ML20198K332
| ML20198K332 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/20/1997 |
| From: | BALTIMORE GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20198K329 | List: |
| References | |
| NUDOCS 9710230326 | |
| Download: ML20198K332 (874) | |
Text
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$p*caC M.o ~5. '5, t T '5 -3/4,4. IN$TRUMENTATION Q[4a @ _
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' REACTOR PROTECTIVEf!NSTRUMENTATION [ OP G hT1 r, , RP5 4. p , x.y . a d .'. . .h h LIMITING CONDITION FOR OPERATI
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,3, SURYEILLANCE REQldRENDITS
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' .. '.*.:.1.1 Each reactor protective EmotfGientaMun chMbe Y M 3'3*I'I riemonstrated 0FIRA8LE by the performance of the ciuumti. ENECK, CNAlblEL CALIBRATION and CNANNEL FUNCTIONAL TEST :; = & n: dur' ; th :'.^^'"' .;. et th: 'r:;2: ret:: Chr '- T;ble 4.',4.
m "[T3.J#.z Ine loq1c r he bypasses s be demonstr d OPERABLE or it& tach reactor $" unless perfo during the eding 92 da L.3 3, 3, g ,3 -
9 W" ~~ ':: all be comonstratec vranA3LE at least once per ie A REFUELING INTERVAL dur g CNAlplEL tRAT ChAtetMng of each channel (B affected by bypass opera __ l t j gua .~ 4 ;. b g , r , ., ,,,a__-....~..,,,,,g t ,4, ,g 5fiM.I.S D The REACTOR TR STDi RESPONSE TIME of ea'ch reactor tr'ip" A,)
function shall be demonstrated to be within its limit at least once per.g REEUFLING INTERVALF i.acn test Mah in ~ude at least one che el per T l '
function such at all channels are ted at least once ev N REFUELIN(
[INTERVALSwh T
e N is the total n of redundarit channe in a specific i reactor tr function as :hown the ' Total .No. of Ch els' coluno ofy)
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Neutron detectors are exempt from response time testing.
CALVERT CLIFFS - UNIT 1 3/4 3-1 Amendment No.108 o
9710230326 971020 PDR ADOCK 05000317 lF ) 4.
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-SURVEILLAllCE REquitEMENTS -
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CALIBRATI0li and CNAINIEL FilNCTI0llAL TEST "a-- ^ - ' - " - - - ~ ~ ' "
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O '* 7 i.3.y tto a Igic reactor for theAefMP a ner " gfmd durtne ses shall be d ted OPERABLE r,7=c="ine 92 b,8 e
'^*' 1 W:: M.;U . she'll be demonstrated artaABLE at least~ence per REFUELIM INTERV during CNAINIEL CALIBRATI0ll. testing of each channel affected by bypes ope 4,,,,,g ;, ( l{ (/. ,I
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, , , , , , , 4,4 E~f!MEoTeachreactort functioii shall be demonstrated to be within its limit at least once per 2 k TVELIM IllTERVAtr.
s Tune tach test snaii msivos as iness one sn.unsi r i I n such thn .11 channels are tested at least once every N FUELIM VALS actor where Nasisshoyn'in trip function the totaltheJumber ' Total No. of redundant of Channelchannels*
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. g Sutrondetectorsareexemptfromresponsetimetesting, "
CALVERT CLIFFS - UNIT 2 3/4 3-1 Amendment No. 186 page IoF 16
DISCUSSION OF CIIANGES 3
SECTION 3.3.1 - RPS INSTRUMENTATION - OPERATING TECIINICAL CIIANGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED DQCUMENTS LA.1 Current Technical Specification 3.3.1.1 Table 3.31 contains a " Channels to Trip" column.
Improved Technical Specification Table 3.3.1-1 will not contain this column. His is an informational column which is more appropriate for the Bases. De number of channels ;n trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Brc.cs will require change in compliance with the Basec Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. De Bases Change Control Program will ensure that changes receive appropriate review, nis change is a less restrictive movement of details change with no impact on safety, This change is consistent with NUREG 1432.
LA.2 Current Technical Specification 3.3.1.1 Table 3.3-1 Endnote f requires at least two decades of overlap between the Wide Range logarithmic Neutron Flux Monitoring channels and the Power Range Neutron Flux Monitoring channels. His is a design detail regarding operation of two types of equipment that is more appropriately maintained in the Bases. This requirement is being moved to the Bases for ITS 3.3.1 He requirement for operability of these functions is not being changed. Any changes to this requirement in the Bases will be controlled in accordance with ITS Section 5.0 Bases Control Program. His Program ensures any changes to these requirements will be adequately reviewed. This change is consistent with NUREG 1432.
LA.3 Current Technical Specification 3.3.1.1 Table 4.3-1 Notes (2) and (4) specifically requires the l adjustment of the Nuclear Power Calibrate Potentiometers and AT Power Calibrated Potentiometers. Improved Technical Specification SR 3.3.1.2 requires that the power rang:
and AT power chann;ls be adjusted. References to the method of adjustment, i.e., the potentiometer, is moved to the Bases of ITS SR 3.3.1.2. Detailed descriptions of calibration equipment is more appropriate in the Bases. The change does not alter the requirement to adjust the two functions based on calirometric results. This change only moves details out of Technical Specifications and does not affect plant safety. He Bases are controlled in accordano with the Bases Control Program in ITS 5.0. These controls ensure that changes to the Bases are adequately reviewed. This change is consistent with NUREG-1432.
LA.4 Not used. l LA.5 Not used. l LA.6 Not used. l LA.7 Current Technical Specification Table 2.2-1 requires the allowable value for Thermal Margin / Low Pressure (TM/L") trip function to be adjusted to be not less than the larger of 1875 psia, or the limits provided i- the Core Operating Limits Report (COLR). How the allowable value is derived will now be contained in the COLR, and the COLR will be referenced by the ITS. Rus, details regarding how allowable values are determined are more nppropriately determined outside the Technical Specifications. This requirement is being moved to the COLR where it can be adequatdy controlled. -
LA.8 i4ot used. l CALVERT CLIFFS - UNITS 1 & 2 3.3.1-6 Revision 8 J
~ _ . . _ _
i l
DISCUSSION OF CilANGES '
SECTION 3.3.1 RP3 INSTRUMENTATION . OPERATING i i
TECHNICAL CHANGES - LESS RESTRICTIVE L.1 Not used.
l L.2 Not used.
l L.3 Current Technical Specification 3.3.1.1, SR 4.3.1.1.2 requires that the logic for the bypasses be demonstrated Operable prior to each reactor startup, unless performed during the preceding 92 days and requires the total bypass function be verified once per refueling interval (24 months). _ Manually or automatically inserted bypasses allow plant operation under conditions that do not require the respective RPS functions, but would result in an unnecessary RPS trip if they were not bypassed. %c total bypass functions remove these bypasses when the plant conditions no longer support allowing the bypasses, improved Tecimical Specification SR 3.3.1.8 requires the total bypass fimetion be verified every 24 months. His is consistent with safety analysis assumptions that the automatic bypass removal function operates. He capability to bypass a function when it is not needed is not assumed in safety analyses since it performs no mitigative function. Herefore, this requirement is deleted from the Technical Specifications. His change is consistent with NUREG-1432.
L.4 Current Technical Specification 3.3.1.1 Action 2.c pennits a second channel to be placed in bypass for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for maintenance or testing when one channel is inoperable and placed in the trip condition. Improved Technical Specification 3.3.1 Action B will pennit one channel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance. His change is acceptable since the cause of the inoperability, either planned or unplanned, has no different impact to the overall safety.
His change would avoid an unplanned shutdown and associated transient due to an unforeseen channel inoperability. This change is consistent with NUREG 1432.
CALVERT CLIFFS - UNITS 1 & 2 3.3.1-7 Revision 8 M.
l 1
NO SIGNIFICANT HAZARDS CONSIDERATIONS '
SECTION 3.3 - INSTRUMENTATION 3.3.1 Chance L3 1.
Does the change involve a significant increase in the probatility or consequences of an accident previously evaluated?
The proposed change removes the requirement to demonstrate that RPS functions can be bypassed when not needed. He RPS bypass capability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. He automatic removal feature of the bypasses is not affected by this change. Herefore, the consequences of an event are not affected since the function will continue to be required to mitigate applicable events.
Therefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
2.
Does the change create the possibility of a new or different kind of accident from any
, previously evaluated?
This change will not physically aiter the plant (no new or different type of equipment will be installed). The changes in requh ' testing methods goveming normal plant operation are consistent with current safety analysh assumptions. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction la margin of safety?
The capability to bypass a function when it is not needed is not a credited function in the safety analyses since it performs no mitigative function. The capability to automatically remove any function from the bypassed condition is assumed in the safety analysis since the function is assumed to operate as required to mitigate analyzed events. The proposed change does not alter or delete any requirement used to preserve tiie assumptions in the applicable safety analysis, therefore, the change does not result in a significant reduction in a margin of safety.
3.3.1 Chanee L.4 1.
Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change provides actions when two channels are inoperable for any reason, in addition to maintenance and testing. The allowed outage time for channel inoperability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. 'Itc consequences of an event are not affected since the function is already permitted to have two inoperable channels for the same allowed outage time for maintenance and testing activities. Therefore, the proposed change does not result in a significant increase in the 4
probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
This change will not physically alter the plant (no new or different type of equipnient will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
9 CALVERT CLIFFS - UNITS 1 & 2 3.3-6 Revision 8
- 2. To resolve NRC comment 3.3.13, Discussion of Cf age LA.2 is revised to reflect tiat the design detail of overlap between the wide rar.ge and power range nucicar instrumenta. ion is moved to the Bases.
I
RPS-Instrumentation-Operating
[ B 3.3.1
. BASES-
" The Power Range excore nuclear-instrumentation drawers,- -
_Themal' Margin / Low Pressure (TM/LP) calculators, and Axial E Power Distribution (APD) calculators, are considered
- components in the measurement channels. The power range nuclear instiuments (NIs) provide _ average power and-f
" subchannel deviation signals. The wide range NIs provide a Rate of Change of Power-High Trip. Two decades of overlap-
- l. are provided between the power range NIs and the wide range 9 NIs.- Three RPS trip functions use a power- level designated
- as Q power as an input. Q power is the higher of NI power and primary calorimetric power (AT power) based on RCS hot
- leg'and cold leg temperatures. Trip functions using Q power
- as an input include the Power Level-High, TM/LP, and the APD
! trips.
4
, The TM/LP and APD calculators provide the complex signd processing necessary to calculate the TM/LP-trip setpoint, Asyw.etric Steam Generator Transient (ASGT) trip setpoint, APD trip setpoint, Power Level-High trip. setpoint, and
- Q power _ calculation.
L >
The excore NI drawers (wide range and. power rang!) and the -
e TM/LP and APD calculators are mounted in the RPS cabinet, with one channel of each in each of the four RPS bays.
Four measurement channels with electrical ano physical separation are provided for each_ parameter used in-the direct generationiof trip _ signals. ' These are designated channels A through D. Measurement channels provide input to one or more RPS bistables within the same RPS channel. In
_ addition, some measurement channels may also be used as inputs to Engineered Safety Features Actuation System (ESFAS) sensor modules, and most provide indication in the control room. Measurement channels used as an input to the RPS are never used for control functions.
E When a measurement channel monitoring a parameter exceeds a predetemined setpoint, indicating an unsafe condition, the bistable Lin the bistable trip unit monitoring the parameter I
i e'
{ CALVERT CLIFFS - UNITS-1 & 2 B 3.3.1-3 Revision f 8 m-,--yy ,- - -- ,,,.g - - -s r- n- w
DISCUSSION OF CIIANGES SECTION 3.3.1 - RPS INSTRUMENTATION - OPERATING TECIINICAL CH'..lGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED DOCUMENTS -
LA.1 Current Technical Specification 3.3.1.1 Table 3.31 contains a " Channels to Trip" column.
Improved Technical Specification Table 3.3.1-1 will not contain this column. This is an informational column which is more appropriate for the Bases. He number of channels to trip will not be changed. He information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that changes receive appropriate review. His change is a less restrictive movement of details change with no impact on safety. This change is coasistent with NUREG-1432.
LA.2 Current Technical Specification 3.3.1.1 Table 3.3 1 Endnote f requires at least two decades of overlap between the Wide Range Logarithmic Neutron Flux Monitoring channels and the Power Range Neutron Flux Monitoing channels. His is a design detail regarding operation of two types of equipment that is more appropriately maintained in the Bases. His requirement is being moved to the Hoes for ITS 3.3.1. The requirement for operability of these functions is not being changed. Any c%nges to this requirement in the Bases will be controlled in accordance with ITS Section 5.0 Bases Control Program. This Program ensures any changes to these requirements will be adequately reviewed. This change is consistent with NUREG-1432.
LA.3 Current Technical Specification 3.3.1.1 Table 4.3-1 Notes (2) and (4) specifically requires the l adjustment of the Nuclear Power Calibrate Potentiometers and AT Power Calibrated Potentiometers. Improved Technical Specification SR 3.3.1.2 requires that the power range and AT po,ver channels be adjusted. References to the method of adjustment, i.e., the potentiometer, is moved to the Bases of ITS SR 3.3.1.2. Detailed descriptions of calibration equipment is more appropriate in the Bases. The change does not alter the requirement to adjust the two functions based on caliro: etric results. This change only moves details out of Technical Specifications and does not affect plant safety. The Bases are controlled in accordance with the Bases Control Program in ITS 5.0. These controls ensure that changes to the Bases are adequately reviewed. This change is consistent with NUREG-1432. ,
LA,4 Not used. l LA.5 Not used. l LA.6 Not used. l LA.7 Current Technical Specification Table 2.2-1 requires the allowable value for T'.,ermal Margin / Low Pressure (TM/LP) trip function to be adjusted to be not less than the larger of 1875 psia, or the limits provided in the Core Operating Limits Report (COLR). How the allowable value is derived will ncw be contained in the COLR, and the COLR will be referenced by the ITS. Rus, details regarding how allowable values are determined are more appropriately determined outside the Technical Specifications. This requirement is being moved to the COLR where it can be adequately controlled. -
LA.8 Not used. l CALVERT CLIFFS - UNITS I & 2 3.3.1-6 Revision 8
.. . . . . . - . . . - - - . _- . .. . ~ . - _ . _ - - - . - - _ . - . . . . .
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RPS Instrumentation-Operating B 3.3.
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BASES
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i E occurrence.' Meett acce able dose felt for an (continued) a$cident category i t9hnsequences ror th ensidered having a optable event.- .
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- The RPS is segmented late four interconnected modules.
These modules are:
.* Measurement channelsi i
L
- Bistable trip units; M m s+ra~.. 4 cE. .I, gl
- RPS Logic; and e*-'***., . r' a we %
Reactortripcircuitbreakers(RTC8s).
j D* * * * ~ M < 6. ~ , t i
- "' - Giu t.e p 4 . 'p ,4 This LC0 addresses measurement channels and bistahle trip p*':*** units.- It also addresses the automatic bypass removal e w ,4 -.c feature for those trips with operating bypasset. The RPS Logic and RTCBs are addressed in LC0 3.3.3, ' Reactor-
, e. . D . . i, ,,, Protective System (RPS) Logic and Trip Initiatly.a."
The role of each of these modules in the RPS, including f-.
g those associated with the logic and RTC8s, is discussed below.
g g, ,,,,5, J,,,,,
c..s.
- Measurement Channels . . , ,
pe .er . ,. 4 % tw. ,g
- Measurement channels, consisting of f d transeo~. . * .? t"" 5
- beg a process sensors and associated inst ntation, provide a 4
seasurable electronic signal bas pon the physical L characteristics of the paramete ing seasured.
- JMe,3 $r d Q Th excore nuclear ins _trueerpatiner and m<analefcorD MroteeHan calculatorsIrussare considered components in
+ 1-~ P,ru s,< (Tm te) f J Mr C*I'vidor5f ard AvraAThree l instruments (N!s provide a RPS triq$ u)se a power evethe measurement Rate of Chang p @ '
ch p'**' pI'I^ W designated as Q power as 4
t f an input. Q
~ calorimetric leg r is the higher of NI power and primary r (AT power) based on RCS het leg and cold h
%h (dg'vyM, the(m "-
u s. Tri d ucine c ::_;r as an input include
- - Powe -
- !""
- Hi h Thermal
" Marg li71".w ssure /Lrp, p Distribution APO) igh trips.
theAxalPower Tuo beabei(NcerIag
! o.rs prov4ed ht+weevs 3
level i - t h p wer m a OIs "e* -a s
)
4 1"d N N8-?*1" U8'_ -
(continue;)
CEOG STS B 3.3-2 Rev 1, 04/07/95 k
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$ 3. To resolve NRC c >mments 3.3.14 and 3.3.1-20, Discussion of Change LA.6 has been deleted and replaced by !)iscussion of Change A.18. ;The improved Technical Specification (ITS) ;
1 maintains the CTS Actions in a different format without a reduction in requirements." The' CTS markup has been updated accordingly, i
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g TABLE g g, REACTOR PROTECTIVE RUMENTATI0li n Re 4,bh 3 3 3 . ,.
- stes t.9.c awru A.2 -IN j 7 FINICTI0hAi-411M 6 (0F CIIAlttELS j _ _ _ _E) MODES ACTIolt e .
- 1. Manual Reactor Trip -
2 1 2 1, 2 and -
l 1 ( s.
D. Pctrer Level - High
- 3. Reactor Coolant Flow - Le i
4/SG
'g F2 L A- I 1, 2 h
r /SG 1, 2 aw j ;
- 4. Pressurizer Pressure - High 4 1 0 3 " 1, 2 j
S. Containment Pressure - High 4 2 3 1, 2
- 6. Steam Generator Pressure - Low rp e 7 7. Steam Generator Water Level -
4/SG 4/SG
[/ 3/SG 1, 2
~
, 2 3/SG 1, 2 Y l" .a,. Dat%A. Hr
" . e
- 8. Axial (Fly (@fse 4
- 9. a. Thermal Margin / Low Pressure 4
3 3
J1, 2 [
i
- b. Steam Generator (EpessurD dTTI<tener- 4 .p l#9b 4
~
[ h' 3 1, 2 g 10. Loss of Load' Q ([
3 J
A.i a
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ro t
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s 9
e V Y '
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? j i
g T (Continued)
.' G ' '
R g REACTOR Pe8TECTIVE INSTRW E RATION w
5 /
ITOT
@ e f q]' pt 4FFLIGAttf i
FUNCTIONAL-UN55 h, h LS ' TO Ju1P I IWBES ACTISE i
e 11. Wide Logarithmic M ,I /e ;
-]~
Flu itor , u,1 g,4
. STARTWP and ting -- *
- 1. 2 a (9 "'** "' '" """ -
High- ^'* --
"2 i*A.il
^
- b. Shutdown 4 M. I
-w f12. Reactor Protection System Logic 6 0 2 3. 4. 5 3) g 1 6 1. 2-A Matrices 4- i
[ 33. Reactor Protection System Log'ic 4/ Matrix 3/ Matrix 4/ Matrix 1. 2* 4 Matrix Relays
'i
, k4. Reactor Trip Breakers '8 6 8 1. 2* 4 g
h bso.us., of ^ }
= .,4 %==S *M 3 3. 2, "
US %.<.A l
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r<:er.AA% I y . ,
Y Y S%L30en e( &w 0 5 ?snu- s.s. z e r~u a .u, v' P
- r 2
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- s. b w.u,., .f cA. .g w k evf.v% 3. 5,12.)
4 L I m nWOylaydlm'c, N<< Aron Fl.is I A %.d.,. Chocis I t
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. he4e.b d es *1 3. l 6ddik Ir f v..i ,
3/4.3 INSTRIMDITAT1001 TE-L ;.L '0enue.ed) g pg g 4 TABLE NOTATION WSM 3 3
- E ."" P5 r,,sb,.k% - st +.tu
) With the rotective system trip breakers in the closed position and w the CEA d ive system capable of CEA withdrawal.
J C
(LT M The provisions of Specification 3.0.4 are not, applicable.
d
@ $ may be bypassed below 10 of RATD TNERNAL POWER bypass shall h
be~ automatically removed when THERMAL POWER is 1 10d of RATED THERMAL POWER.
- u. M may be manually %ypassed below 785 psia; bypass shall be automatically removed at or above 785 psia.
Fedad' N N -
may be b a..;ed below 15% of RATED THERMAL POWER bypass shall e automatica y removed when THERMAL POWER is t 15% of RATED THERMAL POWER.
l
" M bypassed beinw indar and 2have 32% of a1Jrn L
n.a u
$ed ~'$3 E f [- d i f _(f'*y
- 9 8'(l2_ 4 _ _ @,Q (j,) may be bypass testino pursuant to_Snecial Tett- -
ception nh Wr3. .
fa ,,-. s u 6. ,, G @ '_g g. s
- 9 '
re shall be at least t decades of overla etween the Wide Ra e' ogarithmic Neutron F1 nitoring Channel Nauteen rlur Monitorin, h====1*
d the Power Rang Ai ACTION STATEMENTS
@TIONI- With the number of channels OPERABLE one less than required 5'* 0'st.n e.. .c d*
- f 5644.
)bytheMinimumChannelsOPERABLErequirement,restoretheinoperable 3+ 3 J, "" Af s chan in NOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and/or open the y 'y t * * ' T ' * ** ' b.". .
Jrotective systeem trin hr==lrart -
0 ACTION g -
With the number of OPERA 8LE channels one less than the Total ,
,f8 Number of Channels. STARTUP and/or P0MER OPERATION may 1 proceed orovided the follesing conditions are satisfied:
- a. The inoperable channel is placed in either the bypassed j{j((pe[cong{on within 1, hour. Fo
- cgi,,pc ef
. _ _ . _ . . . . . . . . . ... ,..-. - .......... _, {_
d CALVERT CLIFFS - UNIT 1 3/4 3-4 Amendment No. 169 s-py 4 fi4
Spu Sc.4 % g,3,l m- y one c m 4 ,;h.ns u M. & . , 3/4.3 INSTRUMENTATION insee. k Ms ht.sts % .As or
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+ onood 4Js. A br!!W '^ ; h 8 hours from time of initial loss of OPERABILITY: however. .the inoperable channel shall then be either restored to OPERABLE s+atus or placed in the tripped condition.
'b . Wit one hour, 41 runcti al units receiving an puU f the inoperable chann are also placed in t same _.
ndition (either b
'l i or tripped, as appi ble) ast
( j hat reci ired by a,ypasa e for the inoper3ble a,mel . J Aus,a ,8 TM "' 'ni "naxh ^*2M:I :ts.a-- M r:. = :ddi:N.:i :bn=?6.::^r.t' may be bypassed fo to 48 hours /W Wie serrorseno taars a r mainis ance4 (chaeffitFfprovided the other inoperable channel 15 ace
.in the~ tripped FACTION 3 -
io
~
ggy With the numoer of cnannels vre.aAsLE one less than Tequired by the Minimum Channels OPERABLE requirement, verify M (w=4; i compliance with the $NUTDOWN MARGIN requirements of P Specification 3.1.1.1 or 3.1.1.2, as applicable, within- M. I j 1 hour and at least once per 12 hourt thereafter. J { Aclaun 4 - With the number of channels OPERABLE one less than requireQ by the Minimum Channels OPERA 8LE requirement, be in HOT STANDBY within 6 hours however, one channel may be bypassed for up to 1 hour for surveillance testing per Specification 4.3.1.1. I s i %e besusu s & <>m^"p %e Spu,4b., 3, L3,"g es L 9A. - '
' aal TrIr T.,Uhen'*
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- 5. Containment Pressere - Ittsk 4 2 3 1. 2
- 6. Steam Generator Pre.sur - Law 4/3G
, 1. 2 2 7. Stees Generator h ter Level - 2/38 4/3Gh 3/3E 1. 2 i
- 8. Am 4 3
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With the pmtective system trip breakers in the closed position an@ MutnE '**4!L he CEA drive system capable of CEA withdrawal.e g, / The provt: Ions ef SpecIfIcetien 3.0.4 are not app 11 cable. (b) N may be bypassed below lod of RATED TurleEL Peyt bypass sh411 automaticall M .+ r THEIWEL POWER. y removed when TutipML POWER is a 10 of RATED M bfmanua11yb st g, cally removd kassed or abovebelow 785 ps745 fa.at bypass shall be (d) may be bypassed below 1R of RATtt TWERNAL POWER bypass shall automatically removed when TutalEL POWtt is a 1H o:f lutits TutRNAL POWtt. l'..+ 6c M A* $od. ( ((q . Byp. hwnassed hataw 108% and_above 12% of e...t bc _ q.h e.it y , ,-. . . y o* $$' J. 4. t"JyTD EggL U **4 M
/b may be b *assedjluria0 Jetting aprsuaat3a 5.c14,1,littm r Qive... . w i 3_c. 4. ..p ,.ip __
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'al{ TP tra De at least two decs N {Logartt of overlap between )he Wide Range' c Neutron Flux Monito ng Channels and the J6wer tanne
, heut Flux Monitoring Chan s. f A L-_A ' . ACTIONSTATEMENTS
- h!0N1 W1',h the number of channels OPERA 8LE one less than requ br the Minimum Channels OPERABLE requirement, restore the
- -) inoperable channel to OPERA 8LE status within 48 hours or be in ROT STANDBY within the next 6 hours and/or open the j g t protective system trip breakers. -
ACTIONJ- With t.h4 naber of OPERABLE channels one less than the Total Number of Channels, STARTVP and/or POWER OPERATION may A* proceed provided the following conditions are satisfied
- a. The inoperable channel is placed in either the bypassed jg,jg h
or tripped condition within 1 hour. T;- th; ; m
-te; tin; nd =ht=. ;e. the i=;=ble 9--5 ra:y:e te ^f 4 w t%.u.., .r chy , 4 4ec h b 13.1,*grs Q 64 try ;..%.1m 's CALVERJ Ct!FFS . UMlf 2 3/4 3-4
- Amendment No. 149 1
4
Sp.. .r . . t ..s % '~3. 5 . ) l 3/4.3 1N$TRUNutTAT10N
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- s om2 w.i.*w e u . 4 * +. m ACTioy A &;;g i ;; ;.[ hours from time of indtal loss of Ob1LETY: however, the inoperable channel shall then be either restored to SPERA8u status or placed in the trfpped condition.
i .' W<, Min one hour all f ifonal unita rece1y1 .i input' setheinoperble condition either nnel are also placed sted or trip the same 'b - u that_reeut b .ahawaforthafma. as Itcable as aekanaal). ; g{p49 A.,yw g .4Wr'T M "'- b r fi n n u Z "-' n ;'. -
..; 1. . a -
M* 8M h _... . ,,- veiU .; :tz:_d =v he bynamned o o b'@'av'"U* ; - 48 hars/W re ; _.... ins 4tsto d arfatanthe 1 Af3 leis 4*We
";;'7prov' 000 tne etner Inoperable channe **h '"
s pie:ec In t W tr{pped ittaa. _ .. h e.* M 3 foe 4'rc+ O't *OQ Ases ACTION 3 - With the number of c==ss we- -_ .. vess snan requ *$*l lap 1.V by the Minimum Channels SPERABLE requirement, vertfy A . (, compitance with the SNUf90Wh MAR $1N requirements of 5pecification 3.1.1.1 or 3.1.1.2, as ap Itcable, within "'4
^
1 hour and at least once per 12 hours t resfter. l L * ' 104 4 With the number of channels OPERABLE nne less than required
- by the Minimum Channels OPERABLE requirement be jn NOT STANDtY within 6 hours however, one channel may be bypassed for up to 1 hour for surveillance testing per Specification ;
4.3.1.1. f
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4 CALVERT CLIFFS . UN11 2 3/4 1 5 Amendment No. 149 p #5 .F 14
DISCUSSION OF CilANGES SECTION 3.3.1 RPS INSTRUMENTATION OPERATING A.17 Current Technicrj Specification 3.3.1, Table 4.31, requires a Channel Check for the Wide Range logaritlunic Neutron Flux Monitor. Improved Technical Specification 3.3.1 1 includes the Logarithmic Neutron Flux Monitor in the Rate of Change of Power liigh Function. Ilowever, the Channel Check only applies to the monitors. Rus, a Footnote (f) was added to the ITS which clarifies this. This change is administrative since the CTS already depicts this. A.18 Current Technical Specification 3.3.1.1 Action 2.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 2.b requires that witidn one hour all functional units recching an input from the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 3.3.1 Condition A requires one or more functions with one RPS bistable trip unit or associated rneasurement channel inoperable be placed in trip or bypass in one hour. The ITS Condition A captures the technical intent of CTS Action 2.a and 2.b by requiring that all affected functions take the specified actions, therefore, the change is administrative. This change is consistent with NUREO 1432. TECilNICAL CilANGES - MORE RESTRICTIVE M.! Current Technical Specification 3.3.1.1 Action 2.c does not specify a time for the additional inoperable channel to be placed in bypass improved Technical Specification 3.3.1 Action 11 will require one channel to be placed in trip and one channel to be placed in bypass in one hour. This change essentially places a one-hour time limit, where none previously existed, to perform the Actions. His change is, therefore, a more restricthc change. The change will not adversely affect plant safety. This change is consistent with NUREG 1432. M.2 Current Technical Specification 3.3.1.1 requires the Actions for the functional units be followed when a bypass removal channel is inoperable. Improved Technical Specification 3.3.1 established Actions specifically for when one or two bypass removal channels are inoperable (ITS Actions D and E). The Actions are essentially the same as when one- or two-trip units are inoperable, except that the bypass channel is required to be disabled within one hour. The addition of this new requirement is considered more restrictive. The addition of this requirement will not adversely affect plant safety, because the action to disable the bypass channel when the automatic bypass removal is inoperable ensures the trip is in effect. His change is consistent with NUREG 1432. M.3 Current Technial Specification 3.3.1.1 does not have any requirements if an Action cannot be completed within the required Completion Time. Hus, CTS 3.0.3 would have to be entered. Current Technical Specification 3.0.3 allows 7 hours to reach Mode 3, or Mode 2 for those functions which are only applicable in Mode 1. Improved Technical Specifica* ion 3.3.1 added two Actions (Action F and 0), when the Required Action and Associated Completion Times cannot be met. Action (F) allows 6 hours for Hermal Power to be reduced to < 15% RTP, and Action (0) allows 6 hours to place the plant in Mode 3. Two actions are necessary since the associated functions have different modes of applicability. His change essentially allows one less hour to be outside the Mode of Applicability, however, adequate time is still allowed to reach the required plant condition. Therefore, this change will not adversely affect plant safety. l CALVERT CLIFFS - UNITS I & 2 3.3.1-4 Revision 8
DISCUSSION OF CilANGES SECTION 3.3.1 RPS INSTRUMENTATION . OPERATING TECHNICAL CilANGES . MOVEMENT OF DETAILS TO LICENSEE CONTROLLED DOCUMENTS LA.I Current Tecimical Specircation 3.3.1.1 Table 3.31 contains a " Channels to Trip" column. Improved Technical Specification Table 3.3.11 will not contain this column. This ie an informational column which is more appropriate for the Bases. He number of channels to trip will not be changed. %e information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0, llowever, any hardware change to the number of channels to trip will require a design change. He Bases Change Control Program will ensure that changes receive appropriate review, His change is a less restrictive movement of details change with no impact on safety. His change is consistent with NUREG 1432, 1 LA.2 Current Technical Specification 3.3.1.1 Tabic 3.3 1 Endnote f requires at least two decades of overlap between the Wide Range Logaritlunic Neutron Flux Monitoring channels and the Power Range Neutron Flux Monitoring channels. His is a design detail regarding operation of two types of equipment that is more appropriately maintained in the Bases, This requirement is being moved to the Bases for ITS 3.3.1. He requirement for operability of these functions is not being changed. Any changes to this requirement in the Bases will be controlled in accordance with ITS Section 5.0 Dases Control Program. His Program ensures any changes to these requirements will be adequately reviewed. This change is consistent with NUREG 1432. t LA.3 Current Technical Specification 3.3.1.1 Table 4.3 1 Notes (2) and (4) specifically requires the l adjustment of the Nuclear Power Calibrate Potentiometers and AT Power Calibrated Potentiometers. Improved Technical Specification SR 3.3.1.2 requires that the power range and AT power channels be adjusted. References to the method of adjustment, i.e., the potentiometer, is moved to the Bases ofITS SR 3.3.1.2. Detailed descriptions of calibration equipment is more appropriate in the Bases. He change does not alter the requirement to adjust the two functions based on calirometric results. His change only moves details out of Technical Specifications and does not affect plant safety. He Bases are controlled in accordance with the Bases Control Program in ITS 5.0. %csc controls ensure that changes to the Bases are adequately reviewed. This change is consistent with NUREG 1432. LA.4 Not used. l LA.5 Not used. l LA.6 Not used. l LA.7 Current- Technical Specification Table 2.21 requires the allowable value for Thennal Margin / Low Pressure (TM/LP) trip function to be adjusted to be not less than the larger of 1875 psia, or the limits provided in the Core Operating Limits Report (COLR). Ilow the allowable value is derived will now be contained in the COLR, and the COLR will be referenced by the ITS. Hus, details regarding how allowable values are determined are more appropriately determined outside the Technical Specifications. This requirement is being moved to the COLR where it can be adequately controlled. - LA.8 Not used. l CALVERT CLIFFS - UNITS I & 2 3.3.1-6 Revision 8
i 4 To msolve NRC comment 3.3.15, Discussion of Change LA was added to justify placing a ! necond channel in trip for reasons other than maintenance and testing. The CTS markup and No ! Significant liarards Considerations have been updated accordingly, j
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-i 5 2::!f 4 ; t: b44 hours from time of initial loss of OMRABILITY: however. .the Inoperable channel shall then be either restored to OPERA 8Lt status or placed in the tripped condition.
t
'b . Wit one nour als runcti al units receiving an pull f the inopera,ble chan are also placed in t same j
ndition either b ,( i hetreentr(edbya.ypes or tripped, as appl ble ' i
- ( a a fo_r.,the inmoable mal.)as'J ,
, u m_u .m.___ _ ----.... ___ ._. . , , _ .
Acts..i A J;;d d:n! may be lwnassedafor up to 48: haer:1
- . @- ;as ;r yo,_ t m anraat s=anca tcm;Hproviced 3he otner noperable c '
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Jo - - i With the nt er of snanness ersuasi.E one less then require q by the Minimum Channels OptRA8LE requirement, verify A4 wh-- g compliance with the S M T90lAl MARG!ll requirements of t i ( Specification 3.1.1.1 or 3.1.1.2, as applicable, within I hour and at least once ner 12 hours thereafter. a
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mu sen 4 - With the number of channels SPERA8LE one less than requireQ 4 by the Minimum Channels OptRA8LE requirement, be in 110T 4 STANDSV within 6 hours: however, one channel may be bypassed for up to I hour for surveillance testing per specification 4.3.1.1. i j ke bes.iu.% .6 c.L.a p t.c s,. ~ .. o . m ;. m t. . . h aai Tde L 4b.n" gg.3 6e r Ac p..i b l, M'? c -m u o,,-, .. .c r., n
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.d O , b[however, hours from time of initial less of the i be either restored to Sp rable channel shall then tripped condttion. status er placed in the i.' W n theone hour all f itonalun1tareceiVi '
Inoperable 1nput' A nnel are aise placed the same ' condition (either OB u that_reeutred by ."ssed or tripped, asfor theItt-u - a e " cable) as-- _ i gg!(- 1. _ , g A t sow 6 .e 4 N '" ' r ? :- : b ^^^^^f' " 7. ,.'.. __ .f. ;. w o V l i; .... . -- ...i&,.; :t:d saw he bynamned der as
#*'h' M* I 48 hoursM77e n... ins 4WatorimYntagshc jjiiiR)to b43 'a 1.*uv'".6Jt c 'Tyrevitse the etner inoperable channe s pla;ec in tne tripped c ittaa
*+
ACTION 3 With the number of_enanne%p.sM s. Tor 4 utt* O'f***D'" A8"g' *ll y ss w __ n
.. its: snan requiraiD by the Minimum Channels OPERABLE requirement, vertfy compitance with the SNUTDolet MARGIN requirements of A
=
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\ Spectfication 3.1.1.1 or 3.1.1.2, as appitcable, wtthtm " ' w' '
(1 hour and at least once per 12 hours thereafter. l
# (ACTION 4- W1th the number of channels OPERABLE one less than required I O'
[ ) b the Minimum Channels OPERABLE requirement be in NOT 5 AllDlY within 6 hours however, one channel,say be bypassed for up 4.3 1.1.to 1 hour, for survet11ance testing per Specification ;
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DISCUSSION OF CHANGE 8 SECTION 3.3.1 o RPS IN5iTRUMENTATION - OPERATING TECHNICAL CHANGES 1,ESS RESTRICTIVE L.1 Not used. l L.2 Not used. l L.3 Current Technical Specification 3.3.1.1, SR 4.3.1.1.2 requires that the logic for the b> passes be demonstrated Operable prior to each reactor startup, unless performed during the preceding 92 days and requires the total bypass function be verified once per refueling interval ! (24 months). Manually or automatically inserted b> passes allow plant operation under i conditions that do not require the respective RPS functions, but would result in an unnecessary RPS trip if they were not b> passed. De total bypass functions remove these bypasses when the plant conditions no longer support allowing the bypasses. Improved Technical Specification SR 3.3.1.8 requires the total bypass function be verified every 24 months nis is unsistent with safety analysis assumptions that the automatic bypass removal function operates. The capability to bypass a function when it is not needed is not assumed in safety analyses since it performs no mitigative fi nction. Therefore, this requirement is d:leted from the Technical Specifications. His change is consistent with NUREG 1432. L.4 Current Technical Specification 3.3.1.1 Action 2.c pennits a second channel to be placed in bypass for up to 48 hours for maintenance or testing when one channel is inoperable and placed in the trip condition. Improved Technical Specification 3.3.1 Action B will permit one channel to be placed in trip and one channel to be placed in b> pass in one hour and require one channel be restored in 48 hours. His is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance. His change is acceptable since the cause of the inoperability, either planned or unplanned, has no different impact to the overall safety. This change .vould avoid an unplanned shutdown and associated transient due to an unforeseen channelinoperability. This change is consistent with NUREG 1432. CALVERT CLIFFS - UN'iiS I & 2 3.3.1 7 Revision 8 Y
NO SIGNIFICANT !!AZ,ARDS CONSIDERATIONS SECTION 3.3 - INSTRUMENTATION 3.3.1 C ham . I a 1. Does the change involve a significant increase la the probability or consequences of an accident previously evaluated? ne proposed change removes the requirement to demonstrate that RPS functions can be bypassed when not needed. He RPS bypass capability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. He automatic removal feature of the bypasses is not affected by this change. Herefore, the consequences of an event are not affected since the function will continue to be required to mitigate applicable events. Herefore, the proposed change does not r:sult in a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
%is change will not physically aber the p? ant (no new or different type of equipment will be installed). He changes in required testing methods governing normal plant operation are consistent with current safety analysis assumptions. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
He capability to bypass a function when it is not needed is not a credited function in the safety analyses since it performs no mitigative function. The capability to automatically remove any ftmetion from the bypassed condition is assumed in the safety analysis since the function is assumed to operate as re:luired to mitigate analyzed events. De proposed change does not alter or delete any requirement used to preserve tlie assumptions in the applicable safety analysis, therefore, the change does not result in a significant reduction in a margin of safety. 3.3.1 Chanee LA 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change provides actions when two channels are Inoperable for any reason, in addition to maintenance and testing. De allowed outage time for .harmel inoperability is not assened to be the initiator of any analyzed event, therefore, the probability of an event is not affected. The consequences of an event are not affected since the function is already permitted to have two inoperable channels for the same allowed outage time for maintenance and tetting activities. Therefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? This change will not physically aker the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated, CALVERT CLIFFS - UNITS I & 2 3.36 Revision 8
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.3 - INSTRUMENTATION
- 3. Does this change im olve a algnificant reduction in margin of safety?
He current Technical Specifications already permit a second RPS channel to be inoperable for maintenance and testhg purposes. He proposed change extends this to any cause of channel inoperability. He failure of a channel is an infrequent event when compared to the frequency of routine maintenance and testing (e.g., channels are tested quarterly). De proposed change does not alter or delete any requirement used to preserve the assumptions in the applicable safety analysis, therefore, the change does not result in a significant reduction in a margin of safety. 3.3.2 Chanee L1
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change revises the Applicability for the Rate of Change of Power High functional unit from when any reactor trip circuit breaker (RTCB) is closed and any control element assembly (CEA) is capable of being withdrawn to Modes 3,4, and 5, when any RTCB is closed and any CEA is capable bf being withdrawn. This change deletes the requirements for this trip function in Mode 6, and when the reactor ,s defueled. The Rate of Change of Power liigh RPS
, trip is not an initiator of any analyzed event. Als change maintains consistency with the safety analysis. The CEA withctrawa:, ,its are not postulat d in Mode 6 and cannot occur when the reactor is defueled. Boron Dilution in Mode 6 is not terminated by a reactor trip. The proposed !
change does not significantly alTect initiators or mitigation of analyzed events, and therefore does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
He proposed change icylses the Applicability for the Rate of Change of Power - liigh functional unit from when any RTCH is closed and any CEA is capable of being withdrawn to Modes 3,4, and 5, when any RTCB is closed and any CEA is capable of being withdrawn. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. De proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change invelve a significant reduction la margin of safety?
The proposed chann revisn the Applicability for the Rate of Change of Power - High functional unit from when any RTCB is closed and any CEA is capable of being withdrawn to Modes 3,4, and 5, when any RTCB is closed and any CEA is capable of being withdrawn. 'this change essentially deletes the requirements for this trip function in Mode 6 and when the reactor is defueled. The change maintains consistency with the safety analysis by deleting Modes of Applicability that are not applicable. He CEA withdrawal event and boron dilution events are not postulated in Mode 6 and cannot occur when the reactor is defueled. Therefore, the change does not involve a significant reduction in a margin of safety. CALVERT CLIFFS - UNITS 1 & 2 3.37 Revision 8
5, To resolve NRC comment 3.3.16, Discussion of Change L2 has been deleted and replaced by Dir.cussion of Change M.4 since the addition of a time limit to the existing surveillance in more restrictive. Dir.cussion of Change I.A.8 has been deleted and replaced by existing Discussion of Change A.7 which already justified deleting references to operation with less than the required Reactor Coolant System (RCS) loops since that configuration is not permitted by ITS 3 A.4. The CTS markup has been updated accordin' gly. To resolve NRC comment 3.3.17, Discussion of Change Lt 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. 4 i F
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i DISCUSSION OF CHANGES : ! SECTION 3.3.1 o RPS INSTRUMENTATION . OPERATING __ M.4 Cunent Technical Specification 3.3.1.1 Table 4.31 Note (3) requires the excore charmele be i calibrated using the incore detectors aAer power is abow 15% RTP. Improved Technical Specification SR 3.3.1.3 requires the calibration be performed within 12 hours aAct excooding ; 20% RTP. His change is more rostrictive since the CTS did not limit the time required to perform the surveillance, his change is acceptable since the 12 hour time limit provides j sufficient tirae to complete the surveillance without a substantial burden on the operating staff. ; Dis change is consistent with NUREG 1432. , M.5 Current Technical Specification 3.3.1.1 Table 4.3 1 Notes (2) and (4) require the heat balance to be performed when pour is > 15% RTP. Improved Technical Specification 3.3.1 will vid a Note to SR 3.3.1.2 (heat balance) which requires the Surveillance be performed within 12 hours aAer power is > 15% RTP His change is more rostrictive since the CTS did not limit the time required to perform the surveillance. His change is acceptable since the 12 hour '
- time limit provides sufficient time to complete the surveillance without a substantial burden on the operating staff, nis change is consistent with NUREG 1432.
g i M.6 Current Technical Specification 3.3.1.1 Table 4.31 Endnote (3) requires power be limited to 90% RTP if the excore channels are not calibrated using the incore detectors, improved ; Technical Specification 3.3.1 Action C requires power be limited to 90% RTP within 24 hours when the excore channels are not calibrated using the incore detectors. This change is more restrictive since the CTS did not limit the time within which to reduce power to 90% RTP. . De change adds a time limit of 24 hours to reduce power to 90% RTP when no time limit existed. his change is acceptable since the 24 hour limit allows time to complete the Surveillance while minimir.ing the time in a condition where the excore channels may not be - calibrated. His is consistent with the 24 hour delay allowed for a missed SR. His change is consistent with NUREG 1432. 1 M.7 - Current Technical Specification 3.3.1.1, Table 4.31, requires the Surveillance Requirements for the delta T power function be applicable in Mode 1. ITS Table 3.3.1 combines the nuclear power and delta T power functions into a single function identified as Power Level High. De ITS Power Level High function is required in Modes I and 2 consistent with the CTS Table 4.3-1 requirement for nuclear power. He Power Level-High trip function is based on the higher of either nuclear power or delta T power, therefore the two are combined in the ITS. De Surveillances for this function are a combination of the existing Surveillances applicable to nuclear power and delta T power. The CTS requires a daily adjustment (calibration) based on the heat. balance, a quarterly channel functional test, and a channel calibration on a-refueling basis for the delta T power function. His change is consistent with NUREG 1432. De addition of Mode 2 for this function does not affect the daily adjustment based on the heat balance since the CTS and ITS do not require this adjustment until > 15% RTP. He requirement to perform the quarterly channel functional test and the refueling channel calibration prior to MODE 2 is a more restrictive requirement, nis change does not impact safety since from a practical standpoint, these surveillances would already be performed, and the unit does not routinely operate for extended periods in MODE 2, his change is consistent with NUREG 1432.- 1 4 1
- CALVERT CLIFFS - UNITS 1 & 2 3.3.1-5 Revision 8 1
DISCUSSION OF CilANGES SECTION 13.1 RPS INSTRUMENTATION - OPERATING TECilNICAL CilANGES MOVEMENT OF DETAILS TO LICENSEE. CONTROLLED DOCUMENTS LA.1 Current Technical Specification 3.3.1.1 Table 3.31 contains a "C5t annels to Trip" column. Improved Technical Specification Table 3.3.11 will not contain this column. This is an informational column which is more appropriate for the Bases. ne number of channels to trip will not be changed, ne infonnation is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. liowever, any hardware change to the number of channels to trip will require a design change. He Dases Change Control Program will ensure that changes , receive appropriate review. This change in a less restrictive movement of details chsnge with no impact on safety. His change is consistent with NUREG 1432. LA.2 Current Technical Specification 3.3.1.1 Table 3.3-1 Endnote f requires at least two decades of overlap between the Wide Range Logarithmic Neutron Flux Monitoring channels and the Power Range Neutron Flux Monitoring channels. This is a design detail regarding operation of two types of equipment that is more approprirtely maintained in the Dases. His requirement is being moved to the Bases for ITS 3.3.1. He requirement for operability of these functions is not being changed. Any changes to this requirement in the Bases will be controlled in accordance with ITS Section 5.0 Dases Control Program. His Program ensures any changes to these requirements will be adequately reviewed. This change is consistent with NUREG 1432. LA.3 Current Technical Specification 3.3.1.1 Table 4.3 1 Notes (2) and (4) specifically requires the l adjustment of the Nuclear Power Calibrate Potentiometers and AT Power Calibrated Potentiometers, imprmed Technical Specification SR 3.3.1.2 reqtdres that the power range and AT power channels be adjusted. References to the method of adjustment, i.e., the potentiometer, is moved to the Bases ofITS SR 3.3.1.2. Detailed descriptions of calibration equipment is more appropriate in the Bases. The change does not alter the requirement to adjust the two functions based on calirometric results. This change only moves details out of Technical Specifications and dovs not afTect plant safety. He Bases are controlled in accordance with the Bases Control Program in ITS 5.0. nese controls ensure that changes to the Bases are adequately reviewed. This change is consistent with NUREG 1432. LA.4 Not used. l LA.5 Not used. l LA.6 Not used. l LA.7 Current Technical Specification Table 2.21 requires the allowable value for Thermal Margin / Low Pressure (TM/LP) trip function to be adjusted to be not less than the larger of 1875 psia, or the limits provided in the Core Operating Limits Report (COLR). Ilow the allowable value is derived will now be contained in the COLR, and the COLR will be referenced by the ITS. Rus, details regarding how allowable values are determined are more appropriately determined outside the Technical Specifications. This requirement is being moved to the COLR where it can be adequately controlled. e LA.8 Not used. l CALVERT CLIFFS - UNITS 1 & 2 3.3.1-6 Revision 8
DISCUSSICN OF Cl{ANGES SECTION 3.31. RPS INSTRI' MENTATION . OPERATING - TECHNICAL CHANCEN IXAt saltETRICTIVE isi Not used. l , L.2 _ Not used. l L.3 Current Technical Speci6 cation 3.3.1.1, SR 4.3.1.1.2 requires that the logic for the bypasses be demonstrated Operable prior to each reactra startup, unless performed during the ptA 92 days and requires the total bypass _6metion be veri 6ed once per refueling interval (24 months). - Manually or automatically inserted bypasses allow plant operation under conditions that do not require the respective RPS functions, but would result in an unnecessary ! RPS trip if they were not bypassed. %e total bypass functions remwo those bypasses when
'i t
the plant conditions no longer suppo'.t allowing the bypassoi.. Improved Technical l Specification SR 3.3.1.8 requires the tetrJ bypass function be wrified eve y 24 months. His ! is consistent with spety analysis assurnptions that the auttunatic bypass removal function operates. De capability to bypass a f4nction when it is not needed is not assumed in safety I analyses since it performs no mitigative function. Derefore, this requirement is doloted from the Technical Speci6 cations. His chrase is consistent with NUREG 1432. L.4 Current Technical Speci6 cation 3.3.1.1 Action 2.c permits a second channel to be placed in bypass for up to 48 hours for mr.intenance or testmg when one channel is inoperable and placed in the trip condition. Imprtwed Technical Speci6 cation 3.3.1 Action B will permit one ; channel to be placed in trip and are channel to be placed in bypass in one hour and require o,e channel be restored in 48 hour:. His is equivalent to the CTS, however, the ITS does not restrict the condition to testmg and maintenance. His change is acceptable since the cause of the inoperability, either planned or unplanned, has no different impact to the overall safety. His chanae would avoid an vaplanned shutdown and associated trenaient due to an unforeseen channel inoperability. His c'nange is consistent with NUREO 1432. CALVERT CLIFFS - UNITS I & 2 3.3.1-7 Revision 8 k
- - - - - . _ . . - . _ - _ - . - - - . - . . --= -- -
NO SIGNIFICANT . 'AZARDS CONSIDERATIONS SECTION 3J - INSTRUMENTATION
- 2. Does the ebange create the possibility of a new or different klad of scendent from any scendent prevlonaly evaluated?
He proposed changes move detail from the Technical Specifications to a licensee-controlled document. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed chanP,e l will not int xluce any new accident initiators. He changes will not impose diff ,ent ' requirements, and adequate control ofinformation will be maintained. He changes will ne alter assumptions made in the safety analysis and licensing basis. Herefore, the changes w,ll not l create the possibility of a new or different kind of accident from any accident previously evaluated. ,
- 3. Does this ebange involve a si f alfleast reduction la the margin of safety?
%e proposed changes move detail from the Technical Specifications to a licensee-controlled document. He changes do not reduce the margin of safety since they have no impact on any safety analysis assumpsons, in addition, the detail to be moved from the Technical Specifications to a licensee-controlled document is the same as the existing Technical Specifications. Since any future changes to this licensee-controlled document will be evaluated per the requirements of the plant document chrnge control process, no reduction (significant or insignificant) in a margin of safety will be allowed without prior NRC approval.
The NRC review provides a certain margin of safety, and although this review will no longer be performed prior to submittal, the NRC can audit the plant document change control process. Herefore, the margin of safet" lost by not requiring NRC prior approval is not significant. Also, since the proposed change is consistent with the Combustion Engineering Standard Technical Specification, NUREG 1432, approved by the NRC Staff, revising the Technical Sqcifications to reflect the approved level of detail reinforces the conclusion that there is no significant reduction in the margin of safety. Therefore, the change. do not involve a signliicant reduction in the margin of safety. TECHNICAL CIIANGES ITRE HVRTRICTIVE Bahimore Gas and Electric Company, Calvert Cliffs Units I and 2, is converting to the ITS as outlined in NUREG 1432, " Standard Technical Specifications, Combustion Engineering plants." He proposed change involves makvg the Current Technical Specifications (CTS) less restrictive. Below is the No Significant llazards Considerations for conversion to NUREG 1432. In accordance with the criteria set forth in 10 CFR 50.92, HOE has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. He following is provided in support of this conclusion. 3.3.1 Chanee L1 Not used. l 3.3.1 Chanee la Not used. l CALVERT CLIFFS - UNITS 1 & 2 3.3 5 Revision 8
- 6. To resolve NRC comments 3.3.18 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.
DISCUSSION OF CIIANGES SECTION 3.3.1. RPS INSTRUMENTATION . OP5 MATING TECHNICAL CliANGES . MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Currer Technical Specification 3.3.1.1 Tab'. 3.31 contains a " Channels to Trip" column. Improved Technical Specification Table J.3.11 will na contain this column. His is an informational colunm which is more appropriate for t'm Bases. He number of channels to trip will not be changed. %c information is being movvi .o the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channch to trip sdll require a design change. He Bases Change Control Program will ensure that changes receive approp.iate review, his change is a less restrictive movement of detrils change with l no impact on safety. Als change is consistent with NUREG 1432. LA.2 Cunent Technical Specification 3.3.1.1 Table 3.31 Endnote f requires at least two decades of overlap between the Wide Range Logarithmic Neutron Flux Monitoring channels and the Power Range Neutron Flux Monitoring channels. His is a design detail regarding operation l of two types of equipment that is more appropriately maintained in the Bases. His requirement is being moved to the Bases for ITS 3.3.1. He requirement for operability of these functions is not being changed. Any changes to this requirement in the Bases will be cantrolled. in accordance with ITS Section 5.0 Bases Control Program. His Program ensures any changes to these requirements will be adequately reviewed. his change is consistent with NUREO 1432. LA.3 Cunent Technical Specification 3.3.1.1 Table 4.31 Notes (2) and (4) specifically requires the l adjustment of the Nuclear Power Calibrate Potentiometers and AT Power Calibrated Potentiometers improved Technical Specification SR 3.3.1.2 requires that the power range and AT power charmels be adjusted. References to the method of adjustment, i.e., the potentiometer, is moved to the Bases of ITS SR 3.3.1.2. Detailed descriptions of calibration equipment is more appropriate in the Bases. He change does not alter the requironent to adjust the two functions based on calirometric results. This change only moves details out of Technical Specifications and docs not affect plant safety. He Bases are controlled in accordance with the Bases Control Program in ITS 5.0. nese controls ensure that changes to the Bases are adequately reviewed. This change is consistent with NUREO 1432. LA.4 Not used. l LA.5 Not used. l LA.6 Not used. l LA.7 Current Technical Specification Table 2.21 requires the allowable value for nermal Margin / Low Pressure (TM/LI') trip function to be adjusted to be not less than the larger of 1875_ psia, or the limits provided in the Core Operating Limits Report (COLR). How the allowable value is derived will now be contained in the COLR, and the COLR will be referenced by the ITS, Rus, details regarding how allowable values are determined are more appropriately determined outside the Technical Specifications. His requirement is being moved to the COLR where it can be adequately controlled. y LA.8 Not used l CALVERT CLIFFS UNITS 1 & 2 3.3.1-6 Revision 8
- 7. - To resolve NRC comments 3.3.19 and 3.3.1 11. Discuirr' ' ' Change A.9 has been revised to reflect the movement of allowable values to ITS 3.L. % discuss the deletion of the trip setpoints. Discussion of Change LA.4 is deleted since the trip setpoints are the same as tha .
allowable value and do not need to be relocated, i i
^'
. -, _ ,- . . . . ..- -. . . .. . - . .. . . - . . . . .. .....n-. .
, f- @
9 . TABLE w
' .G ,
.g REACTOR PR07,2'VE INSTRUMENTATION TRIP SET *0 INT LDtITS o
!g-: . g l M Q ?;TTPOINT ,
3 (Q. Mantial Reacfor TripO No- ", pi f"
' FUNCT2 e
TRAL 4raC' 4i ALLSIABLE VALUES (Nota lfpyca
- 2. Power Level - High ; 10% a e TJGTJL with ,510% above TEDuglL PSER, and E . aint setpot:L of 30% f RATED ' a minir.m setp? int of 30% of E Q TNE POWER, and a ximum of .3 i 51 .0% of RATED PGWER.
RATED TEDWWIL PBER and a ~ e i maximum of 5107.0% of RATES S ! TWENWIL PENER. r-
- 3. . Reactor Coolant Flow - Lowb 95% of design actor coolant '> of design reactor coolant Tio= 71 i
t ] 4. Pressurizer Pressure - High 5 2400 ps,1 E ' 1 2400 psia y S. Containment Pressure - High 5 4 psig 1 4 psig
- 6. Ste Generator Pressure - t 685 fa 1 685 psfa h' i Low c y ;
j '
- 7. Steam Generator Water Level - 2 10 inches below of feed 3 10 inches below top of fe=d Low . tring ring g 3
M E i
- f. '
a
?
t t M L 4 a! a iF i L 1
.z I :
9
^w
't l
TABLE h (Continued)
@ REACTOR PROTECTIVE INSTRIMENTATION TRIP SETPOINT LIMITS _
O FifMCTIONAL INIIT : 9 hhPSETPON 5' b 8. Axial m @h f,,{Jw. d A Trip set int adjusted to A anumanr VALUES Trip set int adjusted to not g) z ced e limits provided n liefts provided in
- e t
_E M 9. Thermal'Hargin/ Low P ssure ' an
~
- a. Four Reactor Coolan Pumps fp setpoint adjus Operating to not Trip setpoint adjustad ta he exceed the limits ided in Jiot less than thefia C t 43 the COLR ( :114875 neta4 fri i5 limits provided in the CDLR .7 d
- b. Steam Generator Pr sure 5 135 psid Difference - High 5 135 psid 9 ,,
k
& 10. Loss of Load NA NA -
- 11. Rate of Change of Power - High h 3 j 2.6 cades per a te 5 2.6 decades per minute
( m A.9 5, E t A .O
~
~
E _b .4
- iI y-2
r g TABLE . , . REACTOR PROTECTIVE INSTRUMENTATION TRIP SETM INT LIMITS I O hokUNj TRIP SETPOINT ALLOWABLE VALUES G 6. MancalXctorTrio . Not Appifcab Not Appifcable ,-
- 2. Power Level - Hfgh 5 10% ab TNERMAL . with a E minimum etpoint of 3 of RATED $ 10% ebove TRUBWW. POWER, and 5 M a minimum setpoint of 30% of M TBE POWER, and a ximum of m
51 .0% of RATED L 70WER. RATER THERMAL POWER and a a maximum of 5107.v4 of RATED B TPERNAL POWER. 3. g Reactor Coolant Flow - Low I > 95% of dest reactor coolant ilow*
> of design reactor coolant 3 ~
Ti d
- 4. Pressurizer Pressure - High 5 2400 pst
.i g
5 2400 psfa y S. Containment Pressure - High 5 4 ps!
$ 4 psig '
- 6. Ste rator Pressure - 1 685 sia 1 685 psia low
- 7. Steam Generator Water Level -
4m 210 inches bel top of feed Low p 210 inches below top of feed ring y -
!r M E -
n
~2 I S ;
5 . 8 '
}
W ~
g TABLE (Continued) q ~ >m a g REACTOR PROTECTIVE INSTRIMENTATION TRIP SETPOINT LIMITS O FM CTIONAL INIIT . hIPSEdOINT A : - - r VALUES 3 8. Axial Trf setpoint adjus to not Trip setpoint adjusted to not 3
. e eed the limits c-
%,0cshr4.bNkh vided in exc w the Ilmits provided in E g C0tR the'COLR 4 9. Thermal Margin / Low ressure @ g
/
- a. Four Reactor Coo t Pumps g Trip setpoi adjusted to not Trip setpoint adjusted to be
- Operating exceed t letts provided in 1 the COLR -not less than th Jea W of.
(Ilyisis osiaor f2Ythe Ifaits provided in the COLR U
- 3. Steam *,enerator P ure 5 13 pstd 5 135 psid R Difference - High
" b)
/n 10. Loss of Load MA h4
- 11. Rate of Change of Power - High WJ 3
$ 2.6 decad per minute 5 2.6 decades per minute g-
==4 E
44.7 . A.9 8 i
.=.
r v\ 0 7 ! Y 0 w D
~P.
9
DISCUSSION OF CHANGES SECTION 3 3.1 - RPS INSTRUMENTATION - OPERATING placed in trip, and the remanung inoperable channel to be placed in bypass. The channel in which maintenance is being performed is the channel that will most likely be bypassed. Deleting the requirement which stipulates one channel must be placed in trip and one in bypass is admmistrative, because only one channel is capable of being bypassed at a time. His change is consistent with NUREG 1432. A.7 Current Technical Specification 3.3.1.1 Table 4.3-1 Endnote (3) requires hermal Power to be restricted to 90% Rated uctmal Power (RTP), with the existing reactor coolant pump combination, if the excore channels are not recalibrated using the incore detectors. Improved Technical Specification 3.3.1 adds an Action (Action C) which requires the excore clumnels to be calibrated using incore detectors (SR 3.3.1.3), if it has not already been performed, or to limit power to 90% RTP. His change essentially transforms a CTS Surveillance Note into an Action. He requirement that the existing reactor coolant pump combination be maintained is being deleted because in Mode 1, all reactor coolant pumps are required to be operating. The movement of requirements within a Technical Specification without technical changes and the deletion of redundaqt information constitutes an administrative change, his change is consistent with NUREG-1432. A.!, Improved Technical Specification 3.3.1 will add all the excore calibration SRs (ITS SRs 3.3.1.2,3.3.1.3, and 3.3.1.5) to all CTS 3.3.1.1 trip functions that receive input from the excore instrumentation, nis does not add any new requirements to the CTS since the excore 3 calibration only has to be performed once to satisfy the requirement for all the functions. His change is purely administrative because it does not add any new requirements. This change is consistent with NUREG-1432. A9 Current Technical Specification 2.2 on limiting safety system settings is being moved to ITS 3.3.1. The reactor protection system allowable values will be listed in ITS Table 3.3.1-1. He CTS Actions require the applicablo Actions of CTS 3.3.1.1 to be entered if the as found setpoints are not within the allowable value limits. Improved Technical Specifications will also require the applicable Actions for the fimetion be entered. The trip setpoint column in CTS Table 2.2-1 is deleted since these values are the same as the allowable values, except for Thermal Margin / Low Pressure which is discussed in LA.7. This change essentially moves requirements from one Technical Specification to another, therefore, this change is administrative. His change is consistent with NUREG-1432. A.10 Current Technical Specification 3.3.1.1 Action 2.a allows the channel to be in bypass for up to 48 hours to perform maintenance or testing. -Improved Technical Specification 3.3.1 Action A requires 48 hours to restore the channel to Operable status. He ITS wording requires the inoperable channel to be restored to Operable status, which would include maintenance, testing, or whatever may be required to restore the channel to Operable status. This change is considered admi'tistrative because the channel has to be restored to Operable status or the channel must be placed in the tripped condition, which is consistent with the CTS. This change is consistent with NUREG-1432. A.ll Current Technical Specification 3.3.1.1 Table 3.3.1-1 contains a " Minimum Channels Operable" column. Improved Technical Specifications delete this column because the Actions in the ITS are based on the number of channels inoperable, from the total nuniber of channels, CALVERT CLIFFS - UNITS 1 & 2 3.3.1-2 Revision 8
.. .. -- _. -. ~.
