ML20198K326

Forwards Response to 970529 & 0606 RAI Re License Amend Request to Convert to Improved Sts.Response to Section 303 Provided in Attachment 1.Rev 8 to Original License Amend Also Encl

ML20198K326
Person / Time
Site:	Calvert Cliffs
Issue date:	10/20/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198K329	List: ML20198K326 ML20198K332
References
TAC-M97363, TAC-M97364, NUDOCS 9710230325
Download: ML20198K326 (70)

Text

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Cmu Is H. Curse Italtimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Cahert Cliffs Parkway Lusby, Maryland 20657 t

410 495-4455 October 20,1997 s

%l U. S. Nt.elear Regulatory Commission Washington,DC 20555 q

l A'ITENTION:

Document Control Desk b

SUBJECT:

Calvert Cliffs Nuclear Power Plant h

Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 il Revision 8 to the License Amend' rent Request so Convert to the improved

,l Tschnical Speci6 cations (TAC Nos. M97363 and M97364)

REFERENCES:

(a)

Letter from A. W. Dromerick (NRC) to C.11. Cruse (BGE), dated i

May 29, 1997, Request for Additional Information Regarding the hl 4-l Technical Specification Change Request to Convert to the Improved w

Technical Specifications (TAC Nos. hi97363 and h197364)

?

( [

(b)

Letter from A. W. Dromerick (NRC) to C.11. Cruse (BGE), dated T [j June 6, 1997, Request for Additional information Regarding the Technical Specification Change Request to Convert to the improved

}[

Technical Specifications (~TC Nos. h197363 and hi97364)

I References (a) and (b) transmitted questions regarding Section 3.3 of Baltimore Gas and Electric

(

Company's application to convert to the improved Standard Technical Specifications.

L s'

The responses for Section 3.3 are provided in Attachment 1 of this letter. Also attached to this letter is

} $,

Revision 8 to th; original license amendment application. These changes result from the responses l

provided in Attachment 1, as well as other changes identified by plant personnel. Changes to the No j

Significant Hazards Considerations discussions are included where appropriate.

a 4

To assist in reviewing this revision, a list describing each of the changes is provided (Attachment 2). All of the material for each change is grouped by change in Attachment (3). Attachment (4) provides the revision by improved Technical Specification Section for ease of replacing pages in the original amendment request. Page replacement instrudions are provided. All changes are marked with revision bars and are labeled Revision 8.

I h\\

h 9710230325 971020 PDR ADOCK 05000317 P

PDR n

Document Control Desk October 20,1997 Page 2 The Plant Operations and Safety Review Committee and a subcommittee of the Offsite Safety Review Committee have reviewed revisions resulting in changes to the No Significant flazards Considerations and concur that operation with the proposed revisions will not result in an undue risk to the health and safety of the public. Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, 4V

/tW STATE OF MARYLAND

TO WIT:

- COUNTY OF CALVERT I, Charles 11. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, t

Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this License Amendment Request on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my

. personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

w #W does Subscribed and sworn before me, a Notary Public i and for the State of Maryland and County of bild_X/LL)

.this R 0 day of T4),1997.

WITNES8 my Hand and Nota-ial Seal:

l'NAL> b MLL Notary Public My Commission Expires:

A Date CHC/ PSF /bjd -

Attachments: - (1) Responses to Request for AdditionalInformation (2) Summary of Changes (3) Amendment Revision by Change (4) Amendment Revision by ITS Section n

g Documsnt Control Desk October 20,1997

- Page 3 cc:

_ M. L Reardon, NRC (With Attachment 2 only)

R. S, Fleishman, Esquire

11. J. Miller, NRC

- J. E. Silberg, Esquire Resident inspector,NRC

. Director, Project Directorate 1 1, NRC R.1. McLean, DNR A. W. Dromerick, NRC J. II. Walter, PSC i

f 1

3' s

~1

~

ATTACHMENT (1)

IMPROVED TECIINICAL SPECIFICATIONS, REVISION 8 RESPONSES TO REQUEST 1 ADDITIONAL INFORMATION 4

1 1

4 4

A 4

i Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 20,1997

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- - -...- ---.. -. -. -... -.. -. - - -. -... -.. ~

.... ~.

m.

I ATTACHMENT. (1) i RESPONSES TO REQUEST FOR ADDITIONAL'INFORMATION IMPROVED' TECHNICAL. SPECIFICATIONS SECTX)N 3.3 i

2

3.3.11

DOC.

JFD-CHANGE / DIFFERENCE COhAAENT STATUS-1 f

~1 1 A.5 CTS 4.3.1.1.2. requres demonstratmg ' the bypass logic, 'wicludmg the Rewse the sutxnsttal to 5/20f97 automatic bypass removal logic'. Operable prior to each reactor startup, speedically nientdy the open unless performed dunng the precedmg 92 days. ITS 3.3.1 moves this plant procedures ' that a

requirement to urudentdied plant procedures. The ju.'a,.t;cii does not contam this requirement x$ent#y the plant procedure that mamtams thi= requwement nor the sfwXic and desenbe how coiiuvis that maintain the requrement in plant procedures.

changes to it wiB ~ be

-l controlled.

BGE Response:

DOC L3 will be provided'to justify deleton of this requrement. DOC LA.5 will not be used.

j

.2 CTS 4.3.1.1.2 requres demonstrahng the Operatxisty of the total bypass Prowde distmaarvi and 5/20/97 I

funchon dunng Channel Cahbrabons of each channel anected by bypass pstdicabon for this less open operation. ITS SR 3.3.1.7 requres a Channel Funcbonal Test of only the restnctwe change that l

automabc bypass removal function. The t&1:1 bypass funcbon is not deletes teshng of the total j

i demonstrated Operable by the ITS. This less restnchve change is not bypass funcbon.

justdied.

BGE Response:

f I

The total bypass funcbon at Calvert Cliffs is consedered to be the automabc bypass removal feature. Testmg of this feature is retamed in improved l

Technical Specdication (ITS) Surveillance Requrement (SR) 3.3.1.7 and 3.3.1.8.

[

3 LA.2 CTS Table 3.3-1 Notabon f, requres' at least two decades of overlap Revise the submdtal to I 5/20/97

'f between the wide range icyisiiii.ii;c neutron flux mondonng channels and speedicaNy identfy. the open the power range neutron flux monitoring Twn,e;s. ITS 3.3.1 moves this' plant procedures. that detail to unidentifed plant procedures. DOC LA.2 does not identdy the plant contam this regarement procedure that mantans this requrement nor the speedic controls that and desenbe how mantam the requrement in plant procedures.

ct r.fe. to it will be

'f contrt ed.

i

j 1

ooc - Discussion or chano.

1 JFD = Jushncation for Dewation i

m

I ATTACHMENT (1) l I

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT-STATUS i

BGE Response:

)

DOC LA.2 will be revised to move this detail to the Bases.

I 4

LA.6 CTS Table 3.3-1. Action 2.b, requires, within one hour, placing all functional Revise the submittal to 5/20/97 l

units receiving a parameter input from the inoperable channel in the same fu!!y explain.qow Action open tripped or bypassed condition as the inoperable trip channel. DOC LA.6 2.b of CTS Table 3.3-1 wi!!

states this requirement is moved to the Safety Function Determination be accomplished under Program (SFDP) of ITS 5.5.15. Although the SFDP is activated under ITS the ITS. In addition, this is LCO 3.0.6 and ITS LCO 3.0.6 would apply when ITS LCO 3.3.1 is not met, an L-type, not an LA-type it is not certain that the SFDP would require taking the same action as change.

Action 2.b of CTS Table 3.3-1 or an equivalent action.

BGE Response:

DOC A.18 will be provided to retain the requirement in a different format. DOC LA.6 will not be used.

Revise the submittal to 5/20/97 5

M.1 Wrth one inoperable channel in trip, CTS Table 3.3-1 Action 2.c allows discuss and justify the open

(

bypassing an additional channel for testing and maintenance for up to 48 relaxations associated hours. Corresponding ITS 3.3.1 Action B allows placing one inoperable with ITS 3.3.1 Action B.

channel in trip and a second in bypass without restric' ion on the second channel; that is, the second channel can be irv.p.rable for testing, maintenance, or for any other reason. This is less re:cJictive because the ITS allows the second RPS channel to be inoperable for reasons other than permitted by CTS Table 3.3-1 Action 2.c. In addition, in the event a second channel is inoperable for other than routine surveillance test.%, the CTS specify no action requirements; thus a plant shutdown would be required b*f CTS 3.0.3. ITS 3.3.1 Action 8 permits operation for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before a shutdown (per ITS 3.3.1 Action G) is required. The submittal does not address these relaxations.

BGE Response:

DOC L4 will be created to provide justification for deletion of this requirement.

doc = Discussion of Change 2

I JFD = Justificaten for Deviation a-_-

. ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

-3.3.1 DOC JFD.

CHANGE / DIFFERENCE -

COMMENT-STATUS-6 A.7 CTS Table 4.3-1, Endnote (3), restricts reactor power to 90% Rated Revise the submittal to 5/20/97 L2 Thermal Power (RTP) if the calibration of the excore channels to the incore address the requiretreerts open detectors is not current; this surveillance specifies no time limit to reduce of ITS 3.3.1 Actb C that power - in DOC L2, BGE apparently interprets it to be immediately.

are more restnctrve than However, because it is not explicit, specifying a time limit is considered to corresponding Notation be an a-iiitional requieme d. Corresponding ITS 3.3.1 Action C requires, (3) of CTS Table 4.3-1; within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, either calibrating the excore channels to the incore specifically discuss the 24-detectors (i.e., pertorming ITS SR 3.3.1.3), or limiting tne reactor power to hour Cornpiduvn Time and 90% RTP. If either of these actions are not met within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, ITS 3.3.1 the explicit requirement to Action G requires si'utting the plant down to Mode 3. An explicit time limit of either calibrate the excore 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and a shutdown requirement are more restnctive than the channels or reduce power.

requirement of CTS Endnote (3). Therefore, the addition of Actions C and G is a more restrictive change.

BGE Response:

DOC M.4 will be added, and DOC L2 will not be used to justify this change. Also, DOC 1.A.8 will not be used, and existing DOC A.7 will be used to justify this change.

7 L1 ITS SR 3.3.1.2 (heat balance) Note 1 allows delaying the surveillance until Pavise the :ubmittal to 5/20/97 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after power is > 15% RTP in agreement with CTS Table 4.3-1. m)ress this open Notations (2) and (4). DOC L1 discusses > 20% RTP rather than > 15%

_,wnststency.' If the ITS RTP.

uses > 20% RTP, justify it.

BGE Response:

DOC M.5 will be provided and DOC L1 will not be used, to justify this change and the inconsistencies will be addressed.

8 A1 CTS Table 4.3-1 requires a Channel Calibration daily and at each refueling Provide discussion and 5/20/97 LA.3 interval for Function 2.b, "DT Power - High. In addition, Notation (4) to the justification for this less open daily Channel Calibration requires daily adjustments of the "DT Power restnctive change that Calibrate" potentiometers when above 15% RTP. ITS Table 3.3.1-1 does appears to delete testing not specify a Funchon for DT. Power - High (but only Power Level - High).

of the Power Level - High, and consequently, appears to omit the CTS adjustments and calibrations.

DT Power Function See doc = Discussion of Change 3

JFD = Justfication for Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION LIMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 -

3.3.11 DOC

!JFD-CHANGE / DIFFERENCE.'

COMMENT TSTATUS3 This Esppaient less restnchve change has no ju=uin Gan.

Comment 21.d.

BGE Response:

The requirement to adlust both tne excore power range and the delta T power channels to match the calonmetnc results is contaned in the wordng of SR 3.3.1.2. The discussum that this is done usmg the potenbometers is contained in the Bases. DOC LA.3 will be revised to indmate the Ranma as the document to whch the detail is relocated.

9 A.9 l DOC A.9 mistakenly says that the trip setponts in CTS Table 2.2-1 will be Revise the - sutettal to 5/20/97-LA.4 listed in ITS Table 3.3.1-1. ' But DOC LA.4 clearly says they are moved to explicstly state-

'the open 1

tn,6peC~d plant procedures - controlled by the " plant change control procedures e-4.; rag the process," which has not been defined in the sutettal.

trip setpoents and,seen==

the regulatory bases of the

" plant change control process' BGE Response:

DOC A.9 will be revised to discuss the movement of allowable v%Jes to ITS 3.3.1. DOC LA.4 will not be used bemna all the trip setponts in i

Current Technical Spec.licabon (CTS) Table 2.2-1 are the same as the allowable values with one excephon, which is addressed by LA.7.

10 A.14 CTS Table 2.2-1, Funcbon 3,' Reactor Coolant Flow - Low, Table Notabon *,

Revise. the submittal to 5/20/97. '

references CTS 3.2.5, "DN8 Parameters," for the design reactor coolant addrera how reactor open flow. The referral to CTS 3.2.5 for the definsbon of design flow is deleted coolant desegn flow is from ITS Table 3.3.1-1, Functkm 3, Reactor Coolant Flow - Low because defined and controlled for the ITS does not reference other Specificabons. The jue TGi does not this RPS trip Funcbon.

state design flow is defined in the ITS and the controls over that defirubon, nor show that'defirubon is adequate for ITS Table 3.3.1-1 Funcbon 3 Reactor Coolant Flow-Low.

BGE Response:

DOC A.14 will be revised to provide addsbonal ju.GTni606 for the deletKri of this cross-reference, and the cross,.'

nce will be included in the Bases.

ooc = oscussion or change 4

JFD = Justsficahon for Deviation

ATTACHMENT (1) l RESPONSES TO' REQUEST FOR ADDITIONAL INFORMATION 1

-lMPROVED TECHNICAL SPECIFICATIONS SECTION '3.3 l J 3.3.11 DOC iJFDI CHANGE / DIFFERENCE; COMMENTJ

'STATUSi v

.j m

11

- LA.4 CTS Table 2.2-1 contams " Trip Setpont" and "Allowabie Values" columns Revise the submdtal to 5/20/97

[

Correspondmg ITS Table 3.3.1-1 contams only the " Allowable Values" exphcstly state the open column.

Speedic trip setpoirds are ' proposed to be moved to' plant procedures c(Este;inig the procedures The justdicabon for (.ci;.g the trip setponts from ITS 3.3.1 trip setponts and docuss does not Klentsfy the plant procedures. In adddson, the proposed control the regulatory bass of the

[

mechanism for the trip setponts, the " plant change control process," is not

" plant change control l

described.'

process "

i See comment 3.3.1-9.;

.j BGE Response-l DOC A.9 will be revised to discuss the movement of allowable values to ITS 3.3.1. - DOC LA.4 wiu not be used because all the trip setponts in CTS

-l Table 2.2-1 are the same as the allowable values with one excephon, which is addressed by LA.7.

i 12 LA.7 CTS Table 2.2-1 speedies the allowable value for the Thermal Margm/ Low Revise the ~ submdtal to 5/20/97 j

Pressure (TM/LP) RPS funcbon as not less than the larger of 1875 psia or clanfy if and when the open the limits provided in the Core Operabng Limds Report (COLR).

COLR will be rewmed to i

Curia.poriding Funcbon 9.a of ITS Table 3.3.1-1 omits the 1875 psia limit '

melude the 1875 psia limit

]

BGE Response:

This requirement is already in the Core Operating Limits Report (COLR), and all relocahons 'of informabon wiR be wirs:J prior to ITS l

implementation.

13

' M.3 STS 3.3.1 Condsbon F is for "Requred Achon and assocasted Complebon Revise the submdtal as 5/20/97 i

Time not met" 'ITS 3.3.1 Condibon G is for "Requred Achon and appropnale to reflect open associated Complebon Time not met except for Axial Power Dstnbubon -

wthdraval of changes High and Loss of Load Trip Funcbons". The STS devebon e.

'pting the and ddFerences based on I

Axial Power Distnbubon - High and Loss of Load Trip Fun. uns from conformeng to TSTF-80.

j l

Cundition G is based on.TSTF-80. TSTF-80 was ig;ted by the NRC on j

3/14/97.'

j i

E DOC = Drscussion or Change S

'[

JFD = Justdication for Deviation

't a

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS-BGE Response:

See response to RAI 3.3.1-18.

14 M.3 ITS 3.3.1 adds Condition F for" Required Action and associated Completion Revise the submittal as 5/20/97 Time not met for Axial Power Distribution - High and Loss of Lead Trip appropriate to reflect open Functions." The STS deviation adding this condition and Required Action, withdrawal of changes

" Reduce THERMAL POVER to < 15% RTP" within a completion time of 6 and differences based on hours is based on TSTF-80. TSTF-80 was rejected by the NRC on 3/14/97.

conforming to TSTF-60.

BGE Response:

J See response to RAI 3.3.1-18.

