Text

Forwards Responses to 970611 RAI Re Rev 10 to LAR to Convert to Improved TS & Rev 10 to Original License Amend Application
	ML20198R718
Person / Time
Site:	Calvert Cliffs
Issue date:	11/05/1997
From:	Cruse C; BALTIMORE GAS & ELECTRIC CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198R723	List: ML20198R718; ML20198R733;
References
	TAC-M97363, TAC-M97364, NUDOCS 9711130372
	Download: ML20198R718 (30)
	v • d • e

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Cucus 11.Cte:r.

13altimore On and Electric Company Calvert Cliffs Nuclear Power Plant Vice President Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495 4155 November 5,1997 U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION:

Document Contre! Desk SUILIECT:

Calvert ClitTs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Revision 10 to the License Amendment Request to Convert to the improved Technical Snecifications (TAC Nos. M97363 and M97364)

REFERENCE:

(a)

Letter irom A. W. Dromerick (NRC) to C.11. Cruse (DGE), dated June 11, 1997, Request for Additional Information Regarding the Technical Specification Change Request to Convert to the improved Technical Specifications (TAC Nos. M97363 and M97364)

Reference (a) transmitted questions regarding Section 3.8.3 of Baltimore Gas and Electric Company's application to convert to the improved Standard Technical Specifications.

The responses for Section 3.8.3 are provided in Attachment I of this letter, included in Attachment I are some responses to questions associated with Sedon 3.6 which were inadvertently left out of a previous submittal. Also attached to this letter is Revision 10 to the original license amendment application.

These changes result from the responses provided in Attachmer.t 1, as well as other changes identified by the NRC and plant personnel. Changes to the No Significant llazards Considerations discussions are included where appropriate.

To assist in reviewing this revision, a list describing each of the changes is provided (Attachm.nt 2). In addition to the changes to Section 3.8.3, changes to other Sections have been included. All of the material for ca.h change is grouped by change in Attachment (3). Attachment (4) provides the revision by Improved Technical Specification Section for ease of replacing pages in the original amendment I

request. Page replacement instructions are provided. All changes are marked with revision bars and aregdq labeled Revision 10.

The Plant Operations and Safety Review Committec and a subcoinmmee of the Offsite Safety Review Committee have reviewed revisions resulting in changes to the No Significant llazards Considerations and concur that operation with the proposed revisions will not result in an undue risk to the health and 1

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Document Control Desk November 5,1997 Page 2 4

sefety of the public. Sheuld you have questions regarding this matter, we will be pleased to discuss them with you.

- Very truly yours,--

de'-

STATE OF MARYLAND

TO WIT:

. COUNTY OF CALVERT

1. Charles 11. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this-License Amendment Request on behalf of BGE. To the best of my knowledge and belief, the statements

- contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Me Y seu for the State of Maryland and County of Sp> scribed and sworn before me, a Notary Public in an

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,this M day of h

.1997.

WITNESS my lland and Notarial Seal-

Lots

'e Notary Public

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^

-My Commission Expires:

/

V Dde CllC/ PSF /bjd Attachments: (1) ' Responses to Request for Additionalinformation

_(2) Summary ofChanges (3) Amendment Revision by Change (4) Amendment Revision by ITS Section

- Document Control Desk

November 5,1997

- Page 3 -;

cc-M. L. Reardoni NRC,

.I k

'(With Attachment 2 only) -

R. S. Fleishman, Esquire :

H. J. Miller, NRC

.J. E. Silberg, Esquire Resident inspector, NRC Director, Project Directorate 1 1, NRC R.1. McLean, DNR A. W Dromerick, NRC J. H.- Walter, PSC -

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Pcge Replacement lastructions VOLUME 11 Section 3.7 Note: Underlinedtitles indicate tabs in volumes. Regarding C15 markups: Peges are referenced by citing the unit number as well as the spec @ cation number locatedin the upper right-hand corner ofthe C15page.

Key:

DOC = Qiscussion OfChanges DOD = Qiscussion WTechnicalSpec@ cation Deviation or Qiscussion & Bases Deviation '

}

I REMOVE INSERT Overview of Channes None ILS None ITS Itases B 3.7.1-4 through B 3.7.1-6 B 3.7.l-4 through B 3.7.1-6 O'Sylarkun & Discussion of Channes DOC 3.7.9-3 DOC 3.7.9-3 DOC 3.7.11 3 DOC 3.7.11-3 NSHC Findines None LSTS Markup & Justincation None ISTS Bases Markup & Justincation B3.7-4 B 3.7-4 i

MSSVs

'8 3.7.1

.8ASES

' Maximum relieving capacity of any one safety' valve Y

=

inIbs/ hour NRC Information Notice 94-60 states that the linear IO relationship is not always valid; however, the setpoints'in Table 3.7 have been verified by transicnt analyses.

The operator should limit the maximum steady state power level to soce value slightly below this-setpoint to avoid an inadvertent overpower trip.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months _ Completior. Time for Required Action A.2 is consistent with A.1.

An additional 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s-is allowed to reduce the setpoints in recognition of the difficulty of resetting all channels of this trip function within a period of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Required Action A.3 is based on operating experience in resetting all channeis of a p atective function and on the low probability--

of the occurrence of a transient that could result in steam generator overpressure',during this period.

B.1 and B.2 If the MSSVs cannot be restored to OPERABLE status in the associated Completion Time, or if one or more steam generators have less than five MSSVs OPERABLE, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

-CALVERT CLIFFS - UNITS 1 & 2 B 3.7.1-4 Revisionp'jo

MSSVs B 3.7.1

. BASES SURVEILLANCE SR 3.7.1.1 REQUIREMENTS This SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV lift setpoints in accordance with the Inservice Testing Program. The ASME Code Section XI (Ref. 4).- requires that safety and relief valve tests be performed in accordance with American National Stat.dards Institute (ANSI)/ASME OM-1-1987 (Ref. 5). According to Reference 5, the following tests are required for MSSVs:

a.

Visual examination; b.

Seat tightness determination; c.

Setpoint pressure determination (lift setting);

d.

Compliance with owner's seat tightness criteria; and e.

Verification of the balancing device integrity on balanced valves.

The ANSI /ASME Standard requires that all valves be tested every 5 years, and a minimum of 20% of the valves be tested every 24 months. The ASME Code specifies the activities and frequencies necessary to satisfy the requirements.

Table 3.7.1-2 defines the lift setting range for each MSSV for OPERAblLITY; however, the valves are reset to i 1%

during the Surveillance to allow for drift. To comply with the ASME Code, a more restrictive setpoint tolerance of i 3% has been imposed in plant procedures for the as-found values.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This is to allow testing of the MSSVs at hot conditions.

The MSSVs may be either bench tested or tested in situ at hot conditions using an assist device to simulate lift pressure.

If the MSSVs are not tested at hot conditions, the lift setting CALVERT CLIFFS - UNITS 1 & 2 B 3.7.1-5 Revisiong4

MSSVs B 3.7.1 BASES pressure shall be corrected to ambient conditions of the

- valve at operating temperature and pressure.

REFERENCES 1.

UFSAR, Chapter 10 2.

ASME, Boiler and Pressure Vessel Code,Section III, Article NC-7000, Class 2 Components 3.

UFSAR, Section 14.5 4.

ASME, Boiler and Pressure Vessel Code,Section XI, Article IWV-3500 5.

ANSI /ASMEOH-1-1987 l

l

[

l

-CALVERT CLIFFS - UNITS'1 & 2 B 3.7.1-6 Revision 0 w

e-w T

l DISCUSSION OF CHANGES SECTION 3.7.9 - CONTROL ROOM EMERGENCY TEMPERATURE SYSTEM

. TECHNICAL CIIANGES - LFRR D5'RTRICTIVE L.1 Current Technical Specification 3.7.6.1 Action b allows 7 days to restore an inoperable air conditioning unit to Operable status (when one is inoperable). Improved Technical Specification 3.7.9 will allow 30 days to restore an inoperable air conditioning unit to Operable status (when one is inoperable). His change will increase the allowed outage time from 7 days to 30 days when one CRET' train is inoperable. This change is acceptable-J because the remaining CRETS train is r.dequate to maintain the Control Room temperature within limits. It is alco based on the low likelihood of an event occurring requiring Control Roo a isolation, ano that backup Control Room air conditioning system is available.

Extending the allowed outage time for the CRETS constitutes a less restrictive chang:. This change is consistent with NUREG-1432.

L.2 Current Technical Specification SR 4.7.6.1.a requires the CRETS to maintain Control Room temperature s 104*F for at least 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months once per 62 days on a Staggered Test Basis.

Improved Technical Specification SR 3.7.9.1 also requires the CRETS to maintain Control Room tempent ire s 104'F for at least 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; however, the ITS requires the SR to be parformed once per 24 months. His change is appropriate since significant degradation of the CRETS is slow and is not expected to change over this time period. This has been shown by evaluating the previous 10 years of operating experience which show that this test has not had any failures. The CRETS contains redundant electrical and mechanical components and is operated once per 31 days to verify operability. Therefore, per Generic Letter 91-04, the effect of the change on plant safety is small. Also, instrument drift will have no affect on thistest. There is no instrumentation tested by this Technical Specification requirement. l This change is consistent with NUREG-1432 and the guidance in Generic Letter 91-04.

CALVERT CLIFFS - UNITS 1 & 2 3.7.9-3 Revision 10

DISCUSSION OF CHANGES SECTION 3.7.11 - SPENT FUEL POOL EXHAUST VENTILATION SYSTEM no change in the requirement for the SFPEVS to be Operable and in operation. Furthermore, NRC and Ct.! vert Cliffs resources associated with processing license amendments to these requirements will be reduced. His change is a less mstrictive movement of information

. change with no impact on safety. His change is consistent with NUREG-1432.

LA.2 Action a and b of CTS 3.9.12 require the suspensica of all operations involving crane operation with loads over the storage pool. Since crane operation over the storage pool is not necessarily affected by the loss of the SFPEVS or its components, the requirements associate 6 with the suspension of crane operation with loads over the storage pool are to be relocateI to the UFSAR. He bounding design basis fuel handling accident assumes an irradia'ed f,.el assembly is dropped and damaged. The movement oflesds (loads other than fuel astemblies) is administratively controlled based on heavy loads analyses. The heavy loads analysis methodology and crane operation which dictate the controls are described in the UFSAR. Herefore, the Actions associated with crane operations involving loads are not required to be in the ITS to ensure adequate control of loads and are to be relocated to the UFSAR. Changes to the UFSAR will be adequately controlled by the provisions of 10 CFR 50.59.

