in;telled te pr;;;at full ep;ning]. [01;d:d 3[o purg selva el;; atu;te en en ;;testic sisal.] The valves covered by this LCO are listed along with their associated stroke timesintheFSAR(Ref.g g _fo The normally closed M isolation valves are consider OPERABLE when manual valves are closed, automatic valves are de activated and secured in their closed posigti n blind flanges V e-1Aplace,-and \ isci;tionvelyn!gosed-systems-ere-4ntJct,[Th;xf;ssive via; er; then listed in Reference T.) b Pur e cut sed'sem, = b5;;s velva] must meet additional leakage rate requirements. 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 tHHC6nt'ainnefft purge valves will perform their designed safety functions to minimize the loss of reactor coolant , inventory and establish the containment boundary during j - accidents.
\
l (continued) MARK UP OF NUREG 1431 BASES B 3.6 17 5/15/97
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___2 7 .- .ybe.J92.a9 _.- A,_ l t - l l REFERENCES 1. FSAR, Section(15. @ Q 3.G.0-2 ~ ! 2. FSAR, Section 6.2. t l l 31 MiqRia@pp2p \ hf.
~
CEI,$riC I;;^A 0 20 w N .
- g\ " Containment Leakage Due to Seal Deterioration."
43 C;r.cric I;;x " 24. ggL. grm u yi M. % 7 g.er m 9_ y mW E!EU 1 i 4 F f A f_ ist '= O 3.L .3 - 4 Z f' , Q 3 . C. 3 - / D 1 1 I' f 4 1 I 1 k MARK UP OF NUREG 1431 BASES B 3.6 32 5/15/97
i DIFFERENCES FROM NUREG 1431 l NUREG-1431 Section 3.6 v This enclosure contains a brief discussion / justification for each marked up technical change to NUREG 1431. Revision 1, to make them plant specific or 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 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 NUMBER 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 Traveler TSTF-52. 3.6 2 Consistent with Traveler TSTF 17, this change would extend the testing frequency of containment airlock mechanisms from 184 days to 24 months
/O and delete the SR Note per implementation of Appendix J. Option B.
h 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 l 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 required, the ; performance of the interlock surveillance would be required following i 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 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
$ 3u ,fo interlock on a 24 month int vp.
3.6-3 ConsQtent with, e curre t id. a note nas ce acced to larify t at he vawes lispe are not dressed i LCO 3.6. These v ves uti e t stea enerato and ass iated pip' g as a osed syste inside o. co inment. These lves also ave sepa te LCOs atprovidhthe , a iate R vent t q' valve are inoperable. L =U,3
@ pproy g % quired m '-N Ac 'onsM inn-ith y T R (Ev l
/
3.6-4 Not applicable to Callaway. See Conversion Comparison Table 'g 3,c,,3 fo (Enclosure 68), gQ (V i 3.6-5 This change is in accordance with TSTF-45 and revises SR 3.6.3.3 and SR 3.6.3.4 to specify that only containment isolation valves that are JUSTIFICATION FOR DIFFERENCES - TS 1 5/15/97
.[
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, J %i CONVERSION COMPARISON TABLE FOR DIFFERENCES FROH NUREG-1431. SECTION 3.6 Page 1_ of 3 l TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY ) i 3.6 1 This change supports inplementation of 10 CFR 50 Yes Yes, in current TS Yes Yes . Approved as Appendix J. Option B approved in November 1995. Testing is Amendment #111 performed in accordance with the Containment Leakage Rate , Testing Program as described in the Administrative Controls section. This change is consistent with current T5 and in ! accordance with industry traveler T51F-52. I t 3.6-2 This change would extend the testing frequency of Yes Yes Yes Yes containment airlock interlock mechanisms from 184 days to [ 24 months. This thange is in accordance with 15TF-17. _,g g __--Q 3.6-3 ConsistentwiththecurrentT5anotehasbeenaddedko _ -Jes" Yes -Yes jf .Yes, [ clarify that the valves listed are not addressed in MO /Vo ! LCO 3.6.3. These valves utilize the steam generators and - associated piping as a closed system inside of containment. l lhese valves also have separate LCOs that provide the 3,4,3.jo appropriate Required Actions in the event these valves are 8 f inoperable. Q , 3.6 4 This change would extend the Completion Time for a closed Yes Yes No - WC does not No -Callaway does [ system flow path with an inoperable isolation valve to have GOC-57 valves. not have GDC 57 72 hours. This change is in accordance with 151F-30. valves. l 3.6 5 This change would revise SR 3.6.3.3 and SR 3.6.3.4 to Yes Yes Yes Yes f 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 l T5ff-45. j! 3.6 6 Consistent ~with the current CPSES TS. 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 clused except ! af ter each drainage of the canal. l 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' 7 I containment isolation valve and only require verification - of each " automatic isolation valve.' This change is in g g,3,j3 y accordance with I F-46. ' j
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ADDITIONAL INFORMATION COVER SHEET n ADDITIONAL INFORMATION NO: Q 3.6.3-11 APPLICABILITY: DC, CP, WC, CA k } w/ 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 Now 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 i j ITS 3.6.3 RA D.2 have been modified by a Note that states the following: " Isolation i.
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 j 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. Cornment: Delete this generic change. See Comment Number 3.6.3-12. j FLOG RESPONSE (original):
]
WOG-91 has recently been designated TSTF-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 fonvard 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 concemed to retain this change within the submittal pending NRC review of TSTF-269. l 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 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. 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.
4 l i
.. . . .._ -- - ~ . _ - . - -. .- . - - - ...-. _ _ . - - -... - . - ... _. .
ATTACHED PAGES:
- Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 2 3/4.6-17, insert A Encl. 3A 9, insert 9-04-A,12 Encl. 3B 7 and 9 Encl. 5A Traveler page and 3.6-16 l-Encl. 5B B 3.6-20, Bases insert A.2 and C.2, B 3.6-24, Bases insert D.2 and B 3.6-28 Encl.6A 2 and 3 Encl. 6B 2 l
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CONTAINHENT SYSTEMS y 4,g ,j fQ3.6.illk SURVEILLANCE RE001REMENTS (Continued) aaknw%t D rart A
\
GT:54
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\ 4.6.3.2 EachAcontainment isolation valvenhall be demonstrated OPERABL tr4 ; th: COLD SWOT= er "EPJELI"O "00E at least once per 18 months by /?-to- aPit.
W )rtG j I
.a,4-Verifying h :: " h:1:tir tert- signal, each '"~i8eiTG "h::: "" that hele+ onb: "va:lve actuates to its isolation position, /ho r-rx Nn sc%f or .siwJJeg sch<akn ti-io-A l ech-b.f "erifjing .
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- c. "erifyir.g th:t On : C nt:t. at * ;: h:letien tu t signel, 02:5pu;c::;1" rdediert iselitier "21= ::te:t:: t: itt //*#7-L
- iseleti:n ;;;itten.
4.6.3.3 The isolation time of each ;e"e 0;e ated e automatic :ontainmen //-#-A isolation valve shall be determined to be within its limit when tested // "l @/ pursuant to Sp ification 4.0.5. r.,w- x- ru^ poxo- ofwe* led
? LAJ ' G 3.c. 3 -I l 3. 6. 3 - 8 4
l J iTh; specifid 10 unUi Tr eyw.nc3 ::y 5: e ind fer Cycle p,evided ths 5u-"=4:::: b p;rf;r ;d prkr te re: tart Sil ;ny Ene firn iciuci ny //-/#'A eet ;r er 2:3: 1, ! = , hichever :: er: #4-:t. 'h pr:';i tien: c '- S; cifketic? ' 0.2 er: reset fr= nerformance of this surveillance. Amendment No. 8,11 ( CALLAWAY - UNIT 1 3/4 6-17 (Next page is 3/4 6-32)
9 A Q 5.c. 3 - 11 INSERT A FOR PAGE 3/4 6-17 (l.McK) l l that is not locked, sealed or othenvise secured in position l 1 i ( I l i l l I O l l 1 l l l l l [ I
CHANGE NUMBER 82iG DESCRIPTION 344 V 8 11 4S A%om discove@ry of failure to meet the LC0" provis
//Fl has beerNddedd to the completion time for one train'of containment spr CTS 3/4.6.2.1Contaiquent (g/ coolingSpray) systems inoperable.
and 3/4.6.2.3 (Containment Cooling) require restoring the inoperable system to Operable status withiq72 hours. The CTS limits the inoperability of any combinattgof these two systems to 72 hours or it provides a maximum of4 days for restoring one group of cooling fans to Operable status when everything else is Operable. This changhs, considered less restrictive in that the 10 days allowed in the,ITSnottomeettheLC0isgreaterthantheCTSw3Did M
, 'rflow-v.
YUfGM 3 A-- 9 \ Q-il. t 3 A - 9 6J l Q 2.G C-I d 9 ul A Not applicabie to callaway. See Conversion Comparison Table (Enclosure 3B). gy M 3.L - cb 9 02 LG The descriptive information in th LC0 3.6.2.2 regarding operability of the [ Recirculation pH Control] System is contained within the definition of operability as described in the ITS 3.6.7 Bases. This is consistent with the NUREG 1431 and is acceptable because while the descriptive detail has been moved to the bases the bases requirement is retained in the LCO. O. ( 9 03 A Consistent with NUREG 1431. the action statement is revised by deleting the reference to restoring the [RFPC system] to operability within 48 hours or be in cold shutdown within the 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. ~ 9 04 A tct :pplic:bl; to Celle-ay. See Cun m 7 f~Q 3.c.1-H ) w>ya m 7 nbl a (Encinwr a 9A)_ y 9.o9 4 3,g q } 9 05 TR 1 The specific actuati signa (aMnteir=r.tSprr/ O 3 4 k3f7 Astu: tion test rical for the surveillance was repla iic q 3,q,g 3 with generic words t at allow credit for an actual or - simulated actuation. Identification of the signal is moved to the BASES. M 9 06 LG Not applicable to Callaway. Se'e Conversion Comparison Table (Enclosure 36). O 9-07 H Not applicable to Callaway. See Conversion Comparison ( Table (Enclosure 38). DESCRIPTION OF CHANGES.TO CURRENT TS 9 5/15/97 I l
l l Q 3.6.3-11 es INSERT 9-04A '
)
' (V - Consistent with NUREG-1431, 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 I clarification. Valves that are secured in place, are secured in the position required to meet their ;
safety function. The actuation testing ensures that valves can move to the position that meets I their safety function. If the valves are secured in the position that meets their safety function, no testing is necessary. l l I I I I 1 l l
'N O
O T
1 CHANGE NUH8ER EC DESCRPTION ; 11 10 A Deletes [a note] [ waiving the surveillance that was cnly applicable until completion of the first refueling outage] that is no longer applicable. t l
- Nd m # . [di.c. 9/ol 63-IDke[o=n.o
-ono-M e p;
[ , 5 l v f - 3 fu y 2 I 11 12 A The pnrase flow patn" is acced for claritication anc ! consistency with NUREG-1431. This specification is based ! l on GDCs 55, 56, and 57 which address the proper isolation ' for each "line" that penetrates containment. It is recognized that multiple lines can share the same j penetration. Licensees have always been recuired to 1 assure that proper protecticn is provided for each line or 1 i flow path that passes thrcugh 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. i 11 13 LS 22 Not applicable to Callaway. See Conversion Comparison ; Table (Enclosure 38). u m .1 4 3,c,sm ; 11 14 fr Consistent with NUREG-1431. the phrase 'that is not I locked, sealed, or otherwise secured in position' is added for clarlfication in regard to which valves require ; isolation time testing. Valves that are secured in place. are secured in the position requirec 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. W 11 15 A The note in CTS 3.6.3 addressing the RCP cooling automatic isolation valves and remote manual isolation bypass valves is deleted because ITS LC0 3.0.5 allows equipment removed , from service or declared inoperable to comoly with Actions i to be returned to service under acministrative control solely to perform testing recuired to demonstrate operability. 11 16 A Even though not specified in ITS 3.6.3 Required Actions, tne Action to restore the inoperable valve stated in s CTS 3.6.3.a is uncerstccd as always the primary co;ective and a continuous option to oe performed curing any Completion Time. DESCRIPTION OF CHANGES TO CURRENT T3 12. 5/15/97
\ .
A Y.J C)\ N CONVERSION CONPARISON TABLE - CURRENT TS 3/4.6 Page 7 of 11 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 08 11 A "from discovery of failure to meet the LC0~ provision-has Yes No - CPSES current Yes Yes
+G-e-- been added Q the conpletion time for one train tf TS does not have a M containment spray 7 cooling.systemsjnoper'able. This change containment cooler is considered Less RestrictivDrrtha in the ITS notJ o meet the LCO is greater than te-GTS ys allowed 3f 4 - / specification.
y wgttidatMC 7 & g 7- 36 7 I 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 [RFPC System] is contained within Yes Yes Yes Yes _ LG the definition of operability for the [RFPC Sy-tem] as f described in the Bases. ( L_G3' 09-03 This change revises the action statement by replacing the Yes Yes Yes Yes .f , N reference to restorirg the Spray Additive System to ? I A operable status within 48 hours or be in cold shutdown ,h- I within the following 30 hours, with the requirement to be /l/ /
/
in cold shutdown within 78 hours. r. ' .. 4 / ' 09 04 This change adds the phrase 'that is not locked, sealed, or Ne - T M 5 eu. d t Lm Yes Mc Current Curhent A otherwise secured in position
- with regard to which valves 15 &c:t " US, P e " ce per CTS /gerHe= y rTt j require actuation testing. p GAA99 p Q '.5_?_?
09-05 The specific actuati signal h : Centri _.; 4.ar Yes Yes Yes Yes fG 3.G.7-6 for the surveillance was replaced TR-1 9.ctatien test . with generic words that allow credit for an actual or { tQ 3.G.G- 3 simulated actuation.
; [Q 3.0 C- 7 a 09-06 This change moves specific details in the surveillance No -. CTS does not [<es-Surveillance Yes - Surveillance No - Callaway does LG requirement with regard to verifying flow path and the RWST contain this detail details are moved details are moved not have this waterflowfatesofbetween50and100gpmthroughthe to the Bases. to the Bases system. -00 eductor test loopDout of the TS, and adds a general requirement to verify flow capability through each eductor.
09-07 The surveillance for DCPP is modified to require Yes No No No H demonstration of flow through each solution flowpath. M T J 36-7s { 9 3 t- h CONVERSION COMPARISON TABLE - CURRENT TS 5/15/97
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Ye j- ' CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 9 of 11 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAX WOLF CREEK CALLAWAY 11 06 The current TS arveillance requirement to demonstrate the Yes. Yes Yes Yes TR-3 operability of each containment isolation valve by performance of a cycling and isolation time test prior to returning the valve to service after maintenance, repair or replacement work on the valve or its associated actuator. control or power circuit, has been deleted. 11 07 The descriptive material regarding the required containment Yes Yes Yes Yes LG isolation valve actuation signals in the current 15 surveillance requirement is moved to the Bases. 11 08 The actuation surveillance is revised consistent with Yes Yes Yes Yes TR-1 NUREG 1431 to clarify that an actual signal as well as a test signal may be used to verify actuation. 11 09 The isolation time surveillance is revised to delete the Yes Yes Yes Yes A reference to verifying ~each power operated" containment I isolation valve and only require verification of each p] (,, 3 -3 "autumaticpi solation valve." , ,, g j
~ 7. _ 7--
11-10 The note providing a [ waiver of the surveillance that was No - DCPP does not Yes No Wolf Creek Yes A only applicable untti completion of the first refueling have this note does not have this outage) that is no longer applicable is deleted. note 11-11 bn e is ded to conta' .nt iso tion s . ificat n y -": :1.cauy part Yes- -Ves--
,K at th C0 is t applic le to H /s. H$l . FIVs c'-curr ..; M . g MM
[asso ated t ass valv and st om gener or r ef 3 3,c.,3_ m val _s - g# u. . t fa#4, _ __J 11 12 The phrase " flow path' is added for clarification and Yes Yes Yes Yes A consistency with NUREG-1431. 11 13 This thange revises DCPP containment Ventilation Isolation Yes No No No LS 22 valve surveillance frequency from 30 months to every 184 days and from 24 hours to 92 days. + 11 14 - h p.aese (nat is not tocKeu. seait:u or otneiwise m :>:-p;-ti= q et w ry -e n c3 tie < re
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rnWFRSION rottPARISON 1 ARI F - filRRFNT TS c/ic/07
f Q .. INDUSTRY TRAVELERS APPLICABLE TO SECTION 3.6 TRAVELER # STATUS DIFFERENCE # COMMENTS TSTF-17, Rev. 1 Incorporated 3.6 2 NRC Approved TSTF 30. Rev. yJ.- Incorporated 3.6 4 Not eppi kabic i.e Weif Ci eek T'd
~
and C211:,uei.42C h one1 3f,*7 TSTF-45, Rev. 1 Incorporated 3.6 5 NRC Approved TSTF 46, Rev. 1 Incorporated 3.6 7 NRC Approved TSTF 51 Not Incorporated NA Not NRC Approved as of Traveller cutnff date TST[(52;Arb Incorporated 3.6-1 ( h y'^df_g ,W #) fG3 C'l-I= TSTF- Not Incorporated NA Not NRC Approvgj as of Traveller cutcy(f date "CC 01 4 Incorporated 3.6-11 @ M N [ f,j=_> h M 3-//l Tf7F'2.69 V)
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5/15/97
Containment Isolation Valves (Atr;;pteric. Sdat .;;pteric. I;; Conden;;r. and Dual) Ps 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.3.5 Verify the isolation time of ;ed powcr ep;reted end each automatic -- # [ ITEittWtl89@ lWitiglE s 3.6 7 contain= ant isolatinn vad nr 2n, .. Q Egg eW2 - f ' is .s .i. n .Jr $ 3.C.~P il') within limits. er 02 day; B PS-- s pc.1-6 ( [G M*2- Il
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t;;tsic durin; ep;retier, tt.reugt,"ere ;%1 ;t; E cyci; cf full tir..;1. ;r.d v;rify ced de d velv; r;;.r.in; cle;;d 2;n tra di'f;rentiel m ini f pr;;;;r; in tre dir;; tier, of ;w i . [1.2] m p;id er.d ep;n; den tre differentiel pr;;;ur;
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L 0m 9 ~' 7 ,t~ Mx % W % &M g M .~. A u 02 day-(continued) O O MARK UP OF WOG STS REV 1 (NUREG 1431) 3.6-16 5/15/97
Containment Isolation Valves (Atmospheric Subatacspheric ::: Cond;nscr and Dual) B 3.6.3 b
\ BASES ,L ACTIONS A.1 and A.2 (continued)
For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and that have been isolated in accordance with Required Action A.1 the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or v N/d#
$ 3134 ma pyier, ft-4nyolves verificatio , th" ; s- stem walkdown. that those isolation dey of being mispositioned are in the correct position. The j7g g /N Completion Time of "once per 31 days for isolation devices jyy outside containment" is appropriate considering the fact that the j g;n%)/ devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as " prior to entering H0DE 4 from H0DE 5 if not performed within the A previous 92 days" is based on engineering judgment and is (k] considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unifkely possibility.