DISCUSSION OF CHANGES SECTION 3.3.1 - RPS INSTRUMENTATION - OPERATING TECHNICAL CHANGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED p_QQ.UMENTS LA.1 Current Technical Specification 3.3.1.1 Table 3.3-1 cooMins a " Channels to Trip" column. Improved Technical Specification Table 3.3.1-1 will not contain this colunm. This is an informational column which is more appropriate for the Bases, ne number of channels to trip - will not be changei ne information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. He Bases Change Control Program will ensure that changes receive appropriate review. His change is a less restrictive movement of details change with no impact on safety. His change is consistent with NUREG 1432. LA.2 Current Technical Specification 3.3.1,1 Table 3.3-1 Endnote f requires at least two decades of overlap between the Wide Range Logarithmic Neutron Flux Monitoring channels and the Power Range Neutron Flux Monitoring channels. This is a design detail regarding operation of two types of equipment that is more appropriately maintamed in the Bases. His requirement is being moved to the Bases for ITS 3.3.1. He requirement for operability of these functions is not being changed. Any changes to this requirement in the Bases will be controlled in accordance with ITS Section 5.0 Bases Control Program. This Program ensures any changes to these requirements will be adequately reviewed. his change is consistent with NUREG-1432. LA.3 Current Technical Specification 3.3.1 1 Table 4.3-1 Notes (2) and (4) specifically requires the l adjustment of the Nuclear Power Calibrate Potentiometers and AT Power- Calibrated Potentiometers. Improved Technical Specification SR 3.3.1.2 requires that the power range and AT power channels be adjusted. References to the method of adjustment, i.e., the potentiometer, is moved to the Bases of ITS SR 3.3.1.2. Detailed descriptions of calibration equipment is more appropriate in the Bases. The change does not alter the requirement to adjust the two functicas based on calirometric results. This change only moves details out of Technical Specifications and does not affect plant safety. The Bases are controlled in accordance with the Bases Control Program in ITS 5.0, Rese controls ensure that ch:.nges to the Bases are ndequately reviewed. This change is consistent with NUREG 1432. LA.4 Not used. l LA.5 Not used. l LA.6 Not used. l LA.7 Current Technical Specification Table 2.2-1 requires the allowable value for Thermal Margin / Low Pressure (TM/LP) trip function to be adjusted to be not less than the larger of 1875 psia, or the limits provided in the Core Operating Limits Report (COLR). How the allowable value a derived will now be contained in the COLR, and the COLR will be referenced by the n 5 Thus, details regarding how allowable values are detennined are more appropriately determined outside the Technical Specifications. This requirement is being moved to the COLR where it can be adequately controlled. y LA.8 Not used. l CALVERT CLIFFS - UNITS 1 & 2 3.3.1-6 Revision 8
i
- 8. : To resche 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 flow is.
. controlled.-
i
- t d
d .
RPS Instrumentation-Operating B 3.3.1 BASES The Function is not credited in the accident analyses;
-therefore, the Allowable Value for the trip is not derived from analytical limits.
- 3. Reactor Coolant Flow-Low This LC0 requires four instrument channels of Reactor Coolant Flow-Low to be OPERABLE in MODES 1 and 2.
The trip may be manually bypassed when THERMAL POWER falls below 1E-4% RTP. This operating bypass is part of the ZPMS circuitry, which also bypasses the TM/LP trip and provides a AT power block signal to the Q power select logic. The ZPM3 allows low power physics testing at reduced RCS temperatures and pressures. It also allows heatup and cooldown with shutdown CEAs withdrawn. This trip is set high enough to maintain fuel integrity during a loss of flow condition. The setting is low enough to allow for normal operating fluctuations from offsite power. To account for analysis uncertainty, the value in the safety analysis is 93% of design flow. RCS flow is maintained above design flow by LCO 3.4.1, q" "RCS DNB Parameters."
- 4. Pressurizer Pressure-Hiah This LCO requires four instrument channels of Pressurizer Pressure-High to be OPERABLE in MODES 1 and 2.
The Allowable Value is set high enough to allow for pressure increases in the RCS during nonnal operation (i.e., plant transients) not indicative of an abnormal condition. The setting is below the lift setpoint of the pressurizer safety valves and low enough to initiate a reactor trip when an abnormal condition is CALVERT CLIFFS - UNITS 1 & 2 B 3.3.1-20 Revision pg
DISCUSSION OF CHANGES SECTION 3.3.1 - RPS INSTRUMENTATION - OPERATING whics. is speci%i in the LCO. This change is administrative in nature because the minimum channels Operable is no longer used. His change is consistent with NUREG 1432. A.12 Current Technical Specification 3.3.1 Table 3.3-1 Endnotes (d) and (c) do not require the bypass to be automatically removed. However, consistent with the current Cahert Cliffs design, the b> passes are automatically removed. The total bypass function discussed in CTS 4.3.1.1.2 is considered to include the automatic bypass removal feature. Improsed Technical Specifications Footnotes (a) and (b) will require the bypass to be automatically removed. Moving requirements within a Technical Specification is an adnunistratist change. His change is consistent with NUREG 1432. A.13 Current Technical Specification 3.3.1.1, Table 4.31, Endnote (3) requires that above 15% RTP the excore channels be recalibrated using the incore detectors. Improved Technical Specification SR 3.3.1.3 will require the excore channels to be calibrated using the incore detectors prior to reaching 90% RTP. Current Technical Specifications and ITS Actions require the plant to nat exceed 90% RTP if this calibration is not performed. The CTS does mt specify when above 15% RTP the calibration must be performed, but it is required to be peribrmed prior to increasing power 2 90%. Herefore, the proposed change is administrative i becauce both the CTS and ITS require the calibration prior to increasing power 2 90% RTP, This c; ange is consistent with NUREG-1432, Generic Change CEOG 74. A.14 Curreut Technical Specification Table 2.2-1, Table Notation *, references Specification 3.2.5, "DMf3 Parameters" for the design reactor coolant flow. The referral to Specification 3.2.5 is being deleted. Improved Technical Specifications do not reference other Specifications. Improved Technical Specification 3.4.1, RCS DNB Parameters, establishes the minimum required RCS design flow. No technical requirements are removed as a result of this change and the requirement to maintain RCS flow greater than design flow is not affected. Therefore, the removal of cross-references to other specifications is an administrative change. His-change is consistent with NUREG-1432. A.15 Current Technical Specification 3.3.1, Table 4.3-1, Note (6) is a one-time requirement regarding a Surveillance that was due March 31,1996. This Note is no longer required and will be removed. Removing a requirement that is no longer required is considered an administrative change. His change is consistent with NUREG 1432. A.16 Current Technical Specification 3.3.1, Table 2.2-1, Footnote (3), and Table 3.3-1, Footnote (c) indicate that the APD-High trip may be bypassed when RTP is < 15% and must be automatically reinstated 215% RTP. Current Technical Specification Table 3.31, Footnote (c), also applies to the Loss of Load trip function. This note is retained in ITS Table 3.3.1-1 as footnote (d) for the Axial Power Distribution-High and Loss of Load trip functions. Additionally, the Applicability of these functions has been modified by ITS Table 3.3.1-1 Note , e to indicate that the functions are only required to be operable when 215% RTP. This Note is necessary to clarify the applicability for meeting the associated surveillance requirements and the MODES in which the functions must be OPERABLE. This Note is consistent with CTS Table 3.3-1 Footnote (c), since if the function is permitted to be bypassed, it is not required to be OPERABLE and surveillances would not have to be met. This change is administrative since the Note only clarifies what the Current Technical Specifications already allow. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.3.1-3 Revision 8
. - . - - _- ~ - - _ _ .. - . . . _ - - . _ . - . - _ . _
l 'f 4 i RPS Instrumentation-Operating ' BASES } y6 P 3. Reactor toelant Flow-Law h' (contin g This LCO requires fou annels of Reactor Coolant
- Flow-Lov to be OPERA 8LE in MODES 1 and 2. h
.,y y The trip say be manually bypa when THERMAL POWER falls below IE-45 RTP. This ypass is part of the ZPM8 circuitry, which also bypasses the TM/LP trip and
,, Jrovides_a AT power block signal to the Q power select sogic. af!IblPMS allows low power physics testing at 3' reduced RCS temperatures and pressures. It aise allows heatu wIthd'q awn.~ p and cooldown with shutdown CEAs desi This trip is set hl h enough to maintain fuel flou)Sa ,
b, R45
'S M."Q .
int rity during a koss of flow condition. The i' above desi setbng is low enou h to all.w for nomal operating go s,4.1,*pRc1 b4g Mooh{ afluctuations certainty, the from offsite To account for value in the power. safety analysis Er w e.4ers. 4.
@ l Pressurirer Pressure-Hioh
] ,,,,,,,,.
- . This LCO requires four
' . ;, annels oIPressurtzer Pressure-High to be OPERA 8LE in MODES I and 2. h The Allowable Value is set high enough to allow for '
. pressure increases in the RCS during normal operation (i.e.. plant condition. setting not indicative Thetransients)is below of anthe abnomal lift setpotat of the pressurizer safety valves and low enough to initiate indicated.a reactEtrio The(diff.efencel when an abnomal condition is ma_tne Anpsante nMe) analysis setpointGfE470ipisit incJudes 1 Z _
ance for harsh environnen ,,e .
, .p g . 9 4
The Pressurizer Pressure-High trip concurrent with PORV operation avoids unnecessary operation of the pressurizer safety valves
- 5. Containment Pressure-Hich This LC0 requires four channels of Containment Pressure-High to be 0 RABLE in MODES 1 and 2. M v
^O i
-- (continued)
CEOG STS B 3.3-19 Rev 1, 04/07/g5 h *Sid
- 9. To resolm NRC comment 3.3.1 13,14, and 18, references to TSTF-80 were removed from the Standard Technical Speci6 cation (STS) markup and replaced with a plant specinc 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 the location of footnote "e" to Table 3.31. These changes maintain the existing licensing basis for Calvert Cliffs. 1 i I
g TABLE m n w san .s <>.-y REACTOR PROTECTIVE TRUMENTATION n C q 4 sc . Ah 333
*ers q ,. -i $ rro u a- A.2 1Al ,
j '
** [ TOTAL 110. j Appb 3CA31sE
_ FUNCTION @ 10F CMAINIELS j h IEl0E5 ACTIM c 1. Manual Reactor Trip - 2 1 2 1, 2 and ' l' 1 l 3 . h . Pox r Level - High
- 3. Reactor Coolant Flow - Low i 'g f2 LA- @g 1, 2 4/SG g / 1, 2 *w
- 4. Pressurizer Pressure - High 4 i # 3 " 1, 2
- 5. Containment Pressure - High 4 2 3 1, 2
- 6. Steam Generator Pressure - Low 4/SG r,p .
[/ 3/5G [/'
, 1, 2 1 I
- 7. Steam Generator Water Level - 4/SG 2 1, 2 , >
v t~ e. o.u.w-w ,
- 8. Axial (Flya(OJfset; 4 3/5G(1 3
- 9. a. Thermal Margin / Low Pressure b.~SteamGenerator@pessure)
} 4 3 Jl 1, 2 r ,
4 (6ffkten#- 149% l 3 1, 2 ;
- 10. Loss of Load-g .{y { ' '
3 J - l h A.i
'd[ } ; :
a u..a y z :
? (e3 1 .,-
tt. I
$ /1.16 b !
4 O e
~P N '
g "v
'r 1
p.
I l _-- __ i g cs. ,. . - o { 2 m
- s. .. .. ., _ c
<%. q % For 5 x 7ABLC er>L '
, . .a REACTOR riireitntytgINSTRIBENTATION .
1.u, - m ,veF t+-+..- .aT C T,-;p L,t. 4. p g fRINDWi[@ l a
**' [TOTALNB. i- ruaamusit Apptgangte FUNCTie 6 A.1 ( OF [VD i (9PERABLEj samart ACTION
- 1. p=ami paarter Trio 2 2 1 - 1. 2 and
- 1 }
f Power Level - High
- 3. Reactor Coolant Flow - Low F4 'M 4/SG F
2 (3(O W I. 2 SG i SG 1. 2
- 4. Pressurizer Pressure - High 4 2 3 , 1. 2
- 5. Containment Pressure - High 4 2 3 1. 2
- 6. Steam Generator Pressure - Low 4/SG SG 3 1. I s 7. 5,ea. - ,at te ,Levei - 4,5. s 2,SG
,,p 1. 2 p~
$MM (9.
- a. Thennal Margin / Low Pressure 4 4
@ ~..,
3 (
, rr
- 1. 2 i
- b. 6 4 (
3 -
- 1. 2 f t
g * * "',' " " ~~ b W ' c..,..n L . ao
.a
,t 60 !
a.n 4.a , a n.1 m 3 . - A.14 6 $ os n, '
+
N
- O e
y .& {
+ ~
DISCUSSION OF CHANGES SECTION 33.1 - RPS INSTRUMENTATION - OPERATING which is specified in the LCO. This change is admmistrative in nature because the minimum channels Operable is no longer used. His change is consistent with NUREG 1432. A.12 Current Technical Specification 3.3.1 Table 3.31 Endnotes (d) and (e) do not require the bypass to be automatically removed. However, consistent with the current Calvert Cliffs design, the bypasses are automatically removed. The total bypass function discussed in CTS 4.3.1.1.2 is considered to include the automatic bypass removal feature. Improved Technical Specifications Footnotes (a) and (b) will require the bypass to be automatically removed. Moving requirements within a Technical Specification is an administrative change. His change is consistent with NUREG-1432. A.13 Current Technical Specification 3.3.1.1, Table 4.3-1, Endnote (3) requires that above 15% RTP the excore channels be recalibrated using the incore detectors. Improved Technical Specification SR 3.3.1.3 will require the excore channels to be calibrated using the incore detectors prior to reaching 90% RTP. Current Technical Specifications and ITS Actions require the plant to n,0t exceed 90% RTP if this calibration is not performed. The CTS does not specify when above 15% RTP the calibration must be performed, but it is required to be performed prior to increasing power 2 90%. Therefore, the proposed change is administrative because both the CTS and ffS require the calibration prior to increasing power 2 90% RTP. This change is consistent with NUREG-1432, Generic Change CEOG-74. A.14 Current Technical Specification Table 2.2-1, Table Notatiou *, references Specification 3.15, "DNB Parameters" for the design reactor coolant flow. The referral to Specification 3.2.5 is being deleted. Improved Technical Specifications do not reference other Specifications. Improved Technical Specification 3.4.1, RCS DNB Parameters, establishes the minimum required RCS design flow. No technical requirements are removed as a result of this change and the requirement to maintain RCS flow greater than design flow is not affected. Herefore, the removal of cross-references to other specifications is an administrative change. This change is consistent with NUREG 1432. i A.15 Current Technical Specification 3.3.1, Table 4.3-1, Note (6) is a one-time requirement regarding a Surveillance that was due March 31,1996. His Note is no longer required and will be removed. Removing a requirement that is no longer required is considered an administrative change. This change is consistent with NUREG-1432. 4 A.16 Current Technical Specification 3.3.1, Table 2.2-1, Footnote (3), and Tabic 3.3-1, rootnote (c) indicate that the APD-High trip may be bypassed when RTP is < 15% and must be automatically reinstated 215% RTP. Current Technical Specification Tab!c 3.31, Footnote (c), also applies to the Loss of Load trip function. This note is retained in ITS Table 3.3.1-1 as footnote (d) for the Axial Power Distribution-High and Loss of Load trip functions. Additionally, the Applicability of these functions has been modified by ITS Table 3.3.1-1 Note e to indicate that the functions are only required to be operable when 215% RTP. This Note is necessary to clarify the applicability for meeting the associated surveillance requirements and the MODES in which the functions must be OPERABLE. His Note is consistent with CTS Table 3.31 Footnote (c), since if the function is permitted to be bypassed, it is not required to be OPERABLE and surveillances would not have to be met. ,This change is admmistrative since the Note only clarifies what the Current Technical Specifications already allow. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.3.1-3 Revision 8
DISCUSSION OF CHANGES SECTION 33.1 RPS INSTRUMENTATION - OPERATING A.17- Current Technical Specification 3.3.1, Table 4.3-1, requires a Channel Check for the Wide Range logarithmic Neutron Flux Monitor. Improved Technical Specification 3.3.1 1 includes the Logarithmic Neutron Flux Mocitor in the Rate of Change of Power - High Function. However, the Channel Check only applies to the monitors. nus, a Footnote (f) was added to , the ITS wbich clarifies this. This change is administrative since tle CTS already depicts this. A.18 Current Technical Specification 3.3.1.1 Action 2.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 2.b requires that within one hour all functional units receiving an input from the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 3.3.1 Condition A requires one or more functions with one RPS bistable trip unit or associated measurement channel inoperable be placed in trip or bypass in one bour. He ITS Condition A captures the technical intent of CTS Action 2.a and 2.b by requiring that all affected functions take the specified actions, therefore, the change is administrative, his change is consistent with NUREO 1432, 6 TECHNICAL CHANGES - MORE RESTRICTIVE M.1 Current Technical Specification 3.3.1.1 Action 2.c does not specify a time for the additional inoperable channel to be placed in bypass. Improved Technical Specification 3.3.1 Action B will require one channel to be placed in trip and one channel to be placed in bypass in one hour. His change essentially places a one-hour time limit, where none presiously existed, to perform the Actions. This change is, therefore, a more restrictive change. He change will not adversely affect plant safety, his change is consistent with NUREO 1432, 1 M.2 Current Technical Specification 3.3.1.1 requires the Actions for the functional units be followed when a bypass removal channel is inopemble. Improved Technical 4 Specification 3.3.1 established Actions specifically for when one or two bypass removal ch mnels are inoperable (ITS Actions D and E). The Actions are essentially the same as when one- or two-trip units are inoperable, except that the bypass channel is required to be disabled within one hour. The addition of this new requirement is considered more restrictive. The addition of this requirement will net adver:ely affect plant safety, because the action to disable ' the bypass channel when the automatic bypass removal is inoperable ensures the trip is in effect. This change is consistent with NUREG-1432. M.3 Current Technical Specification 3.3.1.1 does not have any requirenunts if an Action cannot be completed within the required Completion Time. Thus, CTS 3.0.3 would have to be entered. Current Technical Specification 3.0.3 allows 7 hours to reach Mode 3, or Mode 2 for those functions which are only applicable in Mode 1. Improved Technical Specification 3.3.1 added two Actions (Action F and G), when the Required Action and Associated Completion Times cannot be met. Action (F) allows 6 hours for Thermal Power to be reduced to < 15% RTP, and Action (G) allows 6 hours to place the plant in Mode 3. Two actions are necessary since the associated functions have different modes of applicability. This change essentially allows
=
one lese hour to be outside the Mode of Applicability, however, adequate time is still allowed to reach the required plant condition. Therefore, this change will not adversely affect plant safety. l CALVERT CLIFFS - UNITS I & 2 3.3.1-4 Revision 8
(:ztd RPS Instrumentation-Operating h ACTIONS p#-s.L @ 3. _ a. w CONDITION REQUIREDhTION COMPLETION TIME 6+ ble D. (continued) D.t,2.1 Restore; w e reasval h k48[ hours and affected a units to OPERA 8LE status.
~
D.2.2.2 ac in trip. unthaffected 48 hours h E. One or more Functions --------- NOT E-------- with two automatic LCO 3.0.4 is not applicable. bypass removal - - - - - - - - - - - - - - - - - - - - hannels inoperable. -- p E.1 Disable bypass ' I hour l VIC - channels Meu QB i . ,' , g, b
-ME.2.1 Place one affected I hour w .,.
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DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NURFG-1432 SECTION 3.3 - INSTRUMENTATION
- 28. Response Time Testing will be added to Specification 3.3.9, " Chemical and Voleme Control System Isolation Signal." The response time is currently tested for this signal at Calvert Cliffr.
and was therefore added to the Calvert Cliffs ITS. This change is consistent with the Calvert Cliffs current licensing basis.
- 29. This change makes the channel check for the Rate of Change of Power - High RPS trip only applicable to the Wide Range Logarithmic Neutron Flux Monitor. The channel check can only be performed on that equipment, and this change is consistent with the Calvert Cliffs current licensing basis.
- 30. Specification 3.3.4 will not include a Containment Radiation - High function for ESFAS because Calvert Cliffs does use Containment Radiation - High for ESFAS This change is consistent with Calvert Cliffs design.
- 31. NUREG-1432 Specification 3.3.3 Conditions B and C contain Notes which str.te the Reactor Trip Circuit Breakers (RTCBs) associated with one inoperable channel may be closed for up to one hour for the performance of an RPS Channel Functional Test. Calvert Cliffs ITS 3.3.3 Conditions B and C will not contain this Note. The Note is not required because LCO 3.0.5 will allow the RTCBs associated with the inoperable channel to be closed to perform testing.
Limiting Condition for Operation 3.0.5 allows equipment that has been removed from service or declared inoperable to comply with Actions to be returned to service under administrative control to perform testing required to demonstrate its Operability or Operability of other equipment.
- 32. Specification 3.3.3 will not include a Ccndition Note which allows three Matrix Logic channels to be inoperable due to a common power source de-energizing three matrix power supplies. The Note is not needed because if a power supply is lost, three matrix logic channels are de-energized and one trip leg is lost (four RTCBs are open in one trip leg). This place = the plant in a safe condition. If a power supply fails and the RTCDs do not open, an operability determination must be made to determine the inoperability, lt is not necessarily a Matrix Logic problem. This change is consistent with Calvert Cliffs' design.
- 33. NUREG-1432 Specification 3.3.1 provides an Action (Action F) which requires a shutdown to MODE 3 if the Required Actions and associated Completion Times are not met, improved Technical Specification 3.3.1 separates this Action into two different Actions, Actions F and G, based on the Modes of Applicability of the associated fimetions. The Loss of Load and Axial Power Distribution-High functions may be bypassed below 15% RTP and are not required to be operable. Therefore, NUREG Action F is retained for all other functions and a separate Action (Action G) is added which only requires a power reduction below 15% RTP consistent with the requirements for operability of the Loss of Load and Axial Power Distribution High functions.
- 34. NUREG-1432 Specification 3.3.2 requires the Rate of Change of Power-High RPS trip function to be Operable during shutdown. Improved Technical Specification 3.3.2 also requires the automatic bypass removal feature associated with this function to be Operable as part of the LCO statement. Current Technical Specification 4.3.1.1.2 requires the bypass , functions to be demonstrated operable and CTS Table 3.3-1 footnote d indicates that this function has an associated bypass feature. The NUREG provides actions for an inoperable bypass feature and CALVERT CLIFFS - UNITS 1 & 2 3.3-5 Revision 8
RPS Instrumentation-Operating BASES LC0 10. Lots of tehd (continued) and Steam t oss of ve equi System are., capable of accgdeodatt
- t. ithout repring the use/f the g
-! +-u - asses [*_ 4s Q The LC0 o ypass CseWisOfve' ' al Guingerequirlt that the automatic bypass removal (e ure of 4T1 four o ating bypass channels de OPERABLE f each RPS Function th an operating bypass in the MODE addressed in the s if'c LCO (E) far each Functiot All fou ypass resoval
. OPERABLE inadvertently bypassed. s must be to er.sure that none of the four RPMhannels are MS4 ' *^* h p g#i The LCO n breass 6'an11es naMe Fune to thts ); ass removal feature only. If the bypass condition, jfoper.tton failed so sayascontinue. to prevent entering b" e [The erlock All le Values are ased on analys re trements fo he bypassed fu lons. These gi scussed abo as 0 discussion th affected F tions.part of th APPLICABillfY
. c. - This LC0 is appitcable tMW 1 and3 Most RPS tripsar required to be OPERABLE in H00ES I and 2 because the reactor sec y / E , a yL i
is critical in these M EES. The trips are designed to take [10 7'4 4/c J.3./-/ tne reactor suberttical, maintaining the SLs during A00s and a
.~ ~ ~ ~ .
assisting the ESFAS in providing acceptable consequences during ace.idents. Exceptions are addressed in footnotes to he'm h the tabit. Exceptions to this AP CABILITY are: The APD-High Trip and Los o oad are only appitcable in MODE Dbecause theyOgVbesautomatically bypassed N j 0 at < 15% RTP, where the7yrno longer needed.
) af Pouer */ and Manual Trip are also required in MODES 3, 4,TheM and 5, w?th the RTC8s closed, to provide protection for boron dilution and CEA withdrawal events. The @
~ Wowe Rate of 56gh-rligh trip in these lower MODES is addressed in LCO 3.3.2, ' Reactor Protective Systee 4
(continued) CEOG STS B 3.3-23 Rev 1, 04/07/95 m b )
_ _ . _ . _ _ _ _ . ~ . _ _ . _ . _ . _ . . _ _ - . _ _ _ _ . . _ . _ _ . _ . _ _ _ _ . _ _ _ . . . _ _ _ _ _ i i 3 RPS Instrumentatten-Operating M l < 5 3.3.1 @ BASES i ^ ) ACTIONS -E. 4
. d A hd f >'.fl (continued) fa11ere affecting both of the
<<assees .h' E during the hours permitted is remote fMIDeT" "
i
- 6l h ; &
Condition' is entered when the Required Action and I m-^k [en +b h M D ' htSh associst not met, Completion Tlas of Condittee A, B, C, 0, or E are h J ea4 L u J to d If the Ree tred Actions associated with these Conditions
. T(,e y m M , cannot be completed within the required Completion Times, the reactor must be brought to a MODE in which the Required Actions do not apply. - The allowed Completion Ties cf i 4 hours to be in N00E 3 is reasonable, based on operattog ' experience i conditions,in an orderly manner and without challengingfor reachin plant systems.
l
- SURVEILLANCE
' REQUIRENENTS The SRs for any particular RPS Function are found in the sR column of Table 3.3.1-1 for that Function. Most Functions
- are subject to CHANNEL CHECK, CHANNEL FUNCTIONAL TEST, .
CHANNEL CALIBRATION t gantresponse11eetestjnp ' i
" F Reviewer's to: In order for a plant a take credit for
/
l topical 'rts as the basis for ju topica fying Frequencies, l g ports must be supported esta an NRC staff SER that- .
-th plant shes the acceptability of ach topical report for 1 (Ref.8).
( b sa- 1.s.t.1 p.A,bM Performance of the EL CHECK once every 12 hours ensures @ that gross failure f instrumentation has not occurred. A CHANNEL CHECK is really a comparison of the parameter indicated on one channel to a stellar parameter on other
. channels. It is based on the assumption that instrument
- channels sonttoring the sans parameter should read approximately the same value. Si ntftcant deviations -
between the two instrument channe s could be an indication (continued)
'CEOG STS.
B 3.3-28 Rev 1, 04/07/95
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('aaaielaa F is ' ,tered when the Required Action and associated Completion Time of Conditions A, B. C, D, or E are ac; 4 net for the APD High and Loss oflead Trip Futations. If the Required Actions associa'od with these Conditions cannot be completed within the required A Completion Tl nes, the reactor must be brought to a MODE in which the Required Actions do not apply, , U8 The allowed Cs mpletion Time of 6 hours to reduce THERMAL POWER to <l5% R*1P is reasoimble, based on operating experience, to decrease power to <l5% RTP from full power conditions in an orderly manner and without challenging plant systems. 6 e
- 10. , To resolve NRC comment 3.3.1 15, references to TSTF-81 were removed from the STS markup supporting the exclusion of neutron detectors from channel calibrations. Als 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) 3.3.1.8 note since the surveiliance is not applicable to this function in Table 3.3.1 1.
t 4 4 4 d 4 4
RPS Instrumentation-Operating 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.1.4 Perform a CHANNEL FUNCTIONAL TEST _of each 92 days RPS instrument channel except Loss of Load and Rate of Change of Power-High. l SR 3.3.1.5 -------------------NOTE------------------- Neutron detectors are excluded from CHANNEL CALIBRATION. Perforp a CHANNEL CALIBRATION on excore. 92 days power range channels. SR 3.3.1.6 Perform a CHANNEL FUNCTIONAL TEST of each Once within Rate of Change of Power-High and Loss of 7 days prior to Lord instrument channel. each reactor startup SR 3.3.1.7 Perform a CHANNEL FUNCTIONAL TEST on each 24 months automatic bypass removal feature. SR13.3.1.8 -------------------NOTE------------------- Neutron detectors are excluded from CHANNEL E CALIBRATION. Perform a CHANNEL CALIBRATION of each 24 months instrument channel, including applicable automatic bypass removal functions. -CALVERT CLIFFS - UNITS 1 & 2 3.3.1-7 Revision flgp
i RPS Instrumentation-Operating B 3.3.1 i BASES TEST. SR 3.3.1.4. Therefore, further testing of the automatic bypass removal feature after startup is unnecessary. SR 3.3.1.8 SR 3.3.1.8 is the performance of a CHANNEL CALIBRATION every 24 months. CHANNEL CALIBRATION is a check of the instrument channel including the sensor. The Surveillance verifies that the channel responds to a measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument channel drift between successive calibrations to ensure that the channel remains operational between successive tests. CHANNEL CALIBRATIONS must be performed consistent with the plant specific setpoint analysis. The as found and as left values must also be recorded and reviewed for consistency with the assumptions of the frequency extension analysis. The requirements for this review are outlined in Reference 9. The Frequency is based upon the assumption of an 24 month 3 calibration interval for the determination of the magnitude of equipment drift. The Surveillance is modified by a Note to indicate that the neutron detectors are excluded from CHANNEL CALIBRATION because they are passive devices with minimal drift and because of the difficulty of simulating a meaningful signal. Slow changes in detector sensitivity are compensated for by performing the daily calorimetric calibration (SR 3.3.1.2) and the monthly linear subchannel gain check (SR 3.3.1.3). g CALVERT CLIFFS - UNITS 1 & 2 B 3.3.1-37 Revision A&
I of eae% . .,4< - , t c % ,,..,,( eaeep& Lo** (+4w f L.., s +d R.Ae
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SURVEILLANCE REQUIREMENTS (continued) SURVE!LLANCE
\ FREQUENCY
' El FUNCTIONAL TEST f 92 [ days
<@in.,)SR 3.3.1.4 dleform at..da r m a M O SR 3.3.1.5 --
----NOTE - --- -
Neutron detectors are excluded free CHANNEL 4.1.t.l.1 CALIBRATIM.
- r.U. 4,3-I :
Perfom a CHANNEL CALIBRATION on excore 92 days power range channels. SR 3.3.1.6 Derform a CHANNEL FUNCTIONAL TESTjoIe)~c~hS Once within over
/4.1.1.l1\ ate oTt.3mge channeiA nd encyloss -
7 days prior to
.c ggew etid al unit. /_ _ --
J each reactor
\T.W AM/ o, irt c%g _of Pod startup
.--)' %w . . .a L .u c t. .. a_ . . o . ~ . 4 , t.. D SR 3.3.1.7 24
\ Perfom a CHANNEL FUNCTIONAL TEST on each Once .R n automatic bypass removal function.
,g,3,g,g/ l92 day prior l to e h reacto
^"l S h
Q_ tup 3.3.1.8 Perform a CliANNEL CALIBRATION of each RPS 4 illi months [Wts.H instrument channel. Including bypass
\ removal functions. k r *fPh."**
Q 4 . ~ . J.% SR 3.3.1.9 b Verify RPS RESPONSE TINE is within limits, i months o STAGGERED TEST BASIS ; @
/
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DISCUSSION OF TECliNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.3 - INSTRUMENTATION 20. The SR 3.3.11.2 Note which excludes the Neutron Detectors from the channel calibration will be modified to also exclude the Reactor Vessel Level Monitoring System. Here is no mechanism at Calvert Cliffs to perform a channel calibration on the Reactor Vessel Level Monitoring Systeia, ne instruments are usually replaced, nis change is consistent with the Calvert Cliffs current licensing basis.
- 21. Surveillance Require nent 33.10.2 was added to require performance of a channel calibration on containment hydrogen analyzers every 46 days on a Staggered Test Basis, instead of 24 months.
This change is consistent with the Calvert Cliffs current licensing basis. In conjunction with the change a statement was added to SR 33.103 excluding the hydrogen analyzers. 22. This change adda Stesm Generator Pressure and RCS Subcooled Margin Monitor (SMM) and l Pressurizer Pressure (low range) to Table 33.11 1. His change is consis+ent with the Calvert Cliffs current licensing basis. Only one channel of RCS SMM is required, therefore, the referenced action on STS Table 33.11-1 is not applicable. Conditions A and B are only necessary for this functi6n. Only one channel is required in the licensing basis dce to diverse indication or core cooling from core exit thermocouples and reactor vess I water level.
- 23. This change removes Auxiliary Feed. vater Flow from Tab!e 33.11-1, removing PAM instrumentation. Auxiliary Feedwater Flow does not meet the threshold for inclusion in this PAM table. This change is consistent with the Calvert Cliffs current licensing basis.
- 24. This change excludes SR 3J.1.8, Channel Calibration from the Loss of Load function. The Loss l of Load Function cannot be calibrated becausa it senses a turbine trip and does not contain setpoints. Loss of Load function is verified operable by performance of a channel functional test. This change is consistent with the Calvert Cliffs current licensing basis.
- 25. Not used.
l
- 26. NUREG 1432 Specification 33.4 condition. D requires an inoperable automatic bypass removal channel to be disabled or placed in trip or bypass in I hour. If the module is bypassed or tripped, the actions subsequently require the channel to be restored to operable status or placed in trip in 48 hours. ITS 33.4 condition C will require the inoperable block removal feature for a sensor block module to be disabled in I hour or placed in bypass. The assumed safety function of the sensor block module is to ensure that the ESFAS features which have bypass capability are automatically unblocked. With the unit disabled or bypassed, the ability to block an ESFAS function on that module is removed, i.e., disabling or bypassing the block module effectively removes it from the circuitry and fulfills the auto-unblock function. His action places the function in a one-out-of-three logic which ensuws the required redundancy. This action is equivalent to continued operation with an RPd channel placed in trip permitted by LCO 33.1 Condition A.
- 27. This -hange adds a Condition (Condition E) and related Required Actions to address the diffrient Mode requirements associated with ESFAS Actuation Logic channels of Specification 3.3.5. This change also adds a statement identifying the second Condition of Condition D as being for the Manual Actuation Channel. The two different Conditions are required to address the different times at which the conditions leave the Modes of Applicability.
His change is consistent with the Calvert Cliffs current licensing basis. CALVERT CLIFFS - UNITS I & 2 33-4 Revision 8 j
d-l f N i- RPS Instrumentation-Operating M B 3.3.1 8ASES SURVEILLANCE-st 1.1.1.s (continued) REQUIRENENTS-
- CH4lelEL CALIBRATION is a i.
channel including the sens that the channel necessary r check of the lastrument Surveillance verifles responds to a measured parameter within the h . and accuracy. CHANNEL CALIBRAT,10N leaves
- -the channel ested to account for instrument #srtft between 'T g f successive operational betweencal brations to ensure successive tests. that the channel remains @
CHAfBIEL Call $ RATIONS must be performed consistent with the plant specific ( setpoint analysis. i i The as fo$nd and as left values must also be recorded and reviewed for consistency with the assumptions of the
- frequency extension analysis. The requirements for this i
review are eutilned in Referencegg g h The Frequency is based upon the assumption of an inonth calibration of equipa. interval :t drift. for the detemination of the magnitude 3 The Surveillance is modified by a Note to indicate that the neutron detectors are excluded from CHANNEL CALIBRATION
.,* l because they are passive devices with minimal drift and because of the difficulty of simulating a meaningful signal.
- Slow changes in detector sensitivity are compensated for by performing the daily calorimetric calibration (SR 3.3.1.2) and the monthly 1inear subchannel gain check (SR 3.3.1.3).
{ SR 3.3.1.9 ' This SR ensures that the RPS RESPONSE TIMES are verified to be less than or equal to the maximum values assumed in the safety analysis. Individ; sal component response times are
- not modeled in the analyses. - .The analyses model the overall or total elapsed time from the point at which the parameter
, exceeds the trip setpoint value at the sensor to the point i which the RTC8: open. Response times are conducted on an i month STAGGERED TEST BASIS. This results in the i of aerval x 18between months, successive where n is surveillances of a given channel function. The Frequency of e number of channels in the operating experiente, which
)monthsisbasedupon i shown that random failures of instrumentation components ausing serious response time degradatloc, but not channel ' allure, are infrequent
-Jh
~
1 (continued) CEOG STS 8 3.3-34 Rev 1. 04/07/95 4
'~
I b 1_ _ - _ _ _ _ _ - _ _
- . - ~ _ . - - ..
. - . . . . - . .~. . . .~ . . - . . . -
4 RPS Instrumentation-Operating 4 ( BASES f SURVE!LLANCE SR 3.'3.1.9 (continued) REQUIREMENTS occurreec u. Also,' response times cannot be determined at power, since eqstpeent operation is required. Testing may be rformed in one measurement or in overlapping segments, wit verification that all components are tested. , 4 REFERENCES 1. 00 r/R 50. Annand1x A. gds.41QOF1, A R App 2.l.s t} h h&FI96? , OP5 A R r. '2. 2) 4 n att Standard 279-UniyApr11A IsnJ-- 4.hSAR, Chapter 14 [ 5. 6. 10 CFR 50.49. Protect 1 { stem SelecJitin of Tripgpatnj Q 7.@SAR,Section 7.2
- 8. 'RC SaHfy Evaluathdn_ Report, @
g
- 9. CEN 327, June 2,1536, including Supplement 1 March 3, 1989.
( L- __ _ keHer +o USHRC % R.E. Du4on, (dE,, da4d fueb IW &
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- 1. EN-'t-io't, " Suncedl a u< T<5frg "
-- w - _ --
- 10. Leber +o C.[, Q, An,6M, bm O, c. A 0oxola,os4Rc 3 dalel 0 lober 19,i4 W b .
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11. To resolve NRC comment 3.3.1 16, references to TSTF 85 were reinoved from the STS markup and replaced with a plant specific Discussion of Deviation 38. 1 i
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DISCUSSION OF TECilNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.3 INSTRUMENTATION also provides surveillance requirements for demonstrating the function Operable.1his change maintains consistency within the ITS and is consistent with the current Technical Specification requirements.
- 35. NUREG 1432 Surveillance Requirernent 3.3.3.1 requires quarterly testing of the RTClis. CTS Table 4.31 requires the RTClis be tested on a monthly basis. Calvert Cliffs has retained the l existing more frequent testing of the RTCDs consistent with the licensing basis and CEN 327, "RPS/ESFAS Extended Test Internal Evaluation," June 2,1986, including Supplement 1, dated March 3,1989.
36. NUREO 1432 Condition E of LCO 3.3.3 is stated as *One or more functions with two or more
. . . Inoperable. This specification is not " function" based, i.e., the functional parameters that can be inoperable under this LCO are already stated in Condition E. There are no other functions covered by this LCO which depend on these functions.1he NUREO statement is not used in any other condition of the LCO and is in error. The statement is deleted from ITS 3.3.3 consistent with the design of Calven Clifts.
- 37. NUREO 1432 Condition il of LCO 3.3.7 requires placing the purge valves in the closed position and entW.ig the applicable conditions of LCO 3.6.3 for the inoperable purge valves which result from an inoperable manual actuation or automatic actuation channel. These actions are in error as,d have been corrected in ITS 3.3.7 to require either the valves be closed, or the actions of LCO 3.9.3 be entered for inoperable valves. The STS reference to LCO 3.6.3, Containment Isolation Valves, is inappropriate since that LCO applies in Modes 1,2, 3, and 4 whereas, LCO 3.3.7 is applicable during core alterations and movement of fuel. LCO 3.9.3, however, has the same applicability of LCO 3.3.7 and is the appropriate reference. The STS is also in error to require both actions be accomplished since the actions are somewhat redundant. Closure of the purge valves performs the safety function of the automatic and manual functions covered by the LCO. 'Ihe actions of LCO 3.9.3 would require that core alterations and fuel movement be suspended which removes the unit from the mode of applicability. Therefore, ITS 3.3.7 Condition il replaces the "and" requirement in the STS with an "or" to indicate that these actions accomplish the same desired result. This change is also consistent with the requirements of the STS for each of the other PWR owners groups.
- 38. 'Ihe Applicability of NUREO LCO 3.3.1 is MODES I and 2. The ITS Applicability references Table 3.3.1 1, and Table 3.3.1 1 has a column spedfying the Applicability for each Function in the Table. This method is necessary since each Function does not have the same Applicability; two of the Functions are only required in MODE 1215% RTp. This change is aho consistent with the Calvert Cliffs CTS Table 3.3 1.
- 39. NUREG 1432 SR 3.3.9.2, Note 2, requires testing of relays after 24 hours of Mode 5 operation for relays that cannot be tested during operation. These relays would cause a closure of the letdown line which is undesirable during unit operation. The CVCS actuation logic is enrrently l not required by the Technical Specifications. The 24 month test frequency proposed in ITS
- SR 3.3.9.2 is consistent with the CTS Table 4.3 2 footnotes 2 6 for other ESFAS functions actuation logic which cannot be tested online. The requirements of the STS would impose an unnecessary more restrictive change on plant operatiens and are not adopted. ,
CALVERT CLIFFS - UNITS 1 & 2 3.36 Revision 8
- - - - - _ _ - _ _ --- --- _-~_
- 12. To resolve NRC cominent 3.3.121b, Discussion of Change M.6 was added to justify adding MODl! 2 to the applicability of delta T power function. The CTS inarkup was annotated accordingly.
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- 6. Steam Generator Pressure - Low $ REFM LING INTE WAL 1. 2 Q l
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DISCUSSION OF CilANGES SECTION 33.1. RPS INSTRUMENTATION . OPERATING hl.4 Current Technical Specification 3.3.1.1 Table 4.31 Note (3) requires the excore channels be calibrated using the incore detectors after power is above 15% RTP. Improved Technical Specification SR 3.3.1.3 requires the calibration be performed within 12 hours after excoeding 20% RTP. This change is more restrictive since the CTS did not limit the time required to perform the surveillance. This change is acceptable since the 12 hour time limit provides sufficient time to complete the surveillance without a substantial burden on the operating staff. His change is consistent with NUREG 1432. hi.5 Current Technical Specification 3.3.1.1 Table 4.3 1 Notes (2) and (4) require the heat balance to be performed when power is > 15% RTP. Improved Technical Specification 3.3.1 will add a Note to SR 3.3.1.2 (heat balance) which requires the Surveillance be performed within 12 hours after power is > 15% RTP. This change is more restrictive since the CTS did not limit the time required to perform the surveillance his change is acceptable since the 12 hour time limit provides sufficient time to complete the surveillance without a substantial burden on the operating staff. His change is consistent with NUREG 1432. C M.6 Current Technical Specification 3.3.1.1 Table 4.31 Endnote (3) requires power be limited to 90% RTP if the excore channels are not calibrated using the incore P.mors. improved Technical Specification 3.3.1 Action C requires power be limited to 90% RTP within 24 hours when the excore channels are not calibrated using the incore detectors. His change is more restrictive since the CTS did not limit the time within which to reduce power to 90% RTP. The change adds a time limit of 24 hours to reduce power to 90% RTP when no time limit existed. This change is acceptable since the 24 hour limit allows time to complete the Surveillance while minimir.ing the time in a condition where the excore channels may not be calibrated. His is consistent with the 24 hour delay allowed for a missed SR. His change is consistent with NUREG 1432. M.7 Current Technical Specification 3.3.1.1, Table 4.31, requires the Surveillance Requiremen'.s for the delta T power function be applicable in Mode 1. ITS Table 3.3.1 comblocs the nuclear power and delta T power functions into a single function identified as Power Level-liigh. The ITS Power level-liigh function is required in Modes I and 2 consistent with the CTS Table 4.31 requirement for nuclear power. De Power Level High trip function is based on the higher of either nuclear power or delta T power, therefore the two are combined in the ITS. The Surveillances for this function are a combination of the existing Surveillances applicable to nuclear power and delta T power. He CTS requires a daily adjustment (calibration) based on the heat balance, a quarterly channel functional test, and a channel calibration on a refueling basis for the delta T power function, his change is consistent with NUREG 1432. The addition of Mode 2 for this function does not affect the daily adjustment based on the heat balance since the CTS and ITS do not require this adjustment until > 15% RTP. He requirement to perform the qurrterly channel functional test and the refueling channel calibration prior to MODE 2 is a more restrictive requirement. This change does not impact safety since from a practical standpoint, these surveillances would already be performed, and the unit does not roatinely operate for extended periods in MODE 2. This change is consistent with NUREG 1432. CALVERT CLIFFS . UNITS 1 & 2 3.3.1 5 Revision 8
I i i
- 13. To resolve NRC comment 3.3.122, the ITS and STS markup for Table 3.3.1 1 was revised to
{ include SR 3.3.1.7, Channel Functional Test, to the Asymmetric Steam Generator Transient ; Function, consistent with the CTS 4.3.1.1.2 tequirement to test bypasses for applicable functions, j Current Technical Specification Table 3.3 1 identifies this function as including a bypass. ' f i I L t I e i f i [ b P o . _ . . . . . _ _ . . . , . . - . , . . . _ , . . , _ _ , . - . ..-.._;..._.- ~ _ ..-.- ,_. _ , ..._..-, ,; ,--.,,. - ,.,
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RPS InstrumentatiCn-Operating 3.3.1 Table 3.3.11(page2of3) Reactor Protective System Instrumentation l
- SURVEILLANCE FUNCTION MODES REQUIREMENTS ALLOWABLE VALUE
- 7. Steam Generator 1, 2 SR 3.3.1.1 2 10 inches below top Level-Low SR 3.3.1.4 of feed ring i
SR 3.3.1.8 SR 3.3.1.9
- 8. Axial Power I I') SR 3.3.1.1 In accordance with the Distribution-High(d) '
SR 3.3.1.2 COLR SR 3.3.1.3 SR 3.3.1.4 SR 3.3.1.5 SR 3.3.1.7 SR 3.3.1.8 SR 3.3.1.9 9a. Thermal Margin / Low 1, 2 SR 3.3.1.1 In accordance with the Pressure (TM/LP)(*) SR 3.3.1.2 COLR SR 3.3.1.3 SR 3.3.1.4 SR 3.3.1.5 SR 3.3.1.7 SR 3.3.1.8 SR 3.3.1.V 9b. Asymmetric Steam 1, 2 SR 3.3.1.1 s 235 psid Generator Transient SR 3.3.1.4 (ASGT)(6) SR 3.3.1.7 2 SR 3.3.1.8 SR 3.3.1.9
- 10. Loss of Load (d) 1(') SR 3.3.1.6 NA SR 3.3.1.7 i CALVERT CLIFFS - UNITS 1 & 2 3.3.1-10 Revision #8
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- 14. To resolve NRC comment 3.3.21, Discussion of Change L3 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 Signlileant llazards Considerations have been updated accordingly, i
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';- ;;;;d 1;7 e !44 hours from time of ittal loss of ONRASILITY: however, the inoperable channel shall then '
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- b. Withi one hour, all ru tional unns receiving an put D 8i* # ' h, N f he inoperable ch not are also placed in t same
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charmanprovicea sne otner inoperable channe' s is: %**f' y%,s, (g) 3y A inthetrippegnd n;j ,, 4,p g, 4 AChM 3 - With the nunour 6i snmu.is vrwirkt one susu tnan riquirer by the Minimum Channels OPERABLE requirement, verify mM i 4 compitance with the SWTDOWN MARGIN requirements of pecification 3.1.1.1 hour and at least once,per or 3.1.1.211 hours as apgareafteritcable, t within [ M.f hCTIM4- With the number of channels OPERABLE one less than requir% t- _ by the Minimum Channels OPERABLE requirement be in NOT , STAND 8Y within 6 hours however, one channel,may be bypassed for up to 1 hour for surveillance testing per Specificattoj 4.3.1.1. ' s Ses 0 % sto A sh u tet $* ** fpe.,% . % 1.1.st 9 Desos.in., / J , g k q,,gg g, A W,"Urk pin @R CAeq< .S4 1s " St *chsh *m 3 3 3 *R 9.s l ' h * 'T"rie % .4.' A . 4 " w4r s4 1'ad G
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[N fer e h*' Ih4 sr c, gie# A, i CALVERT CLIFFS - UNIT l' 3/4 5 Amendment No. 169 3 e i Pay 4 F 7 l
$per C., Aos ~3. *% ~2.
3/4.3 !astaMMENTATION TA K r 3.3 1 (Continued) Q , g f J C,[ [,'i (,, 3 (;pp d g was Q sp y - hours from time of initial tess of LifY . the i reble channel shall then be either re: stored to status or placed in th b'e' ekt \ tripped conditten. QW:,a:= 2.1. \
. witnin one hour all functional units recetyi en input I" '
- from the inoperable channel are also placed i the same A i
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. m Wt required by a.ypassed above orfortripped. as appliceble) the inoperable channel. asJ I @
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(ACTIgu 3 = witirine number of ChilihEll'iranABLE ene less snan requi 3 by the Minimum Channels SPERA8LE requirement. Verify l
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compliance with the SNUTDOWN MARGIN requirements of Specification 3.1.1.1 or 3.1.1.2. as applicable, within
. "**' s' 1 hour and at least once per 12 hours thereafter. @ 4- --
wun snu .-_--_ ofMs ersansLE ene less than required ' by the Minimum Channels OPERABLE requirement STANDBY within 6 hours: however. one may be channel. bypasse be in NOT for up to I hour for
- arveillance testing per Specification]d 4.3.1.1. j- -
(.,,. J. . ... , . f A . v - e 0,ws.w .f .A. 3,. A b b 6 1.1.n,'v en R.,y P. ,. < p . . . r, . 4 + . , 7 ~5 ~5, %M l.m.no.rs % %.1% %scl.e CL .als* L.o . ,
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CALVERT CLIFF 3 - UNIT t 0/4 3 5 Amendment No. 149 py 4 or 7
DISCUSSIEN OF CIIANGES SECTION 3.3.2 - RPS INSTRUMENTATION . SilUTDOWN L.3 Cunent Technical Specification 3.3.1.1 Action 2.c pennits a second channel to be placed in bypass for up to 48 hours for maintenance or testing when one channel is inoperable and placed in the trip condition. Improved Technical Specification 3.3.2 Action B will permit , one channel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours. This is equivalent to the CTS, however, the ITS - does not restrict the condition to testing and maintenance. This change is acceptable since the cause of the inoperability, either planned or unplarmed, has no different impact to the overall safety. This change would avoid an unplanned shutdown and associated transient due to an unforeseen channel inoperability. This change is consistent with NUREO.1432, f, CALVERT CLIFFS - UNITS 1 & 2 3.3.24 Revision 8
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.3 - INSTRUMENTATION 3.3.2 Chamse t M
- 1. Does the change involve a significant increase la the probability or consequences of an accident previously evaluated?
He proposed change removes the requirement to demonstrsa that RPS functions can be bypassed when not needed. He RPS bypass capability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. The automatic removal feature of the bypasses is not affected by this change. Herefore, the consequences of an event are not affected since the function will continue to be required to mitigate applicable events. Herefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
This change will not phpically alter the plant (no new or different type of equipment will be installed). He changes m methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does thl change involve a significant reduction in margin of safety?
The capability to bypasses a function when it is not needed is not a credited function in the safety analyses since it performs no mitigative function. The capability to automatically remove any function from the bypassed condition is assumed in the safety analysis since the function is assumed to operate as required to mitigate analyzed events. The proposed change does not alter or delete any requirement used to preserw the assumptions in the applicable safety analysis, therefore, the change does not result in a significant reduction in a margin of safety. 3.3.2 Chunoe L.3
- 1. Does the chang involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change provides actions when s.vo channels are inoperable for any reason, in addition to maintenance and testing. He allowed outage time for channel inoperability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. He consequences of an event are not affected since the function is already permitted to have two inoperable channels for the same allowed outage time for maintenance and testing activities. Therefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Doeg the change create the possibility of a new or different kind of accident from any previously evaluated?
This change will not physically alter the plant (no new or different type of equipment will be installed). He changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or i different kind of accident from any accident previously evaluated. , 1 I CALVERT CLIFFS - UNITS 1 & 2 3.38 Revision 8
i NO SIGNIFICANT HAZARDS CONSIDERATIONS j SECTION 3J - INSTRUMENTATION [
- 3. Does able change involve a angelfleast rodsetion la margia of safety?
l %e curant Technical Specifications already permit a second RPS channel to be inoperable for maintenance and testing purposes, ne proposed change extends this to any cause of channel inoperability, ne failure of a channel is an infrequent event when compared to the frequency of routine maintenance and testing (e.g., channels are tested quarterly). De proposed change does i not alter or delete any requirement used to preserve the assumptions in the applicable safety l analysis, therefore, the change does not result in a significant reduction in a margin of safety. J l m ru7- Lt I
- 1. Does the change letolve a sigalfleast leeresse in the probability or consequences of an
}- accident prwylosaly evelanteu? l De proposed change revises the Applicability for the Manual Reactor Trip from Modes 1 and 2
- - and when any RTCB is closed and any CEA is capable of being withdrawn, to Modos 1 and 2 j and Modes 3,4, and 5, th any RTCBs closed and any CEA capable of being withdrawn. His
- change deletes the requi ont for the Manual Trip to be Operable whenever the RTCB is closed or any CEA is capable of being withdrawn. De Rate of Change of Power dilgh RPS trip is not
. an initiator of any analyzed event. This change maintains consistency with the safety analysis. l The CEA withdrawal events are not postulated in Mode 6 and cannot occur when the reactor is j defueled. Boron Dilution in Mode 6 is not terminated by a reactor trip. De proposed change L does not significantly affect initiators or mitigation of ai.alyzed events, and therefore does not a involve a significant increase in the probability or consequences of an accident previously evaluated.
' 2. Does the ebenge create the_ possibility of a new or different kind of accident froni any
- previously evalented?
ne proposed change revises the Applicability for the Manual Reactor Trip from Modes 1 and 2, _ and when any RTCB is closed and any CEA is capable of being withdrawn, to Modes I and 2 and Modes 3,4, and 5, with any RTCBs closed and any CEA capable of bein6; withdrawn. This change does not affect the probability of an accident. De change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as pan of the proposed change. The proposed change will not intsoduce any 'new accident initiators. Derefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.-
- 3. Does this change levolve a sigalficant redaction la margin of safety?
ne proposed change revises the Applicability for the Manual Reactor Trip from Modes 1 and 2, and when any RTCB is closed and any CEA is capable of being withdrawn, to Moden 1 and 2
. and Modes 3,4, and 5, with any RTCBs closed and any CEA capable of being withdrawn.- This change deletes the requirement for the Manual Trip to be Operable whenever the RTCB is closed or any CEA is capable of being withdrawn. The change maintains consistency with the safety analysis by deleting modes of Applicability that are not applicable. The CEA withdrawal event and boron dilution events are not postulated in Mode 6 and cannot occur when the reactor is defu eled. Therefore, the change does not involve a signincant reduction in a margin of safety.
- CALVERT CLIFFS - UNITS 1 & 2 3.39 Revision 8
l$. To resolve NRC comment 3.3.2 2, Discussion of Change LA.1 has been deleted and replaced with Discussion of Change L.2. lhe CTS markup and No Significant flatards Considerations have been updated accordingly. l l I
(pr..s.,.4.on T. ~3. *). A.t
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.g,g,3.2 demonstrated OPERABLE by the perfoi i m vi tM *" tt. ECK, C M NNtl ,, , 3, .g. , 4 CAllbRATIM and CENNEL FWCTIONAL TEST operations-;. ;;.. tM "^^1::.Ht tM i..;,.;;.:!** : " h ^ ' ! -17 E ei*a==t Nfe'l SNARTUP rl[ Meter ic for the k fasses unWsshall be d durt perfomad trated OPif.ABLE ' ' ^
- I ?*
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^ %,, shall be cener.strated OPERABLE at least once per .
e b p 05.3.2.5 i4.3.1.1.)
/~funct ri n ion s geg REACTOR TRIP hall be d_emoThe gn*P*r 5YSTEM RESPON$t TIME of the 11 channels are tested least once every N UCLING
,4WTERVAL5 where s the total number of dundant channels in pecific reactor trip f ction as shown in the " tal No. of Channels' lumn of ;
dable 3.31.f f I k o a SLAG - -
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G_oti\ Neutron detectors are exempt from response time testing. @) CALVERT CLIFFS . UNIT 1 3/4 3 1 Amendment No. 208 4 Q , t* l U
. _ _ _ _ _ _ _ - - _ - - - . . - - - - - - - - - - - - - - - - - - - - - - ~ - - - ~__ _
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=LIMIT 1M Com1T1011 FOR DPERATIM
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- 4\y 14 *SutYt1LLAIICE RE0lG'RENDITS , _. ._.
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- y . 4 4t9thhi CAL!tRAT tach reactor protectlyelsstrtEnntatiMannailshall bed the e-~!M --g-,.
and drCNAMil
- r -Tabit%t. FWCTICILAL TC$T operations derh; tL "':^" es si .
'/ 3 h MtEM Y
- tek!M=k".2M-^.shalllie$rff5Nud!a t[FUELIIIGINTERVAL N-g affected by bypass o CILAlllitt CAltl*.AT1001 testinndeath channel _ demonstr Q ,,,,4.
. w. . ..- y,..w- . -
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functic'. s hall be demomThe REACTOR TRIP $YSTEN'Rt3Ftnist TIME of each (LIN ~ d to be within its limit at least once per Uin_i_INTERVA te suilitEi channelsIMTTP .!drut 1 Hit em s are t ed at least once e r
,1N1ftVALS where N 4 the total numb ItfrVELING of redundant channel in a specific Llable 3.33,-reactor trip function as shown in Afte ' Total No. of t$nnels' column of
~
=
on a 9A66& RED (,g ,u e 4 ,. p yg TEt,T 4Asit y,,,,,- .. a...-,i ~J h - r
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- =
Neutron detectors are exempt tros response time testing;4.1 CALVERT CLIFF 3. UNIT 2 3/4 3 1 Amendment No.186 f%s
1 DISCUSSION OF CilANGES SECTION 3.3.2 . RPS INSTRUMENTATION SliUTDOWN adversely affect plant safety, because it places the plant outside the Mode of Applicability. This change is consistent with NUREO 1432. TECIINICAL CIIANGES MOVEMENT OF DETAILS TO LICENSEE CONTROLLED. RQCUMENTS LA.1 Not used. l LA.2 Current Technical Specification 3.3.1.1 Table 3.31 contains a " Channels to Trip" column. Improved Technical Specification 3.2.2 will not contain this infonnation. His is an informational column which is more appropriate for the Bases. De number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change
- Control Program in ITS Section 5.0. llewever, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that change twelves appropriate review. His change is a less restrictive movement of details change with no impact on plant safety, nis change is consistent with NUREG 1432.
LA.3 Not used. l IECIINICAL CilANGES .1.rEE prETRICTIVE L.1 Current Technical Specification 3.3.1.1 Applicability requires the Ratc of Change of Power-liigh functional unit to be Operable when any RTCB is closed and any CEA is capable of being withdrawn. Improved Technical Specification 3.3.2 will change the Modes of Applicability to be Modes 3,4, and 5, with any RTCDs closed and any CEA capable of being withdrawn. His change is reasonable because the CEA withdrawal events are not postulated in Mode 6 and cannot occur when the reactor is defueled, and Boron Dilution in Mode 6 is not tenninated by a reactor trip. These events are not postulated in Mode 6 or cannot occur when the reactor is defueled. Relaxing the Modes of Applicability constitutes a less restive change. This change is consistent with NUREG 1432. L.2 Current Technical Specification 3.3,1,1, SR 4.3.1.1.2 requires that the logic for the bypasses be demonstrated Operable prior to each reactor startup, unless perfonned during the preceding 92 days and requires the total bypass function be ve died < nce pe- %'nmg interval (24 months). Manually or automatically inserted bypassa ali .v plant anslon under condh!ons that do not require the respective RPS functions, bu, would resd b an unnecessary RPS trip if they were not bypassed. The total bypass functions remove these bypasses when the plant conditions no longer support allowing the bypasses, improved Technical Specification SR 3.3.2.4 requires the total bypass function be verified every 24 months. This is consistent with safety analysis assumptions that the automatic bypass remov.I function operates. He capability to bypass a function when it is not needed is not assumed in safety analyses since it performs no mitigative function. Herefore, this requirement is deleted from the Technical Specifications, nis change is consistent with NUREG 1432. , CALVERT CLIFFS - UNITS 1 & 2 3.3.23 Revision 8
NO SIGNIFICANT HAZARDS CONSIDERATIOND f SECTION 3.3 - INSTRUMENTATION 33.2 Cha--- I M - I, Does the ebange involvt a sigalScant lacrease la the probability or consequences of an accident previously evaluated? ne proposed change 'emoses the requirement to demonstrate that RPS functions can be bypassed when not weled, ne RPS bypass capability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected, ne automatic removal feature of the bypasses ir not affected by this change. Derefore, the consequences of an event are not affected since the function will continue to be required to mitigate applicable events. Therefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the cl.ange create the possibility of a new or different kind of accident fmm any prevlonely evaluated?
This change will not phpically alter the plant (no new or different type of equipment will be installed), ne changes m methods governing normal plant operation are consistent with current safety analysis assumptions, nerefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does tble change involve a significant reduction in margin of safety?
The capability to bypasses a function when it is not needed is not a credited function in the safety analyses since it performs no mitigative function. He capability to automatically remove any function from the bypassed condition is assumed in the safety analysis since the functior, is assumed to operate as required to mitigate analyzed events. The proposed change does not alter or delete any requirement used to preserve the assurnptions in the applicable safety analysis, therefore, the change does not result in a significt9 reduction in a margin of safety. 3.3.2 Chamme L3 1, Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change provides actions when two channels are inoperable for any reason, in addition to nalntenance and testing. The allowed outage time for channel inoperability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. The consequences of an event are not affected since the function la already permitted to have two inoperable channels for the same allowed outage time for maintenance and testing activities, nerefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
This change will not physically alter the plant (no new or difTerent type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. - CALVERT CLIFFS - UNITS 1 & 2 3.38 Revision 8 4 m-. --. s. .-,,---w,m...-
- -7e,r.n, m.- , -_, .o-. -- - <..-----:---,--r-
- 16. To resolve NitC comment 3.3.2 3, Discussion of Change LA.3 has been deleted and the CTS ;
markup revised to show that CTS Table 3.31 Action 2.b is applicable to ITS 3.3.1 and not to ! ITS 3.3.2. ; l l l i l
. - . . . .- - . --- -.- --_ -.- -- - --..--.._. .-_- - -.~._. -
Seae.OM 38 h j 3/4.3 IllSTMMENTAT!0N i a TABLE 3.31 (Continued) g,p
- ACT8" "I"'" gf.h.4/
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.,4, umww -
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' b__!LITY: however. therable O i44channel hoursshall from then time infTnf ttei tes: ef be either restored to e status er placed in the trtpped condition,
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- b. With1 ene nour sinc rurpionsi units recalving an put 4
f he Inopera,ble nel are else placed in t same I8i '**"*" @ *% e ttten(either sed or tripped le as A _fia reautred by & _i n for the t m, as.ble a appl nnel). _ ,l g enetiditipn wrm,n issro.el., anehmebeb um .- -- --
!s 9 *g* re* ;f s
- ehassiawpipvices sne etner r, operable channe' 6*** # ,,w Li in tte tripp * '#"'{"(' * "y '8!)
'!ON 3 -
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4 W1th the ..-, vi .==
-is man. a one a uss by ther Minimum Channels GPERABLE requirement Enan .w.irwa'_ --
compitance with the SNT90lAl MAA41N requireme. 4.stA!4 .44. nts of Verify = pectfIcat1on 3.1.1.1 or 3.1.1.2, as app 11 cable, wtthin 4
,4 ,f bour and at least once,per 12 hours thereafter ACTI0li 4 -
With the number of channels SPERABLE one less than requir% t- _ by the Minimus Channels 9PERA8LE requirement, be in NOT STAW8Y within 6 hours :)owever, one channel may be bypassed for up to I hour for surveillance testing per pecification) 4.3.1.1. ' Ses Ohsgston 40 c han tes S*' f p4$d,. 1.1.ft
% ks"Ms*A .f ek.n y Q L he r.%'s At A'n ' OI'* 'l*/'Urd N 'h * * *4 aI It "g t
5 *<Assh m 3 3 3lR P.S O 't. * *Telp .*I~..Usk s.e " stu n t h estwo G 4 . *L Grfg < 64 Tw r c.fiw g, i l 4 . CALVERT CLIFFS - UNIT 1 3/4 3 5 Amendment No.169 n py 4 9 7 4
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3/4.3 INSTRUMENTAT195 {; 1AhLI 2 4 1 (Continued Q,g ,,4 s,Lf( 4,, oc5ppgg] r
- J J heum fra. q ...., in 7 -ti of iwrii itse er LITY: heuever, the i reble channel shall then
- be either restored to status er pieced in the b b ' ef \
tripped condttien.