15 A.1 The Note to ITS SR 3.3.1.5 and ITS SR 3.3.1.8 retains the allowance of Revise the submittal to 5/20/97 CTS Table 4.3-1 Notation (5) to exclude neutron detectors from Channel justify the Note excluding open Calibration (CTS 4.3.1.1.1), (affectirg ITS 3.3.1 RPS Functions 1,2,8, and the loss of load function 9.a). This allowance is not contained in corresponding STS SR 3.3.1.8, the from a refueling-interval refueling interval Channel Calibration for these RPS Functions. These Channel Calibration in ITS exclusions are based on TSTF-81, which is pending. However, approval of SR 3.3.1.8, and explain this STS deviation is not contingent on NRC approval of TSTF-81 because it why ITS SR 3.3.1.8 is not appears consistent with the CTS.

specified for RPS Function 10 in ITS Table in addition, the Note to ITS SR 3.3.1.8 also excludes the loss of load 3.3.1-1.

function from Channel Calibration; this change to the CTS is not addressed.

Further, ITS Table 3.3.1-1 Function 10. " Loss of Load," does not list ITS SR 3.3.1.8 as a requirad SR.

BGE Response:

References to TSTF-81 will be removed and replaced with DOD-3 to justify the changes. The Loss of Load exclusion was removed from the 3.3.1.8 Note because the surveillance is not applicable. DOC-24 was revised to justify deleting the calibration requirement.

16 A.1 ITS Table 3.3.1-1 contains an applicable Modes column; STS Table 3.3.1-1 Revise the submittal with 5/20/97 DOC = Drscussion of Change 6

JFD = Justrrication for Deviation

!E

.I ATTACHMENT (1)

- RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 j

13.3.1 ~

DOC JFDL CHANGE / DIFFERENCE COMMENT 1 STATUS' does not have this colurnn. Inclusion of a Modes column is based on TSTF-a plant-specdc open i

M in i;cq

'for~

'this l

85. TSTF-85 was ic,.M by the NRC on 3/14/97.

deviabon from the STS.

l BGE Response:

1 i

References to TSTF-85 have been replaced'with a plant specific DOD-38.

l f

17 5

ITS 3.3.1 does not contaen figures corresponding to STS Figures 3.3.1-1, Revise the sutettal as 5/20f97

[

STS 3.3.1-2, and 3.3.1-3.

In place of.'.; wing these figures for the.

appropnale to reflect open allowable values for Funcbons 8 and 9a of STS Table 3.3.3-1,, the ITS withdrawal of changes i

references the COLR. These STS'deviabons are based on TSTF-80 and and differences based on

+

the allowable values being controlled by the COLR. TSTF-80 was i;.,.M cun'oriv&q to TSTF-80 j

3 by the, NRC on 3/14/97. However, CTS Table 2.2-1 spwC.c; the allowable not associated. with j

values for Funcbons 8 and 9.a by.'.;wi c;rg the COLR; therefore, the ITS cunivisi#g to the CTS j}

is consstent with the CTS. Approval of this STS deviabon is not conbngent requirements.

on NF.C approval of TSTF-80 because the ITS is consstent with the CTS.

f I

BGE Response:

TSTF-80 is not related to movmg these allowable values to the COLR, and plant spadTK,juniicd;vn is provided by DOD-5.

18 A.16 ITS Table 3.3.3-1 Note (e) for RPS Funcbons 8 and 10 (axial power Revise the submittal to (1) 5f20/97 l

distnbubon - high, and loss of load), stales these trips are only applicable in justify this plant-specdc open

. :l Mode 1 when 215% RTP; DOC A.16 claims CTS (Table 2.2-1 Note (3) (?))

deviabon from the. STS allow these RPS funcbons to be bypassed when Thermal Power is less than and r*v= hon of the CTS,

_j 15% RTP. Thus !TS Note.(e) and the CTS Apphcatzhty for these RPS and (2) reflect withdrawal j

funcbons are equivalent. However, the spadric CTS reference wni.;n;rg of changes and deviabons this bypass /apphcabshty allowance is not clearty indicated on the CTS based on wiuviii, to j

markup and does not appear to be spec.J in the CTS for these two RPS TSTF-80.

j funcbons

'J i

in addibon, the STS does not contam this bynass allowance for the axial j

power detnbubon - high and loss of load RPS funct;uns which is the subject DOC = Descussen of Change 7

f JFD = Jushncahon for Deviaten

ATTACHMENT (1)

RESPONSES TO ' REQUEST FOR ADDITIONAL INFORMATION j

m

' IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 43.3.17 lDOCi JFD -

CHANGE / DIFFERENCE COMMENT JSTATUS!

of TSTF-30. TSTF-80 was repected on 3/14/97.

BGE Response:

Current Technical Specifn.c.t;0n Table 2.2-1, footnote 3, and CTS Table 3.3-1, footnote c, indicate the axial power distnbubon-tugh funcbon may be bypassed below.15% RTP and ' utoiniA.ily unbypassed when >= 15% RTP. Table 3.3-1, footnote c, also apphes to the loss of load funcbon.

a These footnotes were retamed in ITS 3.3.1 as footnote d which is in the funcbon column of the its Table. The ITS sutettal proposed to add footnote e to the. win,ib;iity column for these two funcbons to indicate the funcbon is only requred Operable in Mode 1 when >=15% RTP. This change is consistent with the CTS smce if the function is bypassed, it is not Operable and not requred to funcbon. Cunent Techrncal Speedicahon Table 3.3-1 will be revised to annotate this change, and DOC A.16 is revised to provide addebonalju.i;Tn t.cn. DOC M.3 will be moddied also.

References to TSTF-80 will be ronw;d and replaced with plant specdicju.iiin,s.tism, JFD 33.

19-lA3 CTS Table 4.3-1 Notabons (2) and (4) specific.;;y requae adpusbng the Revise the sutettal to S/20/97 Nuclear Power Cahbrate Potenbometers and the DT Power Cahbrate explicitly

' state.

the open Potenbometers, respechvely. These detads are moved to plant procedures procedures contarung the DOC LA.3 does not idenbfy the plant procedures that mamtart these these procedural details detads. In addebon, the proposed control mecharusm for these detads the and r6mm the regulatory

" plant change control process," is not desenbed.

bases of the " plant change control process."

See comments 3.3.1-9 and 3.3.1-11.

BGE Response:

See response to RAI 3.3.1-8. Comments 3.3.1-9 and 3.3.1-11 do not appear related to this comment.

20 1.A.6 CTS Table 3.3-1 Achon 2.b requres placmg all funcbonal units receivmg a Revise the' sutettal to 5/20/97 parameter input from the moperable channel in the same tnpped or desenbe : the regulatory open bypassed condsbon as the inoperable channel withm one hour. ITS 3.3.1 basis of the plant change does not requre this achon This requrement is moved to.the' Safety control process,.and Funchon Determinabon Program (SFDP) of ITS 5.5.15. DOC LA6 states identdy l the plant that changes to the SFDP,are in accordance with the plant change control promdures.that mantam process The plant change control process is not desenbed.

control over. the. plant Doc = Discussion of change 8^

JFD = Justneshon for DevW. ion

I ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 bOMMENT STATUS

. 3.3.1 i

. DOC--

?JFD~

1 CHANGE / DIFFERENCE "

change -,** -

and cc.evis over changes to the SFDP.

BGE Response:

DOC A.18 will be provided to retain the requirement in a different brmat. DOC LA.6 will not be used. See response to RAI 3.3.1-4.

21a ITS 3.3.1 Table 3.3.1-1, Funcbon 1, Power Level-High Revise the submdtal with 5/20/97 ITS SR 3.3.1.7 Channel Funcbonal Test (CFT) - automatic bypass an expli= tke.

open removal feature CTS 3.3.1.1 Table 3.3-1, Funcbonal Unit 2, Power Level-High CTS 4.3.1.1.2 test of total bypass funchon dunng Channel Cahbrabon CTS 3.3.1.1. Table 4.3-1, Funcbonai Unit 2.a Nuclear Power Level-High CTS 4.3.1.1.2 appears to apply to the power level - high funcbonal unit, but ccsiesperidirig ITS SR 3.3.1.7 is not specified for this funchon on ITS Table 3.3.1-1. The submittal contaens no egli=W of this.

BGE Response:

Current Technical SpecJ,catier 4.3.1.1.2 is apphcable to those criorireis affected by bypass operabons, as stated in the surveillance. Power level-high trip funcbon does not have an operahng bypass. ~ The delta T component of the power level-high may be bypassed as part of the Thermal Margin / Low Pressure (TM/LP) funcbon improved Teclariscr.: SpecKn t;0ri SR 3.3.1.7 is aophcable to the TM/LP funchon 21b CTS Table 4.3-1 specifies that the survesilances for the DT power level -

Revise the sutettal with 5f20/97 -

high funchonal unit are required to be met in Mode 1 only. ITS Table 3.3.1-an expli-tics.-

open 1 specifies that the survesitance (and 'operabikty) requrements for this function apply in Mode 2 also. The submdtal contains no explanabon of this.

doc = Descussion of Change 9

JFD = Justificshon for Deviatien v-

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.1 -

= DOC JFD CHANGE / DIFFERENCE

' COMMENT.

STATUS BGE Response:

DOC M 6 will be provided to discuss this change.

21c CTS 4.3.1.1.2, test of total bypass function during Channel Calibration, is Revise the submittal with 5/20/97 retained as ITS SR 3.3.1.7 Channel Functional Test (CFT) of the automatic an explanation.

open bypass removal feature. The submittal contains nc explanation of the equivalence of these two test requirements.

BGE Response:

CTS 4.3.1.1.2 is retained as both ITS SR 3.3.1.7, Channel Functional Test, and ITS SR 3.3.1.8, Channel Calibration. The Channel Funcbonal Test ensures the operability of the logic, and the Channel Calibration confirms setpoints, as stated in CTS 4.3.1.1.2. These tests are defined in Secbon 1.0. -

21d ITS 3.3.1, Table 3.3.1-1, Function 1, Power Level-High Revise the submittal with 5/20/97 CTS 3.3.1.1, Table 4.3-1, Functional Unit 2.b, DT Power Level-High an explanation.

open The DT power level - high function is not discussed in the Bases for ITS 3.3.1.

4 BGE Response:

l L

The delta T power level provides an input to O power. This is described in the NUREG Bases markup. Delta T power is also described as primary calorimetric power in the Bases. The Pressurizer Pressure-High, Containmen; Pressure-High, and Steam Generator Water Level-Low functions do not have bypass notes, as shown in CTS Table 3.3-1.

l 22 ITS 3.3.1 Table 3.3.1-1, Revise the submittal with 5/20/97 Function 4, Pressurizer Pressure - High an explanation.

(Note:

open 8 unction 5, Containment Pressure - High This comment is repeated Function 7 Steam Generator Level-Low for the power level - high Function 9.b, Asymmetric Steam GeneratorTransient funct onal unit in comment ITS SR 3.3.1.7 Channel Functional Test (CFT) - automatic bypass removal 28.a.)

feature CTS 3.3.1.1, Table 3.3-1, Doc = Discussion of change 10 JFD = Just 6catson for Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST-FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 l

J 3.3.1 :

DOC JFD CHANGE /DIFFERENCEE COMMENT STATUS Funchonal Unit 4, Pressunzer Pressure - High Furdiere Unit 5, Contanment Pressure - High Furdiere Unit 7, Steam Generator Water Level-Low Funcbonal Unit 9.b. Steam Generator Pressure Deerence-High CTS 4.3.1.1.2 test of total bypass funcbon dunng Channel Calibrabon CTS 4.3.1.1.2 appears to apply to the pressunzer pressure - high, viiui;imiont pressure - high, steam generator water level - low, and steam generator pressure chfference - high funcbonal units, but correspondag ITS SR 3.3.1.7 is not speedied for these funcbons on ITS Table 3.3.1-1. The submittal contams no explanabon of this.

BGE Response:

The Steam Generator Pressure Deerence-High Funcbon (Asymmetric Steam Generator Transsent) is equipped with an operabng bypass and ITS 3.3.1.7 has been added to that funcbon.

3.3.2 :

DOC

?JFD CHANGE / DIFFERENCE COMMENT-

-STATUS 1

M.1 With one inoperable channel in trip, CTS Table 3.3-1 Achon Revise the submdtal to discuss and jushfy 5/28/97 2.c allows bypassmg an addebonal channel for teshng and the relaxabons associated with ITS 3.3.2 open mantenance for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Correspondag ITS 3.3.2 Achon B.

Achon B allows placmg one inoperable channel in trip and a second in bypass without restnchon on the second channel, See comment 3.3.1-05 that is, the second channel can be inoperable for tesbng, mantenance, or - for any other reason.

This is less restnchve because the ITS allows the second RPS channel to be inoperable for reasons other than permited by CTS Table 3.3-1 Achon 2.c. In addsbon, in the event a second Doc = oscussion or change 11 JFD = Justication for Devisten I

L

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.2 DOC JFD

- CHANGE / DIFFERENCE COMMENT.

STATUS channel is inoperable for other than routine surveillance testing, the CTS specify no action requrements; thus a plant shutdown would be required by CTS 3.0.3. ITS 3.3.1 Action B permits operation for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before a shutdown (per ITS 3.3.2 Action E) is required.

The submittal does not address these relaxations.

BGE Response:

DOC L3 will be added to justify this change.

2 LA.1 CTS 4.3.1.1.2 requires demonstrating the bypass logic, Revise the submittal to specifically identify 5/28/97 including the automatic bypass removal logic Operable the plant procedures that contain this open prior to each reactor startup, unless performed during the requirement and describe how changes to it preceding 92 days. ITS 3.3.2 moves this requirement to will be controlled.

unidentified plant procedures. The justification does not identify the plant procedure that maintains this requirement See comment 3.3.1-01 nor the specific controls that maintain the requirement in plant procedures.

BGE Response:

DOC L2 will be provided to justify the change, and LA1 will not be used.

3 n.3 CTS Table 3.3-1 Action 2.b. requires, within one hour, Revise the submittal to fu!!y explain how 5/28/97 placing all functional units receiving a carameter iriput from Action 2.b of CTS Table 3.3-1 will be open the inoperable channel in the same tripped or bypassed accomplished under the ITS. In addtion, condition as the inoperable trip channei. DOC LA6 states this is an L-type, not an LA-type change.

this requirement is moved to the Safety Function Determination Program (SFDP) of ITS 5.5.15. Although the See comrrent 3.3.1-04 SFDP is activated under ITS LCO 3.0.6 and ITS LCO 3.0.6 would apply when ITS LCO 3.3.2 is not met, it is not certain that the SFDP would require taking the same action as Action 2.b of CTS Table 3.3-1 or an equivalent action DOC = oiscussion of Change 12 JFD = J;sti6 cation for Deviation

i ATTACHMENTfil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION lMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.2 DOC JFD CHANGE / DIFFERENCE COMMENT

~

STATUS BGE Response:

This action is not applicable in this Limiting Condition for Operation (LCO), and has been annotated to address the issue in ITS 3.3.1 and LA.3 will not be used.

4 CTS Table 2.2-1 specifies an A!!owable Value for the power Revise the submittal with a suitable markup 5/28/97 rate cf change - high channels of > 2.6 decades per minute.

of CTS Table 2.2-1 Functions: Unit 11 in the open A CTS markup of this requirement is not included in the CTS markup for ITS 3.3.2, and also with a submittal for iTS 3.3.2. In addition, ITS 3.3.2 differs from suitable DOC. Acceptance of specifying the STS 3.3.2 by stating the a!Iowable value in ITS SR 3.3.2.4, a!!awable value in ITS SR 3.3.2.4 is not in LCO 3.3.2 as in the STS. This difference is based on contingent on NRC approval of TSTF-82.

TSTF-82, which has not yet been approved ty the NRC.

BGE Response:

This was corrected in a previous Supplemental Amendment Request which incorporated TSTF-82 Revision 1, approved by the Nue:aar Regulatory Commission (NRC).

5 A.1 CTS 4.3.1.1.2, test of total bypass function during Channel Revise the r bmittal with an explanation.

5/28/97 Calibration, is retained as ITS SR 3.3.2.3 Channel open Functional Test (CFT) of the automatic bypass removal See comment 3.3.1-21c feature for the power rate of change - high function The submittai contains no explanation of the equivalence of these two test requirements.

In addition STS LCO 3.3.2 does not specifically include Acceptance of this difference contingent on automatic bypass removal feature for the power rate of NRC approval of CEOG-91.

change - high channels, but ITS LCO 3.3.2 does. This difference is baseo on TSTF-180 (CEOG-91) which has not yet been approved by the NRC.

BGE Response See the response to RAI 3.3.1-21.c for the response to the first comment. The second comment will be justifieci by DOD-34.