LA.3 Not used.

TECHNICAL CHANGES IISS RESTRICTIVE L.1 Not used.

L.2 Current Technical Specification 3.9.12 Applicability for the SFPEVS, is whenever irradiated fuel is in the storage pool. Improved Technical Specification 3.7.ll' Applicability is during -

movement of irradiated fuel assemblies in the Auxiliary Building."His change reduces the':

Modes of Applicability from whenever irradiated fuel is in the storage pool to wheneret irradiated fuel is being moved in the spent fuel pool. His change is acceptable because the fuel handling accident assumes an irradiated fuel assembly is being moved in the spent fuci pool. The reduction of the Mode of Applicability is considered a less restrictive change.

His change is consistent with NUREG-1432.

L.3 Current Technical Specification Surveillance 4.9.12.d.2 requires that SFPEVS maintain a measurable negative pressure telative to the outside atmosphere once per 18 months.

Improved Technical Specification SR 3.7.11.3 requires that SFPEVS maintain a measurable negative pressure relative to the outside atmosphere once per 24 months. This change l

decreases the Surveillance Frequency from 18 months to 24 months. The 24-month l

Surveillance Frequency is sufficient to ensure that the SFPEVS can maintain a measurable negative pressure in the spent fuel pool area of the Auxiliary Building. After reviewing the previous ten years of Surveillance history, the SFPEVS has never failed to maintain a measurable negative pressure in the spent fuel pool area of the Auxiliary Building. The SFPEVS contains redundant electrical and mechanical components and is operated once per 31 days to verify operability. Therefore, per Generic Letter 91-04, the effect of this change on plant safety is small. Also, instrument drift will have no affect on the test. There is no instrumentation associated with this Technical Specification requirement.

Decreasing I

Surveillance Frequencies constitutes a less restrictive change. This change is consistent with NUREG-1432 and the guidance in Generic Letter 91-04.

CALVERT CLIFFS - UNITS I & 2 3.111-3 Revision 10

. ~

t I

MS$Vs

B 3.7.1

-BASES A.1 'nd A.2 (continued)

ACTIONS a

Allowable THERMAL POWER = (W) x 109.2 With one or no MSSVs inoper bl, the calling on the-O-

variable ov r trip is repsced to an amount pver the

} ' allowable rding to Table 3.J).1-1 in the accompanying LCO.

ERMAL POWER equa to the band giverg 'for this trip, ac gg.7 SP

= Allowable THE POWER + 9.8 d 7.7.1

[ A'I'd #

y:

SP Reduced r actor trip setpoi t in percent RTP.

=

This is ratio of the av 11able relieving.

A capaci over the total team flow at ra ed

/

Power 8

-=,To 1 number cf MS5 per steam geneyttor.

N umber of inoper le MSSVs on the team generator

=

ith the greate number of inop rable valves.,.

Ratio of MSS relieving capa ty at 1105 ste '

109.2

=

generator sign pressure t calculated ste flow rate t 2005 RTP +

inctrument unc ainty

-express as a percentag (see text abov g.8

-Band between the maxi THERMAL and the variable overpower t p setpoint ce ing

(

(Table 3.7.1-1).

j he operator should limit the maximum Steady state power level to some value slightly below this setpoint to avoid an inadvertent nyerpower trip.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for Required Action A.2 is consistent with A.I.

An additional 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is allowed to reduce the setpoints in recognition of the difficulty of resetting all channels of this trip function within a period of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The Comoletion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Required Action A.3 is based on operating expulence in resetting all char.nels of a protective function &ne on the low probability of the occurrence of a transient that :ould result in steam generator overpressure during thf5 period.

(continued)

CEOG ST B

Rev 1, 04/07/95 N Rc. I dom on Moh u 9 'l-(,0 skb 4%. bw-cc Whmkip noi Algs vahd, koer, W &n4po,nh in Tc.b h. 3.5 - i _

N kw 6. veriQ by +ms u Je whpas.

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P ge Replaceme:t I:structio:s VOLUME 12 Section 3.8 Note: Underlined titles indicate tabs in volumes. Regarding c15 markups: Pages are referenced by cldng the unit number as wil as the spec $ cation number loccdedin th: upper right-handcorner ofthe C7Spage.

i Key:

DOC = Discussion ofChanges DOD = Discussion Qf TechnicalSpecification Deviation or Discussion QfBases Deviation REMOVE INSERT Overview of Channes None IIft 3.8.3-1 through 3.8.3 3 3.8.31 through 3.8.3 5 ITS Baseg

' B 3.8.3 1 through B 3.8.3 7 B 3.8.3-1 through B 3.8.3 11

_ CTS Maikun & Discussion of Channes Spectfication 3.8.3, Unit i Page 1 of12 through Page 12 of12 Page I of1I through Page 1I of11 Specification 3.8.3, Unit 2 Page 1 of 12 through Page 12 of 12 Page i of11 through Page 11 of11 DOC 3.8.3-1 through 3.8.3-6 DOC 3.8.3-1 through 3.8.3-9 NSIIC Findings Nonc ISTS Markup & Justification 3.8 22 and " INSERT Required Action" 3.8-22 and " INSERT 3.8.3" 3.8-23 and 3.8-24 3.8-23 and 3.8-24 DOD 3.8-3 through 3.8-9 DOD 3.8 3 through 3.8-10 Bases Markup & Justification B 3.8-41 through B 3.8-49 B 3.8-41 through B 3.8-49 DOD 5.8-4 and 3.8 5 DOD 3.8-4 through J.8-6 i

l Diesel Fuel Oil 3.8.3 3.8 ELECTRICAL POWER SYSTEMS i

3.8.3 Die:e1 Fuel Oil LC0 3.8.3 The stored diesel fuel oil shall be within limits for each requireddieselgenerator(DG).

APPLICABILITY:

When associated DG is required to be OPERABLE.

ACTIONS

..............................-..---. NOTE-------------.---.-----.---....-.....

Separate Condition entry is allowed for each DG.

CONDITION REQUIRED ACTION COMPLETION TIME

()

A.

Fuel oil storage tank A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (FOST)1Awithfuel volume to within oil. volume limits.

I

< 49,500 gal and h 42,430 gal.

CALVERT CLIFFS - UNITS 1 s <

3.8.3-1 RevisionJfo

)

f

Diesel Fuel Oil 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

-- - - - - -- NOT E -- - - - -- -

B.1 Verify combined 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to available fuel oil Unit 1.

volume of FOST 21 and OPERABLE FOST 11 2 72,860 gallons.

FOST 21 with fuel oil volume < 85.000 gal.

AND p

B.2 Verify combined 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months available fuel oil volume of F0ST 21 and AND OPERABLE FOST 11 2 85,000 gallons.

Once per 31 days thereafter O

CALVERT CLIFFS - UNITS 1 & 2 3.8.3-2 Revision g/0

6 t

Diesel Fual Oil i

3.8.3 ACTIONS (continued)

CONDITION

- REQUIRED ACTION COMPLETION TIME i

i i

r C.

-... --.. NOT E........

C.1 Verify combined I hour Only applicable to available fuel oil Unit 2.

volume of FOST 21 and j

OPERABLE FOST 11 2 72,860 gallons.

1 FOST 21 with fuel oil 4

- volume < 85,000 gal.

m C.2

... -.. - NOT E S.... -. -

l 1.

Only applicable during MODE 1

2. - 3, or 4.

L 2.

Only applicable between April 1 and to September 30.

Restore FOST 21 fuel 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months oil volume to within limits.

s C.3 Restore FOST 21 fuel 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months oil volume to within limits.

D.

- One or more DGs with D1 Restore fuel oil 7 deys stored fuel oil total total particulates to particulates not-within. limits, within limits.

4 P

CALVERT CLIFFS - UNITS 1 & 2 3.8.3-3 Revision //o M-=.wuc-eerme=wame=N=weu.-==m-h-=w w e e w-se

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Diesel Fuel Oil 3.8.3 ACTIONS (continued) i CONDITION REQUIRED ACTION COMPLETION TIME E.

One or more DGs with E.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.

limits.

F.

Required Action and F.1 Declare associated Imediately associated Completion DG(s) inoperable.

Time not met.

go QB One or more DGs with diesel fuel oil not within limits for reasons other than Condition A, B, C, D, or E.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil volume of:

31 days a.

F0ST 1A 2 49,500 gallons, and b.

FOST 21 2 85,000 gallons.

SR 3.8.3.2 Vertfy fuel oil properties of new and stored In accordance fuel ol' are tested in accordance with, and with the Diesel maintained within the limits of, the Diese'l Fuel Oil l

Fuel Oil Testing Program.

Testing Program l

l l

l CALVERT CLIFFS - UNITS 1 & 2 3.8.3-4 Revisiong/o w-m

-

--+w-q y

w

Diesel Fuel Oil 3e8.3 SURVEILLANCE REQUIREHENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.3 Check for and remove accumulated water from 92 days each fuel oil storage tank.

CALVERT CLIFFS - UNITS 1 & 2 3.8.3-5 Revision 0

1 l

Diesel fuel Oil B 3.8.3 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.3 Diesel Fuel Oil j

)

1 BASES BACKGROUND The fuel oil storage tanks contain sufficient capability for thedieselgenerators(DGs)tooperateoneunitonaccident loads and one unit on shutdown loads for 7 days. This is discussed in Updated Final Safety Analysis Report (UFSAR),

Chapter 8(Ref.1). This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources.

Fuel oil is transferred from the storage tanks to the day tank by transfer pumps associated with each DG.

For proper operation of the standby DGs, it is necessary to i

ensure the proper quality of the fuel oil. Testing to check for water and sediment content, the kinematic viscosity, specific gravity (or API gravity), and impurity level (i.e., total particulates) ensures this quality.

l The DG fuel oil system design at Calvert Cliffs supports four emergency DGs and other non-safety DGs. Three of the four emergency DGs, i.e., Nos.1B, 2A, and 28 are fueled fromtwofueloilstoragetanks(FOSTs),i.e.,FOST11and F0ST 21, and DG 1A is fueled from FOST 1A. FOST 1A and FOST 21 are enclosed such as to be considered ' tornado protected" but FOST 11 is not protected. As such, FOST 11 is not used as the primary source for the emergency DGs, but rather is used as a backup to support FOST 21 if it or the lo l

fuel oil it contains becomes degraded.