.(p;g;,4:= 2.1 \
vnnin one hour, all funettenal units voceiving an input W"'I' from the i le channel are else placed 1a the same
/
i condition A ther bypassed or tripped, as applicable) as i j that requi by a. above for the inoperable channel. J - MC1\oNBf,heseTWP. g N enr
- daddittene) =37_S che mi ^8*"
es ,e mere t far m ( w..frJ disas M w WA> G 5 d F ,4 " Ou !,"Wi&PilRE%e- ,1 % e a nne .y &
- .. a aann . .aicoe ,n or er nr_ one io.. .n ,,,or by the Minteue Channels SPERABLE requirement, verify i
p@y)1tancewiththe35UT90481NAAGINrequirementsof . n[* ** *pg'* *'* 4 fIcetien 3.1.1 1 er 3.1.1.2 x (gnd at least once per 12 hasrsapp 11 cable, vithfn thereafter. ! @' 4 TwiTrie .._-_ _, vi ........i. mansLE ene less than required 1 by the Minimum Channels SPERABLE requirement l i ITAND8Y within 6 hourst however, one channel. be in NOT.ay be bypassed for up to I hour for surveillance tastin0 per specificattenj 4.3.1.1. f (oe J . . s . . . ( a L- . y * ' ' " ' ' * *"t** '
$v4r 61.1.81,"Wrk Regy P.e 9 . . r, .. a ,, . 3 3 ~3, %OS l.nons.rs. ht".% I%ri.e CL. als *
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, CALVERT CLIFFS = UNIT 2 3/435 Amer .. 149 py 4 or 7 1
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DISCUSSION OF CHANGES SECTION 3.3.2 - HPS INSTRUMENTATION - SilUTDOWN adversely affect plant safety, because it places the plant outside the Mode of Applicability. His change is consistent with NUREG 1432. TECHNICAL CHANGES MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED. l DOCUMENTS LA.1 Not used. l LA.2 Current Technical Specification 3.3.1.1 Table 3.31 contains a " Channels to Trip" column. Improved Technical Specification 3.2.2 will not contain this information. This is an informational column which is more appropriate for the Bases. %e number of channels to trip will not be changed. He information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. Ilowever, any hardware change to the number of 4 channels to trip will require a design change. The Bases Change Control Program will ensure that change rgelves appropriate review. This change is a less restrictive movement of details change with no impact on plant safety, nis change is consistent with NUREG 1432. LA.3 Not used. l TECHNICAL CHANGES I.FRS RFETRICTIVE L1 Current Technical Specification 3.3.1.1 Applicability requires the Rate of Change of Power-liigh functional unit to be Operable when any RTCB is closed and any CEA is capable of being withdrawn. Improved Technical Specification 3.3.2 will change the Modes of Applicability to be Modes 3,4, and 5, with a'.y RTCBs closed and any CEA capable of being withdrawn. His change is reasonable because the CEA withdrawal events are not postulated in Mode 6 and cannot occur when the reactor is defueled, and Boron Dilution in Mode 6 is not terminated by a reactor trip. %ese events are not postulated in Mode 6 or cannot occur when the teactor is defueled. Relaxing the Modes of Applicability constitutes a less restive change. His change is consistent with NUREO.1432. L.2 Current Technical Specification 3.3.1.1, SR 4.3.1.1.2 requires that the logic for the bypasses be demonstrated Operable prior to each resetor startup, unless performed during the preceding 92 days and requires the total bypass function be verified once per refueling interval (24 months). Manually or automatically inserted bypasses allow plant operation under conditions that do not require the respective RPS functions, but would result in an unnecessary RPS trip if they were not bypassed. He total bypass functions remove these bypasses when the plant conditions no longer support allowing the bypasses. Improved Technical Specification SR 3.3.2.4 requires the total bypass function be verified every 24 months. This is consistent with safety analysis assumptions that the automatic bypass removal function operates. He capability to bypass a function when it is not needed is not assumed in safety analyses since it performs no mitigative function. Therefore, this requirement is deleted from the Technical Specificanons. His change is consistent with NUREG 1432. , t CALVERT CLIFFS - UNITS 1 & 2 3.3.2-3 Revision 8
J i l 17. To resolve NRC comment 3.3.2 5, references to CEOO. 91 (TSTF.180) were removed from the j STS markup supporting the addition of the automatic bypass removal feature to the Limiting 4 Condition for Operation (LCO) 3.3.2 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, i, ' I ) a
.I L
i
.i
~
...,w ,,nvr,+ .-,-~,--en-,,-- n,- , w v -w m -. , ,,,n,,,,,nw- ~ , , , ww.. ,we , , . . - - - - - - , - + , , , , ,-en,,- -,, -,.n~7,
RPS Instrumentation-Shutdown (I" .;53 g 3.3.Z 3.3 INSTRUMENTATildi 3.3.2 Reacter Protective System (RPS) Instrumentatten-Shut @y d) 64
- W (3 3,Q LC0 3.3.2 Faur " - -- - take of ft -High-nattunenF trx"alshd;l be OPERABLE 6 wtts an A:rir units md ansactated Wee,,, c.,
anotIf GAlger s jp.ej ops) M urhfadoma%r.b c yynt ' - f57f.S2 / n <. 1Y: R) DES 3 4 and 5, alth any reactor trip circuit breakers (RIC3s)closecandanycontrolelementassemblycapable of being withdrawn. os* 4 3
. _ - n0TE . . ._Y _
r1 any be bypassed when THERMAL POWER is < IE-4hRTP. B ass shall be autcastically removed non TH RMAL POWER is 1 IE-4 RTP.
'h ACTIONS COM)! TION REQUIRED ACTION t CuMPLETION TIME I 7 Nisi s
*F we A. One Power Ra La of Chancer-High trip unit A.1 Place affected rip unit in bypass or I hour [le) h or asrociated trip.
Y nope . 83 4Ndfl bidaO
'* * * '
- N* f 4e:p w%1 33.l./
A.t.1 RestoreMhannel to OPERA 8LE status. k48bours g55ea,ygg }. Q _ 4, m, 44.no 4 - 2.A Qg A.t.2 Place affsetedItrip 48 hours ~ unit in trip. (continued)
.A.
CEOG STS 3.J-Il Rev 1, 04/07/95 mbt
DISCUSSION OF TECitNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.3- INSTRUMENTATION
- 28. . Response Time Testing will be added to Specification 3.3.9, "Chu'wl and Volume Control System Isolation Signal" The response time is currently tested ( : E signal at Calvert Cliffs and was therefore added to the Calvert Cliffs ITS. This change 1. e ariitent with the Calvert Cliffs current licensing basis.
- 29. This change makes the channel check for the Rate of Change of Power - Illgh RPS trip only applicable to the Wide Range Logarithmic Neutron Flux Monitor. The channel check can only be performed on that equipment, and this change is consistent with the Calvert Cliffs current licensing basis.
- 30. Specification 3.3.4 will not include a Containment Radiation - High function for ESPAS because Calvert Cliffa does use Containment Radiatl'n - High for ESFAS. This change is consistent with Calvert Cliffs design.
- 31. NUREG-1432 Specification 3.3.3 Conditions B and C contain Notes which state the Reactor Trip Circuit Breakers (RTCBs) associated with one inoperable channel may be closed for up to one hour for the performance of an RPS Channel Functional Test. Calvert Cliffs ITS 3.3.3 Conditions B and C will not contain this Note. The Note is not required because LCO 3.0.5 w!!!
allow the RTCBs associated with the inoperable channel to be closed to perform testing. Limiting Condition for Operation 3.0.5 allows equipment that has been removed from service or declared inoperable to comply with Actions to be returned to service under administrative control to perform testing required to demonstrate its Operability or Operability of other equipment.
- 32. Specification 3.3.3 will not include a Condition Note which allows three Matrix Logic channels to be inoperable due to a common power source de-energizing three matrix power supplies. The Note is not needed because if a power supply is lost, three matrix logic channels are de-energized and one trip leg is lost (four RTCBs are open in one trip leg). This places the plant in a safe condition. If a power supply fails and the RTCDs do not open, an operability determination must be made to determine the inoperability. It is not necessarily a Matrix Logic problem. This change is consistent with Calvert Cliffs' design.
- 33. NUREG 1432 Specification 3.3.1 prc.4 des an Action (Action F) which requires a shutdown to MODE 3 if the Required Actions and associated Completion Times are not met. Improved Technical Specification 3.3.1 separates this Action into two different Actions, Actions F and G, based on the Modes of Applicability of the associated functions. The Loss of Load and Axial 1
Power Distribution-High functions may be bypassed below 15% RTP and are not required to be operable. Therefore, NUREG Action F is retained for all other functions and a sepaute Action (Action G) is added which only requires a swer reduction below 15% RTP consistent with the requirements for operability of the Loss of Load and Axial Power Distribution-High functions.
- 34. NUREG-1432 Specification 3.3.2 requires the Rate of Change of Power-High RPS trip function to be Operal.:e during shutdown. Improved Technical Specification 3.3.2 also requires the automatic bypass removal feature associated with this function to be Operable as part of the LCO statement. Current Technical Specification 4.3.1.1.2 requires the bypass , functions to be
. demonstrated operable and CTS Table 3.31 footnote d indicates that this function has an , associated bypass feature. The NUREG provides actions for an inoperable bypass feature and CALVIE. CLIFFS - UNITS 1 & 2 3.3-5 Revision 8
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.3 - INSTRUMENTATION l also provides surveillance requirements for demonstrating the function Operable. This change maintains consistency within the ITS and is consistent with the current Technical Specification requirements.-
- 35. NUREG 1432 Surveillance Requirement 3.3.3.1 requires quarterly testing of the RTCDs. CTS Table 4.31 requires the RTCBs be tested on a monthly basis. Calvert Cliffs has retained the existing more frequent testing of the RTCBs consistent with the licensing basis and CEN 327, "RPS/ESFAS Extended Test Internal Evaluation," June 2,1986, including Supplement 1, dated March 3,1989.
- 36. NUREG 1432 Condition E of LCO 3.3.3 is stated as "One or more functions with two or more
. . . inoperable. This specification is not " function" based, i.e., the functional parameters that can be inoperable under this LCO are already stated in Condition E. There are no other functions covered by this LCO which depend on these functions. The NUREO statement is not used in any other condition of the LCO and is in error. The statement is deleted from ITS 3.3.3 consistent with the design of Calvert Cliffs.
- 37. NUREG-1432 Condition B of LCO 3.3.7 requires placing the purge valves in the closed position and entering the applicable conditions of LOO 3.6.3 for the inoperable purge valves which result from an inoperable manual actuation or automatic actuation channel. These actions are in error and have been corrected in ITS 3.3.7 to require either the valves be closed, or the actions of LCO 3.9.3 be entered for inoperable valves. The STS reference to LCO 3.6.3, Containment Isolation Valves, is inappropriate since that LCO applies in Modes I, 2, 3, and 4 whereas, LCO 3.3.7 is applicable during core alterations and movement of fuel. LCO 3.9.3, however, has the same applicability of LCO 3.3.7 and is the appropriate reference. The STS is also in error to require both actions be accomplished since the actions are somewhat redundant. Closure of the purge valves performs the safety function of the automatic and manual functions covered by the LCO. The actions of LCO 3.9.3 would require that core alterations and fuel movement be suspended which removes the unit from the mode of applicability. Therefore, ITS 3.3.7 Condition B replaces the "and" requirement in the STS with an "or" to indicate that these actions accomplish the same desired result. This change is also consistent with the requirements of the STS for each of the other PWR owners groups.
- 38. The Applicability of NUREG LCO 3.3.1 is MODES I and 2. The ITS Applicability references Table 3.3.1-1, and Table 3.3.1-1 has a column specifying the Applicability for each Function in the Table. This method is necessary since each Function does not have the same Applicability; two of the Functions are only required in MODE 1215% RTP. This change is also consistent with the Calvert Cliffs CTS Table 3.3-1,
- 39. NUREG-1432 SR 3.3.9.2, Note 2, requires testing of relays after 24 hours of Mode 5 operation for relays that cannot be tested during operation. These relays would cause a closure of the letdown line which is undesirable during unit operation. The CVCS actuation logic is currently not required by the Technical Specifications. The 24 month test frequency proposed in ITS SR 3.3.9.2 is consistent with the CTS Table 4.3-2 footnotes 2 6 for other ESFAS functions actuation logic which cannot be tested online. The requirements of the STS would impose an unnecessary more restrictive change on plant operations and are not adopted. ,
CALVERT CLIFFS - UNITS 1 & 2 3.3-6 Revision 8
t
)-
RPS Instrumentation-Shutdown
- BASES
- I APPLICABLE SAFETY ANALYSES (continued) analysts plant. and the NRC staff approved licensing basis for theacciden These Functions may provide protection for !
demonstrate Function wrfomance. conditions that de not require dynamic transtan Other Functlens, such as the Loss of Load trip, are purely equipment protective. and their use alnletzes the potential for equipment damage]. [de ' ThelEggrJRate of Changet-High trip is used to trip the reactor rate when excore wide range power indicates an excessive of change. h _Ibe4PEEMRate af r"Dinh ted:Mt reeutM 2-e orc Q tylerves startup rate as a m aup to tne noministratively limit. a (
'The for even@ ts such as a continuous dilution avut from low power levels.. The ra a boron Rate of h
CEA withdRate of ChangebHigh Func chang W H1 h trip is automatically bypassed J E-41 1T as sensed bistable, the wide range nuclear instrument anLnavat en poor counting statistics may lead to
- erroneous indication. It is also bypassed at > 125 RTP \, ) where moderator temperature coefftetent and fuel tempera,ture This bypass is effected by the power range NI Level Icoefficient make h bistablei Automatic bypass removal is als ted by these bistables. With the RTC8s open, the change--High trllr-is Tiot required to be'0P
- ate of 2
; however r the indication and alars Functions of least two/cnanne,ls ' w,4, are required to be OPERABLE. LCO 3.3. ' ' " ,
range channels are available to detect ensures the wide < operator to a boron dilution even d alert the g, The RPS instrumentation satisfie Criterton 3 of h _ _
,[L c o '5.
w -
.L = 7.3.7. a b M
- 4 y ppc-bie LCO The LC0 requires all instrumentation performing an RPS Function to be OPERABLE.
the inoperable instrument and reduceschannelorenders the affected channel (s) Failure of any required p Functions, the reliabtitty of the affected gg.g,--qc;D o & (continued) CEOG STS g 3,3 39 Rev 1. 04/07/95
._ c ' +DOA ~
_ _ .. - _ . _ _ . . - - _ . . _ . _ . _ _. ..-. _.. _ ._.m.._ _ . . ,_ __ . . . _ _ _ . _ _ . . . l i
- 18. To resolve NRC comments 3.3.31 and 3.33 8, references to TSTF-79 were removed from the .
i- l STS markup supporting the addition of the automat lc bypass removal feature to the LCO 3.3.2 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 3.3.3.2 was removed. -+
. i g.
i i t 4 i 2. 4 4
RPS Logic and Trip Ini ,1ation 3.3.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Two channels of RTCBs D.1 Open the affected Immediately 9 or Trip Path Logic RTCBs. affecting the same trip leg inoperable. E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time of Condition A, AND B, or D not met.
. E.2 Open all RTCBs. 6 hours 03 Two or more Manual Trip, Matrix Logic.
Trip Path Logic, or RTCB channels inoperable for reasons other than Condition A or D.
, SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform a CHANNEL FUNCTIONAL TEST on each 31 days RTCB channel.
SR 3.3.3.2 Perform a CHANNEL FUNCTIONAL TEST on each 92 days RPS Logic channel, p 5 i i CALVERT CLIFFS - UNITS 1 & 2 3.3.3-2 Revision D'S
. - ~ _ . - . - , _
. ~ . . . _ . - - - . . . . - . - . .
~
1 i-RPS' Logic and Trip Initiation - B 3.3.3 BASES'- r RTCBs. All;RTCBs-should then be_ opened, placing ~the_ plant. , in a MODE-where the LCO does not apply and ensuring no CEA ! withdrawal occurs. ' i- l 1- . ) ) [. ~ SURVEILLANCE SR 3.3.3.1 i REQUIREENTS A CHANNEL FUNCTIONAL _ TEST'is performed on each RTCB channel every_31 days. This verifies proper operation of each RTCB. : l- The RTCB must then be closed prior to testing _ the other RTCBs, or a reactor trip may result. ~ The frequency of 31 days is based on the reliability analysis presented in , topicalreportCEN-327,"RPS/ESFASExtendedTestInterval- , l Evaluation"(Ref.4). . 4 SR 3.3.3.2 A CHANNEL FUNCTIONAL TEST on each RPS Logic channel is 7
- perfomed every 92 days to ensure the entire . channel will perfonn its intended function when needed.
In addition to reference voltage. tests, the RPS CHANNEL FUNCTIONAL TEST consists of three overlapping tests 'as described in Reference 3. Thase tests verify that the RPS is capable'of performing its intended function, from-bistable input through the RTCBs.- The first test, the instrument channel' test, is addressediby SR 3.3.1.4 in LCO 3.3'1.- . This SR addresses the two tests associated with the RPS
. Logic: Matrix Logic and Trip Path Logic.
Matrix' Loaic Testi _ These tests are performed one matrix at a time. They verify that a coincidence in the two instrument channels for each Function removes power from the matrix relays. During testing, power is applied to the matrix relay test coils and CALVERT CLIFFS - UNITS 1 & 2' B 3.3.3-13 Revision g 8
I RPS Logic and Trip Initiation h [c ti) ACTIONS (continued) Co@lTION < REQUIRED ACTION COMPLET!0N TIME E. Required Action and E.1 i assoc 1ated Completion Se in MODE 3. 6 hours Time of Condition A. All2
"## B, # D not met.
J.1.l . I g E.t Open all RTCBs. 6 hours one M.1 or mod Funot'iool
;wo or more 3b Tr ' Matrix 4
' Logic, T Tr.'P m Logic, or C!/ channels inoperable pg for reasons other than Condition A or D. 1 SURVEILLANCE REQUIRENENTS SURVE!LLANCE FREQUENCY SR 3.3.3. Perform a CHANNEL FUNCTIONAL TEST on'52 eachdays b RPS Logic channel (3nsJGell chaefiel.
)
Sa 3.3.3h RPS Perform a CHANNEL FUNCTIONAL once within TEST on each ,~ 3,g.g Manual Trip channel. i 7 days prior to
- each reactor @
startup SR 3.3.3.3 / Perform a CHANNEL FUN 10NAL TEST. incli'dihg separate rificatien.of the X18] months
/)
, - g:rvoltagefand unt trips,'on ~each~y g D I
, 3, y, g, R I.3.3.1 ffde% C.w1N#6t. FvNt7;o4L kSi Ud=yS
, , ~ ,, u m a .. a
~ _
CEOG STS 3.3 17 Rev1,04/07/95 ~ i ' 9 k
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.3- INSTRUMENTATION also provides surveillance requirements for demonstrating the function Operable. This change maintains consistency within the ITS and is consistent with the current Technical Specification requirements. t
- 35. NUREG 1432 Surveillance Requirement 3.3.3.1 requires quarterly testing of the RTCDs. CTS Table 4.3-1 r: 'uires the RTCBs be tested on a monthly basis. Calvert Cliffs has retained the existing more frequent testing of the RTCDs consistent with the licensing basis and CEN 327, "RPS/ESFAS Extended Test Internal Evaluation," June 2,1986, including Supplement 1, dated March 3,1989.
- 36. NUREG 1432 Condition E of LCO 3.3.3 is stated as "One or more functions with two or more
. . . inoperable. This specification is not " function" based, i.e., the functional parameters that can be inoperable under this LCO are already stated in Condition E. There are no other functions covered by this LCO which depend on these functions. The NUREG statement is not used in any other condition of the LCO and is in error. He statement is deleted from ITS 3.3.3 consistent with the design of Calvert Cliffs.
- 37. NUREG-1432 Condition B of LCO 3.3.7 requires placing the purge valves in the closed position and entering the applicable conditions of LCO 3.6.3 for the inoperabic purge valves which result from an inoperable manual actuation or automatic actuation channel. These actions are in error and have been corrected in IT. 1.3.7 to require either the valves be closed, or the actions of LCO 3.9.3 be entered for inw alves. The STS reference to LCO 3.6.3, Containment Isolation Valves, is inapproprm. ....ee that LCO applies in Modes 1, 2, 3, and 4 whereas, LCO 3.3.7 is applicable during core alterations and movement of fuel. LCO 3.9.3, however, has the same applicability of LCO 3.3.7 and is the appropriate reference. The STS is also in error to require both actions be accomplished sin e the actions are somewhat redundant. Closure of the purge valves performs the safety function of the automatic and manual functions covered by the LCO. The actions of LCO 3.9.3 would require that core alterations and fuel movement be suspended which removes the unit from the mode of applicability. The*refore, ITS 3.3.7 Condition B replaces the "and" requirement in the STS with an "or" to indicate that these actions accomplish the same desired result. His change is also consistent with the requirements of the STS for each of the other PWR owners groups.
- 38. The Applicability of NUREG LCO 3.3.1 is MODES I and 2. The ITS Applicability references Table 3.3.1-1, and Table 3.3.1-1 has a column specifying the Applicability for each Function in the Table. This method is necessary since each Function does not have the same Applicability; two of the Functions are only required in MODE 1215% RTP. This change is also consistent with the Calvert Cliffs CTS Table 3.3-1.
- 39. NUREG-1432 SR 3.3.9.2, Note 2, requires testing of relays after 24 hours of Mode 5 operation for relays that cannot be tested during operation. These relays would cause a closure of the letdown line which is undesirable during unit operation. The CVCS actuation logic is currently not required by the Technical Specifications. The 24 month test frequency proposed in ITS SR3.3.9.2 is consistent with the CTS Table 4.3 2 footnotes 2-6 for other ESFAS functions actuation logic which cannot be tested online. The requirements of the STS would impose an unnecessary more restrictive change on plant operations and are not adopted. ,
CALVERT CLIFFS - UNITS I & 2 3.3-6 Revision 8
_ _ . - . _ ._ _. ~ .__ . _ . _ . _ _ .- _... _ . _ _ .._. . . _ _ . _ . _ __ _ _ _ _ _ _ _._ _ _ _ _ s A 3,3.3.1_ h DIAWWnW 1&ST ,y,{.,M .n e, k R tcs ska..<I esay SI I,s . . i !' T4 wrAs per yrha .f cad (T(4, % Ric6 a 4 A Le ekJ p%- h ffd'% h e a n ,c 9 7085 ,r a rtaderirep %y r(sdh Wh ,Amyef t 11 d6yf ts bes(J en g ($.) f ile,dtdillla!.lr,geest4Mln y p anTii Initf~attoii P-Q $ ! *#*#*E ' BASES 4,p (continued ) ,<prf clN alvil,v AL1 Of $[($N M O & est Ss4ted SURVE!LLANCE Revi s Note: in o r for a credit for REQUIREMENTS .topi 1 reports as asts for ,1ustifyt plant to t t cal reports aus Frequencies, supported by as staff Safety aluation Report at estabitshes the j-4 ( epical report f thatunit(Ref.4). captability of a h _j SR 3.3.3 . A CHANNEL FUNCTIONAL TESTne ApS Logic channelrent BR O fis performed every 1497 e anne. will perfore its irtan;s ays to ensure the^'entire ~ ! funettaa "-
;d l
g _ A r cF lr e b e# yet te ~ In addition to g5Wr sypp1btens TheEcnnnnu ~ . FUNCTIONAL TEST consists or three, overlapping tests as described in Reference 3. These tests verify that the Rps ! "" is capable of performing its intended function, from j '* '" '*4 istable input through the RTCOs. The first test, the test, is addressed by SR 3.3.1.4 in LC0 3.3.1. c w% r (- e h t This LogicSR Matr4x addresses Logic andtheTriptwoPat tests associated with the RPS A (2), 7 Matrir Loate Tests %
./
i' These tests are performed one a time.- They verify ~
~
i that a coincidence in the two channels for each ! Function removes power from th lx relays. During i testing, power is applied to the matrix relay test coils and
- . prevents the matrix relay contacts from assuming their de-energized state.
'short circuits around the blstable contacts in theThe Matrix Logic tests will dete coincidence 1 ch as may be caused by faulty histable g relay or trip c bypass contacts.
Trin Path Tests 4c,p g w, ? These tests are sie ar to the Matrix Logic tests except that test power is Ithheld free
- allowing the (Lnl 1st4eib circuit oone matrix relay,at a time, de-energtze, opening the affected sat or RicBs, The to testing the other 'three ni a must then be closed prior o circuits, or a reactor
{L e trip say result. - ! .t i \ i (continued) CEOG STS 8 3.3-59 Rev1,04/07/95 i .- s6 )
RPS Logic and Trip Initiation h BASES , SURVEILLANCE Ir.igftp,Initi REQU!REMENTS continued) Y The analysis present Frequency of 92}> days is based on the reliability in topical report CEN-317, 'RPS/ESFAS Extended Test Interval Evaluation * (Ref.J). f SR 3.3.
' A CHANNEL FUNCTIONAL TEST on the Manual Trip chanc.els is h
performed prior to a reactor startup to ensure the entire
! channel w111' perform its intended function if required. The Manual Trle Function can be tested either at power or shutdown. 'However, the staplicity of this circuitry and the absence of drift concern makes this Frequency adequate. -
Additionally, operating experience has shown that thes's components usually pass the Surveillance when Hrfomed once within 7 days prior to each reactor startup. C -- 1 SR 3.3.3.3 Each RTC8 is ac} ated by an undervoltage co 1 and a shunt
'\ trip coll. Thr systee is designed so that either de-energizi the undervoltage coil or e rgizing the shunt
' ~! trip coil w I cause the circuit breake to open. When an RTC8 is o ed, either during an aut by usi ic reactor tri e manual push buttons in e control room, p theor t undervo age coil is de-energized a the shunt trip coil is energt d. This sakes it impossib the c is or associated circuitry is defective. to detemine if one of Th efore, once every 18 month , a CHANNEL FUNCTIONAL TEST i performed that individuall tests all four sets of dervoltage coils and all f ur sets of shunt trip cotis j/ ' ring undervoltage coil t ting, the shunt trip coils sn : remain de-energized, prev ting their operation. Conversely, during shunt rip coil testing, the underv tage coils shall remain ene tred, preventing their operat n. This Surveillance ens es that every undervoltage co and every shunt trip col is capable of performing its atended function and that n single active failure of any TCB component will pre ent a reactor 1r.ip._JThe 18 th Frequency is bas on the need to perform this urveillance under the condi ons thtt apply during a plan outage and the potential for an unplanned transient if t e Surveillance J (continued) CEOG STS B 3.3-60 Rev 1, 04/07/95
. . ~ _ - . . . . . - .~. ,- . . . . - . - . . . . ~ . . . - . - - - . . - . . . _ . - .. .- ..-.- _ . . . . ...
A Y
- 19. . To resolve NRC comments 3.3.3 2 and 3.3.3-3, Discussion of Changes M.! and M.3 have been deleted and replaced with Discussion of Change A 9 and Discussion of Change M.6 is deleted i and replaced with Discussion of Change A.10. These changes are necessary to reflect that the
- y. _
conversion of the mode of applicability for the trip logic and reactor trip circuit breaker functions f is administrative rather than more restrictive. 5 t 1
!~%
l 4 s 4 r T l 4 s d I c .I i' y-i I i
,r .,,.v<., , - , . , e y e -m.-
Tpr e.C. oo4.o % 3. 3. 3 m- . -- ' G.c ,4. . - - . t ., or R.95, tw N , .~ ;a 6 , C '
^*-"le o 8- ,
/ (115 T op Pu t.5. , F~r eb-<ts or r.uk, 4,;rs
'. c., e o:4 t.. -a..., ( pre.(L A . - d C * . '. . . . % . r v. . .. (
A ., 7.'s
- T.'3 3
-S & 3 INSTRUMENTATI M 9/4rM. cu..
^-
REACTOR PROTECTIVE usi;.;-; 4^ Aiivn wW h ..,d [Tr; la.b N LIMITING CM DITI M FOR OPERATI M t, c o
-3.:.:.: @
n' 3 by;:::a ;f Stu ?.? ! th!" i::. : e r ,1it:m:a:iu um 2_ . .: a., ;=a . ....
= t = 4 -"2 ,
L. . ) APPLICABILITY: ^: th e. 'r. O t k 0.*-1.
** I *"4 2 *i- e ACTION: As shown in Table 3.3-1.
N o oC *h '5'4 .-J 5 <* A * "r RTc.r5 pa y:. < l *v 4 %J
.y e . w.t , etc~ a4
* "" *y S .F i o c.te.s q A,B / ,0, S E **ea%, .r a, ,n SURVEILLANCE REQUITEMENTS 4.0.1.14 Each - ::t^ ;--it-*b't "!t r::te4+en channel shall be h
5 m' .1.D~2. I demonstrated OPERABLE by the performance of the """_.:::L ""I*". """."" L
.e'1?ti'.T!^" iM CilANNEL FUNCTIONAL TEST operations during the MODES and at f'3 M * 3 the frequencies shown in Table 4.3-1.
[.3.1.1.2 The logic for the bypasses shall be demonstrated OPERABLE prich fto each reactor STARTUP unless performed during the preceding 92 days. The total bypass function shall be demonstrated OPERABLE at least once per REFUELING INTERVAL during CHANNEL CALIBRATI0ii testing of each channel fected by bypass operation. , f
/ .3'.1.'1.} "The"liERf6ft'TR1f$YSTEM RESPONSE TIME of each reactor trip (RETUELINGINTERVAL. function shall be demonstrated to be within its limit at least once per Each test shall include at least one channel per function such that all channels are tested at least once every N REFUELING INTERVALS where N is the total number of redundant channels in a specific ,i Q1e3.3-1. freactor trip function as shown in the ' Total No. of Channels" column ofj 4*e </'s u d,. .f A . . ,, s i C>r $p R .,4..n D I .-J 3. 's. 2
)
I"4 r - C4-c. " . .t
- RPS ( au r.
%A.t. .
- i
(. NeutrondetectorsareexemptfromresponsetimetestI@ CALVERT CLIFFS - UNIT 1 3/4 3-1 Amendment No. 208 d E I .F 1o 9 Se
9 N 4 Ei
'd FIMCTI0llAL IMIT b [e
=
qn"*ew ts m
' a m zonse 2 <-
a 3" c 41 L59 INDES ACTICII g 1. Manual Reactor Trip 1 (2 [ _; 1. 2 an [ g 4 1
- 2. Fr- r Leves - .uva e
~
Z g
" F'
- 3. Reactor' Coolant flow - Low
, 4. 4 z' ] j 4/SG 2(*l/SG 3/SG I
- 1. 2 '3 28
- 4. Pressurizer Pressure - High 4 2 3 1. 2 2#
F. Containment Pressure - High 4 2 3 6.
- 1. 2 28 Steam Generator Pressure - Low 4/SG 2M/SG 5 7. Steam Generator Water Level - 4/SG 3/SG 1, 2 2' 2/SG 3/56
<;* Low 1. 2 28 i 8. 3xial Flux Offset 4 2I 'l 3
- 9. a.
1 2' Thermal Margin / Low Pressure 4 2 I'3 3 1. 2 (*3 28
- b. Steam Generator Pressure Difference - High 4 2 I*) 3 1. 2 I*I 28 g 40. Loss of Load 4 ?I'3 3 3 -
1 2)8,
= s nn - .c av-
? SncLW 3.3.I "gn 3 g u ,_ 2. u n,. w .;- Y '
~ u b t I 9 9 u
% b,w.u.m aC b%4 Se=S~'" 3 I 'f's L'#' Wu.&;- 5 ,. c.z e u , s J. ,g
%4 .hes 3.2.1 *An A & .ti d de.* *,* .
Q r- TABLE 3.3-1 (Continued) l
'R l h REACTOR PROTEGN Ill5TEWENTATISH *
=
c-
$ OT
~ $
FUE*.30NAL INIIT l APPLICAALK
, a _ -> - _l N ACTISE' e . Wide R&rge Logarltlunic Neufron _
5
~* Flux Mon 1 tor
** A d P '^ p a. STAitTUP and Operating - 4 2M E
. I) *4 kE.y5 1 Rate of Change of Power - 3M 1, h 2' k _. Hlah fh E k' . P h*
u
- b. Shut h 4 0 2 3, 4, 5 3)
- 12. Reactor Protection System Logic L
[ g ?> 'Uh [ 1 Matrices AI ,[T
/
1, 4 p3 [Ej ,
- 13. Reactor Protection System Logic- 4/ Matrix Matrix Relays L
'3/ Matrix 4 1d T
4 i
- 14. Reactor Trip Breake i
/A,/ 18 #S 1, 4
o e
.., as i
a f; m = d F Y $ 1 ; w ,
.U i m 5 :
~
U O I
S pa..f.e k 3.3.3 1 M4_ 3 INSTRUMENTATION TABLE 3.31(Continued) TABLE 50 TAT 104 @
,~ *6u /*d 2 o mkf4,s.t.Q OfrucA8v.sry W1 he ro ,
i p breakers in the closed position and the CEA drive system capable of CEA withdrawal. 8 The provisions of Specification 3.0.4 are not applicable. - (*) d Trip may be bypassed below 10 of RATLs TCM POWER: bypass shall be automatically ' removed when TNERMAL POWER is t 10 of RATD TMERMAL POWER. (N g Trip may be man [ or ally bautomaticallyremovedbassedbelow785pstatbypas I (C) above 785 psia. <h , Trip may be b assed below 15% of RATED THERNAL POWER: bypass shall be automaticahy removed when THERMAL POWER is 115% of RATD E4 THERMAL POWER. S *I O ) ), $ (d) d Trip may be bypassed below 10 4 and above 12% of RATED 111ERMAL 5 oL POWER. I') O Trip may be bypassed during testing pursuant to Special Test Exception 3.10.3. j N There shall be at least two dt. cades of overlap betweien the Wide Range Logarithmic Neutron Flux Monitoring Channels and the Power Range L Neutron Flux Monitoring Channels. j 41.5 ACTION STATDFlgl , p,. k 4#*d*# ' ACTIoW y,1 thy
, @ he ne gl j g f "- 1 5: gEgg cd YINb I$JSE$E }E,.liTi,;d--- L.Ci iFiR$ 7 gMN g (in NOT STANDBY Orotective withintrip system thebreakers next 6 hours (and/op open the .4 ACTION 2 -
y x _h With the number OT vruABLE channels one less than the Totall Number of Channels. STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied
- a. The inoperable channel is placed in either the bypassed I or tripped condition within 1 hour. For the purposes of /
, testing and maintenance, the inop9?ble channel may be j i CALVERT CLIFFS . UNIT 1 3/4 3-4 Amendment No. 169 o
Spasm **E*S 3. 2. 3 3/4.3 INSTttstDITATION
<y" - [ 3 g m.4-u w TABLE 3.3-1(Continued) acr= ==Em s DistA% .F Aap. A em g ,e. s. .+., 3.3.1 : ., .
i [0PERA8ILITY:however,theinoperablechannelshallthenDypasse be either restored to SPERA8LE status or placed in the tripped condition. I 1
- b. Within one hour, all functional units receiving an input from the inoperable channel are also placed in the same condition (either bypassed or tripped, as applicable) as that; required by a. above for the inoperable channel.
- c. The Minimum Channels SPERA8LE requirement is mett however, one additional channel may be bypassed for up to 48 hours while perfonsing tests and maintenance on that
\ channel provided the other inonerable channel is placed in the trinned condition./-
(ACTION 3- With~ the number or enannels UrtRA5LE one less than requirTt
- ] by t'io Minimum Channels SPERA8LE requirement, verify compdiance with the $NUTDOKJ MARGIN requiremants of Specification 3.1.1.1 or 3.1.1.2 as appitcable, wit 8 Qtr and at imaet anre nar 17 hann thmesafter ACTION / - 6by the the n r of channels ur LE one less than require aus Channels OPE reautrement. he in ROT
$TF = Y ithia E haume hae rJ ong4hannel wayJr bypassed '
ror up hour for survati alice / Testing per Specification A.S
} * * )
. k Jre.Y Nc [ W '
s A.
% ercda .a ky las;
; % ?"' @ S fA/,$64Y ACN'Y h f.
- Ark)e b CALVERT CLIFFS - UNIT l' 3/4 3-5 Amendment No. 169
/
k
9
' V.
REACTOR PROTECTIVE INSTMMDITATION SMTEILLANCE REWIRDluiS w" O a DIAMEL MODES N WIG
" C==a C==n r=CrImu SavEIumx -
FUNCTIO m L UNIT CNECK CALIBRATIN TEST eraurers l h 1. Manual Reactor Trip M NA S/UN
-e r m r Level - High MM1
,JWC 2,(3,4.a5}
f 2. - j
- a. Nuclear Power S 1, 2 I DIU.MW.Q(5) Q elO
- b. AT Power S DM.REFWELIN Q I INTERTE i
, 3. Reactor Coolant Flow - Low 5 S REFUELI M INTERVAL Q 1, 2 i
- 4. Pressurizer Pressure - High 5 RETWELIM INTUtVAL Q I, 2
]
$ 5. Containment Pressure - High 3 REFUELING INTDtVAL Q I, 2
- 6. Steam Generator Pressure - Low l S' REFUELING INTUtVAL Q 1, 2 7.-
l ' Steam Generator Water Level - S REFUELING INTDIVE 1, 2 kw Q l ! 4 i
- 8. Axial Flux Offset S REFUELING INTDtVE g 9. a. Thermal Margin / Low Pressure S REFWELINE INTUtvE Q I l .
[ j g b. Steam Generator Pressure S ItEFUELING INTUtT E Q Q 1, 2 1, 2 l [ J , Difference-Righ l [ ! a.
' e i g I s of Load NA y
, NA S/UM. M I.
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K L8,3 g,g APPLICABILITV: ",; .6 in isbis ^.3 i. MooEi..J'2. - - - - - _ em-I S,e a, .<--- e. v.u. i s_, M ooETS 3,+ a-d5, wed **y p=S < RTC.th d . s e d,
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7,,'s, 3.2 demonstrated OPERABLE by;the performance of the%,channlesh,all,,h,,,,
,5, i;, 3 t*"mrfa" d *"2""EL the frequencies FUNCTIONAL shown in Table 4.3 TEST
- 1. operations during the MODES and at .
(T.3.1.1.2 ' to each reactor STARTUP unless performed during Th the preceding 92 d total bypass function shall be demonstrated OPERABLE at least once per REFUELING INTERVAL during CNANNEL CALIBRATION testing of each channel cted by bypass operation. f l function sThe REACTOR TRIP SYSTDI RESPONSE TIME of each reactor trip . T3.1.1.) REFUELING INTERVAL. hall be demonstrated to be within its 1 limit at least on Each test shall include at least one channel per 4 function such that all channels are tested at least once every N REFUEL *NG INTERVALS where N is the total number of redundant channels in a speelfic 1 reactor trip function as shown in the ' Total No. of Channels
- columrt of )
(#* c/ i u . . . . , .( (k.. s i F., 9, . F. e a . . 'L r, ( 4 T. 3. 2, e RPS i.s,,,,-.a +.,".a pp l +,4 , - S t. ., 4 J m ., i Neutrondetectorsareexemptfromresponsetimetestind CALVERT CLIFFS - UNIT 2 3/4 3-1 4 Amendment No. 186 I e 4
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** TO)WL M FUNCTioRAL WIT 4 t sF M. l t M
IWWE3 ACT14 h 1. Manual Reactor Trip # Q r2. T w r Level - Nigh 1.2andI 1
" 4 2 3M 1, 2 27 8
- 3. Reactor Coolant Flow - Low 4/SG I 2*I/$4 3/3G 1, 2 M 28
- 4. Pressurizer Pressure - High 4 2 3
- 5. Containment Pressure - High 1. 2 28 4 2 3 1. 2 2'
- 6. Stema Generator Pressure - Low 4/SG 2M/3G 3/3G 1, 2 28 3 7. Steam Generator Water Level - 4/SG 2/$G 3/$G T'
l'" 1, 2 2' '
- 8. Axial Flux Offset 4 2M 3 1 28
- 9. a. Thermal Margin /Lew Pressure 4 2M 3 1, 2 M 2'
- b. Steam Generator Pressure 4 I Z'3 3 D1fference - High 1. 2 M 2'
' 10. Loss of Load 4 2M 3 1 2' o 4 F ] '
a 2 4 L ......_ .c c L. 3., 1 e p o
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- 4 - -SL.*4.--
g TABLE 3.3-1 (Continued) r- R N
- REACTOR Haritsvart INSTRWENTATIOli **
C r NDIDEgl CEAIEIELS i
" ~ APPLICWLE FUNCTICIIAL WIIIT 'Md.jl t E LOPERABLE g IWBES . _ACTISE j
e 11. Wide Range Logaritfunic Neutron n! 5 Flux Monitor n ) > a -* C d g a. STARTUP and Operating - of Change of Power - 4 2M 3(O 1, 2 28 E 9 b b ", h Shutdown 4 0 2 3. 4, 5 3) k[hIwk
;* i
- 12. Reactor Protection System Logic (6' Natrices / -
(1 ' @ 1 4
. 13.ReactorProtectionSystemLogic[htyfx] / Mat x 1, 2 4 a Matrix Relays
> .A o 9 14. Reactor Trip Breake '6 , 1, Zh 4 2 r },
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- o. !
With thiii ~ tectlve system tri ~ l the CEA d we system capable o CEA withdrawal. kers in the closed position and
- di, 5 s i
f The provisions of Specification 3.0.4 are not appitcable. T f $ $ j 7 4 I*) Trip may be sed below 10d of RATB TEMAL be automatica y removed when TEEMAL POUR is t 1 thall V I. pi h T"t. MAL POWm.
'M i (b) s trip may be $anually bypassed below 785 psias bypass shall be
- automatically removed at or above 786 psia. I
- l4 (8) 4j Trip may be b
, ssed below 15% of RATD TIERNAL POWRt shall I be automatic y removed when THEMAL POWER is 315% of T O THERNAL j POWER. 'f V l Idl { l
- T d gmay be ' bypassed below 10 4 and above 12% of RATB TRERNAL -.
[ (*) 3 Trip Exception may 3.1 be bk3.assed during testing pursuant to Spect&1 Test d
- If)
There shall be at least two decades of overlap between the Wide Range Logarithmic Neutron Flux Monitorin Neutro.n Flux Monitor.ing Channels. g Channels and the Power Range M. ACTIM STATIMENTS t a ,- u..w.~ mu' t ., I bew e L . ACTIM[. {t{.Q,q--. _.... - ...... ..
.. channe , PERABLE .. im 6a n gmi -
_ = .. ... . 1-
'--- -e! c ^ =- :t t: CTJr_ .^ . ^ .,. .; . . ,,,; . . "..t... .
AcpoN E 6n h0T zTAnver within tae next o -un _.-- . - _.. t l_ yrotecttwo avstem trin breakers._ f ] .g (, 2011 2 - , With the number of OPERABLE channels one less than the Total Number of Channels. STAltTUP cnd/or POWu OPERAT1011 may l proceed provided the following conditions are satisfied: 1
- a. The inoperable channel is placed in either the bypassed or tripped condition within 1 hour. For the purposes c testing and maintenance the inoperable channel may i
I CALVERT CLIFFS - UNIT 2 3/4 3-4 j Amendment No. 149 s'
- 4 1 .
l o O poy l
- - . .. _. _ = _ _ _ _ _ - - . . . - _ - _
p,,c. I.e ,f i m N. 3 . '$ 5, e 4, . . s . , r A . . ., r.e s p t,c iC ea 4ow 3. ~1. lt "pg hp"Mb MfDn Flv(Modor Mag 3/4.3 IllsTRISIENTATION g,, cr.. . . .. . . c ec- vs TABLE 3.5-1(Continued) f*' 9 '#'
- i q ,'. - St * * " . \,
byoassed for up to 48 hours from time of tattial loss t f ettRABILITY: however, the f be alther restored to rable channel shall then trfpped condition. - status or pisced in the
- b. WitMn one hour, all functional units receiving an input I from the inoperable channel are also placed in the same condition (alther bypassed or tripped, as applicable) as that required by a. above for the inoperable channel.
c.g The Minimum Channels OptRABLE requirement is mett however, one additional channel'may be bypassed for up 'tr 48 hours while performing tests and maintenanc= on that } channel provided the other inoperable channel is placed j ' in tha ' M aa^d W itten. (ACTI0llT- - With the number of channels OPERABLE one less than requir2 by the M'ntenas Channels SPERABLE requirement, verify compitanca with the SulRDoldi MARG!al requirements of . (Specification 3.1.1.1 hour and at least or 12 once oer 3.1.1.2, hours t as avgreafter.icable,withinj 4 ACTI0llf-th th -~^^r of channel PERABLE one le y th t* imum Channels LE hanrequir/ed
. be in NOT within 6 hau d.c a a )_reauf one channes may se oypass '1
. or up to I hour for surveillance testing per Specification A-
, 4.3.1.1. s __
l ww RT Acta ou t5 ! p., atcn' eJ Tr',p ,- pg, L...e _. f-
- us AC _h Q, h '
GsyOWG j O A.9 t),7 g + eef ~e a eD CALVERT CLIFFS - UNIT 2 3/4 3-5
- l. Amendment No. 149
+- ,, 4 4 0 l
f g h '$ REACTOR PROTECTIVE INSTRUNDITATI0lt SEVEILIANCE acaurIRDENTS w O mast pggES IN W ICN 4
" CNANilEL CIIAlglEL FUNCTIOML SOltVEILIANCE l
, FUNCTIONAL WIT CNECK _CALIBRATIOR TEST RE951 RED g 1. Manual, Reactor Trip NA NA S/Um y
~ . - - -
m _, , 4 ( 2. Power Level - High N1312 _
- a. Nuclear Power S Om,gw.Q Q I. 2
- b. AT Power S DM.REFUELIM Q 1 INTERVAL '
, 3. Reactor Coolant Flow - Low S REFUELIIIG IIITEltVAL Q I, 2 D 4. Pressurizer Pressure - High l
" S REFWELIIIG IIITEltVAL Q 1, 2 l
a 5. Containment Pressure - High S REFWELIIIG IllTEllTAL Q 1, 2
- 6. l Steam Generator Pressure - tow $ REFWELIllG IIITEltVAL Q I, 2
- 7. l S'eam Generator Water Level - 3 1, 2 REFUELIIIG IltTERYAL Q Low l
- 8. Axfal Flux Offset S REFWELIM IllTDtfAL Q 1 l g 9. a. Therpal Margin / Low Pressure S REFWELIIIG IllTEltfAL Q 1, 2 l g" b. Steam Generator Pressure S REFUELIE INTEltfAL Q 1, 2
, Difference - High l h 10. Loss of Lead NA NA 5/UM NA a
q J
=
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g i ,., . . _ . v . _ _ _ or. C ~ g d
(, 2. s c o +s ., , .O , t. .
,s y ,, J. un s . ., ., l' e t. . , , ,, s E,, S p,, r. . 4 . ~ 3. 3. <, " PS 5 p., g,,, ,. p, . 4. . n ~2, "Rf4 i.2,,-4s..,- o ;y, + A N d A - ,- "'
I a , . ,.-4 . 4 . ., 9 TABLE 4.3-1 (Continued) w G 2 g REACT 0lt ruitwyt, INSTRUMDITATION SUltTEIllamet ernar!ItDElfr$ i.e n C 4
= -
GAlgIEL cnAleEL MODE 3 N WIDI aussiEL FWCTI0luit ssRTEIWulCE FWCTICIIAL WIT _ GECK CALIBitATI0lt senarreen TEST
'II. Wide Range Logaritfunic flectron Flux S utreuIIIG IllTEltTALW S/FW R_. Monitor 1, 2/3, 4 { - l
-e
;3 R
- 12. Reactor Protect'on System Logic M Matrices, M
.s R 3,y.3,2, Q & 2. (( 54,Sh (
- 13. Reactor Protection System Logic M M Q O,,,
Matrix Relays 1 ,6,, 4, S') ' g 14. Reactor Trio Breakers M NA SR 5.5.5.t M 1. 2 and
- u r L6 gc- =g D G
f
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D
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DISCUSSION OF CIIANGES SECTION 3.3.3 - RPS LOGIC AND TRIP INITIATION i A.7 Current Technical Specification Table 331 requires eight channels of RTCB. Improved Technical Specifications will require four channels of RTCDs with each channel containing two RTCBs. This change does not technically alter the CTS requirements; it changes the definition of an RTCB channel, nerefore, this change is administrative. This change is consistent with NUREG 1432. A.8 . Current Technical Specification Table 331, Action A allows one RPS channel to be bypassed for up to one hour for surveillance testing per Specification 43.1.1 (CFT). Improved Technical Specification 333 will not contain this allowance. This allowance is not needed to allow performance of a CFT because ITS LCO 3.0.5 allows equipment that has , bsen removed from service or declared inoperable to comply with Actions to be returned to service under administrative control to perform testing required to demonstrde its Operability or Operability of other equipment. He deletion of an allowance that is allowed per Section 3.0 is an administrative change. This change is consistent with NURFG-1432, generic change TSTIf,181. A.9 Current Technical Specification 33.1.1 Applicability for the Matrix Logic, Trip Path Logic, RTCBs, and Manual Trip is Modes I and 2, and with any RTCBs closed and any CEA capable of being withdrawn. Improved Technical Specification 3.33 will revise the Applicability for these functions to be Modes I and 2, and Modes 3,4, and 5, with any RTCBs closed and any CEA capable of being withdrawn. This change is considered administrative since the CTS Mode of Applicability would bound the ITS Modes of Applicability. The deletion of this requirement in Mode 6 is addressed in a separate Less Restrictive Change. Associated with this change is the addition of ITS Action C for the Manual Trip, RTCBs, and Trip Path Logic in Modes 3,4, and 5. His action is consistent with the existing requirements in CTS Table 33-1 Action 1 and is considered administrative. His change is consister,t with NUREG-1432. A.10 Current Technical Specification 4J.1.1.1 has no specific Mode in which a CIT is required for Manual Reactor Trip. Improved Technical Specifications require the test for Modes I and 2, and Modes 3,4, and 5 with any RTCBs closed and any CEAs capable of being withdrawn. This was actually the intent of the LCO, as shown in the Mode of Applicabil."y in CTS Table 33-1, except it is no longer required in Mode 6, whl:h is discussed in a separate less restrictive change for the LCO Applicability. The requirements of the surveillance does not change, only the Mode in which it is required is clarified consistent with other parts of the CTS. Therefore, this change is administrative. His change is consistent with NUREG-1432. TECHNICAL CHANGES - MORE RESTRICTIVE M1 Not used. l M.2 Current Technical Specification 33.1.1 does not contain Actions when the required Actions and associated Completion Times for the Manual Trip, Matrix Logic, Trip Path Logic, and RTCBs cannot be met, or if two channels of these (except as required by Action Notes) are inoperable. Therefore, CTS would require an LCO 3.03 entry. Improved Technical Specification 333 contains specific Actions for these conditions. The ITS would require a CALVERT CLIFFS - UNITS 1 & 2 333-2 Revision b i
DISCUSSION OF CHANGES l SECTION 33.3 - RPS LOGIC AND TRIP INITIATION power reduction to Mode 3, and the opening of all RTCDs within six hours. The new ITS requirement is more stringent since it requires a reactor trip after six hours, whereas the CTS
' does not, his more restrictive change will not adversely affect the safety of the plant. His change is consistent with NUREG 1432.
M3 Not used. l M.4 Current Technical Specification 33.1.1 Action I requires the unit to be in Mode 3 within 6 hours "and/or" open the protective system trip breakers, improved Technical Specification 333 Action E requires the unit to be in Mode 3 within six hours, "and" to open RTCBs. This change constitutes a more restrictive change because it requires the RTCBs to be open regardless if the unit is placed in Mode 3 within 6 hours, whereas the CTS does not require the RTCBs to be open if the unit is in Mode 3 within 6 hours. The change does not adversely affect plant safety, because it requires the RTCBs to be placed in a , condition which satisfies their safety function. This change is consistent with NUREG 1432. 1; M.5 Current Technical Specification 33.1.1 Action I allows 48 hours to restore an inoperable l Manual Reactor Trip channel to Operable status. Improved Technical Specifications 333 Action B requires the affected RTCB to be opened. This change allows no action to be taken for 48 hours when I channel is inoperable, whereas the ITS requires the affected RTCB to be opened. Therefore, for the first 48 hours, this change is more restrictive. This change does not adversely affect plant safety, because it requires the affected RTCB(s) to be placed in a position to meet their safety function. This change is consistent with NUREG-1432. For any time after the first 48 hours, this change is discussed in a less restrictive discussion of change. M.6 Not used. l M.7 Current Technical Specification 33.1,1 does not provide Actions when two channels of RTCBs or Trip Path Logic affecting the s .mc trip path are inoperable. Thus, CTS LCO 3.03 would be entered requiring a unit shutdown to Mode 3 in 7 hours. Improved Technical 4 Specification 333 Action D requires the affected RTCDs to be opened immediately. This change is more restrictive and is acceptable because the opening of any one remaining RTCB + would cause a reactor trip and the affected channels' safety function would be satisfied. This change is consistent with NUREG 1432. TECHNICAL CHANGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED-DOCUMENTS LA.1 Current Technical Specification 33.1.1 Table 33-1 contains a " Channels to Trip" column. Improved Technical Specification 333 will not contain this information. This is an informational column which is more appropriate for the Bases. The number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that changes receive appropriate review. This change is a less restrictive movement of details change with an impact on safety. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 333-3 Revision 8
( 20 To resolve NRC comments 3.3.3 5 and 3.3.3 6, references to CEOG 73 (TSTF.170) and CFOO 94 (TSTF.182) were removed from the STS markup and the !TS 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. V'
EPS Logic and Trip Initiaticn 3.3.3 3.3 INSTRUMENTATION 3.3.3 Reactor Protective System (RPS) Logic and Trip Initiation LCO 3.3.3 Six channels of RPS Matrix Logic, four channels of RPS Trip Path Logic, four channels of reactor trip circuit breakers (RTCBs), and four channels of heaual Trh shall be OPERABLE. APPLICABILITY: MODES 1 and 2, i MODES 3, 4, and 5, with any R'iLBs closed and any control i element assemblies capable of being withdrawn. ACTJONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Matrix Logic A.1 Restore Matrix Logic 48 hours channel inoperable, channel to OPERABLE status, t B. One channel of Manual B.1 Open the affected 1 hour Trip, RTCBs, or Trip RICBs. rath Logic inoperable in MODE 1 or 2. 1 l C. One channel of Manual C.1 Oper, all RTCBs. 48 hours 2 Trip, RTCBs, or Trip Path Logic inoperable in MODE 3, 4, or 5. CALVERT CLIFFS - UNITS 1 & 2 3.3.3-1 RevMion # S
l RPS Logic and Trip initiation 3.3.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. Two channels of RTCBs D.1 Open the affected Immediately 9 or Trip Path logic RTCBs. affecting the same trip leg inoperable. E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion Time of Condition A. AM B, or D not met, g E.2 Open all RTCBs. 6 hours Two or more Manual Trip, Matrix Logic. Trip Path Logic, or RTCB channels inoperable for reasons other thaa Condition A or D. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform a CHANNEL FUNCTIONAL TEST on each 31 days RTCB channel. SR 3.3.3.2 Perform a CHANNEL FUNCTIONAL TEST on each 92 days RPS Logic channel. 9 CALVERT CLIFFS - UNITS 1 & 2 3.3.3-2 RevisionO'S
i l RPS Logic and Trip initiatiCn l B 3.3.3 , BASES Required Action B.1 provides for opening the RTCDs
- associated with the inoperable channel within a Completion Time of 1 hour. This Required Action is conservative, since depressing the Manual Trip push button associated with either set of breakers in the other trip leg will cause a reactor trip. With this configuration, a single channel failure will not prevent a reactor trip. The allotted Completion Time is adequate to open the affected RTCBs while maintaining the risk of having them closed at an acceptable level.
C C.d - Condition C applies to the failure of one Trip Path Logic channel, RTCB channel, or Manual Trip channel in MODE 3, 4 or 5 with the RTCBs closed. The channel must be restored to OPERABLE-status within 48 hours. If the inoperable channel cannot be restored to OPERABLE status within 48 hours, all RTCBs must be opened, placing the plant in a MODE in which p the LCO does not apply and ensuring no CEA withdrawal occurs. The Completien Time of 48 hours is consistent with that of other RPS instrumentation and should be adequate to repair most failures. Testing on the OPERABLE channels cannot be perfonned without causing a reactor trip unless the RTCBs in the inoperable channels are closed to permit testing. Limiting Condition-for Operation 3.0.5 allows the RTCBs associated with the { inoperable channel to be closed to perform testing. Ed Condition 0 applies to the failure of both Trip Path Logic i channels affecting the same trip leg. Since this will open two channels of RTCBs, this Condition is also applicable to 4 CALVERT CLIFFS - UNITS 1 & 2 B 3.3.3-11 Revision 98
RPS Logic and Trip InitiatiCn ! B 3.3.3 BASES the two affected channels of RTCBs. This Condition allows for loss of a single vital instrument bus or matrix power supply, which will de-energize both Trip Path Logic channels in the same trip leg. This will open both sets of RTCBs in the affected trip leg, satisfying the Required Action of opening the affected channels of RTCBs. Of greater concern is the failure of the trip path circuit in a nontrip condition (e.g., due to two trip path K-relay failures). With only one Trip Path Logic channel failed in a nontrip condition, there is still the redundant set of ; RTCBs in the trip leg. With both failed in a nontrip ) condition, the reactor will not trip automatically when required. In either case, the affected RTCBs must be opened immediately by using the appropriate Manual Trip push buttons, since each of the four push buttons opens one set of RTCBs, independent of the trip path circuitry. Caution must be exercised, since depressing the wrong push buttons may result in a reactor trip. 9 If 'the affected RTCB(s) cannot be opened, Condition E is entered. This would only occi r if there is a failure in the Manual Trip channel or the RTCB(s). E.1 and E.2 Condition E is entered if Required Actions associated with Condition A, B, or D are not met within the required Completion Time or if more than one Manual Trip, Matrix Logic, Trip Path logic, or RTCB channel is inoperable for reasons other than Condition A or D. If the RTCBs associated with the inoperable channel cannot be opened.-the reactor must be shut down within 6 hours and all the RTCBs opened. A Completion Time of 6 hours is reasonable, based on operating experience, to reach the required MODE from full power conditions in an orderly manner and without challenging plant systems and to open CALVERT CLIFFS - UNITS 1 & 2 B 3.3.3-12 Revision B'E
1 l f p.Aed., 3.J.3 3/4.3 INSTRUMENTAT10N
'g PILE 3.31(Continued)
T4tLE MTAT104 8 ftfrDcapt. cry , W 4's /*~4 i, e+pg.t.s; ^ ro hut, systar mp breakers in the closed position and I the CEA drive system capable of CfA withdrawal. The provisions of Specification 3.0.4 are not appitcable.- (a) Trip may be bypassed below 10dof RATO THEMAL Pe be automatically removed when TutamL POWEA is c /110yt RATO bypass shall THERMAL POWtt. (b) Tripmaybemani.allybypassedbelow785esta J automatically removed at or above 745 pala. t bypass shall be (y (8) s Trip may be b assed below 15% of RATO THERNAL POWttg b be automaticahy removed when TWERNAL POWER is 115% of hass S 'E shall 'E (d) POWER. TED TNERMAL i .[ - may be bypassed below 10% and above 12% of RAfte TNERMAL 8. o I') . Trip may be bypassed during testing pursuant to Special Test Cxception 3.10.3. ,% M There shall be at least two decades of overlap betwe'en the Wide Range Logarithmic Neutron Flux Monitorin ( - Neutron Flux Monttoring Channels. g Channels and the Power Range
},
ACTION ITATEMENTS - q.,4 4. #'d' # ACTION . With W _ i channel / h:: 9.= :;;. :d p_iMiO W F'L*?'"?" 7' : ni.Jqir "4 . ACfW d t
^ ACTION 2 -
p re e _h With the number or vrsnABLE cnannels one less than the TotaT Number of Channels. STARTVP and/or POWER OPERATION may proceed provided the following conditions are satisfied:
- a. The inoperable channel is placed in either the bypassed I or tripped condition within 1 hour. For the purposes of testing and maintenance, the inoperable channel av be CALVERT CLIFFS - l' NIT 1 3/4 3-4 Amendment No. 169
~~
- - , - - .h . . . . - ,o e.-,+--.
.~-.-.-v--.,e -
,--a .,,-.-....n,w,-.-.r,-,.-w , ---y . -----y,m+.--.--.~,,-w--- w - - , - - - - , , - - -
Spa.fs. M 3.2.3 i 3/4.3 Ilt$TidMENTATION f.%r %m oF e}..p (e
'. b t. .A.
3 2. Q'W % TABLE 3.1-1(Continued)h Diut % f ,,LpA I i sl*3O4 bfh b$r (,L s ..,t s ACTI0ll$TATEMDris 3' 3 8 e "#* h.sh. - Qs,. A 'ep * * (ettRASILITYI however, the inoperable channel shall thenDyotssee Tor up ' l be either restored to OPERABLE status or placed in the l tripped condition. l f.b Within one hour, all functional units receiving an input from.the inoperable channel are also placed in the same conditten (etther bypassed or tripped, as applicable) as that required by a. above for the Inoperable channel. t
- c. The Minimum Channels OPERABLE requirement is met 4 i
however, one additional channel may be bypassed for up to 48 hours while performing tests and maintenance on that channel provided the other inonarabia chul_is placed n_ the trinned__condtiton./
~'
@ ON 3 - With the number or cnannels crEllABLE one less than requtM
] by the Minimus Channels OPERABLE requirement, verify compliance with the $NUTDOWil MARGIN requirements of Specification 3.1.1.1 or 3.1.1.2. as appitcable, wit u hour and at _immat anca nar 12 haure thaceafter i
ACT!0ll - With the n%r of channels vrt LE one less than require by the M mum Channels OPE
' $T ""*Y [within a hauce, hr er e reautrement. be in It0T g for up ong4hannel r.typbypassed /),B 'l hour for survel ancegesting per Specification
.%)hr /IcrIWT.i g h kred <a h yfa%
W , 2va<r oc~ ,e (Q) 9yuapapac- @ p ___m _ gggh < T! *W b
&LCD w_- - -
CALVERT C'IFFS - UNIT l' 3/4 3-5 Amendment No. 169 I
E&s$w.)113 INSERT ACTIONS A, B, C, D, E (page I of 2) A. One Matrix @ channel A.1 Restore channel (s) to 48 Ints inoperable. OPERABLE status. B. OnechannelofManualTrip, B.! Open the afrocted RTCBs. Ilar RTCBs, or Trip Path Logic inoperablein MODE 1 or 2. 6D -- C. One channel of Manual Trip, RTCBs, or Trip Path Idic inoper. ele in MODE 3,4, or 5. C.1 Open pra metod)RTCBs. 48 Imrs hh D. Twochannelsof53ii5iiiTiiM RTC8(or Trip Path Logic D.1 Open the afrected RTCBs. Immediately h
- aff cling the same trip path iw perable.
i h , fo r. 4 . .. "C 3 3 . .
)
1 I 3/4.3 111STEDWrfAT10ll
,.g TABLE 3.1-1(Continued) '
_ _ _ TAhtF kBTAT10M _ 2
~A spurA rp s.it y
! M Sj**iIMMk N* __5] o. I, j W1th tFe ~ tecifve system tri ~
kers 1n the closed position and a U# the CEA d ive system capable e CEA withdrewel.
* $ (
N 3 0 s s (*) The provisions of Specification 3.0.4 are not app 1tcable. Trip any be ssed below 10d of RATD TBEWIAL j -y shall V be automatica 4 l l TREWIAL POWER. y removed when TBENIAL POWER is 31 '& i i g Ib) 7.-ip may be annua 11 s sed below 785 fa autentica11y remov er above 785 ps a. t bypass shall be I l4 IC) 4j Trip r.ay be assed below 15% of RATED TECWIAL POWEtt ass shall I I be au';omatica y removed when TNERNAL POWER is t 15% o POWER. TRERMAL
'V I i I
(d) j l T d (*I gny be bypassed below 10 4 and above 52% of RATD TIERMAL Trip mat be bypassed during testing pursuant to Special Test
}[ l Exep tion 3.10.3. d (f) there shall be Logarithmic at leastFlux Neutron twoMonitort!
decades of overlap between the Wide Range Neutron Flux Monitoring Channels. q Channels and the Power Range Mi ACTIN.ITATEMENTS **- g ,o + t , of fer4 ed Rc r8 i I ACT10ll[- {ty .._ . _ - - _. Q , (. I bew e
. - . _iv..
channe PERABLE
. .- . ..,.7..
n n .y.nia -
. -_.u. a.--
i g ;,--- Z W.= =;s;G icy. ~ or M ACT1oN E 1197 zTAnwei within tne neu o a _. - the > taceti,. system trin breakers. # yq (g , CTI0ll 2 - With the number of OPERABLE channels one less than the Total Number of Channels. STARTUP and/or POWER OPERATI0li may proceed provided the following conditions art satisfied: W
- a. The inoperable channel is placed in either the bypassed or tripped condition within 1 hour. For the purposes o testing and maintenance, the inoperable channel may_
CALVERT CLIFFS UNIT 2 3/4 3-4 Amendment No. 149 e 4
+ . Cto
-e-- , - - - - - - . . . . , , . -
,.. - , - - - - . . . , , - - - - - , ---------.c --n--.m.-*.-iy -.--.yw y.
yp-c.I.efmn N.3 3 5, , s . , , . $ , . ., , r . L . ~. . ,, r., s e t. f. ca d .* n 3 7.lt,"Wik Rg l
\\ngr. % tu ft h os Flus Moetter % g 3/4.3 instr 40WrfAT10N S,r d.** +.- *f c'** V *a TAttr3.31(Continued) 4"* ' '5 f e # '* d * " TM.
t s , .' - o'r * * * : . '- ( 'M C_ _ _ _ b ssed for up to 48 hours free time of f attial loss of ILITY however, the f be of ther re: stored to rable channel shall then tripped condition. . status er placed in the
- b. Within one hour,ble channel are also placed in the same from the inopera condition elther b that requir(ed by a.ypassed er tripped, as applicable) as above for the inoperable channel.
c.; The Minfaus Channels OPERABLE requirement is sett however, one additional channel'anay be bypassed for up 'to 48 hours while performing tests and maintenance on that j , channel provided the other inoperable channel is placedj in tha 'dpped-condttion. (ACTION 3'With the number of channels SPERABLE one less than requirel by the Minlaus Channels SPERABLE requirement, verify compitance with the suv20W M4R$1N requirements of . pectfication 3.1.1.1 or123.1.1.2. icable,within hour and at least aara ner hours t as apgreafter. ACT10Nf. th t r of channe PERABLE one le yt d laus Channel LE_recui . be in NOThanrequit*/ t' within 6 hau
" 7arJone channet say pe cypassed s?