DOC = Discussion of Change 13 JFD = Justr!icaten for Deviaten

~ -. -

ATTACHMENT (1) i

- RESPONSES.TO REQUEST FOR ADDITIONAL INFORMATION

. IMPROVED TECHNICAL. SPECIFICATIONS SECTION 3.3 t

~ 3.3.3 L DOC JJFD;

' CHANGE /DIFFERENCEi COMMENT A STATUS' 4

1 A.3

. CTS 4.3.1.1.1 requires a Channel Functional Test (CFT) for Clarify that this double testog is intended in. 6/2/97 l

Matrix Logic. Trip Path 8 ogic, and RTCBs as shown in CTS the ITE.-

open Table 4.3-1. TS 3.3.3 moves the CFT requerements to iTS

~

SR 3.3.3.1, RTCB channels every 31 days, and ' ITS l

3.3.3.2, RPS Logic channels (Functions 12 and 13 of CTS

[

Table.4.3-1) and RTCB channels every 92 days. This

}

requires the CFT for the RTCBs'at two frequencies; ITS SR 3.3.3.1, every 31 days, and ITS SR 3.3.3.2, every 92 days.

I

~

BGE P.esponse:

Testing of the reactor trip circuit breaker (RTCB) cic Ew:45 will be removed from ITS SR 3.3.3.2 and justdied by DOD 35.

~

Address this change to the Manual Trip 6/2/97.

i 2

M.1 The CTS 3.3.1.1 Applicability for the Manual Trip is MODES 1 and 2, and wit 5 any RTCBs closed and the CEA APPLGBILITY ' and provide ji Gin Gon open

. i system cap.No of CEA withdrawal. ITS 3.3.3 changes the forit as an adminishative change.

Applicability for these fuoctions to MODES 1 and.2, and

' MODES 3,4, and 5, with any RTCBs cinsed and any CEA capable of being withdrawn. Addog MODES 3,4, and 5 to the APPLICABILITY "with any RTCBs closed and the CEA system capable of CEA withdrawal" is an. administrative change.

-t DGE Response:

DOC A.9 will be rewntten to disx ' these cigiges, and DOCS M.1 and M.3 will not be used.

E 3

M.6 -

CTS 4.3.1.1.1 does not require a CHANNEL FUNCTIONAL Provide adddsonal thanm and S/2/97

{

TEST (CFT) for the Manual Reactor Trip Funchon in any justdicahon for this chany, desenbeg how open specdic MODE. "The CFT is, however, required by CTS d is more restnchve, or reclassdymg as l

Table 4.3-1 within 7 days prior to startup. ITS SR 3.3.3.3 administrabwe.

l requires the test once withen 7 days prior to startup for i

uoc = Dmeussion or change 14 JFD = Justrncaten for Denaten i

m3 k

9 6.

e eg=es______

.m..

.m..

l ATTACHMENTfil RESPONSES YO REQUEST. FOR ADDITIONAL INFORIAATION IMPROVED 7ECHNICAL SPECIFICATIONS SECTION 3.3

3.3.31 DOC

'JFD :

L CHANGE / DIFFERENCE.

COMMENT

STATUS Modes 1 and 2, and Modes 3,4, and 6 with any RTCBs closed and any CF.As cap. bio of being withdrawn. The surveillance in both the CTS and the ITS is requwed for all operating MODES, within 7 days prior to startup (before exiting MODE _6). The change and justification support this change as an administrative change.

BGE Response:

DOC A.10 will be provided to discuss these chan as, and DOC M.6 will not be used.

v 4

The STS 3.3.3 NOTE in Conditions B and C are adopted as Acceptance of this change is contingent on 6/2/97 notes in Required Achons B.1 and C.1, respecitsdi, in ITS NRC approval of TSTF-181 (CEOG-93).

open 3.3.3. This deviation from the STS is based on TSTF-181 (CEOG-93), which has not yet been approved by the NRC.

@GE Response:

Plant specific justification DOD-31 and removal of sof.. onces to TSTF-181 was provided in a previous Supplemental Amendment Request.

5-The wording 'of STS 3.3.3 Required Achon C.1 to "Open an AO +;. trice of this change is eni.i >gont on 6/2/97 RTCBs" is not adopted; rather ITS 3.3.3 Required Action NRC approval ef TSlF-170 (CEOG-73).

open C.1 states "Open the affected RTCBs." This deviahon from the STS is based on TSTF-170 (CEOG-73), which has not yet been approved by the NRC.

BCE Response:

References to TSTF-170 will be removed and the improved Standard Techn; cal Specific. tion (ISTS) will be adopted and jushfied 6

ITS 3.3.3 Conditon D lists two inoperable manual trip Accepimice of this change is Mwnt on 6/2/97 channels in addition to two inoperable channels of RTCBs NRC approval of TSTF-182 (CEOG-94).

open or initiation logic affecting the same trip leg as specified in STS 3.3.3 Condshon D.

This deviahon from the STS is based on TSTF-182 (CEOG-94), which has not yet been DOC = Descussion of Change 15-Jro.katmcation for Devmeson

.~

~

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 T 3.3.3 i DOC

JFD-CHANGE / DIFFERENCE-

COMMENT ~

STATUS f

approved by the NRC.

BGE Response:

References to TSTF-182 will be removed and the ISTS will be adopted and jus'.ified.

7 The wording of STS 3.3.3 Condition E, "One or more Acceptance of this change is contingent on 6/2/97 Functions with," is omitted frem corresponding ITS 3.3.3 NRC approval of CEOG-95.

open Condition E.

This deviation from the STS is based on i

TSTF-183 (CEOG-95), which has not yet been approved by the NRC.

BGE Response:

References to TSTF-183 will be removed, and DOD-36 provided to justify the plant specific change.

8 ITS SR 3.3.3.1, a 31-day CHANNEL FUNCTIONAL TEST Acceptance of this change is contingent on 6/2/97 i

on each RTCB channel, is not specified in STS 3.3.3. This NRC approval of TSTF-79.

open i

deviation from the STS is based on TSTF-79, which was

{

modified, but not yet approved, by the NRC on 3/17/97.

+

BGE Response:

{

References to TSTF-79 will be removed and replaced with plant specific justificaton DOD-35.

i

3.3.4 DOC

.JFD

' CHANGE / DIFFERENCE COMMENT STATUS t

1 1.A.6 CTS 4.3.2.1.2 requwes dmTicn=uduiig the total bypass logic Provide addebonal discusson

.and 6/2/97 l

^

during the at-power Channel Funcbonal Test. ITS 3.3.4 justificafo;4 identifying the plant procedures open moves this bypass teshng requirernent to urudentified plaat that cordein the requerement to demonstrate l

4 procedures. The jushficabon does not identify the plant the bypass logic dunng the at-power

'l procedure that maintains this requirement nor the specific Channel Funchonal Test, and ccaruvis over DOC = Discussion of Change 16 '

JFD = Justincation for Deviabon e

ATTACHMEN1 (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION 1

IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.4 :

DOC lJFD-

? CHANGE / DIFFERENCE-COMMENT STATUS controls that maintain the requirement in plant procedures.

changes to that requirement.

BGE Response:

DOC L3 will be provded to justify deletion of the requirements.. DOC LA.6 will not be used.

2 LA.5 CTS Table 3.3-4 cont & ins

• Trip Setpoint* and " Allowable Provde additonal h=ian and 6/3/97 Values

• columns. ITS Table 3.3.4-1 contains only the justfeh, identifying the pl ant procedures open

" Allowable Values

• column.

Specific trip setpoints are that contain the trip setpoents, and whuis maintained in plant procedures.

The ju=Gra6on for over changes to the trip setpoents in those deleting the " Trip Setpoint* column from ITS Table 3.3.4-1 plant procedures.

does not identify the plant procedures that maintain the trip setpoints nor the specific controls _ that maintain the requirement in plant procedures.

BGE Response:

DOC A.12 will be modified to describe the fact that the trip setpoints in Table 3.3-4 are the same as the allowable values. LA.5 will not be used.

3 LA.3 CTS Table 3.3-3 Action 7.b requires, withen one hour, Revise the submittal to fully explain how 6/2/97 placing all functional units recerving a parameter input from Achon 7.b of CTS Table 3.3-3 will be open the inoperable channel in the same inpped or bypassed accomplished under the ITS. In addebon, condition as the inoperable trip channel. DOC LA.3 states this is an L-type, not an LA-type change.

this requirement is moved to the Safety Function Determination Program (SFDP) of ITS 5.5.15. Although the See comment 3.3.1-04 SFDP is activated under ITS LCO 3.0.6 and ITS LCO 3.0.6 would apply when ITS LCO 3.3.4 is not met, it is not certain See comment 3.3.4-12 that the SFDP would require taking the same achon as Action 7.b of CTS Table 3.3-3 or an equivalent action.

BGE Response:

DOC A.13 will be provided to explain that there is no reduchon in techrucal requirements. LA.3 will not be used.

ooc - o.scussion of change 17 JFD = Just$ cation for Deviation L__

11' ]

ATTACHMENT (1) l 1

RESPONSES TO REQUEST FOR ADDITIONAL' INFORMATION I

IMPROVED TECHNICAL ~ SPECIFICATIONS SECTION'3.3 c 3.3.4 :

DOCi 1JFD; CHANGE /DlFFERENCE COMMENT STATUS.

e 41 M.3 The justificaten for this change states that CTS Table 3.3.3 Provide &scussson and justificabon for this 6/2/97 -

Achon 7.c does not specify a time for placog the addebonal less restnchve change that provides a 1 open noperable channel in bypass and ITS 3.3.4, Achon B, hour extensson of the AOT for teshng and requres placmg one channel in trip and one channel in mantenar'ce.

bypass in one hour.1 The jushficabon does not address the reason for placmg the' addebonal inoperable channel in See comment 3.3.1-05 bypass - the reason bemg tesbng and mantenance, with a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limit-(both CTS and ITS) from the begenmg of testmg Therefore, the one hour limit of ITS 3.3.1 Achon B, to place the channel under test in bypass is a less restnchve change providmg a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> extenson of the allowed, outage time (AOT) for testog and mantenance that is notjushfied.

BGE Response:

DOC L4 will be added to address the change.

5-L1 CTS Table 3.3-3, Achon 11, Contamment Spray Actuabon Provide jushficabon for this less restnchve 6/2/97 System (CSAS), Contamment Pressure - High, when one change removog the requrement to.venfy open or two sensor (trip) channels are inoperable, allows the remanng Containment Pressure - High contmued operation with one moperable channel provided channels OPERABLE withm one hour.

the inoperable channel is bypassed and the other channels are demonstrated OPERABLE withen one hour. ITS 3.3.4, Action A, allows one hour to place the affected sensor (trip) mcdule in bypass or trip. There is no ITS requrement to demonstrate the remammg sensor (trip) channels OPERABLE vnthm one hour. This less restnchve change from the CTS is notjushfied BGE Response:

The CTS does not contain a requrement to aw*mily demonstrate that the remanng channels are Operable The CTS is an admnstrabwe confirmation that no other channels are Operable The CTS is not inteipJ.J to requre any teshng for this achon. - The ITS Achons are predicated ooc-o cussenorchange 18 JFD = Justdicahon for Devneten

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIF CATIONS SECTION 3.3 t

3.3.45

. DOC JFD CHANGE / DIFFERENCE COMMENT' iTATUS.

on the number of channels inoperable, so this is only a change in format and presentation.

6 L1 CTS Table 3.3-3, Action 11, Containment Spray Actuation Provide justification for this more restnctrve 6/2/97 System (CSAS), Containment Pressure - High, when one change requiring bypassing one. sensor open or two channels are inoperable, allows continued opera *:on (trip) module of the Containment Pressure -

with one inoperable channel provided the inoperable High instrumenMon and bypassing the channel is bypassed. One additional channel may be other rather that the CTS requirement to i

bypassed for surveillance testing for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS bypass both.

I 3.3.4, Action B, allows one Sour to place one affected sensor (trip) module in bypass and the other affected sensor (t;;p) module in trip. This more restnctive change to l

the ITS requires bypassing one sensor (trip) module and bypassing the other rather that the CTS requirement to e

bypass both. This more restrictive change is notjustified.

f BGE Response:

f r

This change is considered less restnctive because the CTS requires both Mannels to be in bypass and only for two hours. Tha ITS will allow one l

channel to be in bypass and one in trip for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. DOCS L1 and M.4 have been revised to clanfy the overall change to the Cord.inrent j

Spray Actuation System (CSAS) actions.

i 7

L2 ITS Table 3.3.4-1 adds Footnote c to the CTS Table 3.3-3 Provide additional discussion for this less 6/2/97 footnotes.

This footnote allows the Steam Generator restnctive change, addressirg the ir:clusion open isolation Signal (SGIS) function and the Steam Generator of the Containment Pressure - High function Pressure - Low signal and the Containment Pressure - High in the footnote.

signal to be inoperr when all associated valves isolated by the SGIS funcbon are closed and deactivated. DOC L2 does not discuss the Containment Pressure - High signal nor why it is included in the footnote. Further, Footnote c is not applied in ITS Table 3.3-3 for any funcbon associated with Containment Pressure - High.

doc = Drscussion of Change -

19 JFD = Justircation for Deviation I

i

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.4.

DOC

'JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

The annotations of footnotes in the CTS markup will be revised to be consistent with the ISTS markups. Also, the reference to the containment pressure - high function is in error and will be removed.

8 A.1 CTS 4.3.2.1.2 requires demonstrating the logic for the Provide justification for this less restrictive 6/2/97 LA6 automatic block removal function Operable during the at-change extending the CFT Frequency for open power Channel Functional Tests of channels affected by the logic for the automatic block removal features for the two functions listed from blocks. These CFTs are required quarterly by CTS Table 4.3-2 for Functions -

3 months to 24 months.

1.c (Pressurizer Pressure-Low) and 4.b (Steam Generator Pressure - Low).

ITS Table 3.3.4-1, for Functions -

1.b (Pressurizer Pressure - Low) and l

4.a (Steam Generator Pressure - Low),

requires a CFT on each automatic block removal feature (total bypass function)) at a 24-month Frequency (ITS SR 3.3.4.3) rather than quarterly. This less restrictive change in the Frequency for testing the logic for the bypasses is not justified.

BGE Response:

The CTS total bypass function channel functional test is required every 24 months, and this requirement is retsined in the ITS for automatic bypass removal. The quarterly tests are for the bypasses, which are removed from the ITS (see response ' RAI 3.3.4-1).

9 STS 3.3.4 Actions Note allows separate Condition entry for Acceptance of this STS deviation is based 6/2/97 each "ESFAS trip or bypass removal Function."

on NRC approval of TSTF-178 (CEOG-89)-

open Corresponding ITS 3.3.4 Actions Note a!!ows separate Condition entry for each "ESFAS Function." This difference in wording from the STS is based on TSTF-178 (CEOG-89), which has not yet been approved by the NRC.

DOC = Discussion of Change 20 JFD = Justrroaton for Deviaten

_ _ ~._.. _.. _ _.. _. _.. _ _

_~

ATTACHRIENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRRATION j

--IISPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 '

[

/3.3.41 DOC:

-JFD CHANGE / DIFFERENCE'!

COMMENT

! STATUS'

-(

2 i

BGE Response:

References to CEOG-89 will be iwuw;;d and plant specdicjeJA win be prowded.

[

3 10 26-In the event of one or more Funcbons with the automabc Revee the submdtal to adopt the STS achon 6/2/97 block removal feature.of one sensor block inoperable, ITS requrements.

open 3.3.4 Action C.E does not require restoring the bypass

[

removai channel and aNected trip units to Operable status withm 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or placmg tho afleded unit in trip withm 48 "l

hours as requred by STS 3.3.4 Requred Act;on D.2.2.1 or f

Requred Achon D.2.2.2.

f JFD-26's. Justificabon - for not adophng these STS j

requrements appears to be consstency with ITS 3.3.1

.l Requred Achons A.2.1 and A2.2, which allows withm 48 i

hours either restonng the a5ected betable trip unit and associated measurement channel to Operable status or I

placing the affected unit in trip, which places the unit in a one-out-of-three coencadence logic.

Thus, mdefinde operabon is allowed once the funcbon is in a one-out-of-three concdence logic.

j Smce the STS acbon requrements are logscaNy the same i

as the achon reqorements'of ITS 3.3.1, they should be

{

adopted JFD-26 does not explam how ITS 3.3.4 Requred Achons C.1 and C2 result in placmg the unit in a one-otd-of-three comcdence logic. Therefore, the jt ;Tn t;cii for t

this STS deviabon is inadequate.

)

BGE Response:

DOD 26 will be revised to prowde addtonaljt iiin.t;0n. ' The design of the EnGrs.od Safety Feature Actuabon Segnal (ESFAS) cabnets at Calvert

I Cliffs is from a vendor d:Nerent from that used to model the NUREG-1432 desenphon, requong the descnpbon to be dSerent from the NUREG.