The operability of FOST Nos. 21 and 11 ensure that at least 7 days of fuel oil will be reserved below the internal tank l-standpipes for operation of one DG on each unit, assuming l

one unit under accident conditions with a DG load of l

3500 kW, and the opposita unit under normal shutdown l

conditions with a DG load of 3000 kW. Additionclly, the l

L CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-1 Revisionp/o

Diesel fuel Oil B 3.8.3 BASES operability of FOST 21 ensures that in the event of a loss of offsite power, concurrent with a loss of the non-bunkered fuel oil storage tank (tornado / missile event), at least 7 days of fuel oil will be available for operation of one DG on each unit, assuming both DGs are loaded to 3000 kW. The operability of the FOST 1A ensures that at least 7 days of fuel oil is available to support operation of DG 1A at p

4000 kW.

The operability of the fuel oil day tanks ei.sures that at least one hour of diesel generator operation is available without makeup to the day tanks, assuming DG 1A is loaded to 4000 kW and DGs 18, 2A, and 2B are loaded to 3500 kW.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and 3AFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 2), and in theUFSAR, Chapter 14(Ref.3),assumeEngineeredSafety feature (ESF)systemsareOPERABLE. The DGs are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that fuel, Reactor Coolant System and containment design limits are not exceeded. These limits are discussed in more detail in the Bases for LCO Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS); and Section 3.6, Containment Systems.

Since diesel fuel oil supports the operation of the standby AC power sourcer, they satisfy 10 CFR 50.36(c)(2)(ii),

Criterion 3.

LC0 FOST 1A is required to contain a minimum of 49,500 gallons of available diesel fuel oil which is sufficient supply to operate DG 1A on accident loads for 7 days. FOST 21 is required to contain a minimum of 85,000 gallons of available to diesel fuel oil which is sufficient supply to operate one unit on accident loads.and one. unit on shutdown loads for 7 days.

It is also required to meet specific standards for CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-2 Revisionjflo

Diesel fuel Oil B 3.8.3 BASES quality. This requirement, in conjunction with an ability to obtain replacement supplies within 7 days, supports the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence (A00) or a postulated DBA with loss j

of offsite power. Diesel generator day tank fuel requirements, as well as transfer capability from the FOST to the day tank, are addressed in LCO 3.8.1, "AC Sources-Operating," and LCO 3.8.2, 'AC Sources-Shutdown."

APPLICABILITY The AC sources (LCO 3.8.1 and LCO 3.8.2) are required to ensare the availability of the required. power to shut down the reactor and maintain it in a safe shutdown condition after an A00 or a postulated DBA.

Since stored diesel fuel oil supports LCO 3.8.1 and LCO 3.8.2, stored diesel fuel oil is required to be within limits when the associated DG is required to be OPERABLE.

For both Unit 1 and Unit 2 the FOST 1A associated DG is only DG 1A. For Unit 1, the FOST 21 associated DGs are DG IB and DG 28. For Unit 2, the F0ST 21. associated DGs are DG 2A and DG 28. Alignment does not affect the association of ID DG and FOST since the individual DG fuel oil day tank provides sufficient volume for the DG to perform its safety function while re-alignment is accomplished, if necessary.

ACTIONS The ACTIONS Table is modified by a Note indicating that 1

separate Condition entry is allowed for each DG.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem (s) are governed by separate-Condition entry and application of associated Required Actions.

CALVERT CLIFFS - UNITS 1 & 2 8 3.8.3-3 Revision g/o

l Diesel Fuel Oil B 3.8.3 BASES A.I. B.1. B.2. C.1. C.2. and C.3 In this Condition, the 7 day fuel oil supply for a DG is not available. However, fuel oil volume reduction is limited to

!/7 of the required volume which will provide sufficient capacity to operate one DG on one unit on accident loads and one DG on the other unit on shutdown loads for approximately 6 days. These circumstances may be caused by events such as full load operation required after an inadvertent start while at minimum required level; or feed and bleed operations, which may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. A period of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of the required level prior to lo declaring the DG inoperable. This period is acceptable based on the remaining capacity (approximately 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period.

Condition A addresses only FOST 1A which is " tornado protected" and which contains sufficient fuel for 7 days of required operation of DG 1A.

It supports both Unit I and l

Unit 2 equipment since DG 1A provides power for equipment which is shared by both units, e.g., the control room emergencyventilationsystem(CREVS).

Condition B addresses only FOST 21 which is " tornado i

protected" and which contains sufficient fuel for 7 days of required operation of two DGs. FOST 21 supports both Unit 1 and Unit 2 equipment, but Condition B is written for Unit 1 only to reflect the Unit I requirements for DGs 1B and 28.

I For an accident Unit I requires either DG 1A or both DGs 18 and 2B (since DG 2B powers equipment which is redundant to some equipment powered by DG 1A, e.g., CREVS).

Since DG 1A is supported by FOST 1A and tne redundant required equipment I

CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-4 Revision g to l

I Diesel fuel Oil B 3.8.3 l

l BASES is powered by DGs 18 and 2B which are supported by FOST 21, at least one full train of required equipment is supported by a ' tornado protected' FOST even with an inoperable FOST or DG. Therefore, low fuel oil volume in FOST 21 can be supplemented by the fuel oil volume of an OPERABLE FOST 11 to assure the necessary volume.

Required Action B.1 requires the combined volume of FOST 21 and an OPERABLE FOST 11 to be verified to be greater than 6/7 of the required volume within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is consistent with the time needed to verify through administrative means that the backup FOST is OPERABLE.

l Required Action B.2 requires the combined volume of FOST 21 1

and an OPERABLE FOST 11 to be 2 85,000 gallons within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

In addition, if FOST 21 is not restored and FOST 11 continues to be relied upon, Required Action B.2 must be repeated every 31 days. This effectively replaces the SR 3.8.3.1 periodic surveillance of available DG fuel oil volume for the inoperable FOST 21. Since FOST 11 is not required by the LCO, FOST 11 may be considered OPERABLE only 10 when the stored fuel oil meets SR 3.8.3.2 and SR 3.8.3.3, and is capable of being delivered to the required DG, -

i.e., the necessary piping and valves are capable of performing their safety function.

Specific alignment to a particular FOST is not required since the individual DG fuel oil day tank provides sufficient volume for the DG to perform its safety function while re-alignment is accomplished, if necessary.

Further, if any fuel oil in FOST 11 above the 33,0J0 gallons reserved for emergency DG use is credited for DG use, appropriate administrative controls must be in place to assure its retention for this purpose.

Condition C also addresses only FOST 21 which is " tornado protected" and which contains sufficient fuel for 7 days of required operation of two DGs. FOST 21 supports both Unit I and Unit 2 equipment, but Condition C is written for Unit 2 only to reflect the Unit 2 requirements for DGs 2A and 28.

'For an accident, Unit 2 requires either DG 28 or both DGs 1A and2A(sinceDG1Apowersequipmentwhichisredundantto CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-5 RevisionA/c)

Diesel Fuel Oil B 3.8.3 BASES-some equipment powered by DG 2B, e.g., CREVS).

Unlike Unit 1, at least one full train of required equipment is not supported by a " tornado protectcd" FOST with an inoperable FOST or DG since most of the redundant required equipment is powered by DGs 2A and 2B which are both supported by FOST

21. Therefore, low fuel oil volume in FOST 21 can only be supplemented by the fuel oil volume of an OPERABLE FOST 11 to assure the necessary volume when the probability for a tornado is sufficiently low. This is reflected in Note 2 for Required Action C.2 which addresses the inoperability of FOST 21 from April 1 to September 30.

During the time of low tornado probability, the Unit 2 requirements for the inoperability of FOST 21 are very similar to the Unit 1 requirements for inoperability of FOST 21.

It is acceptable for the combined volume of FOST 11 and FOST 21 to be y

considered in providing 6/7 of the required volume for the 4fs hours allowed by Required Action C.3.

Required Action C.1 requires the combined volume of FOST 21 and an.

OPERABLE FOST 11 to be verified to be greater than 6/7 of the required volume within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Required Action C.3 then requires the volume of FOST.21 to be restored to within volume limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

However, during tornado season, i.e., from April 1 to September 30, the fuel oil volume of FOST 11 is not allowed to be credited and the fuel oil 7 day volume of FOST 21 must be restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as indicated in Required Action C.2.

Required Action C.2 is also modified by a Note such that it is only required during the operation of Unit 2 in MODE 1, 2, 3, or 4 since the unit is already shutdown if it is in another MODE or condition.

An OPERABLE FOST 11 is determined as described above in the discussion for Condition B.

Ed This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.2.

Nonna11y, trending of particulate levels allows sufficient time to correct high

/o particulate levels prior to reaching the limit of l

L CALVERT CLIFFS - UNITS 1 & 2 8 3.8.3-6 Revision g/o

.~.__ -_

Diesel fuel Oil B 3.8.3 BASES acceptability. Poorsampleprocedures(bottomsampling),

contaminated sampling equipment, and errors in laboratory i

analysis can produce failures that do not follow a trend.

3 Since the presence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudtat to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, resampling, and re-analysis of the DG fuel oil.

E.d P

With the new fuel oil properties defined in the Bases for SR 3.8.3.2 not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil properties to within the new fuel oil limits. This period provides sufficient time to test the stored fuel oil to determine that the new fuel oil, when mixed with previously stored fuel oil, remains acceptable, or restore the stored fuel oil properties to within the new fuel oil limits. This restoration may involve feed and bleed procedures, filtering, or combinations of these procedures.

Even if a DG start and load was required during this time interval and the fuel oil properties were outside limits, there is a high likelihood that the DG would still be capable of performing its intended function.

E.d to With a Required Action and associated Completion Time not met, or one or more DGs-with diesel fuel oil not within limits for reasons other than addressed by Conditions A through E, the associated DG may be incapable of performing its intended function and must be imediately declared CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-7 Revision h o

---a n-w

~n e,---

e

Diesel fuel Oil B 3.8.3 BASES inoperable.