Conditica A has b;;n ;;;cdified by a %ct; indic; tin;; that this Conditica is caly epplic;bi; to tFes; p;ratretion i"cw paths with twc cc,ntai..;;;nt isciatica valv;s. Icr p;ratr;tica 'ica paths wtth-Only cri conteir.. ant iscletica velv; and a cles;d systce. Cc,ndition C provid;s th; ;ppropriet; ecticas. Requirad Action A.2 is modified by e M Noteg thet Ndteg appN to isolation devices located in high radiation areas and allows these devices to be verified closed by use of , administrative means. Allowing verification by administrative _ means is considered acceptable, since access to these areas is h LU-M% d N typically restrictedj Therefore, the probability of misalignment of these aev1ces once they have been verified to be in the proper position is small. KS.econdLNote;has] beenNdded 30!Re_q.QiredI6ctionF2;tomrovide clarificlation thatlthKactionitoiperiodica]lylverif.f!thelaffected i O (continued) MARK UP 0F NUREG 1431 BASES B 3.6 20 5/15/97 l
l Q 3.6.3-11 p BASES INSERT A.2 and C2
\'s Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. l l
1 l l v i
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Containment Isolation Valves (Ata;phcric, subst;.;;phcric. ::; Cond;n;;r and Du;l) B 3.6.3
..;p BASES
~N N
ACTIONS Cn'=C 20:andrc 3 E.1. E.2. ond E.2 (contin, ued) - pgM8-f l f' s
~
Action does not ' require any t,estiiig or valve nipulation. Rather, it involves verification, thieugh ; 4;t;; w;1kds.;ng that those isolation devices outside containment capable of being mispositioned are in the ckrect position. For the isolation s* devices inside containment,,the time period specified as " ior to entering MODE 4 from 5 if not performed within t
' /J previous 92 days" is bas on engineering judgment and s W 'S considered reasonable in view of the inaccessibility'of the ,
isolation devices and otyr administrative 1ontrols that will ,' l[ ensure that isolation devir.e misalignment is an unlikely i possibility, l[ggf m2j m/g pt, are[ fot a f W rdM6 k D1 d,* deM'.f / For the Oontainment ge M seal that is isolated in accordance with Required Action CE 4 E.1. 6 SR 3.6.3.7 must be performed at least once , every 3 days. This assures that degradation of the resilient j seal is detected and confirms that the leakage rate of the i containment purge valve does not increase during the time the SE lF.3 ' ^ penetration is isolated. The normal Frequency forgR 3.6.'3.7, 3/,g 3-51 184 days, is based on an IRC initiative, m- - B 20 (Ref. B 4). Since more reliance is placed on a single valve while in this Condition, it is prudent to perform the SR j more often. Therefore, a Frequency of once per 3 days was / ! y ll chosen and has been shown to be acceptable based on operating G yG 3. G.,0 -2. 3 ~2- experience > W -
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-_ m gte - - - p t Qiaw:$.vr es_ J!LeNie [Ts-a%Q@% ss u ._, , m - , G3.G.1-H po .wmil M J - a tt M i l*?E b e m on w gprog de els caefoC 13heym:tWntto" peg @dg81h ".giMaffected Mtggil ._ _ _ Me1@ MrKf adidifttratWelyNor: . ._ _ Vsk,Etod3Jeid' JRieiFth me Toged M led;Io . , _,g ; Jrg[TsJh]s _ ;&gglisface '
these3efelyerffijeditoIbe3nAheicorfectlp6sitionspri.Jo i lockinsqsealinggor.Isecuring2 L (continued) MARK-UP OF NUREG 1431 BASES B 3.6 24 5/15/97
Q 3.6.3-11 Og BASES INSERT D.2 ( 0, V) Required Action high radiationasare%2) is modified bytotwo Notes.closed Noteby1use applies to isolation devices loca End allows these devices be verified of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. V I l O (V ') i I
l-Containment Isolation Valves (Atac;phcric. Substr,csphcric. Icc Condcascr cad DuaU l B 3.6.3 I i , e ( ( BASES l v.-s SURVEILLANCE SR 3.6.3.5 i REQUIREMENTS l (continued) Verifying that the isolation time of each power opcreted and
=He *W--P cultainment_ ischtica r .ht Ett i U " " N 9 ? Nf FE M S M within limits ii r'equired fQ 3.G.D I M trate OPERABILITY. An5Dtomat%'3. xnfeW60schtid -
NTNUML@B.Ve.]2[@Mog1MlisbTatigle NirJcT6sidSbgarWautomat3,tQWieStheir ttujniolis@ ton liadh6TERttistrahiiittgTggiidWeisifeWid3bEothErShih5siinifaT actettionWg@ygg@nhDeatJGWibnojWlot[imoMYoperator)J The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. fThe isolation time and Frequency of this SR are in accordance with the Inservice Testing Program. er 02 days. SR 3.6.3.6 ' Q 3. c. 5 - 2./ r . . A SR 3.G.. tM s& , E51R4t.4M j_kWQfgg@$theQditithTWsyTeilt"~s.[iiTg additttelgesaggsyg[isgandsg3 q!Leguiriem6nts of 77 ) IMmen.vgeMgittdgGDJLopitin.3lllgtignin Tbgsuee OP-'- ~' miMi.cQthatithis d]Emp~eratF[e----C Mhas[FMMQttgglegj; dd1M6rterlti,5
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N "."; %,.,3 b) Et!ggejg nmanufletowdPm-veicreedags f 4 +"j tLA estaN[l[ 34sMMP*Wicr2mRLwirMSihtTRt16h 4 Sa. e q upad. hiu Jm;EcontaDmenJMag]it!!gigtgreen ._XLoritfuh.; a p.y 4 FMM
-te # =t ah Additiona))yTgt _ CSRluistibe#btf ol _dMthW92;l days" ter angergsgemoved Ee;92gral m A.tK4 o#nin92he; 163@en2helbL Ereggener szchosenstecognif LthaRc.tcli!WG ' alyeIMuld I reo %r '#. introdu ;ad.ditionaTtseaEd_ adition!.(beyond .tcoccuttingst 1 l vaTveJthat1haCnotibeen'~ ned)2f,J hu C de'._ asing;theligt _al r n (ftsfiCIB4Zdays)E1s apd6nt2 meas 9ts3f_ rXValye'has~
ed; j i j3 Ifl.ithfbl;ihdifTange'l siinstilledC~eakageMateltestingfoflthe. i b* ! N. ----y. b11nd'flanselmust7be; performed (everf241molnthspindifoliloRing[each j M reinstallation ~fof3he;blindfflangeK0peratinglexperience:has demonstrated 2that;thisytestingifrequency;i sladequateltolassure thisipenetrationrisleaKItjght; l
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(continued) MARX UP OF NUREG 1431 BASES B 3.6 2B 5/15/97
_ . _ . _. __ ____ _.._______ _.m._ _ ___ . _ _ . _ _ _ _ _ . . . . _ _ t l CHANGE '
-m NUMBER JUSTIFICATION !
(iTM not locked, sealed. or otherwise secured are required to be verified closed. The position of the locked, sealed, or secured valves was ' verified before the valves were locked, sealed, or secured. 3.66 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 68). op.op 4fdadnke.f hM3*W _l 3.6 7 This change is in cc[ dance with TSTF 46 and revises SR 3.6.3.5 to delete the refer nce to verifying the isolation time of "each power operated" conta' ent isolation valve and only require verification of each "automati isolation valve." Valves credited as containment . isolation valves which are power operated (i.e. can be remotely ! operated) that do not receive a containment isolation signal do rat have an isolation time as assumed in the accident analyses sir:.e they require operator action. Therefere. deleting reference to powr operated isolation valve time testing reduces the potential for ; misinterpreting the requirements of this SR while maintaining- the assumptions of the accident analysis. 3.6 8 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 6B). 3.6 9 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 6B). 3.6 10 Not applicable to Callaway. .See Conversion Comparison Table (Enclosure 6B). 3.6 11 A new Note is add to ITS 3.6.3 Condition A.2 [and C.2) in accordance with traveler WBC-4i, The additional note applies to isolation devices that are locked. sealed, or othersise secured in position and allows these devices to be closed by use of administrative means. It is sufficient to assume that initial establishment of component status (e.g.. isolation valves closed) was performed correctly. Subsequently. verification is intended to ensure the component has not been inadvertently repositioned. Given that the function of locking, sealing or securing components is to ensure the same avoidance of inadvertent repositioning, the periodic reverification should only be a l
. 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 perform an active verification of the required state. 3.6 12 N3 M - fa s.c. 3-U ]
-C w;i ::rt 4 t h I 2 . E . 2 . S *i:b prc.ide; rne auumon posauon ,
l
-te: ting i: not requi"ed '"- ""es 'ccked. Sc: led, or othemisc ccurd ir thci recu4"od scr4+40" or: der admini:trcti .. control thi: ch25e !
;.c: ld previ& that i:cl: tion time 7::ti~; " ct required #c" '"*~"4" G
JUSTIFICATION FOR DIFFERENCES TS 2 5/15/97
CHANGE JUSTIFICATION n NUMBER ((,/i contai - nt M lation vehet that :r: locked 3ealed, ur uuminiw G 3.c.1-id Jerora 4a tNi r~;uir^d p^:iticn uMe" e&4"istr; tin wnLroi. 3.6 13 [ arifying e is add p N R 3.6.3. g7 at would T6wthat eakage) G l L 3'2)} ate testi for contMtiment purge Mes with r ilient sea isnof s requir when the tration f1 ath is is ated by a k tes (d bli lange. T blind flang rovides t' required i lation.)and) d ional te,s) ng of the va s is unne ssar g , gep u v %g . x % w _- r - 3.6 14 Not applicable to CalPaway. See Conversion Comparison Table ' (Enclosure 6B). l 3.6 15 SR 3.6.6.7 would be modified to reflect plant specific requirements for i cooling water automatic functions as well as containment cooler l functions. l 3.6 16 Consistent with the current Callaway TS, this specification has been ! l modified to reflect the Callaway Recirculation Fluid pH Control System. l 3.6 17 Not applicable to Callaway. See Conversion Comparison Table I (Enclosure 6B). ; 1 DN 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 blind _ -
flanges",
,following eachonce per 24ofmonths reinstallation whenjeac the blind flange the blind aysflange is instal the nd 'ge 1 .a witptf19pdaype1't o in ve)
, nt lind fra/remopv nge Js r ed. Qnis SR recognizes tnet cycnno the Talve could introduce additional seat degradation beyond that occurrin) to a valve that has not been opened, and allows the use of a leak rate I
__ tested blind flange to isolate the nonotration flow Dath./T ' c)nfhg
} is consistpnt'gSRW.7 fof. tfiiicopteTnmentgpur fvve 3.6-19 ConJiiftentwithCTS . 1.7. R 3.6 .7 is dised t eak rat est
/ ,h6 mini t p6rge v es in a ordanc with t Contai nt Leas ande wy' Rat je y d 34-0 Testi Progra after o ning fo testi once h 184
\Theleakratetestacceptance thin
.92 ays af ooenin he_valv Triterion 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 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 6B). () 4 w .ts.e t d ' A . 0:L T rs sk u.a O ( L n q [un n a m
&M2 JUSTIFICATION FOR DIFFERENCES - TS 3 5/15/97
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Page 2 of 3 CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 SECTION 3.6 APPLICABILITY TECH SPEC CHANGE COMANCHE PEAK WOLF CREEK CALLAWAY DIABLO CANYON NUMBER DESCRIPTION Yes Yes - No - CTS has I hour No - CTS has I hour 3.6 8 This change would revise the conpletion time for the completion time. completion time. restoration of containment pressure from 1 hour to [8] hours. The [8] hour completion time is consistent with the current TS. Yes No No No 3.6 9 These portions of the specification do not apply since a containment cooling system is not part of the CPSES plant design. Yes No - CTS in gallons No - Callaway does This change would replace the Chemical Additive Tank volume Yes 3.6-10 not have this limits in gallons with tank level limits in percent. system. Yes Yes Yes This change would provide that the Required Action to Yes 3.6 11 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.
,Ws' Yef , g j}_
3.6-12 Isist t with 5 3.6.3.8. this chan would ovide that Je1f MA /YA NA olation ime test g is no required or aut tic c0 3.6. 3 co ainment isolation alves t t are 1 ed, sea , or othe ise sec ed in t r requi d positi under
\ admini rative ntrol. g._ty._J A clarifying note is added to SR 3.6.3.7 that would allow Yes Yes pg, yg 3.6-13 that leakage rate testing for containment purge valves with { p 3,c ,3yz/]
resilient seals is not required when the penetration flow path is isolated by a leak tested blind flange. No No No This change would incorporate DCPP specific operability Yes 3.6 14 criteria for containment fan cooler units required to meet design functional requirements. No No Yes SR 3.6.6.7 would be modified to reflect Callaway plant No 3.6-15 specific requirements for cooling water automatic functions as well as containment cooler functions. 5/15/97 rnwrosinu rOMPARTSON TARI F - NUREG-1431
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 3.6.3-13 APPLICABILITY: WC, CA p) i V REQUEST: DOC 7-08 M DOC 7-04 R 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 surveillance not only verifies how long the valves have been open but also verifies that these valves are closed. The corresponding ITS SR would be iTS SR 3.6.3.2. The CTS markup adds this ITS SR usir.g 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 Restriciive 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-purge valves closed. The existing requirement to verify, every (qN./
)
7 days, the cumulative time that the valves have been 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 speciSc 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 O 3.6.3-15, DOC 7-04-R has been changed to DOC 7-04-LG l and is applicable only to DCPP. Therefore, in response to this question, DOC 7-06-M has l been revised to be "Less Restrictive - Specific," and its scope has been expanded to l address all changes associated with valve closure status and tracking the cumulative time that the containment mini-purge valves have been open during a calendar year. New DOC 7-08-LS-28 covers the following proposed changes: (O'
+ 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.
i
l 1 Tha r:quir;mtnts associlitd with trecking th3 cumulative tima that the containment mini-purge valves have been open during a calendar year would be l i A eliminated. These requirements are the Surveillance Requirement to determine V)
! 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. j
- These proposed changes will make the Callaway and WCGS ITS consistent with NUREG-1431, Rev.1, requirements for mini-purge valves. The ITS Conversion submittal has been marked up to replace DOC 7-08-M with new DOC 7-08-LS-28.
ATTACHED PAGES: Att. No.12 CTS 3/4.6 -ITS 3.6 l Encl. 2 6-11, 6-12, insert D for page 3/4.6-12 l Encl.3A 6,7, Insert 3A-7c Encl. 3B 4, 5 Encl. 4 1, new LS-28 l l l r \ l V l i
- Vf l
l i
/--C7. A $.3'&,*0-1 -
ITEVJg CONTAINMENT SYSTEMS ' 1 CONT AINMENT VENTILATION SYSTEM
'. " C 'k*
twni-r-qc. is et a% v.he. 8 6
- p4 r A O f a n y ru a r)
( "" T' LIMIT]NG CONDITION FOR OPERATION valve shall be 'l- O l- A 3.6.1.7 Each containment purge supply and exhaust isolation OPERABLE eerd-E:;h 25 n:t :;. .tein . nt thrid:.: ;;r;: :r;;13u uhou; i . ;; . . L7. 7-//-45 7 81-46 ch: ??11 ha M aW rad M ar? 'hng:d, =d
,c w _
t. The 1* 4 9 ::nt:irrent ci.i p ;g; ; ppl3 and p..;;.t H M :tica O C 'W t vel ;(;} -ry be aper 'er 2; t: 2000 he.. do. 3 e ;el;nder p rr.-7,05-I.5 23 Q 3 6.3 APPLICABILITY: MODES 1, 2, 3, and 4. // ] a>.ur'r im. ACTION: yK+ y yy g lI-0F4 -j,j upplyand/orexhaustisolation ~7-o f-4 G
- a. th a O!-r containmentfpurge valve open ednot blank flanged, close and/or blank flange that 7. fj_ gg valve or isolate the penetration >4 within 4 hours, otherwise be in //-lZ-A at least HOT STANDBY within the riext 6 hours and in COLD SHUTDOWN within the following 30 hours. p*W Pdh jty.r.3-1[
ith the 1S 'n;h cento.i.e..t mini purg; : pply :nd/:r exh:u t 7.od-u 2# '
t.
#a- Tere thir 2000 h:;r; dur r; i
- C:rd- r L i:: h tie., ,ei.e(;} 0;e" j s
p r, ch;;. th; :;;;n ;S 'ach =h;(;) ;.7 i;;ht; th; p;ai. etion' ethm ies t,e ir ;; 1;;;t "0T STAN00Y ;;... . tim ning_""]f__::. J 4 t;.;n 4 ;.eo.5,
'[',] 5- he.. a , ;nd ' - CO LO 5"L'TOO'm. ' -ithin the f;Ihnin; 20 he ;r;. g-J
- c. With a containment purge supply and/or exhaust isolation valve (s) having a measured leakage rate in excess of the limits of the 4 -cre-2M e 7-02 -L5 Specifications 4.6.1.7.2 and/or 4.6.1.7.4,ge:ter: otherwise be in at least f.,pq f5 v i ;(;) t: OoE " " LE :t;; ;; ith'- 29 5:;r n, BOLD SHUTDOWN within 7,,,, g,, ts HOT STANDBY within the next 6 hours, and the following 30 hours. g j TbD
- 7-ou - o 7-0 S*'A J-o4-LC DWW 0 j t-o f-LS n-o2. -A 3-/3-A l-o y-t.s J/G 6-11 _
CALLAAY - UN E wue D s AWWW & jaA O & ~ P^ W f c m n m x s a m a y 1. o. n
- f. rom w mooscy-~te+,-t .e .
w re n nQ J W~ m e s A -
i
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CONTAINMENT SYSTEMS h ? 5 #'/ c\ j (J J . G, . 3 - 23) SURVEILLANCE REQUIREMENTS wa i a-ts c 4.6.1.7.1 Each 25 'n:F containment s down upply and exhaust 7 - e t L6 ; fl anged -eed- ci ast r-ll-'S^ l isolation valve (s)* shall be verifi J n - er m l once per 31 days,, . Insert A <, RLi..)'i[ hg 7. oN'- - - I 4.6.1.7.2 Each2".n:hconi.ainmentshutdo(Q1.c.M- urge s eak tested at pr.ty' l isolation valv 7-17-M least once per[_4 nth:: pits associated
- nd following each blank reinct:ll:flange tion f the sell ue fg blank 333-27, f,:r.g: wher pre::ur f P , io.1 p:ig, :nd ver4fying that .; hen the g 3, c 's' _.y --
-::::.:ured leakane rd:e d t:for th,::: v:.lve: :nd fl:ng :, in;1edii.g sta= 7- } "
i
-l ekegt, iaed3ed det:~-ined pursgain. i.u !
Saecificatier 4.0.fe the 1::k:ge rate' " ' r :11 ether Type B 1"d C penetr: I _ tio i c'edined 10:k:ge - 'han 0.00 L,.s.I g p 3.c.i- 4 hu..*3-LVJ ' f.S.I.7.2 The ce= M a +4 +h=+ =11 'n 4achcpen centada-ent rini purg
--supply :nd ::h:.ust isoletion ::lve: haue baea during e celeud.. .reir- M _ m_
-rhall ha riata -in:d :t 1;::t :n:: per 7 d:ys. a 3J 3-13J 9 ro u..s- m 4.6.1.7.Mt least once per 43 :: nth each IS dn:h containment mini-purge '-"* '""
supply and exhaust isolation valve with resilient material seals shall be **#
- i demonstrated OPERABLE by verifying -the the measured leakage rate,i: 1::
-ther. 0.05 L, h;n pressurized to P,. y ) a 3 u.r - q )
q te4 % a a.au % s g # Q 13.'39)
~1-o Bp<
a,.u (Mw) In **cd. D a 3.c.3-n 1 l i O
- Except valves and flanges which are located insid containment.
These valves shall be verified to be closed "i+' ["'- blank flang installed prior to entry into MODE 4 following each COLD SHUTDOWN, Qpd permed in previous U Rf.s (
/-D'{-LS CALLAWAY - UNIT 1 3/4 6-12 Amendment p.rq .
- k ,
i y i , . t Y - v. I INSERT A FOR PAGE 3/4 6-12 (7-03 Al i except for one purge valve in a penetration flow path while in Action 3.6.1.7.c as a
, result of measured leakage rate in excess oflimits. l r
INSERT B FOR PAGE 3/4 6-129-07 LG)
-) a s.c..tA .
l in acc ance wi e Cont t Leakage R- e Testing P gram of Spe ication i 6.8 .g. l 8 . ; INSERT C FOR PAGE 3/4 6-12 (7-06 LS) l l 24 months with blind flange installed, and following each reinstallation of the blind
- flange, very 184 days with blind flange removed, and within 92 days after [
p opening e valve with blind flange removed.
+
l V) u-z.s hr. 3- /[ i INSERT D FOR PAGE 3/4 6-12 (7-08M i l
- i. Each contamment Inini-purge supply and exhaust isolation valve (s) shall be verified closed, except when the contamment mini-purge valves are open for pressure control, [
ALARA or air quality considerations for personnel entry, or for surveillances that require the valves to be open, at least once per 31 days. k INSERT E FOR PAGE 3/4 6-12
+ Isolation devices in hich radiation areas may be verified by use of 1-od-'S I Q 3 ' 2 -d c a+ %trative means.1 I # ent mini-purge s ves 7 -,o-t 5
\ Leakage rat 'esting is not r, ired for con w1 esilient se when the pene tion flow pa isolated by a 1 tested l C blind flan _ - _ .
Cor eN/ a,, k;m,d d~ Hod pn*ye ny y[/ a d e rA d e f' & rGH 6 tu.x /a.r,w & hw one per- Q 7.4.P;W l r E y , _ _ . _ . .
'd
[ INSERT A FOR PAGE 3/4 6-12 (7-03 A) except for one purge valve in a penetration flow path while in Action 3.6.1.7.c as a result of measured leakage rate in excess oflimits.
'i' INSERT B FOR PAGE 3/4 6-1257=07 LG)'
l a s. c..t-L ) in acc ance wi e Conta' t Leakage R e Testing P gram of Spe 1 cation 6.8 . g. ! t I , INSERT C FOR PAGE 3/4 6-12 (7-06 LS) 24 months with blind flange installed, and following each reinstallation of the blind flange, very 184 days with blind flange removed, and within 92 days after 7 l opening e valve with blind flange removed. ! u
- 4. 5 -z. i [ 3.L.3- /[ i INSERT D FOR PAGE 3/4 6-12 (7-08g Each contamment mini-purge supply and exhaust isolation valve (s) shall be verified closed, except when the containment mini-purge valves are open for pressure control, l l
ALARA or air quality considerations for personnel entry, or for surveillances that - require the valves to be open, at least once per 31 days. l 1 INSERT E FOR PAGE 3/4 6-12 l
+ Isolation devices in high radiation areas may be verified by use of I-o* 'S c Winigrative meansh I43M I # 7 -so-t 5 L Leakage rat. testing is not r-, ked for contat ent mini-purge ves wi esilient se when the pene tion flow pa l ' isolated by a le tested
/ J C blind flan ~ -
a N rro ead coi, %>w& sL'*" ?"'7* 'Wh b
- #d "'A'"*
na n w w s w o ~ c ,c ,- 9 zum f-
~ s , , .-- ,. - .- + e ,--
CHANGE j NUMBER N1HC DESCRIPTION ' 6 02 A Not applicable to Callaway. See Converion Comparison
. Table (Enclosure 38).