(for up (4_.3. 3. 3tomI hour for surveillance testing per specificatt3 A. _; k gwh RT*ArTeou4 p r,, it ' c B ; * *d L
-E,P)^
o.,. ef ^ ^ - L' Al 6fD ' QW Ad'O ^d[(b Ai9 h{be.Uk1 3 O ?).1 hCQC ACT[d G CALVERT CLIFFS . UNIT 2 3/4 3 5 Amendment No. 149
& Q
b/n t'Aobod 3 ),J INSERT ACTIONS A. B, C, D, E (page 1 of 2) A. One Matrix Logic channel A.1 Restore channel (s)to 48 hours inoperable. l OPERABl,E status.
)
B. One O of Manual Trip, B.! Open the affiscted RTCBs. Ihour RTCBs, or Trip Path 14 sic inoperable in MODE 1 or 2. Co\D __ C. One channel of Manual Trip, C.! Openttnerapected)RTCBs. 48 hours Q1 RTCDs, or Trip Path logic ) inoperable in MODE 3,4, or 5. D. Two channels ofM D.1 Open the affected RTCBs. RTCB a Trip Path logic the same trip path Immediately h inoperable. 4
. Ap(v//o
DISCUSSION OF CilANGES SECTION 3.3.3 - RPS LOGIC AND TRIP INITIATION
' power reduction to Mode 3, and the opening of all RTCDs within six hours. He new ITS requirement is more stringent since it requires a reactor trip after six hours, whereas the CTS does not. nls more restrictive change will not adversely affect the safety of the plant. His change is consistent with NUREG 1432.
M.3 Not used. l M.4 Current Technical Specification 3.3.1.1 Action I requires the unit to be in Mode 3 within 6 hours "and/or" open the protective system trip breakers. Improved Technical Specification 3.3.3 Action B tequires the unit to be in Mode 3 within six hours, "and" to open RTCBs. His change ccustitutes a more restrictive change because it requires the RTCBs to be open regardless if the unit is placed in Mode 3 within 6 hours, whereas the CTS ~ does not require the RTCDs to be open if the unit is in Mode 3 within 6 hours. He change does not adversely affect plant safety, because it requires the RTCDs to be placed in a condition which satisfies their safety function. His change is consistent with NUREG 1432. M.5 Current Technical Specification 3.3.1.1 Action 1 allows 48 hours to restore an inoperable l Manual Reactor Trip channel to Operable status. Improved Technical Specifications 3.3.3 Action B requires the affected RTCB to be opened. His change allows no action to be taken for 48 hours when I channel is inoperable, whereas the ITS requires the affected RTCB to be opened. Herefore, for the first 48 hours, this change is more restrictive. This change does not adversely affect plant safety, because it requires the affected RTCB(s) to be placed in a l position to meet their safety function. This change is consistent with NUREG 1432. For any time after the first 48 hours, this change is discussed in a less restrictive discussion of change. M.6 Not used. l M.7 Current Technical Specification 3.3.1.1 does not provide Actions when two channels of RTCBs or Trip Path Logic affecting the same trip path are inoperable. Thus, CTS LCO 3.0.3 would be entered requiring a unit shutdown to Mode 3 in 7 hours. Improved Technical Specification 3.3.3 Action D requires the affected RTCDs to be opened immediately. His change is more restrictive and is acceptable because the opening of any one remaining RTCB would cause a reactor trip and the affected channels' safety function wo v .d be satisfied. This change is consistent with NUREG-1432. TECilNICAL CilANGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED-DDfUhlENTS LA.1 Current Technic.: Specification 3.3.1.1 Table 3.31 contains a " Channels to Trip" column. Improved Technical Specification 3.3.3 will not contain this information. His is an informational column which is more appropriate for the Bases. The number of channels to trip will not be changed. He information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. Ilowever, any hardware change to the number of channels to trip will require a design change. He Bases Change Control Program will ensure that changes receive appropriate review. This change is a less restrictive movement of details chrage with an impact on safety. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.3.33 Revision 8
- .- -- . - - - - - . - ~ - - . .- - - - -
DISCUSSION OF CIIANGES SECTION 3.3.3 - HPS LOGIC AND TRIP INITIATION 1 TECilNICAL CHANGES I s'RE Ns'ETRICTIVE L.1 Current Technical Specification 3.3.1.1 Applicability requires the Manual Reactor Trip to be Operable in Modes I and 2, and when any RTCB is closed and any CEA is capabiw of being withdrawn. Improved Technical Specification 3.3.3 will change the Modes of Applicability to I,e Modes 1 and 2 and Modes 3,4, and 5, with any RTCBs closed and any CEA capable of being withdrawn, thus removing the Applicability in Mode 6. His change is reasonable because the CEA withdrawal events are not postulated in Mode 6 and cannot occur when the reactor is defueled, and Boron Dilution in Mode 6 is not terminated by a reactor trip. Rese events are not postulated in Mode 6 or cannot occur when the reactor is defueled. Relaxing the Modes of Applicability constitutes a less restrictive change. %Is change is consistent with NUREG 1432. L.2 Current Technical Specification 3.3.1.1 Action 4 requires the unit to be placed in llot Standby within six hours if one channel of Trip Path Logic or RTCBs are inoperable. Improved Technical Specifications would require the affected RTCB to be opened within one hour, nl change essentially eliminates a shutdown requirement and allows indefinite operation with the inoperable channel. Operation can then continue indefinitely. This change is acceptable because it removes the need for the affected channel by performing its safety function. With the RTCB open, the affected Timetions meet the redundancy requirements. This change is consistent with NUREG 1432. - L.3 Current Technical Specification 3.3.1.1 Action 4 requires the unit to be placed in llot Standby within six hours if one channel of Matrix Logic is inoperable. Improved Technical Specification 3.3.3 Action A would allow 48 hours to restore the channel to Operable status. The 48 hour allowed outage time is acceptable because it is unlikely that a second Matrix Logic channel would fall within a 48 hour period Allowing 48 hours when a failure caused three Matrix Logic power supplies to de energize is acceptable because the system is still capable of performing its safety function. His change is consistent with NUREO 1432. L4 Not used. l , L5 Current Technical Specification 3.3.1.1 Table 4.3 1 requires the RTCB CFT to be perfonned in Modes I and 2, and with any RTCBs in the closed position and the CEA drive system capable of CEA withdrawal. Improved Technical Specification 3.3.3 will require the RTCB CFT to be performed in Modes I and 2, and Modes 3,4, and 5, with any RTCBs closed and any CEA capable of being withdrawn. This change is consistent with Modes of Applicability for the LCO, and consistent with the safety analysis when these functions are required. This change is specifically required for the Rate of Change of Power Trip, which is required in these Modes. This change is consistent with NUREG 1432.
-L.6 Current Technical Specification 3.3.1.1 Table 4.31 requires a CFT on the Trip Path Logic and Matrix Logic once every 92 days, and 7 days prior to reactor startup, improved Techt ical Specifications delete the requirement to perform this Surveillance 7 days prior to reactor ctanup. Per Section 3.0 (LCO and SR Applicability) the Surveillance is required to be perfornad within 92 days of reaching the Mode of Applicability for the particular function.
- he performance of this test within 92 days is adequate to prove Operability CALVERT CLIFFS UNITS 1 & 2 3.3.34 Revision 8
__. s# . . . - - - - --
l DISCUSSION OF CilANGF.S SECTION 3.3.3 RPS LOGIC AND TRIP INITIATION during nonnal operation, therefore, it is adequate to prove Operability prior to startup. The l deletion of a Surveillance interval is considered a less restrictive change. This change is consistent with NUREG 1432. f L.7 Not used. l C CALVERT CLIFFS - UNITS 1 & 2 3.3.35 Revision B
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.3 - INSTRUMENTATION i
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
He proposed change deletes the shutdown requirement when one Matrix Logic channel is inoperable, ne proposed Action will require the Matrix Logle to be restored to Operable status within 48 hours, and also allow 48 hours to restore three Matrix Logic channels when inoperable ! due to a common power source failure, ne change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any new accident initiators. Derefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in er.argin of safety?
He proposed change deletes the shutdown requirement when one Matrix Logic channel is inoperable. %c proposed Action will require the Matrix Logic to be restored to Operable status within 48 hours, and aise, allow 48 hours to restore three Matrix Logic channels when inoperable due to a common power source failure. He Matrix Logic is still capable of performing its safety function. Also, a un!t shutdown is a transient which places stress on safety system components and can cause a plant upset. Therefore, the change does not involve a significant reduction in a margin of safety. 333 Ch==oe L4 Not used. l 333 Chamme L.5 1, Does the change involve a significant increkse in the probability or consequences of an accident previously evaluated? ne proposed change revises the Applicability for performing the RTCB CFT from Modes 1 and 2, and when any RTCH is closed and any CEA is capable oibeing withdrawn, to Modes 1 and 2 and Modes 3,4, and 5, with any RTCBs closed and any CEA capabic of being withdrawn. His change was made for the Rate of Change of Power Trip which is required to trip the reactor in these Modes. The Rate of Change of Power liigh RPS Trip is not an initiator of any analyzed event. This change maintains consistency with the safety analysis. He CEA withdrawal events are not postulated in Mode 6 and cannot ocem when the reactor is defueled. Boron Dilution in Mode 6 is not terminated by a reactor trip, uus, the CFT should only be required when the channel is required to be Operable, ne proposed change does not significantly affect initiators or mitigation of analyzed events, and therefore does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any prevlaaly evaluated?
The pw %d change revises the Applicability for performing the RTCB CFT from Modes 1 and 2, aW when any RTCB is closed and any CEA is capable of being withdrawn, to Modes 1 and 2 and Modes 3,4, and 5, with an) RTCDs closed and any CEA capable of being withdrawn, ne change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will CALVERT CLIFFS - UNITS 1 & 2 3.3 11 Revision 8
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.3 - INSTRUMENTATION not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a signifleant reduction la margin of safety? ;
The proposed change revises the Applicability for performing the RTCD CIT from Modes 1 and 2, and when any RTCB is closed and any CEA is capable of being withdrewn, to Modes 1 and 2 and Modes 3,4, and 5, with any RTCDs closed and any CEA capable of being withdrawn. His change was made for the Rate of Change of Power Trip which is required to trip the reactor in these Modes. He change maintains consistency with the safety analysis by deleting the requirement for a CFT in Modes that are not applicable. He CEA withdrawal event and boron dilution events are not postulated in Mode 6 and cannot occur when the reactor is defueled. Therefore, the change does not involve a significant reduction in a margin of safety. 3.3.3 Channe L6
- 1. Does the change invoht a sigalGennt increase la the probability or consequences of an
- accident previously evaluated?
The proposed change increases the maximum time prior to reactor stanup allowed to perform the CFT on the Trip Path and Matrix Logic from 7 days to 92 days. The Matrix and Trip Path Logic are not inillators of any analyzed event. Allowing the Surveillance to be performed 85 days earlier than currently allowed is within the same Frequency the Surveillance is performed during operation. De Matrix and Trip Path Logle is still verified to perform as required. He proposed chsnge does not significantly affect initiators or mitigation of analyzed events, and therefore does not involve a significant increase in the probability or consequences of an accident j previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
He proposed change increases the maximum time prior to rcactor startup allowed to perform the Cl T on the Trip Path and Matrix Logic from 7 days to 92 days. The change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident 4 initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant redu; tion in margin of safety?
The proposed change increases the maximum time prior to reactor startup allowed to perform the CFT on the Trip Path and Matrix Logic from 7 days to 92 days. This change will make the time to perfonn the CFT on the Matrix and Trip Path Logic consistent before reactor startup and after reactor startup. The increase in time will continue to provide assurance that the Matrix and Trip Path Logic perfonns as required prior to reactor startup. Therefore, the change does not involve a significant reduction in a margin of safety, 3.t3_ Change 12 Not used. l CALVERT CLIFFS UNITS I & 2 3.3 12 Revision 8
, , , - , - n ---
i RPS Logic and Trip Initiation ACTIONS (continued) C0161T1001 R(WIRED ACT10ll COMPLETION TIME
- 5. f.-.... -NOTE -
8.1 Open the affected I hour
- RTCts.
,. 3. .. . RTC8sr.ssoc.iated
-i ie . i wh ,
@ ;h
<A . ,.,. ,, 4 may to hour for t clesed fo up .
pe ersance of n RPS C L fuMCT St.
)
i Trip one channel of Manuel & Ng "rlp TC , or Logic
'noper in MODE 1 or 2. 4 4
C. (......... it........ c.1 Open al) RTCls. f RTC8: as lated wit 44 hours one ino rable chan el A may be losed for
! to I ur for the O perf nce of RPS i C [L FUNCT! L pg W TE ,
g,g,g ..............;....y
' ^'
one channel of Manual h _ rlp. RTC8s, or ( C3
- 0. T nnels of RTCBs 0.1 Hfd Open the affected immediately crormini@ Logic 3M.t tm N.7 affR O ng the same RTC8s. @
trip leg inoperable. (continued) CE0G STS
- 3.3-16 Rev1,04/07/95 b
d
, , , - . . - - - - , , ~~- - - - - - . , . , - . . . - . , . - - , - . , - , - . . .- _,-- v,,, -- ~ . - - . , ,
l
. l RPS Logic and Trip Initiation 8Ast$
ACTIONS L1 (continued) (Therere 'a Note has been assect ed with one I to 1 r for the perfe spectfying that the RT channel of an RP$ be cle h I TE . EL ONAL Required Action 8.1 arevides for opening the RTC8s assectated with the I rable channel within a Completit.n Tlas of 1 hour. This trod Actlen is conservative depressing the Manuel Tr p oush butten assectated wit $ etnce either set of breakers in the other tri reacter trl failure wil$. With this confleuratten,pQkg)will a single channel cause,'a- a not prevent a reacter trip. 'The allotted Lco .3.6.5 e] < Completion Tlee is adeevate to open the affected RTC8: while maintaining 1evel.* the risk of having thes closed at an acceptable 6 #Tch *fsjn;A4W
- 6' d* A W
cL..ut 4o 6 c1.n & 4 (= ' H"" U _ Q Q .
$. pip.D ~~
Condition ci n C applies to the fatture of one 4nW1ohtagte RTCt channel. or Manuel Trip channel GT Xsinode3
- G in MODE 3. 4. or I with the RTC8s uosec. II.e 3
caanne sus
~- ) be restored to 0P[RA8LE status within 48 hours.
If the inoperable channel cannot be restored to OP[RABLE status within 48 hours e opened placing the plant in a MODE in.lall RTC8: must b' which the LC ensuring no CEA withdrawal occurs. 0 does not apply and The Completion Time of 48 hours is consistent with that of other RPS instrumentation and should be adequate to repair most failures. Testing on the OPERABLE channels cannot be performed without causing a reactor trip unless the RTCOs istthe inonerabia channels are closed to permit testt_ng. lfherefore, a N , i vh has cesh - w sp mpng inas sarnicas associat Inoper e channel may be c hone) '
~
4 uarf nee of an RP$ C"."%g1ofor up to I hou r the J FUNCTIONAL TEST.f-U Condition 0 applies to the failure of both channels affecting the same trip les SincN-
~egic *k n p k h open --@'~
h (continued) CEOG STS 8 3.3-57 Rev 1. 04/07/95 . TJh
- - - - - . _ - _ _ _ - _ .._- _ _- - .- - - . - - . . - -_. - ~ - Ap$ Logic and Trip Initiatten h LA$t$ ACTIONS Qd (continued) g" 94 treW4 two channels of RfC8s, this ba* * *I-- the two affectaLETC8s. Tht t on s~also appitcable to
# stasie vitailnstrumenu Conditten trix power supply allows *uhtch for less of a .IC%l0h-will de-enerytte both(
trip le 7 This will open Logic channels in,the same ' trip lpg satisf L ( affectedj>RTCOs. ying the Required Action of opening the sets of RTC8s in the effected h Of greater conce 4 p, p g in a nontrip condition (e alhefattureof inNIstion circuit failures With onl we talttation K relay ly@to a nontrip).(condition,y there one t Dlogic chaneal failed in t RTC8: l1 the redundant set of condition in the trip Ic > With both failed in a nontrip required., the react (or will not trip automatically when immediately by using the appropriate Manual Trip pushIn eith buttons, since each of the four avih buttons opens one set of RTCOs must be e,xercised independent of the dENH31i3b etrtut try. Caution since depress the wrong push buttons may result in a re, actor trip. ggg g cannot be opened Condithn E
, If the This entered.
Manual Trip I affected would onRfC8(s)ly occur if ure there,is in the a fail orthe_Ritt(s). E E.1 and r.2 c ha ~~_w3 __ Tfin Q Condition E is entered if Required Condition A, 8 tions associated with Completion Tlee. or 0 are not met wt hin the re trod one Manual Trip ortfforCoF iwA*Hnt more than channel is inope. Matrix logt , nAiayloli) ogic, or RTC8 ' or D. rable for reasons otherqhan Condition A If the RTCBs associated with the inoperable channel cannot be all the opened, RTCBs the opened. reactor must be shut down within 5 hours and reasonable, based on operating expertenceA Completion Time of 6 hours is to reach the required MODE from full power conditions In an orderly manner RTCDs. and without challenging plant systems and to open in a MODE Allwhere RfCBs th should then be opened placing the plant withdrawal occurs.e LC0 does not apply a,nd ensuring no CEA (continued) CEOG STS 8 3.344 Rev 1. 04/07/95 sej 4
, _ , , , - , _ , . _ - _ _ - . - - _ _ _ , m_ _.
y
t
- 21. To resolve NRC comment 3.3.3 7, references to CEDO 95 (TSTF.183) were removed from the ,
STS markup supporting the removal of the 'one or more functions with" statement from 3 NUREO 3.3.3 Condition E. Discussion of Deviation 36 was added to support this change on a . i plant specific basis. l f l i h
.. i h
9 F h I
RP3 Logic and Trip Initiation [C f1) ACTIONS (contj g t C041710N Rt0Vikt0 Atil0N COMPLET10N TIN ( I
- t. Regelred Action and t.1 .
associated Ceapletten to in M00C 3. 4 hours Tlas of Conditten A, AMI y g B, or 0 not pet. g , t.3 Open all RfC8s.
; 4 hours
\bsc M.7.
o anyiiunoftanD w w or more 36 Lost Trip Logic. or ni6s channe,ls inoperable p,g' h for reasons other tlian Condition A or 0. h
$URVtittANCE Rf0VIRENINTS
$URVEILLANCE TR(QUENCY 3R 3.3.3) it!each days Perfom a CHANN(L FUNCTIONAL TEST on RPS Logic channeiryarJGet chann6. b -
,.p y) $R 3.3.3hRPS Perfom a channel.
Manual Trip CHANN[L FUNCTIONAL once within TEST on each 7 days each r.actor prior to @ startup [R3.3.3.3 Perform a CHANNEL F 10NAL TEST. includth separate )sonths / rificatten of thew Lgrvolage.and unt trips,'on shh g c- '
-J
,g,)4g ' A I.I .3.4 Ndem g vi,8MCL FUNC Tloe*4L 165T U day 5
' . sa esik t yc6 .hasa<l s -_
CE0G STS 3.3 17 Rev1,04/07/95 , 1
,__._.-n,- _ ,, ..- -.- , , _,yw-,. . ., . _.-,...-i,.w-<-- y.-.,,
DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.3 - INSTRUMENTATION also provides surveillance requirements for demonstrating the function Operable, nls change maintains consistency within the ITS and is consistent with the current Technical Specification requirements.
- 35. NUREG 1432 Surveillance Requirement 3.3.3.1 requires quarterly testing of the RTCl3s CTS Table 4.31 requires the RTCils be tested on a monthly basis. Calvert Cliffs has retained the existing more frequent testing of the RTCils consistent with the licensing basis and CEN 327, "RPS/ESFAS Extended Test Internal Evaluation," June 2,1986, including Supp8 ment 1, dated March 3,1989.
- 36. NUREO 1432 Condition E of140 3.3.3 is stated as "One or more functions with two or more
. . . Inoperable nis specification is not " function" based, i.e., the functional parameters that can be inoperable under this 140 are already stated in Condition E. Here are no other functions covered by this LCO which depend on these functions. He NUREO statement is not used in any other condition of the LCO and is in error. The statement is deleted from ITS 3.3.3 consis%nt with the dnsign of Calveri Cliffs.
- 37. NUREG 1432 Condition D of LCO 3.3.7 requires placing the purge valves in the closed posi'8on and entering the applicable conditions of LCO 3.6.3 for the inoperable purge valves which sesult from an inoperable manual actuation or automatic actuation channel. Rese actions are in error and have been corrected in ITS 3.3.7 to require either the valves be closed, or the actions of LCO 3.9.3 be entered for inoperable valves. %e STS reference to LCO 3.6.3, Containment Isolation Valves, is inappropriate since that LCO applies in Modes 1,2, 3, and 4 whereas, LCO 3.3.7 is applicable during core alterations and movement of fuel.1.CO 3.9.3, however, has the same applicability of LCO 3.3.7 and is the appropriate reference. He STS is also in error to require both actions be accomplished since the actions are somewhat redundant. Closure of the purge valves performs the safety function of the automatic and manual functions covered by the LCO. %c actions of LCO 3.9.3 would require that core alterations and fuel movement be suspr*d which removes the unit from the mode of applicability. Herefore, ITS 3.3.7 Condition Il replaces the "and" requirement in the STS with an "or" to indicate that these actions accomplish the same desired result. This change is also consistent with the requirements of the STS for each of the other PWR owners groups.
38, ne Applicability of NUREO LCO 3.3.1 is MODES I and 2. %c ITS Applicability references Table 3.3.1 1, and Table 3.3.1 1 has a column specifying the Applicability for each Function in the Table. This method is necessary since each Function does not have the same Applicability; two of the Functions are only required in MODE I h 15% RTP. This change is also consistent with the Calvert Cliffs CTS Table 3.3 1,
- 39. NUREG 1432 SR 3.3.9.2, Note 2, requires testing of relays after 24 hours of Mode 5 operation for relays that cannot be tested during operation. These relays would cause a closure of the letdown line which is undesirable during unit operat!on. The CVCS actuation logic is currently not required by the Technical Specifications. He 24 month test frequency proposed in ITS SR 3.3.9.2 is consistent with the CTS Table 4.3 2 footnotes 2 6 for other ESPAS functions actuation logic which cannot be tested online. The requirements of the STS would impose an unnecessary more restrictive change on plant operations and are not adopted. ,,
CALVERT CLIFFS - UNITS I & 2 3.3-6 Revision 8
I 9 4 RPS Logic and Trip Initiation h L BA$[$ ACT!h*% L 1 (continued) g, i 5m "4 {
- - two channels of RfCDs, this b* * * *I ----
the two affectaLJ.TC8s. Th tien is'also applicable to alnplevissiinstrumentj tenditten trts power a11ews supplyfor less of a'd. 108h' w11' de-energite both Qit logic channels ia.'anich L trip lejr This will open ; the :ame < satisf sets of RTCOs in the affected ( trip igg >p affectesj TC8s. ying the Required Action of opening the
-4pg g 4
0f greater concem is lhe failure of in a nontr initiation ~ctrcuit failures .ip With conditten onl (e we intttation K relay anontrip)fcondition,yone there Logic channel failed in RTCOs in the trip 1cp With both fatted in a nontris he redundant set of 7 condition, the reactor wt11 not trip automatically when required. immediately by using the appropriate Manual Trip pushIn eithe buttons, since each of the fougr i of RTCBs independent af the dni' t th tuttons opens one set must be e,xercised _ circuttry. Caution es may result in a re, actor trip.since , ggg depress'g'de wrong pu I If the This entered. affected would on RTC8(s)lycannot be openedoccur ~ Condition ifurethere ( ls in the is a fail Manual Trip 4tRUtfe) er the RTC8(s), L 1 and F.f, YS ~~
.Tr p h t
Condition ( is entered if Required Condition A. 8 tions associated with Completion Time, or 0 are not_ net wl hin the ra trod or if forConW iMa more than one Manual Tr1p. Matr1x logit T 1Aiayt og1c, or RTC8 I channel or 0. is thoperable for reas,ons einer7 han Condition A If the be RTC8s opened associated with the inoperable channel cannot alltheRICOsopened.the reactor must be shut down wtthin 6 hours and reasonable A Completion Time of 6 hours is based on operating expertence to reach the required fdDE from full power conditions In an orderly manner RTC8s. and without challenging plant systems and to open in a MODE Allwhere RIC8sth should then be opened placing the plant withdrawal occurs.e LC0 does not apply a,nd ensuring no CEA (contipued) CE00 ti$ 5 3.3 58 Rev1,04/07/95
- 22. To resolve NRC comrnents 3.3 A 1 and 3.3.4 8, Discussion of Change LA.6 has been deleted and replaced with Discussion of Change L3. The requirement to verify the capability of bypassing functions is not credked in the safety analysis, only bypass removal which is retained. The CTS markup and No Significant llamds Considerations have been updated accordingly.
l
$7 ,.f".< 4.us 7. 3. 4-ege _ -
i) 1 s . . . . . ., 4 4 ~ .. . . '
..n..... ..._ . --
'$.3 9/479- JuSTRUMENTATION (t.5%:h g 3. 4 :3/4.3.i ENGINEERED 1 TY FtATURE ACTUATION SYSTEMilNITRIMENTAfl0N f .pri .,. s.i e. . .a . - . %
ps .%.s (. 4 .as @1@ LIMITING CONDIT!0r. OPttATI =
, y g t-Sted ered Safet Featu Actuotton Syst
-int;- : N'i_ . channels and shown in Table (ESFAshei.i.-.sitQ hah se - - -
QA. 9PERABLE with their trip set the Trip setpoint column of able nts3.3-4. set consistent with the values shown in APPLif. ABILITY: t t- '- Tel: 3.! h opp 3 - y h aIWithplESFASinstrumentati channel trip se int less con ovative than the val shown in the M able Values col l c able 3.3 4 declare e channel ino le and apply the daI ' pplicable ACTION reg nt of Table . 3 until the cha 1 is ! restored to OPERABLVstatus with the psetpointadjust J honsistentwithth(TripSetpointy e.f na e . ~
? N 01-E' ~ ..~.
f s.c o m+ c <: ..
- n. ,' a . +u. . . .. W h .t % ,,t L- - - -
. -4 ,9
" rw@
$URVEILLANCE REQUIREMENTS - -
Ws ~~ bV.t T ' . . 'L 7
% 3 . 9 . 4-4.3.2.1.1 EachESTAS1-)'[Y$$ channel shall be demonstrated OPERABLE.by the performance of the CHANNEL CNECK. CNANNEL CALIBRATION and CNANNEL FUNCTIONAL TEST operations M ac na "*
h
- M :t it: ' :;- :in i - '- ?d t : ' . 3 --0.
""'i he tc for the ses snais se si rated OPERAsA curino 59, 3,g 4.3 e power EL FUNCTI EST of channels eted by byp6(L > ['3
.,_._Ja= W ho '-* 1 hynatt marnaa snali ce ;;sa.enstratec vrtuAs'.E at least once per REFUELING INTERVAL dur each channel affected by bypass operett CNANNE gAtlanA? m !ast ua af -p
. 4.
Cc_ A { .. .y t F . 4 ,,, g 3*gf b3fD The ENGINitRED SAFETY FEATURES RESP 0N$t IINE of each A*IE$FA$ Tunction shall be demonstrated to' be within the limit at least once ser' REFUELING INTERVAlf tacn teu nasi include at least one annel per T
/~T u lon sucn that all chann are tested at least once try N REFUELINL l' RVALS where N is the to number of redundant cha 15 in a specifte 5 FAS function as shown i the ' Total Na cf f han%i(* Column of le 3 '
on s %tMD TbT Basi CALVERT CLIFFS . UNIT 1 3/4 3 9 Amendment No. 208 p- .)c 1 o F (6 w-- ,7 --r~,,4 - - .v., ---,- , ----,n-y,,
$ p ,. . . f'. , e 6 . . , ' *5. 7. 4 I . . . 4 c.7 =$='A' N NATIM
(*T, ~5. 4 0.'4.0.7 maturrarn
.i A$])
FEAfutt Actuartns tyttsts/ mgTMasffATIM i LIMITIM COWITION P SPERATION [** N[M)k N the7.$ 55 5I M 3 iMiiff010.
!$ $$*$'~'-"""~~'"'~~""
1 APPd*. ABILITY: ^;:t:-'.72h!.!! $ b ( i
.U 3]
ACT10Ni ;
. With an-Es instroentation channel trip setpoint less consern a than the value a l of Tab 3.3 4 declare the ininoperable nnel the Allowdle a aselyalues colan *Ig appl ble ACTION requi the t of Taele 3.3 3 un tM channel is cred to OPERABLE st s with the tri u onsistent with the T Setpoint value.p-set nt adjusted j "
. i.MnnLasins.-.s[ss S Table 3.3 3. channel m- inoperable.Jtte the ACT!By wXN g _ .
. W oTt" - - - - - -
G,c..... c...i.4.. . . a . ., .s .II.. .J rar SURVE!LIANCE kt00!REMENTS t D N' . b '"? N 3.2.1.1 tech t$FAS
'5 . ~% 4 .1
. channel shall be demonstrated
- 3. *!,. 9 2 g , t . 4. 4.
#PERAllt by the performance of the CNANNEL CNECK C11ANNEL CAL! BRAT 10ll and CNAMEL FullCT!001AL TEST operations OxO.; the ^^:: * : . ;; th: 's.,....ues t- . '- tim t ' .! 3. Q
' 0.0...I-[e logic forthe bypasses shall ne opnstratte vrsuAstpqurl l3 pne apr CNANiltLARICTI0llAL TEST of channew affected by bypaif G (opegations The teit! Ogre nn" shall ne __..urssen vr -- 2 at inn once per REFUEL 11th IWittVAL
'5 N A. 3 each channel affected by bypass operring CllAlulU.
CALIBRAT10lltesting_of_ l
. Q,~ a . ,.o .g -
kl .. k r e .. F *I
- - ----- y 4.3.2.1.3 The EHINtttt0 SAFETY FIATI'Att htSPollst TIME of each ESFA$ g. 4..e -
function REFUEL 1Hshall be demonstrated INittVA14 tech test sh in be within the limit at least once oer incluce at least one chan 1 per fTunction 11ptRVALS such wherethatN all channels is the tot re tested at least once ev 18ttFUELIM number of redundant chann in a specific 25FAS function as shown in ' Total No. of Channels' olumn of
,l Qole3.33. , I ot)a $7A(MR pp -
TEST 6 Asis _ CALVERT CLIFF $ . UNIT 2 3/439 Amendment No. 186
+
MM
DISCUSSION EF CHANGES l SECTION 3.3.4 . ESPAS INSTRUMENTATION j i M.4 Current Technical Specification 3.3.2.1 Action 11 for Containment Spray Actuation Signal (CSAS), allows continued operation with one inoperable channel prwided the channel is bypassed in one hour. Improved Technical Specification 3.3.4 Action A requires an inoperable channel be restored to Operable status within 48 hours or the inoperable channel is placed in trip. His change is more restrictive. This change will not adversely afftet plant safety and i provides consistency with other ESFAS function actions. Other changes to the CSAS actions l are described in a separate less restrictive change. His change is consistent with NUREO.1432. l 'IFCHNICAL CHANGES RELOCATIONS None TECHNICAL CHANGES . MOVEMENT OF DETAILS TO LICENSEE CONTROLLED-DOCUMENTS G LA.1 Not used. l LA.2 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification Table 3.3.41 will not contain this column. This is an informational column which is more appropria:e for the Bases. He number of channels to trip will not be changed. He information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. He Bases Change Control Program will ensure that changes receive appropriate review. His change is a less restrictive movement of details change with no impact on safety. This change is consistent with NUREG 1432. LA.3 Not used. l LA.4 Current Technical Specification 3.3.2.1 Table 3.3 3 Function 3 (Containment Isolation) Endnote # states that containment isolation of non-essential penetrations is also initiated by S!AS (Manual Trip and Pressurizer Pressure - Low functions). Improved Technical Specifications does at c>ntain this footnote. His informational Note is being moved to the Bases. Any changes to the Bases will be controlled via the Bases Change Control Program. He Bases Change Control Program will ensure that any changes to this requirement will be appropriately reviewal. his requirrnent is not being changed, therefore, plant safety is not impacted. His change is consistent with NUREG 1432. LA.5 Not used. l LA.6 Not used. l TECHNICAL CHANGES - I-ESS RESTRICTIVE L.! Current Technical Specification 3.3.2.1 Action 11 allows indefmite operatiorfwhen one CSAS channel is inoperable and placed in bypass. The CTS allows 2 channels to be bypassed for up CALVERT CLIFFS UNITS I & 2 3.3.4-1 Revision 8
EISCUSSION CF CIIANGES SECTION 3.3.4 . ESFAS INSTRUMENTATION to two hours, improved Technical Specification 3.3.4 w9 change the CSAS Actions to be consistent with the othe ESFAS functions (ITS Actions A and B) which permit one channel to be bypassed or tripped for 48 hours and theri cither restored or tripped, and two channels inoperable for up to 48 hours provided one is tripped and the other bypassed. nc 48 hour limitation to bypass a single inoperable channel is discussed in a separate more restrictive change. De allowance to pk:e a channel in either bypass or trip and the allowance to operate for 48 hours with two inopenble channels is less restrictive, no CTS Actions were established prior to manual bypass switcFes being incorpor 1, and prior to modifications which require a CSAS coincident with a SIAS to start the containment spray pumps. Rese l modifications prevent a single failure from causing an inadvutent sprr,ying of containment. For these reasons, it is acceptable for the CSAS to haw the same actions as the other ESFAS functions. L.2 Improved Technical Specification 3.3.4 Table 3.3.41 adds Footnote (c) to CTS 3.3.2.1 which l allows the Steam Generator Isolation Signal (SGIS) function and the Steam Generator Pressure low sigants to not be Operable when all associated valves isolated by the SGIS l function are closed and deactivated. This change is acceptable because, when the valves that are isolated by an SGIS are closed and deactivated, the safety function of the SGIS is met and, therefore, is not required. Adding requirements which allow the trip function to not be Operable constitutes a less restrictive change. This change is consistent with NUREG 1432. L.3 Current Technical Specification 4.3.2.1.2 requires the logic for the bypasses to be demonstrated Operable during the CFT of channels affected by bypass operation. Manually or automatically inserted b> passes allow plant operation under conditions that do not require the respective ESFAS functions, but would result in an unnecessary ESFAS actuation if they were not bypassed. The total bypass functions remove these bypasses when the plant conditions no longer support allowing the bypasses. Improved Technical Specification SR 3.3.4.3 and SR 3.3.4.4 requires the total bypass function be verified every 24 months. This is consistent with safety analysis assumptions that the automatic bypass removal function operates, ne capability to bypass a function when it is not needed is not assumed in safety analyses since it performs no mitigative function. Therefore, this requirement is deleted from the Technical Specifications. His Ocage is consistent with NUREG 1432. L.4 Current Tecimical Specification 3.3.2.1 Action 7.c permits a second channel to be placed in bypass for up to 48 hours for taaintenance or testing when one charrael is inoperable and placed in the trip coadition. Improved Technical Specification 3.3.4 Action D will permit one charmel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours. his is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance. This change is acceptable since the cause of the inoperability, either planned or unplanned, has no different impact to the overall safety, his change would avoid an unplanned shutdown and associated transient due to an unforseen channelinoperability. This change is consistent with NUREG 1432. L.5 Current Technical Specification Tabic 3.3 3 provides an exception to the requirements of Specification 3.0.4 for all ESFAS functions except the auxiliary feedwater actuation signal. Improved Technical Specification 3.3.4 makes the LCO 3.0.4 cxception applicable to all functions including the AFAS. His exception may be necessary to permit mode changes in , support of required maintenance and testing for an inoperable channel. The ITS cfTectively CALVERT CLIFFS - UNITS 1 & 2 3.3.4 5 Revision 8
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3J - INSTRUMENTATION _SGIS safety function is already satisfied. He proposed change does not significantly affect initiators or mitigation of analyzed events, and therefore does not involve a significant increase ' in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
The proposed change adds a footnote that allows the SGIS function and the Steam Generator Pressure - Low signal to not be Operable when the valves, which are isolated by an SGIS, are closed. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The proposed change adds a footnote that allows the SGIS function and the Steam Generator Pressure - Low signal to not be Operable when the valves, which are isolated by an SGIS, are closed. When the valves that isolate on an SGIS are already isolated, the SGIS safety function is r,iready performed and therefore, the SGIS is not required. Therefore, the change does not involve a significant reduction in a margin of safety. 3.3.4 Chance L3
- 1. Docs the change involve a significant lucrease in the probability or consequences of an i
accident previously evaluated? The proposed change removes the requirement to demonstrate that ESFAS functions can be bypassed when not needed. The ESFAS bypass capability is not assumed to be the initiator of any analyzed ewat, therefore, the probability of an event is not affected. The automatic removal feature of the bypasses is not affected by this change. Therefore, the consequences of an event ar: not affected since the function will continue to be required to mitigate applicable events. Therefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously ev:h:4ted.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
This change will not physically alter the plant (no new or different type of equipment will be installcd). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the psibility of a new or different kind of accident from any accident previou. y evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The capability to bypasses a function when it is not needed is not a credited function in the safety analyses since it performs no miscative function. The capability to automatically remove any function from the bypassed condition is assunxd in the safety analysis since the function is assumed to operate as required to mitigate analyzed events. The proposed change does not alter er delete any requirement used to preserve in, ssumptions in the applicable' safety analysis, therefore, the change does not result in a significant reduction in a margin of safety.
'CALVERT CLIFFS - UNITS 1 & 2 3 3-14 Revision 8
-. . . - . . . . - . . . - . - . . . - . . . . . ~ _ _ - .- .- . . . . - - .- . . . - . . . . - . - .-. . .
et ._ i
- 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 valuer in ITS 3.3.4.
+
't H
3< h 6 1 9 t 11 1 4
- m. ,
(
- - , . , - . . _ - = . u .- m. .. y. -
w . J, . - ,
g TABLE
,- R*
Dminttuts $AFETY FEATURE ACTUATION SYSTDI isoimer.mATION TRIP YALUES " n C FUNCTI0llAL UIIIT TRIP N E ' A. pg ALL0lmBLE YALUES 4 3 1. SAFETT INJECTION (SIAS)
/ =
.E b : t r 9 ('-t; Lt;;,.;)
25 - not nyvi;u '. ,,v 6 ,,,,,J' _i?: h O [ b. Containment Pressure - High @ psi 5 475 psig E 2.
- c. Pressurizer Pressure - Lcw
~-
1725
!p 'E ,,2 1725 psia CONTAIMMENT SPRAY (CSAS) -
- a. Mana=1 ('i,, L t .vi.., $ut app o c .,L- not appot.uie R l 6 6 +s]
^
- b. Containment Pressure - High 5 4.75 psig I
,g g 3. CONTAINMENT ISOLATION (CIS
- a. Manual CIS (Trip Buttons) No pp1tca e Not Appifcable '
}
Lyr.,(s t, b. Containment Presscre - High 4.75 ig] 5 4.75 psig
- 4. suis STC"." '_!"E !!^' "!Ius g :. ";.._;? Z'" Snd Litch;; xd St *;;!'--ik 1,; ly,,i k_L';
~
, Feed.Jiead I;.ioi;... .....J 3. . aims)
}
g 1
- b. steam secerator Pressure - tow gga k.2 a sas psia
~
g
- L..t:t -- ... ;.vi.;;;., ;' ;; ;..c..s . .I 1
- ys..u. .u on> u .i >u . n . u atec of .na; ". mmi;.. I _.." - _=
@ ?. ? c L/14 $
e
- a. -
d.' w n W 41 , 14 4
- h. . _
/]1 g TABLE (Continued) g G
- g ENGImrrasa $AFETY FEATURE ACTMTION SYSiDI NATISE TRIP wa_s_mrt i.
M h E M Am3 _ 5 I 5. CONTAllWENT Siff' RECIRCULATION (RAS) g
- 4. "r:M *** (Tri;; L;'m.4 ;; ; " rem:;i?:
" "g" - i!e -
"=
- b. Refuelirc Water Tank - Low ne p > 2a'inche above tank ~
1 CONTAllWENT PURGE VALFES IS0tATION T _ a7 . Manual (PURGE Valve Control Not Applicable Not Applicabie f R= Switches) O'musm -. 8 MN t' b. Containment Radiation - High Area -< 220 ar/hr -< 220 nr/hr gM4
- I
- I* It c .
Monitar "C6s" 7. LOSSOFPUWER\ ,
- a. B 4.16 (Losskw Emergencf us Undervoltage22450 of Voltage 1 105 volts with a 2450 1 105 volts with a 1 0.2 second time delay 2 1 0.2 second time delay '
- b. 3628 1 25 volts with a 3628 1 25 volts with a (E 4.16 kv Emergency)
(Degraded Voltage Bus Undervoltage 8 1 0.4 second time delay 8 0.4 second time delay , 2 a s om . # d..3 G y sp;m.5.% 13 6, _ ups Lo vt _ , 3 e v h D E & F T i ; E ! D W [4 : i E M I t I N 1 t i
m S. Dut=Jts* *I eMy S b$4, y TABLE Continued) 3 w G 5 ENGINEERED SAFETY FEATURE ACTNATION SYSTDI IllSTRENDITATIONM w g FUNCTIONAL UNIT ;hrStTPOI ALLOMABLE YALNES i a e { 8. CVCS ISOLATION 5 , 5} e West Penetration Room /Letde-m Heat Exchanger Room Pressure - High 5 0.5 psig -<0.5psig} $ g [ __
- 9. AUXILIARY FEEDWATER ACTUATION SYSTDi s (AFAS)
=- u= ~ m ' Mp a::; ' a ,wnune m ;,M : __':
" pb
. Steam Cenerator' y, .. .,, Level - -139 inches to inches -149 inches to -194 inches
" /
- Low (inc1 ve) (inclusive) 5
- c. Steam Generator AP - High < 5.0 psi ~< 135.0 psi -
(SG- > SG @ d,IZ
- ^
ar - nign 5 135.0 psi d " ^ pi d,-'tc;;Oc.c.hm J g (SGb->SG-9 8 8 - t 2 g . E b 5 m r a N
-a N
=~-
3.4 i g TAtlE.3.3-+ q ' 'g ' g ,a DIGIIIEERED SAFETY FEATRE ACTMTIM SYSTDI INSTREWITATISR TRIT vasure t C, FUNCTISML WIIIT (kIB Wi d i
- -- ALLAEWLE YALBE3 i 12 1. SAFETY IIIJECTICII (SIAS)
- h
- a. - _' (T ';; .;;; .O m ,ypiicable is50,^,piio. ie g i
~ b. Contalneent Pressere - High f5 5 psig 5 4.75 psig E
- c. Pressurizer Pressure - Low l A* 12, 1 1725 a; 1 1725 psfa
- 2. CollTAIMElli SPRAT (CSAS) av-- ._...u tirip sottons) ;;oi 4,, 'c;",1c m-*
R .
"--?'- me
- b. Containment Pressert - High ".
5 4.75 1 5 4.75 psig
- - I
- 3. CollTAIMENT ISOLATI0ll (CIS N'Il
- a. Manual CIS (Trip Buttons) t Applicab Ilot Applicable t s,I 4,o m (sc,es b. Containment Pressure - Hfgh g 5 4.75 pstg
{4.75
\ y ZI" S*"a i.i;Te I^,^^ a T*%
g m.
=r- :' (5!v u " Gitrewe =~'
[;;$ 7m.u invl.1".;7. "'-' ' P M
":t 4 ,,iis oie "-* ."--? f r ';1e sA '
, 0
- b. .12 Q 17 3
Steam Generater Pressure - low > j 2 685 psfa "O D 5 2 i h F emi.i._..; inutta :' = re-"=1 : :t-e**= f: :?:: '-ituteM; $*C 'T j e :.e. qq ionei =ii.+a o A D ' t vi , 6
- Gk
.t _
*l ;
TABLE Continued) S g- ! g a. Imam sArm nAime Ac=n= mm asn=enAn= me was FMCTI8AAL. set (TRIman ALLelusLE VALSES a e 5. CONTAIISIENT SIN RECIRCULATION (RAS) e f p7 _; Tio (7.;r S S
- b. Refueling Water Tank - Lov
,' " ^--1 4 '* - " * - - " ^ ' "
tank 1241 above tank
~
. CONTAIIW sti PURGE VALVES ISOLATI
- a. Manuai (Purge Yalve Control not Applicable
' * ) Not App 11caMe 1 daw w of cA.. y A !
5 See cAuk 5.s.7, ils? # y b.. Containment Radiation - High 5 220 ar/hr $ 120 ar/hr
- Area Monitor 1 Less0F h
- a. B 2450 + 105 volts with a 2450+105voltswithaT I 4.16kwR.r.clusUndervoltage (Loss of Voltage 210.Isecondtimedelay 210.Ysecondtimedelay 1 , ;
. 4.16 kw Emergency Bus Undervoltage 3628 + 25 volts with a 3628 + 25 volts with a j j' { p , -'-' wattaael a + OEw.-J time delay 8 1 0.fsecond time delay f a ' f s , o , _ ,,
7 for T e r. ,
., .g m ;
G 5 a
~
~
r 4..% T. 3. ( J p G Lovs " ' ; n 5^ . 9 _ t c t T # , W .J , t1
r 9c O. m 5. .., I Cl.h.h.g re sr. i r . ,- 4 .;, , 3. 3. c(# , 334_)
-s <V c.s \ s. o L.
9 r;; m TABLE Gr3-4-(Continued) ?" w E ENGINEERED SAFETY FEATMtE ACT5ATION SYSTDI INSTERElrTATigE 1 REP-TA& GEE. , , E - R '
/
- 3. FUNCTIONAL WRIT CMSETP_GNT ALLOWWLE TALBE3 !
b k CVCS ISOLATION m > a
- e
" West Penetration Room / Letdown Heat 5 0.5 psig 5 0.5 psig R L Exchanger Room pressure - High j ,
- 9. AUXILIART FEEDWATER ACTUATION SYSTEM (AFAS)
R* -
"-*^-">=M=
,l 1r. .- a1 (Ir1p ou u 73) "et
. ?;;;!k.';k Y J 3; Q, . Steam Generator (*%- , Level - -194* -149* -194* to -149' Low lusive) (inclusive)
- c. Steam Generator AP-High S 130.0 psi 5 130.0 psid
( > o-r
- d. t t an= f-- ---- - ^f ";J. 51 . pstd ; "".0 pfi .
I,/d m e O ; O i P
\ ? P r w e
'O $
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e
.d - .J
DISCUSSION OF CHANGES ! SECTION 3.3.4 - ESFAS INSTRUMENTATION feature is inope'able, ITS Action A allows continued operation, therefore, this cumption is not needed When two features are inoperable, ITS Action B does not allow continued operation, therefore, the exemption from LCO 3.0.4 is required. The deletion of the LCO 3.0.4 l exemption to Actions which allow continued operation constitutes an admmistrative change. This change is consistent with NUREG 1432. A.7 Current Technical Specification 3.3.2.1 Action 7.c allows an additional inoperable sensor channel to be placed in the bypassed conditico, provided the other channel is placed in the
' tripped condition. Improved Technical Specification 3.3.4 Action B will allow either scrwor module to be placed in trip and the other sensor module to be placed in bypass. The sensor channel in which maintencnce is being performed is the channel that will most likely be bypassed. Deleting the requirement which stipulates one channel must be placed in trip and are in bypass is administrative because only one channel is capable of being bypassed at a ,
time. This change is consistent with NUREG 1432. A.8 Improved Technical Specification Table 3.3.4 1 will contain a Footnote (b), which states that a l safety injection actuation signal (SIAS) starts the Contamment Spray Pumps. Current Technical Specification Table 3.3-3 does not contain this note. The added Note is an informational note that is consistent with the Calvert Cliffs design. De addition of this Note is wnsidered admmistrative since it does not technically alter any requirements. This change is consistent with NUREG 1432. A.9 A Note was added to CTS 3.3.2.1 which allows separate Condition entry for each ESFAS function. The Note in ITS 3.3.4 provides explicit instructions for proper application of the actions for Technical Specification compliance, la conjunction with the proposed Specification 1.3 " Completion Times, " this Note provides direction consistent with the intent of the existing Actions for the ESFAS Instrumentation. This change is consistent with NUREG-1432. A.10 Current Technical Specification 3.3.2.1 Action a requires 'he associated Actions to be entered if the trip setpoint is less conservative than the allowable value. This is consistent with the ITS requirements, which require Actions to be entered if the Allowable value is exceeded because the channel is inoperable. Specifically stating this is not required. Therefore, the CTS requirement which states this is being deleted. This change is an administrative change. This change is consistent with NUREG-1432. A.11 Current Technical Specification 3.3.2.1 Action b requires the Actions of Table 3.3-3 to be entered if an ESFAS ' instrumentation channel is inoperable. Improved Technical Specification 3.3.4 will delete this requirement because the Actions are no 6nger specified in the Instrumentation Table, The ITS Actions are specified in the Actions Section of the Technical Specifications. He deletion of a requirement that is no longer applicable is considered an administrative change. His change is consistent with NUREG-1432. A.12 Current Technical Specification Table 3.3-4 specifies trip setpoints and allowable values for ESFAS functions. ITS 3.3.4 Table 3.3.4-1 only specifies the allowable values for the ESFaS functions. He trip setpoints and allowable values contained in the CTS are identical, therefore, only the allowable values are necessary to be specified for Operability. This change CALVERT CLIFFS - UNITS I & 2 3.3.4-2 Revision 8
DISCUSSION OF CilANGES ! SECTION 3.3.4 . ESFAS INSTRUMENTATION is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements, his change is consistent with NUREG-1432. A.13. Current Technical Specification 3.3.2.1 Action 7.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 7.b requires that within oce hour all functional units receiving an input trom the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 3.3.4 Condition A requires one or more functions with one ESFAS sensor module or associated measurement channel inoperable be placed in trip or bjoass in one hour. He ITS Condition A captures the txhnical intent of CTS Action 7.a and 7.b by requiring that all affected functions take the specified actions, therefore, the change is administrative. His change is consistent with NUREG 1432. A.14 Current Technical Specification 3.3.2.1 SIAS Endnote @, Parts (b) and (c) which discuss when the high pressure safety injection pumps have to be to be placed in pull-to-lock, are deleted. These requirements are already specified for the HPSI pumps in the ECCS specifications (CTS 0 5.3). Ec elimination of duplicative requirements within the Technical Specifications is an administrative change. Changes to the technical requirements are prosided in the Discussion of Changes for Section 3.5. This change is consistent with NUREG 1432. TECHNICAL CHANGES - MORE RESTRICTIVE M.1 Current Technical Specificat: 3.3.2.1 would require the Actions for the functional unit to be followed when a bypass removal channel is inoperable. Improved Technical Specification 3.3.4 established Actions specifically for when one or two automatic block removal features are inoperable (ITS Actions C and D). He Actions are essentially the same as when one or two sensor modules are inoperable, except that the affected sensor block modules are required to be disabled witidn one hour. The addition of this new requirement is considered more restrictive. The addition of this requirement will not adversely affect plant safety because it adds actions which specifically addresses automatic bypass removal functions. This change is consistent with NUREG-1432. M.2 Current Technical Specification 3.3.2.1 does not have any requirements if an Action cannot be completed within the required Completion Time. Thus, CTS 3.0.3 would have to be entered. Current Technical Specification 3.0.3 allows 7 hours to reach Mode 3, and 13 hours to reach Mode 4. Improved Technical Specifications added an Action (Action E), when the Required Action and Associated Completion Times cannot be met, to be in Mode 3 in 6 hours, and Mode 4 in 12 hours. This change essentially allows one less hour to reach Mode 3, however, adequate time is still allowed to reach Mode 3. Therefore, this change will not adversely affect plant safety. His change is consistent with NUREG-1432. M.3 Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additional inoperable channel to be placed in bypass. Improved Technical Specification 3.3.4 Action B will require one sensor module to be placed in trip and one sensor module to be placed in bypass in one hour. His change essentially places a one-hour time limit, where none previously existed, to perform the Actions. His change is, therefore, a more restrictive char.ge. The change will not adversely affect plant safety because if two channels are inoperable one should be placed in trip and one placed in bypass in a time'ly manner. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.3.4-3 Revision 8
DISCUSSION OF CHANGES-SECTION 3.3.4 - ESFAS INSTRUMENTATION i M.4_ - Current Techmcal Specification 3.3.2.l_ Action ll for Containment Spray Actuation Signal-
'(CSAS), allows continued operation with one inoperable channel provided the channel is bypassed in one hour, improved Technical Specification 3.3.4 Action A requires an inoperable channel be restored to Operable status within 48 hours or the inoperable channel is placed in -
trip, his change is more restrictive. His change will not adversely affect plant safety and provides consistency with other ESFAS function actions. Other changes to the CSAS actions are described in a separate-less restrictive change. his change is consistent with NUREG 1432. TECHNICAL CHANGES - RELOCATIONS
- None TECHNICAL CHANGES -' 6MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED-DOCUMENTS LA.1 Not used.
l LA.2 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification Table 3.3.4-1 will not contain this column. This is an informational column which is more appropriate for the Bases. The number of channels to trip will not be cha:~i The information is being moved to the Bases intact. Any changec to these requirements in the Bases will require change in compliance .with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip . will require a design change. The Bases Change Control Program will ensure that changes roccive appropriate review, his change is a less restrictive movement of details change with no impact on safety. His change is consistent with NUREG-1432. LA.3 Not used. l LA.4 -Current Technical Specification 3.3.2.1 Table 3.3-3 Function .3 (Containment isolation) Eminote # states that containment isolation of non-essential penetrations is also initiated by SIAS (Manual Trip and Pressurizer Pressure - Ixnv functions), improved Technical Specifications does not contain this footnote. This informational Note le being moved to the . Bases. Any changes to the Bases will be controlled via the Bases Change Control Program. The Bases Change Control Program will ensure that any changes to this requirement .ill be appropriately revic.wed. His requirement is not being changed, therefore, plant safety is not impacted - his change is consistent with NUREG 1432.
- LA.5 Not used.
l LA.6 Not used. l TECHNICAL CHANCES - LESS RESTRICTIVE L.1 Current Technical Specification 3.3.2.1 Action 11 allows indefinite operation'when one CSAS channel is inoperable and placed in bypass. The CTS allows 2 channels to be bypassed for up CALVERT CLIFFS - UNITS 1 & 2 3.3.4-4 Revision 8
- 24. To resolve NRC comments 3.3,4-3,3.3.412, 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.l' associated with CTS Action 7.
l
i M_ G 34 -0 g TA8tE.4 -r R
~
m 5* _ ENGINEERED SAFETY FEATURE ACTUATION SYSTEM IllSTRIDIDITATI0li b r. $ 5 . FullCTI0llAL UllIT 0F ACTION ,,,
. 1 , -
- ~ -
y e I. SAFETY INJECTION (SIAS > E - d [a. Manual (Trip Buttons) z 1 2 1.2.3.4 6- i
- b. Containr .at Pressure - High M h[ . . 8 .
r13 I
- c. Pressurizer Pressure - Low f. f , A,6 M
g 2. CONTAIMMENT SPRAY (CS
?' (a. nanual (Trip Buttons) ? 1 ? 1 9 1 a 6]
- b. Containment Pressure - High h 72A ,,
- 3. CONTAll#IENTISOLATION(CISh ia . Manual CIS (Trio nuttano 2 1 2 1, 2. 3. 4 6) --.
- b. Containment' Pressure - High @ Q(1/Z_2) ;
R t4 a 5 S 3 , L y ) u om., J % i . 4 9..C..bs 3.2. 5~, '
"cSvas lyx e L' & .N d @ 1Nr" .
A L
4 0 g TABLE (Continued) r- g m. h .I ENGINEERED SAFETY FEATURE ACTUATIN SYSTEM INSTREENTATION w p Ste beb'IsAir3 Jc)) 3 h @ b# & - h 5, FUNCTIONAL UN T ACTION !
- 4. '"!"l m 07T%; LI 23n"!! Q _
. Manual (MSIV Hand Switches _ 1/ valve 1/ valve and Feed Head Isolation j 1/ valve 1.2.3.4 67 h b.
umnd Gitched / kmh '
) am Generator Pressure - t t 1 ., n R
- 5. CONTAllMENT SUMP RECIRCULATION (RAS) b" 4 rianual RAS (Trip Buttons)_ ? ? 1. 2. 3. 4 1
6)
- b. Refueling Water Tank - Low h h 4.3 h A i
?, u puma.u of e.L, G .
y Sp.J f W 3 1 5,** Esras
; 4.c. J rA .A Tc:p"
= m 1
Y tg < m t . p W 9 i
-A N
g .s., 4%s,o .O TAB (Continued) w Q cha p Er <,p L46 ? 9 3.13, = c ycs r..t. A' , IIGIIIEERED SAFETY FEATURE ACTUATION SYSTEN INSTRUMDITATI0ll w I _ b FUltCTI0llAL UllIT b ACTION
. CVCS ISOLATIDM
- a. Manual (CYCS Isolation 1 R Valve Control Switches) 1/Yalve 1/ Valve 1/falve 1,2,3,4 6' c.
- b. West Penetration Room / Letdown Heat Exchanger l Room Pressure - High 4 2 3 1.2.3.4 7*)
R
- 9. AUXILIARY FEEDWATER ACTUATION gg y SYSTEM (AFAS) g3 r
- a. Manual (TriJ Buttens) 2 sets of 2 per T S/G I set of 2 per S/G 2 sets of 2 _
oer S/G /
- 1. 2, 3 67 h ,
a,j b. Steam Generato vel - Low pG p. 5
- c. Steam Generato P High G I
(( 3d 3
. g,g .
E j 2 LA,2 1 M Q *
,E saeOsss u.-.cck.y, y n & C tnae.f uk 3.35, (,
2 'Erm 4.,,c e ., m.s % T!5*' p h-Y h - h 9 6
- r Spaeik hen 3.3 4 i!
a 3/4.3 INSTRUMENTATION TABLE 3.33(Continued) sm kwauus.s & ek pe\ : ACTIONSTATEMENTS k. 5 A,4,,,s 3. 3. 5, swAs1,.y o A M
+r s e.
SCTION6 . .' With the Number number of Channels, of OPERABLE restore the inoperable channel channelsto one less than the Tota OPERABLE status within 48 hours or be in at least NOT STAND 8Y within the next 6 hours and in COLS SNUTDOWN within the following 30 heu'-a j.- A
.ACI3054 -- Twitn tne r of vrtaABLE chann one less tny Ene I _ ouvin eremsw 84 IdN 88*
Number Channels, operation proceed prov Med th m.J4c. er atte+)=4M . followfha cunditient are matt r ma.MdeM Aer,s The inoperabl c is placed in either the bypassed L& 4 R*SkCL or t. ripped conditier. with.in I hour. .;c" th; ;. ;;;;; d
- 4. op.c.u. w <.. .., 4-+------ '4----"- -
,g s4h in 9::M "- t- t;48 hours from time of initial loss of /'),3 vrtumsatain newever, the inoperable channel shall then be either restored to OPERABLE status or placed in the tripped condition,
- b. 'il t one nour, all fun tonal units receiving 17 pud M f IA
- o. . , =, R y the inoperable che el are also placed in e same ndition (either byp ed or tripped, as ap cable ,
g hat ranutrad hv a- == 'a- +ha inaaarahl -- -=
- b 684 channel) g, 4 as ",@iAN% 4 O--
A.rew W * *44 o .e M S y', ,'-- 57.7.;',; r- _^-'l , ,,,.; , ;. .;,t i; 7;ty - ' " ~ ~ ~ B 'y1 in c;r one additional channel ma
...y be bypassedmoryt to p as 48 hours - .. n. ... .., ..-.. . - . . . . . . . . . . . . ._
a channel provided the other inoperable channel is placed L,4 or beye inthetrippedjcondition. @ l4 ^ lJC n 46 60 =1 0{ 6:agu 5 - With less than the Minimum Channels OPERABLE.-operation may - continue provided the containment purge valves are maintained A*are AA S #C. t closed. 3,y,7 'c gs; , ASH 4N-TT"- F__ With the rpmber of OPERABLE Channels ne less than the To l'
, Number o VChannels, operation may ceed provided the inoper 'e channel is placed in bypassed' condition 4,j the-M imum Channels OPERABLE- utrement is demonstr ed wit I houry one additional annel may be bypass for up to rs for surveillance esting-per Speciff n j h9 L CALVERT CLIFFS - UNIT 1 3/4 3-15 Amendment No. 184 +l
__q S (i.GiW ~AspQ _ = - - - t'Y , , w
,,.,,e. -
]
g TABLE +:b$ r- R a h ENGINEDtED SAFETY FEATWtf ACTWATIM SYSTM TW57mElrTATIM q A,#q TWTAL NB. CRMMEL5 CIW WELS FSNCTIONAL UNIT OF CRANNELS T9 TRIP c- 1. SAFETY INJECTION (SIAS [9PDt4BLA( MUSEf3_ M (e. Manual (Trip Buttons) 2 d 1 2 L2L4 fr ; a i i
- b. Containmer,t Pressure - High h 3 A-C A
- c. Pressurizer Pressure - Low f Ql 'L.
1 g 2. CONTAll01ENT SPRAY ( y & Manual (Trip Buttons) 2 1 2 4. z. 2.
- A' i
- b. Containment Pressure - High @ @ ,
- 3. ConTArnnEnr IsotAiron (Cis P @
@ nanval CIs (Trio autions) 2
"- d' 3 D '
1 1. z, 4.
- 5X ,
b. { j Containment Pressure - High s. h j u.2
% y As: n p_q p 1 < e e W ,
h 3.
>G - , . see o. mm _ -. r c c,- 7.3 g n
Q $ p - .fi,. % ~3. 7. 3, y y ~' g w a s t- eyh end V1.- st '
+.3 i
& Giri @p
k.~3. -- g TABLE-544- (Continued) 3
!Qd "Q'j" "d?"4*"""'"""'f"""f2) 9 f11NCT!8KAL W IT l
. 4.
. ., ,,e , , , .--....
. . . . .. . . .. .. - u
~ ' ' ^ M
.E a. ..am u tr517 == = switches 1/ valve 1/ valve
- 1/ valve 1. 2. 3, 4 d Switches)
J h_h@b
- b. Steau Generator Pressure -
Low 2 pease
..,.ig, team d 4 g 4 g t
4.7j
- 5. .CONTAltNDIT SIN RECIRCULATION '
3 (RAS) A.4 l \ _t* - Q . Manual RAS (Trip Buttons) 2
~ 1 2 1, z. J 4 y
- b. Refueling Water Tank - Low
@ J g' g h@ L4.'2 h ,
.s
$ (n <Ls ~ ~... .T ef- g-s f
g F;;,- se. .c. , n ~1,. T;, J\ x , 'O b .( e.a k * *U" f T 8 *p "
\
* <=
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W O o T) J e y ep p .
l l l 5,e Oscossio . .F Ct -$<3 Gr 5('~'* F
- 4 :- w T W W Contf M )
g 3. 3. 9, "cvcs as sArm rtaTur ACrmrreursum ,_a ..-
; i u s. ., s 3- e-
/ 4..z E rectru a arr Y . CVCS ISOLATION
== zi's' o (Mlurra b a. Manual (CVCS Isolation
[ Valve Control Switches) 1/Yalve 1/Yalve 1/ Valve 1.2.3.4 6 E l b. West Penetration Room / Letdown Heat Exchanger Room Pretture Ntak a 2 3 1.2.3.4 7 - A. 7: R
- 9. AUXILIARY FEEDWATER ACTMTI M
- i Y
SYST91 (AFAS) Me 1 t;; a._ Manual (Trip Buttons) 2 sets of 2 per 1 set of 2 2 sets of 2 1. 2. 3 6) : S/G per S/G 1 ser 1/G f A$ l
\ohsta.sgeneragevei-toe hg ps0 % O7 j g,
- c. stea. cenerator se ns,h e a 1. 2 # g
[
,t s_ e _..