[

However, the proposed achons are the same as those in the ISTS.-

.1 i

i DOC = Docussen cf Change 21 JFD = Just6caten for Devoten

~

ATTACHARENT (1)

RESPONSES TO REQUEST.FOR ADDITIONAL INFORREATION

. IIIPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

3.3.41

. DOC-

-JFD CHANGE / DIFFERENCE COMMENT STATUS

'11 LA.1.

Portons of CTS 3.3.2.1, SIAS Endnote @, which descusses Pronde addebonal discussion

.and 6/2/97 -

when to place the high pressure safety nochon pumps in Jua.rA ksentifyng the piant procedures open pulkto-lock, are moved to unusentified plant procedures.

that contan the requwement for placmg the The justificahon does not ksenbfy the plant procedure that high pressure safety gechon pumps in pun-mantans this requwement nor the specsfic controls that to-lock, and controls over changes to tNut mantam the requrement in plant procedures requrement.

BGE Response:

These requrements are duplicabwe of requrements in ' TS 3.5.3. DOC I.A.1 will not be used, ams DOC A.14 wiH be provided to jestify delebng C

these requirements basec on bemg duphcated elsewhere 12 LA.3 CTS Table 3.3-3 Achon 7.b, requres plaang all Revise the submital to desenbe the 6/2/97 l

funcbonal units recerving a parameter input from the regulatory basis for the plant change control open noperable channel in the same inpped 'or bypassed process and how changes to the SFDP cerxhbon as the moperable trip channel withm one hour.

unplementog procedures will be approved.

ITS 3.3.4 does not requwe this achon. This requrement is moved to the Safety Funcbon Determmabon Freyi-6 (SFDP) of ITS 5.5.15.

DOC LA.3 states that changes to tne SFDP are in acceidis6c with the plant change control process The plant change control process is not idenblied.

BGE Response:

See response to RAI 3.3.4-3.

13 ITS Table 3.3.4-1 Funcbon 1.b SIAS - Pressunzer Confirm that the ITS is correct and coned 6/2/97 Pressure - Low '

the CTS markup open CTS Table 3.3-3, Functuxd Unit 1.c, SIAS - Pressunzer Pressure-Low

. CTS ) markup indicates CTS Table 3.3-3 Notabon (a) corresponds to ITS Table 3.3.4-1 Note (b), but the ITS l

ooc - o,.co on or cw 22 JFD = Justscation for Devisten

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.4 -

DOC JFD

- CHANGE / DIFFERENCE COMMENT STATUS clearly indicate it corresponds to ITS Table 3.3.4-1 Note (a).

l BGE Response:

See response to RAI 3.3.4-7 j

14 A.8 ITS 3.3.4. Table 3.3.4-1, Function 2.a. CSAS -

Confirm that the ITS is correct, and correct 6/2/97 Containment Pressure - High the CTS markup and COC A.8.

open Note (b) to ITS Table 3.3.4-1 CTS Table 3.3-3, Functional Unit 2.b, CSAS -

Containment Pressure-High i

DOC A.8 and the CTS Table 3.3-3 markup ind'cate that Note (c) of ITS Table 3.3.4-1 is being added, but the ITS designates this note as Note (b) to ITS Table 3.3.4-1.

BGE Response:

See response to RAI 3.3.4-7.

15 L2 ITS Table 3.3.4-1 Note (c)

Why does the note also include the 6/2/97 STS Table 3.3.4-1 Note (d) containment pressure - high funcbon? (Note open j

that the ST3 includes it too.)

ITS Note (c) is a new note that relaxes the CTS operability requirements on the steam generator isolation signal function (steam generator pressure - low) when all valves closed by SGIS are closed a.id deactivated.

BGE Response:

See response to RAI 3.3.4-7.

16 CTS Table 3.3-3 Markup (page 3 cf 16)

Revise the submittal with a corrected 6/2/97 markup.

open Action 7 is marked as being replaced by ITS ACTIONS B Doc = Discussion of Change 23 JFD = Justifcation for Deviaten

...i.A1

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

' 3.3.4 ~

DOC

'cJFD2 CHANGE / DIFFERENCE COhWENT

'STATUSl and C for Funchonal Units 4.B Steam Generator Pressure -

Low, 5.B Refuehng Water Tank - Low, and 9. Auxiliary Feedwater Actuabon System. The markup should indicate ITS ACTIONS A and B.

Verify that this'is correct and correct the markup.

BGE Response:

~

Current Technical Specific t;0n Markups will be corrected.

17-ITS 3.3.4 ACTION B Note The submsttal contains no justdicahon for 6/2/97 ITS Table 3.3.4-1 Funcbon 9. AFAS adding the LCO 3.0.4 excephon to the AFAS open CTS Table 3.3-3 Achon 7 funcbons Revise the sutmttal with this CTS Table 3.3-3 Notabon

• jue; Tic.t;0n.

CTS Action 7 apphes to the AFAS funcbonal units but CTS Notation * (LCO 3.0.4 does not apply) does not apply to the AFAS fur #=s.. ITS 3.3.4 ACTION B Note, corresponding to CTS Notation *, app %s to the AFAS funcbons BGE Response:

DOC LS will be provided to jushfy this change.

3.3.5 DOC

?JFD CHANGE / DIFFERENCE:

COMMENTE STATUS 1

A.8 CTS Table 3.3-3 Achon 6 requres restonng an inoperable Provide ju4 sin t;06 for this less restncbve 6/3/97 ESFAS Actuabon Logic channel.to OPERABLE status change and discussson jushfying the open withm 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or being in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in shutdown to MODE 4 rather than MODE 5 MODE 5 withen 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> ITS 3.3.5 Achons, when one for ITS 3.3.5 Achons B and E.

ch nnel in one or more funcbons is inoperable, allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the inoperable ESFAS Actuabon Logic ooc = oscunion or cheng.

24 JFD = JustrRespon for oevotion

_=

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.5' I DOC JFD CHANGE / DIFFERENCE COMMENT STATUS m

e.

cinnnel to OPERABLE status. If not restored vrthin 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, MODE 3 is required within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> MODE 5 is not required for ITS 3.3.5 Achons B and E for not medag the Recuired Acbons and Completion Times of Achons A and C (one actuation logic channel), respectively.

ITS 3.3.5 Actons B and E require shutdown to MODE 4. There is no justification for requiring MODE 4 rattm than MODE 5 for this less restrichve change.

BGE Response:

Improved Technica! Spec fication Condition B appries to an AFAS manual trip or actuabon channel Current Tedu co! Speof, cation Table 3.3-3 on!y requires this funcbon Operable in Modes 1, 2. and 3. Therefore, the ITS Action B only requires a shutdown to Mode 4, consistent with the Mode of applicabirrty. Improved Technical Spec:fication Condit6n G appries to inoperable actu@ ion logic channels for funcuens other than AFAS. Although this function is nc "pecifically described in CTS Table 3.3-3, it was added as desenbed in DOC A 8. Cie gh g the required shutdown Mode from Mode c '" 4 h luc. M in DOC L1.

2 A

CTS Table 3.3-3 Acbon 6 does not address multiple Provide addibonal jmh-~ei including 6/3/97 inoperable redundant channe!s if two or more channels in when iTS LCO 3.0.3 is required for two or open one or more function are inoperable, entry into CTS 3.0.3 is more cieus in one or more funcuvns are required. ITS 3.3.5 Action B when two Manual Auxiliary ir@-Aie and when ITS 3.3 5. Acbons B Feedwater Actuabon System (AFAS) Logic cieuseis are and D, are required.

inoperable, requires MODE 3 within 6 t aurs and MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.3.5 Action D, for two Manual non-AFAS Manual Trip or Acttribon Logic channels are inoperab!e, requires MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 I

within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> The justificabon states that in this Watinn both the CTS and the ITS require entenng (CTS or ITS LCO) 3.0.3. The juGR,4ui does not include @W of ITS 3.3.5. Actions B and D, which are entered for multiple ir@able channels.

Doc - oscussen or change 25 JFD = Jere for oeveaon

ATTACHMENTfil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

^

3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

Acbons for two channe!s inoperable were added as part of CEOG-99 (is t F-187). References to CEOG-99 wiH be removed, and the CTS and ITS marked accordingly. DOC M.2 is deleted.

3 A.8 CTS Table 3.3-3, Achon 6, does not address multiple Provice add Ucral dMW for ITS 3.3.5, 6/3/97 inoperable channels within a Funcbon. If two or more Acbons B and D, when two AFAS Actuation open charinels ir. one or more func.Scms are inoperable, entry into Logic creuneis are inoperab!e.

CTS 3.0.3 is required. ITS 3.3.5, Acbons B and D, do not address when two AFAS Actuation Logc channels are inoperabie, yet address other multiple redundant channels.

It is not clear that this entry into ITS LCO 3.0.3 for the two AFAS Actuation Logc channels is intentional.

BGE Response:

See response to RAI 3.3.5-2.

4 1.A2 CTS Table 4.3-2, Endnotes (2) through (6), discuss the Provide additional justn.4,vn and 6/3/97 logic circuits that cannot be tested during power operation.

discusson, dentfying the plant procedures open They are dentified as only tested at least once per that contain the CTS Table 4.3-2. Endnotes REFUEUNG INTERVAL dunng shutdown. These endnotes (2) through (6), requirements, and how are moved to unidentified plant procedures. Change control those requirements are controlled.

of these requirements moved to procedures is not specifica!!y identified.

BGE Response:

DOC LA.2 will be revised to state that these requirements are in the Bases.

5 A.4 CTS Tabie 4.3-2 and Endnote (1) require performing the Provide justificabon for extending the 6/3/97 CHANNEL FUNCTIONAL TEST of the ESFAS automate Surveillance Test Nerval from 31 +ys to open actuation logic manua!!y every 31 days. ITS SR 3.3.5.1 92 days.

requires performing a CHANNEL FUNCTIONAL TEST of ooc - orscussen or change 26 Jro - Aarw. ror oeymen

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION Ir8tOVED TECHNICAL SPECIFICATIONS SECTION 3.3 33.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS each ESFAS actuabon logic channel every 92 days. This Note: Consistent vnth the STS.

less restnctrve change extendrig the CTS Table 4.3-2 SurveiRance Test interval from 31 da'. to 92 days is not justified.

BGE Response:

This change was a sefwiste Acense amendment request, whx:h has been approved as Amendment 218 for Unit 1 and 195 for Unit 2.

6 A.9 CTS Table 3.3-3, Funcbon 9.a. requres two sets of two Pronde addibonal discussion and 6/3/97 manual trip buttons per steam generator (a total of eight jt%rw-*w, for dwngg the CTS Table 3.3-open pushbuttons). ITS 3.3.5 requres two channels for manual

3. Funcbon 9.a. *wo sets of two manual trip start of the Auxiliary I&d--r... Actuabon System (AFAS) A buttons per steam generator (a total of eight and AFAS B, ITS Table 3351 Funcbon 9.a.

The pushbuttons), to the ITS Table 3351, justmcahon discusses the ITS Table 3351, Function 9.a.

Funchon 9.a. two dwn,ds.

requrement for two manual start channels, one for AFAS A and one for AFAS B. The jeTa tam does not discuss the

+x+yRay of changng the CTS Table 33-3, Funcbon 9.a.

two sets of two manual trip buttons per steam generator, to the ITS Table 3.351. Funcbon 9.a. two channels for manual start, cae for AFAS A and one for AFAS B.

BGE Response:

DOC L2 win be prowded to jushfy the change DOC A.9 will not be used.

7 A.9 CTS Table 3.3-3, Funcbon 9.a. requres two sets of two Provide addebonal

@m and 6/3/97 manual trip buttons per steam generator (a total of eight juMA.uun for this E.G -.=^.5ve change, open u

pushbuttons). ITS Table 3.3.5, Funcbon 9.a. requres two showing how ITS 33.5 implements the CTS dwo-as for manual start of the Auxiliary ra-d

___c Table 33-3 regurements.

Actuabon System (AFAS) Segnal. The jers,.tas for this change states that ITS Table 3351, Funcbon 9, requras two d-o ni-is for manuel start, one for AFAS A and one for AFAS B (Funcbon 9.a). ITS Table 3.3.5 does not separate DOC = Deonsen of Change 27 JFD = Justdicahon for Demeten

l ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHN0 CAL SPECIFICATIONS SECTION 3.3 4

3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS the requrements on a per AFAS bass or a per steam 1.

genei ior basis. Manual Start is listed, and ITS 3.3.5 requires 2 di.iues, not the eight pushbuttons of CTS Table 3.3-3, Funcbon 9.a.

BGE Response:

DOC L2 will be provided to justify the change. DOC A.9 will not be used.

8 ITS Table 3.3.5-1, adds Funcbon 6.c, Steam Generator 1 Provcle a descnpbon of ITS Table 3.3.5-1, 6/3/97 l

Isolabon (Block) Logic, and Funcbon 6.d, Steam Generator Funcbon 6.c Steam Generator 1 Isolabon open j

2 Isolabon (Block) Logc, to STS Table 3.3.5-1. TheiTS (Block) Logc, and Funcbon 6.d Steam 3.3.5 BASES. LCO 6, does not include a hipiica of ITS Generator 2 Isolaban (Block) Loge in the Table 3.3.5-1 Funcbon 6.c and 6.d.

ITS 3.3.5 BASES, LCO.

BGE Response:

A deswpison of the required Operable choi o neis will be added to the Bases.

9 ITS 3.3.5, Condebon B, adds a second Cwdtu. to STS Prcmde addsbonal h== ion and 6/3,97 3.3.5 Ccist;cc. B.

The Condebon added is two AFAS ju:>inotu for this change, showing how open Manual Actuabon Logic ci i.eis inoperable. ITS 3.3.5 ITS 3.3.5 prcmdes aprvri.ie Acbons for 2 Cctstics. D, adds a second Condebon to STS 3.3.5, anoperable, non-manual AFAS Actuabon Cw4tu D. The Condebon added is one or more Funcbons Logc Channels with two non-AFAS Manual Trips or Actuabon Logc disres inoperable. The addbons are based on esit-A @ ce of this STS deviabon is 187 (CEOG-99) winch has not yet been approved by the cca svent on NRC approval of CEOG-99 NRC. However, with this STS deviabon, there is no specific (TSTF-187).

Ccintu. that provxles Achons for 2 inoperable, non-manual AFAS Actuabon Loge Channels.

BGE Response:

See response to RAI 3.3.5-2.

Doc. r&-+ of crmnge 28

.tro i._m% for Devoten

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.5 -

DOC JFD-CHANGE / DIFFERENCE COMMENT STATUS 10 CEOG-99 (TSTF-187)

Verify ConGtion B is worded cuirecty and 6/3/97 ITS 3.3.5 Action B revise the STS markup and ITS ACTIONS open Curdikai B accuiJ.igiy.

3 i

The Condsbon "Two AFAS Manual Actuabon Logic ctw.-es moperable" is added to Ccidt;0n B.

It appears that this A--;& ice of this dderence is dependent wordog rneans "Two AFAS Manual Start channels or two upon NRC approval of Is it -187 or a plant-Actuabon Logic ctw.ie;s moperable." This dSerence is specific ji iiT= ik,n which would have to be based on a s a t -187 which has not yet been approved.

added to the sutrnettal BGE Response:

See resperise to RAI 3.3.5-2.

11 ITS 3.3.5 Revise the sutwrwttal to clanfy the mient of 6/3/97 the CTS, the STS, and the givpesc-d ITS.

open As presented, ITS Table 3.3.5-1 mdicates that the operatility of the manual actuabon and the operabihty of the actuabon logic for each function are independent; thus manual actuabon and actuabon logic may be treated as separate 'Yuncbons." Even if the operabihty is independent.

l this does not appear consistent with tne CTS and the STS.

BGE Response:

1 Current Techrncal Specia inn Table 4.3-2 shows these furn. tion. as separate, and the ITS also separates the funcbons in the LCO and Acbori l

i Statements The manual actuabor, does use a porbon of the logic crcustry, but the manua! actuabon and parts of the actuabon logic crcustry could l

be independently moperable. Therefore, the independence of the crcustry is stated, and no change to the submittal is nece=sary.

12.

4 ITS Table 3.3.5-1 6/3/97 12 open l

The titles of the funcbons in Table 3.3.5-1 use the word Revise the table to omit the word channel in

~

"ctwoiel" This is mistaading given the wording of LCO the funcbon titles.

{

3.3.5, wtuch requres two channels of each funcbon to be l

t ooc - %.-i or ctwee 29 j

.iro.sustericaten for Densten r

m vemum 4

ATTACHMENT (1)

}

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECDON 3.3 3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 9

operable.

BGE Itesponse:

The Functions in Table 3.3.5-1 are the various signals listed in the Table, not the Manual Actuation or Actuation Logic, as desu rved in the LCO, but the term "channe!" will be deleted from Table 3.3.5-1.