" Associated DG(s)" are identified in the p

Applicability Bases.

SURVEILLANCE SR 3.8.3.1 REQUIREMENTS This SR provides verification that there is an adequate inventory of fuel oil in the DG fuel oil storage tanks to support one unit on accident loads and one unit on shutdown loads for 7 days. The 7 day period is sufficient time to place the unit in a safe shutdorn condition and to bring in replenishment fuel from an offsite location.

The 31 day Frequency is adequete to ensure that a sufficient supply of fuel oil is available, since low level alarms are provided and unit operators would be aware of any large uses of fuel oil during this period.

SR 3.8.3.2 The tests listed below are a means of determining whether new fuel oil is of the appropriate grade (i.e., 2D and 2D low sulfur) and has not been contaminated with substances that would have an immediate, detrimental impact on diesel engine combustion. Note that further references to ASTM 2D fuel oil include both 2D and 20 low sulfur.

If results from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of fuel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank (s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable American Society for Testing Materials (ASTM) Standards are as follows:

a.

Sample the new fuel oil in accordance with ASTMD4057-1995(Ref.4);

CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-8 Revision gjo

Diesel Fuel Oil B 3.8.3 4

8ASES b.

Verify in accordance with the tests specified in ASTM D975-1996 (Ref. 4) that the sample has an ibsolute l '#

specificgravityat60/60'Fof20.8155 ands 0.8871, or an American Petroleum Institute gravity at 60*F of 2 28' and s 42', a kinematic viscosity at 40'C of 2 1.9 centistokes and s 4.1 centistokes, and a flash point 2 125'F; and c.

Verify that the new fuel oil has < 0.05% water and sediment (ASTM D975-1996).

10 Failure to meet any of the above limits is cause for rejecting the new tuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.

Within 31 days following the initial new fuel oil semple, the fuel oil is analynd to establish that the other properties specified in Table 1 of ASTM B975-1996 (Ref. 5) lo are met for new fuel oil. The 31 day period is acceptable because the fuel oil properties of interest, even if they were not within stated limits, would not have an ininediate effect on DG operation. This Surveillance ensures the availability of high quality fuel oil for the DGs.

Fuel oil degradation during long term storage shows up as an increase in particulate, due mostly to oxidation.

The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine.

The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

Particulate concentrations should be determined by gravimetricanalysis(basedonASTMD2276-1989) of total 30 particulate concentration in the fuel _ oil and has a limit of 10mg/1.

It is acceptable to obtain a field sample for subsequent laboratory testing-in lieu of field testing.

Because the total stored fuel oil volume for DGs 18, 2A, and 2B is contained in two interconnected tanks, each tank must CALVERT CLIFFS - UNITS 1 & 2 8 3.8.3-9 Revisiond/o i

- - + -

,-c,--

- ~-.-

4.

t Diesel Fuel Oil B 3.8.3 j

BASES be considered and tested separately. There is a separate fuel oil storage tank for DG 1A.

r The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals.

SR 3.8.3.3 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive.

Removal of water from the fuel storage tanks once every 92 days eliminates the necessary environment far bacterial survival. This is the most effective means of controlling microbiological fouling.

In addition, it eliminates the potential for water 1

entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, and containinated-fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 6).

This SR is for preventative maintenance. The presence of water does not necessarily represent failure of this SR provided the accumulated water is removed during performance of the Surveillance.

REFERFNCES 1.

UFSAR, Chapter 8 2.

UFSAR, Chapter 6 3.

UFSAR, Chapter 14 l

CALVERT CLIFFS - UNITS-1 & 2 R 3.8.3-10 Revision 0 u

-..A-

Diesel Fuel Oil 8 3.8.3-BASES f

4.

ASTM Standards: D4057-1995; D975-1996 I#

5.

AST Standards, D975 Table 1 6.-

Regulatory Guide 1.137 i

l 1

P y-i h

p CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-11 Revisionf/o

A ac k d e 3c%.3 f

3.&

Wete ELEtit1 CAL POWER SYSTEM

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he o 4Al$

f ol/.gA // 4e an$n N*O

".h,& <.d,ufr.i a snJ,wk OC.

LIMITING CONDIT! M FOR OPERATION

^ ^

- ~ ^ ^ ~

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.m A...

_,., _ _--_.........rw... ov n.

.... w n e i r....

(a. Two physically independent circuits between the offsite%

1 transmission network and the onsite Class 1E Distributton System consisting of either 1.

Two 500 kV offsite power circuits. or ts necessary The f.,9 kV SMEC0 offsite kover circuit described in the 2.

dy b January 14, 1977 Safety valcation and one 500 kV offstte 4

\\

power circuits t :

and f '-

i 9

Two separate and independe.r,t diesel generators with:

l j

c Separate fuel oil day tanks containing a minimum volume oft (l 4

g g

1.

)

?

a.

325 gallons for No.1A Emergency Olesel Generator, and 3

$ callons for No. IB Emercener Diesel Generator.

q

), j j-Fuel 011 Storsge Tanks containing a minimum volume c6]

N a.

49.500 allons for No.1A Fuel 011 Stora9e tank, andy g

M3yWga'11onJA6fNo.1%el 011,$Wr' age % and k__85.000 calloni for ka z ?i ru.1 nti t+araoe Tank. ands A unarate fuel transfer pump for each diesel generator]

4 With two offsite circuits of the above required A.C. electrical power sourcet inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by perfoming Survelliance s-

^

Requirement 4.8.1.1.1.s within one hour and at least onct per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafters and 4.8.1.1.2.a.4 within 04 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , unless the Diese1 f,anerators are already eterttino. Restore at 1 emet two CALVERT CLIFFS. UNIT 1 3/4 8 1 Amendment No. 214 I Y !b 10 C*g

=

spa.#.J.

3. g. 3 i

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.su.wwu es e %y. %

g e, N b L '4 4,,

C' W Wh 3.s

-4M ELECTRICAL POW MTMS unmas ceuma Pea wtRmp (costie ee

. / errsite circuits to ursaABLE status within TZ hours or te in at f

least NOT STAS OY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLS SmWTBO W within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.

With one diesel generator inoperableforming Sunettlance demonstrate the OPERAB1LM of the remaining A.C. sources by per Requirement 4.8.1.1.1.s within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. and Surveillance Regetrement 4.8.1.1.2.a.4 i

within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Aestore two diesel generators to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least BOT STAW8Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLS SOUT90W within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ,

c. With two offsite circuits and one diesel generator of the above required A.C. electrical power sources inoperabic, demonstrate the OPERASILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hwr and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter and Surveillance Requirement 4.8.1.1.2.a.4 within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , unless the diesel generators are already operating. Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least BOT STAmsY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SMTDOW within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

"? store at least two offsite circuits and two diesel generators to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from the time of f..itial Ir r or be in at least BOT STAm8Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SarT90W within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

d.

With three of the above required offsite A.C. circuits inoperable demonstrate the OPERABILITY of two diesel eenerators by perforwIng Surveillance Requirement 4.8.1.1.2.a.4 within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months unless the diesel generators are already operating:

restore at least one of the inoperable offsite sources to SPERABLE ttatus within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least NOT STA m8Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With only one offsite source restored, restort at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from time of initial loss or be in at least NOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLS SWTDOW within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

e.

With two of the above required diesel generators inoperable, demonstrate the OPERASILITY of two offsite A.C. circuits by performing Surveillance Requirteent 4.8.1.1.1.a within one hour 5

(and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter restore at least one of j the inoperable diesel generators to OPERABLE status within j

CALVERT CLIFFS - UNIT 1 3/4 8-2 Amendment No. 169 ybM

S e$ cab 3.f.3 p

f 3/4.8 ILECTRICAL *0WER SYSTEMS LINITING CONDITION Fet 0iEAATION (Continued)

"AC brees. herei%"

fZ hours er av in es seest bei STAN05Y wf thin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and l

in COL 8 $ NUT 90601 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore at least L,l a

two diesel generators to SPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from time of initial loss or be in at least NOT STAW8Y within the tnext 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COL 8 SNUTD0lAl within the followins 30 Md

f. With ".he No.1A Fuel Oil Storege Tank (troMrable stratethef so i

H[vrsamItaT1eTsneremaininga.c.sourceseiSurveillance Requirement 4.8.1.1.

orsing Actious once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and by prfomin neoutrament 4.4.a.1.r.a.4 m. in==,g $urveillance.

A, E 4 F J

n a.i

- 2 1'/

w th' n f a ha-a. i nstrat he $PthA8 TV of No. 21 0'

(orage fa ' by perfo Sury' ell nce rement-thebingi f1w lj I-il 4

.1.2.a.

verifying gall s) and rif th from e No. 21 F 0I1Stor e Tank

.,s s

mereen Diesel Go stor with I hour.1 Mtore No.1A %

p)'

lmi storage Tant to ersansLE status withinR2Jhourz a a rr- __

g gesu no. i _. mo..... -- - - - - i trithin the followina 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .F g.

Ith the Nos. [11 anA21 Fuel Ol' Storace "make liaa-cable]

l.

Edee... trets sne Ursus4LITT of U.he remaln' ng A.C. Sources by S

perfoming Surveillance Requirement 4.8.1.1.1.a within one hour 45 M C.T s04)$

and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. and by perfoming Surveillance Requirement 4.8.1.1.2.a.4 on No.1A Emercancy Dlate 6 s4F denerator within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .1 Demonstrate tha 9ranABILITT of the, '" ^b' I

No. In fuel U115torage Tank by perfoming Surveillance Requirement <4.8.1.1.2.a.2 (verifying 49.500 gallons) and X

i verifying the flow path from the No.1A Fuel 011 Storace fan 1*

/,/

the No.-1A EmeraaTev Diese9 Sanerator within 1 h= 1 Restore reIIherNo.IIodl Fuel 0451prane Tanks to OP 'hAfLE status f(,)

(within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months spr av an

.6

. -. eiv i.. _. wi.nin ins neuj te nours ano in E0LD $NUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . A g No' f'or '21 Fuel Oil Storage Tank (IIi30erabl I

h.