.e e.,
3 A. L. $ n [ .c S p .c.'c.;,4.,. - L 3 5, J
] ,[ " EG E AS L%c t --J N~3 o '= r. . g ~ / ['
n ,,
~
i m . LM . O n d g @> @
.4.n*, ..3 *.w5 4 %+Js _e.A >-e.-.3 h +. arm-+.-- e --i me4 u-4.+A-+-#-. rwa-h-ed4 *5 d8'---J *"i A -'fekHi--*+.-e.F*,,w.4 J i I fp ,. . f . . o .o n T.~5. 4 '
1 3/4.3 INSTRWENTATION See C1. . v $ .o % of Cu y TABLE 3.3-3 (Continued) ,,, c, , , . 4 . ., . . ., ~5. ~3. 4, ACTION STATOIENTS "g gh 3 ,3, 1 .*J ; ,7l GN 5 - With the number of OPERABLE channels one less than the Total / Number of Channels, mstore the inopersole channel to SPERABLE status within 48 hours or De in at least NOT STAND 8Y within the next 6 hours and in COLD SNUTDOW within the
*a h ina to hauen. _
; ,_ J . ,. ,
Afff0It-f - ifft neber of OP Lt channels one i than the Tota " Ik r of Channels, losino conditi ation may proceed re satisfied 7 vided th. ..'e****
- c. t? W A S
~
- dole l
, , s - r-ACTioW A Js s se3e ~
,a . n. e . s * * !
R'*4"* \ The inoperablerchannel TV placed in either the bypassed r ,. w i c. ~ . -A 4 or tripped condition within I hour. E r t h ;.r;::r 0. .v. ..n M . * *$ Ne ia ka ' wanen.Tia ;- eer the inoperable channel shall then fhi fligi[iallsEof d. 5
--=
be either restored to OPERABLE status or placed in the y tripped condition. N #^ ' ' ' " D. Within o out, all functional nits receiving an nput' I*"* * ' * *' % '#' from t inoperable channel also placed in t same I' *** MS con on (either b required by a,ypassed tripped, as applfannel), le as - M ! sem.e e d*" , t abo or the inoperable e-AcTiou Q 3
" -.... 4 4 'M m -*-- th:=h ME=^**_E n;t ; ; .-4 % =^ - or 4 ripped *+b m
, * * * - ts . i"g 4 t*" 't- - - ~ ' ' however, one additional char.ael may be bypasse r up to
- 48 hours dih ---'Waa *** ** r d d ....... en sn. o A, L
ehenne l provided the other inoperable channel is placed
^
in the trippedj condition.
@\
CTION 8 = - ' With less than the Minimum Channels SPERA8LE. operation may7 continue provided the containment purge valves are maintained-( closed. - Atttes-44-- f0ith the adr of OPERABLE C is one less than t otal
- NumbergChannels, operatio may proceed provided ino able channel is pla in the bypassed cond on and t inimum Channels OP LE requirement is d strated thin 1 hour; one ad ional channel may be assed for up to 2 hours for surv lance testing per S ficatibn L%
M. 5ee. dui 4 chap 4 40 kb . tid. 7 '
"CR$
- CALVERT CLIFFS - UNIT 2 3/43-15 AmendmentNo.J61 l hs J9]/ C' '
0 J
^
, , . e ,s
DISCUSSION OF CHANGES SECTION 3.3.4 . ESFAS INSTRUMENTATION is administrative since the change involves removal of duplicate information and there is'no reduction in technical requirements. His change is consistent with NUREG-1432. A.13 Current Technical Specification 3.3.2.1 Action 7.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 7.b requires that within one hour all functional units receiving an input from the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 3.3.4 Condition A requires one or more functions with one ESFAS sensor module or associated measurement channel inoperable be placed in trip or bypass in one hour. The ITS Condition A captures the technical intent of CTS Action 7.a and 7.b by requiring that all affected functions take the rpecified actions, therefore, the change is administrative. His change is consistent with NUREG-1432. A.14 Current Technical Specification 3.3.2.1 SIAS Endnote @, Parts (b) and (c) which discuss when the high pressure safety injection pumps have to be to be placed in pull-to-lock, are deleted. These requirements are already specified for the HPSI pumps in the ECCS specifications (CTS 0 5.3). He climination of duplicative requirements within the Technical Specifications is an administrative change. Changes to the technical requirements are provided in the Discussion of Changes for Section 3.5. This change is consistent with NUREG 1432. TECIINICAL CHANGES - MORE RESTRICTIVE M.1 Current Tecimical Specification 3.3.2.1 would require the Actions for the functional unit to be followed when a bypass removal channel is inoperable. Improved Technical Specification 3.3.4 established Actions specifically for when one or two automatic block removal features are inoperable (ITS Actions C and D). The Actions are essentially the same as when one or two sensor modules are inoperable, except that the affected sensor block modules are required to be disabled within one hour, ne addition of this new requirement is considered more restrictive. The addition of this requirement will not adversely affect plant safety because it ac'ds actions which specifically addresses automatic bypass removal functions, This change is consistent with NUREG-1432. M.2 Current Technical Specification 3.3.2.1 does not have any requirements if an Action cannot be completed within the. required Completion Time. Thus, CTS 3.0.3 would have to be entered. Current Technical Specification 3.0.3 allows 7 hours to reach Mode 3, and 13 hours to reach Mode 4. Improved Technical Specifications added an Action (Action E), when the Required Action and Associated Completion Times cannot be met, to be in Mode 3 in 6 hours, and Mode 4 in 12 hours. His change essentially allows one less hour to reach Mode 3, however, adequate time is still allowed to reach Mode 3. Therefore, this change will not adversely affect plant safety. This change is consistent with NUREG-1432. M.3 Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additional inoperable channel to be placed in bypass. Improved Technical Specification 3.3.4 Action B will require one sensor module to be placed in trip and one sensor module to be placed in bypass in onehour. This change essentially places a one-hour time limit, where none previously existed, to perform the Actions. This change is, therefore, a more restrictive change. The change will not adversely affect plant safety because it two channels are inoperable one should be placed in trip and one placed in bypass in a timely manner. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.3.4-3 Revision 8
DISCUSSION OF CIIANGES SECTION 3 3 4 - ESFAS INSTRUMENTATION M.4 Current Technical Specification 3.3.2.1 Action 11 for Containment Spray Actuation Signal (CSAS), allows continued operation with one inoperable channel provided the charmel is bypassed in one hour. Improved Technical Specification 3.3.4 Action A requires an inoperable channel be restored to Operable status within 48 hours or the inoperable channel is placed in trip. This change is more restrictive. His change will not adversely affect plant safety and provides consistency with other ESFAS function actions. Other changes to the CSAS actions are described in a separate less restrictive change. This change is consistent with NUREG-1432. TECIINICAL CIIANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED-DOCUMENTS I LA.1 Not used. l LA'.2 Current Technical Specification 3.3.2.1 Table 3.3-3 contains a " Channels to Trip" column. Improved Technical Specification Table 3.3.4-1 will not contain this column. This is an informational column which is more appropriate for the Bases. He number of ch:mnels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0, However, any hardware change to the number of channels to trip will require a design change. He Bases Change Control Program will ensure that changes receive appropriate review. This change is a less restrictive movement of details change with no impact on safety. His change is consistent with NUREG-1432. LA.3 Not used. l LA.4 Current Technical Specification 3.3.2.1 Table 3.3-3 Function 3 (Containment Isolation) Endnote # states that containment isolation of non-essential penetrations is also initiated by SIAS (Manual Trip and Pressurizer Pressure - Low functions). Improved Technical Specifications does not contain this footnote. This informational Note is being moved to the Bases. Any changes to the Bases will be controlled via the Bases Change Control Program. The Bases Change Control Program will ensure that any changes to this requirement will be appropriately reviewed. This requirement is not being changed, therefore, plant safety is not impacted. His change is consistent with NUREG-1432. LA.5 Not used. l LA.6 Not used. l TECTINICAL CliANGES - LESS RESTRICTIVE L.1 Current Technical Specification 3.3.2.1 Action 11 allows indefinite operation'when one CSAS channel is inoperable and placed in bypass. The CTS allows 2 channels to be bypassed for up CALVERT CLIFFS - UNITS 1 & 2 3.3.4-4 Revision 8
?
h 25T To resolve NRC comment 3.3,4 4,' Discussion of Change L.4 was added to justify placing one i channel in bypass and one channel in trip for reasons other than maintenance and testing. The - l
- CTS markup and No Significant Hazards Considerations have been updated accordingly..- !
i h e T 9 y > e 8 a i 7 <- y+ ,.v. - - , o -
, _ -_- , . ---- . ~ ,. - .- y , - -- -- - , - ,
~ _ - - - . . . . . -..~.-- . _ . - . . . - - . . - . - _ _ -. . . . . . - . . . --. - ..-
t
%3-
.g r-TABLE a ]r4d] -
g i a N ENGINEERED SAFETY FEATURE ACTCATI N SYSTEN INSTRW U TATI M f
- t. h 5 l
FUNCTIONAL UNIT 0F. ACTIM
. ~ .
g 1. SAFETY INJECTION (SIAS g
~
z , . [a. Manual (Trip Battons) 1 2 1. 2. 3. 4 63- A
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- 2. CONTAlletENT SPRAY (
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- b. Containment Pressure - High 2,8) !
- 3. CONTAllW4ENTISOLATION(CISh (a . nanual CIS (Trin autenne 7 1 2 1, 2. 3. 4 6) I
- b. . Containment Pressure - High k L.4 '
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Q 5 . b ec s ,. , . O TAS (Continued) Q cb p Er s e 4A" y 9 3.12, "cycs r..t,ti INEERED SAFETY FEATURE ACTBATION SYSTEN INSTRWENTATION w r2 2 - FtmCTIONAL W IT LS I ACTION ,., c . CVCS ISOLATION 5 -- y a. g
- Manual (CVCS Isolation l 3 Valve Control Switches) 1/ Valve 1/ Valve 1/ Valve 1.2.3.4 6' m%
- b. West Penetration Room / Letdown Heat Exchanger Room Pressure - High 4 2 3 1.2.3.4 7*/
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- 9. AUXILIARY FEEDWATER ACTUATION SYSTEM (AFAS)
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- a. Manual (Irip Buttons) 2 sets of 2 per I set of 2 2 sets of 2 _ 1. 2, 3 6)
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- c. Steam Generator .iP High G.I
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3/4.3 INSTRWENTATIN TABLE 3.3-3 (Continued) sa kw.ssws *f CWyn - ACTI N STATEMENTS 6. gg f.,4,, n 3,3, g _ ssrAs L.p a os4
+rie.
(ACTION 6 With Number theofnumber Channels, of restore OPERABLE channels the inoperable one less channel to than the . Total]
' OPERABLE status within 48 hours or be in at least NOT STANDBY within the next 6 hours and in COLD SNUTDOW within the following 30 baura ] A*
l o.4 . , me et aA*v
-ACI3054 --
Twitntne r or artnABLE chann one less tnyi the T 64 ' +4 . *4 IJN
- i
' Number' Channels, operation proceed provMed th mehle. er atfo6Adel Lfollowho conditiant are nati ed .r-- me v,(. ,l Ae rs.W The inoperabl c is placed in either the bypassed
~ rA
! A 45h CL _4. op.c.ug or. t.anripped .,a condition e-... --. within '- 1 hour. T; th; ;.re;;;. ;f
; ;7x,; ;t;,,,,; g 4 446s la 6" -9 'r = id48 hours from; time of initial, loss of /45
' orERAsaLalTg newever, the inoperable channel shall then be either restored to OPERABLE status or placed in the tripped condition. {- M
- b. .W it one nour, all fun ional units receiving inpuD l f the inoperable che el are also placed in e same .
} O m * * **
- ndition hat recuired (either by abyp wa ed or tripped, as ap cable as
- fe the innnarahl channel).i-y
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# B: c :7. one additional channel may be bypassedWor up to j
r Z','7 48 hours wM . r., ... . ... ..... ..~...........,--*Mt O* 7 A t o channel provided the other inoperable channel is placed in the tripped 4condition.- L,4 @ g Msepe4ye_ ,, g u avu 5 - : With less than the Minimum Channels OPERA 8LE, operation may' continue provided the containment purge valves are maintained ) 3.3.7 '^)de A^ 5#8* closed.
'c pssi J
4 GHON-TT"- With the rpmber of OPERABLE ChannelsAne less than the To 1
' Number ofchannels, operation may %ceed provided the '
inoper ;e channel-is placed in bypassed' condition nd the f*j imum Channels OPERABLE- uirement is demonstr ed wit I hoursione additional hannel may be bypass for up to hours for ' surveillance esting-per Specift
.z.1. .
n j h.9 J I CALVERT CLIFFS - UNIT 1 3/4 3-15 Amendment No. 184 #l u W.___-- g f7 , , g
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E A.N TsTAL W. fGWWEL$l OWEELS f 7 FW CTIONAL GRIT {yGWWELS N e I. SAFETT INJECTI0ft (SIAS (79 TRIP) OPDIABLE A MODES
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Tt. r . , C . ,$ + .o T. ; . 4 3/4.3 INSTIMNtNTATION see o s< vu .as o r C L~ m ~, e TABLt.3.3 4 (continued) ,, g,, , , c, . , , e ~5. '5. 4, ACT10E STAfDWrf1 $ $ p p g l, gi ,, . J _ ]* * *,* l Itu 5 - With the . weber of GPERABLE channels one less than the Total Number Jf Channels. restore the inoperable channel to OptRABLE status within 48 hours er be in at least 00T STAISOY within a11aminsthe next M h5 ehours
- s. and in COLS $ NUT 00lAl within the J.re
,, ,, 7 A0ftelt? - Wit number of OPE Lt channels one 1 than the tota N # * *'" # "
Nt r of Channels attnnmayproceedNytdadthe c. ItWA $ tawins conditt , re stilafted: #
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inoperable channel shall then be either restored to SPERABL.' status or placed in the Ag tripped condition.
" ** ***," t. Within o our, all functional nits receiving an nput' from t inopert.ble channel also placed in t sawe I* * ' ' * *' % '#
( **
- ITS M S con ()4 on (etther bypassed t M required by a. abo tripped, as appi le d.3 l
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'" *4'* hewner, one additional channel may be bypasse r 48 hours Wh ^^-'H aa +^^M rd dom.nw en s.up to n..c A
-ehennt1 providtd the other inoperable channel is placed A,
7 in the trippedjcondition. ff!0li
-s_
8 . With less than the Minimum Channels SPERABLE, operation may7 continue provided the containment purge valves are maintained' y losed, f-Attt0544-- fliitht r of OPERABLE C nels one less than t otaf ' Number Channels, operatio may proceed provided l ino ble channel is pla in the bypassed cond on and t intaus Channels OP Lt requirment is d strated frithin 1 hourg one ad ional channel may be assed for up to 2 hours for su lance testing per $ fication t-*l m, w b e m.., s <>s y. 4 4 0 4 4.. 3ia 7 -
" Cdi
- CALVERT Cliff $ - UNIT 2
_ _ . ~- 3/4315 Amendment No. 161 > l wyw'-w 33 G5 0
. p ., $ c '7 . F Ib
l DISCUSSI N OF CilANGES SECTION 3.3.4 . ESPAS INSTRUMENTATION to two hours. Improved Technical Specification 3.3.4 will change the CSAS Act ions to be consistent with the other ESFAS functions (ITS Actions A and D) which pennit one channel to be b) passed or tripped for 48 hours and then either restored or tripped, and two channels inoperable for up to 48 hours prmided one is tripped and the other bypassed. %e 48-hour limitation to bypass a single inoperable channel is discussed in a separate more restrictive l change. %c allowance to place a channel in either bypass or trip and the allowance to operate i for 48 hours with two inoperable channels is less restrictive. no CTS Actions were established prior to manual bypass switches being incomorated, and prior to modifications which require a CSAS coincident with a SIAS to start the containment spray pumps nese l modifications prevent a single failure from causing an inadvertent spraying of containment. For these reasons, it is acceptable for the CSAS to have the same actions as the other ESFAS functions. L.2 Improved Techrjcal Specification 3.3.4 Table 3.3.41 adds Footnote (c) to CTS 3.3.2.1 which l allows the Steam Ocnerator Isolation Signal (SGIS) function and the Steam Generator Fressure low sigrmis to not be Operable when all associated valves isolated by the SGIS l function are closed and deactivated. His change is acceptable because, whcn the valves that are isolated by an SOIS are closed and deactivated, the safety function of the SGIS is me: rnd, therefore, is not required. Adding requirements which allow the trip function to not be Operable constitutes a less restrictive change. His change is consistent with NUREG 1432. L.3 Current Technical Specification 4 0.2.1.2 requires the logic for the bypasses to be demonstrated Operable during the CFT of channels affected by bypass operation. Manually or automatically inserted bypasses allow plant operation under conditions that do not require the respective ESFAA functions, but would result in an unnecessary ESFAS actuation if they were not bypassed. He total bypass functions remove these bypasses when the plant conditions no longer support allowing the bypasses. Imprmed Technical Specification SR 3.3.4.3 and SR 3.3 A 4 requires the total bypass function be verified every 24 months. This is consistent with safety analysis assumptions that the automatic bypass removal function operates. He capability to bypau a function when it is not needed is not assumed in safety analyses since it performs no mitigative fun-tion. Acrefore, this requirement is deleted from the Technical Specifications. His change is consistent with NUREG 1432, L.4 Curmnt Technical Specification 3.3.2.1 Action 7.c pennits a second channel to be placed in bypass for up to 43 hours for maintenance or testing when one channel is inoperable and placed in the trip condition. Improved Technical Specification 3.3.4 Action D will permit one channel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours. His is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance. His change is receptable since the cause of the inoperability, either planned or unplanned, has no different impact to the overall safety. His change would avoid an unplanned shutdown and associated transient due to an unforseen channel inoperability. His change is consistent with NUREG 1432. L.5 Current *, chnical Specification Table 3.3 3 prmides an exception to the requirements of Specification 3.0.4 for all ESFAS functions except the auxiliary feedwater actuation signal. Improved Technical Specification 3.3.4 makes the LCO 3.0.4 cxception applicable to all functions including the AFAS. His exception may be necessary to permit' mode changes in support of required maintenance and testing for an inoperable channel. The ITS cffectively CALVERT CLIFFS - UNITS I & 2 3.3.4 5 Revision 8
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3J - INSTRUMENTATION 33.4 Chave L4
!. Does the change involve a significant increase la the probability or consequences of an !
accident previously evaluated? ! De proposed change provides actions when two channels are Inoperable for any reason, in j addition to maintenance and testing. De allowed outage time for channel inoperability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not 4 affected. De consequences of an event are not affected since the function is already permitted to have two inoperable channels for the same allowed outage time for maintenance and testing ; l activities. Derefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any preslously evaluated?
%ls change will not phhsically alter the plant (no new or different type of equipment will be installed). %c changes in methods goveming normal plant operation are consistent with current i
safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 1
- 3. Does this change involve a significant reduction in mart in of safety?
ne current Technical Specincations already permit a second ESPAS channel to be inoperable for maintenance and testing purposes. De proposed cht.nge extends this to any cause of channel inoperability. De failure of a channel is an infrequent event when compared to the frequency of routine maintenance and testing (e.g., channels are tested quarterly). He proposed change does not alter or delete any requirement used to preserve the assumptions in the applicable safety analysis, therefore, the change does not resuit in a significant reduction in a margin of safety. 33.4 Chamme L.A
- 1. Does the change involve a significant increase la the probability or consequences of an accident previously evaluated?
The proposed change provides an exception to LCO 3.0.4 when two AFAS channels are inoperable, ne AFAS is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. De consequences of an event are not affected since the function is already permitted to have two inoperable channels and remains capable of responding to an event if necessary with a one-out of two logic. Herefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. - Does the change create the possibility of a new or different kind of accident from any previously evaluated?
This change will not physically alter the plant (no new or difTerent type of equipment will be installed). He changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS i & 2 3.3 15 Revision 8
, _ _ _ . , cr, --w ~< e ,
- 26. To resolve NRC comment 3.3.4 6, Discussion of Changes L.I and M.4 were revised to clarify the changes to the containment spray actuation signal Actions.
h
i DISCUSSION.O!' CHANGES SECTION 3.3.4 ESFAS INSTRUMENTATION l ! M.4 Current Technical Speci6 cation 3.3.2.1 Action 11 for Containment Spray Actuation Signal (CSAS), allows continued operation with one inoperable channel progided the channel is l bypassed in one hour, improved Technical Specification 3.3.4 Action A requires an inoperable i channel be restored to Operable status within 48 hours or the inoperable channel is placed in trip. His change is more restrictive. His change will not adarsely aff'oct plant safety and provides consistency with other ESFAS function actions. Other changes to the CSAS actions are described in a separate less restrictive change. This change is consistent with
- NUREG 1432.
TECHNICAL CHANGES - RELOCATIONS l None TECHNICAL CHANGES MOVEMENT- OF DETAILS TO LICENSEE CONTROLLED-DOCUMENTS T LA.1 Not used. l LA.2 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification Table 3.3.41 will not contain this column. His is an informational column which is more appropriate for the Bases, ne number of channels to trip will not be changed. The infonnation is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. -De Bases Change Control Program will ensure that changes !- receive appropriate review, his change is a less restrictive movement of details change with
. no impact on safety. his change is consistent with NUREG 1432.
LA.3 Not used. .l LA.4 Current Technical Spe:ification 3.3.2.1 Table 3.3 3 Function 3 (Containment Isolation) Endnote # states that containment isolation of non-essential penetratic 4 is also initiated by
- SIAS -(Manual Trip and Pressurizer Pressure - 14w functions), improved Technical Specifications does not contain this footnote. His infomational Note is being moved to the Bases. Any changes to the Bases will be controlled sia the Bases Change Control Program.
~ ne Bases Change Control Program will ensure that any changes to this requirement will be appropriately reviewed. His requirement is not being changed, therefore, plant safety is not
; impacted. This change is consistent with NUREG-1432.
LA.5 Not used. l LA.6 Not used. l TECHNICAL CHANGES - LESS RESTRICTIVE
- L.1 . Current Technical Specification 3.3.2.1 Action 11 allows indefinite operation'when one CSAS channel is inoperable and placed in bypass. De CTS allows 2 channels to be bypassed for up
- CALVERT CLIFFS UNITS 1 &. 3.3.4-4 Revision 8 9
DISCUSSION CF CHANGES SECTION 3.3.4 ESFAS INSTRUMENTATION to two hours, impromi Technical Speci6 cation 3.3.4 will change the CSAS Actions to be consistent with the other ESFAS Ametions (ITS Actions A and B) which permit one channel to be bypassed or tripped for 48 hours and then either restored or tripped, and two channels inoperable for up to 48 hours provided one is tripped and the other bypassed. De 48 hour limitation to bypass a single inoperable channel is discussed in a separate more restrictive change. Le allowance to place a channel in either b> pass or trip and the allowance to operate for 48 hours with two inoperable channels is less restrictive. %e CTS Actions were established prior to manual bypass switches being incorporated, and prior to modifications which require a CSAS coincident with a SIAS to stait the containment spray pumps. Dese l modifications prevent a single failure ham causing an inadvertent spraying of W-aa-( For those reasons, it is acceptable for the CSAS to have the same actions as the other ESFAS functions. L.2 Improved Technical Specification 3.3.4 Table 3.3.41 adds Footnote (c) to CTS 3.3.2.1 which I allows the Steam Generator !=olation Signal (SolS) function and the Steam Generator Pressure Law signrds to not be Operable when all associated valves isolated by the SGIS l function c.re closed and deactivated. - Inis change is acceptable because, when the valves that are isolated by an SGIS are closed and deactivated, the safety function of the SGIS is met and, therefore, is not required. Addag requirements which allow the trip function to not be Operable constitutes a less restrictive change his change is consistent with NURFA1432. L.3 Current Technical Specification 4.3.2.1.2 requires the logic for the bypasses to be demonstrated Operable during the CFT of channels affected by bypass operation. Manually or automatically inserted bypasses allow plant operation under conditions that do not require the respective ESFAS functions, but would result in an unnecessary ESFAS actuation if they were not bypassed. De total bypass functions remove these bypasses when the plant conditions no longer support allowing the bypasses, improved Technical Specification SR 3.3.4.3 and SR 3.3.4.4 requires the total bypass function be veriued every 24 months. Als is consistent with safety analysis assumptions that the automatic bypass removal function-operates. De capability to bypass a function when it is not needed is not assumed in safety anal >ws since it performs no mitigative function. - Herefore, this requirement is deleted from the Technical Specifications. his change is consistent with NUREG 1432. L.4 Current Technical Specification 3.3.2.1 Action 7.c permits a second channel to be placed in >
. bypass for up to 48 hours for maintenance or testing when one channel ~is inoperable and placed in the trip condition. Improved Technical Speification 3.3.4 Action B will permit one channel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours. His is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance. nis change is acceptable since the cause of the inoperability, either planned or unplanned, has no different impact to the overall safety. l This change would avoid an unplanned shutdown and associated transient due to an unforseen channel inoperability. His change is consistent with NUREG 1432.
L.5 Current Technical Specification Table 3.3 3 provides an exception to the requirements of Specification 3.0.4 for all ESFAS functions except the auxiliary feedwater actuation signal. Improved Technical Specification 3.3.4 makes the LCO 3.0.4 exception applicable to all l functions including the AFAS. This exception may be necessary to permit mode changes in
. support of required maintenance and testing for an inoperable channel. The ITS cffectively CALVERT CLIFFS UNITS 1 & 2 3.3.4 5 - Revision 8 d
l' ! t i l 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. He reference to 3 Containment Pressure liigh function in the footnote (c) was an error and has been deleted. -i l i I [ i l I l 1-f l 1 I w l l i s
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- -, .--.ve--h-ny'u++-+--.
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ESFAS Instrumentation 3.3.4 ; Table 3.3.4-1 (page 3 of 3) Engineered Safety Features Actuation System Instrumentation (d Pressurizer Pressure-Low may be manually bypassed when pressurizer i pressure is < 1800 psia. The bypass shall be automatically removed ; whenever pressurizer pressure is a 1800 psia.
~
(H SIAS is _ required to start the containment spray pumps. (d . Only the Steam Generator triolation (SGIS) Function and the Steam Generator Pressure-Low signal are not required to be OPERABLE when all 7 associated valves isolated by the SGIS Function are closed and de. activated. ' (d Steam Generator Pressure-Low may be manually bypassed when steam generator pressure is < 785 psia. The bypass shall be automatically removed whenever steam generator pressure is 2 785 psia, f 1 } CALVERT CLIFFS - UNITS 1 & 2 3.3.4-7 Revisionff8 4 5
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1 a v 7 T hj s - N w e O o cn e r I T
'sn L
)O R O
to ii wt - u s s A L U t t o - k I Sa e O J- l r C R B u a n N u Hdoe P I T A ns C p aI r E r s S o i h I Ya. dd t a R T ( r t e a 3r a s
*r "e 1 eh r N W m e L d s T 5Hc M
(di e t G n e I S T S A R g n c * , T,
- I I R
l eG l i l f 5
.b W
L
= aF u
ndu an-m a O W l a a u n f e u o 1. t -
.a M :" Ma= S l
A) n R e =. 2 s e O : TS I NA JrbC t. OR T . N b C( Wb Dw4.a U F 4 5
- L. .
wps4 gr- m2 .g** 1 l R* wh yl3 g;o. '-
~r.
kw %
Spe<i44,. 3,3,9 3/4.3 IllsfalBitNTATIN
. r[
~
TABLE L3 3 (Continued) r TABLE NOTATION ' Me Fi S e.d h av.I hr ntm ? nc$ n$tsY . i
/ - ,
{hhentheRCStemperatureist
'IM. Greater than 345'F. the required opstABLE Mps! pops must be able '
u to start automatically un'Hi receipt of a $1A5 sinnal. _ Between l'F s'nd 365'F. a transt f(b)Op Mp31-pump wt11.be plac n recton exists wnere rne l 1 in puO .to lock on a cool and stored to automatic st s on a heatup. 4. l 4 k(c)/ u11 365'F tred OptRABLE HPS! be in l _%is,6 g 4a.and lackless, the re start and util autamattea11v. pump 8 J l The provisiens of SpecttIcation 3.0.4 are not app 11 cable. h h, Must be Opt 248LE only in N005 6 when the valves are required OptRABLE and they are open f %f Fashed. gg () N Trip function may be bypassed in this MODE when pressurtzer pressure J-is < 1800 patas bypass shall be automatically removed when Ie pressurtzer pressure is y,1800 psia. y N Tri function may be bypassed in this MODE ')elow 785 psta bypass '
@ shafi be automatically removed at or above 785 psia.
i mv- , g
'N* I Only Ma Stee. Co.sedoc L.tihem Jy d l56' D O * "
- w & hwa.t.., ,ay w J rw w y upt$ .<J ug.ma
- u eeten u o,. . a a v.% w . w % s w c.a,..,
j
- na (6 J - A4 A de.-adtn4v4.
i W$$? A Geh: d sp.y p.q,
.CALVERT CLIFFS - UNIT 1 3/4 3-14 "
Amendment No. 185 pey L ef Ib
,,, e y e ytver ep ~te
4 Q g- TABLEW t.*., h DICINEEEED SAFETY FTAT=E ACTEATT= SYSTDI amuamaus b si o.,4 r s, r=Cneau =rr (wc====n,.) a- as < g . 7 s s(n wP/t t = is una g 1. SAFETT INJECTIOlt (SIAS " g g (a. Manual (Trip Buttons) 2 2 1 L2L4 CI N
- b. Containment Pressure - Nigh h % 3 -C A
- c. Pressurizer Pressure - Loir
[ { h ' LI. g 2. CONTAllWENT SPRAT ( * { 6 Manual (Trip Buttons) 2 2 1 a. 4. a. , y* ,'
- b. Contafrument Pressure - High @ ,
1
- 3. CONTAllWOIT ISOLATION (CISP LA~3 rA. A.3 A- #5
@ nonval CIS (Trip Buttons) 2 a I, z, J,
- 6X ,
k b. Contafrasent Pressure - High g . A- t4.2 g j( A.S X j,7 _f 1 o-e
.i
@ W 'h E. .
>G -
3 '
, . su o. ., s ,. _ rcLr> W T> '
Q $g~E.% 3. T. 5, 'u y
- gwas t-eya '
~J V1.- ,s '
+p **
- GEi @p
i.~5.h @ _ TABLEW (ContfitweQ .. acs W~ c p c :.... n ~ ~ ~ % *%~ --- &n ..
" ' " "_n,..c.,xi.2f)f
( b c
- 4. E:" m? :.:_ := ;=
- w) , ACr m g
~
$ . meas (mIT .t.; Switches $
uvalve uvalve uvalve 1, 2, 3, 4 D namE
&_ +c.GL t
b.. Steam Generator Pressure - g . 4
- 5. CONTAllW0tT Stpr RECIRCUI.ATION "6 $ ,8 4 ~7 IW A,4 'r{, 3 . j 2 .
Y . Manual RAS (Trip Buttons) 4y/ 2 1 2 1. z. J. 4 g
- b. Refueling Water Tank - Low L4 A i 8b 4 .s T
. <n s ..- .c e s . ,. :
k F;;, se.. c. , r,,, s ,.1; , p 5 m r..;
,; BF45 g,. ._ a. M.... ;
\ i i 7 ':
7 ; u, e y tJ -
, s n .J 6
l y & I ; i
. . - . - ~ - . . _ - . - - - . - _ - . _ - _- .
Seo e.Fic64 :5. 3. 4 l 1 3/4.1 INSTR 100tMAT30N , TABLE 3.3 3 (Continued)
' b'#" Y 4.r Src. h . k 1. M ,
TABLE hefAf!0N
'hMW*e AAMirm .
e M+a4 1 1 _ Ei!A$ H t W unIb"! a**j$8[ { Pene s is else init
^
fifhen the ACS temperature is I the required $PERABLt HP$1 (D) Greater than 328'F.lly upon recatet of eL $1AS sSs ani be abj) to start autenatica Lt w 11' lace (YpYu.Y,.'10c aYooown
. nd Mstored to automat sfatusonahettup. I c) At 301*F and less. required OPERABLE N p*$,;,,g L pu11.to-10ck and 11 not start autome ly.pm, shall be i.d
. ---- g.
e Q-A ct u ra C 4 % ( - Now The provisions of Specification 3.0.4 are not appitcable. h J U
%, .4 e a ;xx,,ig y = = ....... - ,.- ao o d 1J (p) g Trip function ma be bypassed in this MODE when pressortaer pressure d 'p h' is < 1800 pstas ypass shall be automatically removed when i' t F ,..J , .4 , Pressuriter pressure is t 1800 psis,
- (.O M Tri function may be bypassed in this MODE below 785 pstal b#ass sha 1 be automatically removed at or above 785 psis
. [,e i s. L'.+ .'. M a iI ($ c l 5) a FAw +'< GD ~ C'*' **" P' ' ' * ' < - L e ~
(.c) g ,< p .. + v v< % .c / a. s s..s . p ~ < f
;.+ c p.,,a 4 w< onr% et.e c ., .o p w .cl%4c4 waturs .'s*Ia4*4 ky ne. SGi$ ,
y 4,n .i r e cl.ged and de Ac 4 iv w 4.d ,
= _.
-m m ~-__==.,=,~-= +~--
******* 4' 'd* * ***** ~ * * ~i Stag ,, c ' b ' " I
& .s pey pep S ,
' ~ ~ ~- _ ~ ~ -~'
A,8 CALVERT Clifr$ . UNIT 2 3/43.g4 Amendment No. 178 e
EISCUSSION OF CilANGES SECTION 3.3.4 - ESFAS INSTRUMENTATION feature is inoperable, ITS Action A allows continued operation, therefore, this exemptivn is not needed. When two features are inoperable, ITS Action D does not allow continued operation, therefore, the exemption from 1.C0 3.0.4 is required. He drietion of the LCO 3.0.4 cxemption to Actions which allow continued operation constitutes an administrative change. His change is consistent with NUREG 1432. A.7 Current Technical Specification 3.3.2.1 Action 7.c allows an additional inoperable sensor channel to be placed in the bypassed condition, provided the other channel is placed in the tripped condition. Improved Technical Specification 3.3.4 Action D will allow either sensor module to be placed in trip and the other sensor module to be placed in b> pass. De sensor channel in which maintenance is being performed is the channel that will most likely be bypassed. Deleting the requirement which stipulates one channel must be placed in trip and a c in bypass is administrative because only one channel is capable of being b> passed at a time. His change is consistent with NUREG 1432. A.8 Improved Technical Specification Table 3.3.4 1 will contain a Footnote (b), which states that a l safety injection actuation signal (SIAS) starts the Containment Spray Pumps. Current Technical Specification Ts ole 3.3 3 does not contain this note. He added Note is an infonnational note that is onsistent with the Calvert Cliffs design. The addition of this Note is considered administra'.;ve since it does not technically alter any requirements. His change is consistent with NUREG 1432. A.9 A Note was added to CTS 3.3.2.1 which allows separate Condition entry for each ESFAS function. He Note in ITS 3.3.4 provides expheit instmetions for proper application or the actions for Technical Specification compliance. In conjunction with the proposed Specification 1.3 " Completion Times, " this Note provides direction consistent with the intent of the existing Actions for the ESFAS Instmmentation. His change is consistent with NUREG 1432. A 10 Current Technical Specification 3.3.2.1 Action a requires the associated Actions to be entered if the trip setpoint is less conservative than the allowable value. His is consistent with the ITS tcquirements, which require Actiora to be entered if the Allowable value is exceeded because the channel i inoperable. Specifically stating this is not required. Herefore, the CTS requirement which states this is being deleted. His change is an administrative change. His change is consistent with NUREG-1432. A.ll Current Technical Specification 3.3.2.1 Action b requires the Actions of Table 3.3-3 to be entered if an ESFAS instrumentation channel is inoperable. Improved Technical Specification 3.3.4 will delete this requirement because the Actions are no longer specified in the Instrumentation Table. The ITS Actions are specified in the Actions Section of the Technical Specifications. He deletion of a requirement that is no longer applicable is considered an administrative change. This change is consistent with NUREG 1432, A.12 Current Technical Specification Table 3.3 4 specifies trip setpoints and allowable values for ESFAS functions. ITS 3.3.4 Table 3.3.41 only specifies the allowable values for the ESFAS functions. He trip setpoints and allowable values contained in the CTS are identical, therefore, only the allowable values are necessary to be specified for Operability. His change CALVERT CLIFFS - UNITS I & 2 3.3.4 2 Revision 8
DISCUSSION OF CHANGES SECTION 3.3.4 ESFAS INSTRUMENTATION to two hours, improved Tecimical Specification 3.3.4 will change the CSAS Actions to be consistent with the other ESFAS functions (ITS Actions A and B) which permit one channel to be b> passed or tripped for 48 hours and then either restored or tripped, and two channels inoperable for up to 48 hours provided one is tripped and the other bypassed. Ec 48-hour limitation to bypass a single inoperable channel is discussed in a separate more restrictive change. Ec allowance to place a channel in either bypass or trip and the allowance to operate for 48 hours with two inoperable channels is less restrictive. The CTS Actions were established prior to manual bypass switches being incorporated, and prior to modifications which require a CSAS coincident with a SIAS to start the containment spray pumps. %csc l modifications prevent a single failure from causing an inadvertent spraying of containment. For these reasons, it is acceptable for the CSAS to have the same actions as the other ESFAS functions. L.2 Improved Technical Specification 3.3.4 Table 3.3.41 adi : ootnote (c) to CTS 3.3.2.1 which l allows the Steam Generator Isolation Signal (SGIS) function and the Steam Generator Pressure IAw signals to not bc Operable when all associated valves isolated by the SGIS l function are closed and deactivated, This change is acceptable because, when the valves that arc isolated by an SGIS are closed and deactivated, the safety function of the SGIS is met and, therefore, is not required. Adding requirements which allow the trip function to not bc Operable constitutes a less restrictive change. This change is consistent with NUREG 1432. L.3 Current Technical Specification 4.3.2.1.2 requires the logic for the bypasses to be demonstrated Operable during the CFT of channels afTected by bypass operation. Manually or automatically inserted bypasses allow plant operation under conditions that do not require the respective ESFAS ftmetions, but would result in an unnecessary ESFAS actuation if tlxv were not bypassed. He total b> pass functions remove these bypasses when the plant conditions no longer support allowing the bypasses. Improved Technical Specification SR 3.3.4.3 and SR 3.3.4.4 requires the total b> pass function be verified every 24 months. This is consistent with safety analysis assumptions that the automatic bypass removal function operates. The capability to bypass a function when it is not needed is not assumed in safety analyses since it performs no mitigative function. Therefore, this requirement is deleted from the Technical Specifications. This change is consistent with NUREG-1432. L.4 Current Technical Specification 3.3.2.1 Action 7.c permits a second channel to be placed in bypus for up to 48 hours for maintenance or testing when one channel is inoperable and placed in the trip condition. Improved Technical Specification 3.3.4 Action H will permit one channel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours. This is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance. This change is acceptable since the cause of the inoperability, either planned or unplanned, has no difTerent impact to the overall safety.- This change would avoid an unplanned shutdown and associated transient due to an unforscen channelinoperability. This change is consistent with NUREG 1432. L.5 Current Technical Specification Table 3.3 3 provides an exception to the requirements of Specification 3.0.4 for all ESFAS functions except the auxiliary feedwater actuation signal. Improved Technical Specification 3.3.4 makes the LCO 3.0,4 cxception applicable to all functions including the AFAS. This exception may be necessary to permit mode changes in support of required maintenance and testing for an inoperable channel. The ITS effectively CALVERT CLIFFS UNITS 1 & 2 3.3.45 Revision 8
_ .____ __ . _ _ ._. _-__________m.. _ _ _ _ _ _ . . _ . . _ . i I EstA5 Instrsamentatfori
} g gg 8,ein d 6.fMy1.bi p .w.e 3.3.41A.t.tlen (p.e. pp , e.tt. 33 i ,.tew.n tl.n ,
TcMr 33 3 f eeenase. FWuct3. (nue,s asedesseets utu.us tea , . o> .. , in, . ... i...
.. -in - . .i. /
3 .3 33,a
. 3.3.4. ,
en 3.3.4.3
. 3.3.4.4 (de 3.3.4.l.a w -i -tm ,,3.i .
;.;gg ,. i .
4 - c> 3. -.i , ..n,i-im e / t 3.3.4.33. 3.3.4.3 4.4, e-
.. m.i ... 3.3 . 3.3.4.,
- 3. 4.3 3.3.4.4
,i .
- 0) 3. .-.i .. m .i,.i /
i <., 3.3.4., > Os ,4,
.. cm.i, ee . si, i,3.3 . 3.3.4 i eqipeei gre
- 3.3.4 3
' - 3.3.4.4 W 3.3.4 D
- f. A..
c j-
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- 3. -evo... s.i-p
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(.C) Ti,sti. ee. sines a.; ier wtiv vna .ii w. .t.w.@i i.iw wi.iw . i iee .
@) QB CEOG STS 3.3-!! Rev1,04/07/95
- 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."
l
- . -_ _ - - __. . . _ _ - . ._ - _ _ . _ ~ _ . _ ._.
I . I Instrumentation g (cr@ ' 3.3 thSTRtMLATATION 3.3.4 ed safety Features Actuation System (ESFAS) Instrumentation I e Svded clgan i a k g'I'8,g LC0 3.3.4 Four ESFAS(tr er wrim and associated removai t
. OPERA 8LE.
a for each Fuwtlon in Table 3.a.4-1 : n land be y# h_
,h t 5 APPLICA81LITY: MODES 1, 2, and 3.
ACTIONS U
. NOTE-------------------------------- -
Separate Function. Condition entry is allowed for each ESFAS(trifor byAss roer(al) 1 CON 0! TION REQUIRED ACTION CONPLETION TINE f-T T A. One to alnment Spray -
) Actu A.! P1 e affected trip I hour )
-' on Signal it in bypass.
(C ) trip unit ci- Q(, a ociated instrument operable. )
/
1 Place I hour J. o._ _ s .
' - 4 4.OneormoreFunktions y~ with one ESFAS
)orassociatW p ._
in bypass or $ k.111 ( 2rghiisD channel g Qwe mad k kewa T.s "
*fji0Nh'O
- }
h
.t.1 eK6r anne to 48fhours OPERA 8LE status, @
sue - t) ~ 91
.t.2 e f ed $ 48 hours (continued) i CEOG STS 3.3-18 Rev 1, 04/07/95 s.gi t 4
-.,,__-m . _ _ . . e _.mm . , - ~
~. .. . _ - -- ___ - - _. - - . .. _ - . - - - - .__
- DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG.1432 SECTION 3.3- INSTMUMENTATION
- 40. The ESFAS Functions listed in Table 3.3.41 include trip and bypass removal features as appropriate. Referring to trip and bypasa removal features as separate Functions is incorrect and confusing. Removing the words " trip or bypass removal" satisfies the intent of the Note and climinates the error, i
4 6 i i A 1 I i CALVERT CLIFFS UNITS I & 2 3.37 Revision 8
- 29. To resolve NRC comment 3.3.411. 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 unr.ecessarily duplicated.
E
, . , , _ , _ , , , - - , - ----e e"'r-* * '- '" '
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4 Ma r 'l gL Ely a 1
- 6 P
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- 5 p
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; I M
b Vz.E T C L A B A E T R U T A E F M z 7 7 A S r u r sV e h i g w o h i g t h i g
^
D H E R d - L H h S t n a H E E A ) s e er ) s e I C t e P t N n r n r ( u r I G S A o u s u o u B u
, t s t s N s I I t s i t s O n s D S
( u e t ( u e I i e B r . B r T r r P 7 T P A T P N p A p L ( O i t r R i t O t I r n e P r n S S n T C T ( e m i z S T ( e n I I e T E n r T u C m r J l i u N i r T N n N a a s la l i w I u t s E u t a E a n a r . a n n e f n n f n t n t a M o r l l a o l l u o C P A n C A a Aut T N T N r C n c S a b c
. O C a b
. O C
[ ( ia b a r 1 2 3 pN$ ! g* gy g% 5. - ,-
,4 N% 5
. Sf weW.4., 3,3,4 3/4.3 INSThlDitNTATION TABLE 3.3-3(Continued) h 0 % sr. 4(ko v y rg,,,4,, 9,f,r, TABLE NOTATION 4 sad hal
'05 % la,i Ar4nts n un s .
I _ fWhentheRC5temperatureis: ' I y (M.toGreater than the start automatica required SPERA8LE HPSI pumps must be able 385T.lly upon receipt of a $1AS signal. j f(b)Between 5Y. God 345V. a transi ton enists wnere sne OPE HPSI pump will be plac in pu -to-lock on a cool l and stored to automatic st s on a heatup. 4. l4 c) 36l4 and less, the re trod OPERABLE HPS! %gg. - ull-in lock --' will start au+a==tica11v, pump s beind- l j
! The provisions of Specification 3.0.4 are not applicable. hj h Must be OPERABLE only in MODE 6 when the valves are required OPERABLE 5 3y and they are openf r
%henin, g y,
@ Trip function ma be' bypassed in this M00t when pressurizer pressure -
is < 1400 psf as ypass shall be automatically removed when j. pressurizer pressure is 1 1800 psta. y N Tri
@ shaflbeautomaticallyremovedatorabove785 psia.functiek may be by
_~wr n a, 6 I h /9 ,+ 4 n e. % 2,.):bes Jyd l583 ** * (oh.uk frassert.. (a y Timesi M ruere p# tyy n .e4 Hg.sv(A
.A % opfath9 w6 A asum4.J vilA 'id A4 % -N SG4s f hbm nae ( 6 J -AnA da-4 diva 48 4.
I f M h - >e d h.rM g. , CALVERT CLIFFS - UNIT 1 3/4 3 14 " Amendment No. 185 pp L e f Ib
lll!;Iil \l!lI l , h :yI g a* i M , 5- 31' M L 5, ' 3 # j g !* : a
,2 7
.w ,
y g i j
- %. g j k' ' - ,
x t- 31 V+ M@ % 'y . 3. ct c: ,. J~ a e S y@ t E D O M ? 3
=~* 4 a
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_ Evs E L B A T C A EE mMu Lu L E W A 2 2 2 T A TO s T F TF 0
- Y T
E (\ F A h h S g w g hg f o f D q, H L H ,s i E t .
) fS n H U A ) )
- o -
E I I S A s n o mr u us e s n e u e r I ( C 1 1 e r u E I t t s s s t s s N s D S ( u e e ( t u e O . s e B r r B r I T f r r P P T P N p A p A T P O t r L I T i T r en ez R P i r t n O -< S S t n C ( m i S T ( e s I I e T E u r r T e T c m I lU l a f a u N l l r N i n W s E a a i u E a a I t s n e u t T a n o er l n n M t n I R T M C P l A M a o I o - N E T C A C s F N T N A O 6b ob
- a. S c
. . O n.
i (a b C C a . r I 2 3 g g 4** e5[ g t_* { e.,a - Q ,, p 1o%
- _ _ - _ - . - _ ~ _ - _ . - . . . . . - - -. _ -
l
$pos.Fec'c.+,h '3 '5 9-l 1
I 3/4.3 Ilt5ftlBIENTATIM
# I FABLE 3.3 3 (Continued) 4r is.$.h 1.1.S, fABLEN07AT10H * ($F Ag 1 g't. o.) %. d G_ n u a n,.nat m m.'v ~'"'~'"y)
AAMitmi e
}l
~
. When the RCS temperature ist
(.*) Greater than 325T. the required OPERABLE HPSI pimps ausst be able to start automatically upon recets.t _of a $1AS stenal. - kbJBet 9 325 Y and 301T ansition LE MpSI pump will, a placed in pu .to loc nd restored to autama status on a heatup. ton exists to the a cooldown
,14
;h c) At 301Y and less, required OptRABLE N R
t pull.to-lock and 11 not start automa
- Iy. pump f shall be tad 4-M A *$oire I ! ff
^[ The provisions of Specification 3.0.4 are not applicable, n o. . m : = = u u. : u = .... ... m .... - m . m D h Id 3
' C1 and they are open. f 8 1r 'l 3
%A 4e p/ Trip function may be bypassed in this N0DE when pressurizer pressure is < 1800 pstas bypass shall be automatically removed when y&
i p,,4 ,4 , pressurizer pressure is ,t 1800 psta. (d) M Trip function may be bypassed in this N0DE below 785 pstag bypass
- shall be automatically removed at or above 785 psta.
.7,e is.t+iw M yi*I (% Cal 5) r 4-u ., , , , c , , .. . ,- p. , o . c - t ., -
g%, psf Pe% ec / WW 4 "3 *
- f ' ' '
;,. , ...,a 4 e, e se a~ -o i eg.cIwie4 *
- b'8 * **
D #' L-4,, ,,, ,, . i . , a -a e ~ a.
- - , _m- . ,,---
p ,,u ., + - 4, we co d..
*144 5 it c# b ' " ,a ,4...
e _- > a -t '
*s g#s y l' 1 - '
CALVERT CLIFF $ . UNIT 2 3/4 3 14 Amendment No. 178 . s 4
-m % _ _- , --.m~-.. , - . . .,w .- -e- . , - - , .
, - - - =r-- ---,,-,e
DISCUSSION OF CilANGES SECTION 3.3.4 . ESFAS INSTRUMENTATION is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. His change is consistent with NUREG 1432. A.13 Current Technical Speci6caten 3.3.2.1 Action 7.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 7.b requires that within one bour all functional units receiving an input f.om the inoperable channel be placed in the tripped or bypass Condition. Improwd Technical Specification 3.3.4 Condition A requires one or more functions with one ESFAS sensor module or associated measurement channel inoperable be placed in trip or bypass in one hour. The ITS Condition A captures the technical intent of CTS Action 7.a and 7.b by requiring that all affWtod functions take the speciflod actions, therefore, the change is administrative. His change is consistent with NUREO 1432. A.14 Current Technical Specification 3.3.2.1 SlAS Endnote @, Parts (b) and (c) which discuss when the high pressure safety insection pumps have to be to be placed in pull to-lock, are deleted. bee requirements are already speciflod for the HPSI pumps in the ECCS specifications (CTS 0 5.3) De elimination of duplicative requirements within the Technical
- Specifications is an administrative change Charises to the technical requirements are provided 4 in the Discussion of Changes for Section 3.5. his change is consistent with NUREO 1432.
TECHNI"AL CHANGES . MORE RESTRICTIVE M.1 - Current Technical Specification 3.3.2.1 would require the Actions for the functional unit to be followed when a bypass removal channel is inoperable. Improved Technical-Specification 3.3,4 established Actions specifically for when one or two automatic block removal features are inoperable (ITS Actions C and D). De Actions are essentially the same as when one or two sensor modules are inoperable, except that the affected sensor block modules are required to be disabled within one hour. The addition of this new requirement is considared more restrictive. De addition of this requircirent will not adversely affect plant safety because-it add . actions which specifically addresses automatic bypass _ removal-functions. This change is consistent with NUREG 1432. M.2 Current Technical Specification 3.3.2.1 does not have any requirements if an Action cannot be completed within the required Completion Time. Dus, CTS 3.0.3 would haw to be entered. Current Technical Specification 3.0.3 allows 7 hours to reach Mode 3, and 13 hours to reach Mode 4. Improved Technical Specifications added an Action (Action E), when the Required Action and Associated Completion Times cannot be met, to be in Mode 3 in 6 hours, and
- Mode 4 in 12 hours. His change essentially allows one less hour to reach Mode 3, however,-
adequate time i . still allowed to reach Mode 3. Derefore, this change will not adversely affect plant safety. His change is consistent with NUREG 1432. M.3 _ Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additional-inoperable channel to be placed in bypass, improved Technical Specification 3.3.4 Action B will require one sensor module to be placed in trip and one sensor module to be placed in bypass in one hour, his change assentially places a one-hour time limit, where none previously existed, to perform the Actions, his change is, therefore, a more restrictive change, The change will not adversely affect plant safety because_if two channels are inoperable one should be pbced in trip and one placed in bypass in a time'1y man:wr. His - change is consistent with NUREO 1432. CALVERT CLIFFS . UNITS 1 & 2 3.3.4 3 Revision 8
^ ~
DISCUSSION OF CHANGES SECTION 3.3.4 - ESFAS INSTRUMENTATION
- M.4 Current Technical Specification 3.3.2.1 Action i1 for Containment Spray Actuation Signal
~ (CSAS), allows continued operation with one inoperable channel provided the channel is bypassed in one bour, Imp oved Technical Specification 3.3.4 Action A requires an inoperable channel la restored to Operable status within 48 hours or the inoperable channel is placed in ,! trip. His change is more restrictiu. His change will not adversely affect plant safety and provides consistery:y with other ESPAS functim, actions. Other changes to the CSAS actions are described in a separate less restrictive change. His change is consistent with NUREO 1432. TECHNICfL CHANGES - RELOCATIONS None TECIINICAL CHANGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED. DOCUMENTS T LA.1 Not used. l LA.2 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification Table 3.3.4-1 will not contain this column. nis is an informational column which is more appropriate for the Bases. The number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. De Bases Change Control Program will ensure that changes
~
receive appropriate review. This change is a less restrictive movement of details change with no impact on safety. His change is consistent with NUREG-1432. LA.3 Not used. l LA.4 . Current Technical Specification 3.3.2.1 Table 3.3-3 Function 3 (Containment Isolation) Endnote # states that containment isolation of non-essential penetrations is also initiated by SIAS (Manual Trip and Pressurizer Pressure - Low functions). Improved Tecimical Specifications does not contain this footnote, his informational Note is being moved to the Bases. Any changes to the Bases will be controlled via the Bases Change Control Program. He Bases Change Control Program will ensure that any changes to this requirement will be appropriately reviewed. This requirement is not being changed, therefore, plant safety is not impacted. This change is consistent with NUREG-1432. LA.5 Not used. l LA.6 Not used. l TECHNICAL CHANGES - LESS RESTRICTIVE L.1 Current Technical Specification 3.3.2.1 Action 11 allows indefmite operation'when one CSAS channel is inoperable and placed in bypass. The CTS allows 2 channels to be bypassed for up CALVERT CLIFFS - UNITS 1 & 2 3.3.4-4 Revision 8 ua _ _ _ _
- 30. To resolve NRC comment 3.3.4-17, Discussion of Change L.5 was written to justify the exception to LCO 3.0.4 for the Auxiliary Feedwater Actuation System (AFAS) function.
l l
l 9 S brus.,.0 TAB (Continued) y Q cb y, & sp.eA.b y E! 3.13, acycs r.4%., INEERED SAFETY FEAT M E ACTUATION SYSTEM INSTR WENTATI M s.* E _ h FUNCTIONAL UNIT b l ACTION e . CVCS ISOLATION g
- C l
- a. Manual (CVCS Isolation 1 R Valve Control Switches) 1/ Valve 1/ Valve 1/ Valve 1.2.3.4 6'
- b. West Penetration Room / Letdown Heat Exchanger .
Room Pressure - High 4 2 3 1.2.3.4 7*) > , 9. AUXILIARY FEEDWATER ACTUATION gg,
'f SYSTEM (AFAS) y
- a. Manual (Irip Buttons) 2 set . of 2 per 1 set of 2 2 sets of 2 _ 1. 2. 3 63 per S/G X S/G ner $/G /
a, . Steam Generato eyel - Low j { [1, 3 L 5
- c. Steam Generator AP High l 3M '
g,g . E i'. 7-zA.2 3 4 Q
- g so, 0.s. u.- .c c h p u L rs 4 e.L L 3.3.5, T.
? 'u"~ns L,,e ea m.~a
, , 15 ' f h-Y
- n. .'."
h U 5 4
. Sp..&. 4..., 3,3,9 3/4.3 INSTRUMENTATION TABLE 3.b3 (Continued) h 0%s.Hk<vs 4, rgg,, y,7,r, TABLE NOTATION T5% Q"6 Arinim . **d Ma aal n n un s .
I {When the RCS temperature 1st (Ta). toGreater than 385'F.uponthe required CPERABLE HPSI pumps must be able start automatically receipt of a $1AS signal. _ fib)Between 5'F aid 365'F. a transt n region exists where the l OPERAB HPSI pump will be plac in pull-to-lock on a cool and stored to automatic sta s on a heatup. 4,l 4 l hi'jap (c) 365'F and less, the re ull-to-lock and will tred OPERABLE start HPSI automatically. s pump / be ina j l j The provisions of Specification 3.0.4 are not applicable. Must be OPERABLE only in MODE 6 when the valves are required CPERABLE hh h and they are openf S sy M ade. g -g () Trtr function may be bypassed in ttis MODE when pressurizer pressure ~J a 4-is < 1800 psias bypass shall be automatically removed when j'I-pressurizer pressure is t 1800 psia. N Trip function may be bypassed in this MODE below 785 psia; bypass
@ shall be automatically renioved at or above 785 psia.
* ,,, W m.%
/~e<*ni' Onl y . +b Stee. Cu,Lec tL.i h e h d b'"3 6 < m k % sters . L ,a [ f T 6 .i- N fr#W~ %% t%sh <=0 O I'It'"A
.h L otEu%E wh* di suom4 J vilA inbb4 % % SG4 fochen w de J aa 1 de.-%hwhd.
h M h "jd'<d h ,eM jf, g.g CALVERT CLIFFS - UNIT 1 " 3/4 3-14 Amendment No. 185 pp L ef Ib
See G5=a5'io = .F Ct 5 3 Gr 5(*~' F^ m , T W M Catf M 'g g ~3.3.9,"CVCS DE SAFETY FEATutE ACTMTIWLSymn ins minusu in I s. l44. .% S ,.y. [ 4,2 42 c, t ^ { M N * ,J M
. . CYCS ISOULTION w e
- a. Maswal (CVCS Isolation ;g
[ Valve Control Switches) 1/ Valve 1/ Valve 1/ Valve 1.2.3.4 6 ' E
.b. West Penetration i Room / Letdown Heat Exchanger
( Room Pre <<ure MM a 2 3 1,2,3,4 7*j l d b-A. 7[ t R
- 9. AUXILIARY FEEDiet.TER ACTUATION
- A y SYSTEM (AFAS) bN*
O a. Manual (Trip Buttons) 2 sets of 2 per 1 set of 2 2 sets of 2 1. 2. 3 6) : 1 SIC per S/G ser S/G f 4$ Steam Ge jne evel - Low h ' gg
\o
- c. Ste . o rator ,n,,,,
e S 1. 2 m
!i e s~ ne- - o a . q:;p ( t4.2
.s A- t,.
[ .c S p.c.'C,;,4a. 3 3 5, n
] ] " gg EAs L3c --J M- -8
[ t te A T. . g '- _s m . di o [ g - I.'
- - -. . . _ . . . - . .. _- - - . . . - . - .-..- .-- -. .-.-. - ~ -.-
$p e c 8e c'c.+Nm ~T, 3. 4-4 j 3/4.3 INSTRWOffATION TABLE.3.3-3 (Continued) 4,r$( % k 3.1.S, TABLE NOTATION * ($FM t t. e4 80e**l 1
G r u n w .::.v; m w s' ~ "Ad.M%g*
'"<>g
}l
~
. ifhen the RCS temperature ist
(*) Greater than 325T. the required OPERABLE HPSI pumps must be able to start
~
automatically upon receipt of a SIAS stonal, s
- b(i) Bet "325Y i aH 301Y, a ansition region exists re the ,1 0 LE HPSI p op will placed in pull-to-loc a cooldown
- nd restored to automat i 1
status on a heatup. i c) At 301T and less, , required OPERABLE H
-R w,.r rJ pull-to-lock and 11 not start automat ly pump shall be in4/ N
$ f g r'
'[{f ! (The provisions of Specification 3.0.4 are no h
e 1 and.sstheyo.are .==.u = =. m_ ....t appitcable....,..._ .,mo g b,4., .4 e open. f aN+E g- Trip function may be bypassed in this M00E when pressurizer pressure is < 1800 pstas bypass shall be automatically removed when y F 'I y .A'- g , ,4 , pressurint pressure is 11800 psia. (d) M Trip. function may be bypassed in this N00E below 785 psta bypass shall be automatically removed at or above 785 psia.
.p ,, Ne is NO2 key *I(Scal 5) r 4- 4 ,
7 , ,, , , , , m w, c ~ , . . . ,. p. o . c - c.m g o,, j a f Pe % ec / W M 4'*J** k ** ,
-,9 7, ,,,cd +b< oP E Gt A G.t E u L ** a ll c1 e4 ** \ u's
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% ,,,, s.,a -a Q ,
__- _ v- A muu . -
= v - --
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.h ,
CALVERT CLIFFS - UNIT 2 3/4 3-14 Amendment No. 178 e
DISCUSSION OF CHANGES SECTI"N 3 3.4 ESFAS INSTRUMENTATION to two hours, improved Technical Specification 3.3.4 will change the CSAS Actions to be ! consistent with the other ESFAS functions (ITS Actions A and B) which permit one channel to be bypassed or tripped for 48 hours and then either restored or t-ipped, and two channels inoperable for up to 48 hours provided one is tripped and the other bypassed. The 48-hour limitation to bypass a single inoperable channel is discussed in a separate more restrictive j change. The allowance to place a channel in either bypass or trip and the allowance to opew ! for 48 hours with two inoperable channels is less restrictive. He CTS Actions were established prior to manual bypass switches being incorporated, and prior to modifications which require a CSAS coincideat with a SIAS to start the contain nent spray pumps. Rese l modifientions prevent a single failure from causing an inadvertent spraying of containment. r or these reasons, it is acceptable for the CSAS to have the same actions as the other ESFAS functions. L.2 Improved Technical Specification 3 3.4 Table 3.3.41 adds Foo' note (c) to CTS 3.3.2.1 which l allows the Steam Generator Isolation Signal (SGIS) function and the Steam Generator Presrure - Low signals to not bc Operable when all associated valves isolated by the SGIS l function are closed and deactivated. his change is acceptable because, when tlc valves that are isolated by an SGIS are closed and deactivated, the safety function of the SGIS is met and, therefore, is not required. Adding requirements which allow the trip function to not be Operable constitutes a less restrictive change. His change is consistent with NUREG-1432. L.3 Current Technical Specification 4.3.2.1.2 requires the logic for the bypasses to be deaonstrated Operable during the CFF of channels affected by bypass operation. Manually or automatically inserted bypasses allow plant operation under conditions that do not require the respective ESFAS functions, but would result in an unn.:cessary ESFAS actuation if they were not bypassed. He total bypass functions remove these bypasses when the phmt conditions no longer support kilowing the bypasses. Improved Technical Specification SR 3.3.4.3 and SR 3.3.4.4 requires the total bypass function be verified every 24 months. This is consistent with safety analysis assumptions that the automatic bypass removal function operates. The capability to bypass a function when it is not needed is not assumed in safety analyses since it performs no mitigative function. Therefore, this requirement is deleted frou the Technical Specifications. This change is consistent with NUREG-1432. L.4 Current Technical Specification 3.3.2.1 Action 7.c permits a second channel to be placed in bypass for up to 48 hours for maintenancc or testing when one channel is inopera~o le and placed in the trip condition. Improved Technical Specification 3.3.4 Action B will permit one channel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours. This is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance. His change is acceptable since the cause of the inoperability, either planned or unplanned, has no different impact to the overall safety.
- This change would avoid an unplanned shutdown and associated transient due to an unforseen channel inoperability. This change is consistent with NUREG 1432.
L.5 Current Technical Specification Table 3.3-3 provides an exception to the requirements of Specification 3.0.4 for all ESFAS functions except the auxiliary feedwater actuation signal. Improved Technical Specification 3.3.4 makes the LCO 3.0.4 exception applicable to all functions including the AFAS. This exception may be necessary to permit 'inode changes in support of required maintenance and testing for an inoperable channel. The ITS cffectively CALVERT CLIFFS - UNITS I & 2 3.3.4-5 Revision 8
DISCUSSION OF CHANGES SECTION 3.3.4 . ESFAS INSTRUMENTATION limits this exception to the 48 hours specified in the required actions for two inoperable channels. His cwuiition is acceptable since in this configuration, the function is in a one-out- - of-two logic which is capable of providing the actuation function if neces ry to mitigate an event. His change is consistent with NUREG-1431. CALVERT CLIFFS - UNITS 1 & 2 3.3.4-6 Revision 8 '
NO SIGNIFICANT-HA7ARDS CONSIDERATIONS SECTION 3.3 - INSTRUMENTATION 1 l 3J4 Chamme L4 i
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? i The proposed change provides actions when two channels are inoperable for any reason, in addition to maintenance and testing. The allowed outage time for channel inoperability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. The consequences of an event are not affected since the function is already permitted to have two inoperable channels for the same allowed outage time for maintenance and testing activities. Herefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
This change will not phhsically alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The current Technical Specifications already permit a second ESFAS channel to be inoperable for maintenance and testing purposes. The proposed change extends this to any cause of channel inoperability. The failure of a channel is an infrequent event when compared to the frequency of routine maintenance and testing (e.g., channels are tested quarterly). The proposed change does not alter or delete any requirement used to preserve the assumptions in the applicable safety analysis, therefore, the change does not result in a significant reduction in a margin of safety. 3.3.4 Chance L,5
- 1. Does the change involve a significaat increase in the probability or consequences of an accident previously evaluated 7
, ne proposed change provides an exception to LCO 3.0.4 when two AFAS channels are inoperable. The AFAS is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. The consequences of an event a e not affected since the function is already permitted to have two inoperable channels and remains capable of responding to an event if necessary with a one-out-of two logic. Therefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaivated?