3.3.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

L3 CTS Surveillance Requirement 4.3.2.1.3 requires response Provide addibonal discussai and 6/3/97 time testing for the DG-LOVS instnsnc,uuvo on a justification showing the response time open staggered test basis every 24 months ITS 3.3.6 does not testng for the DG start is inclusive of the require response time testing for the DG-LOVS DG-LOVS instrumentation respurs time for instrumentation because the DG-LOVS instrurnecuucn both LOVS Funcbons response time is negligible compared to the ten second DG start time required, and does not coninbute significantly to determining operability of the DGs. The DG start time testing of ITS SR 3.8.1.16 venfies the DG starts within 10 seconds of a actual of simulated loss of power in conjunction with a actual or simulated ESFAS. ITS SR 3.8.1.16 is satisfied with a less than 10 second start, regardless of whether the start s%nal from the LOVS instrument Functions is timely. For instance, the ITS SR 3.8.1.16 testing could show satisfactory results based on the ESFAS initiation with the LOVS in.tations being inadequate to meet the 10 second requirement The justification does not show that both LOVS Funcuvis (Loss of Voltage and Degraded VoP. age) meet the response time requiremerfo.

)

1 DOC = Descusson of Change 30 UD = Just(caten for oevoton

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IIRPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.6 -

DOC JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

DOC A.17 wiR be provided to explan that the delebon of 4.3.2.1.3 for diesel generator-loss of voltage start (DG-LOVS) is admmetrabwe. DOC L3 wiu not be used. The instrument response time is located in the Updated Final Safety Analyss Report (UFSAR). The UFSAR only provides a response time for the loss of voltage, and the time is the same as the maximum Allowable Value. Improved Technical Spec.in,.Lun mantams the Allowable Value in SR 3.3.6.2 (see resperme to 3.3.6, cuirur.cid 7). Also, ITS SR 3.8.1.15 venfies the DG start time.

2 I.A.2 CTS Table 3.3-3, Acbon 7.b. requires, withm on hour, Provide addsbonal rE=es >==an and 6/3/97 piacog a5 funcucre units receivmg a p..v~;c.-input from ju=LTn Gen, denbfyog how CTS Table 3.3-3 open the moperable dwce in the same inpped or bypassed Achon 7.b is acceiripie ved under the ITS.

cerdbun as the inoperable trip channe!. ITS 3.3.6 does not requre this Acbon. This requuement is moved to the See cc v v.cr4 3.3.4-03 Safety Funcbon Oeterminabon Program (SFDP) of ITS 5.5.15. Mc;.;m, the SFDP is achvated under ITS 3.0.6, which is not requred by any ITS 3.3.6 ACTION, and does not a.cunsprish CTS Table 3.3-3, Achon 7.b, or an equivalent achon.

BGE Response:

DOC A.14 is provided to explan that ITS 3.3.6 requres these acbons to be taken by usmg "one or both Funcbons* in the statement of Cerd^uen A.

Therefore, a0 affected Funcbcns would be requred to enter the Cerduvn. There is no reduchon in requrements. DOC LA2 wil not be used.

3 LA2 CTS Tabie 3.3-3 Acbon 7.b. requres placing all ftin. Lure Provide addsbonal dscussion and 6/3/97 units receiving a p..r~;c.- input from the moperable ju=Lin,. Gen, denbfymg the plant procedures open dwce in the same inpped or bypassed condsbon as the that mantam control over the plant change moperable trip dwce withm one hour. ITS 3.3.6 does not control guc==s and conLv;s over dwy==

requre this achon. This requrement is moved to the Safety to the SFDP.

Funchon Determmahon F vyer. (SFDP) of ITS 5.5.15.

The ju=LTc. Gen states that dw.yw= to the SFDP are in See cui.ncre 3.3.4-12 a,cuidance with the plant dwige control pivcess. The plant change control guc==s is not idenbfied.

g Doc = orscussen of change 31

.FD = Jusbncaten for Dewabon

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADOfTIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

See response to RAI 3.3.6-2.

4 A.4 With one inoperable LOVS channel in trip, CTS Table 3.3-Provide @_W and ji s_r--4-i for this 6/3/97 M.1 3 Achon 7.c, allows bypassmg an additonal dwoe for less restnchve change that provides for open test or mantenance for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ITS 3.3.6, Acbon B, byW9 a second inoperable dwae for allows placog either of two inoperable dwces in trip and reasons other than tesbng and byp.saag the remammg moperable channel, without mantenance.

restriction on the second dwre, that is, the second dwce can be inoperable for teshng, mantenancc, or for See ccavener.t 3.3.1-05 and 3.3.4-04 any other reason. This is a less restnchve change because the second LOVS dwce can be inoperable for reasons other than the CTS Table 3.3-3. Acbon 7.c, allowed teshng and mantenance. Addog the allowance for the second moperable dwie to the CTS Table 3.3-3, Acbon 7.c.

alicmar.cs for ieasons othen than testeg and mantenance is notjustified BGE Response:

DOC L4 will be provided.

5 L1 CTS 3.32.1 and Table 3.3-3 do not sequre Achons if more Provide addebonal MW and 6/3/97 than two channels are inoperable, runedi.te entry into ju=Esi for this less restnchve change open CTS 3.0.3 (shutdown) is requred. ITS 3.3.6 Action C that changes the CunAi Time from allows one hour to restore all but two DG - Loss of Voltage immediately.;ti in9 a shuidown to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> charmels per DG to OPERABLE status if more than two to restore at but two DG '- Loss of Voltage (three or four) dwres are inoperable. This ' creases the dwies per DG to OPERABLE status.

m Complebon Time for the acbon from =>ui.edC'y to one hour.

ooc-oecussion orchange 32 Jro - Jusencebon for oevieson r

tj ! ti lt jiti ;il!e!!f1[ti jil};!

rif l!

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1

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e n l t h' t

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3 ot

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ATTACHMENT _(1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.6 DOC JFD CHANGE / DIFFERENCE COMMENT' STATUS deleting the Trip Setpoint* column from CTS Table 3.3-4 plant procedures.

does not identify the plant procedures that maintain the trip setpoints aor the specific controls that maintain the requirement in plant procedures.

BGE Response:

DOC A.15 will be provided to explain that the trip setpoints in CTS Table 3.3-4 are the same as the Allowable Values. DOC LA.3 wiTI not be used.

Reference to TSTF-91 will in removed.

8 CTS Table 3.3-4 contains " Trip Setpoint* and "A!!awable Revise the submittal to include A!!owable 6/3/97 Values" columns.

ITS 3.3.6 does not maintain the Values in ITS SR 3.3.62, consistent with open Allowable Value requirements. There is no justification for STS SR 3.3.6.3 and CTS TaNe 3.3.4 deleting the

• Allowable Values" column from CTS Table Funcbonal Units 7.a and 7.b.

3.3-4.

This is not in conformance with the STS, which includes the a!!awable values in STS SR 3.3.6.2.

This difference from the STS is based on TSTF-91 which was rejected by the NRC on 3/14/97. (See isit-meeting summary dated April 8,1997).

BGE Response:

References to TSTF-91 will be removed, and the ISTS format adopted.

9 19 l STS 3.3.6 applies in MODES 1,2,3, and 4, and when the Revise the submittal to conform to the 6/3/97 associated DG is required OPERABLE by STS 3.8.2. ITS Applicability of STS 3.3.6.

open 3.3.6 applies only in MODES 1,2, and 3. Not requrnng the DG - LOVS instrumentation OPERABLE in MODE 4 and when the associated DG is required OPERABLE by ITS 3.8.2 is because ESFAS APPLICABILITY is MODES 1,2, and 3. The justification does not address the requirenwnts for DG OPERABILITY which includes SHUTDOWN Conditions.

Doc = oscussen of chawge 34 JFo = Justrr,caten for oevabon

ATTACM (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHIWCAL SPECIFICATIONS SECTION 3.3

33.6

DOC JFD R-CHANGE /DFFERENCE CORAENT STATUS BGE Response:

DOD-19 wiR be revised to provide additonal justncaten, and Mode 4 win be added to Ibe.W. DOC A.12 wiR be modmed to jusLfy tie change 10 L2 ITS 3.3.6 Requred Acton D 1 Reese sterummeri gGg7 open DOC L2 and the Ranma refer to LCO 3.82 for appropnate Revise the Ramat and DOC L2 to conect schon requrements in response to Required Achon D.1.

this error.

Srice the Applicability of ITS 3.3.6 is aanda= 1, 2 and 3, l

only entenng the achon regurements of ITS 3.3.1, not ITS i

33.2, would be appropnate.

i 3

BGE Response:

i DOC L2 wis be revised to remove these references.

11 A.13 ITS SR 3.3.6.1 Notes 1 and 2 6G97

{

STS SR 3.3.62 open I

a. The aEowances of Notes 1 and 2 in ITS SR 3.3.6.1, Ramse the submiltal with an appropnete f-Channel Funcbonal Test-of the DG loss of voltage y% of thisless resencewe dienge.

]

instrumentabon, are not explicitly W in comespondrig j

CTS 432.1.1 (Funcbonal Unit 7 cf CTS Table 3.3-3). Thus 8

including them in SR 33.6.1 is a less resencewe change.

b. DOC A.13 at=aan the inclusion of Notes 1 and 2 in ITS Remme the sutmital witt an appropnete I

SR 33.6.1 is consistent with the NUREG-1432 (the STS).

jusWicahon of this apparenty plant-specdc However, the STS does not include them in correspondng diNerence from tie STS.

STS SR 3.3.6.2, and the STS markup c5ers no specdc a

jih for this dWerena.

r ooc - o.~-, or c e.

as i

j

.ro - m *,o on j

i

-- - - ~

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORGAATION IROPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.6 DOC

'JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

The allowance wiu be deleted from the ITS, DOC A.13 will not be used DOC M2 will not be used, and the entre Actuabon Logic requrement wiE be deleted from the spec 4n iicai.

i 3.3.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

L1 CTS 3.3.2.1 and CTS Table 3.3-3, Funcbon 6.a. requwe two Proinde addebonal discussion and 6/3/97 Cunt &nywd Purge Valve Isolabon Manual Trip channels ju4A inai for this less restnchve dwive, open per perich iicai OPERABLE.

ITS 3.3.7 reduces this

&neidnj the adequacy of ITS 3.3.7, requrement to one Manual Actuabon channet The Requred Achon B.2, for an inoperable requred acbons in the event a channel is anoperabia are Contaw1 ment Purge Valve isolabon Manual either ITS 3.3.7 Requred Achon B.1 (based on CTS Table Trip dwiset 3.3-3 Acbon 8) or ITS 3.3.7 Requred Acbon B.2, to enter the onA bie Condsbons and RequrM-Ac6ns of ITS 3.9.3.

The ju4A iicai does not explain why ITS 3.3.7 Requred Acbon B.2 is an acceptable opbon to Requred Action B.1.

BGE Response:

DOC L3 was provided to jushfy this change in a previous Supplemental License Amendment Request.

2 M.2 in the event less than the requred number of containment Proinde addebonal

<scrin<ian and 6/3/97 radiabon monitors are OPERABLE, CTS Table 3.3-3 Acbon judA inni for this less restnchve change, open 8 allows conbnued operabon if the c.ca4&ered purge addressing the adequacy of ITS 3.3.7, isolabon valves are kept closed.

ITS 3.3.7 Achon A Achon A, for fewer than the requred number requres, if one radiabon monitor sensor module or of containment radiabon monstors associated measurement c.iwisci is w1 operable with the OPERABLE.

c.cnit.;r Twd purge valves or containment vent valves open, placulg the affected sensor module in trip, or suspendwig ooc-oscussion or change 36 so.iusencatenforoe,nsten

1 ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.7 DOC

.JFD CHANGE /DfFFERENCE COMMENT STATUS Core Alterabons and all movement of tradsated fuel assembhes within contanment. This less restnctive change adds opbons of tnpping the affe::ted sensor module or suspending Core Altei.ims and movement of irradiated fuel assemblies withm cent. wrent. The ju=In Gon does not address this less restrictive change.

BGE Response:

Existing DOC L2 provides justification for this change.

3 M.1 in the event fewer than the requimd number of containment Provide addsbonal h=%

and 6/3/97 rad;.tM nonitors are OPERABLE, CTS Table 3.3-3 Achon ju=UTn Gon for this more restnctive change, open 8 allows continued Oper Gon provided the containment addic==ir.g the adequacy of ITS 3.3.7 purge isolabon valves. are mantained closed.

This Achon A, Completion Tirnes.

arvewance has no time limit. ITS 3.3.7, Achon A, requres, if one instrurnent channel is rioperable, either placing the Note: The ITS 3.3.7 Complebon Tirnes are affected sensor module in trip vnthin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or cens: stent with the STS.

immediately suspending Core Alterabons and all movement of rradiated fuel assemblies withm cor/us;ninent.

The ju=iirn 600 does not explan why the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Complebon Time of ITS 3.3.7 Required Action A.1 (similar to the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limit in ITS 3.3.2, Required Action A.1) is accept.uc.

BGE Response:

DOC L2 will be revised to provde additionaljustiin tion for this change.

4 M.3 in the event less than the requaed number of contanment Provide addibonal W_meJan and l 6/3/97 M.4 radiabon monitors are OPERABLE, CTS Table 3.3-3 Action ju=UT.t.cn for this less restnchve change.

open A.8 8 allows conhnued Oper tw prowded the contanment l

purge isolabon valves are kept closed. ITS 3.3.7 Acbon B requires, if one requred manual Actuabon channel or Actucbon Logic channel is inoperable, or more than one ooc-o scussen or ceange 37

.FD = Jushncmon for Deinabcn 1,

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS instrument channel is inoperable, or the Completion Time of ITS 3.3.7, Action A, is not met, either closing the containment purge and exhaust valves and mair.taining them in a closed position, or entering the applicable Conditions and Required Acbons of ITS 3.9.3, wiuch requires suspending Core Alterations and all movement of irradiated fuel assemblies within containment. By provxfing attemative Actions, this is a less restnchve change. The justification does not address or justify this as a less restrictive change.

BGE Response:

DOC L3 was provided in a previous Supplemental Amendment Request to justify this change.

5 LA.1 CTS Table 3.3-4 contains a " Trip Setpoint* column and an Provide addibonal discussion and 6/3/97

" Allowed Values" column.

ITS 3.3.7 contains only the justificabon, xlentifying the plant procedwes open allowable values for the trip setpoints. Taese specific trip that contain the trip setpcints, and controls setpoints are moved in piant procedures. The justificaton over changes to the trip setpoints in those does not identify the plant procedures receiving these trip plant procedures.

setpoints nor the specific controls that maintain the requirement in plant procedures.

BGE Response:

DOC A.10 was added to explain that the trip satpoints are the same as the allowable value. DOC 1.A.1 will not be used.

6 1.A.3 CTS Table 4.3-2, Funcbonal Unit 6.a. requires a CHANNEL Provide justfication for this as an 6/3/97 FUNCTIONAL TEST (CFT) for the manual purge valve administrative change or provide details open control switches every refueling interval. ITS SR 3.3.7.5 clearfy showing the details removed from requires a CFT of the Containraent Radiabon Signal the CTS requirements.

Manual Actuation Char.,els every 24 mcnths. This is justified as a Less Rest-ictive Removal of Requirements rather than as an administrative change.

Doc = oscussen of change 38 50 - Aem for penaten

ATTACHN (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFOREILTN 10 PROVED TECHNICAL SPEC 8FICATIONS SECTION 3 -

3.3.7 DOC i JFD CHANGE / DIFFERENCE CmaaFNT STATUS' BGE Response:

DOC A.1 will be used to justdy this change, and DOC l.A.3 wiB not be used.

7 STS 3.3.7 Requred Actons B.1 and 82 are connected by Prowde ji-- --- ^+i for this STS densbon F/3/97

^'

an 'AND' logcal connector.

Correspondng ITS 3.3.7 based on currett Icenseg bass, system open Requred Acbons B.1 and B2 are connected by an 'OR-desgn, and operabonal constrants.

logeal cuni.edvi.

Changng the logmal connector from

%.c of this STS deviabon is based

'AND* te 'OR' is based on i s n -185 (CEOG-97) wtuch has on NRC approval of TSTF-185 (CEOG-97).

not yet been.pyc;;d by the NRC.

BGE Response:

DOD-37 wid prowde plant spc-cir.cjw:I-- :4. for this change. References to CEOG-96,97, and 98 wiB be removed.

3.3.8 DOC

'I D.

CHANGE / DIFFERENCE COlmAENT STATUS 1

15 STS/ITS 3.3.8 Applicabihty Renee f5e submetal to justdy this STS 6/3/97 STS/ITS 3.3.8 Achons A, C dSerence in Applicability and acben open requrements by discussmg the system The Applicability of STS 3.3.8 is MODES 1,2. 3,4,5, and desgn and the adary =ry of current teshng 6, dunng CORE ALTERATIONS, ard dunng movement of pi+Rh irradiated fuel The ApM of wire.pvin'.;rg ITS 3.3.8 is only MODES 1,2,3, and 4.