6 03 TR-2 Not applicable to Callaway. Ses Conversion Comparison i Table (Enclosure 38).
]
6-04 M Not applicable to Callaway. See Conversion Comparison i Table (Enclosure 38). . i I l 7-01 A Consistent with NUREG 1431. the LC0 and surveillance : requirements for containment ventilation / purge valves are now included in Section 3.6.3 for containment isolation valves. , l 7-02 LS 9 Consistent with NUREG 1431 the required action for a l containment ventilation / purge valve with a leakage rate l ) which exceeds the acceptance criteria is revised to allow l 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 considered acceptable because with the associated l penetrations isolated per the proposed Action l requirements, no accident as a result of the leaking valve ! O is credible. ! l V 7-03 L.6-Zb
-A-
/
l change [for CTS 3.6.1.7.c] consistent wi G-1431 , SR .1 is added to provide an ance for one Q 3, l,.3 j l g[/44 isolation performing the e in a penetr e n flow path to be open when tions for leakage not within I4/ limits. This is a a consistency change which goes 4hINId with the revi reouired actic see 7-02 above). The l ggg ) required 1on allows continued oper n with leakage m not in limits and this change to the S llows a valve [TQ3.f..-O e ?ned to repair the excessive leakage. f= = g} y l 7 04 w
-R -
u;xw . w . I The time l'fdt restrictione on opening 11e [ mini- 'rge
~ y = M.,. -
~
i l supply d exhaust] valv and the r uirement to cally accumulat the time tP t the val es have _en 8 (perioopeft would be rCoc id to licen e control ed docum ts7 r g / [ K g d@-u.\ 7-05 A Consistent with f6 REG-1431. an action is 'added for two valves inoperable in one penetration flow path. The change is administrative since the current TS would have relied on LCO 3.0.3 which has essentially the same requirements. h 7 06 LS 11 Consistent with NUREG 1431. the leakage rate testing l Q frequency for containment isolation valves with resilient seals is revised to 184 days based on the NRC resolution i- DESCRIPTION OF CHANGES TO CURRENT TS 6 5/15/97 I
CHANGE NUMBER R$liC DESCRIPTION of Hulti Plant Action No. B 20. " Containment Leakage Due [ j to Seal Deterioration." -Testing vo a sloggered Lesi Losi5-(j - ic ^^ lenger rcquired. A acw requi remcat4as-ala- beca , _added-tc perferiii e leakoge test within 92 days M pening tha vme ; to reuvwuke sai ujclir.g - .oi ve uvuiu intr 6 duce addiLionoi desi degreceuon oeyond UiaL- lf 3 3 ~" b
,._occwring to e volve Uial has uvi Leen creaed.. . . t 3 A -7h 7 07 L8 Consistent with NUREG 1431. the leakage rate test 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 not directly tie to safety but indicates degradation of the resilient seals. ITS SR 3.6.1.1 is the leak rate which ties to the safety analysis. []
31 day SR to ver'fy mi [ Q 3.6.1-I3 ) 7 08 .7 T'schangesadds purg vaives L S- M clo d exc t for a orize easons. This ds a e strin t req ement at is ropriat or c tai 71 f 3A-7c. 4 isolatio valves cons tent wi NUREG-1431. 7 09 LG The descriptive details regarding the valve size and isolation requirements for the LCO have been moved to tha , ITS 3.6.3 bases. I-J Q 3.C J- M- / ( 7 ),! 7 10 LS 9 A note s added to clarify that leakage rate testing is ]FQu.3-1/]
'" not requ ed for conta'nment purge ' valves with r ilient f* seals whe the penetrat n flow path 's isolated b a leak p'e qg tested blan flange. The urpose of t leak testin .
- r uirement i to ensure co tainment lea e integrity D' NNAh.
~ ~ ~ "
dur g an acci t, and ther limit acci nt 6 p= y conse ences. Is lation of th flow path wi a leak tested ind flange ccomplishes his safety fu tion and additiona leak testi of the val s in the flow ath is (redundantandunnecessary. l Q 3.c.1- El 7-11 LS 25 Removes the requirement from CTS 3.6.1.7 surveil nce ' - requirements to blank flange the containment s tdown -
~
purge supply _.and exhmist valve nd rev se~s t' y :* !A 7( sur tTlanc e en rvefrfic ion clo [a3,6 yh ehwn Hrae Ives fl3Mes inside onta t TAllc L i A -f (p 3.f.,3 - 3 )l men 8 01 LG Consistent with NUREG 1431. the LCO references to suction flowpath and manual transfer of suction to containment sump have been deleted. These details are included within the operability requirements of the Containment Spray System (as required by SR 4.6.2.1 and as further described o in the Bases). There is no technical change resulting f I from this deletion. 'v' 7-/G A T a 3a- u JT3. c . 3_ a PO M IMA G .1-$ DESCRIPTION OF CHANGES TO CURRENT TS 7 5/1 M 'C M M - le lo t A.3 - ul
. ___.__m._ . . - . . _ _ . . _ _ _ . _ _ _ _ - _ _ . _ _ _ _ _ _ . _ INSERT 3A-7c Q 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 mini-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 i 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 sllowable 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 LCO 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 govemed by the ' requirement that they remain closed unless opened for an allowable reason. Operating the mini-d 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 i either plant was 535 hours in a year. l 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 l 1 l INSERT 3A-7c (continued) Q 3.6.3-13
.. . . - - - . _ _ - . . _ .-. ._ . - _ . - . . - - ... - - - - -.,. ~ -. - .
I. c
?
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 all times
- during plant hfe.' The capability of the valves to perform their s.lety function has been i
demonstrated by a qualification program based on testing and analysis required by NUREG- [ 0737, issue ll.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 ! trie limited time that this flow path is in service is very small. i : l . Absent the plant shutdown requirement associated with exceeding the cumulative time limit and l failure to isolate the flow path, the mini-purge valves would continue to be governed by other l containment isolation valve specifications and plant shutdown requirements should the valves be j . inoperable, , ?: j [. : i t I ! l f
?
i I e f Y i i ! b ! 4 h 5 6 f l I l' l: ! - . _ . ,
( (- \ f
\
1 \ I
/ ! !
U / k./ % CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 4 of 11 TECH SPEC CHANGE APPLICABILITY DIABLO CANYON COMANCHE PEAK WOLF CREEK CAllAWAY NUMBER DESCRIPTION 6-02 The inspection requirements associated with structural -Ves- Ab, Ic e Yes No - (3.6.1.6 not Ne - (3.6.1.6 not A integrity of the exposed accessible interior and exterior containment surfaces, are contained in Appendix J. Option B g g***' g in CTS) in CTS) and in RG 1.163. / 2.M/ f 6 03 Reporting requirement for Containment Structural Integrity be Yes No (3.6.1.6 not in No (3.6.1.6 not in
-Ves~
/$wfc Ab, M/b/tts CTS) CTS)
TR 2 are deleted. 6 04 A0T for Containment Structural Integrity not estabiished Ves- Ah, le < Yes No (3.6.1.6 not in No (3.6.1.6 nct in H decreased from 24 hours to I hour. -h /g ,,g fa;/jgf CTS) CTS) The LCO and surveillance requirements for containment Yes Yes Yes Yes 07-01 A ventilation / purge valves are now included in ITS 3.6.3 for Containment Isolation Valves. Yes Yes Yes Yes 07-02 The required actions for a containment ventilation / purge LS-9 valve with a leakage rate which exceeds the acceptance criteria is revised to be stated on a per penetration tiow path bases. Yes Yes Yes Yes 07-03 A clarification is added to allow one isolation valve in a
-*- L.5-2. f. penetration flow path to be opened for repairs when performing the required actions for leakage rate not within limits.
07-04 The time limit restrictions on opening the [ mini-purge Yes - Relocated to No - CPSES does not Yes Refoca to Y[-R e oca C pteV16 to/ the ECG. have restrictions Mie
--R-supply and exhaust valves] and the requirements to JEht Lh on these valves.
periodically accumulate the time that the valves have been f13 4 3 ~ # 8~ open would be relocated to licensee controlled documents. A Yes Yes Yes 07-05 An action is added for two valves inoperable in one Yes A Pnetration flow path. No - See Yes Yes Yes 07-06 The leakage rate testing frequency for containment LS-11 isolatioruralves with resilient seals is revised to 11-13-LS-22. etmerM test,-basis-4: c lenpr 184 days and t mting nn a requir . A i.c., ceCr;; ac..t 15 6150 6dded to perfom a [O 3 -4 3 ' 2 L -
-Icakage testMtMe-92-daya vi upening Um vahes.
c 4 -&t 7-se-ts-z] la s. 6. 5 ~& 5/15/97 CONVERSION COMPARISON TABLE - CURRENT TS
O m d CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 5 of 11 TECil SPEC CllANGE APPLICABILITY tGtBER DESCRIPTION DIABLO CANYON COMANCilE PEAK WOLF CREEK CALLAWAY 01 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. 8 Adds new requirement to perform a 31 day surveillance to No - ady No - CPSES does not Yes Yes 4&- verify closure of the mini-purge valve a have any closure f S'U restrictions on Q 16. 3- /J r_ Jire t.
@ ?-t l c.T$) this valves.
07-09 Details regarding the valve size and isolation requirements No - CTS does not No - This detail is Yes Yes tG have been moved to the ITS bases contain this not in the current , requirement. TS. l t 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 JerM* y#8 when the penetration flow path is isolated by a leak tested requirement, , g, y g . bl6nk flange. [ 07-11 Removes the requirement to blank flange the containment No - That' No - That Yes Yes
- LS 25 . shutdown poroe supply and exhaust isolation valves nd requirement was not requirement was not
~Tev ses th survejdlance/egditer.y6t for ytrific ion of part of CTS part of CTS ._
c sed sh down y6rge v/lves and/ flanges /inside [G 3. c.3-r./ ( , [t ntai nt.J ; y . ,
" 08 01 The LCO references to suction flowpath and manual transfer Yes Yes Yes Yes (G of suction to containment sump have been de!eted. These j details are included within the operability requirements of the Containment 5 pray System as described in the Bases.
08-02 This change revises the action statement by replacing the Yes Yes Yes Yes A reference to restoring the Containment Spray System to j operable status within 48 hours or be in cold shutdown l within the following 30 hours. with the requirement to be in cold shutdown within 78 hours. 08 03 The actuation surveillance is revised to clarify that an No LA 114/112 made Yes Yes Yes 1R 1 actual signal as well as a test signal may be used to this part of CTS : 1 verify actuation. The specific actuation signals that I apply for automatit actuation are moved to the Bases. l
~7Il ]~JSecT 7 7 ya et 1. c. 3 - 2.1 J $3.L.3-17 CONV SION C0t1 PAR i TABLE - CURRENT TS g g g gJ- 5/15/97
. _= . - - _ .. _ ._ _ _ _ _ . . - _ - __
ENCLOSURE 4 i m 4 -G' ' N0 SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC) CONTENTS I. Organi zati on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 "LG" - Less Restrictive (Moving Information Out of the Technical Specifications) . . . . . . . . . . . . . . . . 11 "M" - More Restrictive Requirements. . . . . . . . . . . . . . . . . 13 1 IV. Specific No Significant Hazards Considerations "LS" h) i v LS 1........................................... .... 15 LS 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Nd. Arg. . 47- 8 9. 6. 6 -# LS 3................................................ 19 LS 4................................................ 21 LS 5................................................ 23 LS 6................................................ 25 LS7...............................................27 LS-8................................................ 30 [ a 3.6-3-21 LS - 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . NJ. M. . .iB- , . LS 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Noi. u s ea - N , Q3U-4 LS 11. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 5 LS 12. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS 13........................ ...................... 37 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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS-19............................................... 42 LS - 2 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not U s ed LS 21..........................................Not Used LS - 22. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS 23............................................... 44
% LS 24..........................................Not Used
.............. 46 s
LS-25......{..........w............. ts .-U. a.v'l. I
& 145-9
;- m.up L, 3 \ Q 3. (.. F B 1 NOSIGNIFICANTHAZARDSCONSIDERATIONS 1 5/15/97
,a. -
Q 3.6.3-13 l lq INSERT 4-a l l (V) IV. SPECIF!C NO SIGNIFICANT HAZARDS CONSIDERATIONS l ! NSHC LS-28 l 10 CFR 50.92 EVALUATION FOR 1 TECHNCAL CHANGES THAT IMPOSE LESS RESTRICTIVE l l REQUIREM ENTS V.U HIN THE TECHNICAL SPECIFICATIONS l The proposed changes would decrease he frequency for verifying position status of mini-purge valves from once per 7 days to th ;e pv 71 days and would eliminate the requirements associated with tracking the cumulay bme that the containment mini-purge valves have been open during a calendar year. These (Nuirements consist of the surveillance to determine the l cumulative time that the vslves are open, the LCO statement thet 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 specified limit and the associated penetration cannot be isolated l within the next 4 hours. Changing the surveillance frequency from 7 days to 31 days is acceptable because this change ) l 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 i l valves, as noted in CTS Bases, specify that the valves should be opened only for safety-related i reasons. The proposed ITS SR 3.6.3.2 Bases specify that the valves would be inoperable if ) l!p) l 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 ! V 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. l Eliminating the LCO limit on cumulative time, and its associated Action Statement and : i surveillance requirement, are acceptable changes because, as stated in the Bases for proposed I , SR 3.6.3.2, the new surveillance would assure that the mini-purge valves are closed as required l or, if open, open for an allowable reason. Therefore, although the cumulative time limit l l requirements would not be in ITS, the mini-purge valves would continue to be governed by the l l requirement that they remain closed unless opened for an allowable reason. Operating the mini-l 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, i 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. I However, the mini-purge valves are designed to meet the requirements for automatic containment isolation valves and are capable of performing their required containtnent isolation function at any time following a DBA, even during a loss of coolant accident. Following a design l 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 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 thet the (Q Nj 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 l testing and analysis required by NUREG-0737, Issue ll.E.4.2, for purge valves intended for use ! during plant operation. Thus, containment isolation is assured by the design of the valves. l l
- ~ . -- - ~ .- .. - . - . . - ._ - - - - . - _- . - . - - . - - . -
l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS I p NSHC LS-28 (continued) 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 l 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 l the criteria set forth in 10 CFR 50.92(c) as quoted below: I "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 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."
h Q 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 ceasistent 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 the 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 analyzed accidents by isolating containment as required. Thus, the consequences of accidents would not be adversely affected by the changes. Therefore, the proposed cr,anges would not result in a significant increase in the probability or consequences of a previously evaluated accident.
- 2. Does the change create the possibility of a new or different kind of accident from s any accident previously evaluated?
The proposed changes to surveillance frequency and elimination of the requirements associated with cumulative time that the valves have been open do not involve any
i IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS p) ( v NSHC LS-28 (continued) physical alteration of the plant. No new or different types of equipment or components will be installed. Also, the proposed changes do not involve new methods 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 changes to accident analysis assumptions, initial conditions, or results. The change in surveillance frequency from 7 days to 31 days would have no adverse effect on valve OPERABillTY; 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 (O) k' r 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 foilowing a DBA, even during a loss of coclant 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. 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 no significant hazards consideration finding is justified. x -) - x .
- . - - - . - , . _ . . - - . - - - ~-- - --. - . - . - - . . . . - -
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: O 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) l 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 l cumulative time purge valves, vacuum / pressure relief valves and mini-purge valves l may be opened per calendar year. The CTS markup shows these items as being L relocated and justifies the relocation in DOC 7-04 R. The "R" designation is for l 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 controlled by 10 CFR 50.59 i respectively. The DCPP document "ECG"is not defined in the submittal. in addition, l l no justification is provided as to why this information can be relocated. I l Comment
- Revise the CTS markup to show this change as a Less Restrictive change l and provide additional discussions and justification for this Less Restrictive change. !
The justification should include the reasons the individualitems can be relocated. For DCPP describe the document "ECG" and the document change control process. I FLOG RESPONSE: (original) DOC 7-04-R is revised to 7-04-LG since this information is l 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 flow 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 (DLAP) ! OP1.DC16, " Control of Plant Equipment Not Required by the Technical } Specifications." DCPP ECGS are similar to other plant's Technical jf Requirement Manual (TRM). Changes to ECGS are made under the
- \, provisions of 10 CFR 50.59, as required by DLAP OP1.DC16 and FSAR Chapter 16. The NRC has accepted ECGS as a licensee controlled
~...- _ - - -_ _- . - _ . - , _ - - - . _ - - - . . . - . ... - = . - - . _ . -
1 document. This is confirmed most recently in License i Amendment 120/118 dated 2/3/98, page 2 of the NRCs safety evaluation report. l O FLOG RESPONSE: (revised) Changes for Callaway and WCGS, that were previously addressed by DOC 7-04-R, have been integrated into new DOC 7 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 l combined with the low probability of a DBA while this flow path is in service makes the total risk very small. 1 Diablo Canyon has Equipment Control Guidelines (ECGS) that'are controlled by DCPP Depanment-Level Administrative Procedure (DLAP) OP1.DC16, " Control of Plant Equipment Not Required by the Technical f Specifications " DCPP ECGS are similar to other plant's Technical ( Requirement Manual (TRM). Changes to ECGS are made under the , l
's provisions of 10 CFR 50.59, as required by DLAP OP1.DC16. The NRC !
has accepted ECGS as a licensee-controlled document. This is I confirmed most recently in License Amendment 120/118 dated 2/3/98, j l 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. l l-IO
ADD!TIONAL INFORMATION COVER SHEET t l O)
\
O 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 i 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 l 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. 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 that the preponderance of the changes would result in the chuge 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 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-p\ (Q 21 for additional 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 comment 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: i 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 i containment shutdown purge isolation valves with or without blank flanges installed. The DOC supporting the proposed changes (DOC 7-11 LS-25) is discussed in the response to Comment Number 3.6.3-21 m and 3.6.3-24. To further support the Callaway and Wolf Creek changes,
/ T DOC 7-11 LS-25 has been modified to employ the NUREG-1431 test 5,j frequencies of 184-day and within 92 days of opening as mitigating l
I factors in the overall relaxation of test requirements for the containment shutdown purge isolation valves. I \ )\ 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 i 92 days of opening a valve. The DCCS that justify these changes are discussed in the response to Comment Number 3.6.3-20. In responding 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. l 4.6.1.7.4 - For DCPP and CPSES, this is not applicable because this I surveillance is not used. For Callaway and Wolf Creek, the proposed l changes revise the testing frequency for the mini-purge valves from 92 l days to 184 days and within 92 days of opening a valve. The same l DOCS (7-06 LS-11 and 7-16A) discussed in the response to Comment l Number 3.6.3-20 also are applicable to the proposed changes for i Callaway and Wolf Creek. l 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 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 1 response to Comment Number 3.6.3-18. /m 1 U FLOG RESPONSE: (supplement) As discussed at the meeting on October 13-14,1998, the 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 as follows: 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 changes revise the testing frequency for the mini-purge valves from 92 days to 184 days and within 92 days of opening a valve. DOC 7-06-11 was used to justify the change from 92 days to 184 days. DOC 7-16-A is used to justify adding "and within 92 days after opening the valve. ATTACHED PAGES: None g i t
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ADDITIONAL INFORMATION COVER SHEET cx ADDITIONAL INFORMATION NO: O 3.6.3-21 APPLICABILITY: WC, CA { ) ( ,/ REQ' JEST: DOC 7-06 LS-11 JFD 3.6-18 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 92 days 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 concems 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 n DOC 7-11-LS-25. This is the case for adding proposed surveillance requirements for leak V) ( testing the valves alone - without blank flanges. CTS 4.6.1.7.2 provides requirements associated with testing valves and blank flanges; while proposed ITS SR 3.6.3.6 provides more operational flexibility by providing the altemative of testing the vaives without blank i I 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 attemative of operating without blank flanges. ; Nevertheless, the overall proposed change is considered to be less restrictive. i The CTS markup for WCGS inadvedently omitted the additional Frequency of "184 days and within 92 days after opening" for these valves without blank flanges installed. The i 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 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 of the requirements to blank flange the shutdown purge valves. DOC 7-10-LS-9 has been I deleted for Wolf Creek and Callaway based on new 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
/N revised as discussed at the meeting. This supplemental response supersedes the l i response to Comment Number 3.6.3-24.
I O
Th3 propossd chang 3 to allow ths 36-inch shutdown purgs and exhnust p:nstrations to be isolated by either the shutdown purge valves or a combination of valves and blank g flanges is acceptable for the following reasons:
\'s
- 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 determine leakage rate of these 36 inch shutdown purge valves. The ' i extended test interval applied to Wolf Creek and Callaway was a 24-month i leakage test requirement based on the use of a conibination of closed valves and !
- blank flanges.