This change will not physically alter the plant (no new or different type of equipment will be installed). The changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 3.3-15 Revision 8
NO SIGNIFICANT llAZARDS CONSIDERATIONS SECTION 3.3 - INSTRUMENTATION
- 3. Does this change involve a significant reduction la margin of safety?
The current Technical Specifications already provide an exception to LCO 3.0.4 for all ESFAS functions except AFAS. The proposed change extends this to the AFAS channels. The current specifications already permit two AFAS channels to be inoperable for 48 hours and the allowance of a mode change during this time period has no more significant affeci on safety than for other ESFAS functions which already have this allowance, ne probability of a common mode (silure affecting both remaining channels is low during the limited time period. He proposed change does not alter or delete any requirement used to preserve the assumptions in the applicable safety analysis, therefore, the change does not result in a significant reduction in a margin of safety. 3.33 Channe L1
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change rehises the Mode to which the plant is broug,ht if an Actuation Logic channel is inoperable. Current plant practice would require Action 6 to be entered, which requires the inoperable channel to be restored to Operable status in 48 hours, or the plant is ' brought to Mode 5 within 36 hours. The new requirement would require the plant to be brought to Mode 4 within 12 hours if the channel is not made Operable within 48 hours. Actuation Logic is not an initiator of any analyzed event. Plant safety analyses only credits the Actuation Logic in Modes 1,2, and 3. Once the plant is in Mode 4, it is outside the Modes of Applicability. This change has no affect on plant safety analyses and potentially eliminates an unnecessary transient to Mode 5. The proposed change does not significantly affect initiators or mitigation of anslyzed events, and therefore does not involve a significant increase in the probability or consequences of and accident previously evaluated. 2, Dot (the change create the possibility of a new or different kind of accident from any previously evaluated? The proposed change revises the Mode to which the plant is brought from Mode 5 to Mode 4 if an inoperable Actuation Logic channel cannot be restored to Operable status. The change will not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the prnposed change. The proposed change will not introduce any new accident initiators. Therefore, the changes does not create the possibility of a r.ew or different kind of accident previously evaluated.
.1 Does this change involve a significant reduction in margin of safety?
The proposed change revises the Mode to which the plant is brought from Mode 5 to Mode 4 if an inoperable Actuation Logic channel cannot be restored to Operable status. The safety analyses only credits the Actuation Logic in Modes I,2, and 3, so there is no affect on plant safety analyses. Therefore, the change does not involve a significant reduction in the margin of safety. CALVERT CLIFFS - UNITS 1 & 2 3.3-16 Revision 8 j
.~ 31. To resolve NRC comments 3.3.5-2, 3.3.5 3, 3.3.5 9, and 3.3.5-10, references to CEOG 99 (TSTF-187) are removed and the ITS revised consistent with the- STS. Discussion of- l
- 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.
v
9 ESFAS Logic and Manual Actuation 3.3.5 3.3 INSTRUMENTATION 3.3.5 EngineeredSafetyFeaturesActuationSystem(ESFAS)LogicandManual Actuation LCO 3.3.5 Two ESFAS Manual Actuation or Start channels and .two ESFAS Actuation Logic channels shall be OPERABLE for each ESFAS Function specified in Table 3.3.5-1. APPLICABILITY: According to Table 3.3.5-1. ACTIONS
-------------------------------------NOTE-------------------------------------
- Separate Condition entry is allowed for each ESFAS Function.
CONDITION REQUIRED ACTION COMPLETION TIME A. One Auxiliary A.1 Restore affected AFAS 48 hours Feedwater Actuation manual start channel System (AFAS) Manual and Actuation Logic Start channel or channel to OPERABLE Actuation Logic status. channel inoperable. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 4. 12 hours 1 CALVERT CLIFFS - UNITS 1 & 2 3.3.5-1 Revision /Ul
ESFAS Logic and Manual Actuation 3.3.5 ACTIONS (continued)
. CONDITION REQUIRED ACTION COMPLETION TIME C. One or more Functions C.1 Restore affected 48 hours with one Manual Manual Actuation Actuation .hannel or channel and Actuation Actuation Logic Logic channel to channel inoperable OPERABLE status, except AFAS.
D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time of Condition C g AND , not met for one Manual Actuation 0.2 Be in MODE 5. 36 hours , channel. E. Required Action and E.1 Be in MODE 3. 6 hours associated Completion - Time of Condition C AND not met for one Actuation Logic E.2 Be in Mode 4. 12 hours Channel. 4 CALVERT CLIFFS - UNITS 1 & 2 3.3.5-2 Revision ff S
- ~ - -
ESFAS Logic and Manual Actuation B 3.3.5 BASES-vulnerability of a single failure in the only remaining OPERABLE channel.- 4 B.1 and 8.2 If the Required Action and associated Completion Time of E Condition A cannot be met, the reactor should be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the 'equired plant conditions from full power conditions in an orderly manner and without challenging plant systems. C.d Condition C applies to one Manual Actuation or Actuation Logic channel inoperable for those ESFAS Functions- that must i be OPERABLE-in MODES 1, 2, 3, and 4 (Manual Actuation) 9r MODES 1, 2, and 3 (Actuation Logic channel). Actuatie Logic includes the block-logic modules when the affect block is in effect. The shutdown track imposed by ! Condition D or E requires entry into MODE 4 or 5, respectively, where the LCO does not apply to the affected Functions. i The channel must be restored to OPERAELE status to restore redundancy of the affected Functions. The 48 hour Completion Time is commensurate with the iraportance of avoiding the vulnerability of a single failure in the only remaining OPERABLE channel. D.1 and 0.2 Condition D is entered when the Required Action and S associated Completion Time of Condition C are not met for h 1 CALVERT CLIFFS - UNITS 1 & 2 B 3.3.5-14 Revisiongg _J
ESFAS Logic and Manual Actuation B 3.3.5 BASES one Manual' Actuation channel. If Required Action C.1 for-one Manual Actuation channel cannot be met within the required Ctupletion Time, the plant must be brought _to a MODE _in'which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours to MODE 5 within 36 hours. The allowed Completion-Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without- challenging _ plant systems. ( l L.1 and E.2 Condition E'is entered when the Required Action and associated Completion Time of Condition C are not met for one Actuation Logic channel. -If Required Action C.1 for one g Actuation Logic channel cannot be met within the required Completion Time, the plant must be brought to a MODE-in which the LCO does not apply. To achieve-this status, the plant must be brought to at least MODE;3 within 6 hours to MODE 4 within 12-hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems- . SURVEILLANCE SR 3.3.5.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed every 92 days to ensure the entire Actuation Logic-channel will perform its intended function when needed. Sensor channel tests are addressed in LC0 3.3.4. This SR addresses Actuation Logic tests. CALVERT CLIFFS'-_ UNITS 1 & 2_ B 3.3.5-15 Revision gg
I S eat 8 d 6* 3. '3, $ i i 4 , t 1 ) 1 3/4.3 INSTEMENTATIM j TABLE 3.3-3(Continued) . ACTION STATEMENTS # E **O%fn$ g M0065(OReves.AreReh Nhs.. ' ACTIM 4 qr ( Nusber of Channels, restore thews one 1th1the number of g" ', a' c,, otaOPERAALE chan rable channel to OPERABLE status within 48 hou or in at least NOT STAND 8Y ! Ac.4 m 6,D,Edw Y19..tn,the, m , . . gest 6 hours and in _.2 i ..Z "r.P W 7 y (M p) b At'TI M 7 - , With the number of ersnABLE channels one less than the TotaN t Number of Channels, operation may proceed provided the follow (pg conditions are satisfied:
- s. .The inoperable channel is placed in either the bypassed i
or tripped condition within 1 hour. For the purposes of i testing and maintenance, the Inoperable channel may be bypassed for up to 48 hours from time r3 initial loss of 3 i' OPERABILITY: however, the Inoperable channel shall then be etther restored to OPERABLE status or placed in the l tripped condition. 1-
- b. Within one hour, all functional units receiving an input from the inoperable channel are also placed in the same condition (either bypassed or tripped, as applicable) as that required by a. above for the inoperable channel.
- j. c. The Minimum Channels OPERABLE requirement is mett however, one additional channel may be bypassed for up to j 48 hours while performing tests and maintenance on that j channei provided the other inoperable channel is placed]
in the tripped condition. 7 l IM 8 - witn less snan the Minimum channels vrsansLE. operation) j- 1 continue provided the containment purge valves are maintained
% rinsed. <
'ECTI M 11 - With the number cf OPERABLE Channels one less snan sne Tota Number of Channels. operation may proceed provided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is' demonstrated within 1 hour; one additional channel may be bypassed for up 4
2 to 2 hours for surYelllance testing per Specification 4.3.2.1. f j s~bb~~.4
- u u., o.,
3 7/7, acAs" $ .s ,.*,( M 2.2.f
,5.1M s ys **
, CALVERT CLIFFS - UNIT 1 3/4 3-15 Amendment No. 184 l 4 p.y 6 4 to
1 1 ypy.r.,. o ., r.3 5 i b 3/4.3 INSTElBIENTATION IABLE 3.3 3 (Continued) p nog 4 a g g i ..,,f b- A W, 1
$CTIGESTATINENTS MODE, 5 A 36 heoss bbdv.J*s.
I ACTION 6 - With the number of SpERABLE ' - E e'iie~1ess than the Total 4my s umber of Channels restore the rable channel to s e, GPERABLEstatuswilhin48hou or in at least NOT STANDBY Acnews within the next 6 hours and in.__'l -ZZZ 98- W 04 OiE $"W M E .. l + (ACTION 7 - with the number of OPERABLE channels one less than the Total
. ] Number of Channels, operation any proceed provided the -
foifneconditionsaresatisfi
- 4. -The inoperable channel is placed in either the bypassed or tripped condition within 1 hour. For the purposes of i
testing and maintenance, the inoperable channel may be bypassed for up to 48 hours from time of initial loss of OPERABILITY: however, the inoperable channel shall then be either restored to OptRABLE status or placed in the 4 tripped condition. .
- b. Within one hour. all functional units receiving an input-fron the inoperable channel are also placed in the same 1 condition ither bypassed or tripped, as applicable) as
- that requi by a. above for the inoperati channel,
- c. The Minimum Channels SPERABLE requirement is mett I
however, one additional channel may be bypassed for up to - 48 hours while perfoming tests and maintenance on that ) channel provided the other inoperable channel is placedf the tripped conditio... f
~
ON-4 , With less than the Minimum Channels OPERABLE, operanon may continue provided the containment purge valves are maintained closed. f kiiii 11 - With 1 the number of mansLE cnannels one less than the Totall t
. Nunoer of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and -
the Minimum Channels OPERABLE requirement is demonstrated within 1 hours one additional channel may be bypassed for up to 2 hours for surveillance testing per Specification ( 4.3.2.1y J DeJis. d.-,.fek. % $,J,m g.. f,L, $ C., < he,r. c= C , 3. T 'J, [',, g, c. f, , J ,., %~$ 4, C 4, 5 " EWA $ tre t- <M* % 4 CALVERT CLIFFS - UNIT 2 3/4 3-15 Amendment No. 161 l 4 e sa
, .,e + ----.*--r
DISCUSSION OF CHANGES SECTION 3.3.5 - ESFAS LOGIC AND MANUAL TRIP actions for Techical Specification compliance. In conjunction with the proposed Specification 1.3 " Completion Times, " this Note provides direction consistent with the intent of the existing Actions for the ESFAS instrumentation. This change is consistent with NUREG-1432, A.8 Current Technical Specification 33.2.1 does not specifically list the Actuation Logic for each function. Ilowever, current plant practice would require Action 6 to be entered if an Actuation Logic channel is inoperable, Current Technical Specification Action 6 will require the inoperable channel to be restored to Operable status within 48 hours, or be in Mode 5 within 36 hours. Improved Technical Specification 33.5 will specifically require the Actuation Logic to be Operable, ne Actions when one channel in one or more functions is inoperable is consistent with the CTS. When two or more channels in one or more function are inoperable, LCO 3.03 is required to be entered for both the CTS and ITS. Since the Required Actions are the same for the CTS and ITS, this change is considered administrative. This change is consistent with NUREG 1432. His requirement to be in Mode 4 rather than Mode 5 is addressed in a less restrictive change. A.9 Not used. l A.10 Improved Technical Specification 33.5 contains two Notes which are not included in CTS 4.3.2.1.1. One clarifies tlat Actuation Logic testing shall include verification of the proper relay driver output signal. The second clarifies that relays associated with plant equipment that cannot be operated during plant operation are only required to be tested once per 24 months. These Notes are consistent with current plant practice. This change is consistent with NUREG 1432. A.ll Current Technical Specification 33.5, Table 43-2, Footnote (a) is added to clarify that the high pressure safety injection pumps are only required to start automatically on a SIAS when Reactor Coolant System temperature is > 385*F for Unit 1 and > 325'F for Unit 2. His clarifies an existing requirement. nus, the Note only clarifies what CTS already states. This change is consistent with NUREG-1432, TECHNICAL CHANGES - MORE RFRTRICTIVE M.1 Current Technical Specification 33.2.1 Action 6 requires the unit to be in Mode 3 in 6 hours, and Mode 5 in 36 hours, if an AFAS Manual Trip channel cannot be restored to Operable status within 48 hours. Since the AFAS Manual Actuation channel is required to be Operable in Modes 1,2, and 3,36 hours is allowed to reach Mode 4 instead of Mode 5, because once in Mode 4, the unit is no longer in the Mode of Applicability. Improved Technical Specification 33.5 Action B will decrease the time allowed to reach Mode 4 from 36 hours to 12 hours. The 12 hours allowed to reach Mode 4 is adequate based on operating experience to reach the required plant condition from full power in an orderly manner, and without challenging plant systems. Decreasing Completion Times constitutes a more restrictive change. His change will have not affect on the safe operation of the plant, because enough time is allowed to go to Mode 4 in an orderly manner. This change is consistent with NUREG-1432. M.2 Not used. l CALVERT CLIFFS - UNITS 1 & 2 33.5-2 Revision 8
i l i 4 ESFAS Logic and Manual krJ/(EM 3.3.5
.6 3.3 INSTRUMENTATION '
3.3.5 Ensinaared taf tures Actuation $3 stem (ESFAS) Logic and Manual Qr)) (ApslogD d, ,m__,_._ __ ;.-
,[, ch% er %A 3keyT4
^
LC0 3.3.5
~
,3,4,) ' Two ESFAS Manual andtwoESFASActuationLoicchannels 1( -
~
shall be OPERABLE or wach ESFAS Function specifged in Table 3.3.5-1. APPLICABILITY: . According to Table 3.3.5-1. ACTIONS - SFA
............ N0TE--- - - -----------------..-....-..
Separate Condition entry is allowed for each Function. CONDITION- REQUIRED ACTION COMPLETION TIME 3.3,1.1 .
~ Oda k A. ' On o more'"FunctMn') A.)
, t nf Aux 111ery-g 4 Feedwater Actuation -
Restoreichannel to' OPERABLE status. m, 48 hours hI tog c c n ""#* 5 inoperable,- i "* chnnel **d Ab.k Lose B. equired Action and 6.1 -Be in MODE 3. Ad?'a b 6 hours associated Completion
-Time of Condition A Atl0 not met.
B.2 Be in MODE 4, 2 haurs 3 '3' 2*1 C. One or more Funct ns C.) Restorefeh'annel to 48 hours ' d% with one Manual ( or Actuation Log'c [ aPfDM gpg y g j @
-channel inoperable
'excep F . _ _ c,hannel ..] Achd%
thkabhaab t Lon 4_ (continued) [
-CE06 515 3.3-24 Rev 1, 04/07/95 g.
_. . _ . _ . ._. - . . . _ = .. ESFAS Logic and ManualC[rV(An ACTIONS (continued) CONDITION REWIRED ACTION COMPLETION TIME D.' Required Action and D.1 Be in PODE 3. 6 hours associated Completion Time of Condition C &lg) not me ,
,, .g (r}gg D.2 Be in MODE 5. 36 hours
_dedw c.kwei
?
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 -.--------..-------NOTES-------------------
- 1. Testing of Actuation Logic shall reby Jetter include verification of the proper j g JCoper4 Won optach inithtton rany) h
- 2. Relays associated with plant equ pment that cannot be operated during p ant "# F" operation are only reautred to be hod (
testedlduring h MODE 5 rP [excyding 24 urs unless sted Ldynng the p vious 6 me hs. a @ Perform a CHANNE6 FUNCTIONAL (EST on each 192}' days @ (C,~t b ESFA 1 nnel, e @ l SR 3.3.5.2 Perform a CHA FUNCTIONAL TEST on each onths ESFASManual( channel. e _ Q E. Beqyrst A4,m 4 .c E.1 Se .'. Inoos 1 6 Loen
)
aupv.ded. Com p\dre n s he .4 Conbrbon C nd U Y ( . r& %c e A M nm g f.2 Be m, Ino0E 4, 12 hours CEOC STS , - 3.3-25 Rev 1. 04/07/95 h 1
l ESFAS Logic and Manual Trip h BASES ACTIONS M Ac.; h+ (continued) Condition A applie te one AFAS Manual 8or AFAS ~
- 7. ~
Actuation Logic channel inoperable. It is identical to Condition C for the other ESFAS Functiona, except for the shutdown track taposed by Condition D. ? The channel must be restored to OPERA 8LE status to restore redundancy of the AFAS Function. The 48 hour Completion , Time is commensurate with the taportance of avoiding the 3 vulnerablitty of a single failure in the only renalning OPERA 8LE channel. t L1 and B.2 s e If the Required Action and associated Completion Time of Condition A cannot be met, the re ctor should be brought to . 8 a MODE in which the LC0 does status, the plant must be bro not pply. To achieve this 6 hours and to MODE 4 within t2hhours. to at least MODE 3 within The allowed Completion Times are reasonabl , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems _ - 3
~
U (r% ~.1 A c4 %4 0.,,) .t Mod % ('1 a .:1 3 2 {A.wo.., L9 Con'dttion C applies to one Manual channel inoperable for those ESF n Logi O'*-ei unctinas that must be I Achdt. bpt- h BLE in MODES 1, 2, 3 and 4 a 1 ftfnettonf'sTeenr\ The shut nto M00 wn track imposed by Condition DgequTres 3
~ % d d log c,i ro b lo , affected Functio where the LCO does not apply to the hg 4)y ] .h uks 4t w4eAA t
Thechannel.ustberestoredtoOedAsttstatustorestore redundancy of the affected Functions. The 48 hour hIoch A s,a CNed.
- Completion Time is commensurate with the importance of avoiding the vulnerabtitty of a single failure in the only remaining OPERABLE channel, i
(continued) CEOG STS B 3.3-g7 Rev1,04/07/95 e f d
- . ~ - - , ~ . ~ ~ _ _ _ _ _ _ _ _ . - - - - - - . - . _ . . , _ . - . . _ _ .
v -
-= , _ _ _ _ _
h'I **A 4 m o c), Acia + hen l*3 [c W o Q . i -; LCon)dren" 6 is sabed wles +k%vh4 A d Na..nk sisectak a ,
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d l C. V for ne AdsAr,~L. & CLasel w s t % M Ws W eA S '
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7 [ f T. kte.c An.4 4,w ph e ~<s & 6 W A dl<asf A' Nr, .=4 QepG GrM. thees, (ESFAS Logic and Manual TripU, L' '^ ! w a..-4 c.+4,,ar-> a.n .gew.% -
%e.A 4Le, y<4 eb ba4tbu e a.~ v~ll A A gwr usu.ns <n b .
BASE .4 A p ,,,,, ,, yrksb ,(,H,,,,g ,(d ,,t, g,, j '- Q y# inued)- * * 'Lt O ^*' -
- ~= A 3 Condition D is ente when. 'RequiraT Ac' tion and @
associated Casplet a Time of condition C are not setdf trod Action C. cannot be met within the required I j letion Ties, the plant must be brought to a MODE in -
- whi the LC0 does not apply. To achieve this status, the
- plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are l
onable based on operating experience, to reach the
- ired dant conditions from full power conditions in an .
~o rly manner and without challenging plant systems. '
i' i
- ~
SURVEILLANCE-REQUIREMENTS SR' 3 3 5 1 A CHANNEL FUNC11 A. **I sa l. TEST is pe h reed every 92 days to y l ensure the entire hantel will perform its intended function g when needed. SensorG3bmstemptests are addressed in LC0 3.3.4. This SR adc resses Actuation Logic tests. Actuation Loaic Tes [;1,g 4 5w drea
- d )
' ncludes i i ne s j Actuation signal into subsyfteii)testi1-four each two-out-0 logic in each ISF Function and using a bistable trip fnoun to satisfy logic.) snitiation r ays assoc 1st with sne eft,1
.n m uu G We will then tuate the in idual ESF 3 component -Since each AS Function oys subch nels 'O "g" of Act on Logic, it possible to tuate indi dual ,bl.,klogcp t tc nts without ac atina an enti e ESFAS Function. ag -
- Note : reautres that Actuation Logic tests include operat. ion af an' inttoa7 relays. Note 2 allows deferred at power -
- testing of certalrurelays to allow for the fact that'
/ operating corsain relays during power operatio could cause plant transients or equipment damage. Those 4,,
Ackev4 relays that cannot be tested at power must be testedln -
- ' IAS No. 5, SIAS accordance with Note se include 10; CIAS No. 5 No.-
gg h Thes relays actuate the Iowing components, which cannot be tested at power:
- RCP seal bleedoff isolation valves;
-(continued)
CEOG STS B 3.3 Rev1,04/07/95 - o e
- - ,,+r- r+v--w-
- 32. - ' To resolve NRC comment 3.3.5-4, Discussion of Change LA.2- was revised to reflect the
. movement of Engineered Safety Feature Actw.tlon 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. ' l I l i f
t
, $p,e'.f.I.d.'e 3 . ~5 5
$ ,, J. s . ,u. -. ,, r ,4 3,.3 F.e $p.. F.e +. % 4.3. 7, j 3/4.3 INSTRUMENTATION " < A 5 I
' (,, d. . ,s... .# e L*g s,
. TABLE 4.32.(Continued)
,37,, F-i $~A.t., ~5. 3. 4, w e i.-s ,_ .u.... , - .
Containment isolation of non-essential (Q_ $1AS (functional units 1.a and, 1.c). penetrations is also initiatedM t they be OPEPULE are open only in MODE 6 when the valves are required erE@ ( J T / Free.* e logic days. circuits snati ne mwd =nnily at least once perY\ sn 3.1.r.1 A fv j QB (2) 31AS logic uits A-10 and B.10 shall be tes with th< exception the Safety injection Tank isol on va ves. The $1A . logic c cuits for these valves are exemp d frem ter?ing during oper ons however, these logic circui shall be tested as least o per REFUELING INTERVAL during s down. l I3) SIAS logic circuits A-5, and B- are exempted from testing during operations however, these lo L. k , 2 once per REFUELING INTERY circuits shall be tested at least during shutdown. (4) C15 logic circuits A- and B-5 are exempted from testing ing SR 3.25.) A operation: hoiever hese logic circuits shall be teste t least once per REFUELI INTERVAL during shutdown. p t QS l III SGIS logic cuits A-1 and B-1 are exempted f esting during operatio - owever, these logic circuits shall e tested at least once'p REFUELING INTERVAL during shutdown [ (6) C logic circuits A-3 and B-3 are ex . ted from testing during perations however, these logic cir i s shall be tested at lea once per PEFUELING INTERVAL duri hutdown. l CALVERT CLIFFS - UNif 1 3/4 3-22 Amndment No. 208 MC 4l-0*f0 W
i Se . A a.., T. T. 5
- g. '
4 L 3/4.3-INSTRMENTATIM i 4
<,,4...~..-
< g .. h 4..
.r .L n e.
T.1. *7, TABLE 4.5-2(Continued)
- e g .g .,
- TABLE NOTATI M s e, d....**. .C 6-e i
L "'Eb,.,
- . .F. .s 4. . %As eT.T.9,~ 4
,+ c 4,. *
;. Containment isolation of non-essentfai penetrattont is also initiatD '
1 SIAS (functional units 1.s and Let-Must be OptRABLE only in - - o . sne vaives are required SPERA8 and thav are open. - Frot hwg 1 te circuits shall be tested ranua11y at least aa,a ser
. l dst.s.3.r.t
'5IAS logi rcuits A-10 and B-10 shall 4"test excepti o the safety Injection Tan asiation with the logi rcuits for these valves are
. The SIAS o ted from testing during.
tions however, these 1 ic c uits shall be tested at least e per REFUELI M INTERVAL un 8 shutdown. l I3) $1AS logic circuits A-5 a operations however, thes ogic -5 are exempted from testing during
/
circuits shall be tested at least once per REFUELIM INT AL during shutdown.
- l U) CIS logic circuit operations howe
-5 and 8-5 are exempted from testing dur N 3
. these logic circuits shall be tested least MD4 E once per REFU M INTERVAL during shutdown.
l , (5) SGIS logi circuits A-1 and 8-1 are exempted f esting during
' operat however, these logic circuits she ,
once r REFUELIM INTERVAL during shutd tested at least l (6) logic circuits A-3 and 8-3 are empted from testing during operations however, these logic cults shall be tested at least once per RETUELIM INTERVAL dur ng shutdown. l b CALVERT CLIFFS'- UNIT 2 3/4 3-22 Amendment No. 186 W %%D
\o of W
DISCUSSION OF CHANGES SECTION 3.3.5 - ESFAS LOGIC AND MANUAL TRIP TECHNICAL CHANGES - MOVEMENT OF DETAILS TO LICENSEE-CONTROLLED DOCUMENTS
- LA.1 Current Technical Specification 3.3.2.1 Table 3.3-3 contains a " Channels to Trip" column.
Improved Technical Specification 3.3.5 will not coatain this information. This is an informational column which is more appropriate for the Bases. The number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that changes receive appropriate review. His change is a less restrictive movement of details change with no impact on plant safety. This change is consistent with NUREG 1432. LA.2 Current Technical S,1ecification 3.3.2.1 Table 4.3.2 Endnotes (2) through (6) discuss the l 1 logic circuits that cannot be operated during power operation. Hey are identified as only tested once per 24 months. The circuits and functions which cannot be tested during operation are moved to the Bases for ITS 3.3.5 Note 2 to ITS SR 3.3.5.1 was added which allows logic circuits which cannot be tested during power operations to be tested every 24 months. This change is acceptable since the requirement for testing is retained in the ITS, only description details are moved. Changes to the Bases are controlled in accordance with ITS 5.0 Bases Control Program. This will ensure that any changes to these requirements will be appropriately reviewed. This change moves details out of Technical Specifications and therefore does not impact plant safety. This change is consistent with NUREG 1432, 1 TECIINICAL CIIANGES - LESS RESTRICTIVE L.I Current Technical Specification 3.3.2.1 does not specifically list the Actuation Logic for each function. However, current plant practice would require Action 6 to be entered if an Actuation Logic channel is inoperable. Current Technical Specification Action 6 will require the inoperable channel to be restored to Operable status within 48 hours, or be in Mode 5 within 36 hours. Improved Technical Specification 3.3.5 will specifically require the Actuation Logic to be Operable in Modes 1,2, and 3. Actuation Logic is credited in safety analyses for Modes 1,2, and 3. Therefore, once the plant is in Mode 4, it is outside the Modes of Applicability for Actuation Logic, and there is no need to go to Mode 5. Although changing the Mode requirement for inoperable Actuation Logic from Mode 4 to 3 is less restrictive, it has no impact on safety analyses, and eliminates an unnecessary plant ,- transient to Mode 5. This change is consisteat with NUREG-1432. L.2 Current Technical Specification 3.3.2.1, Table 3.3-3, Functional Unit 9.a, Auxiliary Feedwater Actuation System (AFAS) Manual Trip Buttons, requires two sets of two per 4 steam generator. These trip buttons are physically located on the AFAS sensor cabinets, and requires two of four trip buttons for one steam generator to be actuated to manually actuate the AFW System. There is one trip button per steam generator on each sensor cabinct, thus to manually actuate the AFW System, one trip button on two separate cabinets must be actuated. The ITS will require two channels to be Operable, one channel for AFAS A and one channel for AFAS B. These trip buttons are located on the AFAS logic cabinets. CALVERT CLIFFS - UNITS 1 & 2 33.5 3 Revision 8
- 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,
ESFAS Logic and Manual Actuation 3.3.5 Table 3.3.5-1 (page 1 of 2) Engineered Safety Features Actuation System Actuation Logic and Mar.ual Actuation Applicability 9 FUNCTION APPLICABLE MODES
- 1. Safety Injection Actuation Signal '3 l
- a. Manual Actuation 1,2,3,4 g
- b. Actuation Logic 1,2,3
- 2. Containment Spray Actuation Signal t
- a. Manual Actuation 1,2,3,4 g
- b. Actuation Logic 1,2,3
- 3. Containment Isolation Signal
- a. Manual Actuation 1,2,3,4 g
- b. Actuation Logic 1,2,3
- 4. Steam Generator Isolation Signal
- a. Manual Actuation (MSIV Handswitches and Feed Head 1,2,3,4 Isolation Handswitches)-
- b. Actuation Logic 1,2,3 9
- 5. Containment Sump Recirculation Actuation Signal
- a. Manual Actuation 1,2,3,4 g
- b. Actuation Logic 1,2,3
- 6. Auxiliary Feedwater Actuation System Signal
- a. Manual Start 1,2,3
- b. Actuation Logic 1,2,3 g h
CALVERT CLIFFS - UNITS 1 & 2 3.3.5-4 Revisiongp
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- 9. AUXILIARY FEED 15LTER ACTM TION sysTm (ArAs) t
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- 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 accordingly, i
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#@ *Q Q i b. Containment Radiation - *Q Hfgh Area Monttor 4 2 3 6** 8
- 7. . c.,JM B LOSS OF POWER
, p.n r ,
- h" c. 4.16 ky Emergency Bus 4 ! '3 1
- 1. 2 4 $\ '
UMervoltage (Less of ' 3 Voltage) -
\, q
- b. 4.16 kv Emergency Bus '
Undervoltage (Degraded Yoltage) h /"
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'S ped EcAhr., 773.c, 3/4.3 INSTHNENTATION 3 MkG 4,8-8 (" nth...O -
(ACTION 6'- c. tu . CLv With the number of CPEMBLE channels one less than the Totall
~ Number restore the ino trable channel to of Channelslhin 48 hours or he in at least 4 kM (- 35. J
E4r 4 4.y 4 **8 M OPERA 0LE status wi we NOT STAND within the next 6 hours and in COLD SWTDOWN within the s 4110 wing 30 hours. , ,
ACH90t-f - yllhthen - or v Hiiitti nnele vne le snan the Tot F A c y#,a 4 M - Ihle N[' eMkD g.
.w m.,,s,w e -
The inoperable channel is placed in either the bypassed or trtoped tondition within 1 hour. " er _~ _res et "A""i * A',4 N.w ,w A.l 5
=-n .. . .,.p e .e n. . w . , . . . i _ m t+ i.p.g 4toe,nogg D (.--...-25ErT M N 3'-' T "Ei W hBuis~from' time
>ruuu1Lms however, the inoperable channel shall then of 1 nit'fal Iosi of i g,,, .
be either restored to OPERABLE status or placed in the tripped condition. p i a
- b. Within one . ', all functional its receiving an inp '
from t nopi ble channel a also placed in the : A.] con on(ett, ' bypassed tripped, as appitcab required h. 1. abov. or the inopera'>1e ch el. as *** W O '"5 Ac.m4 8 g wo 5.,*er e Mo
- *p fys. un u eu...ie amenwer -
-..n- - -
_e g , ,. o,,,.s,4 ., gm,..g AA
- lir*UM 48...hours . ___hnnr.Mi one additional channel may be bypassedffer @..sthr"-.Pl.'
up to D.$ (6 prov' ded 3he other inoperable cffannel is plac
,,JJm 44 in Ine trippedtcondition. y,4; ,g T,J ,
9 tq . ACTION 8 - With less than the Minimus Channels OPERABLE, operation stay continue provided the containment purge valves are maintained ( .** closed. n 7, g ,# CACTION11- With the number of OPERA 8LE Channels one less than the tom Humber of Channels, operation may proceed p*ovided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is demonstrated within 1 hours one additional channel may be bypassed for up to 2 hours for surveillance testing per Specification I 4.3.2 1. , (ce thm;,_ f y. G 5goA4.- 5.11) ,
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CALVERT CLIFFS - UNIT 1 3/4 3 15 Amendment No.184 h. h 'Nxr- _ Ac _- - = _ rw! _ _[ b 'N' \ 4 ma Q e * ~
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E L. 4 ,A) 5 J 4 7 Ev a CALVERT CLIFFS - UNIT 2 3/4 3-12 Amendment No. 161 l
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for J . s e. e s s * . .( eke gs c., ....4.., ,. ,. g w c e s 3/4.3 INStalBWITATIM I*T' *"d ' " " *
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1, f 400Eslml:&-(Gen 64aued) Aff885 6 lllth the neuter of 98ClAELE channels one less than the Total 1 Dumber of Channelt metere the inoperesle channel to ! OptRABLE status kilhin 48 hours or se in at least NOT stale 8Y i within the next 6 hours and in COLD SNIITDelAl within the following 30 hours. p '.I d.iMay' ' M is wW '
' 405805 4 Titht r ____E is one Jess than tiuf Totall <i o< *M e an,.- ' ; I Action of i operati procqpi prowldedAfee J 4 ng ens a m afi 7 j' g'8e
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' a. The inoperable channel tv placed in etther the hvnanand h.'icC(..M g opegme ) br::r- r -; e tours fmm time of initial loss of )
j . d'* be either restored_.or, the inoperable channel shall then f w mT .- m
%4-4** to OptRABLE status or placed in the A7 b tripped condition.
U$
'b7 n one , all functi units receivt eninpuT '
rom the i rable chan are also plac n the same conditto either b or tripped, a ppitcable as * ' that utred by a.ypes e for the ino ble channel /) J T
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1 hoursrev1 _d ". W Um other in0p passe c M nne is blaced ) s . .,,. ... (, 1 1ppe@:endition. { With less than the Minimum channils wsusta, operation ( ,, ,, , o g M ' ' "8 '
- 9 '*b p.,
k continue provided the containment purge valves are maintal closed. .I
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or 4 ' w* s 3011 11 With the number er wupistE channels one less than the not
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L. . 4 i.r) - operation may proceed provided the 7 Number of Channels,is placed in the bypassed condition and inoperable channel the Minimum Channels OptRASLE requirement is demonstrated _-h . within 1 hours one additional channel may be bypassed for up to 2 hocrs for surveillance testing per Specification j
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CALVERT CLIFFS . Ull!T 2 3/43-15 Amendment No.161 l N SEfft he'noh3 C Al 8
= _ - -
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- i DISCUSSION OF CHANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER 4
' therefore, the DO LOVS Applicability will now include Mode 4. His constitutes an administrative change. His change does not affect the safe operation of the unit.
? j A.13 Not used. I i A.14 ' Current Technical Specification 3.3.2.1 Action 7.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 7.b requires that within one hour all functional units receiving an input from the inoperable channel be placed in the tripped or : bypass Condition, improved Technical Specification 3.3.6 Condition A requires one or more l 3 functions with one sensor module or associated measurement channel inoperable be placed .
, in trip or bypass in one hour, ne ITS Condition A captures the technical intent of !
CTS Action 7.a and 7.b by requiring tha: all affected functions take the specified actions, -; therefore, die change is administrative. Als change is consistent with NUREO 1432.
- A.15 Current Technical Specification Table 3.3 4 specifies trip setpoints and allowable values for
- l DO loss of voltage i?gnal functions. Improved Technical Specification 3.1.4 Table 3.3.41 i
- only specifies the allowable values for the DO loss of voltage signal functions, ne trip setpoints and allowable values contained in the CTS are identical, therefore, only the !
- allowable values are necessary to be specified for Operability, nis change is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. His change is consistent with NUREG 1432. a i
- A.16 Current Technical Specification 3.3.2.1 does not contain Actions when more than two channels are inoperable, therefore, Specification 3.0.3 would be entered. CTS 3.0.3 provides 4
one hour to correct the condition or a plant shutdown would be required. Improved : Technical Specification 3.3.6 Action C provides one hour to restore all but two DG - Loss of Vohage channels to Operable status if more than two (three or four) channels were . inoperable. The one hour Completion Time is acceptable because it is consistent with the existing Completion Time in CTS 3.0.3 and allows a reasonable time to evaluate and take L action to correct the degraded condition in an orderly manner. He requirements associated
- with a subsequent plant shutdown if two channels are not Operable in 1 hour is addressed in l a separate Less Restrictive Discussion of Change. His change is consistent with--
- NUREG 1432.
! A.17 Current Technical Specification 4.3.2.1.3 requires a response time test for DO LOVS. He " i actual time allowed for t3 oistrumentation portion of the response time is located in the i UFSAR. The actual respuose times were relocated to the UFSAR in a previous license i amendment consistent with NRC generic guidance, ne UFSAR only provides a response + time for the loss of voltage DO LOVS; no response time is provided for the degraded - l voltage DG LOVS. The msponse time in the UFSAR is the same as the maximum ' ! Allowable Value. He ITS maintains the Allowable Value in ITS SR 3.3.6.2. In addition,- ' ITS SR 3.8.1.15 maintains the DO start time portion of the response time test. Therefore, CTS 4.3.2.1.3 is not required to be maintained in the ITS and has been deleted. Since all parts of the current requirement are being maintained in the ITS, this deletion is considered - 3 administrative. '
.~
l i CALVERT CLIFFS e UNITS I & 2 3.3.63 & ision 8 L 3 - w - w - -, ,,wU ,%,- ,~.+.-y,y, .._,,m ,,, . - ,mm,-,---wew----*W+**~
- w-wc--<s--- #w e- ~* - - - - U: =--w-+ v- s"- w ee- - - - -ev-- -t v- '++=e'w- a- '---v-
DISCUSSION OF CilANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER TECIINLCAL CilANGES - MORE HrRTRICTIVE M.1 Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additional inoperable channel to be placed in trip or bypass. Improved Technical Specification 3.3.4 Action D will require one channel to be placed in trip and one channel to be placed in bypass in one hour. His change essentially places a one hour time limit, where none previously existed, to perform the Actions. Als change is, therefore, a more restrictive change. The change will not adversely affect plant safety, because its appropriate for a time limit to be set for placing one channel in bypass and one channel in trip when two channels are inoperable. l His change is consistent with NUREG 1432. M.2 Not used. l TECHNICAL CIIANGES - RELOCATIONS None g TECIINICAL CilANGES . MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification 3.3.6 will not contain this infonnation. This is an informational column which is more appropriate for the Bases. %e number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0, llowever, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that changes to this requirement receive appropriate review, nis change is a less restrictive movement of details change with no impact on plant safety. His change is consistent with NUREG 1432. LA.2 Not used. l LA.3 Not used. l TECIINICAL CHANGES . I.FRS RESTRICTIVE L.I Not used. l L.2 Current Technical Specification 3.3.2.1 does not contain any actions if the Required Actions l cannot be met within the allowed Completion Times. Therefore, Specification 3.0.3 would be entered. improved Technical Specification 3.3.5 adds an Action (Action D), which would require the applicable Condition and Required Actions for the associated DO made inoperable by DO Loss of Voltage instrumentation, to be entered. This change is appropriate because the DO Loss of Voltage instrumentation essentially renders the affected DO incapable of starting automatically, thus the affected DO would be unable to perform it safety function. Entering the applicable Actions of LCO 3.8.1 is appropriate to ensure all l Required Actions for an inoperable DO are completed. It would be imprudent to shut down CALVERT CLIFFS - UNITS 1 & 2 3.3.6-4 Revision 8 c3
- 35. To resolve NRC cornment 3.3.6-4, Discussion of Change L.4 was added to justify placing a second channel in tr!p for reasons other than maintenance and testing. The CTS markup and No Significant llazards Considerations have been updated accordingly, I
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- 7. LOSS OF POWER 6 ,.4 4 E Y - ,
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Spec.Godim,7:3.c, 3/4.3 Iltlit MENTAT!0h 7^.*'_! ! !- ! '"; ,". i...O - (ACTION 6'. 0%. 4 cw With the number of OPERABLE channels one less than the Tota Os17 5w 66,.- us . Number of Channels restore the ino ..a OPERABLE status wtIhtn 48 hours or Nrable channel to* We twas hy 8 within the next 6 hours and in COLD $NUTDOWN within a thein at least NOT $ TAN 0tYj
@ llowing 30 hour
- p ,.,
A0ftelet . jfilh-"inu .. - or vri vwi.E ' ar.d. - isp snan the Tota Number annels, o n may proceeA1frovidad the A 4.re.a bit no en.ctta.. 4 " b ..e t aw-
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t. The Inoperable channel is placed in either the bypassed ## "'$'d***6 w.w,w A.I I or trioned condition with A*"I <t+i. g ( 32 -- r me..... 3.in 1 hour. .u . , wu -- _g _ _ ._._er: e U;re t.3, cA.a h :r" ';; ..,w48 hours from time of initial ;oss of g, g 4, enustg 1 prumsILrT nowever, the inoperable channel shalll then
! gjj,,
be either restored to OPERABLE status or placed in the tripped condttion. p 1 r, all functional 'a (b.b Within one ' from t no erable channel a also placed in the s conO on e ther b its receiving an inpu , g,
'n' + quir(e by a.ypassed
,, aboy tripped, or the as applicabiel inoperable ch as
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""-a'i t ^**"'"t" d : x" I : C_ . <* * *s e#. 4 'a * * $* **** t h.4 *e bi P*AM 48 hours @En;;;, one additionalnachannel m a -- -
may be bypassedffor u.s to _'htasth r"0l*
' ( 6 prov'ced the other inoperable cffannel is plac ,; ,p g e 3 S.
in Ine trippedcondition. ~g,4; ,g hi, ACTION 8 - L q h! With less than the Minimum Channels OPERABLE. operation may continue provided the containment purge valves are maintained [ g* h ,* closed. n y g5.$ ACTI0ll 11 -
- With the number of OPERABLE Channels one less than the Toh Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and
, the Minimum Channels SPERABLE requirement is demonstrated within 1 hours one additional chanael may be bypassed for up to 2 hours for surveillance testing per Specification l 4.3.2.1. , he N w fcb y.G "CwAs z.,ho~*. Seeaf..A. 33 0 CALVERT CLIFFS - UNIT 1 3/43-15 Amendment No.184 h
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+ m ee-erAfe erve ATTles 6 -
Wif.6 the number of OptRABLE channels one less than the Total I restory the inoperaale channel to " 9ptRABLE status wi Ihaber of Channels [hin 48 hours or De in at least 11T STAN _ _ - - vithin the next 6 hours and in COLD MUTDetAl within the fellowins 30 hours. - j(ifeE .'e ke%] e> M6 wW t N. Itth re rsuaskt c 1s one ss than tidTotall wow f Cha si operett prec 3revided>he _J b'oc.em.. aMf '/r'8 8[**'*j #'.4. I 4 ng tions are a tsft : _'86/y,,
- s. The inoperable channel is placed in ettbar the hvnused h.,.e -mu (b .~ t or C._ tet- "2=21. tan within 1 hour. = -" : ---- 9 g opaq m e
_ m ._... 2 'l: tr; nth enx; e.y4e- A.N ( S :::et ' ; SA hours from time of initial loss of . ( Wu* "*
- ers===Itml ..--.ver, the inoperable cha.inel shall then be either restored to OPERA 8Lt sfatus or placed in the
~
tripped condition. A.7 b bIW g (H.) n one . all functie units receivt an input' ' rom the i rable chacae are alf.o plac n the same conditto either b or tripped, a ppitcable)as G " ' 90jb g,g g that utred by a.ypas a _ e for the ino ble channel /J N.,'4,,, .,, 4 4* [/Nt ...."'-* *"nne10-ep5tAthE requi. -..Me 1 met -
, one addittani ekanaal atv be bypassedyor up t 4 "*
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- tippegcondition.
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\ ( ,,g ,,, .,, ., , 5 e h With less than the Mintmum cnannels orERAstr. operation continue provided the containment purge valves are maintai D C'
~- ' ' "' T N cf ~
oc 4 ' w* _2 4.i ION 11 - W1th the e=^ r or vrt _ 'l cnannels one less than the #- t Ih operation any proceed provided the
, 7 Nuber inoperableofchannel Channels,is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is demonstrated within 1 hours one additions) channel may be bypassed for y to 2 hours for surveillance testing per Specification I
j sa . - .. . . . ~ . . . , fr 'i pa c.C', , t , . o a_ ..- .c . Y.S 2, p ., e Sp . f, ,,, 4 , ,, ,, 3 . ~f. ~7, "BMA$ k yt e n e . 4. so.
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CALVERT CLIFFS . UNIT 2 3/4 3 15 Amendment No. 161 l G~arril Aorica c ('. dERT d, , Al h _ L.g ry 4 .c s
4 DISCUSSION OF CHANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER when the Actions entered for inoperable DG(s) may allow continued Operation. His would prevent an unnecessary plant shutdown. His change is consistent with NUREG 1432. L.3 Not used. l L.4 Current Technical Specification 3.3.2.1 Action 7.c permits a second channel to be placed in bypass for up to 48 hours for maintenance or testing when one channel is inoperable and placed in the trip condition. improved Technical Specification 3.3.6 Action B will permit one channel to be placed in trip and one channel to be placed in bypass in one hour and require one channel be restored in 48 hours. This is equivalent to the CTS, however, the ITS does not restrict the condition to testing and maintenance, nis change is acceptable since the cause of the Inoperability, either planned or unplanned, has no different impact to the overall safety. This clange would avoid an unplanned shutdown and associated transient due to an unforeseen channel inoperability. This change is consistent with NUREG 1432. r CALVERT CLIFFS - UNITS 1 & 2 3.3.6-5 Revision 8 s
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTIC..' 3.3 - INSTRUMENTATION accident initiators. Herefore, the change does not create the possibility of a new or diffrrent kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction le margin of safety?
He proposed change replaces the requirement to enter LCO 3.0.3 when the Required Actions l cannot be met within their Completion Times, with a requirement to enter the Required Actions for the associated DG made inoperable by the DO LOVS instrumentation. Entering the applicable Actions of the inoperable DO is appropriate to ensure that all Required Actions for an inoperable DO are completed because the DO is inoperable when the instrumentation which automatically starts the DG is inoperable. Requiring a plant shutdown is overly restrictive and may cause a plant upset, because a plant shutdown is a transient that challenges safety systems. Thus, this change will prevent a plant shutdown by requiring entry into the DO Specifications. Therefore, the change does not involve a significant reduction in a margin of safety. J.3.6 Chanoe L3 , Not used. l 3.3.6 Chance L.4 I. Does the change involve a significant increase la the probability or consequences of an accident previously evaluated? The proposed change provides actions when two channels are inoperable for any reason, in addition to maintenance and testing. The allowed outage time for channel inoperability is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected, ne consequences of an event are not affected since the function is already permitted to have two inoperable channels for the same allowed outage time for maintenance and testing activities. Therefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
His change will not physically alter the plant (no new or different type of equipment will be installed). He changes in methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The current Technical Specifications already permit a second DG loss of voltage channel to be inoperable for maintenance and testing purposes. The proposed change extends this to any cause of channel inoperability, ne failure of a channel is an infrequent event when compared to the frequency of routine maintenance and testing (e.g., channels are tested quarterly). The proposed change does not alter or delete any requirement used to preserve the assumptions in the applicable safety analysis, therefore, the change does not result in a significant reduction in a margin of safety. CALVERT CLIFFS - UNITS 1 & 2 3.3 19 Revision 8
. , . . _ . - - - , , . _ . . - ,., ~c..
5pedE'<2h 'f.3.G. i 4 i 3/4.3 INSTRWENTATIM 1
-- I I I ' $ ~.N .....) -
t u ,{ CL + i (ACTIM6'- WIth the number of SPERABLE channels one less than the Totall Number of Channels restore the ino 4 Saubb by4 . 8us*~. J OPERABLE status within 48 hours or Nrable channel to%s i within the next 4 hours and in COLS $NTDOW within thein W at least NOT STANDIYj i s 4 1
@ lowing 30 hours. , ,
A0V 3 0t t - iTfDiTns u or vri-5.^i. - Number annels, op I ... irse snan the Tota n may proceeAfrovfdad iha A t.rs.e liait no randttinne ea+ 1e rt od r ou
- b% N.
A '
- s
- g. .The inoperable channel is placed in either the bypassed *k'"' " * ' 5' 4 *4 au n w" A e <4 i
or---~m..... tripped condition wi, thin 1 hour. T ' k i.y. w
*t. 4-o. .w . , . -- .. m (te 1
fa,3fwM ,,,u,gg (IE5h:S ti. .. na48.hi[urs'from' crtansILavig nowever, the inoperable channel shall then time of initial '\ ioss'of , i
'gjj,,
be either restored to OPERABLE status or placed in the tripped condition. p 1 l r, all functional *\ I. Q Within from tone noperable channel a also placed in the s con on (either b its receiving an inp ' g tripped, as applicab or the inoperable ch el.as) L- required by a.ypassed abov 4 ** ' W I'* M
- J
- Actrh4 8 ou,'wo weee ei.4As g yk. m ' - e'.---ie amraa m. e zt-g n n _
, ,io,,gs.4 ..sm,.4
'- .- 7, one additional channel may be bypassedffor up to L'htasih. FM AA *e btr*seJ 48 hours ;. . ; n n._
XM prev' ded (,M,Mi _'3 S.4 in tne trippe# condition. ;he other inoperable cffanne1{1s plac p,dia .i14 ~ ' t,q 4 ; [ ACTI M 8 - With less than the Minimum Channels OPERA 8LE. operation may t continue provided the containment purge valves are maintained I h*- n 7, g,g.< closed.
- ACTI M 11 -
l With the number of OPERABLE Channels one lesc than the tom operation may proceed provided the Number inoperable channel of Channels,is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is demonstrated within 1 hours one additional channel may be bypassed for up
- to 2 hours for surveillance testing per Spectfication 4.3.2.1. ,
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CALVERT CLIFFS - UNIT 1 3/4 3 15 Amendment No. 184 h 4 ha' _ E<% $ c I
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- . m . 3. . . v . . a d'I Affl0E 6 -
With the number of OptRABLE channels one less than the Total l Ihaaber of Channels restore the inopera51e channel to OptRABLE status wilhta 48 hours or te in at least 30T STAISOY wtthin fo11ovins the M next 6 hours- and in Cett SEUT80lAl vithin the hours. jro -_- '
~br.%i.',ke%N 46 wut
'1AST8016 I th t' ^ number e LE
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1s one I Action of Cha s.' operati s than tidTotall J' meMf *r 4 j(swingc tions are aft : proc providedAfie _) 4 8[*j,hd .. l 4. ,yv,W
- a. The inoperable channel is placed in either the broanted h=wCt.. ,t or tri w w itian w thin 3 hour. = 2; r -- 9
.e C : --- - .
W ': ;;.th ": .:.3 is.y-be- A*@ j % opagcu,s tr::9 'r ; ';: murs from; time of initial loss of t *. 4 " w - "* wrs==='Emg . __..er, the inoperthle channel shall then
~- " be either restored to OPERABLE status or placed in the tripped condition. A7
- b. W n one , a11 functie g @b rom the i units receivt an inpuf '
. rable channa are also plac
- n the same 1conditto either b or tripped, a pplicable) as G' --'O' q.7,g g (that utred by a.ypas a e for the ino
, ble channel /) N a .,", .4
' (masa-a-7*gg} g g g g ge 4. v. -se.
one additional ehmaa=1 may be byptssed er up e . e ' - '. *' g*=cW ' :-,.. hours
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a
==
-u prWilled'tWif5 r fE6ptfavId trippe(gcondition.
( ( channe ,u , ,, ,, , p,, _1 {s bl eced With less than the Minimum channels vrsanskt. opeiration W' /
- T D continue provided the containment purge valves are maintal ~
~
closed. ~ 4
,i s
1911 11 With the r_r;r of vrt-f=" channels one 1ess than .A thei w .'~ot%
. ,#h (~or d ' w Ilumber of Channels, operation may proceed provided the 7 inoperable channel is olaced in the bypassed condition and - h.
the Minimum Channels SPERABLE requirement is demonstrated within 1 hours one additional channel may be bypassed for uo to 2 hours for surveillance testing per Specification f
< .a . _ . . . . . m . ,.s f*/ Tp ecA .t. , . , , . _ . . . . .%
4 T.'E 2, pe Tp , . . f. e. 4. ., 3 . 3. ~7, "EU A $ l d , ,, i .1 .
"C N CALVERT CL!rrs . llMgt g 3743,3$
Amendment No. 161 l
^JMh Af73pNI C AJ
, N SE RT Ac,,og g A O
DISCUSSION OF CHANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER therefore, the DO LOVS Applicability will now include Mode 4. His constitutes an administrative change. His change does not affect the safe operatics of the unit. A.13 hot used. A.14 Current Technical Specification 3.3.2.1 Action 7.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 7.b requires that within one hour all l functional units receiving an input from the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 3.3.6 Condition A requires one or more functions with one sensor module or associated measurement channel inoperable be placed in trip or bypass in one hour. The ITS Condition A captures the technical intent of CTS Action 7.a and 7.b by requiring that all affected functions take the specified actions, therefore, the change is administrative. His change is consistent with NUREG 1432. I A.15 Current Technical Spec 8fication Table 3.3 4 specifies trip setpoints and allowable values for DO loss of voltage signal ftmetions. Improved Technical Specification 3.3.4 Table 3.3.41 only specifies the allowable values for the DO loss of voltage signsi functions, ne trip setpoints and allowable values contained in the CTS are identical, therefore, only the allowable values are necessary to be specified for Operability, nis change is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. This change la consistent with NUREG 1432. A.16 Current Technical Specification 3.3.2.1 does not contain Actions when more than two channels are inoperable, therefore, Specification 3.0.3 would be entered. CTS 3.0.3 provides one hour to correct the condition or a plant shutdown would be required, improved Technical Specification 3.3.6 Action C provides one hour to restore all but two DO - Loss of Voltage channels to Operable status if more than two (three or four) channels were inoperable. The one hour Completion Time is acceptable because it is consistent with the existing Completion Time in CTS 3.0.3 and allows a reasonable time to evaluate and take action to correct the degraded condition in an orderly manner. He requirements associated with a subsequent plant shutdown if two channels are not Operable in I hour is addressed in a separate Less Restrictive Discussion of Change. This change is consistent with NUREG 1432. A.17 Current Technical Specification 4.3.2.1.3 requires a response time test for DO LOVS. He actual time allowed for the instrumentation portion of the response time is located in the UFSAR. The actual response times were relocated to the UFSAR in a previous license amendment consistent with NRC generic guidance. The UFSAR only provides a response time for the loss of voltage DO LOVS; no response time is provided for the degraded voltage DG-LOVS. The response time in the UFSAR is the same as the maximum Allowable Value. De ITS maintains the Allowable Value in ITS SR 3.3.6.2. In addition, ITS SR 3.8.1.15 maintains the DO start time portion of the response time test. Therefore, CTS 4.3.2.1.3 is not required to be maintained in the ITS and has been deleted. Since all parts of the current requirement are being maintained in the ITS, this deletion is censidered administrative. CALVERT CLIFFS - UNITS 1 & 2 3.3.6-3 Revision 8
DISCUSSION OF CIIANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER I TECIINICAL CIIANGES - MORE RFMTRICTIVS M.1 Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additionnl 1 operable channel to be placed in trip or 'oypass, improved Technical Specification 3.3.4 Action B will require one channel to be placed in trip and one channel to be placed in bypass in ont hour. Als change essentially places a one hout time limit, where none previously existed, to perform the Acticns. His change is, therefore, a more restrictive change. He change will not adversely affect plar t safety, because its appropriate for a time limit to be set for placing one chaniel in bypass and one channel in trip when two channels are inoperable. His change is consistent with NUREG 1432. M.2 Not used. I l TECIINICAL CIIANGES - RELOCATIONS None TECHNICAL CHANGES MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS 3 LA.1 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification 3.3.6 will not ccealn this information. This is an informational column which is more appropriate for the Bases. He number of channels to trip will not be changed. He information is being moved to the Bases intact. Any ch nges to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. 110 wever, any hardware change to the number of chann"Is to trip will require a design change. He Bases Change Control Program will ' ensure that changes to this requirement receive appropriate review. This change is a less restrictive movement of details change with no impact on plant safety. His change is consistent with NUREG 1432. LA.2 No: used. l LA.3 Not used. l TECIINICAL CIIANGES - LESS RESTRICTIVE L,1 Not used. l L.2 Current Technical Specification 3.3.2.1 does not contain any actions if the Required Actions l carmot be met within the allowed Completion Times. Therefore, Specification 3.0.3 would be entered. Improved Technical Specification 3.3.6 adds an. Action (Action D), which would require the applicable Condition and Required Actions for the associated DG made inoperable by DG. Loss of Voltage instrumentation, to be entered. This change is appropriate because the DG. Loss of Voltage instrumentation essentially renders the affected DO incapable of starting automatically, thus the affected DG wou!? be unable to perform it safety function. Entering the applicable Actions of LCO 3.8.1 is appropriate to ensure all l Required Actions for an inoperable DG are completed. It would be imprudent to shut down CALVERT CdFFS - UNITS 1 & 2 3.3.6 4 Revision 8
t DG-LOVS M @ J.3.6 ACTIONS (continued) 4 CONDITION REQUIRED ACTION COMPLETION TINC B. One er Functions 3.1 with two hannels per Enterahlicable I hour
- OG inopera e. Condittens and l Required Actions for ,
the associated OG WeM ! (fy[ *# or assocMed instruentation. I 31.2.1 "" W * 'aY g A s m a 7.c d**88 I$ __ f B,2.1 -
-NOTE- - a .
LC0 3.0.4 is not
' app 1tc6ble.
-, ~~'
Place onMsGib in (#M & other 1 hour g
~
a s i B.2.2 44 ours o, m ed dle sad
.. Restoreone%hannek. q,,g+ej to OPERABLE status -
geqg,g4+
/ Nf k C. One or Functions C.! Restore
\31sIf with more than two two I hour '
ichannels inoperable. (channels status. WtP RABLE k'f"5"**d#g'5""g Pygtd mesortment @ D. Required Action and
/* 33 associated Completion line not met.
0.1 Enter appitcable Conditions and lanedtately 8 h.1,) st Required Actions for the associated DG made tioperable by DG-LOVS instrumentation. b I l CEOG STS 3.3-28 Rev 1. 04/07/95 . a
*!*$ 17.
e
36. To resolve NRC coenmeat 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. l i __ i -
~
5(ed(uM6 73.6. 3/4.3 Ilt$TRUMENTAT10ll
'Y^."*.! ! .!- ! 'C; .t ',;. 4 -
(ACTION 6'- te N %... 1 c w With the number of OPERABLE channels one less than the TotaIl 4 5wW MS . Number of Channels restore the ino trable channel to %S t.yia ..a wJ OPERABLE status wi hin 48 hours or e in at least NOT STAN0tYj We within the next 6 hours and in COLO $NUTDOWII within the s e llowing 30 hours. , ACTHel-P - SITim - of vanis- sr.r.eis vns snan the Tota A crew 4 h - d [ M o "e k h - f ' *^ " t *MkMT
- g. The inoperable channel is placed in either the bypassed **'5'd ..%.,,, a,w or trtoped condit *k""' ='io New%e Ail y -- y m. ion within
...,.1yhour.
t u b c),. J r d ";m5i48' hours from' time of initial loss of e.em.mn rr m ,u.n_f5:y.-W , t.ar.= w 4 ,m,gg E tuAsILaIT nowever, the inoperable channel shall then i 4 ,w be either restored to OPERABLE status or placed in the
' a- tripped condition. p t
- b. Within one r, all functional '\.
from t its receivin (A ,1 j no erable channel a also placec n g+he ans inpu' l con on(etherb required by a.ypassed tripped, as app 1tca as aboyf or the inoperable ch 1. da' " W' E' h'"
- AcM64 8 4 wo ws** eoM S (Tu m '_- au- .1mm : 7.t S 1;;; ,, . ..gs.4 . .w .)
_bir*8 h a8 hoursh:=;;r, one additional channel may be bypassed /for up to 4ta'lt 8 NM prov ded the other inoperable cffannel is plac
,L.if.6' in tne tripped} condition, i g,,g; yA,a L '
ACTION 8 - With less than the Minimus Channels OPERABLE operation may continue provided the containment purge valves are maintained n7,.Qcg',.),g closed. CACTI 0li With 11 the - number of OPERABLE Channels one less than the ToD Number of Channels, operation may proceed provided the inoperable channel is laced in the bypassed condition and the Mintuun Channels 0 ERA 8LE requirement is demonstrated within 1 hours one additional channel may be b passed for up to 2 hours for surveillance testing per Specif cation I 4.3.2.1. , (ce bw; f CL$w C. 5ceu f..J.,. nq ,\
"CvAs 4 %Gk". l CALVERT CLIFFS - UNIT 1 3/43-15 Amendment No. 184 [
f Ch4W&@ n,a p
% g , .'. f. .. l . o % 3 . I . G y ,, .l . u. . u . .e , .I cb ges f ,,, < p ,. h 4. m 't.~5. Q "F5C65 3/4.3 INSTRUMENTAT!M I 9 ' ""' " " "
~ ' i'
, l 4ABLE4,3-3-{ Cont 4aved)
-60fHlf-ffAftMtifff*
ACTION 6 - Number With theofnumber of OPERABLE channels one less than the Total I Channels, restore the inopereele channel to b'I OPERABLE status within 48 hours%6: within the 30 following next 6 hours and hours. - in COLD $NUTDOWN within the ~ or be.e JA in at least NO
, ora uu..-
*ACT445-7. - M th umber ruoustE c els one ss than the'Totall i ' NM8
- r' I Aepou N of Chan s. operetto may proc provided 4 e 4 Ing c ens are sj(tsft : -
_J 4 8y,'{'h A... f /3. pu,n
- a. The inoperable channel is placed in ettie a the bynassed
~
A Corr.i tefanad enndtuton within I hour. = t r r --- 9 h.o--CL. .e -. - i n .......;O th: h :;; reb 1: : c r.;; s y-tie- A*@ ( 4 oDERmw byoassed 6 upv4B hours from time of initial loss of ( C a4 e - 'b vrtusIL&ITg newever, the inoperable channel shall then
"^ be either restored to CPERABLE sfatus or placed in the A7 tripped condition.
b7W n one all functio units receivt an input ' rom the i ble channe are also place n the same = condittop ther b or tripped, a pplicable)as G *' V0b ' that tequ d by a.ypas e for the inop able channeln,-,,'4,,, / _) ACrioN (3 a
., -4 7
' h~ ~ [/The-Matsum-Channels-4PERABLf requirement-is 4*** met S"'
L; ;.g. one additional channel may be bypassed [or up t - *d*'a 4 hours (' ' - W' * " ' d 4e.Seriorskg-4ests-and m ar n-m _- mt
~
.**.++ i
~ - ^" prov ded'the 6theF'Th@hrIUle Eharine is laced /,4......s n etrippeQcondition.
( ,,,.g p., { With less than the Minimum channels Or[usLt. operation @"__ '# 1' shcontinueCb prov closed. u
~
orirer-(dCTIN11- With the number or or[usLE channels one less than1the"b Number of Channels, operation may proceed provided the o-7 inoperable channel is placed in the bypassed condition and h/4 the Minimum Channels OrtRABLE requirement is demonstrated within 1 hours one additional channel may be bypassed for yp to 2 hours for surveillance testtrg per Spectitcation j
< .a . - . . . . . ~ . . , . ,
f ., T p.< .c; .b.
, a. _ . . ... .c n. ,
T. '4. 2 , g ., e 57 ...c,e.4. 3. T. ~7,
^%FAS I 4 < .. J .s. "C W
\
CALVERT CLIFF 3 - UNIT 2 3/4 3 15 Amendment No. 161 l NWR1 A R 6otQ C All 8
,NSERT Ac isow O L'l 5
p a$ t* k ON
l DISCUSSION OF CilANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER therefore, the DO LOVS Applicability will now include Mode 4. His constitutes an administrative change. Als change does not affect the safe operation of the unit.