This dMerence in Applicabihty is also reflected in certan STS achon requrements that are not bemg =dardarf in the ITS. JFD-15 does not explan why this specdicahon need not be applir-dea dunng CORE ALTERATIONS and dunng movement of irradiated fuel, except to say the rW Applicability is based on consstency with the plant desgn and current teshng methods. The submeat should dian=

m c -D e - orchange 39 JFD = JusWicehon for Dematon

l ATTACleENT.. (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.8 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS the system desgn and teshng methods to make clear why the enbre AppicabeTdy of STS 3.3.8, and related achon requrements, need not be adopted.

BGE "

,~.w:

DOD 15 will be revised to address the applicatwTsty of the Control Room Recrculabon Signal (CRRS).

2 4

STS SR 3.3.8.1, CHANNEL CHECK, is not adopted in ITS Pronde jusblicabon for this STS deviabon 6/3/97 3.3.8. JFD-4 does not directly justfy this STS deviabon nor based on system desgn and the adequacy open explain why a Channel Check is not needed based on of cunent tesbng gKt-

• system desagn and tesbng gKtks BGE Response:

The Charmel Check requrement wiH be retained in the ITS.

3 15 STS SR 3.3.8.3, CHANNEL FUNCTIONAL TEST of the Provide jt%. for this STS deviabon 6/3/97 Actuabon Logc, and SR 3.3.8.5, CHANNEL FUNCTIONAL based on system design and the adequacy open TEST of the Manual Trip, are not adopted in ITS 3.3.8.

of cunent teshng pracbees.

JFD-15 does not explain how the system design and teshng gin in.m.jusbfy omessson of these surveiBances.

BGE Response:

DOD 15 wiu be enhanced to jushfy these exclusions.

4 3

Why does STS SR 3.3fa.6, response time teshng, not need Revise the submsttal to avrd==i why 6/3/97 to be adopted in ITS 3.3.8? The juen.4;06 for this STS response time tesbng is unnece===ry for the open deviabon is based on ira.visad g plant speofic controi room recrculabon sgnal.

Liviir i;un into brackets not sufficent basis.

BGE R;;,

No response time is assumed in the UFSAR Chapter 7 for Control Room isolabon. This is a bracketed SR in the ISTS and is not appocable.

Doc - om:vesen et change 40

.FD = Just6caten for oevaton

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ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADOWlONAL INFORABATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 L3.3.9 DOC

.JFD CHANGE / DIFFERENCE COMMENT STATUS Funcbon Determinabon Picy.-n (SFDP) of ITS 5.5.15.

Action 7.b, requrement for placmg ah The jusTic tini states that changes to the SFDP are in funcbonal units recemng a parameter input accordance with the plant change control process. The from the moperable channel in the same plant change control process is not idenbfied tnpped or byp ssed condson as the inoperable trip channel withm one hour.

See con..ent 3.3.4-12 BGE Response:

i See tws to RAI 3.3.9-2.

l 4

M2 CTS 3/4.32.1 does not include specific requrements if an Prowde discussen and junin inn. for this 6/4/97 Achon cannot be unny;cied withm the requred COnip;etkoi change from the CTS 3.0.3 - 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> open j

Time, or if two Actuabon Logic channels are moperable.

requwernent to reach MODE 4 to the ITS

}

Thus, entenng CTS 3.0.3 is required if the Achon is not 3.3.9. Achon D. 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> requrement to completed withm the Complebon Time or if two Actuabon reach MODE 5.

Logic ctwreis are inoperable. CTS 3.0.3 aBows 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to reach MODE 3, and 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> to reach MODE 4. ITS 3.3.9 Action D is added for when two Actuabon Logic ctwie;5 m moperable, or the Requred Acbon and Associated Canplebon Trnes cannot be met. It requres MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

No jusin tkai is provded for crgrgiraj the CTS 3.0.3 - 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> requrement to reach MODE 4 to the ITS 3.3.9, Achon D, 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> i

a requrement to reach MODE 5.

BGE Response:

DOC M2 was in crror with respect to the Modes and will be ceiTected to :natch the CTS 3.0.3 requrement of Mode 5 in 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> and the ITS 3.3.9 requirement to bein Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> j

5 1.A.3 CTS Table 3.3-4 cunt sw " Trip Setpomt* and " Allowable Provde addibonal discussen and 6/3/97 I

Vaiues" columns.

ITS SR 3.3.9.2 contams only the jusin ik,i, idenbfymg the plant procedures open Doc = oscuss.on or cnange 42 JFD = Justficahon for Densbon

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.9 DOC JFD l

CHANGE / DIFFERENCE COMMENT STATUS "A!!cwable Values" column.

Speafic tnp setpoints are that contain the tnp setpoints, and controls ma:iitained in plant procedures.

The justifcation for over changes to the trip.,etpoints in those deleting the CTS Table 3.34 " Trip Setpoint* column does plant procedures.

(

not identify the plant procedures that maintain the trip setpoints nor the specific controls that maintain the requirement in plant procedures.

BGE Response:

DOC A.13 wi!! be provided to explain that the trip setpoints and Allowabie Values are the same. DOC 1.A.13 will not be used.

H 6

I TS 3.3.S adds the note "LCO 3.0.4 is not applicable" to !TS Venfy that the changes assoc:ated with 6/3/97 3.3.9 Action C. The note "LCO 3.0.4 is not appreable" is id i F-84 have been withorawrt open not contained in STS 3.3.9 Action C. This STS deviation is based on TSTF-84. On 4/22/97 BGE indc~ ated by e-mail that TSTF-84 was be:ng withdrawn from the submittal.

I BGE Response:

TSTF-84 was approveo' by the NRC, and has been retained in the ITS.

7 I ITS 3.3.9 adds the condition 'two Actuation Logic Channels Acceptance of this STS deviation is based 6/3/97 inoperable" to Action D, that is not contained in STS 3.3.9, on NRC approval of i s i F-187 (CEOG-99).

open Action D.

This STS deviation is based on TSTF-187 (CEOG-99) which has not yet been approved by the NRC.

BGE Response:

References to CEOG-99 will oe removed and the ISTS format will be adopted.

8 4

ITS SR 3.3.9.2 limits CHANNEL FUNCTIONAL TESTING Provide a plant-specfc Justification for this 6/3/97 of relays associated with plant equrpment that cannot be STS deviation based on current Icensing open operated during plant operation to once per 24 months, basis or system design.

instead of the STS SR 3.3.9.2 "during each MODE 5 entry g

exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless test" within the previous 6 i

ooc - oscussen or change 43

.mo.susteicsoon for omnaten

l. ]

ATTACM.(1)

RESPONSES TO REQUEST FOR ADDITIONAL NTION IIIPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

-3.3.9 DOC

'JFD CHANGFJDIFFERENCE c COMtMTT STATUS nxmths.' TNs STS deviabon is not justded by JFD-4.

IBGE Response:

See response io RAI 3.3.9-11.

9 A.11 4

ITS SR 3.3.9.2 Notes 1 and 2 6/3/97 CTS 4.3.2.1.1 for Table 4.3-2 Funcbonal Unit 8 "CVCS open isoiabon-

a. Notes 1 and 2 for ITS SR 3.3.92 have been adopted

a. Revise the sutettal with appropnale as an administratrve change. However, har=ma Note.1 jusblicabons.

speofies a requrement not explicitly given in CTS 4.3.2.1.1, i.du,A g it is a more restnchve change.

In %,

v==a Note 2 specdes an adowance not grven in CTS 4.3.2.1.1, adophng it is a less restnchve change.

b.

ITS SR 3.3.9.2 Note 2 is less 'restnchve than the correspondag Note 2 of STS SR 3.3.92. The STS markup

b. Revise the submittal with a JFD to indicates that JFD 4 explains the bases for the d6erence.

address this diffe v.w.

However, JFD 4 does not explam why it is =crar*=No to only test the relays "once per 24 months" instead of "dunng each Mode 5 entry +:+:: Mg 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless tested within the previous 6 months."

EDGE Response:

See response to RAI 3.3.9-11.

10 M.3 ITS SR 3.3.9.1 Revise the sutmital to correct this error.

6/3/97 CTS 4.3.2.1.1 open

CTS Table 4.3-2 Funcbonal Unit 8 "CVCS isolabon" A Channel Check for the CVCS isolabon funcbonal unit is ooc = oscus on orcnenge 44 JFD = Justerm for Dov'esen

?

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

.3.3.9

DOC, JFD-CHANGFJDIFFERENCE COMMENT STATUS L

adopted as ITS SR 3.3.9.1 and justdied by DOC M.3, as exhcated on the markup of CTS Table 4.3-2. Mcx=, the markup of CTS 4.3.2.1.1 mistakenly lists this DOC as M.4, which doesniexist.

BGE..esponse:

The CTS markup has been corrected to refer to DOC M.3.

11 A.1 ITS 3.3.9 ACTIONS A and D 6/3/97 j

l.A.4 CTS 3/4.3.2.1 Achon b and Table 3.3-3 Achon 6 for open Functional Unit 8.a *1danual (CVCS isolabon Valve Controi Switches)

CTS 3/4.3.2.1 Actn, b and Table 3.3-3 Funcbonal Unit 8.b 'CVCS isolabon" l

a. CTS Table 3.3-3 Acbon 6 corresponds to both ACTION

a. Revise the CTS markup c.cwia py.

t A and ACTION D of ITS 3.3.9. The markup of CTS Table i

3.3-3 (page 3/4 3-15) does not show thc currespOndence to l

ACTION D.

l i

b. CTS Table 3.3-3 Acbon 6 is listc1 with Funcuord Unit

b. Revise the submittal with an Esppup;.W::

l 8.a. not with 8.b. All requrements for Funcuenid Unit 8.a ju.LTw for applying the requrements of are moved from the CTS to plant procedures in,wia9 to Achon 6 to Funcbonal Unit 8.b.

i DOC LA4. Yet Achon 6 is treated as being retained for l

Funchonal Unit 8.b. "CVCS ise:itivn." Only CTS Achon 7 is i

listed with Funcbonal Unit 8.b.

Thus, applying the requrements of Acbon 6 to Funcuenist Unit 8.b in ITS 3.3.9 is a more icotrictive change.

[

i i

i ooc - Discuss.on et change 45 1

JFD = Justrncation fe: Deviatien

h f-ATTAC16 (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 l-3.3.9 :

DOC yJFD CHANGEIDIFFERENCE CNMAfT STATUS i

l BGE Response:

I The CTS mark-up will be reweed to show the =driervi of =remswwi logic to the Chemmal and Volume Control System (CVCS) et=rarnswwt.

[

Artimerwi logic is assumed in the safety analyses, manual is not. DOC M.4 justifies this change, and DOC A.11 win not be used. Notes are added to l

the Channel Funcbonal Test assoanmaad with Ar*n=#wwi Logc. Adushon logic can not be tested at power because it would isolate letdoom flour, so i

teshng is proposed every 24 months, consistent with similar ESFAS Fundsons. DOD 30 will be added to justify the denshon from the ISTS.

1 3.3.10 ~

DOC JFD-CHANGE / DIFFERENCE fM MFNT STATUS 1

1.A.2 CTS Table 3.3-10 Note

• states that a channel of the Pronde

.,+ ear =ml rEmen=arwi and 6Mt97 Reactor Vessel Water. Level instumentshon consists of jusblicahon for monng these details, open eight sensors per probe, and that a channel is documenhng the recapsent documentaton OPERABLE if four or more sensors (one or more among for these desegn details and controls over j.

the upoer three and three or more in the lower five) are changes ' to the detals lar=And in that OPERABLE. - The Jusblicahon for doishng these details documentahon.

from ITS 3.3.10 ef=taa these details are relocated to the BASES and moved to plant procedures. LA.2 is not clear i

as to the rGarandwwi of these desegn details and the l'

controis that mentam these details once they are i.

removed from the ITS.

BGE Response:

DOC LA.2 win be reused to reflect movement of the details to the Ranma, t

2 CTS Table 3.3-10 instrument 3 Reactor Coolant Outlet Remse the submdtal to jushfy the change 6M/97 l

Temperature, requwes a minimum of 2 channels from a mirumum of 2 channels to 2 open l

Operable. Correspondrig ITS Table 3.3.10-1, Funchon 2, irwEr=8wwi channels perloop.

j Reactor Coolant Outlet Temperature, requses 2 inwEr=8wwi j

diannels per loop Operable.

The diange from a j

minsnum of 2 channels to 2 irwer=8rwi channels per loop i

. ooc-o-orce mi i

JFD = JustScaten for Deweton

ATTACHitENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 I

3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS appears to be a more restrictive change.

BGE Response:

There are only 2 hot leg and 2 cold leg temperature indicators, not 2 per loop, and ITS wi!! be revised to be consistent with the CTS.

3 CTS Table 3.3-10 Instrument 9 and ITS Table 3.3.10-1, Justify having the same action for both the 6/4/97 Function 4 RCS Subcooled Margin Monitor, require a inoperabirity of the only required RCS open single instrument channel for this Regulatory Guide 1.97, Subcooled Margin Monitor channel and the Type A, variable.

The ITS 3.3.10 Actions for that inoperability of one channel of a redundant inoperab;c channel are the same as the iTS 3.3.10 pair ofinstrument channels.

Actions for the loss of a single channel of a Funcbon with redundant channels. It is not clear how the loss of the Provide justLUcn for this STS deviation single RCS Subcooled Margin Monitor channel is based on current licensing basis and system compensated for as it is the only indicator of RCS desgn.

Subcooled Margin. This deviates from STS 3.3.11, as redundant instrument channels are required for a!!

variables in STS Table 3.3.11-1.

BGE Response:

The ITS will be revised to delete a required action in Table 3.3.10-1 for this Funcbon. Acbons A and B are sufficient to control this Funcbon. The Subcoc'ed Margin Monitor is backed up by reactor vessel water level and core exit thermocouples These are diverse ind~cabons of Reactor Coolant System (RCS) subcooling, so only one subcooled margin monitor is required in the plant TK,cidg basis 4

LA.8 CTS Table 3.3-6 requires two channels of Containment Provide additional ds W and 6/4/97 LA.10 Area High Range monitors OPERABLE in MODES 1,2 justification for moving this

detail, open 3, and 4.

In addition, CTS Table 4.3-3 specifies docurnadug the plant procedure cordc.irarg surveitlances to be met in these Modes. Cuirespr.n. dire this reqtmenient and controls over chiin es v

ITS Table 3.3.10-1 does not specify these requiremants in to this regtmenient located in that Mode 4, which is a less restnchve change. The Mode 4 procedure.

requirements are moved to uniderfafied plant procedures.

Doc = oisensson or change 47

.FD = Justreaten for Deveten

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

DOC L7 wit! be provided to justify the Mode of apphcability, and the deletion of the Channel Fundicnal Tests and trip setpents, and DOC LA8, LA.10, LA.11 and LA.13 will not be used.

5 LA8 CTS Table 3.3-6 requires two Containment Area High Revise the submittal to discuss and justfy 6/4/97 LA.10 Range monitors in MODES 1,2,3, and 4. Similarly, CTS this less rest-;ctve change, docurreLg open Table 4.3-6 requires surveillances for this PAM why CTS Table 3.3-6 and 4.3-3 requires two instrumentation to be met in Modes 1, 2, 3, and 4.

chonr.eis of Containment Area High Range Corresponding ITS 3.3.10 and Table 3.3.10-1 require two monitors OPERABLE in MODE 4 and PAM channels of Containment Area Radiation (high detair;ng the a.eptMdy of deleting that range) au.1 corresponding testing requirements (SR requirement 3.3.10.1 and SR 3.3.10.3) in MODES 1, 2 and 3 only.

The deletion of the MODE 4 from the Appfcabi!ity is a less restrictive change. LA.8 does not explain why this PAM instrumentation is not needed in Mode 4.

BGE Response:

See response to RAI 3.3.10-4.

6 CTS Table 3.3-6 lists for Instrument 1.b. Containment ReAse the submittal to identify and justfy 6/4/97 Area High Range monitors, a range of 1 to 10' R/hr and a the removal of the required range and the open alarm / trip setpoint of > 10 R/hr. The disposition of the alarm / trip setpoint for the Cunt,uunent Area required range and the alarm /tnp setpoint is not identfied High Range monitors.

in the markup of CTS Table 3.3-6. These requiremer.Ls are not contained in corresponding ITS 3.3.10 for Function 9.

BGE Response:

See response to RAI 3.3.10-4. The range was moved to the Bases by LA.14 as part of a previous Supplemental Amendment Request.

doc = Discussen of Change 48 JFD = Justrficaten for Deviaton

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

-3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS I

7 ITS Table 3.3.10-1 Func:an 4. RCS Subcooled Margin ' Provide addibonal d' hon, clanfying 6/5/97 1

Monitor, requires a single instrument channel for this there are 2 required channels for this open Regulatory Guide 1.97 Type A, variable. The ITS 3.3.10 Type A variable in ITS Table 3.3-10, as Bases states the "two SMMs consist of redundant required by Regulatory Guide 1.97.

microprocessor based instruments,"

indicating one analog indicator for the two microprocessor based channels.