{ . 2. The improved STS do not address the use of blank flanges on containment I shutdown purge isolation valves. Improved STS apply to the use of isolation j 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. l 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 e 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:
, ( Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 2 6-12, insert E for Page 3/4 6-12 Encl. 3A 7, insert 3A-7a, insert 3A-8e Encl. 3B 5, Insert 3B-Sc Encl. 4 Index,33,34,46,47 Encl. 5A 3.6-16,3.6-17 Encl. 5B B 3.6-28, insert SR 3.6.3.6, B 3.6-30, Insert SR 3.6.3.7 a and b Encl.6A 3, insert 3.6-19 Encl. 6B 2, 3 l [ l k 1 j
l s
/-07-/4 CONTAINMENT SYSTEMS hI S #'/
p) 1 U SURVEILLANCE REQUIREMENTS
-~
wa d3.G.3-2N) f_og 4s upply and exhaust 1 L6 4.6.1.7.1 Each 25 'nch-containment s down isolation valve (s)* shall be verifi J(flanged-end-clop , ast 1- H-'S once per 31 days,, . Insert A o o he_ m ^- 7- os -ts
.nc., con m nment shutdo CO 3.c urgea-2f[ct3.c.)-4 supp [e exhaust- Oy ;
4.6.1.7.2 Each " ! 7-17-d isolation valv pits associated blank flange shall oe eak tested at F . least once per 4 n :nd fell wing each *ein:t:11: tier Of the t,lenk ,.e 4 3 64-2f, fl;ng: wh:npre::ur5:th: ? , 48.1 p:ig, :nd ver4fy4ng th:t .; hen the g_.u
-^""-ad leakage rde d t:for th,:: v:lv:: :nd fl:nger, incied; .g sta= 7-l 1;;kagt, is edded rater dete-"ined pursce.d Lu Speci'!:stien i.0.ye the 12:k:g: E 2ad C penetr:tient,' the I cembi-ed 1::k:ge ir- @.1 h d S r ;11 ether-Typ:e u Q.'han ;.<..' 3. 0.00 z_9) L ,
43 4,5,2,7,9 T he -,,- stiJn +4 +ks+ .11 to_4nrk en-+s4n-e + purgg, I _, _, i
- tpply :nd 2:h:;st isolation v:lver have been cpen during e celendo per '" "
-Shell ho dato -in;d et 1 ::t ene; per 7 d:ys, g 3.c,3-[3 J
- 7 ro u, . 3 -u i 4.6.1.7./8dt least once per 43 m: nth: each IS 'n:h containment mini-purge * *
- supply and exhaust isolation valve with resilient material seals shall be '-'" '
l demonstrated OPERABLE by verifying thet the measured leakage rate i: 10:'
-then 0.05 L, when pressorized t: P,. ) 9 3 u, r _.q , , ,
A _ O 3 I~ J 7j d4kN ub d A.4 92. kp d open,g A n p 1 (Meu) .Inket D 7-o teu G- c
~a s.u.s-a } l l
1 I l l OY
- Except valves and flanges which are located insid containment.
These valves shall be verified to be closed with [h:ir- blank fla installed prior to entry into MODE 4 following each COLD SHUTDOWN, Qpet pev$ermee in previous 91 by G) WhN THWRT~ G i s -L 5 w _ t r-CM1AWAY - UNIT 1 3/4 6-12 Amendment o. & 103 L.
i s 1
'-E , 1 1
INSERT A FOR PAGE 3/4 6-12 (7-03 A) ! 3 except for one purge valve in a penetration flow path while in Action 3.6.1.7.c as a < result of measured leakage rate in excess oflimits. ; i INSERT B FOR PAGE 3/4 6-129-07 LG) ,
) ca s.c..t-L} i inacc ance wi e Cont t Leakage R e Testing P gram of Spe 1 cation !
6.8 .g. - j s INSERT C FOR PAGE 3/4 6-12 (7-06 LS) 24 months with blind flange installed, and following each reinstallation of the blind flange, - very 184 days with blind flange removed, and within 92 days after , opening e valve with blind flange removed. I L.s -21 fL. 3-Ik INSERT D FOR PAGE 3/4 6-12 (7-08 M Each contamment mini-purge supply and exhaust isolation valve (s) shall be verified closed, except when the containment mini-purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for sr veillances that require the valves to be open, at least once per 31 days. k INSERT E FOR PAGE 3/4 6-12 l
+ Isolation devices in high radiation areas may be verified by use of I-o4-'S I43'-d I #c-Winistrative means_
Leakage rat testingis not r- ' red for con a ent mini-purge s ves 7 -ro-L 5 w esilient se when the pene tion flow pa isolated by a ic tested i J t blind flan. _ _ l Cor e a c A a ,, k m -f sL-hba pnefe 'befl} a d c/A<kN- V' N
.a a 6 w x k,w s ka+o-cpan 9 2.u-;w f
i
r CHANGE NUMBER R21C DESCRIPTION l 7 of Multi Plant Action No. B 20. " Containment Leakage Due
/ 1 to Seal Deterioration." -Testing vu a naggered ten basit C/ _R-no longer rcquircd. A new requirement-has-alse bccn -
-._added-tc perfers e leakage test within 92 days mpening the v&csadditionai iatreduce to reuvwnbe Uial ujclingoeyund seai degradauon the velve Uial- could @ l 3" b occaering to e valve Uial has ovi Lecn vpened.
7,. . . t 3 A- 7h 7 07 La Consistent with NUREG 1431. the leakage rate test 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 not directly tie to safety but indicates degradation of the resilient seals. ITS SR 3.6.1.1 is the leak rate which ties to the safety analysis. [] g T s cha es adds 31 daygSR to ve 'fy mi purg vaives [ cR 3.4.1-I3) 7 08 L.5- 2A clos d exc t for a orized easons. This ds a strin t req ement at is ropriat or c tai L J 3 A-7c. # isolatio valves . cons tent w (NUREG 431. 7 09 LG The descriptive details regarding the valve size and isolation requirements for the LC0 have been moved to tha ITS 3.6.3 bast , r-4 Q 3C 3-32
-r m .,
1 (~ji 7-10 LS-9 A note 's added to clarify that leakage rate testing is ys.r. 3-2/] not requ ed for conta'nment purge alves with r rilient
/ seals whe the penetrati n flow path s isolated b a leak p qg tested blan flange. The urpose of t leak testin
- r uirement 1 to ensure co tainment lea ge integr1ty D 'b '
~
dur 9 an acci t. and ther limit acci nt 6 g y GNMh. conse ences. Is lation of th flow path wit a leak ind flange ccomplishes his safety fu tion and tested leak testi of the val s in the flow th is (additiona redundant and unnecessary.
} Q 3. r. 3 - 7.1 7-11 LS-25 Removes the requirement from CTS 3.6.1.7 surveil nce ~ -
l requirements to blank flange the_ containment s Jtdowr purge supply. and exhansQ1veQnd rev' es t' 7g 3474 ur a en r ic ion clo 73 3.r,% h dnwn grae lves d fla es 'nside onta_ men _ -
.n/E / 3eg' j 3. 4. 3 - 3 /
8 01 LG Consistent with NUREG 1431. the LC0 references to suction flowpath and manual transfer of suction to containment sump have been deleted. These details are included within the operability requirements of the Containment Spray System (as required by SR 4.6.2.1 and as further described p in the Bases). There is no technical change resulting from this deletion. ('v) 7-/4 A Ta 3a- u gr 3. c ,3_6) ( Fil M IAA 5/1 4 . 3 - 35 I DESCRIPTION OF CHANGES TO CURRENT TS 7 / M M CM M-te jogy,,3,tg]
l Q 3.6.3 24 m [V INSERT 3A-7a i l 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 i 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-operateo onntainment 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 purge supply and exhaust valves and flanges, located inside containment, to be verified closed (of f'anges 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. The revised surveillance interval extension (184 days) described in DOC 7-06 LS-11 is modified [G "*v u1 by the addition of "and within 92 days after opening the valve." The likelihood of leakage is gg further reduced by adopting the surveillance testing requirements of NUREG-1431 for these ( ) , valves with resilient seats when relving nn "'e v2!ves 'Mna to orovide the required isolation J 'Ul Efunction._,(The proposed changes permit using either current TS requirements or NUREG-1431, Rev], requirements for the shutdown purge supply and exhaust valves. 1 O \ i v
e (N 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 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 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 more restrictive change. since the surveillance frequency has been reduced from 24 months to 184 days, even though the blind flanges are not installed.
/3 U
I I l l (O)
h,,- ] v
\v ] (a)
CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 5 of 11 TECll SPEC CilANGE APPLICABILITY NUttBER DESCRIPTION DIABLO CANYON COMANCilE PEAK WOLF CREEK CALLAWAY 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.
-08 Adds new requirement to perform a 31 day surveillance to No - ady No - CPSES does not Yes Yes 4+- verify closure of the mini-purge valve. - a have any closure L p 2.2 r_ sire it . restrictions on [ G 1 G. 3 - 13 /
@L-t _. _ / . c75) 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 testire is not No - CTS does not Yes Jae- p LS-9 required for containment purge valves with resilient seals contain this M de when the penetration f!ow path is isolated by a leak tested requirement. , 4, y g blank I1ange. 07-11 Removes the requirement to blank flange the containment No - That No - That Yes Yes LS 25 shutdown purge supply r M exhaust isolation v_alves nd requirement was not requirement was not
% ses th surve' lanc=/egdireme . t for )/rt fic ion of part of CTS part of CTS , . . ,
c sed sh down irge v[ves and flanges /inside [G 3. c.3-r./ f [cintainirnt.1 P 8-01 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. 08 02 This change revires the action statement by replacing the Yes Yes Yes Yes A reference to restoring the Containment Spray System to operable status within 48 hours or be in cold shutdown within the following 30 hours. with the requirement to be in cold shutdown within 78 hours.
, 08 03 The actuation surveillance is revised to clarify that an No LA 114/112 made Yes Yes Yes IR-1 actual signal as well as a test signal may be used to this part of CTS l
verify actuation. The specific actuation signals that apply for automatic actuation are moved to the Bases.
-7/0 f~JSrAT 7- 7 y4 [CL3.L.3-7.1j 3. L. 3 -17 CONVE SION Col! PAR TABLE - CURRENT IS g g g sJ- 5/15/97
_ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . _ _ _-_-_-________J
/~s
( r~ (.s l () b INSERT 38-Sc 0 3.6.3-21 TECil SPEC CHANGE APPLICABILITY DESCRIPTION DIABLO CANYON COMMANCHE PEAK WOLF CREEK CALLAWAY NUMBER 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 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 the blind flange removed. 1
ENCLOSURE 4 n ! l 9 NO SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC) CONTENTS I. Organization ........................................ 3 II. Description of NSHC Evaluations. . . . . . . . . . . . . . . . . . . . . . 4 III. Generic No Significant Hazards Considerations "A" Administrative Changes......................... 6 "R" - Relocated Technical Specifications. . . . . . . . . . . . . 8 "LG" Less Restrictive (Moving Information Out of the Technical Specifications) . . . . . . . . . . . . . . . . 11 "M" More Restrictive Requirements................. 13 IV. Specific No Significant Hazards Considerations "LS" /9 'q,) LS 1................................................ 15 LS 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Nd. ./kc]. . M- 0 3. (,. C -4 LS 3................................................ 19 LS 4................................................ 21 LS-5................................................ 23 LS 6................................................ 25 LS 7................................................ 27 LS-8................................................ 30 l d 5.f.3-21 1 5 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . N#. N. . 93- ' LS - 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . im u s eo - W Q 3 C 5 ~LI LS 11............................................... 35 LS 12. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS 13............................................... 37 LS 14. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS - 15. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i c abl e LS 16. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not _ Appl i cabl e LS 17............................................... 39 LS 18. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS-19............................................... 42 LS 2.0..........................................Not Used LS 21..........................................Not Used LS 22. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS-23............................................... 44 f LS 24....................................... ..Not Used (]J - u -v. a n.s- s LS25......\..........n............................46 a-v , : m,up t 5 -1.1 l a u. 3-13 i NOSIGNIFICANTHAZARDSCONSIDERATIONS 1 5/15/97
l l IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS '34#
)
(~' ()} NSHC LS-9 10 CFR 50.92 EVALUATION FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE I REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS l The required ac 'on for a containment ventilation isolation valve not wi in its I leakage limit is vised to allow the penetration to be isolated using closed and deactivated automat' valve, a closed manual valve or a blired flange d does not l notexplicitlyavaila(b) require the isolatior valve to be Th restored is to an operable option status. in the current TS. The Completion Time 24 hours remains the same as in the curr t TS. If valves with resilient seals a e used to isolate the flow path, the leak r te of these valves must be verified least every 92 days. If a leak tested lind flange is used to isolate t penetration flow path, the valves with resili t seals whose flow is isolat by the blind flange are not required to be leak rate sted. Isolation of the fl path with a leak tested blind flange provides the requi d leak barrier and add ional leak testing of the valves in the flow path is redun nt and unnecessary. This proposed TS change has been ev luated and it s been determined that it involves no significant hazards cons 1 eration. is determination has been performed in accordance with the crite a set f rth in 10 CFR 50.92(c) as quoted ( below: \W]l "The Comission may make a final d rmination. pursuant to the procedures in 50.91. that a proposed amendnent oa operating license for a facility licensed under 50.21 (b) or 50. or f a testing facility involves no significant hazards considera on. if op ration of the facility in accordance with the proposed amendment ould not:
- 1. Involve a signific t increase in the obability or consequences of an accident previou y evaluated: or ,
i
- 2. Create the po sibility of a new or differe kind of accident frorn any }
accident pr iously evaluated; or l l
- 3. Involve s i.
~ reduction in a margin of a fety. "
The following eval ation is provided for the three categories of he significant hazards consider ion standards:
- 1. oes the change involve a significant increase in the pr ability or consequences of an accident previously evaluated?
e proposed change does not result in any hardware changes. The ro of ; rw these valves during an accident is to isolate containment, and thereby limit ' accident consequences. The proposed actions will not allow continuous lV) operation such that containment leakage after an accident will exceed assumed NO SIGNIFICANT HAZARDS CONSIDERATIONS 33 5/15/97
LC 3-h IV. SPECIFIC N0 SIGNIFICANT HAZARDS CONSIDERATIONS ( NSHC LS-9 1 e,n (continued) lues. With the associated penetrations isolated per the proposed A ion r uirements, no accident as a result of the leaking valve is credi e. Fur er, with the line isolated it cannot contribute to the conse ences of a I previ sly evaluated accident. Therefore, this change will not nvolve a signifi nt increase in the probability or consequences of an ccident previousl evaluated.
- 2. Does t change create the possibility of a new different kind of accident from any accident previously evaluat .
The proposed chang does not necessitate a physic alteration of the plant (no new or different type of equipment will be stalled) or changes in parameters governing rmal plant operation. hus, this change does not createthepossibilityo%anewordifferen ind of accident from any accident previously evalu ed.
- 3. Does this change invol a sign icant reduction in a margin of safety?
The proposed change is acceptable nce the isolated penetration provides protection equivalent to restori he valve to operable status. Providing p) t v the option to isolate the pene atio will minimize the potential for plant transients that could occur ring a s tdown required by TS if the isolation valve could not be restored o operable atus. In addition, the isolation of the line (in accordance w h the proposed uired Action) ensures that leakage through the ass iated penetration i within limits. As such, any reduction in a margin f safety will be insign icant and offset by the , benefit gained throu avoiding an unnecessary p nt transient. 1 NO SI FICANT HAZARDS CONSIDERATION D INATION Based on the above e luation, it is concluded that the activi ies associated with NSHC "LS 9" resulti g from the conversion to the improved TS fo t satisfy the no significant hazar s consideration standards of 10 CFR 50.92(c): an accordingly, a no significant zards consideration finding is justified. C NO SIGNIFICANT HAZARDS CONSIDERATIONS 34 5/15/97
3 '
.6. 3 - Z 1) 3 gn Q- g4 IV. SPECIFIC NO SIGNIFICAfiT HA - S CONSIDERATI0 0 #
Al -ID/i Ak / h O NSHC LS 25 2 a i 10 CFR 50.92 EVALUATION w/ f. - FOR L 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 de- I activated power-operated containment isolation valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured. ' 1 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. This change is consistent with NUREG 1431.t A provision "if not performed within the previous 92 days" is added to the footnote i to CTS Surveillance Requirement 4.6.1.7.1. The footnote allows the containment shutdown purge supply and exhaust valves and flanges, located inside containment, to (v be 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 i the inaccessibility of the isolation devices and other administrative controls that will e'sure n 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 consiceration. This determination has been perfonned in accordance with the criteria set fcrth in 10 CFR 50.92(c) as quoted below: I "The Cormiission may make a final determination pursuant to cne procedures in 50.91. that a proposed amencment to an operating 1icense for a faci 1ity 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 amenoment would not:
- 1. Involve a significant increase in the probab111ty 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 O 3. Involve a significant reduction in a margin of safety. "
NO SIGNIFICANT HAZARDS CONSIDERATIONS 46 5/15/97
- . L L 3-2.C
~IV. SPECIFIC NO~SIGNIFICANT HAZARDS CONSIDERATIONS '
NSHC LS-25 O (continued) The following evaluation is provided for the three categories of the significant i hazards consideration standards:
- 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 the 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 leaking valve is credible. ! Further. with the line isolated it cannot contribute to the consequences of a l previously evaluated accident. Therefore, this change will not involve a
- significant increase in the probability or consequences of an accident previously evaluated.
. Does the cn s e create the possibility of a new or different kind of i accident from any accident previousi y evaluated?
The proposed changes do not necessitate a physical alteration of the plant (no ; new or different 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 this change involve a significant reduction in a margin of safety?
The proposed changes are acceptable since isolating the penetration with a J 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 following each COLD SHUTDOWN "if not performed in the 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 line (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 unnecessar plant trans1ent. Y 71 bbdwf / m is ,-4,. n A 49 .g flQAG)-2[
'W ' 'fby fuNr nd of &&& - y3/, / W h
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e i p/ N ,OzM Y h'f :9/A5 k&. NO SIGNIFICANT HAZARD 5 COESIDYrvu10C 47 u 5/15/97
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Containment Isolation Valves (Atr,esphcri . Osatr,caphcric. Ic; Ccad nscr. and Dual' ps j 3.6.3 ' l
, SURVEILLANCE REQUIREMENTS (continued) 1 s SURVEILLANCE FREQUENCY 1
SR 3.6.3.5 Verify the isolation time of cech p w;- !!!!Bt!Nt!1Mi 3.6 7 ! epcr;ted and each automatic _ M s containmant isolaten va y n.:.. . ;. . ._; , .q,,_. gig lg - F 42-is ,. erg 3.c -if)
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Containment Isolation Valves (n~;paric. Subst ~;pheric. !;; C; dc..;;r. r.d Ou;l) PS 3.6.3 i l i { SURVEILLANCE REQUIREMENTS (continued)
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3.4 43-l l l l 1 Perfom leakage rate testing for contai t 184 days -3.6 19- 1 g___ valves with resilient seals. __ .. . B PS l
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s J Within 92 days _ ~ -- {Qp..:-Q d4 after opening { the valve l SR 3.6.3.8 Verify each automatic containment isolation 3 months .8 valve that is not locked, sealed or otherwise i secured in position actuates to the isolation l position on an actual or simulated actuation i y signal .
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.MWK UP OF WOG STS REV 1 (NUREG 1431) 3.6-17 5/15/97
.. . - . _ - . . - _ ~ . . - . _ . - . - - - . _ _ -
Containment Isolation Valves (At ;spberic, Mat .c;pteric. Ice Ccadcascr and OtteH-B 3.6.3 m (* BASES N.. s SURVEILLANCE SR 3.6.3.5 REQUIREMElGS (continued) Verifying that the isolation time of each Ac cpcrated and _ = tit wrC '=' c^ntai==nt _isc]:tica & _..:t ' Tet
'~'""jt-U_' $^2TiTfT"' M within limits is' ~rehir~ ed 'Q U .P 11]
M trate OPERABILITY. AfGBRDogggggioptR"Yoperatid - MN8SEF8N_Jnt1Bn3a]1e estetrels Instgo2 9BedlREDillfiRW$tuiNeanGBT NWM~ gggeyntong . The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. EThe isolation time and Frequency of this SR are in accordance with the Inservice Testing Program er 02 days.] SR 3.6.3.6 0 3. f. 5 - 2.1
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,mAC oMLiss3 helle 3*e03helblL liis#2s2 emoted ~ ATheJ2:#ay ea d#- Etegencyy Ectiosen;tecogni dnaticMijfstt ; 7 a)ye39uld _F intjodd ledditiona]IsealE _adation3beyond? _t"loccurtingtt . _ ! va1 Vel.listihasinotibeen" i)~"11 mis 72 _ asi_ngEthelint' _al (f_ AZdaysEfsfar ,..ent;measute~ .tZalyilye:has7 n i (W If2ths' blind Mangelisiinstalled368kagefrate3testi riglofjthe J \
#gg . --t blindigangeladst1belpegormedreibM12EmonthsfiandifolloGring! each reinstallation 2cfEthe; blind?flangeUf0peratinfexperience;has demo.nstratedithat'this;testingTfrequency21s[adequatelto assure thisj penetrati on 71 sil eak^:.ti.ght?