)
A.13 Not used. A.14 - Current Technical Specification 3.3.2.1 Action 7.a requires that an inoperable channel be 1 placed in trip or bypass within one hour. Action 7.b requires that within one hour all functional units receiving an input from the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 3.3.6 Condition A requires one or more functions with one sensor module or associated measurement channel inoperable be placed in trip or bypass in one hour, ne ITS Condition A captures the technical intent of CTS Action 7.a and 7 b by requiring that all affected functions take the specified actions, therefore, the change is administrative. This change is consistent with NUREG 1432. A.15 Current Technical Specification Table 3.3-4 specifies trip setpoints and allowable values or DO loss of voltage signal functions, improved Technical Specification 3.3.4 Table 3.3.4 . only specifies the allowable values for the DG loss of voltage signal functions. He trip setpoints and allowable values contained in the CTS are identical, therefore, only the allowable values are necessary to be specified for Operability. This change is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. This change is consistent with NUREG-1432. A.16 Current Technical Specification 3.3.2.1 does not contsin Actions when more than two channels are inoperable, therefore, Specification 3.0.3 would be entered. CTS 3.0.3 provides one hour to correct the condition or a plant shutdown would be required. Improved Technical Specification 3.3.6 Action C provides one hour to restore all but two DG Loss of Voltage channels to Operable status if more than two (three or four) channels were inoperable. He one-hour Completion Time is ecceptable because it is consistent with the existing Completion Time in CTS 3.0.3 and allows a reasonable time to esaluate and take action to correct the degraded condition in an orderly manner, ne requirements associated with a subsequent plant shutdown if two channels are not Operable in I hour is addressed in a separate Less Restrictive Discussion of Change, nis change is consistent with NUREG 1432. A.17 Current Technical Specification 4.3.2.1.3 requires a response time test for DG LOVS. The actual time allowed for the instrumentation portion of the response time is located in the UFSAR. The actual response times were relocated to the UFSAR in a previous license amendment consistent with NRC generic guidance. The UFSAR only provides a response time for the loss of voltage DO LOVS; no response time is provided for the degraded voltage DG-LOVS, ne response time in the UFSAR is the same as the maximum Allowable Value. The ITS maintains the Allowable Value in ITS SR 3.3.6.2. In addition, ITS SR 3.8.1.15 maintains the DG start time portion of the response time test. Therefore, CTS 4.3.2.1.3 is not required to be maintained in the ITS and has been deleted. Since all parts of the current requirement are being maintained in the ITS, this deletion is considered administrative. i CALVERT CLIFFS - UNITS 1 & 2 3.3.6-3 Revision 8
DISCUSSION OF CilANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER TECllNICAL CIIANGES - MORE RESTRICTIVE M.1 Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additional 1 inoperable channel to be placed in trip or bypass. Improved Technical Specification 3.3.4 l Action D will require one channel to be placed in trip and one channel to be placed in bypass in one hour, nis change essentially places a one hour time limit, where none previously existed, to perform the Actions. This change is, therefore, a more restrictive change. He change will not adversely afTect plant safety, because its appropriate for a time limit to be set for placing one channel in bypass and one channel in trip when two channels are inoperable. His change is consistent with NUREG 1432. M.2 Not u'.:d. l TECIINICAL CIIANGES - REI OCATIONfi None TECilNICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification 3.3.6 will not contain this information. This is an informational column which is more appropriate for the Bases. The number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. Ilowever, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that changes to this requirement receive appropriate review. This change is a less restrictive movement of details change with no impact on plant saiety. His change is consistent with NUREG 1432. LA.2 Not used. l LA.3 Not used. l TECIINICAL CIIANGES - I ESS RESTRICTIVE L.1 Not used. l L.2 Current Technical Specification 3.3.2.1 does not contain any actions if the Required Actions l cannot be met within the allowed Completion Times. Therefore, Specification 3.0.3 would be entered. Improved Technical Specification 3.3.6 adds an Action (Action D), which would require the applicable Condition and Required Actions for the associated DG made inoperable by DG Loss of Voltage instrumentation, to be entered. This change is appropriate because the DG Loss of Voltage instrumentation essentially renders the afTected DG incapable of starting automatically, thus the affected DG would be unable to perform it safety function. Entering the applicable Actions of LCO 3.8.1 is appropriate to ensure all l Required Actions for an inoperable DG are completed. it would be imprudent to shut down CALVERT CLIFFS - UNITS 1 & 2 3.3.6-4 Revision 8
3 7.- 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 te 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.- h L t i 1 0
..m~m..:...-- -. . . . , . , ,_. ~ ,. - _ - , .e,-, e.. - , .- , , - - _ , . ,
DG-LOVS 3.3.6 { ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME g D. Required Action and D.1 Enter applicable Immediately associated Completion Conditions uno Time not met. Required Actions for - h the associated DG =' n de inoperable by ' D6-LOVS
- instrumeistation.
\ SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3 SR 3.3.6.1 Pet fonn CHANNEL FUNCTIONAL TEST. 92 days SR 3.3.6.2 Perform CHANNEL CALIBRATION with setpoint 24 months Allowable. ' alues as follows: _ 1. Degraded Voltage Function 2 3603 V and s 3653 V Time Delay: 2 7.6 seconds and g s 8.4 seconds at 3628 V; ct:d
- 2. Loss of voltage Function 2 2345 V and s 2555 V Time Delay: 2 1.8 seconds and E=
s 2.2 seconds at 2450 V. r CALVERT CLIFFS - UNITS 1 & 2 3.3.6-3 Revision 0 m ,,
- $p,eir +. w "'I. ~5. 4 g'
%,T m .c _.aun.-. ...,,-,w - _d _
.i .... . g. . , no (,, .g.,
t% .s is, i 4. p r ,s ... ...A r.o , . y . ,. s., i, a
)
-l v.....
. ~ + eu ...n p.e oc. r., +<._Oy,Ms',%<Lho. '
- x' i . .
' g' A - Q n ! } i. '.c ,
C8 -i
- - : '5. ~5 ~ ~
4/4.a. INsTaNN GTATION ~
"~
Oie w t C., .. 4.,. Coc,'
~% ~f. 4 e/(. .: _ .sner- rs .. ; 1 -- ---)- L.y .r: v(t
- ---- -nou y %,4 6.og LIMITING C0WITIM Fet OPERATIM it I" C 4.i.i.a ins angr.x s zare
% s. 6 linstnmentation channels and ree w n actuan on system (ESFA5 ~
' sses skwn in Table 3.3-3 ska 1 be OPERABLE the Trip Setpoint with column their tripofsetpo Tablents set consistent with the values shown in 3.3-4. ! g __ APPLICARILITY: L AC.uptle-
*st.'ridh!.!5.=kooEs-( hg k I-With a m
instrumentation c 1 tri set int les t conse ive than the value in the 1 of la Va column e 3.3-4. declare t channel i
- i. I icable ACTIM requ restored to ti'ERAll atus with che trip se rable end nt of Table .3-3 unt tadjusted the hannel i .h Donsistentwith Trio setootnt wa h L
l-
- s. . ~
't . .r '7 QE'L"Me'i'PI"'$""" '"'""' '#*: . ~- MO 'rt"
"" "* **t2~ . O Ag,, ,44c, ,, g g , p , , ,,,, , c, ,, ,, ,
g,4 , y ;, , 4, , ,,,, SURVEILLANCE REQUIRENENTs rc , . t, r .a. , i i 2 5 R. 3.~N S. ) ' " 0.1.1- Each@Ja,,, ws instrumentation channel shall be de'monstrated A.3 ' st.3.3.6.~J.- SPERABLE by the performance of the'thiANNE4-4Nf616. CNAMEL CALIBRATIM and CNANNEL FMCTIONAL TEST - rt'"-' "*H siw., ... '-t'- ' '
- tha ' "' iM it th '-- c---'t- ,
- . W,F.i The logic for the power CRAINlEL asses shall-be demonstr ed SPEEiiph curirig TEST of channels aff ed by ss '
ration. The total b ss function shall be d strated east once per REFILE INTERVAL during CNANNE LE at , (tech channel affee by bypass operation. 7 'BRATIM testing o fl
.L21[3'The INEERED SAPITY FEATURES .Rt5f0NSE TIME of.. esc'h ESF fur.ct shal d(gonstrated to ~ within the limit atlea t" RE I RVAL'. Each test per j tion 11'incisde' at lea's t'ohe' per
' ch that all chan - are tested at least once e N REFUELING A ff I
ERV where N is the t i number of redundant chan in a specific ESFAS nction as shown ble 3.3-3.g- r-the ' intal No. of Channels'
lumn of ')
s ., ,s . 4 CALVERT CLIFFS - UNIT I 3/4 3-9 Amendment No. 208 w k pcge 1 W3 b
n
,n
'"' E ? _ ? ? 'C .t'in
e , m-= P b 11 0 .
} _ APPLICABLE g
FUFCTI0llAL IntIT CNAlWI MotC
' PJ ACTIDH ,.,
c
* /6. CCNTAlfetENT PURGE VALVES k ISOLATION h
2
]{* a. Manual (Nrge Valve Control (2/PepeGalT6) d7PerptfatioDdhtpetNII6lD 6** 8 33,7,h ce a 'i cQes $ g g
- b. Containment Radiation -
High Area Monitu 4 2 3 6** e , R
* . c.,JM B
- 7. LOSS OF POWER
. - p.n
- a. 4.16 kv Emergency Bus ' 3/
Undervoltage (Loss of ' 2 us l
- 1. 2 *4 @\ '
Voltage) f
/ -
- b. 4.16 kv Eme gency Bus us Bus 3/Bu 1. 2 Q G* # A*B.
Undervoltage (Degradad Voltage) /~ L 1 ' y a.s i s.g g 8
%^- ' I (Q ll" M.I
; L.fi
~
P '
~
c - I d.1 .
! j y
- s s
& 4
~
O
A t 2 o c~ d e __ - g Ind ^.3-2 (Co.di.n.4 y M -- --a urrry traviser arvaarvane 5-9-- - y
. . . _ . _ _ _ _ - - - - -_ _ , , w c
y (W.5.G.hNCmWEt
= _Sb nmEs a mIC
@n
*a CHA MEL CIWWEL FWCTIONAL "
FMCTIMAL WIT SURVEILLANCE CNECK CALIBRATI N M M451RO -
- 7. LOSS OF MMER C '
A 4.16 kv Emergency Bus Undervoltage NA REFKLIM
' Loss of Voltage) Q 1.2.3,4 NTERVAL
% .~'.16 kv Emergency Bus Undervoltage (Degraded Voltage)
NA REFMLIM Q 1. 2 ,y 4Q INTERVAL
- 8. ~ CYCS ISOLA h A West Penetration Room / Letdown t' Heat Exchanger Room Pressure - High MA REFWELIM INTERVAL Q 1.2.3.4)
}
.. AUXILIARY FEEWATER
- a. Manual (Trip Buttons) NA M RENELIN
- b. Steam Generator Level - Low NTERVAL RA
]
S RETWELIM Q 1. 2. 3
=>
- c. Steam Generator AP - PigF S INTERVAL REFUELIM INTERVAL Q 1. 2. 3 ]d.
Automatic Actuation Logic MA NA 3 1, 2. 3 m [ i * ' J, , s s s.- .@..-. z u- .,
'%cse%%ede .h ch. .g ***
- PMN
- O M -
- 4 - #
t s bef ESFAS u p ,,,,,.,4 . + . y
#~ ~
9 hy e 8. .4 os .T. 3. 9, W t4 m
" (vc 5 l, g,4,_ q, g '-
$pec R e%4% 3. 7. 6
=- e_w =~ -
Co.,c 5.,,,, . . .l u t ,5 a .cs
.~.
s.a d + e 6 --* 4 p,e p% ry .r% f ,o ois Wi 4.y Ca.i. .- J J pue s ,. . . w . AJ , , ,,, ,, .- .. . -
- eL-a 3,3 06 6, e
+ls p p- A.5
-9M IMTEWitiffATIM %_4 As M V.)be F s. ..A 06 AAA e 1 -
t ste 3 _, 3/g;t:t rwu - m -- - u,m=_r;;;,., ; ,_n, . : ,;;
*4 y
.,. Ge.
-.UNIMNS COSIUM FOR h'I'L% ~.+. q - C . n or q ,4. g .. $
=-
t.c.o k3.1.I The Engineered safe 3 3.b instrumentatfor. channels and OPERABLE with their trip se Feature ses shoun Actestian in Table 3.3- System ESFAS) (3 shall be 1 - the Trip Setpoint colienn of lets3.5-4. set consistent with the values shown> in '
- -~
~
APPLICA81L]TY: t t - '- !dh 0.LO hoDB 5t,'2 ,3 ,a d AGILGHz
. With an FAS instruent ion channel t setpoint less , :
conse ative than the se shown in of la'3.3-4. dec the channel llowable Val column l' fcable ACTIM rable and the j frement of .3-3 until l restored to e status wi trip setpo channel Qnsistent the Trip Set adjusted valut.
<r, '",Q [htion chap jnope e. g the ACTI f Py*
- l'? 4nm 4,y ,.4. o now - .
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SURVEILLANCE RE$l!REMENTS _--
- e. .s. c ,4. ., A ~s tune 6w g g , , t,,\ 4.^.i.4 4
- S E ST ' q.) Each 46f*E miQ-ntation channel shall be demonstrated - .
1 i 0.*ERABLE - v.u. , u by the prfonnance of the eBRigitt-elltatr CilAIElEL CAL (10;$ 1 1.2 the at he logic for the byp--Ti shall be demonstrat r CalAlplEL FullCTI OPERABLE during ' ope of channels affect by bypass 1e The total bypes unction shall be demon A, once r REFUELIIIG AL during CEAl81EL ated OPERABLE at / j channe affected ypass operation. f BRATION testing o V J l Mdd.'3F Tunction' ~e W INE----6t ~
-~~~~ RESPUlGE TINE of e 11 be demonstrated to h ESIAS) l
$1[KLI INTERW.LCEachtest
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ETn'tlie' limit at l' st oncpr f suc t all channe are1tested includist~1 east~~ chenriel per 7 at least ALS where N is the tot every N REFUELIlls number of redundant ch.nnels in a speciflo r .,l function as shown i 1e 3.3-3.f ' Total llo. of Chanoels' Column of fj
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CALVERT CLIFFS _- UNIT 2 3/4 3-9 Amendment No. 186 p ci # #
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i R 7. LOSS OF POWER
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- 7. LOSS OF POWER "
" L <tri
- a. 4.16 kv Emergency Bus Undervoltage NA (Loss of Voltage REFUELIM Q I.2.3,4
- b. 4.16 kv Emergency) Bus bndervoltageNA INTDtVAL (Degraded Voltage) REFUELIM Q I 2. df,4 g*Q INTDtVAL
[8. CVCS ISOLATION A West Penetration Room / Letdown y ( Heat Exchanger Room Pressure - High MA REFUEUM INTDtVAL Q I. 2. 3. 4 pl i
- 9. AUXILIARY FEEDWA
- a. Manual (Trip Buttons) NA NA RD1pELIIIC M
- b. Steam Generator level - Low INTERVAL
$ REFUELIIIG Q 1. 2. 3 k c. Steam Generator AP - High $
INTDIVAL REFUEUM l J Q I 2. 3 "3 h d. Automatic Actuation Logic NA IIITDtVAL M II ) P+ I. 2. g. E .
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DISCUSSION OF CHANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER is not required. Herefore, the CTS requirement which states this is being deleted. His change is an administrative change. His change is consistent with NUREG 1432. A.7 ' Current Technical Specification 33.2.1 Action b lequires the Actions of Table 33-3 to be entered if an ESFAS instrumentation channel is inoperable, improved Technical Specification 33.6 will delete this requirement because the Actions are no longer specified in the Instrumentation Table. The ITS Actions are specified in the Actions section of the Technical Specifications. The deletion of a requirement that is no longer applicable is considered an administrative change. His change is consistent with NUREG-1432. A.8 Current Technical Specification SR 4.3.2.1.1 requires testing of the logic for the bypasses, ' improved Technical Specification 33.6 will delete this requirement for the DG - Loss of Power function because this function does not have any Technical Specification required bypasses. Deleting a requirement that is not applicable constitutes an administrative change. This change is consistent with NUREG-1432. s A.9 Current Technical Specification 33.2.1 LCO requires a total number of loss of power instrumentation channels be Operable, as required by Table 33-3. Improved Technical bgcification LCO 33.6 requires four channels of Loss of Voltage and De:;raded Voltage instrumentation to be Operable. This number is consistent with the CTS. His change essentially moves the total number of channels column from CTS Table 33-3 to the LCO. Moving requirements within a Technical Specification is an administrative change, This change is nonsistent with NUREG-1432. A.10 Current Technical Specification 33.2.1 Action 7.a allows the channel to be in bypass for up to 48 hours to perform maintenance or testing. Improved Technical Specification 33,4 Action A requires 48 hours to restore the channel to Operable status. The ITS wording requires the inoperable channel to be restored to C >erable status, which would include maintenance, testing, or whatever may be required to restore the channel to Operable status. This change is considered administrative because the channel has to be restored to Operable status, or the channel must be placed in the tripped condition, which is consistent with the CTS. His change is consistent with NUREG-1432. A.ll Current Technical Specification 33.2.1 Action 7 exempts the requirements of Specification 3.0.4. Improved Technical Specification 33.6 will transfer this requirement to Action B. Action 7 of the CTS corresponds to Actions A and B of the ITS. The exemption of this requirement is not needed for Action A because this Action allows unlimited operation. It was added to Action B because this Action does not allow continued operation. This change is adminis*ative because deleting a requirement where it is no longer required constitutes an administrative change. This change is consistent with NUREG-1432. A.12 Current Technical Specification 33.2.1 Table 3.3-3 requires the loss of power functional unit to be Operable in Modes 1, 2, and 3, and Table 43-2 shows the Modes in which the Surveillance; are required. Improved Technical Specification 3.3.6 will delete tables and lists the Modes in the Applicability section. In addition, CTS 4.8.1.1.2.d3 requires a Surveillance to be performed that will demonstrate the DG capability to aqtomatically start and sequence loads on a loss of offsite power signal. To be able to meet this requirement, the DG-LOVS must be Operable. The Applicability of CTS LCO 3.8.1.1 includes Mode 4, CALVERT CLIFFS - UNITS 1 & 2 33.6-2 Revision 8
1 DISCUSSION OF CHANGES - SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER therefore, the DG LOVS Applicability will now include Mode 4. His constitutes an l , riministrative change. This change does not affect the safe operrtion of the unit. A.13 Not used. 4
'A.14 Current Technical Specification 33.2.1 Action 7.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 7.b requires that within one hour all functional units receiving an input from the inoperable channel be placed in the tripped or bypass Condition. hnproved Technical Specification 33.6 Condition A requires one or more functions with one sensor module or associated measurement channel inoperable be placed in trip or bypass in one hour. The ITS Condition A captures the technical intent of CTS Action 7.a and 7.b by requiring that all affected functions take the specified actions, therefore, the change is administrative. His change h consistent with NUREG-1432.
A.15 Current Technical Specification Table 33-.i specifies trip setpoints and allowable values for DG loss of voltage ingnal functions. Improved Technical Specification 33.4 Table 33.4-1 only specifies the allowable values for the DG loss of voltage signal functions. He trip setpoints and allowable values contained in the CTS are identical, therefore, only the allowable values are necessary to be specified for Operability. His change is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. This change is consistent with NUREG-1432, A.16 Current Technical Specification 33.2.1 does not contain Actions when more than two channels are inoperable, therefore, Specification 3.03 would be entered. CTS 3.03 provides one hour to correct the condition or a plant shutdown would be req:: red. Improved Technical Specification 33.6 Action C provides one hour to restore all but two DG - Loss of Voltage chatmels to Operable status if more than two (three or four) channels were inoperable. The one-hour Completion Time is acceptable because it is consistent with the existing Completion Time in CTS 3.03 and allows a reasonable time to evaluate and take action to correct the degraded condition in an orderly mancer. He requirements associated with a subsequent plant shutdown if two channels are not Operable in I hour is addressed in a separaa Less Restrictive Discussion of Change. His change is consistent with NUREG-1432. A.17 Currect Technical Specification 43.2.13 requires a response time test for DG-LOVS. The actual time ailowed for the instrumentation portion of the response time is located in the UFSAR. The a:tual response times were relocated to the UFSAR in a previous license amendment consistent with NRC generic guidarce. The UFSAR only provides a response time for the loss of voltage DG-LOVS; no response time is provided for the degraded vo!tage DG-LOVS, The response time in the UFSAR is the same as the maximum Allowable Value. He ITS maintains the Allowable Value in ITS SR 33.6.L In addition, ITS SR 3.8.1.15 maintains the DG start time portion of the response time test. Therefore, CTS 43.2.13 is not required to be maintained in the ITS and has been deleted. Since al' parts of the current requirement are being maintained in the ITS, this deletion is considered administrative. CALVERT CLIFFS - UNITS 1 & 2 33.6-3 Revision 8
semer. modvles od mensvymed Dr D =~~ OG-LOSS h 3.3 INSTR ATION 3.3.6 Diesel Generater (DG)-Loss of Voltage Start (LOYS)({kfah
.A.2.)1LCO 3.3.6 kFour Qwt6els4f) Lost ef V61tage Functie.
'; fourf s iannet24_n Degraded Voltage Functionsuf.e<1nttlaMm0 L i.4. M shall be OPERABLE. h s APPLICABILITY: MODES 1. 2, 3. and 4.
[ Whenas lated DG is re L
- red to be OPE LE by LC0 Sources-Shutd .
ACTIONS
--------NOTE -
Separate Condition entry is allowed for each Function. -- CONDITION REQUIRED ACTION COMPLETION TIME Lo% A. One or s ensor- J.a
.) with oneghanne Functions A.1 P(laceM'e31th'Q n
bypass or trip. I hour DG inopera E )l?per ^ -- @ ale sea.sor tam 3.M . AcmW(8A g n.ed 4 A.2.1 R(ster channel to k48 ours
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4 g,44 , OPERABLE status. ofnd CE QLp Y A.2.2 Place the(c,htriniD in trip. 48 hours b
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(continued) CEOG STS 3.3-27 Rev1,04/07/95
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DISCUSSIGN OF TECliNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.3- INSTRUMENTATION ddopted since it is not required by the Applicability; once NUREG-1432 Required Actions C.2.1 and C.2.3 are completed, the LCO is no longer required to be met (and thus Required Action C.2.2 is not required to be completed). The Notes in Actions A and C have been deleted since the Calvert Cliffs design does not include a toxin ;as mode.
- 16. Specification 3.3.10 will not be included in the Improved Technical Specifications because Calvert Cliffs does not have a Shield Building Filtration Actuation Signal. This change is consistent with Calvert Cliffs design.
- 17. Specification 3.3.12, which requires that the Remote Shutdown System be Operable, has been changed to require the Remote Shutdown Instrumentation to be Operable; the control circuits and transfer switches are not included in this Specification. As noted in the Safety Evaluation Repo t for License Amendments 120 (Unit 1) and 102 (Unit 2), dated August 6,1986, the remote shutdown instrumentation is provided for monitoring purposes only. This is consistent with the position stated in previous Safety Evaluations for other License Amendments, such as Amendment 88 for Unit:1 (dated November 17, 1983). That Safety Evaluation stated that the instrumentation was used to monitor key safety parameters and that no automatic features were actuated from the remote shutdown instrumentation. Therefore, the Technical Specification only requires the instrumeatatica to be Operable, not the control circuits and transfer switches. Due to this change, SR 3.3.12.2, which venfies the control circuits and transfer switches are capable of performing their intended function, has been deleted.
- 18. The Note in Specification 3.3.12 SR 3.3.12.3 which excludes the Reactor Trip Breaker Indication from the channel calibration is being modified to also exclude the Reactor Trip Breaker Indication. The Reactor Trip Breaker Indication channels indicate whether the Reactor Trip Brnakers are open or closed, which does not require a channel calibration. This change is consistent with Calvert Cliffs current licensing basis.
19. This change removes part of the Applicability for LCO 3.3.6. "When associated DG is required to be Operable by LCO 3.8.2, 'AC Sources - Shutdown'" is removed because the Diesel Generator-Loss of Voltage Start (DG-LOVS) is required for ESFAS systems to function in any - accident with a loss ofoffsite power, and ESFAS Applicability is Modes 1,2, and 3. As noted in the Safety Evaluation Report for License Amendments 198 (Unit 1) and 175 (Unit 2), dated September 27,1994, the undervoltage instrumentation is only required in Modes I through 3. His is consistent with the discussion provided in our application for a license amendment dated November 2,1993. That letter states that an EDG is required during shutdown and refueling to ensure adequate AC electrical power is available to mitigate events such as a fuel handling incident or a bss of shutdown cooling. Due to the reduced pressure and temperature conditions of the reactor coolant system during shutdown conditions, these events develop more slowly and the results are less severe than the events which occur at full power. Thus, additional time is available for the operator tc evaluate plant conditions anc respond b, manually operating engineered safey feature components as required to successfully mitigate the consequences of the event. These discussions support not including Modes 4 through 6 and movement of irradiated fuel assemblies. Hoivever, to be consistent with the AC Sources-Operating requirements (CTS 3.8.1.1, ITS 3.8.1), which requires that the DG auto start and sequence loads following a loss ofoffsite power, the Mode 4 requirements will be added. CALVERT CLIFFS - UNITS 1 & 2 3.3-3 Revision 8 o
DG-LOVS h BASES - AS_ / , 1-APPLICABLE testability requirements ofCGDC 21 taAb cFR 50. Aspbendix p g SAFETY ANALYSES (Ref. 5). y (continued) The delay times assuspd in safety analysis for the ESF
- equipment include the410 second DG start delay and the appropriate sequencing de ay if applicable. The response times for ESFAS actuated equ poent include the appropriate DG loading and sequencing de ay.-
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- DVS_channals satiJfy Criterion 3 ofC1 ncy) t h
- LCO "
The LC0 for the LOVS requires that four channels per bus of each LOVS instrumentation Function be OPERABLE in MODES 1, l - l- A e l supports s'afety systems aspctated with the ESFAS
'r=_=m a anu
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sne tour ca.un. - v. vranand var, - the associa DG is requir i o.be OPERABLE to en re that . Qhe autom c start of the is available when n edad. J-
,, _ Actions allow maintenance (thye--TDbypass of i nm u uumwh = =--1 Q1 an h N N 4rs '
heloEranneDbypass condit' A restricted to 48 hours in on before either restoring the - a-Function so four channel operation two-out-of-four logic)
;A %,- or placing the channel in trip (one-(out-of-three logic).fI p ants where c- uate channel to enann independence lias been demonstra , specific exceptio have been approv by the NRC staff o penait one of the l0 to be bypas d for an extended na ad -out-of-four at tiaa- ch els 1 J
m Loss of LOVS Function could result in the delay of safety. Mr.n synta= rin11.lettofDwhen required. - This could lead to h nacceptable consequences during accidents. During the loss of offsite power, which is an anticipated operational occurrence, DG powers the fe allure of turbine driven p or driven auxiliary pung s to start would -_h s well as an _ increased pothtial for a loss of deca heat removal through the secondary system. g Only Allowable Yalu s e c for each Function in the LCO. Nominal trio se nt are specified in t specific (selpointpeuletTonj The nominal s t@nts are - u%s s hp (continued) , CE0G STS B 3.3-102 Rev 1. 04/07/95 e
_ s -= -% Mowsk akS And 4 Nig 3 an eshMd la or4,- 4, s
& b l ce m .cr a a et,r. m +o p ,a st,n, a 4 6 ,perae g ,
i.M N erber 4o prosth. eqq powu 4e $knd ad suppy ne em% l l
. dtdrral lods rec 4 wary do idey skddown & gbt o A ^ *M
8'f b g wit hMA*wn coM'm, _ BASES , g e 3 LC0 . selected to ensure that the measured by CHANNEL (continued) FUNCTIONAL TESTS does not exco e Allowable Valce if the b ble is perfoming as required. Operation with a trip tooFnDless conservative than the nominal trip , but within the Allowable Value, is acceptable, prov ed that operation and testi consistent with the assumptions of the plant spelfic e ca lation. A channel is z inoperable if its ac un ria- is not within its required Allowable Value. Mr _
~
[Fohthisu , the Bases for thegowable Values andIip re as followst f p setpoint f _ _f_ l APPLICABILITY The DG-LOVS actuation Function is required in H00ES 1. 2, 3, and 4 because ESF Functions are designed to provide yrotection in these M00ESJAct tion in nuus = or o ts 3 requirea wns er the required must be OPERABL so that I it can per its function a loss of power degraded p) power to vital bus. i
%f) he
! ACTIONS A LOVS hannel i inoperable when it does not satisfy the i OPERABILITY cri ria for the channel's Function. The most T*******I cosmon cause o hannel inocerability is outricht failure wwj, _ drift of the histablefor4Irar$ sodwilffsuffic to exc the tolerance allowed bv the c:at specific 4Iii analysis. Typically, the drift is found to be saa 1 and results in a delay of actuatlo rather than a total loss of C4 awe (. CAL 4 Wio" function. Deterstnation affa durina the performance of ajcHANNEL FyNGH UMAL I DI
~detrt ts generally made nthe) @
Wha N grocen i 5b ed" nstrumept is set up top'adjustmentAo brina it wi J h, ut og for.1pki- , specification.Ilf the actual tripQetseWhis not within the Allowable Value, the channel is inoperable and the _ b b'3 N i* Mk appropriate Co itions must be entered. Sftd'L*4ren, bwelr6F In the event annel's(trio M6ot; un cMA ahn k TM,ddreh nonconservative with respect to the Allowable Value, or the channel is found inoperable, then all affected Futictions I dwig & CHbWE.t.ufty, provided by that channel must be declared inoperable and the -
, 0%NNCL f*JLTlouhL fn he$
um :a.s.y - .
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(continued) CfoG STS B 3.3 103 Rev 1, 04/07/95
~~
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_. _ 4 _ ._- _ . - - _ . . . . . _ . . ._. 4 . r-4,t - p' 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.- 5
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DG-LOVS B 3.3.6 BASES - account the low probability of an event requiring LOVS occurring during this interval. D_d Condition D applies if the Required Actions and associated 8 Completion Times are not met. Required Action D 1 ensures that Required Actions for the affected DG inoperabilities are-initiated. The actions g specified fin LCO 3.8.1, "AC Sources-Operating," are-required immediately. SURVEILLANCE The following SRs apply to each DG-LOVS Function. REQUIREMENTS SR 3.3.6.1 A CHANNEL FUNCTIONAL TEST is performed every 92 iays to ensure that the entire sensor channel will perfoi? its intended function when needed. The Frequency of 92 days is based on plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one sensor channel of a given function in any 92 day Frequency is a rare event. Any setting adjustment shall be consistent with the assumptions of.the current plant specific. setting analysis. E SR 3.3.6.R SR 3.3.6.3 is the performance of a CHANNEL CALIBRATION every 24 months. The CiANNEL CALIBRATION verifies the accuracy of each component within the sensor channel, except stepdown transformers, which are not calibrated. This includes calibration of the undervoltage relays and demonstrates that h CALVERT CLIFFS - UNITS 1 & 2 B 3.3.6-8 RevisionJT3 _ . +
DISCUSSION OF CHANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER - TECHNICAL CHANGES - MORE RESTRICTIVE
. M1 Current Technical Specification 3.3.2.1 Actior. 7.c does not specify a time for the additional inoperable channel to be placed in trip or bypass. Improved Technical Specification 3.3.4 Action B will require one channel to be placed in trip and one chancel to be placed in bypass in one hour. His change essentially places a one-hour time limit, where none previously existed, to perform the Actions. His change is, therefore, a more restrictive change, ne change will not adversely affect plant safety, because its appropriate for a time limit to be set for placing one channel in bypass and one channel in trip when two channels are inoperable.
His change is consistent with NUREG-1432, M.2 Not used. l TECHNICAL CHANGES - RFLOCATIONS None 1; TECHNICAL CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification 3.3.2.1 Table 3.3-3 contains a " Channels to Trip" colun.n. Improved Technical Specification 3.3.6 will not contain this information. This is an informational column which is more appropriate for the Bases. The number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the numt>er of channels to trip will require a design change. He Bases Change Control Program will ensure that changes to this requirement receive appropriate review. His change is a less restrictive movement of details chang. with no impact on plant safety. His change is consistent with NUREG-1432. LA.2 Not used. l LA.3 No' used. l TECHNICAL CHANGES - LESS RESTRICTIVE L.1 . Not used. l L.2 Current Technical Specification 3.3.2.1 doe 3 act contain any actions if the Required Actions l cannot be met within the allowed Completion Times. Herefore, Specification 3.0.3 would be entered. Improved Technical Specification 3.3.6 adds an Action (Action D), which would require the applicable Condition and Required Actions for the associate,i DG made inoperable by DG-Loss of Voltage instrumentation, to be entered. This change is appropriate because the DG-Loss of Voltage instrumentation essentially renders the affected DG incapable of starting automatically, thus the affected DG would be unable to perform it
, safety function. Entering the applicable Actions of LCO 3.8.1 is appropriate to ensure all l Required Actions for an inoperable DG are completed. It would be imprudent to shut down CALVERT CLIFFS - UNITS I & 2 3.3.6-4 Revision 8
____---__------- - - ----- - - - - --- - ~~~ DG-LOVS h BA$iS ACTIONS L 1 (continued) 1 reasonable to evaluate and take action to correct the - + ' degraded condition in an orderly manner and takes into account the low pmbability of an event requiring LOVS occurring during this interval. IL1 Condition D applies if'the Required Actions and associated Completion Times are not set. Required htion 0.1 ensurt.s that Required Actions for the affected DG inoperabilities are initiated. (p (Dviit30GDjhe actiontspecified in LCO 3.8.gggtas, cow) 1, 'AC Sources-Operating,' grVW3,42)are required immediately.
~
\ SURVE!LLANCE PEQUIRENEhTS The following SR; apply to each OG-LOVS Function. SR 3.3.6.1 1
~
Performance of the CHANNEL CHECK ce every 12. hours ensures that a gross failure of inst CHANNEL CHECK is norsally a e tation has not occurred. A arison of the indicated ' output of the potential tra formers that feed the LOVS undervoltage relays. It i based on the assumpcion that instrument channels mont ring the same parameter should read approximately the ame value. Signtficant deviations /
/ Qi between the two chan s could be an indication of exces ve drift in one of the hannels or of something even more serious. CHANNEL ECK will detect gross enannel fat re; thus, it is key verifying that the instrumentati continues to c cate properly between each CHANNEL CALIBRATION.
Agreement riteria are determined by the plan staff, based on a c nation of the channel instrument u eriainties, includ g indication and readability. If t channels are withi the criteria, it is an indication at the channels are PERABLE. (continued) CEOG STS B 3.3-106 Rev 1, 04/07/95 i, 5
._ . . . _ _ . _ _ . . - . . . . - _ . . _.-....._..._.._..__..__...1.-. . . . . ._ _ .. ..._, . . .
7._-._. T h 1-
- 40. - To resolve NRC: comment 3.3.410, Discussion- of Deviation _ 26 was revised to provide' additional clarification on the operation of the sensor block modules and how they are effectively .;
removed from the circuitry when inoperable. J Y f L J F a-1- t i i k i f e
- 1. .
1 k .l ^
l 1 DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 33 - INSTRUMENTATION 20. The SR 33.11.2 Note which excludes the Neutron Detectors from the channel calibration will be modified to also exclude the Reactor Vessel Level Monitoring System. Here is no mechanism at Calvert Cliffs to perform a channel calibration on the Reactor Vessel Level Monitoring System, The instruments are usually replaced. This change is consistent with the Calvert Cliffs current licensing basis.
- 21. Surveillance Requirement 33.10.2 was added to require performance of a channel calibration on containment hydrogen analyzers every 46 days on a Staggered Test Basis, instead of 24 months.
This change is consistent with the Calvert Cliffs current licensing basis, in conjunction with the change a statement was added to SR 33.103 excluding the hydrogen analyzers.
- 22. His change adds Steam Generator Pressure and RCS Subcooled Margin Monitor (SMM) and l Pressurizer Pressure (low range) to Table 33.11 1. This change is consistent with the Calvert Cliffs current licensing basis. Only one channel-of RCS SMM is required, therefore, the referenced action on STS Table 33.11 1 is not applicable. Conditions A and B are only necessary for this functi6n. Only one channel is required in the licensing basis due to diverse indication or core cooling from core exit thermocouples and reactor vessel water level. g
- 23. This change removes Auxiliary Feedwater Flow from Table 33.11-1, removing PAM instrumentation. Auxiliary Feedwater Flow does not meet the threshold for inclusion in this PAM table. This change is consistent with the Ca: Vert Cliffs Current licensing basis.
- 24. This change excludes SR 33.1.8, Channel Calibration from the Loss of Load function. The Loss l of Load Function cannot be calibrated because it senses a turbine trip and does not contain setpoints. Loss of Load function is verified operable by performance of a channel functional test. This change is consistent with the Calvert Cliffs ct.rrent licensing basis.
- 25. Not used.
l
- 26. NUREG-1432 Specification 33.4 condition D requires an inoperable automatic bypass removal channel to be disabled or placed in trip or bypass in I hour. If the module is bypassed or tripped, the actions subsequently require the channel to be restord to operable status or placed in trip in 48 hours. ITS 33.4 condition C will require the inoperable block removal feature for a sensor block module to be ciisabled in 1 hour or placed in bypass. The assumed safety function of the sensor block module is to ensure that the ESFAS features which have bypass capability are automatically unblocked. With the unit disabled or bypassed, the ability to block an ESFAS function on that module is removed, i.e., disabling or bypassing the block module effectively remc*zes it from the circuitry and fulfills the auto-unblock function. His action places the function in a one-out-of three logic which ensures the required redundancy. This action is equivalent to continued operation with an RPS channel placed in trip permitted by LCO 33.1 Conditior A.
- 27. - This change adds a Condition (Condition E) and related Required Actions to address the '
diiTerent Mode requirements associated with ESFAS Actuation Logic channels of < Specification 33.5. His change also adds a statement identifying the second Condition of Condition D as being for the Manual Actuation Channel. He two different Conditions e e required to address the different times at which the conditions leave the Modes of Applicability. This change is consistent with the Calvert Cliffs current licensing basis. CALVERT CLIFFS - UNITS 1 &. 2 33-4 Revision 8
d h
- 41. - -- To resolve NRC comment 3.3.7-3, Discussion of Change L2 was revised to provide additional ~
clarification regarding the acceptability of the four hour Completion Time to place the radiation monitor channel in trip. i 4 i t-Y i f o ec- e.- 4 + --m- - - - - - m++ nre- e m - r m --+- 4
. .- .- .~ . . -
1 DISCUSSION OF CHANGES SECTION 33.7 - CONTAINMENT PURGE VALVE ISOLATION SIGNAL LAJ Not used. l LA.4 Current Technical Specification 333.1, Table 33 6, contains the measurement range for the Containment Purge and Exhaust Isolation monitors. Improved Technical Specifications will move this detail to the Bases. This is acceptable as the exact range of the instrument is unimportant as long as the instrument is capable of performing its safety function as required for operability. Placing this detail of operability in the Bases is consistent with the ITS star.dards for formst and content. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program, ne Bases Change Control Program will ensure that changes receive appropriate review. His is a less restrictive movement of details change with no impact on safety. His change is consistent with NUREG-1432. TECHNICAL CHANGES - LESS RESTRICYlVE L.1 Current Technical Specification 33.2.1 requires two Containment Purge Valve Isolation Manual Trip channels per penetration to be Operable. Improved Technical Specification 3.3.7 reduces this requirement to one channel of Manual Trip per penetration. The change is based on the fact that the ability to close the valves remains assured with one channel Operable. Also the Containment Purge and Exhaust Isolation will also occur on a High Radiation Signal or Containment Isolation Signal. Also in conjunction with this change, the CTS Actions when one of two Manual Trip channels is inoperable are now applicable when the one required Manual Trip channel is inoperable. The change is consistent with NUREG 1432. L.2 - Current Technical Specification 33.2.1 Action 8 requires that with fewer than the required , number of containment radiation monitors Operable, Operation may continue, provided the containment purge isolation valves are maintained closed. Improved Technical
' Specification 33.7 Action A requires that if one instrument channel is inoperable, then within four hours, either the affected sensor module be placed in trip or Core Alterations and all movement of irradiated fuel assemblies within containment be suspended. Allowing continued operation, with the sensor module in trip without closing the containment purge isolation valves, is a less scstrictive change. Placing the sensor module in trip satisfies the function of the monitor. The Completion Time of four hours is acceptable because there are three redundant channels which remain operable to complete the required safety function, and due to the low probability of an event occurring during this time. His logic is more conservative, and thus is an acceptable condition. His change is consistent with NUREG-1432.
LJ Current Technical Specification 33.2.1 Action 8 requires that with fewer than the required number of containment radiation monitor channels Operable, operation may continue provided the containment purge isolation valves are maintained closed. Improved Technical Specification 33.7 Acdon B requires that if one required manual Actuation channel or Actuation Logic chanr.el is inoperable, or more than one instrument channel is inoperable, or Completion Time of Action A is not met, then contam;nent purge supply and exhaust i:;oiation valves must be placed and maintained in a closed position, or Core Alterations and all movement of irradiated fuel assemblies within containment must be suspended CALVERT CLIFTS - UNITS 1 & 2 33.7-4 Revision 8
- 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 is added to reflect the retentian of allowable values in ITS 3.3.7. >
4-e y.- t 4 4 f S
.+ -m . - _ _ _ _ , _ . _- _ . ---. . 4- .4 -
w- ,
tij_ ' V , tj g TABLE 3.3-4(Continued) ENGINEERED SAFETY FEATURE ACTUATION SYSTEN INSTRUMENTATION TRIP VALO'ES U
,b, FUNCTIONAL UNIT [T M SET 7 DINT A/0 ALLOMRSLE VALDE5
w r - = --., CONTAINMENT SUMP RECIRCULATIOC (RAS)
?! a. ManualRAS(IripButtons)
D**{* - d
- l Not Appitcable Not Appifcabl !!\ '^bl%
lQ. Refueling Water Tank - Low 1 24 inches above tank I E \*esenMk'
- - -1 24 inches above tank N_
bottom j
- 6. CONTAIMMENT' PURGE VALVES ISOLATION .
Ma a PURGE V g cable [ Not App 11 cable
,4-SR 337.2.
Y
- b. Contafrrsent Radiation - High Area Moniter p0//hr A;lO 5 220 ar/hr LO550FPOWER(
. 4.I6 ky Emergency Bus Undervoltage 2450 + 105 volts with a (Loss of Voltage) 2450 1 IOS volts I 2 1 0.Y second time delay 2 1 0.2 second time delay
- b. 4.16 kv Emergency Bus Undervoltage 3628 1 25 vo'1ts with a (DegradedVoltage) 3628 1 25 volts with a ,
{ o 8 1 0.4 second time delay 8 1 0.4 second time delay / g _
.._/ -
a , c- - g tec w . 17 6 a De^k f .. m6; c m'OC -t ov5" E __ - mrt - -- - - v\
- T festosh s Ahk % ?
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c , See J.uan.- . e c ..e I. . $ , . f. --% _ , v,, tg ,
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w g TABLE 3.3-4 (Continued)
} w
_ % ENGINEERED SAFETY FEATURE ACTERTION SYSTDI IIISTRWIEllTATISR TRIP VALBES I SETPSGli IO gleisigLE..TAlgES I h O FUNCTIONRL GRIT u a .
-- 5. CONTAlf9011 SUMP RECIRCULATION (RAS) c 1
5 4. Manual RAS (Trip Buttons) not Applicable flot Applicable d
. -. g
'* Refueling Water Tank - Low
- b. 1 24 inches above tank 1 24 inches w'- above tanky I, cit,,
7 5 6. CONTAIIS0l' PURGE VALVES ISOLATI0h Ma ( alve Control llot Applicable HotApplicaby t* b. Containment Radiation - High < ar/ ~< 220 nr/hr Area Monitor AsIO [ h 5 g, fy 0 7. LOSS OF PO hWE .~
; a. 4.16 kv Emergency Bus Undervoltage 2450 + 105 volts with a 2450 + 105 volts with a j !
(Loss of Voltage) 2 1 0.2 second time delay 2 1 0.Y second time delay -5 s I b. 4.16 kv Emergency Bus Undervoltage 3628 + 25 volts with a 3628 1 25 volts with a
.[ \ (Degraded Voltage) 8iOJsecondtimedelay 810.4secondtimedeg Ei g i , = .
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4 f* 4 8 ef A
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4 4 er - L .. . . . . . . .. . . . . . .. .. . . ... . . .. ~---__=m_=--
f DISCUSSION OF CllANGES SECTION 3.3.7 - CONTAINMENT PURGE VALVE ISOLATION SIGNAL - A.7 Current Technical Specification 33.2.1 Table 33-3, "ESFAS Instrumentation, " includes a functional unit for Containment Purge Valve Isolation. Improved Technical Specification 33.7 is created specifically for the Containment Purge Valve Isolation function. Creating a new Specification from existing requirements constitutes an administrative change. This change is consister.t with NUREG 1432. A.8 Current Technical Specification 3.3.2.1 Action 8 requires that with fewer than the required number of Containment Radiation channels Operable, Operation may continue provided the containment purge isolation valves are maintained closed. Imprewd Technical Specification 33.7 Action B requires that if one required manual Actuation channel or Actuation Logic channel is inoperable, or more than one instrument channel is inoperable, or the Completion Time of Action A is not met, then containment purge ad exhaust valves must be closed, and Core Alterations and all movement of irradiated fuel assemblies within contain.r..mt be suspended (LCO 3.93). Closing the containment purge and exhaust valves for this Condition is.The same requirement as in CTS. The other actions are addressed in a less restrictive change. Moving a Specification within the Specifications constitutes an administrative change. This change is consistent with NUREG 1432. A.9 Current Technical Specification 33.2.1, Table Notation """ requires the containment purge valve manual control switches and containment radiation - high radiation monitor be
- Operable when the containment purge valves are required to be Operable. Current Technical Specification 3.9.4 requires the valves to be Operable during Core Alterations and movement of irradiated fuel within containment. Improved Technical Specification 33.7 requires four containment radiation monitor sensor modules and measurement channels, one Actuation Logic channel, and one manual Actuation el annel to be Operable during Core Alterations, and during movement of irradiated fuel assemblies within containment when containment purge valves are open. The intent of when the equipment k required to be Operable is the same. Movement of a requirement within the Specifications constitutes an seinistrative change. This change is consistent with NUREG-1432.
A.10 Current Technical Specific : ion Table 33-4 specifies trip setpoints and allowable values for the containment purge isolation function, improved Technical Specification SR 33.7.2 only specifies the allowable values for the containment purge isolation function. The trip setpoints and allowable values contained in the CTS are identical, therefore, only the allowable values are necessary to be specified for Operability. This change is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. This change is consistent with NUREG-1432. TECHNICAL CHANGES - MORE RESTRICTIVE M.1 Current Technical Specification 33.2.1 Action 8 requires that with fewer than the required number of containment radiation monitors Operable, Operation may continue provided the containment purge isolation valves are maintained closed. No time requirement is stated for the action. Improved Technical Specification 33.7 Action A requires that if one instrument channel is inoperable, then within four hours, either place the affected sensqr module in trip, or suspend Core Alterations and all movement of irradiated fuel tssemblies within containment. The addition of a time requirement for Actions to be taken is a more restrictive CALVERT CLIFFS - UNITS I & 2 33.7-2 Revision 8
DISCUSSION OF CHANGES SECTION 3.3.7 - CONTAINMENT PURGE VALVE ISOLATION SIGNAL change. This change will not have an adverse affect on plant safety. This change is consistent with NUREG-1432. M.2 Current Technical Specification 3.3.2.1 Action 8 requires that with fewer than the required number of containment radiation monitors Operable, Operation may continue provided the containment purge isolation valves are maintained closed. Improved Technical Specification 3.3.7 Action A requires that if one instrument channel is inoperable, then the affected sensor modt.!e is placed in trip, or Core Alterations and all movement ofirradiated fuel assemblies within containment be suspended with containment purge valves or containment vent valves open. This is moie restrictive because closing the containment vent valves is added as a criterion for continued operation. This change will not adversely affect plant safety. His change is consistent with NUREG-1432. M.3 Current Technical Specification 3.3.2.1 requires a CFT to be performed on the Containment Radiatior. Signal. Improved Technical Specifications SR 3.3.7.2 also requires a CFT to be performed. However, the ITS SR is modified by a Note which requires testing of actuation logic to include verification of the proper driver relay output signal. his is an additional requirement which is added to the Technical Specification SR, and is therefore a more restrictive change. This change will not adversely impact plant safety because verifyi..g the proper relay driver output signal is currently included in the CFT. This change is consistent with NUREG-1432. M.4 Improved Technical Specifications will add a Surveillance (SR 3.3.7.2) to perform a CFT on each Containment Radiation Signal Acmation Logic channel once per 92 days. Current Technical Specification 3.3.2.1 does not contain this SR. This SR will ensure that the containment purge valve isolation aignal is properly tested. This Surveillance was added to CTS 3.3.2.1. The addition of new requirements to CTS constitute a more restrictive change. This change is consistent with NUREG-1432. TECHNICAL CHANGES - RFI OCATIONS None TECHNICAL CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENT 3 LA.1 Not used. l LA.2 Current Technical Specification 3.3.2.1 Table 3.3-3 contains a " Channels to Trip" column. Improved Technical Specification 3.3.7 will not contain this information. This is an informational column which is more appropriate for the Bases. The number of channels to trip will not be changed, ne information is being moved to the Base 9 intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that changes receive appropriate review. This change is a less restrictive movement of details change with no impact on safety. This change is consistent with N'UREG-1432. CALVERT CLIFFS - UNITS I & 2 3.3.7-3 Revision 8
t g
-43; To resolve NRC comment 3.3.7 6, Discussion of Change LA.3 is Jeleted and replaced by Discussion of Change A.I. ne requirements'for channel functional test of manual purge
- isolation are retained as ITS SR 3.3.7.5.
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GARET FWWCTION E SWITEILEANCE E
** FUNCTIONAk-INRf- CRECK CALIBRATION eg g RE05INED E b 5 >
MIN STEAM LIE ISOLATION b
- a. m E Manual SGIS (MSIV Hand Switches MA M REFUELING M l and Feed Head Isolation Hand INTERVAL t Switches) f
' b. Steam Generator Pressurt - Low 5 REFMLING I, :', 3 Q
INTERVAL
- c. Automatic Actuation Logic NA M # M 1, 2, 3
*j S. CONTAlleEllT SIN RECIRCULATION (RAS)
- a. Manual RAS (Trip Buttons) M M REFUELINE M I IIITERVAL !
- b. Refueling Nater Tank - Low M Kf5ELING 1, 2, 3 Q .!
- c. Automatic Actuation Laoic INTERVAL h ;
M M W$U 1, 2, 3
- 6. CONTAllOENT PURGE VALVES ISOLATION
[ a. Manual (Purge Valve Control p l NA M REFUELINE M
=
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- b. Containment Radiation - High Area Monitor -
S KFMLIM Q N INTERTAL ' o g 7
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7 FgNCTISRAL WIT " n FAJt + ,,,- * *..- GEO CALIBRATION E REEWIRD
- 4. MIN STEM LINE ISOLATION (SGIS) l b
- a. Manual SGIS (MSIV Mand Swttches' M M E
.and Feed Mead Isolation Mand REFUELING M i INTERVAL
. Switches)
- b. Steam Generator Pressure - Low S REFUELING Q 1. 2. 3 INTERTAL
- c. Automatic Actuation Logic M M # M I. 2. 3
- 5.
w CONTAIMENT SIMP RECIRCULATION (RAS) j ! k t a. Manual RAS (Trip Butto.s) M M REFWELINE M ' INTERVAL
- b. Refueling Water Tant - Low M REFWELING l
Q 1, 2. 3
- . Automatic Actuation Logic M INTERVAL.y M MD
- 6. CONTAIMENT PURCE VALVES ISOLATIDM I. 2. 3 J ,
~
{ s
- a. Manual (Purge Yalve Control M M REFWELINE M
(
.=.,.
Swftches)
- b. Containment Radiation - High Area Monitor
$ REFWELING INTE; VAL INTERVAL Q @Y o A
f M4 A
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y h fft.c., CFr o. Do , . 3 C .. , A 4 4 '* 4 -- S {' eA cRS Ac.>e6 9 L g;c et. --f ~ 0 e 3 ~ ~ . - ~ .t . r , , , - 4. ~ 4 .s 3 ~ re t - *y t % . - r - -- - -. ' 2
' .d 9 % ,,p, d'g
DISCUSSION OF CIIANGES SECTION 3.3.7 - CONTAINMENT PURGE VALVE ISOLATION SIGNAL LA3 Not used. l LA.4 Current Technical 11pecification 333.1. Table 33 6, contains the measurement range for the Containment Pure and Exhaust Isolation monitors. improved Technical Specifications will move this detril to the Bases. This is acceptable as the exact range of the instrument is unimportant as long as the instrument is capable of performing its safety function as required for operability. Placing this detail of operability in the Bases is consistent with the ITS standards for format and coment. Any changes to these requhements in the Bases will require change in compliance with the Bases Change Control Pror- . The Bases Change Control Program 'will ensure that changes receive appropriate e.w. This is a less restrictive movement of details change with no impact on safety h. . change is consistent with NUREG 1432. TECIINICAL CIIANGES IMS RESTRICTIVE L.1 Current Technical Specification 33.2.1 requires two Containment Purge Valve Isolation Manual Trip channels per penetration to be Operable. Improved Technical Specification 33.7 reduces this requirement to one channel of Manual Trip per penetration. The change is based on the fact that the ability to close the valves remains assured with one channel Operable. Also the Containment Purge and Exhaust Isolation will also occur on a High Radiation Signal or Containment Isolation Signal. Also in conjunction with this change, the CTS Actions when one of two Manual Trip channels is inoperable are now applicable when the one required Manual Trip channel is inoperable, ne change is consistent with NUREG 1432. L.2 Current Technical Specification 33.2.1 Action 8 requires that with fewer than the required number of containment radiation monitors Operable, Operation may continue, provided the containment purge isolation valves are maintained closed. improved Technical Specification 33.7 Action A requires that if one instrument channel is inoperable, then within four hours, either the affected sensor module be placed in trip or Core Alterations and all movement of irradiated fuel assemblies within containment be suspended. Allowing continued operation, with the sensor module in trip without closing the containment purge isolation valves, is a less restrictive change. Placing the sensor module in trip satisfies the function of the monitor. The Completion Time of four hours is acceptable because there are three redundant channels which remain operable to complete the required safety function, and due to the low probability of an event occurring during this time. His logic is more conservative, and thus is an acceptable condition. This change is consistent with NUREG-1432. LJ Current Technical Specification 33.2.1 Action 8 requires that with fewer than the required number of containment radiation monitor channels Operable, operation may continue provided the containment purge isolation valves are maintained closed. Improved Technical Specification 3J.7 Action B requires that if one required manual Actuation channel or Actuation Logic channel is inoperable, or more than one instrument channel is inoperable, or Completion Time of Action A is not met, then containment purge supply and exhaust isolation valves must be placed and maintained in a closed position, or Core Alterations and all movement of irradiated fuel assemblies within containment must be suspended CALVERT CLIFFS - UNITS I & 2 3J.7-4 Revision 8
- v. j l
= 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
- 1 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.-
i-r i I 4 f k 4 i. i' 4 4 t t-i.' i. f. j- 1 l i. 5 i-1' 7
._.,..m _ ._ _ -.,_, _ , , - .
CRS 3.3.7 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.7.2 -------------------NOTE------------------- Testing of Actuation Logic shall include I
/
verification of the proper relay driver output signal. Perfonn a CHANNEL FUNCTIONAL TEST on each 92 days CRS Actuation Logic channel. SR 3.3.7.3 Perforg a CHANNEL FUNCTIONAL TEST on each 92 days containment radiation monitor sensor. Verify CRS high radiation setpoint Allowable Value is s 220 mR/hr. 3 SR 3.3.7.4 Perform a CHANNEL CALIBRATION on each 24 months containment radiation monitor instrument channel. SR 3.3.7.5 Perform a CHANNEL FUNCTIONAL TEST on each 24 months CRS Manual Actuation channel. SR 3.3.7.6 Verify CRS RESPONSE TIME is within limits. 24 months on a STAGGERED TEST BASIS h CALVERT CLIFFS - UNITS 1 & 2 3.3.7-3 Revision 9'?
DG-LOVS B 3.3.6 BASES the equipment falls within the specified operating characteristics defined by the manufacturer. The Surveillance verifies that the sensor channel responds to a measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift between successive calibrations to ensure that the channel remains operational between successive tests. CHANNEL CALIBRATIONS must be performed consistent with the plant specific setting analysis. The as found and as left values must also be recorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis. The requirements for this review are outlined in Reference 6. The settings, as well as the response to a Loss of Voltage and Degraded Voltage test, shall include a single point verification that the trip occurs within the required delay time as shown in Reference 1. The Frequency is based upon the assumption of an 24 month calibration interval for the - detemination of the magnitude of equipment drift in the plant setting analyses. E' REFERENCES. 1. UFSAR, Section 7.3
- 2. UFSAR, Chapter 8
- 3. Plant Set'.ing Analyses
- 4. Proposed IEEE Standard 279, August 1968
- 5. UFSAR, Appendix 1C
- 6. EN-4-104, " Surveillance Testing" CALVERT CLIFFS - UNITS 1 & 2 B 3.3.6-9 Revision E 8
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.f g ENGHIEfkt.p 3At TIT FEATUltE AuUAHDW 3DILM AN)I_nsnuvw G.i 7^db b
-4 FUseCTI0llAL UllIT ALL0lmBLE VALUES
( M SETEN NT E a f S. CONTAllMENT SUMP RECIRCULATION (RAS) - g e
$ a. Manual RAS (Trip Buttons) >
" . Not Appifcable Not (ylicable d -
- b. Refueling Water Tank - Low R 1 24 inches above tank 1 24 inches N ye tank -
bottom botton
~
- 6. CONTAIMMENf PURGE VALVES ISOLATION
- a. Manual (PURGE Valve Control Not Applicable Not Appifcable R
=
Switches) i' b. Containment Radiation - High Area -< 220 mr/hr
~
t: Monitor -< 220 mr/hr
- 7. LOSS OF POWER
- a. 4.16 kv Emergenc Bus Undervoltage F 2450 + 05 volts with 7 2450 + 105 volts with a w 33.t, ,2. (Loss of Voltage 210 second time d ay 2 1 0.Y second time delay
- b. 4.16 ky Emergency Bus Undervoltage 8 1 25 volts ha (OegradedVoltage) 3628 1 25 volts with a
[ 1 0.4 second t delayj 8 1 0.4 second time delay A E l As/5 '
.O
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. CONTAINMENT SIN RECIRCULA e -
g 5 a. Manual RAS (Trip Buttons) Not Applicable Not App 1tcable d
] E
- b. Refueling Water Tant - Low 1 24 inches'above tant 1 24 inches above tank
- 6. CollTAllelENT PURGE VALVES ISOLA Q ttom botton
- a. Manual (Purge Valve Control Not Appitcable Not Appitcable R. Switches)
Y b. Containment Radiation - Nigh 5 220 nr/hr $ 220 nr/hr O Area Monitor
- 7. S OF POWER
- a. 05 volts with
$R 'P>. 6 ?_ 4.16 (toss ofkv E-.g..ci Bus Undervoltage Voltage 21 h50 2450 + 105 volts with a
; second time ay 210.Ysecondtimedelay
- b. 4.16 ky Emergency Bus Undervoltage 1 25 volts th a (Degraded Voltage) 3628 + 25 volts with a '
[ 1 0.4 second delay 3 8 1 0.fsecond time delay /\ 0 -g J 3 o y, J . , o . . . . ., _r et-. ~, - 3 3 n
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M DISCUSSION OF CHANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER therefore, the DG LOVS Applicability will now include Mode 4. His constitutes an administrative change. This change does not affect the safe operation of the unit. l A.13 Not used.
- A.14 Current Technical Specification 33.2.1 Action 7.a requires that an inoperable channel be placed la trip or bypass within one hour. Action 7.b requires that within one hour all Smetional units receiving an input from the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 33.6 Condition A requires one or more functions with one sensor module or associated measurement channel inoperable be placed in trip or bypass in one hour. The ITS Condition A captures the technical intent of CTS Action 7.a and 7.b by requiring that all affected functions take the specified actions, therefore, the change is administrative. This change is consistent with NUREG-1432.
A.15 Current Technical Specification Table 3.3-4 specifies trip setpoints and allowable values for DG loss of voltage (Ignal functions. Improved Technical Specification 33.4 Table 33.41 only specifies the allowable values for the DG loss of voltage signal functions. The trip setpoints and allowable values contained in the CTS are dentical, therefore, only the allowable values are necessary to be specified for Operability. His change is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. This change is consistent with NUREG 1432. A.16 Current Technical Specification 3.3.2.1 does not contain Actions when more than two channels are inoperable, therefore, Specification 3.03 would be entered. CTS 3.03 provides one hour to correct the condition or a plant shutdown would be required. Improved Technical Specification 33.6 Action C provides one hour to restore all but two DG - Loss of Voltage channels to Operable status if more than two (three or four) channels were inoperable. 'he one-hour Completion Time is acceptable because it is consistent with the existing Completion Time in CTS 3.03 and allows a reasonable time to evaluate and take action to correct the degraded condition in an orderly manner. The requirements associated with a subsequent plant shutdown if two channels are not Operable in I hour is addressed in a separate Less Restrictive Discussion of Change. This change is consistent with NUREG-1432. A.17 Current Technical Specification 43.2.13 requires a response time test for DG LOVS. He actual time allowed for the instmmentation portion of the response time is located in the UFSAR. The actual response times were relocated to the UFSAR in a previous license amendment consistent with NRC generic guidance. The UFSAR only provides a response time for the loss of voltrge DG LOVS; no response time is provided for the degraded voltage DG-LOVS. The response time in the UFSAR is the same as the maximum Allowable Value. The ITS maintains the Allowable Value in ITS SR 33.6.2. In addition, ITS SR 3.8.1.15 maintains the DG start time portion of the response time test. Therefore, CTS 43.2.13 is not required to be maintained in the ITS and has been deleted. Since all parts of the current requirement are being maintained in the ITS, this deletion is considered administrative. CALVERT CLIFFS - UNITS 1 & 2 33.6-3 Revision 8
DISCUSSION OF CHANGES SECTION 3.3.6 - DIESEL GENERATOR - LOSS OF POWER TECHNICAL CHANGES - MORE RERTRICTIVE M.1 Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additional inoperable channel to be placed in trip or bypass, improved Technical Specification 3.3.4 Action B will require one channel to be placed in trip and one channel to be placed in bypass in one hour, nis change essentially places a one-hour time limit, where none previously existed, to perfoim the Actions. This change is, therefore, a more restrictive change. He change will not adversely affect plant safety, because its appropriate for a time limit to be set for placing one channel in bypass and one channel in trip when two channels are inoperable. His change is consistent with NUREG-1432. M.2 Not usei. l TECHNICAL CHANGES - RELOCATIONS None TECHNICAL CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification 33.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification 3.3.6 will not contain this information. This is an informational column which is more appropriate for the Bases, ne number of channels to trip will not be changed. He information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0. However, any hardware change to the number of channels to trip will require a design change. The Bases Change Control Program will ensure that changes to this requirement receive appropriate review. This change is a less restrictive movement of details change with no impact on plant safety. This change is consistent with NUREG-1432. LA.2 Not used. l LA.3 Not used. l TECHNICAL CHANGES - LESS RESTRICTIVE L.1 Not used. l L.2 Current Technical Specification 3.3.2.1 does not contain any actions if the Required Actions l cannot be met within the allowed Completion Times. Therefore, Specification 3.0.3 would be entered. Improved Technical Specification 3.3.6 adds an Action (Action D), which would require the applicable Condition and Required Actions for the associated DG made ir. operable by DG-Loss of Voltage instrumentatiors to be entered. This change is appropriate because the DG-Loss of Voltage instrumentation essentially renders the affected DG incapable of starting automatically, thus the affected DG would be unable to perform it safety function. Entering the applicable Actions of LCO 3.8.1 is appropriate to ensure all l Required Actions for an inoperable DG are co npleted. It would be imprudent to shut down CALVERT CLIFFS - UNITS 1 & 2 3.2.6-4 Revision 8
DG-LOVSM _h J.3.6
$URVEILLANCE REQUIREMENTS
$URVE!LLANCE FREQUENCY F$R3.3.6.1 form CHANNEL CHECK. It ho SR 3.3.6 Perform CHANNEL FUNCT'10NAL TEST. 92 days SR 3.3.6.h . Perform $ CHANNEL CALIBRATION'with setpoint months 37l -
Allowable Values as follows:
- a. Degraded Voittg(_ Function 2 Y and $ IMP 1 #1366.3 C e d nd
- b. Loss of Voltage Function 2 V and s V
,, g
' Time delay: 2 seconds and
-s seconds .
O gr. - k CEOG $15 3.3 29- Rev 1, 04/07/95 i , .
DG-LOV$M 5 3.3.6 h PASES SURVEILLANCE 1R ,3.3.6 ontinued) REQUIRLMENTS ensure that the channel remains operational between successive tests. CHAMEL CAllBRATIONS t be perfomed consistent with the plant specific 7 n analysis. The as found and as left values must also be racorded an - reviewed for consistency with the assumptions of the surveillance interval extension analysts. The requirements for t)ts review are outilned in Reference 4W Hr The detnoMt:3 as well as the response to a loss of Voltage 02 and Degraded Voltage test, shall include a single point ' verification that the trip occurs within the required delay time as shown in Refe 1. The Frequency is based upon the assumption of-an reination of the a nthofcalibration itude equipment interval for the @ drift in the-analysts. REFERENCES 1.hFSAR,Section 2.$5AR, Chapter hh
~
[ g
- 3. uon systea SelecKof Trip Setpoi 5.