BGE Response:

See response to RA: 3.3.10-3. The bases for Action b will be revised to identify the diverse methods of mbcooled monitoring.

8 1.A.7 The requirements for CTS Table 3.3-10, PAM Provide additional discussion and 6/5/97 Instrumentation, include requirements for the non-ju M n Gcm for moving these PAM open Category 1 variables Auxiliary Feedwater (AFW) Flow instrunierdoGon requircinents, docurnen6g Rate. Power-Operated Relief Valve (PORV)/ Safety Valve the plant procedures cordaWrg these Acoustic Flow Monitoring, PORV Solenoid Power requirenients and controls over changes to Indication, and Feedwater Flow. These requirenients are these requireinents located in those moved to unidentified plant procedures.

procedures.

BGE Response:

DOC L8 will be provided to justify removal of norx:ategory 1, non-Type A instruments. DOC t.A.7 will not be used.

I CTS Table 4.3-10, Footnote *, requires calibrating the Provide additional discussion and 6/5/97 9

1.A.6 core exit thermocouple prior to installation into the reactor j'%r-M+i for troving the requiresient to open core. This requirement is moved to urudentified plant calibrate the core exit thermocouple prior to procedures.

installation into the reactor

core, docurre.We the plant procedures containing these requircincrds and controls over charges to these requuene-ds located in those procedures.

doc = Docussen of Change 49 JFD = Justrreation for Deviaten

ATTACM (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATIOes IMPROVED TECHIGCAL SPECIFICATIONS SECTION 3.3 13.3.10f DOC "JFD CHANGE / DIFFERENCE CORAENT STATUS BGE Respcmoe:

DOC A.6 wGl be revised to jusbly the change. DOC LA6 wiR not be used.

10-LA.12 CTS Table 4.3-3, requres a CHANNEL CHECK of the Revise the submdtal documenhng the plant 6MW97 Contanment Area High Range r=rG=hnu mondors each procedures contarung the shey Channel open shift. ITS SR 3.3.10.1 requres a rnandhly CHANPEL Check recp.ement and controis over CHECK # r these PAM metrument chands.

The changes to these procedures.

3 requrement for the CHANNEL CHECK every shift is moved to unidentdied plant procedures.

BGE Response:

See response to RAI 3.3.10-11.

11 LA.12 CTS Table 4.3-3, requiras a CHANNEL ClIECK of the Revise the sutuvultai to jushfy the Channel 6MWg7 Contanment Area High Range r=rs=hnri mondors each Check Frequency relaxaten as a L-type open shift. ITS SR 3.3.10.1 requires a monthly CHANPEL change.

CHECK for these PAM instrument channels. Decreaang the Channel Check Frequency from shey to monthly is a less restnctive change.

BGE Response:

DOC L9 wiR be provided, and DOC LA12 wiR not be used.

12 LA.4 CTS Survedlance Requrement 4.6.5.1.1 requres Provide arHhnnal diSCVisaan and 6MW97 4

demonstrahng each hydrogen analyzer is OPERAELE at pJ_' 4. ior moving the req arement for open least tweeeldy, on a Staggered Test Basis, by draunng a demonstrahng endi hydrogen analyzer is sample from the Waste Gas System through the

OPERABLE, documentng 2nr plant hydrogen analyzer.

This requrement 3 moved to procedures containng these reamrements unidenblied plant procedures. In addibon, no justncahon and controls. over changes to these is given for removing this surveitance from CTS.

regurements located in those prnrwswes.

ooc - oscussen or cheas.

50

.ro -Justacewm var oevenon

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

' 3.3.10 COC JFD' CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

DOC L10 will be provided to justify the reduchon in f.w, and DOC LA.4 will be revised to place the details of the Channel Check in the Bases.

This requh s4.-nt serves the funcbon of a Channel Check for this monitor.

13 LA.9 CTS Table 3.3-6, Achon 30, rec:ures, with the number of Prowde addebonal

@== ion and 6Ea/97 channels of Cordrsir.T,Ent Area High Range radiabon jMin,.trun for rnoving the requrement for open monitors less than that required, irdi in g an attemate pre-implemenbng the pre-p!anned altemabwe planned method of monitonng within 72 hot.s. The 72-method of meidvdre this

vanable, hour requeement to implement the pre-planned attemabwe documenhng the plant procedures method of morntudig this vanable is moved to an contarung these requeenmnts and conhois ur dentified procedure.

over changes to these requrements located 4

in those procedures.

BGE Response:

DOC L6 will be revised tojustify this change, and DOC LA.9 will not be used.

14 LA.11 CTS Table 4.3-3, requires a monthly CHANNEL Revise DOC LA.11 to contain addibonal 6/6/97 FUNCTIONAL TEST (CFT) of tne Curd u v,cnt Area High

@_m= inn and j6Tn tion for moving the open Range Radiation Monitor. This CTS Table 4.3-3 CFT requrement for a monthly CHANNEL requirement is not requred by ITS 3.3.10, and is moved to FUNCTIONAL TEST of the Cud anent

]

undentdied plant procedures.

Area High Range Radiabon Monitor, doctsredag the plant procedures r,vid.umg these requrements and cvuuvis over chiscn,es to these requrements located in those procedures BGE Response:

See response to RAI 3.3.10-4.

15 ITS Table 3.3.10-1 Ftmcbon 4 n.w. a single RCS Provide @_mainn on how the loss c' the 6Mi/97 Subcooled Margin Monitor ch.nnc-1. For this Funcbon, RCS Subcooled Margin Monitor i.J raeel open coc - oiscussen or change 51

.CD = Just6 cation for Deviahon

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONA*. INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ITS Table 3.3.10-1 requires Condition F when referenced requires the forced shutdown of ITS 3.3.10-from ITS 3.3.10, Acticn E. However, for Action E to apply, 1, Condition F, as required by ITS Table and hence, Action F, the Action C is not completed.

3.3.10-1, Function 4.

Action C is required when +wo required indication channels are inoperable, a condition that can not occur for Function 4, RCS Subcooled Margin Monitor, because only one channel is required by ITS Table 3.3.10-1. Thus, the ITS Table 3.3.10-1, Fun Son 4, entry for Condition F (a forced shutdown), is not posdbic with the single RCS Subcooled Margin Monitor channel.

BGE Response:

Improved Technical Specification Table 3.3.10-1 will be revised to say "N/A" for Actions. Actions A and B provde the appcpfste requirements for an inoperable subcooled margin monitor. The special report required by Action B will indicate the availability of diverse monitoring for RCS subcooling. Not shutting down based on diversty is justified in DOC L1.

3.3.11 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

1.A.1 The CTS 3.3.3.5 and CTS Table 3.3-9 details of the Provde additional discussion and 6/6/97 readout location and measurement range of the individual justification for moving the details of the open instruments for the Remote Shutdown instrumentation are readout location and measurement range of moved to unidentified plant procedures and the Updated the individual instruments, docuumumrg the Final Safety Analysis Report.

plant procedures containing these requirements and controls over changes to these requirements located in those procedures.

BGE Responte:

DOC LA.1 will be revised to move these details to the UFSAR and justify the relocation.

Doc - Drscussion of change 52 JFD = Justicabon for Deviation

~ - - -.-

.r ATTACHMENT (1)

' RESPONSES.TO REQUEST FOR ADDITIONAL INFORIAATION i

100 PROVED TECHNICAL SPECIFICATIONS SECTION 3.3 lq i3.3.11(

DOC

?JFD b CHANGE / DIFFERENCE COneAENT.

STATUSj l

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'2 LA.1 The CTS 3.3.3.5 and CTS Table 3.3-9 details of the Provide addibonal af=n==iari

-and 64W97 readout locahon and measurement range of the indudual jushficahon for movmg the details d _the open 3

ristruments for the Remote Shutdown instrumentabon are readout locahon and measurement range of

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moved to unidenbfied plant promdures and the Updated the indmdual mstrumerts, dan==arig the l

Final Safety Analysis Report.. The justificabri for movmg acceptatzhty and the safety impact !of l

1 these requrements does not dan== the acay*=hd*y nor movmg these regurements.

j the safety unpact of movmg these seguirements r

BGE Response:

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See response to RAI 3.3.11-1.

3 CTS Table '4.3-6 specifically requres the wide-range Provide h% and r6=a==iari on 6MW97 steam generator level channels for the re note shutdown movng of the specific requrement for wide-open instrumentabon. Correspondmg ITS Table 3.3.11-1, while range channels - to monitor : the steam I

requairg steam generator level instrumentabon, does not generator level for the remote stuminwn specificaNy requre ; the wideHrange Channels.

Not instrumentabon.

t contromng the requrement for the ude-range channels in l

ITS 3.3.11 could result in their" replacement with the i

narmw-range channels BGE Response:

The term " wide range" will be added to Steam Generator Level in ITS Table 3.3.11-1.

4 JFD 17 STS SR 3.3.12.2 venfies each requred control cucuit and Revise the sutrnettal to adopt this STS SMW97 l

transfer switch is operabonal. ITS 3.3.11 does not adopt surveillance recurement or provide open STS SR 3.3.12.2 because it is not requred in the CTS.

Jushficabon for this STS deviabon based on j

i The jushficahon does not stan=s system desagn and cummt licensmg basis, system design, and i

opershonal emistracts that preclude addmL this operabonal constrants.

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i regurement to iTS 3.3.11.

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DOC = Decussson of Change 53 JFD = Justication for Devebon p

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ATTACHMENT (1)

!y RESPONSES TO REQUEST'FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3

-[

t 13.3;11!

DOC

?JFD.

CHANGE / DIFFERENCE COMMENT' STATUS:

BGE Response:

P DOD-17 will be revised to provide justificabon based on current licensing basis l

2 5

The Bases discussion of ITS 3.3.11 Reqrired Achon A.1 Resolve this discrepancy between ITS 6/6/97 v

f states that the control and transfer switches are included 3.3.11 and the ITS 3.3.11 Bases.

open in the Funcbons requwed OPERABLE. However, the control and transfer switches are not included in ITS Table g

3.3.11-1, and have no requwements in ITS 3.3.11.

BGE Response.

t Action A.1 Bases'will be modified to delete these references i

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i 33.3.1.2-DOC:

JFD:

CHANGE / DIFFERENCE :

COMMENT

. STATUS 1

A.3.

CTS Table 3.3-1 contans a " Total No. of Channels

• Provide ju.ia.t;vii and discussion showing 6Mi/97 l

LA.1 column, a." Minimum Channels Operable" column, and a the acceptabihty of the change from the open

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" Channels 1to Trip" column, requenng 4 wide-range CTS Table 3.3-1 minimum of 3 OPERABLE wide-range 10 iGniisc neutron flux monitor

[

ic imiGniiic neutron flux. monitor channels at least 3 v

9 OPERABLE, and 2 channels to trip. Corresponding ITS channels to 2 OPERABLE channels in ITS 3.3.12 requires 2 OPERABLE channels' of wide-range 3.3.12.

icyc=suniic neutron flux monitor channels. The change j

from the CTS Table 3.3-1 minimum of 3 OPERABLE wide-i i

range icy.nuniiic neutron. flux monitor channels to 2 l

OPERABLE cri

b in ITS 3.3.12 is a less restnchve change that is notjustified.

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ooc = oiscunion of change

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JFD = JustWication for Devehon l

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4 ATTACHMENT (1) l RESPONSES TO-REQUEST FOR A*1DITIONAL INFORMATION i

IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 p

CHANGE / DIFFERENCE COMMENT

. STATUS'

3.3.12 L L-DOC'

'JFDc

't BGE Response:

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,1 Current Tecin.;cel Specificetion Table 3.3-1 requres a muumum of 2 channels Operable. Current Techmcal Specifei Achon 3 is h==ri on "one less than required by the minimum channels. Operable." With 2 of 4 channels anoperable in the CTS, no achon is requred, so only 2 channels.are l

requered for compliance with the LCO. These 2 channels are requwed by ITS 3.3.12. This admirustrative change is justified by DOC A.3.

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1 ATTACllMENT (2)

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IMPROVED TECHNICAL SPECIFICATIONS, REVISION 8

SUMMARY

OF CIIANGES

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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 20,1997

i ATTACHMENT m

SUMMARY

OF CIIANGES 1,

To resolve Nuclear Regulatory Commission (NRC) comment 3.3.1 1 Discussion of Change LA.S has been deleted and replaced with Discussion of Change L.3. The requirement to verify the capability of bypassing functions is not credited in the safety analysis, only bypass removal which is retained. The Current Technical Specification (CTS) markup and No Significant Hazards Considerations have been updated accordingly.

2.

To resolve NRC comment 3.3.1-3, Discussion of Change LA.2 is revised to reDect that the design detail of overlap between the wide range and power range nuclear instrumentation is moved to the Bases.

3. -

To resolve NRC comments 3.3.1-4 and 3.3.1-20, Discussion of Change LA.6 has been deleted and replaced by Discussion of Change A.18. The improved Technical Specification (ITS) maintains the CTS Actions in a different format without a reduction in requirements. The CTS markup has been updated accordingly.

4.

To resolve NRC comment 3.3.1-5, Discussion of Change L,4 was added 3 justify placing a second channel in trip for reasons other than maintenance and testing. The L TS markup and No Significant flazards Considerations have been updated accordingly.

5.

To resolve NRC comment 3.3.16, Discussion of Change L.2 has been deleted and replaced by Discussion of Change M.4 since the addition of a time limit to the existing surveillance is more restrictive. Discussion of Change LA.8 has been deleted and replaced by existing Discussion of Change A.7 which alreadyjustified deleting references to operation with less than the required Reactor Coolant System (RCS) loops since that configuration is not permitted by ITS 3.4.4. The CTS markup has been updated accordingly. To resolve NRC comment 3.3.1-7, Discussion of Change L.1 has been deleted and replaced by Discussion of Change M.5 since the addition of a time limit to the existing surveillance is more restrictive. The CTS markup has been updated accordingly.

6.

To resolve NRC comments 3.3.1-8 and 3.3.1-19, Discussion of Change LA.3 is revised to reflect that the detail regarding adjustment of power range and delta T potentiometers is moved to the Bases rather than procedures.

7.

To resolve NRC comments 3.3.1-9 and 3.3.1-11, Discussion of Change A.9 has been revised to reDect the movement of allowable values to ITS 3.3.1 and discuss the deletion of the trip setpoints. Discussion of Change LA.4 is deleted since the trip setpoints are the same as the allowable value and do not need to be relocated.

8.

To resolve NRC comment 3.3.1-10, Discussion of Change A.14 was revised to provide additional justification for removing cross-references within the Technical Specification. A clarification was added to the Bases of ITS 3.3.1 to identify where RCS design How is controlled.

9.

To resolve NRC comment 3.3.1-13,14, and 18, references to TSTF-80 were removed from the Standard Technical Specification (STS) markup and replaced with a plant specific Discussion of Deviation 33. Discussion of Changes A.16 and M.3 were revised to clarify and provide additionaljustifications for the changes to the CTS. The CTS markup was annotated to identify I

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ATTACHMENT m

SUMMARY

OF CHANGES the location of footnote "e" to Table 33-1. These changes maintain the existing licensing basis for Calvert Cliffs.

10.

To resolve NRC comment 33.1 15, references to TSTF 81 were removed from the STS markup supporting the exclusion of neutron detectors from channel calibrations. This exclusion exists in the CTS and is retained. Justification for Deviation 24 was revised to justify not performing channel calibrations on the loss of load function. The loss of load function exclusion was removed from the ITS Surveillance Requirement (SR) 33.1.8 note since the surveillance is not applicable to this function in Table 33.1 1.

11.

To resolve NRC comment 33.1 16, references to TSTF-85 were removed from the STS markup and replaced with a plant specific Discussion of Deviation 38.

12.

To resolve NRC comment 33.1-21b, Discussion of Change M.6 was added to justify adding MODE 2 to the applicability of delta T power function. The CTS markup was annotated accordingly.

13.

To resolve NRC comment 33.1-22, the ITS and STS markup for Table 33.1-1 was revised to include SR 3.3.1.7, Channel Functional Test, to the Asymmetric Steam Generator Transient Function, consistent with the CTS 43.1.1.2 requiren.wo test bypasses for applicable functions.

Current Technical Specification Table 33 1 identifies this function as including a bypass.

14.

To resolve NRC comment 33.2-1, Discussion of Change LJ was add 9d to justify placing one channel in bypass and one channel in trip for reasons other than maintenance and testing. The CTS Markup and No Significant Hazards Considerations have been updated accordingly.

15.

To resolve NRC comment 33.2 2, Discussion of Change LA.1 has been deleted and replaced with Discussion of Change L.2. The CTS markup and No Significant Hazards Considerations have been updated accordingly.