-~
U . (continued) MARK UP OF NUREG 1431 BASES B 3.6-28 5/15/97
1 i Q 3.6.3-21
/
A INSERT SR 3.6.3.6 (Bases) { ' t ' l Leakage integrity tests with a maximum allowable leakage rate for containment shutdown purge supply and exhaust isolation valves will provide early indication of resilient material seal degradation and will allow opportunity for repair before gross leakage failures could develop. l l
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- a l
l
_ -_m . _ . . - _ _ _ _ . _ _ _ _ . _ _ . . . . _ _ _ . _ _ . - . _ _ _ _ _ _._ _.__ -__. . _ . _ Containment Isolation Valves 'At;;.sphc-ic. Subetssphcric. Ice Cendca;cr and Ouel) B 3.6.3 l l BASES MG 1.4. 3 -U i w e s a. 3.c..>.1 j SURVEILLANCE SR 3.6.3.7 (continued) / [O 3. t. .f - G ] I REQUIREMENTS e _a 2-ymnygge.3,. _.:my
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, nne yr sa 3.c.. s.r b b (Tst s.c.5- 2-t )
i l !. SR 3.6.3.8 Automatic containment isolation valves close on a containment ! isolation signal to prevent leakage of radioactive material from 3 containment following a DBA. This SR ensures that each automatic l containstent isolation valve will actuate to its isolation p position on a containment isolation signal. Mjtht_iDri i t sigitaTjgt'QMMIM
\ RiaM ;
and-rNMwM This surveillance is not _ I ! required for valves that are locked, sealed, or otherwise secured in the required positior, under administrative controls. The
!! month Frequency is based on the need to perform this l Surveillance under the conditions that apply during a plant i outage and the potential for an unplanned transient if the l Surveillance were performed with the 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. l S" 2 1.2." (Not[us.ed) l In asatresphcric centsinants, the check valscs that scrvc c centeir. rent i';;letion functica er; weight er opring icedcd to , provid; paitive cle;ur; in th; dirccti;n ;f fl;W. This creara l that thac cred velva will ic;;ein clacd uten the inside l centein. Tent stTespherc rcturns t; subat;r.caphcric conditions
- kil; wing e DCA. 5" 3.0.2.0 verific the operatica of the chcd
, (continued) MARK UP 0F NUREG 1431 BASES B 3.6-30 5/15/97
. l 1 ; i i O 3.6.3 21 i INSERT 3.6.3.7a i ( The SR is modified by a Note indicating that the SR is only required to be performed for the
- . containment shutdown purge valves when the associated blind flange is removed, f
t
' INSERT 3.6.3.7b l
h The combined leakage rate for the containment shutdown purge supply and exhaust isolation ! j valves, when pressurized to Pa, and incluc'ed with all Type B and C penetration is less than , {. .60 La. . i t i L e' L 1
\
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CHANGE NUMBER -JUSTIFICATION O a 3.c.s-d D caatai==nt icalatica vehet that rc locked. sealed, vi uUmi dsE p" rad 4" thi" r^';uir^d pccitic uade" 294"ictr; tin cum.coi . eisaddpPtNR3.6.3. at would aT10w that eakage) G 313-11) 3.6 13 jTarifying
/atetesti for cont nt purge es with r ilient sea isnof requir hen the tration f1 ath is is ated by a k tes d s
bli lange. T blind flange rovides t required i lationan yd g,(,y u v % . w % u. = g ional te3% ng of the va es is unnecessar 3.6 14 Not applicable to CalPaway. See Conversion Comparison Table (Enclosure 68). 3.6 15 SR 3.6.6.7 would be modified to reflect plant specific requirements for cooling water automatic functions as well as containment cooler functions. , 3.6 16 Consistent with the current Callaway TS this specification has been modified to reflect the Callaway Recirculation Fluid pH Control System. 3.6-17 Not applicable to Callaway. 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 blind _ - V flanges", once per 24 months when the blind flange is installed [a-.JL {W
,following each reinstallation of _the blind flange.$eac ays en ] G 3.r..)
the ndpengeifremov .a witptfi 9fMaypaft o in ve) n thp411nd Fange r . ed.Qnis SR recognizes Inat cycTfng the Talve could introduce additional seal degradation beyond that occurrin) to a valve that has not been opened, and allows the use of a leak rate I tested blind flange to_isolata tha nanatration flow path./T c n
] is gonsisgwjtfSRJ4r3.7 foptfiiicognmentyttf6pur v ve W-21 3.6 19 [ Con - ent with CTS)4. 1.7. R 3.6 .7 is vised t eak rat test mini- rge v fes in a ordanc with t Contai nt Lea e Rate -
y d IA- O ,, ? } , esti Progra after o ning fo _testi once h 184 s and w iq
,92 ys af ooenin he valv (TheleaKratetestacceptance Triterion 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 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 6B). p Q 4 w m C L_ ? t 1 L-L 175 50 U u ( 3 ggrA@ d a nu x s xn n a
&wM-TS 3 5/15/97 JUSTIFICATION FOR DIFFERENCES
Q 3.6.3-21 , l INSERT 3.6-19 b ITS SR 3.6.3.7 is modified to specify the containment mini-purge valves and shutdown purge valves consistent with CTS 4.6.1.7.2 and 4.6.1.7.4. A note is added to indicate that ITS SR 3.6.3.7 is only required to be performed for the containment shutdown purge valves when the I associated blind flange is removed since iTS SR 3.6.3.6 requires leakage rate testing when the { associated blind flanges are installed. Leakage testing of the shutdown purge valves and j associate blind flanges on a 24 month frequency is consistent with CTS 4.6.1.7.2. l l 1 I I r~'N i A. t (
6
..I- e O fi'}
V - Page 2 of 3 CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431 'SEC110N 3.6 i i 1 APPLIf. ABILITY TECH SPEC CHANGE COMANCHE PEAK WOLF CREEK CALLAWAY DIABLO CANYON NUMBER DESCRIPTION Yes No - CTS has I hour No - CTS has I hour This change would revise the completion time for the Yes ' I 3.6-8 completion time. conpletion time. restoration of containment pressure from I hour to _ [8] hours. The [8] hour completion time is consistent with the current TS.
- Yes No No No 3.6 9 These portions of the specification do not apply since a -
containment cooling system is not part of the CPSES plant ' design. Yes No - CTS in gallons No - Callaway does , This change would replace the Chemical Additive Tank volume Yes 3.6 10 not have this < limits in gallons with tank level limits in percent. system. Yes Yes Yes This change would provide that the Required Action to Yes 3.6-11 ; 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. would ovide that )k(MA g Vef , gg4 . 3.6-12 bsist t with 5 3.6.3.8. this cha
/YA /VA [
is no required or aut tic ' f r
^olation ime test to ainment isolation alves t t are 1 ed, sea , or cQ 3 r. 3h -
othe ise sec' ed in t . r requi positt under , (admini rative ntrol. gh ..J t A clarifying note is added to SR 3.6.3.7 that would allow Yes Yes Jes 4" yg 3.6-13 ' that leakage rate testing for containment purge valves with resilient seals is not required when the penetration flow [ g 3,c. 37 z/]
- path is isolated by a leak tested blind flange.
No No No This change would incorporate DCPP specific operability Yes 3.6-14 , criteria for containment fan cooler units required to meet design functional requirements. Yes ; No No No 3.6-15 SR 3.6.6.7 would be modified to reflect Callaway plant specific requirements for cooling water automatic functions , as well as containment cooler functions. 5/15/97 - rnwrostnN rnMPARTSON TARIF - NUREG-1431 r
- - - . - . . - - - - . ~ . - - - - . - - . _ . - . . . - . - - - . -
O N Nt.
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N CONVERSION COMPARISON TABLE FOR DIFFERENCES FROM NUREG-1431. SECTION 3.6 Page 3 of 3 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY i 3.6-16 Consistent with the current TS this specification has been No No No Yes modified to reflect the Callaway Recirculation fluid pil Control System. 3.6-17 The ACTIONS and SR's of ITS 3.6.3 are redified to reflect Yes No No No the DCPP current TS allowance to open one time any 2 of the 3 DBA qualtfled 48 inch purge supply and/or exhaust valves and 12 inch vacuum / pressure relief valve. ; 3.6 18 Consistent with CIS 4.6.1.7.2, a new SR is being added to No - CTS does not No - CTS does not Yes Yes perform leakage rate testing for the 36 inch containment contain 24 month have the 24 month purge valves and associated blank flanges once per requirement. frequency. 24 months and following each reinstallation of the blank flange. 3.6 19 s' tentyRh CT .6.1.7.4. 50-3.6.3. s being vi d No - DCPP does not No - not in CTS Yes Yes t coverAhe lea rate testi of the ini purge alves have mini-purge ithj[silient seals after pening r testin nce each j system. [g3,g, Q8 vdays an within 92 ys afterA pening i valve. j 3.6-20 Not used. N/A N/A N/A N/A 3.6 21 Consistent with Wolf Creek CIS 4.6.2.3.b. SR 3.6.6.3 is No No Yes No l 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 l' the 31 days frequency required in ITS SR 3.6.6.3. 1 3.6 22 This change deletes the note to ITS 3.6.3. Conditions A No - ITS wording No - ITS wording Yes Yes and B. retained retained , 3.6 23 This change deletes the ITS 3.6.3. Condition C. to ITS wording No - ITS wording Yes Yes i etained retained 3h 2 Y On gis, lens arp zLll4 475 4'4- 2.3.L, o go go ygg - g
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3~2 3.L.L.9 is r-or; red /e. re p h: o Mrnroa*M y Coolay A.t/ ass- fly n{e Q g 6fylgg'o'st rTS 5 A. 3.G 3 7 ' - !f^ C & *tS* & m & W m =*= ^- w NA N
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i ADDITIONAL INFORMATION COVER SHEET (
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ADDITIONAL INFORMATION NO: O 3.6.3-24 APPLICABILITY: WC, CA
\d) REQUEST: DOC 7-11 LS-25 l CTS 4.6.1.7.1 l
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 l 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 3.6.3-23 above. The staff considers , this change to be a beyond scope of review item for this conversion. See Comment l Number 3.6.3-25. l l Comment: Delete this change. l l FLOG RESPONSE: (original) Wolf Creek and Callaway continue to pursue this change. l However, changes have been incorporated to clarify that the proposed l 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 7'] 1. The original sarveillance 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 j requirement based on the use of a combination of closed valves and i blank flanges.
- 2. The improved STS do not address the use of blank flanges on containment snutdown 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. l l Improved STS also require the large purge isolation valves to be sealed l l closed, since they are not qualified to be open during MODES 1 through l 4.
l l 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. l
Based on the above discussion, DOC 7-11 LS-25 and JFD 3.6-18, the proposed changes to CTS 4.6.1,7,1 and 4.6.1.7.2 that would allow the l purge and exhaust penetrations to be isolated by either a blank flange l q consistent with current TS or OPERABLE purge isolation valves 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. ATTACHED PAGES: See the attached pages in response to Comment Number 3.6.3-21. ! l ! 1 l l 1 l l b lA l ! l l l t p-l 1 V l i l
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.6.3-28 APPLICABILITY: DC, CP, WC, CA REQUEST: DOC 1-01 LG CTS 3.6.1.1 ACTIONS CTS 4.6.1.1.a ITS 3.6.3 ACTIONS 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 RESPON!/ (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 INTEGRITY 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") would provide 4 hours to restore the valve or secure the flow path. This was not changed under ITS 3.6.3 ACTION A. One "pene' ration" not meeting the conditions of CTS SR 4.6.1.1.a (two valves unsecured /out of pssition in the same flow path) would provide one hour to secure one valve closed in orr er to restore containment OPERABILITY. This was also retained under ITS 3.6.3 ACI'lONS 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." FLOG RESPONSE: (supplement) A The original response provided for this comment continues to reflect the position of the b 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.
l ATTACHED PAGES: { s Att. No.12 CTS 3/4.6 -ITS 3.6 i Encl. 2 3/4.6-1, insert D 3 Encl. 3A : 1, insert 1-02-LS Encl. 3B 1 l Encl. 4 1,34a,34b i i 1 1
- 1. .
i.i 1 r 4 ,1. l 1.-. I I l t j
- 4. i
!- l i I 1 l i' e i-i i .> i .:. ' j -(. t-i q , t i. I h jd i e. L , +~ -,w,-, , . ,- ..--..,,., , ...,-..n.-, - , , , , - -- , . , . , - ,- -- ,-w,- r.,- . , ,..,n.. ,.- , , n, ---..n, n,-,,., wa,-,--,---
3/4.6 CONTAINMENT SYSTEMS I A 0? ( . .a j Q 3. 6.0 -) \U ~ \ 3 /4. 6.1 ""'"'"" CONTAINMENT
. A .
/-of.h6 l i
V CONTAINMENT INTEGRITY p33, f_ f LIMITING CONDITION FOR OPERATION 3.6.1.1 fr.r .Y=9x:.wr?""";"I I"T:C",ITY shall be maintainedx ONA'44tE, 1 wy m. /_ o/-f g l APPLICABILITY: MODES 1, 2, 3, and 4. l lCTlDN: ktc ~ + 4 OM'MLE
/"yA W co.,ww 'so&fc th t ;t. cry C^"T?!""EF IFTEC".:TY, restore,L'""'I"".:n 1"TEGRITY within /-o/ 46
- I hour or be in at least HOT STANDBY within the next 6 hours and in COLD 4
SHUTDOWN within the followin ours. } :ra b c - o 3.c. 3-z. l '1 ! SURVElltANCE REOUTREMENTS j 4.6.1.1 & Mdb" NT IMTECR!'Y shall be demonstratedt SNAMstEr /-ol-
- a. At least once per 31 days by verifying that all penetrations #not /-o4-45 4 capable of being closed by OPERABLE containment automatic isolation - o2-A valves and required to be closed during accident conditions are ( ts closed by manual valves, blind flanges, +e deactivated automatic U._)
valves secured in their closed positions, except for valves that are open under administrative control as pe tted by Specification (' 3.6.3;f_, , , , rurgg7, /,-oyg o
- b. By verifying that each containment air lock is in compliance with .
the requirements of Specification 3.6.1.3; #'##-A ! 1
- c. Deleted.
- d. By performing containment leakage rate testing in accordance with the Containment Leakage Rate Testing Program of Specification 2' 6.8.4.g; and
- e. By verifying containment structural integrity in accordance with the Containment Tendon Surveillance Program of Specification 6.8.5.c.
*Except valves, blind flanges, and deactivated automatic valves which are located inside the containment,aM m h & d, re p e - nth e e secured /-04-45 in th ;1c2ed posities These penetrations #shall be verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.
NJ fpgy'r zs, l~ Oh"I 5 CALLAWAY - UNIT 1 3/4 6-1 Amendment No. 13,52,10!,111,113
Q .1.6.3-28 l INSERT D for Page 3/4 6-1 (1-02-LS) , (y With one or mare penetration flow paths (applicable to flow paths with two containment isolation ! valves) with one containment isolation valve inoperable (except for containment nrtSt:sr, isolation valves with resilient seals that are inoperable due to leakage not within limits), isolate y ; l 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 i secured; or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN I within the following 30 hours. I l t b i i t i i i 9 0
DESCRIPTION OF CHANGES TO CURRENT TS SECTION 3/4.6 This enclosure contains a brief description / justification for each marked up change . to the current Technical Specifications. The changes are identified by change numbers contained in enclosure 2 (Mark-up of the current Technical Specifications). e-G In addition, the referenced No Significant Hazards Considerations (NSHCs) are contained in enclosure 4. Only technical changes are discussed: administrative ; changes (i.e., format. presentation and editorial changes) made to conform to the ! improved Standard Technical Specifications (STS) are not discussed. For enclosures i 3A. 3B. 4, 6A and 6B. text in brackets "[ ]" indicates the information is plant specific and is not common to all the Joint Licensing Subcomittee (JLS) plants. Empty brackets indicate that other JLS plants may have plant specific information in that location. CHANGE-RUMBER [{SE DESCRIPTION 1 01 gA {0NTAINM:!C ItCEC'1In is ne lca;cr defined terr. in NUREC 1431. Thc requircacats for centcia==t operatn-14t-y, including the requircacats g evivualy ivund in i.h6 C0tCAINMENT INTCORIU dcfinition, crc discussed n-the p.3,c,g_ ; exp:nded bcscs of the contairment LCO. This lang: s ; consistent "ith NUREC l'31. /^/f(47- #6%F ! 1 i 1 02 -fr- Consistent with NUREG 1431, surveillance requirement to : p # verify the affected penetration flow path is isolated is O *~ , t% r[M3./,,,3>- now addressed by ITS 3.6.3 Containment Isolation Valves, d I Conditions A. C [c-ar+&] and Surveillance Requirements ; SR 3.6.3.3 a SR 3.6.3.4 .Z A)f 6 67- /-c2-0 i Ds A 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 deactivated 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. Th s change is less restrictive in that the current.TS SR 4.6.1.1 has an exception to valves, 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 eacn COLD SHUTDOWN. However, under current TS if an area outside of containment became a high radiatien area, entry into the t area would still be required to verify the closed A positions. The ITS would allow verification of all areas that are high radiation areas or become high radiation ! DESCRIPTION OF CHANGES TO CURRENT TS 1 5/15/97 l 1 I 1
Q 3.6.3-28 g3 INSERT 1-02-LS ! /
\d The CTS action associated with this specification says that without CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRlTY 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 hourif 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 8.1 (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.
9 /m- i
m o , ,.m i [Vb \.)) CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6
'(N.s}
Page'1 of 11 TECil SPEC OIANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCliE PEAK WOLF CREEK CALLAWAY 01-01 &ONfAINHENT-1NTEG4HV--is-m longer-a-defined term-4m Yes Yes Yes Yes Mrg NUREG-1431,- the_ requirement 5-for-containment-operabilityi gg,f ./ including _the_tequiremnts -previously_found-in_the- r CONTAINHENT-INTEsttYY-definttion are-dhcussed-in-the-ez p_auded_b a ses_o f. .t he-s ont ai nmen t-LET) . Jyf6Er~ //6E 6' 01-02 This requirement to verify the penetration flow path is Yes Yes Yes Yes _ isolated is addressed by ITS 3.6.3 Containment Isolation y,g,3 3) ( {$' Valves. 01-03 An 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 1silation Yes Yes Yes Yes LS 1 devices located in high radiation areas to be vet ified by use of administrative means. 01-05 This requirement is addressed by ITS 3.6.2 Containment Air Yes Yes Yes Yes A Locks Required Actions. 01-06 Only containment isolation valves that are not locked. Yes Yes Yes Ye! LS-19 sealed, or otherwise secured are required to be verified closed. 02 01 The Containment Leakage LCO is now addressed by ITS 3.6.1 Yes Yes Yes Yes A Containment LCO. 02 02 The wording " prior to increasing the Reactor Coolant System -Yes- Ma, Se 8 Yes No - (3.6.1.2 not No - (3.6.1.2 not temperature above 200*F" is replaced by the equivalent in CTS) in CTS) A requirement of ~ prior to the first unit startup following 4 testing performed in accordance with the Containment #2 #b I meakage Rate Testing Program." 02 03 CPSES testing requirements for containment air locks are No Yes No No A now provided in ITS 3.6.2 for Containment Air Locks. 02 04 LCO and surveillance requirements for containment No - CTS does not Yes No - (3.6.1.2 not No - (3.6.1.2 not A ventilation / purge valves are now included in 115 3.6.3 for contain this in CTS) in CTS) Containment isolation Valves. requirement,
& /-6? l0 ]~n/W/EF S f' - / & 3. 6 &I)
C0fWERSION COMPARISON TABLE CURRENT TS 5/i5/97
-. . - . . - - - - . . - - - - - - - . - - - . ~ . . - . - . . -
ENCLOSURE 4 l O l 1m NO SIGNIFICANT HAZARDS CONSIDERATIONS (NSHC) CONTENTS I. Organization ........................................ 3 II. Description of NSHC Evaluations. . . . . . . . . . . . . . . .. . . . . . . 4 l l III. Generic No Significant Hazards Considerations :
"A" Admini strative Changes. . . . . . . . . . . . . . . . . . . . . . . . . 6 l I
"R" Relocated Technical Specifications. . . . . . . . . . . . . 8 "LG" Less Restrictive (Moving Information Out of the Technical Speci fi cations) . . . . . . . . . . . . . . . . 11
! "M" - More Restrictive Requirements................. 13 IV. Specific No Significant Hazards Considerations "LS" I i, C g LS.1................................................ 15 , l x LS 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Nef. .#24. . .-W- dP 3. 6. 6 - 4/ L 'LS 3................................................ 19 LS 4................................................ 21 i LS5................................................23-l LS 6................................................ 25 l LS 7................................................ 27 LS 8................................................ 30 l [ a 3.4 3-2t , LS-9................................. N #.On M.. . .iE- -
, i LS 10..........................................im usea - W Q W48 l
- LS 11............................................... 35 LS - 12. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e l LS 13 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 7 l 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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS 19............................................... 42 L LS 20..........................................Not Used LS-21..........................................Not Used l LS 22. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Not Appl i cabl e LS-23............................................... 44
~,
,O ~LS 24................................. ........Not Used
\ / LS25......{...........,............................46 ;
s46 a n.s- 9 1
- l. v u-U t, 3 -t f l a 3. L. 3-13 j,
= WN.T AM l
NO SIGNIFICANT HAZARDS C0'NSIDERATIONS 1 5/15/97 I i l ! l 1
Q 3.6.3-28 l / A)/ IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-10 l 10 CFR 50.92 EVALUATION l FOR TECHNICAL CHANGES THAT IMPOSE LESS RESTRICTIVE REQUIREMENTS WITHIN THE TECHNICAL SPECIFICATIONS l l 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 O 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 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 failure 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 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 f '~
previously evaluated; or
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or 1
3 'fa
1 l IV. SPECIFIC NO SIGNIFICANT HAZARDS CONSIDERATIONS NSHC LS-10 (O) v (continued)
- 3. Involve a sigrificant 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 i1volve 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 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 from any accident previously evaluated?