With either h PERABILI1T oT the other ruti vil 5torage Ta%

emonstrate t e n10

['l McfsN b by: 11 perforuina Surveillance Reautrement 4.8.1.L2.a.2 ying 85.000 gallons) within 1 hourJand at least once per)

Everif

[]) hour, snwrreneruanc z) ver1Tylng ITie Tiow patn Tram sne i l

operaD e ruel Of f 3torage Tank to the No.13,ilierge,yDiesAe1 tGenerator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .]

p,3 i

KasskT Acrs$ D 1

N J

l CALVERT CLIFFS - UNIT 1 3/48-3 unhent No. 214 6

3 o

INSERT D.

One or more OGs with 0.1 Restore fuel oil 7 days stored fuel oil total total particulates particulates not to within limits.

within limits.

[086 N Ok Il

- - _ = -. -

S p.48we b.1.g.3 1

1 1 -3/4.8 ELECTRICAL Petitt SYITDG w bm.6.n / dway A scattILLANCE attuttnerfs r-c.r.u6 3 ti.I, ". AA

%. om. g.

/

)

"4.8.1.1.1 Each requires i...... ursva pn-.... une ensne t

[

transmissi6n network and the onsite Class 1E Distribution System shall pes}

4.

Demonstrated SPt4ABLE. as ft,110ws:

}

.i 1.

For each 500 kV offstte circuit at least once Mr 7 days by verifying correct breaker altenments and indicated power

}

availability.

2.

For the 69 kV $MECO offsitt power circuit within one hour o substitution for a 500 kV ^'fsite power cIrcutt, and at less once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter during use by vertfying correct breaker alignments and indicated power availabilityg and Demonstrated OPERABLE at least once per REFVELING INTERVAL durinh b.

shutdown by manually transferring unit power supply from the nomal circuit to the alternate circuit.

.8.1.1.2 Each diesel generator :nall be demonstrated OPERABLt:

a. At least once per 31 days on aGTAGGetED issi EtHD5y L__varifvinathefuellevelit: the dav faal

+='4 3

% Vertfying the fuel level in the fuel storage tank.

d 3,0 3 }

ra. veruying the fuel transfer pump can be startes anc tranuers' I

fuel from the storage system to the day tank.

4.

Vertfyingthedieselstartsandachievesageneratorvoltage and frequency.cf 4160 1 420 volts and 60 1 4.2 Hz.

respectively.

5.

Verifying the generator is synchron1 red. Ioaded to

4000 kW for No.1A Emergency Diesel Generator or > 2250 kW Tor No.1B Emergency Diesel Generator, and operates Tor a 60 minutes.

6.

Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

7.

Verifying that the automatic load sequencer timer is OPERABLE with the interval between each load block within i 10% of its design interval.

i All engine starts for the purpose of this St..teillance Requirement may be preceded by an engine prelube period and/or other warsup procedures reconrended by the manufacturer so that mechanical wearj (and stress on the diesel engine is minimized. f CALVElti CLIFF 5. UNIT 1 3/4 8-4 Amendment No. 214 e., s.e n h

Spdubs~ 3 03 V1. l 3/4.8 ELECTRICAL p0WER SYSTDt$

smartLLAmerReevlacetwTs(contined)

.ift 34.k1

b. ' t least e per vz says Dy fy that a sample o siese q -

fuel f he fuel storage t i

in the accept e lletts msre.

pecif in Table 1 of AS 5

checked f viscosity.J g gas ate nd sediment.I 4-w::r.a 510 secondsp:: =,:wwame,srwm i

d.

At least once per REFUELING I RERVAL by:

1. Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its annufacturer's recoassendations for this class of standby service.

Verifying the generator ca 2.

1500 hp without tripping.pability to reject a load of 3.

$1mulating a loss of offsite power in conjunction with a safety injection actuation test signal, ands a) Verifying de energization of the emergency busses and load shedding from the emergency busses.

b) Verifying the diesel starts from ambient condition on the auto start signal, energizes the emergency busses with pennanently connected loads, load sequencer and operates energizes the auto-connected emergency loads through the for t 5 minutes while its generator is loaded with the emergency loads.*

c) Verifying that automatically bypassed diesel trips are automatically bypassed on a Safety injection Actuation Stenal.

4.

Vertfying the diesel generator operates for 160 minutes while loaded to > 4000 kW for No.1A Emergency Diesel Generator or 12700 kW for No. IB Emergency Diesel Generator.

5.

Verifying that the auto-connected loads to each diesel geherator do not exceed 4000 kW for No.1A Emergency Diesel Generator or 2700 kW for No.18 Emergency Diesel Generator.

All engine starts for the purpose of this Surveillance Requirement may be preceded by an engine pre-lube period recomunended by the manufacturer 50 that mechanical wear and stress on the diesel engine is minimized.

n Su D wes..s of h. In y

Sp.,4c.4m 35.1,*A.c,/

Gwu, - on J.

or CALVERT CLIFFS. tlNIT 1_

3/4 8 5 Amendment No. 211 guy b of Il

i Sf'*I'edron T.7,3 JNSERT SR 3.8.3.2 I

SR 3.8.3.2 Verify fuel oil properties of new and stored fuel oil are In accordance with tested in accordance with, and maintained within the limits the Diesel Fuel Oil t

of, the Diosol Fud Oil Testing Program.

Testing Program h

INSERT SR 3.8.3.3 SR 3.8.3.3 Check for and remove accumulated water fran each fuel oil 92 days storage tank.

r i

4 s

a

_ _. _ _ _. _ ~. = _

~ _.

i S P *** k o. '),t; y 8

'3, g 0l0.; atCTt! CAL Paurn SYSTEl:$

M A C' SW y k m.,,f <},.ay. %.

Shutdown Sp65 4m 1.%. h " A4-p skddr44.*

LDttT188 COWITIM Fet ePERATIM w

3.4.1.2 As a minimum. the following A.C. electrical power sources sh411 be SPERABLE:

I i

a. One circuit between the offsite transmission network and the i

ensite Class 1E 01stributton System, and

b. One diesel generator with:

1. A fuel o11 day tank containing a minimum volume of:

s.

325 gallons for No.1A toergency Diesel Generator 8 or L275 nellons for No.18 Emergency Diesel r neratort and A ruel 0115t6 rage 3ystem containing a minimum volume of ^

s 49,600 callons in No."iA Fuel Oil Storage Tank for the a.

No.1A Imergency Diesel Ganerator8 or h4 b.

85.000 gallons in No. 21 Fuel 011 Storage Tankfantr33 ML.

I

(,.{w. top Ubsso. ILJegrl 01Latpranamriffr the j

.l gM as amergency piessi menerator, and,

/3. A Tuel transfer pump M m.

n., i, n.

.,,v.--

v, m,

w ACIlQtle

a. With less than the above minimum requireo A.U. eleCtrlCal powt sources DPERABLE:

l 1.

Inmediately* suspend all operations involving tott ALTERATIONS. positive reactivity changes. movement of irradiated fuel and movement of heavy loads over irradtsted fuel, and 2.

Ismediately initiate corrective actions to restore the I

minimum A.C. electrical busses to OPERABLE status, and Performance of ACTIM a. shall not preclude completion of actions to

( estabitsh a safe conservative position. _

CALVERT CLIFFS - UNIT 1 3/4 6 6 Amendment No. 214 a

$ CeklcAYe>< $

f

=

Set busdubO es 3/4.8 ELECTRICAL POWER SYSTEMS b 4 9t NitA M 3 I I l

i 3

LIMITING CONDITION FOR OPERATION (Continued) 3.F All containment penetrations providing direct access from t@

containment atmosphere to the outside atmosphere shall be i

either closed by an isolation yt1ve, blind flange, or manual valve, or be capable of being closed by an OPERABLE autom purge valve. A minimum of one door in each airlock shall be closed and the equipment door shall be closed and held in >

(place by a alsimum of four bolts.f b.

FWith th

o. Ili Emergency Ole Generator requi d to be OPERA and the No. 11 Fu 11 Storage Tank operable.

demo trate the OPERABIL of No. 21 Fuel Storage Tank b.

[,)

j

. Performing Surve ance Requireinent

.8.1.1.2.a.2 (ve yint1 85,000 gallon within 1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months an 2.

Verifying e flow' path from

. 21 Fuel Oil Sto se Tank to

( No. 1B rgency Diesel Gen stor within 1 hou.

c. With the No.1B Emergency Olesel Generator required to be or:RABLE and the._No1_21 Fuel.011 Storace TankrinoceraDiea I

gg dewanstrate the OP[RABILITY of No.11 Fuel Oil Storage Tint byp

.1.YPerfo'rnine Surveillance ~ftehulresznt 4.8.1.1.2.4.2)(veri fying g3 B,64F e5,000 saiions) within 1 hourt tand f 2.

Verifying the flow path from No.11 Fuel Oil Storage Tank to

,)

the No. IB Emtrgency Olesel Generator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

J Restore No. 21 Fue) 011 Storage Tant to OPERABLE sEtus within 72 h

rs or suspena all operations involving CORE ALTERATION $[)

tve peactivity changes, movement of irradiated fuel and pos (yvemoser of nepr span opr Irrapered fAJ d.

With the No.1A [mergency Olesel Generator required to be

~

gg

[ 0PERABLE a the No.1A Fuel 011 Storage Tank inoperable.

f IImmediateT uspena all operapons twosving tunt ALlERATIONS.L ga ggp

. positive reactivity changes, movement of f rradiated fuei and f npet'fhent oi,Jttsyy igen urcrpaQlat@el.]

L l.b.I ZAH EE T Aerion D O(M J

Per e of A

d. shall reclude letion o ions to est ish a safe nservative ition. f-e CALVERT CLIFFS - UNIT 1 3/4 84 Amendment No. 21a po p 9 e; il M

INSERT D.

One or more DGs with D.1 Restore fuel oil 7 days stored fuel oil total total particulates particulates not to within limits.

within limits.

B 1

t pga10ofll h

.=

. Spa +(sub % 3.$,3 3/4.8 ELECTRICAL Petitt $YSTDt$

setyt1LLAmet trestacarts 1.8.1.2 The abeve required A.C. electrical power sources shall be demonstrated 9PtWLt by the performance of each of the Surveillance Rogsf rements of 4.8.1.1.1 and 4.8.1.1.2 ucept for Requirements 4.8.1.1.2.a.5, 4.8.1.1.2.a.7. 4.8.1.1.2.d.3. and 68.1.1.F.d.5.