16..

To resolve NRC comment 3.3.2-3, Discussion of Change LAJ has been deleted and the CTS markup revised to show that CTS Table 33-1 Action 2.b is applicable to ITS 33.1 and not to ITS 33.2.

17.

To resolve NRC comment 33.2-5, references to CEOG-91 (TSTF-180) were removed from the STS markup supporting the addition of the automatic bypass removal feature to the Limiting Condition for Operation (LCO) 33.2 statement. This requirement exists in the CTS and is retained. Discussion of Deviation 34 was added to support this change on a plant specific basis.

18.

To resolve NRC comments 3.33-1 and 3.33-8, references to TSTF-79 were removed from the STS markup supporting the addition of the automatic bypass removal feature to the LCO 33.2 statement. This requirement exists in the CTS and is retained. Discussion of Deviation 35 was added to support this change on a plant specific basis: The inadvertent duplication of channel functional testing in the ITS SR 333.2 was removed.

19.

To resolve NRC comments 333-2 and 333-3, Discussion of Changes M.1 and M3 have been deleted and replaced with Discussion of Change A.9 and Discussion of Change M.6 is deleted 2

ATTACHMENT m

SUMMARY

OF CHANGES and replaced with Discussion of Change A.10. These changes are necessary to reDect that the conversion of the mode of applicability for the trip logic and reactor trip circuit breaker functions is administrative rather than more restrictive.

20.

To resolve NRC comments 3.3.3 5 and 3.3.3-6, references to CEOG-73 (TSTF-170) and CEOG 94 (TSTF-182) were removed from the STS markup and the ITS was revised consistent with the STS. Discussion of Change L.7 was deleted and Discussion of Change L.4 was replaced by Discussion of Change M.7 since the change was actually a more restrictive change on plant operations. The CTS markup was revised accordingly to reflect these changes.

21.

To resolve NRC comment 3.3.3 7, references to CEOG-95 (TSTF-183) were removed from the STS markup supporting the removal of the "one or more functions with" statement from NUREG 3.3.3 Condition E. Discussion of Deviation 36 was added to support this change on a plant specific basis.

22.

To resolve NRC comments 3.3.41 and 3.3.4 8, Discussion of Change LA.6 has been deleted and replaced with Discussion of Change L.3. The requirement to verify the capability of bypassing functions is not credited in the safety analysis, only bypass removal which is retained. The CTS markup and No Significant llazards Considerations havc been updated accordingly.

23.

To resolve NRC comment 3.3.4 2, Discussion of Change LA.5 is deleted since the trip setpoints are the same as the allowable values and do not need to be relocated. Discussion of Change A.12 is added to reflect the retention of allowable values in ITS 3.3.4.

24.

To resolve NRC comments 3.3.4-3,3.3.4-12, and 3.3.416, Discussion of Change LA.3 has been deleted and replaced by Discussion of Change A.13. The ITS maintains the CTS Actions in a different format without a reduction in requirements. The CTS markup has been updated accordingly. The CTS markup was also revised to correct errors in the Action labels for the functions in CTS Table 3.3-1 associated with CTS Action 7, 25.

To resolve NRC comment 3.3.4-4, Discussion of Change L.4 was added to justify placing one channel in bypass and one channel in trip for reasons other than maintenance and testing. The CTS markup and No Significant Hazards Considerations have been updated accordingly.

26.

To resolve NRC comment 3.3.4-6, Discussion of Changes L1 and M 4 were revised to clarify the changes to the containment spray actuation signal Actions.

27.

To resolve NRC comments 3.3.4-7,3.3.4-13,3.3.4-14, and 3.3.4-15, the annotations of footnotes in the CTS were revised consistent with the STS markup and the ITS. Discussion of Changes A.8 and L.2 were revised to correct the footnote references. The reference to Containment Pressure-High function in the footnote (c) was an error and has been deleted.

28.

To resolve NRC comment 3.3.4-9, references to CEOG 89 (TSTF-178) are removed and Discussion of Deviation 27 provided tojustify removal of the phrase," trip or bypass removal."

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ATTACHMENT d)

SUMMARY

OF CIIANGES 29.

To resolve NRC comment 3.3.4-11, Discussion of Change LA.1 was deleted and replaced with Discussion of Change A.14. The requirements for high-pressure safety injection Operability are already specified in CTS 3.5.3 and are unnecessarily duplicated.

30.

To resolve NRC comment 3.3.417, Discussion of Change L.5 was written to justify the exception to LCO 3.0.4 for the Auxiliary l'eedwater Actuation System (AFAS) function.

31.

To resolve NRC commnts 3.3.5-2, 3.3.5 3, 3.3.5 9, and 3.3.510, references to CEOG 99 (TSTF 187) are removed and the ITS revised consistent with the STS, Discussion of Change M.2 is deleted and the CTS markup is revised accordingly to reflect consistency with the STS which does not include two inoperable functions. In addition, the Bases for Actions D and E were revised to ensure consistency with the ITS Conditions D and E.

32.

To resolve NRC comment 3.3.5-4, Discussion of Choe LA.2 was revised to reflect the movement of Engineered Safety Feature Actuation Signal logic circuits which cannot be tested at power to the Bases. The CTS markup was also annotated to clarify the requirement for testing which is retained as ITS SR 3.3.5.1, Note 2.

33.

To resolve NRC comment 3.3.5-12, the word " channel" was removed from the function names in ITS and STS Table 3.3.5-1. The CTS markup was revised accordingly.

34.

To resolve NRC comments 3.3.6-2 and 3.3.6-3, Discussion of Change LA.2 has been deleted and replaced by Discussion of Change A.14. The ITS maintains the CTS Actions in a different format without a reduction in requirements. The CTS markup has been updated accordingiy.

35.

To resolve NRC comment 3.3.6-4, Discussion of Change L.4 was added to justify placing a second channel in trip for reasons other than maintenance and testing. The CTS markup and No Significant Hazards Considerations have been updated accordingly.

36.

To resolve NRC comment 3.3.6 5, Discussion of Change L.1 was deleted and replaced by Discussion of Change A.16. The one hour provided in ITS 3.3.6 Condition C is equivalent to the one hour in CTS 3.0.3, therefore, there is no change in technical requirements.

37.

To resolve NRC comments 3.3.6-7 and 3.3.6-8, Discussion of Change LA.3 is deleted since the trip setpoints are the same as the allowable value and do not need to be relocated. Discussion of Change A.15 is added to reflect the retention of allowable values in ITS 3.3.4. References to TSTF-91 are deleted and the ITS is revised consistent with the STS to include the allowable values in the surveillance requirement.

38.

To resolve NRC comment 3.3.6-9, the Mode 4 Applicability requirement has been added into the ITS. Discussion of Change A.12 has been revised to discuss this change. Appropriate CTS and STS markups have also been made. In addition, the second Applicability [When associated diesel generator is required to be OPERABLE by LCO 3.8.2, "AC Sources-Shutdown"] has not been added. Discussion of Deviation 19 has been revised to provide additional ju:;tification for not including this Applicability in the ITS.

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NITACIIMENT (2)

SUMMARY

OF Cl{ANGES 39.

To resolve NRC comment 3.3.6-10, references to LCO 3.8.2 were removed from the Bases and from Discussion of Change L.2 since the diesel generator loss of voltage instruments are only required in Modes 1,2,3, and 4.

40.

To resolve NRC comment 3.3.4-10, Discussion of Deviation 26 was revised to provide additional clarification on the operation of the sensor block modules and how they are efTectively removed from the circuitry when inoperable.

41.

To resolve NRC comment 3.3.7 3, Discussion of Change L.2 was revised to provide additional clarification regarding the acceptability of the four hour Completion Time to place the radiation monitor channel in trip.

42.

To resolve NRC comment 3.3.7 5, Discussion of Change LA.1 is deleted since the trip setpoints are the same as the allowable value and do not need to be relocated. Discussion of Change A.10 i

is added to reflect the retention of allowable values in ITS 3.3.7.

43.

To resolve NRC comment 3.3.7-6, Discussion of Change LA.3 is deleted and replaced by Discussion of Change A.I.

The requirements for channel functional test of manual purge isolation are retained as ITS SR 3.3.7.5.

44.

To resolve NRC comment 3.3.7-7, a plant specific Discussion of Deviation 37, was written to justify the correction of the logical connector error in the STS and references to CEOG-97 were removed. Additionally, references to CEOG-96 were removed and replaced with plant specific justifications for correcting the errors in the STS. References to CEOG-98 were removed and the ITS revised consistent with the STS.

45.

To resolve NRC comments 3.3.8-1, 3.3.8-2, and 3.3.8-3, tne ITS was revised to include the "During Core Alterations" and "During movement of irradiated fuel assemblies" Applicabilities, and to include the Channel Check Surveillance Requirement. Appropriate changes were made to the ITS Actions, Bases, CTS markup and STS markup. Discussion of Deviation 15 was revised to provide additional justification related to the Modes of Applicability not retained and associated actions for the Control Room Recirculation Signal.

46.

To resolve NRC comment 3.3.9-1, Discussion of Change LA.4 was deleted and replaced by Discussion of Change L.1 since the manual function is not credited in the safety analysis.

47.

To resolve NRC comments 3.3.9 2 and 3.3.9-3, Discussion of Change LA.2 has been deleted and replaced by Discussion of Change A.12. The ITS maintains the CTS Actions in a different format without a reduction in requirements. The CTS markup has been updated accordingly.

48.

To resolve NRC comments 3.3.9-4 and 3.3.9-7, Discussion of Change M.2 was revised to match the shutdown track actions specified in the CTS and ITS. References to CEOG-99 were removed and the ITS and CTS revised consistent with the STS.

49.

To resolve NRC comment 3.3.9-5, Discussion of Change LA.3 is deleted since the trip setpoint is the same as the allowable value and does not need to be relocated. Discussion of Change A.13 is added to reflect the retention of allowable values in ITS 3.3.9.

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ATTACIIMENT m

SUMMARY

OF CHANGES 50.

To resolve NRC comments 3.3.9-8, 3.3.9 9, and 3.3.9-11, Discussion of Change A.11 was deleted and Discussion of Change M.4 was added to describe the addition of the actuation logic to the Chemical and Volume Control System isolation function. Discussion of Deviation 39 was added tojustify only testing actuation logic relays during shutdown.

51.

To resolve NRC comment 3.3.910, the CTS 4.3.2.1.1 markup has been revised to refer to Discussion of Change M.3 rather than Discussion of Change M.4.

52.

To resolve NRC comment 3.3.10-1, LA.2 was revised to indicate the details of the reactor vessel water level instruments are moved to the Bases. The ITS and STS Bases was revised to provide this detail.

53.

To resolve NRC comment 3.3.10-2, ITS Table 3.3.101 was revised to remove the two per loop requirement for hot and cold leg temperature to only require two indicators consistent with the design and the CTS.

54.

To resolve NRC comments 3.3.10-3, 3.3.10-7, and 3.3.10-15, the ITS Bases were revised to identify the diverse means of indication for an inoperable RCS Subcooled Margin Monitor.

Irmed Technical Specification Table 3.3.10-1 was revised to delete the required action for nannels inoperable. Discussion of Change L.! and Discussion of Deviation 22 were

.d to provide additionaljustification and clarification of the plant licensing basis.

55.

To resolve NRC comments 3.3.10-4, 3.3.10-5, 3.3.10-6, and 3.3.10-14, Discussion of Changes LA.8, LA.10, LA ll, and LA.13 were deleted and replaced with Discussion of Change L.7 to justify the deletion of the Mode 4 requirements and the deletion of alarm / trip setpoints and channel functional test for the containment high range area monitors.

56.

To resolve NRC comment 3.3.10-8, Discussion of Change LA.7 was deleted and replaced with L.8 to justify the removal of the non Category 1, non-Type A, variables from the post-accident monitoring specification, 57.

To resolve NRC comment 3.3.10-9, Discussion of Change LA.6 was deleted and Discussion of Change A.6 was revised to provide additional justification for deletion of the core exit thermocouple note.

58, To resolve NRC comments 3.3.10-10 and 3.3.10-11, Discussion of Change LA.12 was deleted and replaced with Discussion of Change L.9 to justify changing the channel check for containment radiation monitors from shiftly to monthly.

59.

To resolve NRC comment 3.3.10-12, Discussion of Change LA.4 was revised to indicate that the details of a channel check for the hydrogen monitor is moved to the Bases ofITS 3.3.10 and new Discussion of Change L.10 was provided to justify the change in frequency from biweekly on a staggered test basis to monthly.

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SUMMARY

OF CllANGES 60.

To resolve NRC comment 3.3.10-13, Discussion of Change LA.9 was deleted and Discussion of Change L.6 was revised to address the removal of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requirement to initiate alternative actions.

61.

An additional change was made to revise Discussion of Changes LA.3 and LA.5 to indicate these details associated with hydrogen monitors are moved to the Bases ofITS 3.3.10.

62.

To resolve NRC comments 3.3.11-1 and 3.3.112, Discussion of Change LA.! is revised to indicate the design details of the remote shutdown instruments are relocated to the Updated Final Safety Analysis Report and to provide additionaljustification for the relocation.

63.

To resolve NRC comment 3.3.113, ITS Table 3.3.11 1, and STS markup were revised to add

" wide range" to the required steam gererator level function.

64.

To resolve NRC comment 3.3.115, ITS Bases 3.3.11 Condition A was revised to remove references to control and transfer switches. The STS markup was annotated accordingly.

65.

To resolve NRC comment 3.3.6-1, new Discussion of Change A.17 was added to justify the deletion of CTS 4.3.2.1.3 and old Discussion of Change L.3 and associated No Significant llazards Considerations was deleted. The CTS markup was annotated accordingly.

66.

To resolve NRC comment 3.3.11-4, Discussion of Deviation has been revised to describe the plant specific reason the LCO has been modified and NUREG SR 3.3.12.2 has been deleted.

67.

To resolve NRC comments 3.3.5-6 and 3.3.5-7, New Discussion of Change L.2 and associated No Significant Hazards Considerations has been provided tojustify the chs,ge in the number of channels required for the AFAS Manual Trip Function. In addition, ouring the development of the response to these questions, it was noted that the addition of the Actuation Logic Channel for AFAS was already covered by Discussion of Change A 8, as shown on the CTS markup page 2 of 10. Therefore, the addition of the Actuation Logic Channel as shown on CTS markup page 4 of 10 has been deleted. Also, the ITS added the Steam Generator 1 and 2 Manual isolation Block Logic as described in Discussion of Change A.9.

After further review, this manual actuation logic is not currently required by the current Calvert Cliffs Technical Specifications and has been removed from the ITS. As a result of these changes, Discussion of Change A.9 is no longer needed and has been deleted.

68.

To resolve NRC comment 3.3.6-11, the Notes to ITS SR 3.3.6.1 have been deleted in lieu of providing ajustification for the addition of the Notes. These Notes were added to describe the manner in which the Actuation Logic is tested. Due to this deletion, the changes to the LCO, which added an Actuation Logic requirement, and Condition D, which added Actions for when the Actuation Logic is inoperable, have also been deleted. These changes (the addition of the Actuation Logic requirements) were not consistent with the Improved Standard Technical Specification (ISTS) nor the CTS, which do not have a requirement for Actuation Logic. They were added to be consistent with other similar Instrumentation LCOs, which require Actuation Logic. However, Calvert Cliffs will not add these requirements at this time but will pursue the change generically at a future time. Appropriate Bases, CTS markup, and ISTS markup changes, as well as the deletion of Discussion of Changes A.13 and M.2 and Discussion of Deviation 25 7

ATTACHMDTr (2)

SUMMARY

OF CIIANGES for Section 3.3, and the revision of Discussion of Change L.2 and associated No Significant 11azards Considerations, have been made, f9.

An additional change was made to revise the Bases ofITS 3.3.4, Applicable Safety Analysis to re-instate the indication that the Engineered Safety Feature Actuation Signal Safety injection Actuation Signal also initiates control room isolation.

70.

An additional change was made to revise the Bases of ITS 3.3.1 and 3.2, Applicable Safety Analysis to clarify that the Rate of Change of Powec-liigh Reactor Protective System trip provides assurance that consequences of events that the trip addresses are much less severe than events initiated from critical conditions. 'llie Rate of Change of Power liigh Reactor Protective System trip serves as a backup to the administratively enforced startup ratc limit.

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IMPROVED TECHNICAL SPECIFICATIONS, REVISION 8 AMENDMENT REVISION BY CHANGE 4

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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 20,1997

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To resolve Nuclear Regulatory Commission (NRC) comment 3.3.1 1, Discussion of Change LA.5 has been deleted and replaced with Discussion of Change L.3. The requirement to -

verify the capability of bypassing functions is not credited in the safety analysis, only bypass

' removal which is retained. The Current Technical-Specification (CTS) markup and No Significant Hazards Considerations have been updated accordingly.

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