The proposed chango does not necessitate a physical alteration of the plant (no new or different [^% type of equipment will be installed) or changes in parameters governing normal plant operation, (
%) and does not impose any new safety analyses limits. Thus, this change does not create the possibility of a new or different kind of accident 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 Action 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 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 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. 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. m
/ \ \v/
346 l
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. 1 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 Bases already contained similar wording. The description of DOC 11-18-A is changed to read: ! l "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 j Surveillance under the conditions that apply during a plant outage and the potential for an 1 l 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:
"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 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 complets some repair or modification made while operating, a shutdown should not be required."
ATTACHED PAGES: Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 2 6-17 O Encl. 3A 13 i Encl. 3B 10 ; i
e
/-07-A -
CONTAINHENT SYSTEMS y f G 3 Oil L ,4,o -f i SURVEILLANCE RE0VIREMENTS (Continued) \ F] adnugt Zirert A 9'-R- A \ \ 4.6.3.2 d" 4-- EachAcontainment isolation valveWha11 be demonstrated OPERABLE th: 00;.D SHUT"A 'N 07 "EFUELI"C "00E at least once per 18 months by -ii-ihe V( l/ e6-#.-to-+Hr@
- s. .
"h :: " I::1:ti:n tert- signal, each
//-o7- L '6 6,4- Verifying
^h::: that on4:r
+ va:lve actuates to its isolation position, n-or-7A'
*** icel &n scheaA or & schss7th 1/-10 -A t.: varir.,ii.g th:t en : "'::: "e" I:e!:tien t::t :1;n:1, :.:tr M,::: "0" i::1: tier Y 1=e act" ster te it: i:eletien ,,e:i t i:n , :.r.djf f,T.[ f
- c. Y;rifyir.; th:t On : C::t:in- nt " ;: I::letien twat signei,
- ch purge :::;1; nd e d a"st icelatter yelv: ::te:t:: t: i t:- //-#7-L
- s i:el: tier p::itier.
4.6.3.3 The isolation time of each ;ee epe sted e automatic :ontainmen isolation valve shall be determined to be within its limit when tested
//-*f-A /
/.' !'! O pursuant to Sp ification 4.0.5.
-r* ,. 2,
^
r,- jaexo- oferded
'n .1&A Q *b . c. 3 - l \ Q 3. 6. 3 - 8
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. . . . . . . ..7m.. ,___.a..>._;
,,_ , , - m
- m. . . . .,,m.. .. .. un..ui i s e y w n s.,.-_._.,,u__s__..;,__,.._,-
, y.. me fu-"a4'!:n:: i: ;;rfer cd prier te estart f: liv.iny ine firn icTuciini eutege er h:: 1, l00, hi:he.:r ::: err #4 rtt. 'h: pr:vi: ion: :P //-/ #'A Specifi:stier ' 0.2 er: retet h= nerfomance of this surveillance.
CALLAWAY - UNIT 1 3/4 6-17 Amendment No. 8,113 (Next page is 3/4 6-32)
i l CHANGE ) Whi38 EliC DESCRIPTION - l p 11 17 - Not used.
\C') 11 18 -M./f-/ & -Relecete "during the COLD SliUTD0"N 0 - REFUELING HCDE" fi ow n :J N'#- .
)
-19 mnth curvcillance requirc crt; to the CASES. 2?vEAY' 3A-GlQp.3-l5)l 12 01 A Not applicable to Callaway. See Conversion Comparison Table (Enclosure 3B).
12 02 M Not applicable to Callaway. See Conversion Comparison i Table (Enclosure 3B). 12 03 LS 15 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 3B). , 1 12 04 M Not applicable to Callaway. See Conversion Comparison l Table (Enclosure 38). l 12 05 LS 16 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 3B). 12 06 LG Not applicable to Callaway. See Conversion Comparison Table (Enclosure 38). j 12 07 Not applicable to Callaway. See Conversion Comparison I n' M Table (Enclosure 3B). ( V) 13 01 LS 17 A new Cond1 tion has been added to this specification. This i condition describes the Required Action for two hydrogen I recombiners inoperable. Whereas in the current I specification LCO 3.0.3 applied, this change allows up to 7 days to restore one hydrogen recombiner to OPERABLE status, based on the availability of the containment Hydrogen Purge System to provide the required safety function. In order to use this action time, the Required Actions require that the hydrogen control function be verified available within 1 hour and once every 12 hours thereafter. This administrative verification will assure that the hydrogen purge system is capable of performing the safety function if an event occurs. Also, the bases for operation of the recombiners indicates that if a design basis event occurs, approximately 8 days would elapse before the containment atmosphere approached the lower explosive limit for hydrogen. It is therefore reasonable to assume that the inoperability of two hydrogen recombiners will not significantly jeopardize the capability of the facility to respond to a design basis event. This change is consistent with NUREG 1431. ([ ,)
\
13-02 LS 18 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 38). DESCRIPTION OF CHANGES TO CURRENT TS 13 5/15/97
N N
't)
CONVERSILN COMPARISON TABLE - CURRENT TS 3/4.6 Page 10 of 11 TECH SPEC CHANGE APPLICABILITY DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY NUMBER DESCRIPTION No No Yes 11-15 A Callaway specific note to 3.6.3 regarding testing is No A deleted based upon ITS LCO 3.0.5. Yes Yes Yes 11-15 Even though it is not specified in ITS 3.6.3 Required 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. N/A N/A N/A N/A 11-17 Not used.
~3 ' 3 b -18 The words "during the COLD SHUTDOWN or REFUELING HDDE" 3 are No-notinCTS\ No not in CTS. Yes Yes s:A n -~ed te the essa- de leg _a aq -c3= ; _;4., . , y -wc :.: xf u n> Yes u 2.c..n an No - CTS Hydrogen No - CTS Hydrogen 12 01 Consistent with NUREG-1431. the hydrogen monuormg
- Honitor Monitor A specification is moved to ITS section 3.3.3 concerning Post requirements are Accident Monitoring Instrumentation (PAH). requirements are not in this not in this section. section.
Yes No - CTS Hydrogen No - CTS Hydrogen The H00E of ,pplicability for the hydrogen monitors is Yes 12-02 Monitor Honitor H extended to MODE 3. requirements are requirements are not in this not in this section. section. Yes No - CTS Hydrogen No - CTS Hydrogen 12-03 The action is revised to require a special report to be Yes Honitor submitted within 14 days in lieu of being in HOT STANDBY Monitor LS-15 requirements are requirements are within 6 hours. if one train of hydrogen monitoring cannot not in this not in this be restored to operable within 30 days. section, section. Yes No - CTS Hydrogen No - CTS Hydrogen Adds the requirement to be in HOT SIUTDOWN within 12 hours Yes 12-04 Monitor Monitor H if both trains of hydrogen monitoring are inoperable and requirements are requirements are one train was not restored within 72 hours. not in this section not in this section. ~......-.,,-.,s.. -. .n . n y n. , n n, r ennnrnr TR 5/15/97
ADDITIONAL INFORMATION COVER SHEET (~g ADDITIONAL INFORMATION NO: Q 3.6.3-34 APPLICABILITY: CA
- i. )
\d REQUEST: JFD 3.6.3-5 STS SR 3.6.3.3, SR 3.6.3.4 and Associated Bases ITS SR 3.6.3.3, SR 3.6.3.4 and Associated Bases STS SR 3.6.3.3 and SR 3.6.3.4 have been modified by TSTF-45 Rev.1. While ITS SR 3.6.3.3 and SR 3.6.3.4 have incorporated the changes associated with TSTF-45 Rev.1, the Bases for ITS SR 3.6.3.3 and SR 3.6.3.4 do not fully incorporate all of the Bases changes associated with TSTF-45 Rev.1.
Comment: Revise the Bases for ITS SR 3.6.3.3 and SR 3.6.3.4 to incorporate the Bases changes associated with TSTF-45 Rev.1 or pmv!de additional discussion and justification for the deviations. FLOG response: (original) ITS Bases SR 3.6.3.3 and Bases SR 3.6.3.4 have been revised to be consistent with TSTF-45, Rev.1. The following statement has been added to both Bases sections:
"This SR does n 't apply to valves that are locked, sealed, or otherwise secured in the closed positions, since these were verified to be in the correct position upon locking, sealing, or securing."
This question is not applicable to Callaway as Bases SR 3.6.3.3 and SR 3.6.3.4 already
/^'N contain this statement.
FLOG RESPONSE: (revised) This question is not applicable to Callaway as Bases SR 3.6.3.3 and SR 3.6.3.4 already contain this statement. CA-3.6-ED was initiated to remove this redundant statement from ! SR 3.6.3.3 as the statement was inadvertently added in two places in SR 3.6.3.3. ATTACHED PAGES: Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 68 page B 3.6-27 is retransmitted I i l i i
/ h ,
m l
Containment Isolation Valves (Atr,csphcric. Substr,c;phcric. Ic; Condcascr and Ducl) { B 3.6.3 I l t f% s l () BASES j SURVEILLANCE SR 3.6.3.3 (continued) REQUIREMENTS l use of administrative means. Allowing verification by administrative means is considered acceptable, since access to l these areas is typically restricted during MODES 1, 2, 3 and 4 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small. EttKSRg6si iapp))
.._;x;nq.g
=_=.5= [J8@@M]@M@7M5L 31,$$NgtMsepmy, mage .pel he g4) 1 P di,jfpoMt)sf.1l dppedl@MgE@pafLnhidnWJe_ckM92 SR 3.6.3.4 This SR requires verification that each containment isolation ;
manual valve and blind flange located inside containment itidMFot TdGMCEinstWi",'0:nget#egsta!TJeMpm 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 p of the containment boundary is within design limits. For t containment isolation valves inside containment, the Frequency of
\ " prior to entering MODE 4 from MODE 5 if not performed within the 3 previous 92 days" is appropriate since these containment i 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 the time they are open. M3RFLWMiio1911FeiQhM t
$NgeSRaeaEQu~ jMMIM5ecteqEtsje3]dsW?positjb!g sinteilgetEP98WecWeirtistTried'toTherthMRurtent]pbsition gpggbickfnjCsFaThig2W"securitig A B6 Note [taCbienled@f,lthet allows valves and blind flanges located in high radiation areas to be verified closed by use of 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 reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.
V (continued) MARK-UP OF NUREG 1431 BASES B 3.6 27 5/15/97
. ADDITIONAL INFORMATION COVER SHEET l f ,q ADDITIONAL INFORMATION NO: Q 3.6.6-13 APPLICABILITY: DC, WC, CA l l ! V REQUEST: CTS 4.6.2.3a.1 ITS SR 3.6.6.2 and Associated Bases 1 CTS 4.6.2.3.a.1 verifies that containment cooling fan units are started and operated for at l least 15 minutes at least once per 31 days. The corresponding ITS surveillance is ITS l 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 l 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 the bracketed ([]) word p " required" can be deleted since the LCO requires all components to be OPERABLE.
\ I V 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 operating at the time the SR is performed, the operating fan units are not required to be verified that they are running for
,eG, 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 V this change to the CTS even though the surveillance testing performed at WCGS and
! Callaway meets the STS SR 3.6.6A.2 requirements. l l l
DOC 8-12-M h:s bern initi: tad for WCGS and Cilliway which statss: " 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 i 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." J For DCPP, the work " required" is removed from SR 3.6.6.2. ATTACHED PAGES: : Att. No.12 . CTS 3/4.6 -ITS 3.6 Encl. 2 6-15 Encl.3A 9, inser13A-9b Encl. 3B 7, insert 3B-7a 1
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H 7 -A .
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Q 3. 6. o -1 ggyISJ g ' , . . " *
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ONTAINMENT SYSTEMS 7 cg- A
.0NT AINMENT COOLING SYSTEM LIMITING CONDITIONS FOR OPERATION 3.6.2.3 Two independent groups of containment cooling f ans shall be OPERABLE j j ,,j,gg M th te f:n :y:tr~ + a d ; ep. !
APPLICABILITY: HODES 1, 2, 3, and 4. wp ACTION: TA$WA 'h3.L.(-y' '
- a. With one group of the above , required containment cooling fans [ /Fl ,
inoperable and both Containment' Spray Systems OPERABLE D- / /-AS be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
- b. With two groups' of the above required containment cooling fans inoperable and both Containment Spray Systems OPERABLE, restore at least one group of cooling fans to OPERABLE status within 72 hours or be in at least HOT STANDBY within the both Restore nextabove 6 hours required and in COLD SHUTDOWN within the following 30 hours.
groups of cooling fans to OPERABLE status within 7 days of initial \ loss or be in at least HOT STANDBY within the next 6 hours and in 3 COLD SHUTDOWN within the following 30 hours. With one group of the above required containment cooling fans p y,4.. ( - t/'
.m)
(%/ c. inoperable and one Containment Spray System inoperable, restore the g , 8- U-)d
~ ~ ' inoperable . Containment Spray System to OPERABLE status within 72 hoursHUTDOWNor be in at within least HOT STANDBY within the next 6 hours and in the following 30 hours. Restore the inoperable COLD grou of containment cooling fans to OPERABLE status within 7 days T
of 1 itial loss or be in at least HOT 5. ANDBY within the next l 6 ho rs and in COLD SHUTDOWN within the following 30 hours.
.TM627' A
- N#~A SURVEILLANCE R'EOUIREMENTS 4.6.2.3 Each group of containment cooling fans shall be demonstrated OPERABLE:
At .least once per 31 days by: y_g-g
- a. "*
7
.; ad .cn-eper? tin; ':n gre"p '"Cr the cen* *c' Q 3.c. 6 -13 1)/L L acA verifying + hat each f an-gaciap operates for at least _
15 minutes, and
- 2) Verifying a cooling water flow rate of greater than or equal to 2200 gpm to each cooler __ group.
N
- b. Atleastonceper/18 months +rverify4lFyhatcr.': Of0ty hjc;ti;. e/Lp5'-Id tmst F ; < . the/fa p :A,r M,,.t- A 5 %,. s; 9 W pc- - - - ~ -.
.n~
. ' ' " ;w , : Hmss
'. W
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/O-0 2d s;.. ~ ~7::;a?.~'! A. ".:, %w -,. .,, n o r. rim ula f pf
% $Chad.l)V llVt Y.
15 CALLAWAY - UNIT 1 L dke. _ o 3. L . (. - 7 N
i CHANGE NUMBER M2iG DESCRIPTION O 3.G.L 'l 8 11 4G-E- A*kom discovery of failure to meet the LC0" provision l /47 has been'added to the completion time for one train of l L (( containment sprq/ cooling systems inoperable. CTS 3/4.6.2.1 (Containment Spray) and 3/4.6.2.3 ; l (Containment Cooling) require restoring the inoperable ! system to Operable status w'ithiq 72 hours. The CTS limits j the inoperability of any combination of these two systems 1 to 72 hours or it provides a maximum of4 days for ! restoring one group of cooling fans to Operable status , when everything else is Operable. This change is l considered less restrictive in that the 10 days aTTowed in ; the,ITS not to meet the LC0 is greater than the CTS woul I
,nTlow. w gggy wcp l (,J-Il /4 r - - S 3 A - 9 6J l G 2. G .C -I d
! y ul A Not applicabie Lo LallaWay. See Conversion Comparison Table (Enclosure 3B). (Q) dA 31 - d 9 02 LG The descriptive information in th LCO 3.6.2.2 regarding l l operability of the [ Recirculation'pH Control] System is l contained within the definition of operability as described in the ITS 3.6.7 Bases. This is consistent with ! l the NUREG 1431 and is acceptable because while the l descriptive detail has been moved to the bases, the bases requirement is retained in the LCO. O. l 9 03 Consistent with NUREG 1431, the action statement is l (' A j revised by deleting the reference to restoring the [RFPC , system] to operability within 48 hours or be in cold ! shutdown within the following 30 hours. The revised i 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 j restoration of the system operability and an additional l 36 hours to achieve cold shutdown.
y Q34.3-il) , 9 04 A -"ct cppH cabk to Celle-ey. See Cun c. wmpam a ; T=hl o (Encinence 'un 9_o q _4 3,4,g i 9 05 TR-1 The specific actuati n signa (a Contei=cr.t Spry / Q '3 A 4 .- 3 l A tu tier test signal for the surveillance was repla ec Q 3.r..g 1_ I with generic words tdt allow credit for an actual or - simulated actuation. Identification of the signal is moved to the BASES. M 9 06 LG Not applicable to Callaway. Se'e Conversion Comparison Table (Enclosure 3B). 4 OA 9 07 Not applicable to Callaway. See Conversion Comparison V) ( H Table (Enclosure 38). DESCRIPTION OF CHANGES TO CURRENT TS 9 5/15/97 l-
_.. .. _ _ _ _ . _ . _ . . _ _ . . . . . _ _ . . - = _ _ . . _ . _ _ _ . _ _ . - _ _ . _ -. _ _ . . . . . _ _ _ _ _ _ _ . _ _ _ . . . . _ _ . l l
- Q 3.6.3-13 INSERT 3A-9b
# 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 t
.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, he CTS surveillance { requirement is performed by starting as y non-operating fan unit ! and verifying it runs for greater than if minutes and verifying the ! operating fan units are running for grenter than 15 minutes.
" ^^
m 7 ' ^- i
=
l I I i i 1 .) 1 s i
- i. - , ~ , , --m_._ - - . . . - - ., , , , _ ,r-,, . - =. _ - - , _ _ . , ,.
d A CONVERSION COMPARISON TABLE - CURRENT TS 3/4.6 Page 7 of 11 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 08-11 A "from discovery of failure to meet the LC0" provision has Yes No - CPSES current Yes Yes
-tS-e- TS does not have a M been added containment to p /cnolingJiystems inoperable.
spray completion time for one, train This change tf containment cooler is considered Less RestrictivDffthagays allowed 3f,6 <[ specification. in the ITS notJo meet tfie LCO is greater than the-CTS p%_
.wguld-e1itiw. fggg 7- "54I- 7 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 [RFPC System] is contained within Yes Yes Yes Yes LG the definition of operability for the [RFPC System] as f ~ described in the Bases. ( L_ O 09-03 This change revises the action statement by replacing the Yes Yes Yes Yes j , reference to restoring the Spray Additive System to I A operable status within 48 hours or be in cold shutdown within the following 30 hours, with the requirement to be /V eh b[
/
~
/
in cold shutdown within 78 hours. n ... f f 09-04 This change adds the phrase 'that is not locked. sealed, or %e This a,Jiti.m fr kedy 'n CE Yes Mc Cu rent ar=c+1cc ;:r CTS h-Cubent
/pc+4ea nar CR f A otherwise secured in position
- with regard to which valves m
require actuation testing. p GaA99 p i ' 5.? ?. 09-05 The specific actuati signal b C:ntti - l 4 af Yes Yes Yes Yes[Glb'7~W TR-1 'Actiatien t::t -iso for the surveillance was replaced O 3.G.(.- 3 with generic words that allow credit for an actual or simulated actuation. LGt 3.f. .C- 7 2 09 06 This change moves specific details in the surveillance No - CTS does not Yes - SurveillFnce Yes - Surveillance No - Callaway does requirement with regard to verifying flow path and the RWST contain this detail details are moved details are moved not have this LG waterflow@atesofbetween50and100gpmthroughthe to the Bases. to the Bases system. M eductor test loopDout of the TS. and adds a general requirement to verify flow capability through each eductor. 09-07 The surveillance for DCPP is modified to require Yes No No No H demonstration of flow through each solution flowpath. 3- t 2-- TM 2 g - 7a M [ Q 3-(. 4M_ CONVERSION COMPARISON TABLE - CURRENT TS 5/15/97
t
~
-Q3 13; l i
INSERT 3B-7a
-)
TECH SPEC CHANGE APPLICABILITY i NUMBER DESCRIPTION' DIABLO COMMANCHE WOLF CREEK CALLAWAY ! CANYON PEAK 08-12 CTS SR 4.6.2.3a.1) is revised to indicate that each No No Yes Yes M containment cooling fan unit is verified operating for at .
; least 15 minutes. }
i i t 2 i
^l, i i i
l 1
'I i
t i
ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: Q 3.6.6-18 APPLICABILITY: CA l i ! l REQUEST: STS B3.6.6A Bases- APPLICABLE SAFETY ANALYSES ITS B3.6.6 Bases - APPLICABLE SAFETY ANALYSES The second paragraph in STS B3.6.6.A Bases - APPLICABLE SAFETY ANALYSES describes briefly the containment pressure and temperature limits used to design the Containment Spray and Cooling Systems. A statement in the paragraph specifies the assumptions used in the analyses and evaluations. Callaway ITS B3.6.6 Bases - APPLICABLE SAFETY ANALYSES deletes this sentence. Since 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 deletion does not seem to fall into any of these categories. The staff believes the statement provides useful descriptive l information on the initial assumptions used in the safety analyses. Comment: Retain the deleted STS sentences modified by plant specific values and 4 assumptions. I FLOG RESPONSE: (original) STS B3.6.6 Bases - APPLICABLE SAFETY ANALYSIS has been revised to retain the STS words as amended "The analysis and evaluations assume a unit specific power level of 102%, one containment spray train and one containment cooling train operating, and initial (pre-accident) containment conditions of 120 F and 0 psig." l FLOG RESPONSE: (revised) Page B 3.6-43 associated with the " master" markups has been corrected and enclosed herein. ATTACHED PAGES: l j Att. No.12 CTS 3/4.6 -ITS 3.6 ! Encl. 58 B 3.6-43 i
~)
l l
Containment Spray and Cooling Systems fAtr.caphcric and Ducl-)- B 3.6.6A O SrtcA>
,- M (G 3 G 04 b
( BASES '" I -N < APPLICABLE The analysis and evaluation sho that under the wo 'st case ! SAFETY ANALYSES scenario, the highest peak cont inment pressure is 48 I psig (continued) (experienced during a bOGA SEB). The analysis shows that the 384TF (experienced during an peakBoth SLB). containment results meettemperature the in is;t'ent of the (See design basis. the Bases for LCO 3.6.4, " Containment Pressura "
= Q CO C 3.6.5_
fo a d tailed Thc -- yxs and saluation assure I ' _ //gfDLC
. . ~
N.~5II').S5i .I.I.3fI$..O woe ..~o, -v . o. wr.. .ov."'" ";/E..i N. g@o mm o s s ow- n. oso w m u's.2 - "... o ..~ au
- m. .q - .,
o v .