,, hswssis, of cbar 9,, R. 6 3.5 t j " A C-Se,e - sk4W" 1

i i

i l

CALVERT CLIFF 3 - UNIT 1 3/4 6-8 Amendment No. 214 i

h i

Specification 3.8.3 t

Unit 2 1

I

}

s

-,e

S r. c... <...

~5. 8. 3 i

I 3.7

$/4:4 EtECTRICAL PfniER SY1TE!1 T,. '3 3

/**.1 A m Rcts /hel Ad di/

0"Wt' M 7 ' JK,,s d,o, fy,/ o;/ s 4*// b

^

g

/.%dt $,, gQ,,,I,;eup gl,us) jo ~"N00*

LIMITIN COMITI0ld FOR OPE T

-w Lc. O

'5,v.3 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLT*

Two physically independent circuits between the offsite a.

transmission network and the onsite Class 1E Distribution System g,

consisting of either:

Y 1.

,, T Two 500 kV offsite power circuits, or as necessary

T, 2.

The 69 kV SMECO offsite power circuit described in the 8

January 14, 1977 Safety Evaluation and one,00 kV offsite 6,,' p power circuitt gNj and

ff b.

Two separate and independent diesel generators with:

b.

<[0 1'

1.

Separate fuel oil day tanks containing a minimum voline of l-2 OSlions of fuel for each diesel generator, f{

[2. A convnon Fuel Storage System consisting of:

D No.21FuelOilStorahueloilande Tank containing a minimum volume a.

gj of 85.000 gallons of.

jl g

hI*

No. Il el 011 S' a e Tank ntainin vainimum ume of 3 00 gallo of uel

, and I

bI M

i

,, Qseparate fuel t'ransfer pump for each diesel generator")

APPLICABillTY: 4100ES-Ir-Er-3-andA

=

ACTION:

(,.

o s s.,. 4 ed DOG ____t b" '

J '*

w With two offsite circuits of the above required 5C. electric 415 a.

power sources inoperable, demonstrate the OPERABILITY of the p,

renrining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter: and 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unless the diese generators are already operating. Restore at least two CALVERT CLIFFS - UNIT 2 3/4 8-1 Amendment No. 191 l

kob pae c

hei fi,. 4 c e IS 2.3 5-c D we,.r G.

.., N Sy e, r'... 4., 3

,3,l 3/4.8 ELECTRICAL POWER SY M E "A4

%. e n - O g., u...,

LIMITIM CONDITION FOR OPERATION (Castinued)

'\\

offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be inYt le&st NOT STANDsY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SNUTD0lRI within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months , b.

With one diesel generator inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.s within one hour and at least orce per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter, and Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Resto m two diesel generators to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least NT STAW8Y cithin the i

next 6 hocrs and in COLS INT 90lAl within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

t c.

With two offsite circuits and one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate i

tin OPERABILITY of the remaining A.C. sources by psrforsing 1

Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter and Surveillance Requirement 4.8.1.1.2.a A within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , unless the diesel generators are already operating. Restore at least ene of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or be in at least NOT STAND 5Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD 5NITTD0lAl within the following 30 houn. Restore at least two offsite circuits and two diesel generators to OPERAELE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from the time of initial loss or be in at least NOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SWTDetal witMn the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

d.

With three of the above required offst'te A.C. circuits inoperable demonstrate the OPERABILITY of two diesel generators byperformIngSurveillanceRequirement4.8.1.1.2.a.4within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months unless the diesel generators are already operating; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least NOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from time of initial los t or be in at least NOT STAMBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHVIDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

. With two of the above required diesel generators inoperable, demonstrate the OPERASILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.1.1.1.a within one hour

( and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within

.'/

.' w CALVERT CLIFFS - UNIT 2 3/4 8-2 taendment No. 149 3

o9 il pay

S,c $ ca h 3,t 3 -

p

~

A 0T t.1' 80 t

),e l

'3/4.8 ELECTRICAL POW (R SYSTDl3 Y

4,Speci b 4.T.A.)

Lilt! TIM Com! TION F0k OPERATION (Continued)

S c g,,q,c -apn.W q,

a f

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least NOT STAIElBY within the next nd in COLD $NIR90lel within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Restore at lea two diesel generators to SPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from

. time of. initial loss or be in at least NOT STAlulBY within the i

L===t s 6..e and in casa _ 5857D0681 within the fallawina in 6.

J With the No. 21 Fuel Oil Storage'Tanklinoperablebidding the; 7'

f.

period from:

~

burDAU

1. fMobev1 tcAared.Tdemonstrate the OPERABILITY of the c,t(F no. u cuei vu >; orc.e rank by: 1) performing survetiiance L,i

' Requirement 4.8.1.1.2.a.2 (verifying 85.000 gallonal within l-IJiour and at least once per 8

hours thereafteridiii3 N.3 1

1) vertrying sne risw path from the No.11 Fumi 011 paracD A

. Tank to the c'esel nenarators within 1 6 = 1 Restore-g No. 21 rue 't

' i naeage Tank to_DFERABLE status within 72'hourspr se in as suon avi ei__v witnin the nut

[6 nours and in COLD $NUTDOW11 within the'fallawina 20 haurs.

g

.5

.@ led h-

,2.

April m to Sectem>erMemonstrate the OPERABILITY of cgwo git.u a,g,, muits by perfoming Surveillance Requirement 4.8.1.1.1'.a within I hour and at laaet anca ne' r 2-e I O hours thereafter.1 Restore No. 21 Fuel Oil Storage Tant Yo L OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Jor ce in at least avi avr__rl in unw n.u e av.m ana in COLO $NUTD0lai within the j following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . f i

l

g. fWith No.*1 uel Oil Storage Tan noperable, demon ate the OPERA 51 of No. 21-Fuel Oil torageTankby1) rforming i Surve ance Requirement 4.8

.1.2.a.2 - (veri fyin 5.000 gallons

'l-wit I hour and at least nee.per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months th after, and verifying the flow pa from No.~21 Fuel Storage Tank

,l he diesel generators thin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Rest e No.-11 Fuel Storage Tank to OPE LE status within 7 ays or be in a east l'

NOT STAN0BY withi he next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months an in COLD SH within) jhefollowing3 incurs. f

^%62.1 Ae:rroA) Q tt.t; SURVEILLANCE REQUIREMENTS 4.8.1.1.1 tacn required independent circuit between the offsite transmission network and the onsite Class IE Distribution System shall be:

a.

Demonstrated OPERA 8LE. as follows:

1.

For each 500 kV offsite circuit, at least once per 7 days by z

verifying correct breaker alignments and indicated power j availability.

i p

CALVERT CLIFFS - UNIT 2 3/4 8-3 Amendment No. 191 See, his'em ok Okage5 I

L spew:caan nu "M Sources-O oralI$

t g e l d 11 b

1 lI

~

'Ir1 SERT A.

Fuel oil storage tank A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (FOST) 1A with fuel volume to within oil volume limits.

< 49,500 gal and 2 [42.430] gal, b

D.

One or more DGs with D.1 Restore fuel oil 7 days stored fuel oil total total particulates particulates not to within limits, within limits.

6 Okhh

S ye.C.,.A e 3.7.~3 J

1 l

3/4.8 ELtcTRICAL POWER SYSTDt$

[,',I((,,

[' A p

SURVEILLANCE REQUIRDIDfTS (Continued)

(

5.wreas - De***+ %

2.

For the 69 kV SMECO offsite power circuit within one hour of substitution for 4 500 kV offsite power circuit. and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter during use by verifying correct breaker alignments and indicated power availability and b.

Demonstrated OPERABLE at least once per REFUELING INTERVAL during shutdown by manually transferrin) unit power supply from the normal circuit to the alternate circuit.

d 1.1.2 Each diesel generator shall be destrated OP9#LE:

y At least once per 31 days on a@AG8tRED/tST 845!Dby:

f a.

Verifying the fuel levei in the day fuel tanQ

$R 3,9.3.l

$ Verifying the fuel level in the fuel storage tank.

[6 76fiffThg the fuel transfer' pump can be started and transfers fuel from the storage system to the day tank.

4.

Verifying the diesel starts ~ and achieves a generator voltage l

and frequency,of 4160 1 420 volts and 60 1.2 Hz.

1 respectively.

5.

Verifying the generator is synchronized. *oaded to 12700 kW.

l and operates for 160 minutes.

6.

Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

7.

Verifying that the automatic load sequencer timer is OPERA 8LE

( with the interval between each load block within i 10% of its i

design interval.

_J

b. T ienst once er u cays oy ver fying tnat a sample of dieseT 6A 3.S,3,2.

fuel from t fuel storage ta i

hin the accepta e limits

{ specified r) Table 1 of ASf 975 en checked f viscosity.

AO qvater a sediment.

ZNf64 M16.3,7, N

All engine starts for the purpose cf this Surveillance Kequiremen may be preceded by an engine prelube period and/or other warsup procedures recommended by the manufacturer so that mechanical wear and stress on the diesel engine is minimized.

CALVERT CLIFFS - UH T 2 3/4 8-4 Amendment No. 191 9~ y 5& II h

podrtM tm 5.T 3 --

S INSERT SR 3.8.3.2 S R 3.8.3.2 Verify fuel oil properties of new and stored fuel oil are in ashec with tested in accordance with, and maintained within the limits the Diesel Fuel Oil of, the Diesel Fuel Oil Testing Program Testing Program INSERT SR 3.8.3.3 S R 3,8.3.3 Check for and remove accumulated water from each fuel oil 92 days storage tank.

4

h y c. P. c *4 s ch 3-

3 i

3/4.8 ELECTRICAL POWER $YSTEMS SURVEILtAllCE REQUIREMEllT$ (Contissed)

[CNTleastonceper164daysbyverifyingthedieselst ambient cond1

[

510 seconds.} ton and accelerates to at least 60 Hz in.l d.

At least once per REFUELIIIG IllTERVAL bf:

1.

Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service.

2.

Verifying the generator capability to reja:t a load of 1 500 hp without tripping.

3.