IEEE Standard 279 60 CFR 50 Aendix VT.DC 2D h Afe'6) ( 6. h EtJ-%ou, "Sur<dl.,grd,3 " @g I L +4e, to 0$W/ fro % R.6,0<4on t.fre dJed - be 6 Iqtf
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CE0G STS 'B 3.3-108 Rev 1, 04/07/95
'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 changa. Appropriate CTS and - STS markups have also been made,- In addition, the sxond Applicabilhy [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 additionaljustification for -
not including this Applicability in the ITS. 4 I.. 4
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e
DG-LOVS 3.3.6 3.3 INSTRUMENTATION 3.3.6 Diesel- Generator (DG)-Loss of Voltage Start (LOVS) LCO 3.3.6 Four sensor modules and measurement channels per DG for the Loss of Voltage Function, four senso* modules and measurement & channels per DG for the Degraded Voltage Function shall be 7 OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4. 8 ACTIONS
-t -------------------------------------NOTE-------------------------------------
Separate Condition entry is allowed for each Function. CONDITION REQUIRED ACTION- COMPLETION TIME A. One or both Functions A.1 Place sensor module 1 hour with one sensor in bypass or trip. module or associated measurement channel AND per DG inoperable. A.2.1 Restore sensor module 48 hours and associated measurement channel to OPERABLE status. og A.2.2 Place the sensor 48 hours module in trip. CALVERT CLIFFS - UNITS 1 & 2 3.3.6-1 Revision 48
DG-LOVS B 3.3.6 BASES ESFAS actuation. The diesel loading has been included in the delay time associated with each safety system component requiring DG supplied power following a loss of offsite power. The analysis assumes a nonmechanistic DG loading, which does not explicitly account for each individual component of the loss of power detection and subsequent actions. This delay time includes contributions from the De start, DG loading, and Safety Injection System component actuation. The response of the CG to a loss of power must be demonstrated to fall within this analysis response time when including the contributions of all porti.ns of the deley. The required channels of LOVS, in conjunction with the ESF systems powered from the DGs, provide plant protection in the event of any of the analyzed accidents discussed in Reference 2 in which a loss of offsite power is assumed. Loss of Voltage Start channels are required to meet the redundancy and testability requirements of Updated Final Safety Analysis Report (UFSAR). Appendix 1C (Ref. 5). The delay times assumed in the safety analysis for the ESF equipment include the 10 second DG start delay and the appropriate sequencing delay, if applicable. The response times for ESFAS actuated equipment include the appropriate DG loading and sequencing delay. The DG-LOVS channels satisfy 10 CFR 50.36(c)(2)(11), Criterion 3. LC0 .The LCO for the LOVS requires that four channels per bus of each LOVS instrumentation Function be OPERABLE in M0nE3 1, 2, 3, and 4. The LOVS supports safety systems associated 9 with the ESFAS. Actions allow maintenance bypass of individual sensor channels. The plant is restricted to 48 hours in a maintenance bypass condition before eit?.2r restoring the CALVERT CLIFFS - UNITS 1 & 2 B 3.3.6-3 Revision 6 8
DG-LOVS B 3.3.6 BASES Function to four channel operation (two-out-of-four logic) or placing-the _ channel in trip (one-out-of-three logic). Loss of LOVS Function could result in the delay of safety system actuaticn when required. This could lead to unacceptabic consequences during accidents. During the loss of offsite power, which is an anticipated operational occurrence, the DG powers the motor driven auxiliary feedwater pump. Failure of this pump to start would leave two turbine driven pumps as well as an increased potential , for a loss of decay heat removal through the secondary , system. & [ Only Allowable values are specified for each Function in the' LCO. Nominal trip settings are specified in the plant specific procedures. The nominal settings are selected to ensure that tne setting measured by CHANNEL FUNCTIONAL TESTS does not exceed the Allowable Value if the bistable is perfoming as required. Operation with a trip setting less conservative than the nominal trip setting, but within the Allowable value, is acceptable, provided that operation and ' testing are consistent with the assumptions of the plant specific setting calculation. A channel is inoperable if its actual trip setting is not within its required Allowable Value. The Allowable Values and trip settings are established in order to start the DGs at the appropriate time in response to plant conditions in order to provide emergency power to s start and supply the essential electrical loads necessary to safely shutdown the plant and maintain it in a safe shutdown condition. APPLICABILITY The DG-LOVS actuation Function is required in MODES 1, 2, 3 g and 4 because ESF Functions are tiesigned to provide protection in these MODES. h CALVERT CLIFFS - UNITS 1 & 2 B 3.3.6-4 Revision gg 9 l
p @ erun 3.3.7 o 3.3 INSTRUNENTAi!0N~ SfMor MedMCS " ' 3.3.7 Containmenthe Isolado]n Signal (@)(()d}4g9 ND Ltc 3.3.7 'r . containment radiation mentter hanna i Actuation
" 8 I
- and one Manualc7 t
-E gg,g,p APPLICAtlLITY:
' During CORE ALTERATI '
During movement of irr lated fuel assembites wit containmentg , s eco.4. qs. <s.r ACTIONS ~ CONDITION REQUIREDACTION COMPLETION TINE A. One radiation monttor A.1 channel inoperable. P the affected 4 hotrs c one in trip. e,e m egnob, o c U
; qAorjated me4 pre.wd A.2.1 Suspend CORE 3,
ALTERATIONS.
!modtatelfi AllD A.2.2 Suspend movement of Innedtatelfn irradiated fuel ~~ ~
~ assemblies within contalnment.
r0b?"b'? 1'L'!. 1 B.I qut_ red Manual 8.1 Place and maintain immediately or 4WdnaHb containment purge and Actuation Logic tral exhaust valves in @. inoperable, closed position. CEOG STS 3.3-30 Rev 1, 04/07/95
, d i
f b_mmm 3.3J 94 ,' ACTIONS CONDITION REQUIRED ACTI0lt COMPLETION TIME
~
B. (continued) . 8.2 Enter appilcable lamediately More than one Conditions and Required Actions for radiation monitor affected valves of channel inoperable. LC03g QR atJ1Fn valvePN h Required Action and mace ~ Inoperable by associated Completion isolation Time of Condition A i instrumentation. F not met. n__ _
=~_ -
Mnsor Wdelt or suoc,Pajch rney g SURVE!LLANCE REQUIREMENTS SURVEILLANCE
,) FREQUENCY SR 3.3.7.1 .
Perform a CHANNEL CHECX on each containment 12 hours radiation monitor etEEE1. ' sew sM b SR 3.3.7 Perform a CHANNEL FUNCTIONAL TEn each containee radiation monitor k9thys A$1 ble Ya ah ' 1 A - i 65 (continued) 0% CQUA\ h N CEOG STS 3.3 31 Rev 1. 04/07/95 s E%Y
i
. DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.2-. INSTRUMENTATION also provides surveillance requirements for demonstrating the function Operable. His change maintains consistency within the ITS and is consistent with the cunrent Technical Specification requirements.
- 35. NUREG 1432 Surveillance Requirement 33.3.1 requires quarterly testing of the RTCBs CTS Table 431 requires the RTCBs be tested on a monthly basis. Calvert Cliffs has retained the existing more frequent testing of the RTCDs consistent with the licensing basis and CEN 327, "RPS/ESFAS Extended Test Internal Evaluation," June 2,1986, including Supplement 1, dated March 3,1989, 36.
NURCG 1432 Condition E of LCO 333 is stated as "One or more functions with two or more
. . . Inoperable, nis spec;fication is not " function" based, i.e., the functional parameters that can be inoperable under this LCO are already stated in Condition E. Here are no other functions covered by this LCO which depend on these functions. He NUREG statement is not used in any l other condition of the LCO and is in error. De statement is deleted from ITS 333 consistent with the design of Calvert Cliffs.
- 37. NUREG-1432 Condition B of LCO 33.7 requires placing the purge valves in the closed position and entering the applicable conditions of LCO 3.63 for the inoperable purge valves which result from an inoperable manual actuation or automatic actuation channel. These actions are in error and have been corrected in ITS 33.7 to require either the valves be c:*ed, or the actions of LCO3.93 be entered for inoperable valves. The STS reference to LCO 3.63, Containment isolation Valves, is inappropriate since that LCO applies in Modes I, 2, 3, and 4 whereas, LCO 33.7 is applicable during core alterations and movement of fuel. LCO 3.93, however, has the same applicability of LCO 33.7 and is the appropriate reference. The STS is also in error to require both actions be accomplished since the actions are somewnat redundant. Closure of the purge valves performs the safety function of the automatic and manual functions covered by the LCO. The actions of LCO 3.93 would require that core alterations and fuel movement be suspended which removes the unit from the mode of applicability. Therefore, ITS 33.7 Condition B replaces the "and" requirement in the STS with an "or" to indicate that these actions accomplish the same desired result. This change is also consistent with the requirements of the STS for each of the other PWR owners groups.
4
' 3 8. The Applicability of NUREG LCO 3.3.1 is MODES I and 2.- The ITS Applicability ref ences Table 33.1-1, and Table 33.1-1 has a column specifying the Applicability for each Fm. on in the Table. This method is necessary since each Function does not have the same Applicability; two of the Functions are only required in MODE 1215% RTP, This change is also consistent <
with the Calvert Cliffs CTS Table 33 1.
- 39. NUREG-1432 SR 33.9.2, Note 2, requires testing of relays after 24 hours of Mode 5 operation for relays that cannot be tested during operation. These relays would cause a closure of the letdown line which is undesirable during unit ope ation. The CVCS actuation logic is currently not required by the Technical Specifications. The 24 month test frequency proposed in ITS SR 33.9.2 is consistent with the CTS Table 43 2 footnotes 2-6 for other ESFAS functions actuation logic which cannot be tested online. The requirements of the STS would ' impose an unnecessary more restrictive change on plant operations and are not adopted. _
CALVERT CLIFFS - UNITS 1 & 2 33 6 Revision S l
- 45. To resolve NRC comments 3.3.81, 33.8 2, and 3.3.8-3, the ITS was revised to' include the --
"During Core Alterations" and "During movement ofirradiated 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 Dev*ation 15 was revised-to provide additional justification related to' the Modes-of Applicability not retained and associated actions for the Control Room Recirculation Signal, s
CRRS 3.3.8 - 3.3 INSTRUMENTATION 3.3.8 Control Room Recirculation Signal (CRRS) LCO 3.3.8 One CRRS trip circuit and measurement channel shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4 During CORE ALTERATIONS, g During movement of irradiated fuel assemblies. ACTIONS
' CONDITION REQUIRED ACTION COMPLETION TIME A. CRRS trip circuit or A.1 Place one Control I hour measurement channel Room Emergency inoperable in MODE 1 Ventilation System g
2, 3. or 4. train in recirculation mode-with the post-LOCI g filter fan in service. B. Required Action and B.1 Be in MODE 3, 6 hours associated Completion g Time of Condition A AND not met. B.2 Be in MODE 5. 36 hours _ 1 w CALVETT CLIFFS - UNITS 1 & 2 3.3.8-1 Revision 0 l
CRRS 3.3.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. CRRS trip circuit or C.\ Place one CREVS train Immediately measurement channel in recirculation mode inoperable during with post-LOCI filter CORE ALTERATIONS or fan in service, during movement of irradiated fuel 08 assemblies. g C.2.1 Suspend movement of Immediately irradiated fuel assemblies. , I AND C.2.2 Suspend CORE Immediately ALTERATIONS. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on the CRRS 12 hours measurement channel. E SR 3.3.8.2 Perform a CHANNEL FUNCTIONAL TEST on the 92 days 8 CRRS radiation monitor trip circuit and measurement channel. Verify CRRS high radiation setpoint 8 Allowable Value is s 6E4 cpm above normal background. CALVERT CLIFFS - UNITS 1 & 2 3.3.8-2 Revisiong8
CRRS 3.3.8 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.3.8.3 Perform a CHANNEL CAllBRATION on the CRRS 24 months p radiation monitor trip circuit and measurement channel. CALVERT CLIFFS - UNITS 1 & 2 3.3.8-3 Revision D'E
CRRS B 3.3.8 I 1 BASES i APPLICABLE The CRRS, in conjunction with the CREVS, maintains the SAFETY ANALYSES control room atmosphere within conditions suitable for prolonged occupancy throughout the duration of any one of the accidents discussed in Reference 1. The radiation exposure of control room personrul, through the duration of any one of the postulated accidents discussed in " Accident Analysis," Updated Final Safety Analysis Report (UFSAR), Chapter 14 (Ref.1), meets the intent of UFSAR, Appendix IC l (Ref.2). l The CRRS satisfies the requirements of , 10 CFR 50F36(c)(2)(ii), Criterion 3. t i LC0 LC0 3.3.8 requires one channel of CRRS to be OPERABLE. The required channel consists of a trip circuit and the gaseous 8 radiation monitor (measurement channel). The specific Allowable Value for the setpoint of the CRRS is listed in the SRs. Only the Allowable Value is specified for the trip Fenction in the LCO. Operation with a trip setpoint less conservative than the nominal trip setpoint, but within its
- Allowable Value, is acceptable.
Operation and testing are consistent with the assumptions of the plant specific setpoint analyses. A channel is inoperable if its actual trip setpoint is not within its required Allowable Value, i
- The Bases for the LCO on the CRRS is that one channel of Airborne radiation detection and trip circuitry is required to be OPERABLE to ensure the control roer isolates on high 9 gaseous concentration. The Allowable Value was established as part of original plant design. It provides reasonable assurance of safety for Control Room personnel.
b CALVERT CLIFFS - UNITS 1 & 2 B 3.3.8-2 Revision p'?
A B_ASES APPLICABILITY The CRRS Functions must be OPERABLE in MODES 1, 2, 3 and 4, during CORE ALTERATIONS, and during movement of irradiated 7 fuel assemblies to ensure a habitable environment for the control room operators. ACTIONS A CRRS channel is inoperable when it does not satisfy the OPERABILITY criteria for the channel's function. The most common cause of cMnnel inoperability is outright failure or drift of the trip circuit or measurement channel sufficient to exceed the nominal trip setpoint. Typically, the drift is hot large which at worst would result In a delay of actuation rather than a total loss of function. This detemination is generally mado during the perfomance of a CHANNEL CAllBRATION when the process instrument is set up for adjustment to bring it to within specification. CHANNEL FUNCTIONAL TESTS identify trip circuit drift. If the trip setpoint is not within the Allowable Value, the channel is inoperable and the appropriate Conditions must be entered. Au.l . B .1. B . 2. C . l . C . 2.1. a nd C . 2. 2 Conditions A, B, ano C are applicable to the CRRS trip circuit and measurement channel. Condition A applies to the failure of the CRRS trip circuit or measurement channel in MODE 1, 2, 3, or 4. Entry into this Condition requires action to either restore the failed channel or manually perform the CREVS function (Required Action A.1). The g Completion Tine of 1 hour is sufficient to complete the Required Actions, if the channel cannot be restored to OPERABLE status, the plant must be brought to a MODE in which the LCO does not apply. To r hieve this status, the plant must be brought to at leM
- JOE 3 within 6 hours and to MODE 5 within 36 hours. mpletion Times of 6 hours and 36 hours for reeching nxE and 5 from MODE 1 are reasonable, based on operatir' xperience and normal cooldown rates, for reachin; ic required MODE from full 3
CALVERT CLIFFS - UNITS 1 & 2 0 3.3.8-3 Revisiong3
CRRS B 3.3.8 BASES power conditions in an orderly manner and without challenging plant safety systems or operators. Condition C applies to the failure of the CRRS trip circuit or measurement channel during CORE ALTERATIONS or when moving irradiated assemblies. The Required Actions are g Immediately taken to place one OPERABLE CREVS train in the recirculation mode with post-LOCA fans in service or to suspend CORE ALTERATIONS and movement of irradiated fuel assemblies. The completion Time recognizes the fact that the radiation signal is the only Function available to initiate control room isolation in the event of a fuel handling accident. SUR\'EILLANCE SR 3.3.8.1 REQUIREMENTS Perfonnance of the CHMNEL CHECK once every 12 hours ensures that a gross failure of instrumentation has not occurred. CHANNEL CHECK will detect gross channel failures thus, it is key to verifying the instrumentation continues to operete properly between each CHANNEL CALIBRATION. Acceptance criteria are determined by the plant staff based on a combination of the channel instrument uncertain' ties, including indication and readability. If a channel is 3 outside the criteria, it may be an indication that the transmitter or the signal processing equipment has drifted nutside its limit. The Frequency, about once every shift, is based on operating experience that demonstrates the rarity of channel failure. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel OPERABILITY during normal operational use of the displays associated with the LCO required channels. In addition, a downscale alann and upscale alarm immediately alert operations to loss of the channel. 4 . CALVERT CLIFFS - UNITS 1 & 2 B 3.3.8-4 Revision #5'
CRRS B 3.3.8 BASES SR 3.3.8.2 3 A CHANNEL FUNCTIONAL TEST is perfomed on the control room radiation monitoring channel to ensure the entire channel will perfom its intended function. The Frequency of 92 days is based on plant operating experience with regard to channel OPERABILITY and drift. SR 3.3.8.3 3 t, CHANNEL CAllBRATION is a check of the CRRS channel including the sensor. The Surveillance verifies that the channel responds to a measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for channel drift between successive calibrations to ensure that the channel remains operational between successive surveillances. CHANNEL CALIBRATIONS must be performed consistent with the plant specific setpoint analysis. The Frequency of 24 months has been shown by operating experience to be adequate to detect any failures. REFERL.1CES 1. UFSAR, Chapter 14
- 2. UFSAR, Appendix 10 t
s CALVERT CLIFFS UNITS 1 & 2 B 3.3.8-5 Revision # 9
$pec. C.ea4.., 3. '5, 3 Add Technical Spccification 3.3.8, " Control Room Recirculation Sipal (CRRS)."
e s es f O
338 3.3 INSTRUMENTATION g 3.3.8 Control Room Recirculation Signal (CRRS) LCO 3.3.8 One CRRS trip circuit and measurement channel shall be OPERABLE. APPLICABILITYt. MODES 1, 2, 3, and 4, During CORE ALTERATIONS, g During movement of irradiated fuel assemblies. ACTIONS 6 CONDITION REQUIRED ACTION COMPLETION TIME A. CRRS trip circuit or A.1 Place one Control I hour measurement channel Room Emergency inoperable in MODE 1, Ventilation System 2, 3 or 4. train in g recirculation mode with the post-LOCI g filter fan in service. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A g 6NR not met. B.2 Be in MODE 5. 36 hcurs CALVERT CLIFFS - UNITS 1 & 2 3.3.8-1 Revision 0 y 2 of 4
hYbb i h(N 3 0 ACTIONS (continued) CONDITION REQUIRED ACTION C0tfLET10N TIME C. CRRS trip circuit or C.1 Place one CREVS train Imediately measurement channel in recirculation mode inoperable during with post-LOCI filter CORE ALTERATIONS or fan in service. during movement of irradiated fuel Q3 q assemblies. C.2.1 Suspend movement of Imediately irradiated fuel assemblies. gg C.2.2 Suspend CORE Imediately ALTERATIONS. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.1 Perfom a CHANNEL CHECK on the CRRS 12 hours measurement channel. E SR 3.3.8.2 Perform a CHANNEL FUNCTIONAL TEST on the 92 days 8 CRRS radiation monitor trip circuit and measurement channel. Verify CRRS high radiation setpoint g Allowable Value is s 6E4 cpm above nomal background. i CALVERT CLIFFS - UNITS 1 & 2 3.3.8-2 Revisiong8 y 3 o G 'l 1
1 j _ (Otw) h CRRS 3.3.8 4
- . SURVEILLANCE REQUIREENTS (continued)
! SURVEILLANCE FREQUENCY i I SR 3.3.8.3 Perfom a CHANNEL CALIBRATION on the CRR$ 24' months g i radiation monitor trip circuit and
- . measurement channel.
2 1 .l 1 I )
- i j l
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l 4 b 3 t 1 4 o@ 4 : 3 g CALVERT CLIFFS - UNITS 1.& 2 3.3.8-3 Revision 9'E
4, , c. . . . ., 1.,. . e . O f &
3 [rw > 3.3 INSTRUMENTATION 3.3.8 Control Room Recirculation Signal (CRRS) LCO 3.3.8 One CRRS trip circuit and measurement channel shall be OPERABLE. APPLICABILITY: MODES 1, 2, 3, and 4, During CORE ALTERATIONS, g During movement of irradiated fuel assemblies. ACTIONS I CONDITION REQUIRED ACTION COMPLETION TIME A. CRRS trip circuit or A.1 Place one Control 1 hour measurement channel Room Emergency inoperable in MODE 1 Ventilation System 2, 3, or 4. train in 2 recirculation mode with the post-LOCI g filter fan in service. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion g Time of Condition A AM not met. B.2 Be in MODE 5. 36 hours i CALVERT CLIFFS - UNITS 1 & 2 3.3.8-1 Revision 0 py 2 oF 4 i _ _ _ , . -_ - -- - ~ --
e-> 38 ACTIONS (continued) CONDITION REQUIRED ACTION COWLETION TIME C. CRRS trip tircuit or C.1 Place one CREYS train Imediately measurement channel in recirculation mode inoperable during with post-LOCI filter CORE ALTERATIONS or fan in service, during movement of irradiated fuel 93 assenblies. g C.2.1 Suspend movement of Imediately irradiated fuel assemblies. Alfa C.2.2 Suspend CODE Imediately ALTERATIONS. SURVEILLANCE REQUIREMENTS
, SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on the CRRS 12 hours measurement channel. 3 SR 3.3.8.2 Perform a CHANNEL FUNCTIONAL TEST on the 92 days 8 CRRS radiation monitor trip circuit and measurement channel.
Verify CRRS high radiation setpoint 8 Allowable Value is s 6E4 cpm above nomal background.
.c t
CALVERT CLIFFS - UNITS 1 & 2 3.3.8-2 Revision Ji 8 pacp 3 oC 'l
3 b# - SURVEILLANCE REQUIREMENTS (continued) SURVE!LLANCE FREQUENCY SR 3.3.8.3 Perfom a CHANNEL CALIBRATION on the CRRS 24 months g radiation monitor trip circuit and measurement channel. s i
.pp 'l of 4 CALVERT CLIFFS -' UNITS 1 & 2 3.3.8-3 Revision 9'E I
3.3 INSTRLMENTATION hk 3.3.8 Control Ro a stiinal (C )@g _ _ _ LC0 3.3.8 One C channel sha u , , e , a .s . 4 . m . u s_ ~ a_ . be DPihA8Lt. b APPLICABILITY: MODES 1 kT[MTOR3.*C . ;4_d. During
@h During movement of trradiated fuel assemb11es. < i h ACTIONS I CONDITION REQUIRED ACTION COMPLETION TIME _
A., ~
# Manual
.uation L tc, or IC A.1 ( i-n---NOTE ------Q one or no required /PinceContr Room ) ((h W A channels f ,
Emergency tr Cleanup Systes 08 partic ate / lodine or toxic EACS) in gaseo ] radiation s protectio mode automatic 8 annitatilinoperab e n N00E 1, 2, 3 or 4. tra for to toxi gas
=- -_=<
pr ection mod t perable. C6P6 trp strser4 --------- ------- ' A -."i'# "8 S*N -- Place one 1 hour gg. @ id&_pfshteer ( ther b 1._ serv.yc .] B. Required Action and 8.1 Be in MODE 3. assoctated Completton 6 hours line.cf_Cond1 tion.A' Alg) not met. /A 8.2 y W Be in MODE 5. 34 hours (continued) CEOG $15 3.3 33 Rey 1, 04/07/95
~.
cf'%#9O ACTIONS (continued) CON 0lT10el REQUIRED ACTION CONPLETION TIME C. I !r ' Actu F annel
$ Man er so Legt er 1 ,
C.1' ' NOTE-P1 e CREACS s protec G toxic mode i h pa i f aut c tranaf ate ne to ten gas eous' ; lati pro ten made monit# T noserable 1 rable. W nuu during i 0
,W (- -- u>
ALTERATIOQlEorduring. Place one tenedtately movement of irradiates' train in fuel asseabites. toestari _,, h(IPC'da h,'*) 0PJ.S I1ripcireu gg I*
- or measurciscat C.t.1 Suspend movement of g g\ Ismediately trradiated fuel assemblies.
. ) C .2 5 p lame tely] h AND C.t suspend CORE lamediately ALTERATIONS.
$URVEltt.VeCE REQUIREMENTS SURVEILLANCE FREQUENCY SR '.3.8.1 3
Perform a CHANNEL CHECK on the (Cadila
~
12 hours control roce radiation monitor channe$ l. (continued) CEOG STS 3.3-34 Rev 1, 04/07/95 9 6'W'
_l- ::,- s, ans+ .a3 e w.w a Megjorem(nk f 3*3*3
- SURVEILLANCE REQUIREMENTS (continued) *
$URVitLLANCE f FREQUENCY SR 3.3.8.1 Parform a CH4 CIEL FUNCTIONAL TE en the i days doorted CafDredtation monito 1. _
- Verify Allowab e alue high redletten settelet " 8 b'I '" g[
background. j 6E4) cpa above normal
,y hpd to Re.]
ran J.J.W.J --.-
)
-f WIC
- 1. Survet ance of Actuation Logic shall-inc1 vertftcation of the proper tion of each initiation relay.
- 2. lays associated with plant equipmen that cannet be operated during plan [
operetton are only required to be . i' tested during each N00E 5 entry exceeding 24 hours unless test within the previous 6 months. a Perform a CHANNEL FUNCTIONAL T T on the [31] days reautred CRIS Actuation Logi channel. ; SR 3.3.8 Perfore_a EL CALIBRATION on the [ months 3 cG_- radiation monito chanel. trie_ den.N sdmessortmenf ) h 3.3. . ( 15R Perform a CHANNEL F required CRIS Manua ONAL TEST on the rip channel. [14] thsI r
}
SR 3.3.8 Verify respon'e s time quired CRIS channel is within I s. [18] s L- - J f
)
CEOG STS 3.3-35 Rev 1, 04/07/95
~.
s .=Ms'_k 4
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREGol432 SECTION 3J- INSTRUMENTATION System (RCS) temperature is > 385'F for Unit 1, and > 325'F for Unit 2. His change is consistent with the requirements of the Calvert Cliffs Low Presst're Overpressure Protection Specification, which requires only manual operation of the Figh pressure safety injection pumps when RCS temperature is s 385'F for Unit I, and s 325'F for Unit 2. This change is consistent with the Calvert Clifts current licensing basis.
- 9. Table 3.3.41 contains a Modes column which requires all the ESPAS functions to be Operable in Modes 1,2, and 3. This is the same Applicability as required by the Applicability section of Specification 3.3.4, and the CTS. His change deletes the Modes column from the Table and moves Footnote (d) from the Modes column to the function column. Footnote (d) allows the Main Steam Line isolation Signal to not be Operable when all Main Steam Line Isolation valves,
=% h are isolated by a Main Steam Line Isolation Signal, are closed.
- 10. Table 3.3.41 Function 1.b Footnote (b) states that SIAS is required as pemdssive to initiate Containment Spray. His Footnote will be changed to state that SIAS is required to start the Containment Spray Pum(s. His change is consistent with the Calvert Cliffs design.
I1. Surveillance Requirement 3.3.5.1 (Channel Functional Test) is modified by a Note which allows relays associated with plant equipment that cannot be operated during plant operation to only be tested during each Mode $ entry execeding 24 hours, unless tested during the previous 6 months. His change will revise the Frequency in the Note to require the valves to be tested once per 24 months. This change is consistent with Calvert Cliffs current licensing basis.
- 12. Table 3.3.51 lirts each individual function and the applicable Modes associated with each function. This change will add line items for the Manual Trip and Automatic Actuation Logic channels for each function. His was necessary because the Modes of Applicability for the Manual Trip and Actuation Logic channels are not the same, ne Modes of Applicability for Manual Trip are Modes 1,2,3, and 4, and the Modes of Applicability for Actuation Logic channels are Modes 1,2, and 3. His change is a result of the Calvert Clifts design.
- 13. Surveillance Requirements 3.3.2.2 and 3.3.2.3 require a Channel Functional Test on the Rate of Change of Power and on the automatic bypass temoval feature every 92 days, resp:ctively. This change will revise the Frequency for these Surveillance to once within 7 days prior to each reactor startup for SR 3.3.2.2, and every 24 months for SR 3.3.2.3. This change is consistent wuh the current Calvert Cliffs licensing basis.
- 14. All Reviewers Notes will be deleted, These Notes are for the NRC reviewers and are not intended to be included in the specific plant's improved Technical Specifications.
- 15. Calvert Clifts does not currently have a Technical Specification for the Control Room isolation Signal. Specification 3.3.8 will be added to Calvert Cliffs ITS. He Specification is named Control Room Recirculation Signal. The NUREO.1432 version of this Specification will be revised to be consistent with the Calvert Cliffs design and the current testing performed on the components. No credit is taken in the accident analysis for manual initiation of the control room isolation, therefore, the NUREG-1432 Actions and Surveillance Requirements associated with manual operation are not adopted, in addition, no credit for filtration is assumed in the accident analysis for the gas decay tank supture, therefore, the MODE 5 and 6 Applicability and associated Actions have been deleted. NUREG 1432 Required Action C.2.2 has not been CALVERT CLIFFS - UNITS I & 2 3.32 Revision 8 i
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.3 - INSTRUMENTATION adopted since it is not required by the Applicability; once NUREO 1432 Required Actions C.2.1 and C.2.3 are completed, the LCO is no longer required to be met (and tims Required Action C.2.2 is not required to be completed). He Notes in Actions A and C have been deleted since the Calvert Cliffs design does not include a toxic gas mode.
- 16. Specification 3.3.10 will not be included in the improved Technical Specifications because Calvert Cliffs does not have a Shield Buildirig Filtration Actuation Signal. His change is consistent with Calvert Cliffs design.
- 17. Specification 3.3.12, which requires that the Remote Shutdown System be Operable, has been changed to require the Remote Shutdown Instrumentation to be Operable; the control circuits and transfer switches are not included in this Specification. As noted in the Safety Evaluation Report for License Amendments 120 (Unit 1) and 102 (Unit 2), dated August 6,1986, the remote shutdown instrumentation is provided for monitoring purposes only. This is consistent with the position stated in previous Safety Evaluations for other License Amendments, such as >
Amendment 88 for Units (dated November 17, 1983). nat Safety Evaluation stated that the instrumentation was used to monitor key safety parameters and that no automatic features were actuated from the remote shutdown instrumentation. Therefore, the Technical Specification only requires the instrumentation to he Operable, not the control circuits and transfer switches. Due to this change, SR 3.3.12.2, which verifies the control circuits and transfer switches are capable of performing their intended function, has been deleted.
- 18. He Note in Specification 3.3.12 SR 3.3.12.3 which excludes the Reactor Trip Breaker Indication from the channel calibration is being modified to also exclude the Reactor Trip Breaker Indication. The Reactor Trip Breaker Indication channels indicate whether the Reactor Trip Breakers are open or closed, which does not require a channel calibration. %1s change is consistent with Calvert Cliffs current licensing basis.
- 19. This change removes part of the Applicability for LCO 3.3.6. "When associated DO is required to be Operable by LCO 3.8.2, 'AC Sources . Shutdown"' is removed because the Diesel Generator Loss of Voltage Start (DG LOVS) is required for ESFAS systems to function in any accident with a loss of offsite power, and ESFAS Applicability is Modes I,2, and 3 As noted in the Safety Evaluation Report for License Amendments 198 (Unit 1) and 175 (Unit 2), dated September 27,1994, the undervoltage instrumentation is only required in Modes 1 through 3.
This is consistent with the discussion provided in our application for a license amendment dated November 2,1993. Hat letter states that an EDO is required during shutdown and refueling to ensure adequate AC electrical power is available to mitigate events such as a fuel handling incident or a loss of shutdown cooling. Due to the reduced pressure and temperature conditions of the reactor coolant system during shutdown conditions, these events develop more slowly and the results are less severe than the events which occur at full power. Thus, additional time is available for the operator to evaluate plant conditions and respond by manually operating enginected safety feature components as required to successfully mitigate the consequences of the event. These discussions support not including Modes 4 through 6 and movement of irradiated fuel assemblies, llowever, to be consistent with the AC Sources Operating requirements (CTS 3.8.1.1, ITS 3.8.1), which requires that the DG auto start and sequence loads following a loss of offsite power, the Mode 4 requirements will be added. , CALVERT CLIFFS UNITS I & 2 3.33 Revision 8
h M *. SA$t$ , SACKGROUND frin 1stantnis and A11awable VQgt1 (continued) Idescription of th methodology used to e colate the tr p l setpoints inel ng their expiteit un rtainties is Iarovidedln'P nt Protection systen lection of,Tr thetpointValu ' (Ref. 2). The act entered int he bistable is norma y attil more nominal tri etpoint h iconservati than that specified the A110 web'! Value' to'{ account rchangesinrandom asurement error detectable; I a, C FATIONAL 1[57.fDne exaayiv er such a cnangs n suremen YFiri drin during the survet11ance interval. If the mensvr setpoint does not exceed the Allowable Value, the61 ts ,cnnstdarad DPERABLE.
- s %4tiosieri3 Q3 TiYpeim in a6 roHCT"ETIFTEe ni wenia 1alue w 11 ensurh that safety Li ts are not vloist during antict ted operational currences the conseque es of Design Bas Accidentsw(A00s) ill be ccer f.,le, r ding the plant is ersted from withi the LCOs at t onset of the A00 or accident and the equipment functions as designed.
APPLICABLE Ihe in_ con.ivnction with the fontrol Room [mergench '- SAFETY ANALYSES LCleanupysten LylEACD, maintains the control room Vedildm $7:44- rataospners occupancywnnnn throughoutconditions suitable the duration of any forone prolon!ed of he s accidents discussed in Reference 1. The radiation exposure CRtvs1 of control room personnel through the duration of any one of the postulated accidenb iscussed in ' Accident gZ-Analysisdsf - a m SAR,
-1 Chapter av spM DU ef.1), ahs=
Ar MM,
. exsees ta IE IEa#. 3. @gA Aet4s 6e
"'h 4 '
c 17 s Thed23 satisfies _ the re resents of Criterien Forg-ygg g g)ggg Q 2 g (,,9 C . W L"'h)- .3(,(s)(iDJ , LC0 LC0 3.3.0 requires one channel of "o be OPfDahl f,
, Thg required channel consists of 0Letuattanoole.16thual r o.
AnR'ilair arehedimI =figasecus radiation monito A spec 1 Tic Al'owable Va' ve$for the setpoints of the The z @ itsted in the $Rs. are 4rtp g g g ,,,.y Only the Allowable Yalues specified fo Mr trip 3 function in the LCo. Ope on with a trip setpoint less
@dc_k..
~
(con nued) , CE0G STS B 3.3 118 Rev1,04/07/95 9
o frnbrema d les AtteNsh4ts% h
. f wHk k psympirent oh fle \ f i
Bast $ Seede d read aanlso y ,pna d LCO
~(continued) Allowable Value, is_acceptablodprovidconservative thatlhe gir erent than the noelnal trip s
- between the nos 4T trip actpeTnt a the Allowable alue is equal to or gr ter than the drift lowance ass for 05 each trip in he transient and act ont anslyses Each Allo bleValuespecified more conserv tva than the analytt linilt assumed in th dransient an accident j analy in order to account erlnstrument r.:ertainties appr late to the trip Fu ton. These certainties are I de d in Reference f.J A chennel is inoperapie u its
" actual trip setpoint is not within its required Allowable Value.
- gfp,3 ggg The haanAthe LC0 on theQRis arp4fscussedpow (93 (eac W nctiont Q
[a, Manual Trig
]
The LCO on Manual p backs up the automat trips and ensures oper rs have the capability o rapidly
~~ initiate the CR runction if any para r is -
trending towa its setpoint. One cha el must be LU OPERABLE. T s considers that the M ual Trip capability a bhckup and that oth means are availabl o actuate the redundant train if required, including manual $1A$ % k Airb M e Radiation 3 g o % channe19ef Airborne Radiation detection A youtpf5_trum arejrequired to be OPERABLE to ent . 1he control room isolates on annarnuurinefnaAd) W I 4 .lN high(ISPt1BWT15t"6B gaseous concentration. CAru N @A [Forthisunit,t basis for the A110w le Value is ' as followst) C. Actuation too One train f Actuation Logic mus e OPERABLE, since 4 4 there ar alternate means avail le to actuate the redunda t train. Including SIAS. s h All E a W Opld v' M edul.[Eha pe rf af
% .ngei ,1, e a e, n. I. + 2 h
\
/ . m % eco.nWeanvra (continued) c ,, ,,,
b u t a . w + w ofs.f _ -
,,vi,Ou0u S I
e -, - - p r
5 3.3.5 4A$ts (continued) M APPLICAtlLITY The L, - Functinan must be OptaABLE in =t 1. f.1. and 4 er ' suring 2 : mL punswis, and 4 b movement of 1 'ated fuel as illes to ensu environment the contrel operators. itab ci n!. A e OPE n A
~vgwiteL a2 channel is inoperable when s net sad sfy the A iu ,4p w p.: ' ILITY criterta for the channel cessen cause functlen. The most 1 iname"a:illity a outri ht failure er W .
drift of ik N fjjy }' t al i, er star -
. s sne
---suffic enn to exceet n Typ ca if. Ine en n is avi largeT & ,..a n1da mg e tse' h ,9 ,4,_ Q, CNAsAtsukauas A resuit in a del of actuatten rather than a i tess of 4 F'8 h*4'M n W4 functlen. This
.perfemance of at.minetten is annarallit e i vt 4c 4ML.i je ter gg. ' inst Tpwasts rwya it:1 wneu e
. = far ^t + =t te hein . ks. ss_2 4 w% sptM44'M. 1
.;f the trfp setpoint is not w thin the ve. the channel is inoperable and the C%Mt hwtwmentet appropriate Condittens must be entered.
%4.t yireysirser4 )erth ,
A.'t.'R$i.R.f.t.1.C.f.1 C.f. 'UED Tenditt and C ha en modif a Note ich spec s that CRE ction mode placed vall in t texte gas -- the aut transfer he toxic retection s inoper [Atthi g g Jhls Note as follow >
. it, the be for
-c'eren W p f Condit '
re '- l Mf AS 4 f t, Med ape es to ure ( t.bw w e.\ " -- " M ^^2 = - Ichanne in m ut - 2 3, or 4. Ent into this Cond- nrowresactionle ti e.CIttS 4w$ t 4 failed channe er manus 11 perfem the eiterete, se m y gig
. function ( Action A. V C s t c wW. - e t" .[ ' 3The Cosp1 I beur is ss ficient to coes) its the Required Action Tien of -
meSy@ , qg irr,=g.mwEyggy;a,. , sn. cnan,i cannet he r. .or.d to cer Atte -t _ .tthe plant must be brought to a MODE in which the LCO (continued)- CE04 STS B 3.3-120 Rev 1. 04/07/95
'k e
SASEs ACili45 &J L & & 1 2 t4. c.' W C2A 9
,(continued) b h d%t Aet apply. i's achieve this status, the plant must be Yasnt to et least MODE 3 within e hours jRequired Action 6.1? end to MODE 5 within 34 hours s7 quired Action 4.t?. The Ceapletion Times of 6 bass and 36 hours for reach 8ef N00t$ 3 and I from MODE I are reasonable on seerating experience and nomal couldewn rates for, based reaching the required N0DE from full power conditions in an orderly manner and without challenging plant safety systemt or' operators.
- btM om - g <Tr1F3
-c ~ a ek m e\ j 23-Condition g.at 4 an.
t., 7M. C,NappliesG. , ,.,wn.n "ha " n tred Acti n to the edi
,n 4
failurejof gManua ken to q
^
[CfL4VSj - e Orti are train in the end CORE ALTE tunedtate$ i-n- [-L} vesent of irradle uel fecWh\AD*9 -- assene es. The Complett ime recognizes the f act that the radiattan ataan1 p tst t Anly Functions available to _ 'dd initiate control room 18 elation [in the event of a fuel handling accident. 4y p3g gg gg g ; 3
$URVEILLANCr, gt 3.3.s.1 REQUIREMEN
Performance that a eross failure ofofthe CHANNELhas instrumentation CHECK not occurred. ence every 11 hours ensure [O
'cluvas ChtcE 1s really a compa son of tWllTFIM6t'tr' /
indi ted on one hannel ti a s lar parameter on other / th els._ lt based en the sumption that nstrumenty nnels mont ring the same erameter shou read pproximate the same val .
$1gnific deviations ween the two strquent ar.nel s an indicati 4
.(could af th channels or -f thtam excessive i trument
-"^1
--- ^-ta d f.Lin. ant /
.I CHANNFL A CHECK v111 Setect gross channel failure; thus.- it is key to ;
verifying the instrumentation continJes to operate properly ,! Q6 between each CHANNEL CAlllRATION.
- N s
.(continued)
CE0G ST5 8 3.3-121 Rev 1. 04/07/95 o
---__.-----________m.-______ ._m_
BAlti 3 SUIwtILLANct RegutRentwTs in s.n.a.1 (continued) .
's criteria are detemined by the plant staff based . R.
(Ac4Yhue ac natten of the channel instrument uncertainties, includine indicatten and Madability. If a channel is it any be an Indication that the outside transettterthe criteria er the s \gnal processing equipment has drifted /\ outside its Itatt. US The frequency,- about once every ahtft , is based on operatin
,ammettene
- s. ,. that
. = desenstrates th> rartw of channel fatture.g I
nie se he1ha allu F'---' m , r s. re .e. ryres in f$f d-M.f The CHANNEL i CHECK
- ans a
g supplements less femal b channel OPERABILITY durl nonnal ut moreoperettenal frequent, checks use ofof . p i .L=Jdth'en,cy c displays assectated withlho LC0 required channels. ' .he . , (4pscMe oh. t m 1 4g/tsen Qw& Ag " defian fat [ures 16.o.1 downscale operations to less of sancuen we the ly. alert alsthe a
.- M11awina Maint/
a ichannel p, testion of le s neent ar.d 3%
/A~"'isunit,y
,e ation for see s, ,arti ate, adst'em ied a .enitors is required a o lows:
1R 2.3.a.fL A CHANNEL FUNCTIONAL TEST is erformed on the control rees radiatten monito tieg channel to en h entire _ channel will eerform its intended function.fA t at spe aa$ys ' f the as found and left values must aise recorded and ' reviewed for e stency with the assump frequency exte ten analysts. The re s of the nts for this h, miew are out ined in Jteference [4).q J The Frequency ofhths is based on slant operating experience wIth e- t @ GJ'r,l" 402"fn% a channel OptPAblLITY 6)and drift.IiWZ/M:;' (continued) . y CLOG STS 8 3.3 122 Rev 1. 04/07/95
~~
4
L BA$ts SURVE!LLAleCE REQUIRtntNTS N 3R3 (continued) Proper operetten of the individual initiation m1 s is vertfled by 6e-energi these nisys during the (L FUIICT10llAL TEST of t Actuation Logic ever days. This will actuate function a ociated ail equipment. Proper peration ek operating the equipment tusted by (31 each train is th verified. The; Frequency [31)daysisbasedonolan operating experience wi regard to channel OptRAbi Y,which demonstrates hat failure of more than o channel of a given Funct inany[31)daysinterva is a rare event.
- Note 1 i cates this Survet11ance 1 udes vertftcation of operetto for each initiation relay Note 2 ndicates that relays that annot be tested at power are excepted from the Surveilla e Requirement while at power. These rela or, be tested during each entry into MODE $ exceeding ys must, I tested within the prevleus 6 annths. hours unless they have beeng w- t -
st 3.3.s g CHAleitt CAlltRATION channel including is "he the sensor. 4G') check of verifles surveillance the W' h that the channel responds to a measured parameter within the necessary range and accuracy. CHAleitL CAL BRAT 10ll leaves the channel adjusted to account forQnst-modrift between [( successive calibrations to ensure that the channel remains-operational between successive surveillances. CHANitEL CALIBqAT10ltS must be performed consistent with the plante-- specific setpoint analysis. Theasfoundan s left values must also reviewed for sistency with the assump : ofecorded the and]Ot3 survet11ance aterval extension analys . Tne requirements v-g this low are outilned in Refer ce(4). _ J-The_ Frequency Ihie"IR"L"TTgpof@[ @ CS5;"*"M,na'":mm;;?' '"# "'""*JP
, ka sen sk.n k,iyc4%e,pi + k aApsfckdshckeyfalloo._ _ _
(continued) CE0G STS 8 3.3-123 Rev 1. 04/07/95 9
46.- To resolve NRC comment 3.3.91 Discussion of Change LA.4 was deleted and replaced by Discussion of Change Ll since the manual function is not credited in the safety analysis. mxA. . __..__.._
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DISCUSSION OF CIIANGES SECTION 3.3.9 - CYCS ISOLATION SIGNAL TECllNICAL CilANGES - RFIDCATIM None TECIINICAL CHANGES MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a Channels to Trip" column. Improved Technical Specification 3.3.9 will not contain this information. His is an informational column which is more appropriate for the Bases. De number of channels to trip will not be changed. De information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change ir compliance with the Bases Change Control Program in ITS Section 5.0. Ilowever, any hardware change to the number of channels to trip will require a design change. He Bases Change Control Program will ensure that changes receive appropriate review. nl change is a less restrictive movement of details change with no impact on safety. This change is consistent with NUREG ld32. LA.2 Not used. l LA.3 Not used. l . LA.4 Not used. l TEC11NICAL CIIANGES - I.FSS MFRTRIC* lye L.I Current Technical Specification 3.3.2.1 requirements for the CVCS Isolation Manual Initiation are being deleted. Manual CVCS isolation is not required by safety analyses for the mitigation of an analyzed event. He requirements for automatic CVCS isolation which is credited for providing protection for a letdown line break are not affected by this change and are retained in ITS 3.3.9. This change is consistent with NUREG 1432. CALVERT CLIFFS - UNITS I & 2 3.3.9-4 Revision 8
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3J ~ INSTRUMENTATION 33.9 Chamme L1
- 1. Does the change involve a significant increase in ibe probability or consequencea of an accident previously evaluated?
He proposed change removes the requirement for manual initiation of the CVCS isohtion signal. He CVCS signal is not assumed to be the initiator of any analyzed event, therefore, the probability of an event is not affected. He automatic ir.itiation feature of the CVCS signal is not affected by this change. Herefore, the consequences of an event are not affected since the function will continue to be required operable to mitigate applicable events. Herefore, the proposed change does not result in a significant increase in the probability or consequence of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kled of accident from any accident previously evaluated?
His change will not physically alter the plant (no new or difTerent type of equipment will be installed). He changes lh methods governing normal plant operation are consistent with current safety analysis assumptions. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the change involve a significant reduction in a margin of safety?
He capability to manually initiate the CVCS signal is not a credited function in the safety analyses. The capability to automatically initiate CVf'S isolation is assumed in the safety analysis and is not affected by this change. The proposed change does not alter or delete any requirement used to preserve the assumptions in the applicable safety analysis, therefore, the change does not result in a significant uduction in a margin of safety. 33.10 Chm =ae L1
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
He proposed change replaces the shutdown track statement with a requirement to send a report to the NRC. The report will be issued when one required channel of PAM instrument is inoperable and the Completion Time cannot be met. The PAM instrumentation is not an initiator of any analyzed event. Post accident monitoring is still available from the one remaining Operable channel and the pre-planned alternate method of monitoring. Also, the PAM instrumentation does not provide an active safety function. He proposed change does not significantly ffect initiators or mitigation of analyzed events, and therefore does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or dlierent kind of accident from any accident previously evaluated?
The proposed change replaces the shutdown track statenient with a requirement to send a report to the NRC, ne change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any new accident initiators. %crefore, the change does not create the , possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 3.3 23 Revision 8
- 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, a
l se .s,a u ,, 3/4.3 INSTRUMENTATION IABLE3.33(Continued) ACTION STATEMENTS AgA ACT44E + - With the number of OPEeABLE channels one less than the Total Number of ChanneTs. restore the inoperable channel to OPERABLE status within 48 hours or be in at least NOT STAND 8Y within the next 6 hours and in COLS $NUTD0lal within the following 30 hours.
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- a. The inoperablelchannel is placed in either the bypass w .*J -+
Acm d 8 J...A N,,,.1, or tripped condition within 1 hour. n; 3. r., rv... vf -- - t*= HT ' n 'nt:x xx . t h ' n ; =il; ;t x x: ;.;., t; 3
/ Ash ch J b;:: -' fr ;; t;j48 hours from; time of initial loss of OPERASILITY: houwer, the inoperable channel shall then j% A ottedotE in be either restored tr OPERABLE status or placed in the tripped candition.
- 5. "'t" := h=r. :!' fr t'er! ::'t; ::n ?;' ; = ';;T f,- ,,, ;t; in;;,;ti; ;hna;; er; e;;e pie;;4 ',,-e 4g n .41;;;a '.; Gi. u
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g4 gc e ,l o , _ , _ . - - . - g g ; 7; $ T _g 9 .... = r,'fM wp. A,d43 however,oneadditiona.channelm;;ybebypassedTrupto a i
,, m, g,4,4 48 hours "t'" ;t-' -t ; *- *! M r!-t:ran = tSt ehannel provided the other inoperahle c annel is placed 8
,. "[* g*I M*A in the tripped 4conditton.
/ ;}'4, cn um a -
with less snan sne mnimum cnannels vrtnABLE. operatton may1 continue provided the containment purge valves are maintained] 9 .-a , (auaun u - with the number of OPERAELE Channels one less snan sne io6s Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirment is demonstrated Within 1 hour; one additional channel may be by I to 2 hours for surveillanea +--t':; ;r f- :"!passedy ntte . d .3.2.1J
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" 6. ras t.Avl CALVERT CLIFFS - UNIT 1 3/4 3-15 Amendment No. 184 l
[x.seef AcTua & M.1 l n + 9,
% ,. e . C. ,a 4 . . .- \'h9 3/4.3 InsTRWENTATIM TABLE 3.3-3 (Continued)
ACTIM STATMENTS A #'" "^ 4tTt0E 4 - With the neber of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours or De in at least 507 STANDBY within the30 following nett 6 hours and in COLD SNT90W within the hours. ACT30g y ug g6 t' -- '. _ e vr . ACTON B
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- a. The inoperab9 channel is placed in either the bypassed . s . . . . . ,a
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' 1 Jhour.
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CLac-* l *
- rt:d f;r ;; "d,48 hours from;;ime t of initial loss of%+ "
pstrAht E 6 san mTi6 m,
..r. the inoperable channel shall then A.
be either restorsd to OPERABLE status or placed in the ymp tripped condition. -
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g4 c' =$$**"*d S c 7..; "'-tr On .;i; G1^21" r;,. tis.t t: et; 4 "eP* $ however, one additional channel may be bypass r up to-e.,r.. .. /4 48 hours .... .. .. . . .. .., te.i. and maintenam.. ,,o that i
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, i 3 shM provided the other inoperable channel is placed w..r
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(ACTIM 8 - ~ With less snan tne mnimim t.nannels artuunskt. operation may ~ continue provided the containment ource valves are maintaine 1_osed. f - - -
@ 11 - With the number of OPERABLE Channels one less than the Totah
, Number iinoperabitof channel Channels,isoperation laced in themay proceed bypassed provided condition and the the Minimum Channels ERABLE requirement is demonstrated within 1 hours one additional channel may be bypassed for up to 2 hours for surveillance testino ner Snecification J
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- Est Aq 1.,.e d 4..o " C SS" CALVERT CLIFFS - WIT 2 3/43-15 Amendment No. 161 l
\Nsyf{1 cTio O) p 3,- 4 oF 7
DISCUSSION OF CHANGES SECTION 3.3.9 - CVCS ISOLATION SIGNAL A.7 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Minimum Channels Operable" column. Improved Technical Specifications 3.3.9 deletes this column because the Actions in the ITS are based on the number of channels inoperable, from the total number of channels, which is specified in the LCO. This change is administrative in nature because the minimum channels Operable requirement is no longer used. His change is consistent with NUREG 1432. A.8 Current Technical Specificatio.. 3.3.2.1 Action 7 exempts the requirements of Specification 3.0.4. Improved Technical Specification 3.3.9 will transfer this requirement to Action C. Action 7 of the CTS corresponds to Actions B and C of the ITS. He exemption of this requirement is not needed for Action B because this Action allows unlimited operation. It was added to Action C because this Action does not allow continued operation. This change is administrative because deleting a requirement where it is no longer required constitutes an administrative change. This change is consistent with NUREG 1432. A.9 Current Technical Sfecification 3.3.2.1 Action 7.a allows the channel to be in bypass for up to 48 hours to perform maintenance or testing. Improved Technical Specification 3.3.9 Action B requires 48 hours to restore the channel to Operable status, ne ITS wording requires the inoperable channel to be restored to Operable status, which would include maintenance, testing, or whatever may be required to restore the channel to Operable status. This change is considered administrative because the channel has to be restored to Operable status, or the channel must be placed in the tripped condition, which is consistent with the CTS. His change is consistent with NUREG 1432. A.10 Current Technical Specification 3.3.2.1 Action 7.c requires an additional inoperable channel to be placed in the bypassed condition provided the other channel is placed in the tripped condition Improved Technical Specification 3.3.7 Action C will allow either channel to be placed in trip and the remaining inoperable channel to be placed in bypass. The channel in which maintenance is being performed is the chemel that will most likely be bypassed. Deleting the requirement which stipulates one anel must be placed in trip and one in bypass is an administrative change, because only ..ie channel is capable of being bypassed at a time. His change is consistent with NUREG 1432. A.11 Not used. A.12 Current Technical Specification 3.3.2.1 Action 7.a requires that an inoperable channel be placed in trip or bypass within one hour. Action 7.b requires that within one hour all functional units receiving an input from the inoperable channel be placed in the tripped or bypass Condition. Improved Technical Specification 3.3.9 provides separate conditions for each required function. The ITS also requires that all affected functions enter the applicable conditions and required actions. The ITS Conditions capture the technical intent of CTS Action 7.a and 7.b by requiring that all affected functions take the specified actions, therefore, the change is administrative. His change is consistent with NUREG 1432. A.13 Current Technical Specification Table 3.3-4 specifies a trip setpoint and an allowable value for the CVCS isolation function. Improved Technical Specification SR 3.3 9 2 only specifies the allowable value for the CVCS isolation function. The trip setpoints and allowable value contained in the CTS are identical, therefore, only the allowable value is necessary to be CALVERT CLIFFS - UNITS 1 & 2 3.3.9-2 Revision 8
DISCUSSION OF CHANGES SECTION 3.3.9 - CVCS ISOLATION SIGNAL TECIINICAL CHANGES - RELOCATIONS None TECilNICAL CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification 3.3.2.1 Table 3.3 3 contains a " Channels to Trip" column. Improved Technical Specification 3.3.9 will not contain this information. His is an informational column which is more appropriate for the Bases ne number of channels to trip will not be changed. The information is being moved to the Bases intact. Any changes to these requirements in the Bases will require change in compliance with the Bases Change Control Program in ITS Section 5.0, However, any hardware change to the number of channels to trip will require a design change. He Bases Change Control Program will ensure that changes receive appropriate review. This change is a less restrictive movement of details change witg no impact on safety. This change is consistent with NUREG 1432. LA.2 Not used. l LA.3 Not used. l LA.4 Not used. l TECIINICAL CIIANGES - LESS RESTRICTIVE L.1 Current Technical Specification 3.3.2.1 requirements for the CVCS isolation Manual Initiation are being deleted. Manual CVCS isolation is not required by safety analyses for the mitigation of an analyzed event. The requirements for automatic CVCS isolation which is credited for providing protection for a letdown line break are not affected by this change and are retained in ITS 3.3.9. This change is consistent with NUREG 1432, CALVERT CLIFFS - UNITS 1 & 2 3.3.9-4 Revision 8
' 4 8, iTo 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 CEOO 99 were removed and the ITS and CTS revised consistent with the STS.
/ l
'" "~
CVCS Isolation Signal 3.3.9 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Two CVCS isolation - - - - - - - - - - - N OT E - - - - - - - - - - - - sensor modules or LC0 3.0.4 is not applicable, associated ---------------------------- measurement channels inoperable. C.1 Place one sensor 1 hour module in bypass and place the other sercor module in trip. AND C.2 Restore one sensor 48 hours module and associated measurement channti to OPERABLE status. T D. Required Action and 0.1 Be in MODE 3. 6 hours associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform a CHANNEL CHECK of each sensor 12 hours channel. CALVERT CLIFFS - UNITS 1 & 2 3.3.9-2 Revision ff? i
CVCS Isolation Signal-
-B 3.3.9 BASES' acccmplished, one channel should bu placed in bypass and the other channel in trip. The allowed Completion Time of 1 hour is sufficient time to perfom the Required Actions.
Once the Required Action to trip or bypass the channel has been complied with, Required Action C.2 provides for restoring one channel to OPERABLE status within 48 hours. The justification of the 48 hour Completion Time is the same as for Condition B. After one channel is restored to OPERABLE status, the provisions of Condition C still apply to the remaining inoperable channel. The Required Action is modified by a Note stating that LCO 3.0.4 is not applicable. The Note was added to allow the changing of MODES even though two channels are inoperable, with one channel bypassed and one tripped. MODE changes in this configuration are allowed, to pemit maintenance and testing on one of the inoperable channels. In this configuration, the protection system is in a one-out-of-two logic, and the probability of a common cause failure affecting both of the OPERABLE channels during the 48 hours pemitted is remote. D.1 and D.2 Condition D specifies the shutdown track to be followed if 9 the Required Actions and associated Completion Times of Condition A, B, or C are not met. If the Required Actions ]S cannot be met within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The Completion Times are reasonable, based on operating experience, to reach the required MODE from full power 4 CALVERT CLIFFS - UNITS 1 & 2 B 3.3.9-6 Revision /8 l
$ p r e .r%-L .o., 3,3. 9 INSERT ACTION D - ,
D'. [ cenat' I chanpjli D.1 Be in MODE 3. 6 hours ! AND- 8 1 D.2 Be in MODE 5. 36 hours C=pWm Time not met. 1 i b O GO e 4*
g ,go i f. , % -4 . % 379 INSERT ACTION D _D.fTwo D.1 Be in MODE 3. 6 hours M D.2 Be in MODE 5. 36 hours Required Action and associated Completion Time not met. G 9 [
l l DISCUSSION OF CHANGES SECTION 3.3.9 - CVCS ISOLATION SIGNAL specified for Operability. This change is administrative since the change involves removal of duplicate information and there is no reduction in technical requirements. His change is consistent with NUREO-1432. TECHNICAL CHANGES - MORE RFMTRICTIVE M.1 ' Current Technical Specification 3.3.2.1 Action 7.c does not specify a time for the additional inoperable channel to be placed in bypass. Improved Technical Specification 3.3.9 Action C will require one channel to be placed in trip and one channel to be placed in bypass within one hour, nis change essentially places a one-hour time limit, where none previously existed, to perform the Actions. This change is, therefore, a more restrictive change. The change will not adversely affect plant safety, because its appropriate to set a time limit on placing one inoperable channel in bypass and one inoperable channel in trip. His change is consistent with NUREG 1432. ' M.2 Current Technical Specification 3.3.2.1 does not have any requirements if an Action cannot be complerd within the required Completion Time, or if two Actuation Logic channels are hoperable. Thus, CTS 3.0.3 would have to be entered. CTS 3.0.3 allows 7 hours to reach Mode 3,13 hours to reach Mode 4, and 37 hours to reach Mode 5. Improved Technical Specie ' as added an Action (Action D), when the Required Action and Associated Ce ,
'. Times cannot be met, to be in Mode 3 in 6 hours and Mode 5 in 36 hours. This ch: ,entially allows one less hour to shutdown the unit, however, adequate time is still alloww to shutdown the unit. Therefore, this change will not adversely affect plant safety, because the unit is capable of shutting down in a controlled manner and these times are consistent with other similar shutdown requirements. This change is consistent with NUREG-1432.
M.3 Improved Technical Specification 3.3.9 will contain a 12 hour channel check (SR 3.3.9.1)_ Current Technical Specification 3.3.2.1 does not contain this SR. This SR will ensure that the CVCS isolation signal is properly tested. Adding new SRs to the CTS constitutes a more j restrictive change. This change will not adversely affect plant safety. This change is consistent with NUREG 1432. M.4 Current Technical Specification 3.3.2.1 Table 3.3-3 and 4.3 2 only require the pressure sensors and manual actuation associated with the CVCS isolation function to be operable. The manual actuation function is deleted in a separate less restrictive change since only automatic actuation is assumed in the safety analysis. Automatic actuation logic is added to the CTS consistent with the accident analysis assumptions. Since the automatic actuation results in a closure of the letdown line, a Channel Functional Test of the logic can only be performed during shutdown, consistent with other ESFAS functions in CTS Table 4.3 2, footnotes 2 through 6. This exception is added as a Note to the Channel Functional Test. Additionally, a second Note is added to the test to require the verification of the relay driver output signal, consistent with equipment design. The addition of these requirements is more restrictive, however, it is consistent with the assumptions in the safety analysis. This charge is consistent with NUREG-1432, b CALVERT CLIFFS - UNITS 1 & 2 3.3.9-3 Revision 8
Q
')
CVCS Isolation Signal h, ACTIONS
- ,- a56adaltd rnedurfbd)
CONDITION REQUIREDACT!0f COMPLETION TIME C. (continued) C.2 Restoreone>i thannel 44 hours to OPERABLE status. - 0+ D. Required Action and 0.1 associated Completion Be in M000 3. 6 hours ( Time not met. 83Q g D.2 Be in MODE 5. 36 hours
..]
CEOG STS 3.3 37 Rev 1, 04/07/95
- - e
CYCS Isolation Signa 1Q h
. ....e BASES ACTIONS D.1 and D.2 (continued)
Condition 0 specifies the shutdown track to be followed*1f 4 the Required Actions and associated Completion Tlees of Condition A. I, or C are not met. Iftthe Required Actions cannot be met within the required Completion Time, the pla.it To achieve this status, the plant must be brought to atmust be brought to least MODE 3 within 6 hours and to MODE 5 within 36 hours. The Completion Tlass are reasonable,3 based on operating experience, to reach the required MODE from full power conditions plant in an orderly manner and without challenging systems. . SURVEILLANCE 5R 3.3.9.1 REQUIREMENTS Perfonnance of the EL CHECK on each CYCS isolation pressure indicating channel once every 12 hours ensures that a gross failure of instrumentation has not occurred. A $*w S.r CHANNEL CHECK is normally a comparison of the parameter ' indicated on one channel to a siellar parameter channels, it is based on the assumption that er
, ) channels monitoring the same parameter should te approximately the same value. ,d)
_f;J,o F Significant deviations between the two nrt= C " channels / could be an indication of excessive d.astpdfen of'the channels or of something even more serious. in rift one
~
CHANNEL
%ld.di[Nggt verifying CHECK will detect gross channel failure thus, it is key to
$ the instrumentation continues;to operate properly between each CHANNEL CALIBRATION.
O b WF d**A Ag p Q g r g on~reement eriteria arethDchannel determined bs, plant staff based Nhahinawar including indication and readabt ity. If a channel is outside the criteria, it may be an indication that the uncertainties, h transaltter or the signal processing equipment has drifted outside its limit. The frequency, about once every shift, is based on operatin experience that demonstrates the rarity of channel failure.g Since the probability of two random failures in redundant channels in any 12 hour period is low, the CHANNEL CHECK (continued) CEOG STS B 3.3-130 Rev 1, 04/07/95 o ,-a:',
.. ~ - - . . . -.. -. .. . - . .-.-., = . . . - ._ - . ...-. .. -. . - - . . .- -. . . -
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- 49,
-- To resolve NRC comment 3.3.9 5, Discussion of Change LA.3 is deleted since the trip setpoint is
'the seme as the allowable value and does not need to be relocated. Discussion of Change A.13 is t
added to reflect the retention of allowable values in ITS 3.3,9. - . Y ^ 4 g- _ l i t i t .. fb + (
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b West Penetration Room / Letdown Heat < 0.5 ig ~< 0.5 psig d [ Exchanger Room Pressure - Higt C_ J E
- 9. AUKILIARY tttsruta ACTUATION SYST (AFAS)
- a. Manual (Trip Buttons) nor,appu cante - Not Appitcable 7
- b. Steam Generator (A or 8) Level - -149 inches to -194 inches Y Low (inclusive) -149inchesto-194 (inclusive) inches /
E /
- c. Steam Generator AP - High 5 135.0 psi 5 135.0 psi (SG-A>SG-8) e Steam Generator AP - High 5 135.0 psi 5 135.0 psi (d. (SG-B > SG-A) r f
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