- g. . ..~' ,,, - '- The ana yses etse assume a response time aetayea initiation to -
provide conservative peak calculated containment pressure and temperature responses. For certain aspects of transient accident analyses, maximizing the calculated containment pressure is not conservative. In particular, the effectiveness of the Emergency Core Cooling System during the core reflood phase of a LOCA analysis increases with increasing containment backpressure. For these calculations, the containment backpressure is calculated in a n manner designed to conservatively minimize, rather than maximize. ('v) the calculated transient containment pressures in accordance with 10 CFR 50, Appendix K (Ref. 2). i l The effect of an inadvertent containment spray actuation has been l aslyzed. An inadvertent spray actuation results in a 2~/2 E:e psig containment pressure and is associated with the sudden i cooling effect in the interior of the leak tight containment. Additional discussion is provided in the Bases for LCO 3.6.4A. The modeled Containment Spray System actuation from the containment analysis is based on a response time associated with exceeding the containment High-3 pressure setpoint to achieving full flow through the containment spray nozzles. The Containment Spray System total response time of [00] scconds includes diesel generator (DG) startup (for loss of offsite power), tReek- se,quenced loading of equipment, containment spray pump startup, and spray line filling (Ref. 4 B). Containment cooling train performance for post accident conditions is given in Reference 4. The result of the analysis is that each train can provide 100% of the required peak cooling (}' ( (continued) MARK UP OF NUREG-1431 BASES B 3.6 43 5/15/97
1 i l ADDITIONAL INFORMATION COVER SHEET ! f o ADDITIONAL INFORMATION NO: O 3.6.8-6 APPLICABILITY: CA
\
l REQUEST: STS B3.6.8 Bases - ACTION B.1 and 8.2 l ITS B3.6.8 Bases - ACTION B.1 and B.2 i STS B3.6.8 Bases - ACTION R.1 and B.2 states the following: "It does not mean to l perform the Surveillances needed to demonstrate OPERABILITY.. " ITS B3.6.8 Bases - i ACTION B.1 and B.2 modifies this sentence as follows: No surveillances or other testing i are needed to demonstrate OPERABILITY.. " . Since ITS changes to the STS Bases l 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 made to this sentence do not seem to fallinto any of these categories. The staff believes that these changes could be ! generic and beyond the scope of review of this conversion. See Comment Number ; 3.6.-2. ! Comment: Delete this change. 1 FLOG RESPONSE: (original) ;
- \
The proposed changes to the Bases noted in the comment have been deleted. The proposed changes were intended to clarify that only administrative means are required to l verify OPERABILITY of the altemate system. l FLOG RESPONSE: (revised) The proposed changes to the Bases as discussed above have , j been included with this response. l l (' ATTACHED PAGES: l l l Att. No.12 CTS 3/4.6 -ITS 3.6 l Encl. 5B B 3.6-60 l l 1 1 i l O l l
. ._. . - . - - - _ = -
1 I Hydrogen Recombiners (Atmosphcric, Substacaphcric. !cc Condcascr. and Oual) l B 3.6.8 i e n , I ( BASES
& )i ACTIONS L.1 (continued) l Required Action A.1 has been modified by a Note that states the provisions of LCO 3.0.4 are not applicable. As a result, a MODE change is al. lowed when one recombiner is inoperable. This allowance is based on the availability of the other hydrogen i recombiner, the small probability of a LOCA or MSLB occurring (that would generate an amount of hydrogen that exceeds the flammability limit), and the amount of time available after a j LOCA or MSLB (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit.
1 B.1 and B.2 '
."cVic.;cr's !?;tc. This Condition is only elicWcd for units with i en alternetc hydrogen centrol systc; eccccptabic to the technical l stem-With two hydrogen recombiners inoperable, the ability to perform ;
the hydrogen control function via alternate capabilities must be l (^) V verified by administrative means within 1 hour. The alternate 6 J M h ogen control ca 111 ties are provided by N (redlM ydrogen Purge ysteg The 1 hour Completion Time allows a CA-251oS reasonable period _of) time to verifyy that a loss of hydrogen 3 3,c,,o 2
/e"I ), 7 , m ,,Jco,,y' ~ control function does not exist. p avicucr*s !!etc. Thc
/
- Q f;11 ewing is to b; uscd if a non Technical Sp;;ific;tien Of Y , ., " '7 [ / -it;rnet hydre;cn centr:1 function is u;cd to justify this H7 1p [& "/ endition. InDideftf6tighbDiltehdatKtjgh@Fnic@l?fistes ;
0;Jr., JA v; M n capa#Rftyfprst2tgye@edienceIpeyilghoes"tlWreafterZty I
;mnf - erisureIftKcogj!ided7avaiTabflityClBot!) the initiG verification
@d7alfjgubjegqegEyeriffi tjcation( may be performed as an r ^, ^ b strative check by examining logs or other information to L :. g# -
offr/A'c determine the avaiBBTTity 6fhlterna6n contial system. @ decs rdt x;n to p6; thc]g(Jif lr veillancesK g3.4.M TAMereU12ded to denichstrate OPERABILITY of the d alt;Irgt; hydrogenJurge certicH- system. _ILthe abilit1to perform the hydrogen control function is maintained continued operation is permitted with two hydrogen recombiners inoperable for up to 7 days. Sevt.n days is o retsonable time to allow two hydrogen recombiners to be inoperanle because the hydrogen control function is maintained and because of the low probability of the occurrence of a LOCA that would generate hydrogen in the amounts capable of exceeding the flammability limit. t 4 (continued) MARK UP OF NUREG-1431 BASES B 3.6-60 5/15/97
. .. - . . . . . _ . = , ..- . . - . - . . . _ - - . . ._ . . . - - - . . . ~ --
l ADDITIONAL INFORMATION COVER SHEET l !- 5 ADDITIONAL INFORMATION NO: CA-3.6-001 APPLICABILITY: CA REQUEST: Removed reference to Regulatory Guide 1.35 and add reference to FSAR Chapter 16. I l FLOG RESPONSE: (revised) The reference to Regulatory Guide 1.35 has been removed and reference is now made to FSAR Chapter 16. Reference 4 will become FSAR Chapter 16 and Reference 5 will be deleted. This is acceptable because both FSAR Chapter 16 and the Callaway Containment Tendon Surveillance Program reference Regulatory Guide 1.35. l ATTACHED PAGES: l Att. No.12 CTS 3/4.6 -ITS 3.6 l Encl. 58 B 3.6-5 I I l l i t ! /^\ I' l l i f E k I
Containment (Atacsphcric) B 3.6.1 BASES
~'
SURVEILLANCE SR 3.6.1.1 (continued) REQUIREMENTS s 1.0 L, the offsite dose consequences are bounded by the assumptions of the safety analysis. SR Frequencies are as required by Appcadix J. es r.edificd by ar - MfM*f***=Nate~TiitfhtFProgten[m^d =--.tions Tl,as. SR 3.0.c (wnicr the [ 211= Frcqwin.y extensiens' does id ohybMperivuic .1 4 testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis. 3.6.1.2 for angreuted, p;st tensiencd tcadens This SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4). REFERENCES 1. 10 CFR 50, Appendix JEEor@.
] g 3,c,_ o (O)
/ m/
- 2. FSAR, Chapte 15.
- 3. FSAR ction 6.2.
%, y Y, F$AR. CAr m /6,
,. .w.vu s a wa y uulue A.ss , .w.....
q --gy' (3mi4m- , y3 < - x _ _;-- -* ' 3 ~y' N - q I_Cif3.C-ooI a 4 MARK UP 0F NUREG 1431 BASES B 3.6 5 5/15/97
i ADDITIONAL INFORMATION COVER SHEET l ADDITIONAL INFORMATION NO: CA-3.6-004 APPLICABILITY: CA i REQUEST: 1) Add requirement to the Bases for Required Actions 3.6.3.A.1 and l
- 3.6.3.B.1 that valves used to isolate a containment penetration must have been leak rate tested.
- 2) The Bases for Required Actions 3.6.3.A.1 and 3.6.3.8.1 are inconsistent I
with regard to the description of automatic valves. Change " closed and de-activated isolation valve" to " closed and de-activated automatic valve" within Bases paragraph 1 for Required Action 3.6.3.A.1 (Attachments 12 and 20). Delete "(this includes power operated valves with power removed)" from Bases paragraph 1 for Required Action 3.6.3.C.1 (Attachment 12 only). This statement is used in the Bases for Required Actions 3.6.3.A.1 and 3.6.3.B.1 to clarify requirements for a closed manual valve, and should not be used to describe a closed and de-activated automatic valve in Bases for Required Action 3.6.3.C.1. l FLOG RESPONSE: (revised) See revised request and attached pages with this item. ATTACHED PAGES: 1 Att. No.12 CTS 3/4.6 -ITS 3.6 l Encl. 58 B 3.6-19, B 3.6-21, B 3.6-23 l 1-i l l
, O
- - /
1 Containment Isolation Valves (Ata.caphcric. ibetasphcric, m w.m.m. m. m vom., B 3.6.3
.s i (s BASES ACTIONS A second Note has been added to provide clarification that, for (continued) 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 containment isolation valve.
Complying with the Required Actions mav 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 l appropriate remedial actions are taken. if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve. In the event the air leck contiYnsief,t%f#o18tfonyeT'is leakage results in exceeding the overall containment leakage rate ahibereriteria. Note 4 directs entry into the applicable Conditions and Required Actionslad r.deof LCO &c 3.6.1.Nd O (c%- 3. & , A.1 and A.2 ' la N# f In the event one ontainment isolation valva in nne or more penetration flow aths is inoperahld except for ContiLillmeht j FSttqging purge ggt'stg30ttr:gg valve oc jhicid buildEiVd 43 J l ne arrecteo penetration flow path 1
%tleakaoe notThe be isolatec'. with,4n met li@ hod of isolation th must include of at least onehisolation barrier that cannot be advepsely affected by a single active failure. Isolation barrfers that meet this criterion are a closed and de-activated autentic g,f-co4 centsian..t wlatimi valve, a closed manual valve Ethistincru%s o '
l g6iitrTi$Fet&tedIyaTWsWJgt(,'poetir$rja6Vedi. a blind flange, and a check valve with flow through the valve secured. E remote manuaW8WeA"fl41ECOntroYBoard;powerli,solateIWitch""spfbe usedItoideactivitelthelfa]Ve3 For a penetration flow path isolated in accordance with Required Action A.I. the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be completed within 4 hours. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during H0 DES 1, l
- 2. 3. and 4.
/O (continued)
MARK-UP OF NUREG 1431 BASES B 3.6 19 5/15/97
Containment Isolation Valves (Atacspbcric, Subatacaphcric. Icc Condcn:cr and Duci) B 3.6.3 y BASES ACTIONS A.1 and A.2 (continued) perfe_tratton?EdgEgath. Zig 11solat' e djim.aEgyerltied { admini$tgatiVeTyRotiblYnd[flangesiandsclosedimanuaUvilye5'sthat ' J ai;e bckikQtieiTed7odLthernisesseiredMJMsTislacceptib]e l sint~e itheseWere5jderMiedXbe?intthe? corr _ectEposition7ribrito l@iHK33MlfMIE0ffje;@lagg u I
//,.a c.d e + a n - (ta*'*Ll e
l With two containment jisolation valves in one or more penetration flow paths inoperable, the affected penetration flow path must be ) isolated within 1 ha'u r. 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 valve, a closed manual valve EthisgitSUdesTp]MrInnerated 9dT1ies '
Wittflgo!ier1temoV65);, and a blind flange. [A9 emoted huaT V8V!JggtgChatrgoHlDpdIpolificiUMLNiedZlgelgl[dlig p dea]M35EttinMraNQ The 1 hour Completion Time is consistent y with the ACTIONS of LC0 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a l periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the probability of their misalignment is low. Ccadition C is modified by ; Nott indicating thi; Condition i; only applicebic to pcactration 'icw paths with two contain; cat j i;clation volves. Condition A of this LCC cddicasc; the condition of cac containscat iscistion valvc inopcrsbic in this l tsc cf pcactratica ficW p;th. c.1 and C.2 With onc cr ; orc pcactretion ficw path; with onc contaire. cat O isoletion velv; inoperabic, the inopcr;bic volvc flow p;th must (~/ (continued) MARK UP OF NUREG 1431 BASES B 3.6-21 5/15/97
Containment Isolation Valves (Atuspk-ic. Suht;;;phcric. Icc Coninxr and Ou;l; B 3.6.3 BASES d ACTIONS (hi (continued) With tk shield building bg.en labs r;tc not within limit, th; enu;ption; cf tk afcty enelyxs arc not ut. Tkrcforc. th; ic;;b;; aust bc rate;1d t; within li;it within 4 heur;;.
";;ter;;ti;n an k eGwlisMd by isolating th; gatretion(s) tkt ceuxd tk li;it to bc exu;ded by ax of era cicxd end i ativ;ted ;;ute;; tic volve, ciend unu;;l volve cr blird fienge. Ukn ; gxtration is isoleted tk labg ret; fer the iscletcd gxtretien is enu.ed t; k tk ectual pthw;y inbg through the i nletien i vice. -If two is;l;tien ivix; er; uxd t; inletc the Factretien, the lab;; retc i;; ;;nund te, k the icncr ectuel peth.;;y 1Ghsc of tk two ivia;. The 4 hour twicti;n Tin is rana;;bk an;;iiring th; tix rc-viccd to ruter; th; 1shg by i;;;1etir; the Fatr;; tion (s' eri the relativ; i;grt;;x; ef xcender; Gatein at bypen laug; t; the everell cent;;in nt furetion.
CTE2!'!TneM55 E-hy_ =d " (n In the event one or rore Containment S@dogggattrgPurge valves in one or more penetration flow paths are not within the i purg; velve leakage limits, purg; velve leakage must be restered Q 3. f. 4 y t9RW5( to within limits. or the affected penetration flow path m ~ rf I must be isolated. The method of isoiation 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 7 criterion are a Eclosed and de activated automatic valve CJ jCA-73 % N e ---C . ~-- Z L T. C M _ C . c.1; x d u nuel a vehe- or blind flange 3. A purge Qng;4_irmgestRatioMIPoige l or ttff Ml valve with resilient seals utilized to satisfy Required Action gI E-+ must have been demonstrated to meet the leakage requirerents of SRJ;tu.sq SR 3.6.3.7. The specified Completion Time is reasonable, considering that one containment purge valve renains closed so that a gross breach of containment does not exist. t In accordance with Required Action CE2i E.2. this penetration flow path must be verified to be isolated on a periodic basis. The periodic verification is necessary to ensure that containment penetrations required to be isolated following an accident, which are no longer capable of being automatically isolated, will be in the isolation position should an event occur. This Required 0 U - (continued) MARK 'UP OF NUREG 1431 BASES B 3.6-23 5/15/97
ADDITIONAL INFORMATION COVER SHEET 77 ADDITIONAL INFORMATION NO: WC 3.6-010 APPLICABILITY: CA tb) REQUEST: The ITS Bases - SR 3.6.6.2 is revised to indicate that performance of this surveillance is concemed with containment cooling fan unit degradation. This 31 day Surveillance Requirement does not verify that all associated controls are functioning properly. A quarterly slave relay surveillance test ensures that the associated controls are functioning properly. FLOG RESPONSE: (revised) The ITS Bases - SR 3.6.6.2 is revised to indicate that performance of this surveillance is concerned with containment cooling fan unit degradation. This 31 day Surveillanco Requirement does not verify that all associated controls are functioning properly. A quarterly slave relay surveillance test ensures that the associated controls are functioning properly. (Enclosed is a corrected index of Additional Information showing this item as applicable to CA and WC only.) ATTACHED PAGES: Att. No.12 CTS 3/4.6 -ITS 3.6 Encl. 58 8 3.6-47 Corrected Index Page 6 of 6 from ULNRC-3853 (6/26/98) t
'v I j
/ \
l l \ (v)
Containment Spray and Cooling Systems (Atmosphcric cnd Duci) B 3.6.6A (g,) BASES vg ACTIONS E.1 and E.2 (continued) If the Required Action and associated Completion Time of Condition C or D of this LCO are not met, the plant must 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. El With two containment spray trains or any combination of three or more containment spray and cooling trains inoperable, the unit is in a condition outside the accident analysis. Therefore, LC0 3.0.3 must be entered immediately. fq SURVEILLANCE SR 3.6.6A.1 -
,, d (v) REQUIREMENTS -
%s Verifying the correct alignment for manual, power operated. and automatic valves in the containment55spray ap1M flow pathVorovides assurance that the oroner nnw piths u '1 ads for'C'o'n tainment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in
_'N-~ position, since these were verified to be in the correct position s 3,(,, 3- f 2 prior-to-lockingmiealing, or securing. This SR does not require p- any testinyr valve manipulatiqn. gather,it involves
/ b .g verification. 'through c;ystc; wcmdythat those valves y outside containment (only check va;L crc insidc centcinmcat)
/ and capable of potentially being mispositjoned are in the correct
/hthh position.
h4a4 lL u W s A _U '
]
c.v rud /AIWkj SR 3.6.6A.2 % *A A/bperating each containment coo ing train fan unit for
- bW' 2 15 minutes ensures that all trains are OPERABLE end th&Tt1 a"^ N enntrn1< ara functinninn nrnnarly. It-else cusw es MDioCKage. Tan or motor foilm c. Gr EXc555ive v ibr6t-IOU c61i te ddected for-eerrectia actinn V The 31 day Frecuency was (n
V
) J/ +e n Ja wh C A n,x uasaap~ a x(continued) $
MARK UP OF NUREG 1431 BASES B 3.6 47 5/15/97 l 1
INDCX OF ADDITIONAL INFORMATION Page 6 of 6 [ ADDITIONAL INFORMATION APPLICABILITY ENCLOSED ('/ ) CP 3.6-013 CP NA
# *- CP 3.6-014 CP ., NA CP 3.6-015 CP NA CP 3.6-016 CP NA CP 3.6-017 CP NA TR 3.6-002 M CP,DC, % NA WC 3.6-ED WC NA WC 3.6-001 WC NA WC 3.6-002 WC NA WC 3.6 003 WC NA WC 3.6-004 WC NA WC 3.6-005 WC NA( M WC 3.6-006 WC NA(5 W WC 3.6-010 WC, CA YES U
O
i ADDITIONAL INFORMATION COVER SHEET
- ADDITIONAL INFORMATION NO
- Q 3.7.1-4 APPLICABILITY: CA j REQUEST: CTS 3.7.1.1 Action a ITS 3.7.1 Action A.1 and A.2 and Table 3.7.1-1
~ DOC 01-04-LS3 l JFD 3.7-01 ;
f This change is beyond the scope of a conversion because of the industry travelers . 4 referenced in this DOC (WOG-83, Rev 0 and Rev.1) that have not been approved by the t ! NRC.
\
Comment: Withdraw the change or adopt the STS. ' FLOG RESPONSE: ! (ORIGINAL) WOG-83 has been approved by the TSTF and is designated as TSTF-235. l This traveler has been submitted to the NRC and is under review. The proposed wording i-in TSTF-235 was modified from WOG-83 and these modifications have been incorporated into the ITS. Comanche Peak, Wolf Creek, and Callaway, continue to ! pursue the changes proposed by this traveler. Diablo Canyon will no longer pursue this
- change due to issuance of LAs 125/123 (dated May 28,1998) which revised 1
CTS 3/4.7.1.1, Table 3.7-1, " Maximum Allowable Power Range Neutron Flux High
- Setpoint With inoperable Steam Line Safety Valves" and the associated Bases. See
! licensee-initiated number DC 3.7-008 for more details. FLOG SUPPLEMENTAL RESPONSE: ; i AmerenUE's original response to NRC RAI Question 3.7.1-4 from ITS Section 3.7 i indicated the adoption of traveler TSTF-235, with modifications unique to Callaway. After j , additional NRC review that the modifications are out of scope, AmerenUE is withdrawing , j the portion of its response to RAI 3.7.1-4 in the October 21,1998 submittal which revised the power levels in Table 3.7.1-1 with valves inoperable and the footnote for having a j single valve inoperable on one steamline. The attached pages show the revised- L 1 response and are a replacement to those submitted in the October 21,1998 transmittal.