Simulatino a Irss of offsite power in conjunction with a safety injection actuation test signal ands a) Verifying de-energization of the emergency busses and-load shedding from the emergency busses, b) Verifying the diesel starts from ambient condition on the auto-start signale energtzes the emergency busses with pemanently connected loads, energizes the auto. connected emergency loads through the load sequencer and operates for 15 minutes while its generator is loaded with the emergency loads.*.

c) Verifying that automatically bypassed diesel trips are automatically bypassed on a Safety Injection Actuation Signal.

4.

Verifying the diesel generator operates for 160 minutes while loaded to 13000 kW.

l S.

Vertfying that the auto-connected loads to each diesel generator do not exceed 3300 kW.

All engine starts for the purpose of this Surveillance Requirement may be preceded by an engine pre-lube period reconnended by the manufacturer so that mechanical wear and stress on the diesel engine is minimized.

CALVERT CLIFFS - UNIT 2 3/4 8-5 Amendment No.191

)

gp e 4, d W de t & *%

O4$#%

7p,s.E,

%un s

5 G o., m O p u s +. 5 page h o E ll

h><c.A$w4*bn

3. 8. ]

I l

3,9

-5/4.4. ILl;f11 CAL PWER SYSTDt3 5, e %wn.,

r c L...s,,

o 3/4.8.1 A.C. SOURCES p,

$ p. e. 6, f.. %

3. S. '2, Shutdown

- 4 J C.

S ow.c,5 - Op

4 3

LDEITIES COWITION FOR OPERATIM 3.8.1.2 As a minisus, the following A.C. electrical power sources shall be OPERABLE:

I a.

One circuit between the offsite transmission tietwork and the f

onsite Class 1E Distribution 'ystes, and c.

One diesel generator with:

1.

A fuel oil day tank containing a minimum volume of 275 gallons of fuel,

2. T conson Fuel storage syst$ consisting of:

a.

No. 21 Fuel 011 Storage Tank containing a minimum volume -

of 85,000 gallons of fuel oil, and j

33 n of 1

f A fuel transfer pump. 7 fDPIfcABILITYt NADH E==d 5.-

a.

With less than the above minimum required A.C. electrical power sources OPERABLE:

l 1.

Innediately* suspend all operations involving CORE ALTERATIMS. positive reactivity changes, movement of irradiated fuel and movement of heavy loads over irradiated fuel, and 2.

Innediately initiate corrective actions to restore the minimum A.C. electrical power sources to OPERABLE ttatus, and

( Perfonnance of ACTION a. shall not preclude completion of actions to establish a safe conservative position.

CALVERT CLIFFS - UNIT 2 3/4 8-6 Anendment No. 191 pg e b oE l}

5pec'ihee.A.b 3.2.3 s

See b;scussim o(CL es 4

S @ ' O l'l 3/4.8 ELECTRICAL POWER SYSTENs P

a LIMITING CONDITION FOR OPERATIM (Continued)

"M # "

3. 'Allcontainmentpenetrationsprovidingdirectaccessfromthe]

containment atmosphere to the outside atmosphere shall be either closed by an isolation valve, bitnd fla e, or manual valve, or be. capable of being closed by an OP LE automatic purge valve. - A minimum of one door in each airlock shall be closed and the equipment door shall be closed and held in g by a mini== ef four bolts.

b.

W1th the No. Il Fuel 011 Storage Tank inoperable, demonstrate thel OPERASILITY of No. 21 Fuel 011 Storage Tank by:

,I 1.

PefformingSurveillanceRequirement4.8.1.1.2.a.2(verifying-85.000 gallons) wtthin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; &nd 2.

Verifying the flow path from No. 21 Fuel Oil Storage Tank to 1 the diesel cenerator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

c.

With No. 21 ruel Oil Storaae Tankanonerabbemonstrate th gpg vruuw1LITT of sio.11 Fuel Oil Storage Tant Dy:

~

o. ro-ine survemance n.-<rement u.i.u.o (veritying lA3 gJ g g p' a.

85.000 gallons) within I hour 3 g (2. Verifying the flow path from No.11 Fuel 011 Storace Tank to]

b'

(

the diesel generator within I hour. r TRestore so. za ruei v's storano Tank to OPERABLE status within

.3 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sfor suspend a'I operat ons involving CURE ALTERATIONS.

"pbsittve reactivity chances. movement of irradiated fuel and Wovement of neavy loads over irraaistea mes.]

^

+

/.[.I WJSEer Aesh Q

.I s-

~

g g"Q ~f b CTIOK) h CALVERT CLIFFS - UNIT 2 3/4 8-7 Amendment No. 191 L

. - ~... ~

eM llNSERT g-o i-A."

Fuel oil-: storage tank A.1~

Restore feel oil 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months s-(FOST) 1A with fuel volume to'within oil volume limits.

< 49.500 gal and

'I 2 [42,430] gal.

v D.

-One or more DGs with 0.1 Restore fuel-oil 7 days, stored fuel oil total total particulates particulates_not to within limits, within limits.

4 i '

e i

p3e.10 d il k

$ pre Incadeo

7. 3. 3 '

2 i

3/4.8 ELECTRICAL POWER SYSTEMS

. SURVEILLAllCE REQUIRENDITs T.8.1.2 The above esquired A.C. electrical power sources shall be demonstrated OPERABLE by the performance of each of the Surveillance }

Requirements of 4.8.1.1.1 and 4.8.1.1.2 except for Requirements 4.8.1.1.2.a.5, 4.8.1.1.2.a.7. 4.s.1.1.2.d.3, and

[4.8.1.1.2.d.5.

d.

.w w,..

.r O wges pos spec. f. c 4.on

3. T. 7,

" 4C S c u e r - s --

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CALVERT CLIFFS - UNIT 2 3/4 6-8 Amendment No. 191 p.3 e il d 11 fh

4 DISCUSSION OF CHANGES SECTION 3.8.3 - DIESEL FUEL OIL ADMINISTRATIVE CHANGES A.1 The proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change of intent, to be consistent with NUREG-1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users.

During the Calvert Cliffs ITS development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Tec' nical Specifications. Additional information may also have been added to more fully describe cach LCO and to be consistent with NUREG-1432. Ilowever, the additional information does not change the intent of the CTS. The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications.

A.2 Current Technical Specification 3.8.1.1 applies to AC Sources during Modes 1,2,3, and 4, and CTS 3.8.1.2 applies to AC Sources during Modes 4 and S. He Improved Technica:

Specification separates the portions of 3 8.1.1 and 3.8.1.2 which deal with the fuel oil storage tank (FOST) and creates a new Technical Specification for diesel fuel oil (LCO 3.8.3,

" Diesel Fuel Oil"). nia change separate out portions of CTS 3.8.1.1 and CTS 3.8.1.2; specific changes to these portions will be discussed in other discussions of changes. The moving of requirements within the Technical Specifications constitutes an administrative change. This change is consistent with NUREG-1432.

A.3 Current Technical Specifications 3.8.1.1 and 3.8.1.2 Applicability is Modes 1,2,3, and 4, and Modes 5 and 6, respectively. Improved Technical Specification 3.8.3 requires the Diesel Fuel Oil Technical Specification to be applicable when the associaied DG is required to be Operable. The AC Sources are required to be Operable in Modes 1,2,3,4,5, and 6, as required by ITS 3.8.1 and 3.8.2. Therefore, the addition of the Applicability for ITS 3.8.3 is an administrative change. This change is consistent with NUREG 1432.

A4 Current Technical Specifications 3.8.1.1 and 3.8.1.2 LCOs contain requirements for the specific amount of fuel oil that must be stored in the FOSTs. Improved Technical Specification 3.8.3 will move this requirement from the LCO to the SRs.

Moving l requirements within the Technical Specifications constitutes an administrative change. This change is consistent with NUREG-1432.

A.5 Current Technical Specification 3.8.1.1 Unit 1 Actions f(No. l A FOST moperable) and g (FOST Nos.11 and 21 inoperable) require the perfonnance of an AC sources breaker lineup and a DG Operability test when a FOST is inoperable.

Current Technical Specification 3.8.1.1 Unit 2 Action f.2 requires an AC sources breaker lineup when No.21 FOST is inoperable. Improved Technical Specification 3.8.3 will not contain these requirements. The ITS provides Actions that will allow a period of time to restore the FOST to Operable status in the event the FOST is inoperable due to fuel oil volume not being within limit, but greater than approximately a six day supply, or the fuel oil properties not within limits. In the event one of these Actions is not met, or if the FOST is inoperable for any other reason, the associated DG is declared inoperable. Once the DG is declared inoperable, the Actions in the DG Specification must be followed, which are consistent with the above listed CTS requirements. This change to the CTS is a result of cther changes to CALVERT CLIFFS - UNITS I & 2 3.8.3-1 Revision 10

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DISCUSSION OF CHANGES SECTION 3.8.3 - DIESEL FUEL OIL the Specification (to declare the DG inoperable) in a less restrictive discussion of change.

3 Therefore, this change is administrative. His change is consistent with NUREG-1432.

A.6 Current Technical Specification 3.8.1.1 Actions f and g require the plant to enter a shutdown track when the Required Actions cannot be met when the fuel oil storage requirements are not within limits. Ituproved Technical Specifications will not contain these requirements.

The ITS will require the associated DG to be declared inoperable and the Actions of Specification 3.8.1 be entered. If the Actions of the DG cannot be completed in the required time limit, the Act!ons will require the plant to enter a shutdown track. The movement of requirements from one Specification to another constitutes an administrative change. This change is consistent with NUREG-1432.

A.7 Current Technical Specification SR 4.1.1.2.b requires verifying that a sample of diesel fuel from the FOST is within th: acceptance limits specified in Table 1 of American Society for Testing MaterialD975-81 when checked for viscosity, water, and sediment. Improved Technical Specification SR 3.8.3.3 will refer to the Diesel Fuel Oil Testing Program, nis change relocates the requirements of CTS SR 4.1.1.2.b to Section 5.0 of the ITS. He movement of requirements within the Technical Specification constitutes an c.iministrative change. His change is consistent with NUREG-1432.