- These revisions are applicable only to Callaway and do not impact Comanche Peak, j Diablo Canyon, or Wolf Creek.
? - ATTACHED PAGES: . I l Att. No.13 CTS 3/4.7 *TS 3.7 ; Encl. 2 7-1, 7-2 : Encl. 3A 2 ; Encl. 5A 3.7-1, 3.7-3 l
. Encl. 5B B 3.7-4
- i. Encl.6A 3 i J Encl. 6B 2 l
\
O
-.,,y .-.y , . _ r,-w
/% "
O) REviS l0 2 i l 3/4.7 PLANT SYSTEMS l j.] 3/4.7.1 TURBINE CYCLE ]-\'5 - A l i SAFETY VALVES Q '3.'L I-l l i
. LIMITING CONDITION FOR OPERATION f
.'.h. .. .
3.7.1.1 All main steam line Code safety valves associated with each steam generator shall be OPERABLE wi:.'. if t settia;; ; ;pe.ified in Tam ;.7 2. o g. ot- A s + APPLICABILITY: 500ES 1, 2, and 3._ t IS * * 'A "ck. rnSS@ on- ol-LS1 ACTION: h,M bd.b +. Loo With four reactor coolant loops and associated steam generators in f43S.1-4 operation andWith or more main steam line Code safety valves inoperable,+ operation in H00E51, 2, and 3 may proceed provided, that o;,34,ts.3 rwithin 4 nours, either the inoperable valve is restored to OPERABLE .cg g status er th: ':wcr kn;; M utr:n ' lux Hgh -f p 5:t:01nt i: : du e : d"o g. e4-L5 5 OM of rnor-6 -;cr 7;tle 2. ~_; otherwise, be in at least HOT STANDBY within the gg hours. ( \epe j next6hoursandinf SHUTDOWN within the f:11:0 -- V' b. *he. previ:icas f 'peci fi;;tica 2. 0.1 :.r; act cpplicabic. e; C ^ - f.t s'
=
cl-6-A s o s_o .-L55n C L- C (.- fA C. . Twse.<L b - f4 C W h.L.5-40 g,g;_g
}
SURVEILLANCE REOUIREMENTS 4.7.1.1 He addition:! :;uir:eene ether th:n th::: rq uircd by ot-o7- A Speci fice^.ica 4. 0. 5. Insed. C.
, er om, or m ore s6 geni. odors M L cnc H55V mo p l,le. J &. MTC.,
posh 4 9 pousu . b uE : . g 3.1.j-co t.s '5 cl 'an, t- 4 o i_oq_ Ls-3 ct.. co$.oweor
,no p a \e. a H od u d ormere coep(usm+
S6 y%p
w &
CALLAWAY - UNIT 1 3/4 7-1 'N ', m RT & WY rn 89'o f sj._
5 no 4 yu p w G r.Ptl R T P.
y..
m '
CTS 3.7.1.1 fooisotes and inserts
(
( --
l 2-Insert A )
- 9 ' or r:Ex Thcand Powerh h:: M, cc :q"'I m & M'vi-- ^ !!c >>dk- - 'CN 01-04-LS3 -
W , RTP gd&d is Table 3.7-1 fc: Se r/Me cf OPEPRLE MSSV: and (e adeoe the Power Range Neutrdn Flux High Trip Setpoinfis reduced 4e4 es - C s.t' 6 . :: :qud te Se M' vin = A!E 2/d!: ?'. R'm :;::!Sd in Table 3.7-1 ..
.v- .. . fc: S n~1:: cf OPEPJ ELE MSSV: within 72 hours; ?y
+.g .u-
. ma. nn. :s..
. .,w. .
- SGi Insert B NEW 'l ~
H0DE 3 ~ 12 - s
- c. With one or more steam generators with less than two MSSVs 01-06-M OPERABLE, be in at least I!OT ST/QB'rwithin the next 6 hours and
, in IIOT SI"=b7a ' within 6: fcik >&kurs.
/4
-]* - HoDE 4 -
Insert C
" 01-07-A 4.7.1.1@ Verify each required MSSV lift setpoint per Table 3.7-2 in i O. accordance with the Inservice Testing Program. Following l Q testing, lift setting shall be within +/- 1%.
Footnotes A
@ Only required to be performed in MODES 1 and 2 01-05 .M' 4 'ifl h6
$ re uu ed in MobE i _o t-nd -LS- 3 a s n.1 - +
1 (O
REviSt oy TABLE 3.7-1 ., 7.-m.g ( I .AXIMU" ';LLOW?.3LE PCNER '^NCE "ELCC" PLUX "IC" SE~ POI"' WITH
/ ,
(%- - 27.y
~
. "1HGPEMSLE LTEA!; It E SAf ETY "AL'!:S otra s.AbLE f%cin Shaw WW *\es 1 uu, It!C FCUD LCCP CPERATIC" W. Mo.y. O.tL%1e. P.we.c
;,8 h LE MAXIMUM ALLOWABLE POWER N _ ot-o4-LS$ ,
-- r fraB. .~ ,i .-..mo ~ . -.- . n. e. .u. -
w, . . . . . , , - .~.v_ uu. .r. . .OF ftpsl9RurrNUMBER . -.
- SOPE
- ger. em. l 3
- q ) .,
~,,_ -
--(NOF GTED inEiimt r u dE R',
i
, . . . ,o..,.,,,. l s'4, ly T-1 h-e CRAT!"C; STEAM GENERATOR
( o/o R.T P ) ,2 l j
^
- w n , .r us. , , ' _ _ . _ X f h
.A, O ll 04-LS 3
.'7.l- Y L # 3 g ~
f*" M " -
# 2 '"( 44-
. T?
, .3. J.;, , . .
.04k s _f ~
on o\y one. E e.w r3 kh ahup '
- g. g og h55V 6 er \e.
55 v j? 15
- ET?. 1 on g ,,
1 ah.w aAtw- Nwm
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u , e, w '7. R . 7-
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- 5. -ED )
.c -. . .
I a D ..) CALLAWAY - UNIT 1 3/4 7-2 ( N
CHANGE
\ NUMBE9 EE!C DESCRIPTION ,1
('-) high trip setpoint be reduced for inoperable MSSVs if a positive moderator temperature coefficient (HTC) exists at
- 'y ,
the allowed percent rated thermal power in H00E 1: and
- 3) the power range neutron flux high trip setpoints be
-f ruiuced to account for a control rod withdrawal at partial 3 power witn more than one MSSV inoperable. Jnaddition, y
the completion time for resetting the high Tiux trips is
., revised from 4 hours to 72 hours and the ACTION is revised
~
-, to specifically require an appropriate power reduction $
d o within four hours. This is a relaxation since the CTS E "iI g require the high neutron flux trip setpoint to be reduced % A-as required within four hours for inocerable MSSVs W 3oCP # reoardless of the HTC valuejPending approval of draft h$ I p I have
.1 of WOG-83, the cnanges proposed in the travel an modified to retain the current TS re ' ement to Tg S o, reset the - r range neutron flux high trip etpoints b 3_. based on the numee f HSSVs inoperable t a maximum 9 > allowable power determi in accordan with calculations E or analysis to account for W *ingh se NSAL 94 001 and t i
o r NRC Information Notice 94 60. h ver, the completion Q N 'j 9T E_ i time of 72 hours proposed by -83 been retained and {
- ~
ghf is justified based on the w probabilit f an event
" ((
occurring during this - and the need to p vide
- ~ sufficient time to set the channels in an orc ly manner f ~"Ggo <ithout inducin transient due to human error.
$ a Retention of . e CTS requirement for resetting the re tor trip set ints is acceptable because this requirement is
*e nore anservative than the ACTIONS scecified bv either the 5orWOG83.asrevised) 01 05 XA The exception to TS 3.0.4 is no longer needed due to the note associated with the revised surveillance. The
_ exception was allowed to TS 3.0.4 due to the fact that the applicable s00ES must be entered in order to perform the Q M.1-5 required surveillance (if the MSSVs are tested in place) and to allow Mode changes to be made if the applicable action was met. In the CTS. MODE 1. 2. or 3 could be ant er_ed. In NUREG 1431. the surveillance is modified by a 74_ , -;;-i:t' [})ote that specifies that the surveillance
~
[ eed oWiy be current prior to reaching MODE 2. The surveillance note still allows MODE changes into the MODE of APPLICABILITY of the LCO. i .e. . MODE 3 for testing purposes. 01-06 M The new ACTION adds an explicit requirement to be in 7-N MODE 3 in 6 hours and MODE 4 in 12 hours if any steam generator (SG) loop has less than two MSSVs operacie. ( V) NUREG 1431 requires that tne plant only be placed in a DESCRIPTION OF CHANGES TO CURRENT TS 2 5/15/97
. . - .-_ - - -.. - . . - - -. . - -- - _-_. - - . .. ~ _ _ - - Q 3.7.1-4
] INSERT 3A-2 Based on Westinghouse Nuclear Safety Advisory Letter, NSAL 94-001, for plants licensed to I-jd . operate at partial powerlevels with a positive MTC, changes are made to require a reduction in ud.J ,,,, the Power Range Neutron Flux-High reactor trip setpoint in addition to a reduction in reactor .t:h*.2 power when the MTC is positive. This is necessary to limit the primary side heat generation that UO$may occur during a RCS heatup event. With a positive MTC a heatup of the coolant will result in d$ Ea power increase which requires additional steam relieving capacity. Changes are made to 21@Wreduction require a reduction in the Power Range Neutron Flux-High reactor trip setpoint in a in the reactor power when there is more than one inoperable MSSV on any single W ' i steam generator. For a reactivity insertion accident such as an uncontrolled RCCA bank
- Na withdrawal from a partial power level the reactor power will increase during the transient until a -
$7raactor trip occurs on Overtemperature (Delta-T] or Power Range Neutron Flux-High. With more Q;; = ;; than one inoperable MSSV on any steam generator the combined steam flow capacity of the inoperable MSSVs and the turbine may be insufficient in some cases to prevent overpressurization of the Main Steam System prior to reaching the reactor trip setpoint. The Action for reducing the Power Range Neutron Flux High reactor trip setpoint is modified by a footnote to indicate that reducing the setpoint is only required in MODE 1. In MODES 2 and 3 the reactor protection system trips in CTS 3.3.1 provides sufficient protection.
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\ i 'J 3.7 PLANT SYSTEMS .
3.7.1 Main Steam Safety Valves (HSSVs) 9 A LCO 3.7.1 Fne inve MSSVs pecriean genetator. shall be OPERABLE :: :p:;i' icd ir, :3 7 01~
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5 APPLICABILITY: HDDES 1. 2 and 3. ACTIONS Separate Conditi entry is ilowed r each MSSV. CONDITION REQUIRED ACTION COMPLETION TIME)
~
f X One or more r g ir;d 'N.1 Reduce y u.ime m =rm et 4 hours w317:0b.. ( i 6 l '"l: 'r:p;r f :. 3 to less than or equal to the Shaun ,Je s u),' appli:Sc t!weewante he o,q Ys t RTP 'i:t:d spetsmec in Q 0.,0'I-N MopraNE.,. Table 3.7.1-1 Icr.snernamnen McE121EER552 OR E - . - - N OTE - - -- de 1 h 0% or mort 5 .
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C Required Action and 6 hours Ck. X.1BeinHODE3. associated Cctlpletion Time not met. BQ M [2 Be in MODE 4. 12 hours C.
- One or more steam
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3.7 1 5/15/97 MARA UP 0F WOG STS REV 1 (NUREG 1431)
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- CONDITION REQUIRED ACTION COMPLETlON TIME A. . One or more steam ,mnM
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l l MSSVs 3.7.1 wimMO Table 3.7.1-1 (page 1 of 1) OPERABLE Main Steam Safety Valves versus L f>pplicabigower ir Nrcer.t of RATED Til:TWAL 70','En 3'7-O/ l 1 !"IMUM NUMBED OFYMSSVs MAvrMuH A RNABG q 3.1. ; ._4 D PER STEAM GdrlERATOR APPL-CACL:- POWER _ 4: QUIRE OPEIACLC- (Y. RTP) 49h ye e4 w
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I MSSVs - B 3.7.1 i 1 ! BASES 1 ACTIONS A.1 liRI T 2 (continued) Q 3,"/. I ettfriartniliva1BNuiEMIEEEEEEEMEstBEREn j With one or more MSSVs inoperable, rCduc pC.;Cr wo hs M so that the available MSSV relieving capacity meets E LL_ ___1 npu g
- Reference 2 requ1 resents ..__ . b.~ o ry . J. _ ._ .L 1. _ M. .. jrnu .ma e . .
usi.ranhs./a- Q kY 3 7.G-I ) y.,, w ,....s,c.. ration with less than all SVs OPERABLE for i each steam generator is permissible, if POWER is
; prepe-tienelly limited to the relief capacity of the resa l MSSVs. is is accompl by restr_icting THERMAL POWER l.
Q3.'7. l- Y o that t energy transfer to the most ng s generator is not greater than the available relief capacity in that steam generator. ";I ca.;plC. if era "SS" 13 iI pdreblC 10 er.C 3ts; ,Crareter, tra rCliCf CepeCity of tPat sts; ___m__ ,___;..2 ,._ _,,__. m,_
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CHANGE NUMBER JUSTIFICATION lllVq l i 3.7 07 Revised Conditions A and D to be consistent with current licensing basis. Ths ITS as written would have allowed the OPERABLE emergency exhaust sptem (EES) train to remain in standby during movement of irradiated fuel. l c- 3.7 08 SR 3.7.5.1 is revised to add a note consistent with the CTSs and the ny ~ plant specific design. The verification of flow control valve position
.is deferred until conditions are appropriate.
' 3.7 09 Not applicable to Callaway. See Conversion Comparison Table
. (Enclosure 6B).
n r, - 3.7-10 Not applicabl'e to Callaway. See Conversion Comparison Table (Enclosure 68). 3.7 11 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 68). - 3.7 12
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},4 3.7 13 Not applicable to Callaway. See Conversion Comparison able (Enclosure 6B).
Gf)% f 3.7 14 Not applicable to Callaway. See Conversion Comparison Table V (Enclosure 68). 3.7 15 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 6B). 3.7 16 Not applic-E e to Callaway. See Conversion Comparison Table (Enclosure 68). 3.7 17 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 6B). 3.7 18 Not applicable to Callaway. See Conversion Comparison Table (Enclosure 68). 3.7 19 REQUIRED ACTION B.1 is revised to state that restoration of "all but one" [ASD] line is required, which will effectively exit REQUIRED ACTION B.1 and re enter REQUIRED ACTION A.1. This is consistent with the BASES of NUREG 1431. The specific change proposed by Industry Traveler TSTF 100 is to add the "all but one" phrase to REQUIRED ACTION B.1 for plants that only require three of the four [ASD] lines to be OPERABLE. l ikA l 3.7-20 This change implements a requirement that is in CTS for Callaway. A 7 i (/ new Condition is added to address the inoperability of one of the Essential Service Water (ESW) supplies to the turbine driven AFW pump. JUSTIFICATION FOR DIFFERENCES TS 3 5/15/97
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i Q 3.7.1-4
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.S RT6Al points ar giv in Ta /
[w ge tor. A Note added to T e 3.7 3.7.1-1 for i se of 4 OPE Vs per ste\a and to e Require ti .1 to addre thegiant ecific equirement. ddition of th ote does not c ge chnical req ' eme , but provides arificatiort. he two s oints dbas ses. The saf 's on current lic g and analyses a lyses r ased on We i ouse Nuc Safe dviso etter, N D 94 001. Fopcifther \ info son re r to DOC - LS-3. - C. ok n'a 4 l l l
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CONVERSIONCOMPARISONTABLEFORd5EFERENCESFROMNUREG-1431.SECTION3.7 Page 2 of 7 TECH SPEC CHANGE APPLICABILITY NUMBER DESCRIPTION DIABLO CANYON COMANCHE PEAK WOLF CREEK CALLAWAY 3.7-09 New Conditions F. G and H and the surveillance YES NO NO NO requiremant associated with the FWST ATW punp supply are relocated from the CTS on AFW supply and included in the DCPP AFW specification for conpleteness. 3.7 10 The specification description. the LCO the action YES NO NO NO requirements and the survelliance are ravised to incorporate the DCPP plant specific requirement for ( operable AFW supply sources via the CST and the FWST per the current licensing basis. 3.7-11 The REWIRED ACTIONS for CPSES feedwater isolation and NO YES NO associated bypass valves inoperable are revised consistent NO with the current Ifcensing basis for a COTLETION TIE of 4 hours and to credit the HFRVs (feedwater control valves (fCVs)) and associated bypass valves for a coupletion time of 72 hours. A new SR is added for the FCVs and associated bypass valves. 3.7-12 -83 eviseu wm WA a ntjoF) w ants hat edit Iaoie 3.i-1 act Powe Range Igh Ne ron F Ux Wipf j 3,qpy e M M/A e y[A, e M/A f nct an whe HTC posit e (Se 3.7-01 above . ik [ rdt g of ie tra eier h been fffe Qg gg@ j A plant oariff diff y -for 6Sr5 j;o y 3.7-13 ~ Note 1. under REWIRED ACTION A.1 is deleted. The DCPP YES NO NO NO emergency diesel generators have self contained cooling systems that do not rely upon an external source of cooling water. 3.7-14 The note for SR 3.7.8.1 is deleted since the DCPP ASW YES NO NO N0 system supplies only the CCW heat exchanger and no other individual conponents. 3.7-15 SR 3.7.8.1 is revised to include a DCPP specific YES NO NO requirement to verify the availability of power and air so NO that the valves can be placed in their correct positions as described in the bases. CONVERSION COMPARISON TABLE - NUREG-1431 5/15/97
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ADDITIONAL INFORMATION COVER SHEET ADDITIONAL INFORMATION NO: CA 3.9-001 APPLICABILITY: CA REQUEST: ITS Bases 3.9.3.2 SURVEILLANCE REQUIREMENTS are modified to add the word "... Westinghouse..." to make it clear that channel calibrations include integral Bias Curves for Westinghouse detectors only, because Gammametric detectors are Fission Chambers rated for a 40 year life and routine Integral Bias Curves are not required for them. Under the Bases Section 3.9.3 for Applicable Safety Analysis, the phrase " ..and a signal..."is deleted. The Gammametrics channels provide indication only. ATTACHED PAGES: Att. No.15 CTS 3/4.9 -ITS 3.9 Encl. 5B B 3.9-9, B 3.9-12 ' t k a
S Nuclear Instrumentation B 3.9.3 4 ( B 3.9 REFUELING OPERATIONS B 3.9.3 Nuclear Instrumentation ) i BASES ' 1 BACKGROUND The source range neutron flux monitors are used during refueling operations to monitor the core reactivity condition. The 1 installed source range neutron flux monitors are part of the Nuclear Instrumentation System (NIS). These detectors are located external to the reactor vessel and detect neutrons leaking from the core.
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The insteilcd ; 6 s s .n # source range neutron flux monitors i ga .m w.: ,.i:9asm are BFS & detectors operating in the proportional region of the gas filled detector characteristic curve. The detectors monitor the neutron flux in counts per p) ( V second. The instrument range covers six decades of neutron flux (100 gs) m with a M instr; cat accuracy. The detectors also provide continuous visual indication in the control room ;nd on ;;dibic aler; to alcit opcreters to e possibic dilutica eccident. The NIS is designed in accordance with the criteria presented in Reference 1. Os E!t!RdMBMINBar2nJimm!LnE1MiiGNMIR2Wilkstaplutment
!aW515ERSHRIMt325!MLtREMMMmmtamp3mps 1EBJ@ltiREONFC%ifttHMEtD6siWMtWilggtDit~u~5Ev EilfttiirTc6Yb EEE C A 3.9- co l APPLICABLE Two OPERABLE source range neutron fluxFmonitors are required to SAFETY ANALYSES provide 25htindbnEihdid~atT6KMs/ggef)to alert the operator to unexpected changes in core reactivity such as with a bcron dilution accicent Gef. 2; or an imprcperly loaded fuel assembly.
Ec accd fer a sef;ty onelysis for an uncontrolled berca dilution accidcat is elimincted by isolating oil unbcreted Watcr sourc;3 O ( (continued) MARK UP 0F NUREG 1431 BASES B 3.9 9 5/15/97
Nuclear Instrumentation B 3.9.3 BASES SURVEILLANCE SR 3.9.3.2 REQUIREMENTS (continued) SR 3.9.3.2 is the performance of a CHANNEL CALIBRATION every l 18 months. This SR is modified by a Note stating that neutron l detectors are excluded from the CHANNEL CALIBRATION. gg)h005C CALIBRATION for thdsource range neutron flux monitcrs consists The CHANNEL l ' of obtaining the dctcctor pletceu or pr;;;.p di;cris.imte C.A 3,9-00 l ManiaEmistis curves, evaluating those curves, and comparing the curves to the manufacturer's data. The 18 month Frequency is based on the need to pcifcr;, thi; Surveiller.cc MMERWgpM1 NfgM..._ under the conditions that apply during a plant
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M Operating experience has shown these components l usually pass the Surveillance when performed at the 18 month Frequency. I REFERENCES 1, 10 CFR 50, Appendix A. GDC 13, GDC 26, GDC 28 and GDC 29.
- 2. FSAR, Section M MARK UP OF NUREG 1431 BASES B 3.9 12 5/15/97
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