TECIINICAL CIIANGES - MORE RNTRICTIVE M.1 Improved Technical Specifications will add an SR (SR 3.8.3.3) to remove accumulated water from the FOSTs once per 92 days. Current Technical Specification 3.8.1.1 does not contain this requirement. He addition of this SR to remove the accumulated water in the FOSTs will help climinate microbiological fouling, which is a major cause of fuel oil degradation, ne addition of Surveillances constitutes a more restrictive change, his change will not adversely affect plant safety because a major cause of fuel oil degradation is reduced by performing this SR. This change is consistent with NUREG-1432.

M.2 Current Technical Specification 3.8.1.2 Action c. requires the No. 21 FOST to be restored to Operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when it is inoperable due to the level not within limits.

Improved Technical Specification 3.8.3 Actions will require it to be restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . In the CTS, if the level cannot be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , Core Alterations, movement of irradiated fuel, and positive reactivity additions must be suspended. In the ITS, the DG is required to be declared inoperable. The Actions for the inoperable DG would require the suspension of Core Alterations, movement of irradiated fuel, and positive reactivity additions. Therefore, this change decreases the allowed outage time (AOT) when the No. 21 FOST is inoperable due to level, from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months AOT for the No,21 FOST level allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank.

Decreasing an AOT constitutes a more restrictive change. This change will not adversely affect plant safety because 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allows enough time to restore the appropriate level in a FOST His change is consistent with NUREG-1432 M.3 Improved Technical Specification 3.8.3 Condition F addresses inoperabilities other than addressed by ITS 3.8.3 Conditions A through E, and requires that the affected DG(s) be immediately declared inoperable. Improved Technical Specification 3.8.1 will continue to provide a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for an inoperable DG. Since No. l A FOST only }

CALVERT CLIFFS - UNITS 1 & 2 3.8.3-2 Revision 10

DISCUSSION OF CHANGES SECFION 3.8.3 - DIESEL FUEL OIL supports No. l A DG, ITS 3.8.3 Condition F and ITS 3.8.1 (which allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for an inoperable No. I A DG) are msistent with the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed for an inoperable No l A FOST by CTS 3.8.1.1 Unit 1 Action f. However, No. 21 FOST supports two DGs associated with each unit, and CTS 3.8.1.1 Unit 1 Action g and Unit 2 Action f.1 address the inoperability of No. 21 FOST by providing an AOT of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with the FOST (and therefore, two DGs) inoperable. His AOT for this condition is not retained in ITS since ITS 3.8.1 requires one of these DGs to be restored to Operable status within two hours.

Therefore, for No. 21 FOST, the adoption of ITS 3.8.3 Condition F is consistent with the CTS 3.8.1.1 Unit 2 Action f.2 AOT but more restrictive than CTS 3.8.1.1 Unit 1 Action g and CTS 3.8.1.1 Unit 2 Action f.! AOTs. Rese changes are consistent with NUREG-1432.

Current Technical Specification 3.8.1.1 Unit 1 Action h allows for the fael oil volume in No,11 FOST to fulfill the Unit I requirements for a seven day supply for No. IB DG when No. 21 FOST is inoperable. Number 11 FOST and No. 21 FOST both support Unit I required Nos.1B and 2B DGs. Number 2B DG is required for Unit I since it supports some Unit I required equipment such as CREVS which is redundant to equipment supported by No, l A DG, Herefore, the allowance for No.11 FOST fuel oil to be used in lieu of or in conjunction with the fuel oil in No. 21 FOST is also applicable to No. 2B DG in ITS 3.8.3.

Since the capability to support No. 2B DG was not required by CTS, this change is more restrictive than CTS.

With FOST fuel oil volume less than required, CTS 3.8.1.1 Unit 1 Actions f and g and CTS 3.8.1.1 Unit 2 Action f.1 provided a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT. The equivalent ITS 3.8.3 Conditions, i.e., Required Actions A.1, B.2, and C.3, will include Completion Times of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Since no action was required by CTS for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , these changes are more restrictive than CTS. These changes are consistent with NUREG-1432.

wig No. 21 FOST fuel vil volume less than required, CTS 3.8.1.1 Unit 2 Action f.1 requires verification of the backup fuel oil supply within one hour but only if the inoperability occurs between October 1 and March 31 (primarily because the No. 21 FOST fuel oil volume is required to be restored to within limits within two hours during the rest of the year, i.e.,

during tornado season). To simplify the Specification, this one hour verification of the backup fuel supply is required during the entire year.

1 M.4 Current Technical Specification 4.8.1.1.2.b references ASTM-D975-81 for sampling the diesel fuel oil storage tanks for viscosity, water, and sediment. Improved Technical Specification B 3.8.1 requirements for testing the diesel fuel oil storage tanks will require l

compliance with ASTM-D975-96. This change will commit Calvert Cliffs Nuclear Power l l

Plant to the updated ASTM which contains additional testing requirements. The requirement to include additional testing constitutes a more restrictive change. This change does not impact plant safety because the updated A$TM includes better testing methodology along with additional testing which allows for a more thorough test of the diesel fuel oil.

Current Technical Specifications 3.8.1.1 and 3.8.1.2 provide requirements for DG FOSTs but do not contain any requirements or limitations for total particulates in the fuel oil. Improved Technical Specification 3.8.3 includes requirements in SR 3.8.3.2 that the total particulates be within limits established by the Diesel Fuel Oil Testing Program, and provides Condition D for total particulates of the stored fuel oil not within limits. Condition D includes a seven day Completion Time which is appropriate since particulates is typically a CALVERT CLIFFS - UNITS 1 & 2 3.8.3-3 Revision 10

DISCUSSION OF CIIANGES SECTION 3.8.3 - DIESEL FUEL OIL slowly changing parameter and the probabilities are high that the DG remains capable of performing its function. Limits on total particulates are appropriate for DG fuel oil since the particulates can cause fouling of filters and fuel oil injection equipment, which can lead to DG failure. Since no requirements exist in the CTS for particulates, these changes are more restrictive than CTS. These changes are consistent with NUREG 1432.

TECIINICAL CHANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROILFD DOCUMENTS LA.1 Action c of Units I and 2 CTS 3.8.1.2 and Action d of Unit 1 CTS 3.8.1.2 require the suspension of movement of heavy loads over irradiated fuel when one required FOST is inoperable. Since crane operation is not necessarily affected by the loss of one these FOSTs, the requirements associated with the suspension of heavy load movement over irradiated fuel assemblics are to be relocated to the UFSAR. De bounding design basis fuel handling sccident assumes an irradiated fuel assembly is dropped and damaged. De movement of heavy loads (loads other than fuel assemblies) is administratively controlled based on heavy loads analyses. The heavy loads analysis methodology and crane operation which dictate the controls are described in the UFSAR. Therefore, the Actions associated with crane operations involving heavy loads are not required to be in the ITS to ensure adequate control of heavy loads and are to be relocated to the UFSAR. Changes to the UFSAR will be adequately controlled by the provisions of 10 CFR 50.59.

LA.2 Current Technical Specification 3.8.1.2 Action d footnote (*) requires that the performance of Action d. not preclude completion of actions to establish a safe conservative position.

This requirement is being moved to the Improved Technical Specification Bases. The ITS Bases states that suspension of these activities does not preclude completion of actions to establish a safe, conservative condition. The movement of this requirement to the Bases will still ensure that the actions taken will establish a safe, conservative position. His type of specific information is being moved to the Bases as part of the conversion to NUREG-1432.

Any changes to these requirements will be in accordance with the Bases Control Program in Section 5.0 of the ITS. This will ensure that any changes to these requirements will be appropriately reviewed, This change is consistent with NUREG-1432.

LA.3 Cunent Technical Specifications 3.8.1.1 and 3.8.1.2 Actions for a FOST inoperable require verification that the Operable FOST is aligned to the appropriate DG. Improved Technical Specification 3.8.3 Actions will not specifically delineate this requirement. This requirement is a condition of Operability and is dis:.ssed as such for No. I1 FOST in the Bases. This is acceptable because Technical Specifications should only contain specific requirements for system Operability (requiring the FOST is sufficient), and the Bases should clarify what constitutes the required Operability. This type of specific information is being moved to the Base as part of the conversion to NUREG-1432. Any changes to these requirements will be in accordance with the Bases Control Program in Section 5.0 of the ITS. This will ensure that any changes to these requirements will be appropriately reviewed. This change is consistent with NUREG-1432.

CALVERT CLIFFS - UNITS I & 2 3.8.3-4 Revision 10 w

DISCUSSION OF CHANGES SECI'lON 3.8.3 - DIESEL FUEL OIL TECIINICAL CHANGES I 5'RS M5'ETRICTIVE L.1 Current Technical Specification 3.8.1.1 Unit i Actions f, y, and h, and CTS 3.8.1.1 Unit 2 Actions f and g, provide AOTs when one or more FOSTs are inoperable. The AOT is generally consistent with and based on the consideration that if the FOST is inoperable, the DG is inoperable. Ilowever, it is overly conservative to consider the DG inoperable when the FOST volume is only slightly low or when fuel oil properties such as particulates or viscosity are slightly out oflimits since these conditions do not result in immediate inability of the DG to perform its safety function. These parameters, while supporting diesel generator Operability, contain substantial margin in addition to the limits which would be absolutely necessary for DG Operability. 'Iherefore, certain levels of degradation in these parameters are justified to extend the allowances for restoration. Improved Technical Specification 3.8.3 Conditic-E provides a 30 day Completion Time for new fuel oil discovered to have fuel oil pperties which do not conform to the limits after the new fuel oil has been added to the FOST. This Completion Time is appropriate since the fuJ replenishments are made in relatively small amounts compared to the size of the tank and the probabilities are high that the DG remains capable of performing its function. The addition ofITS 3.8.3 Condition D and the changes reflected in ITS 3.8.3 Condition F are addressed in Discussions of Change M.3 and M.4. The Actions for fuel oil volume are addressed for each FOST below.

Current Technical Specification 3.8.l.1 Unit 1 Action f provides a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT when No.

I A FOST is inoperable. This 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is consistent with and based on an inoperable DG AOT Current Technical Specifications 3.8.1.1 Unit 2 and 3.8.1.2 Unit 2 do not directly address No. I A FOST. Ilowever, since No. l A DG supports required Unit 2 equipment, e.g., CREVS, the inoperable support system, i.e., No. l A FOST, results in an inoperable DG and correspondingly, the supported inoperable CREVS components. As indicated above, it is overly conservative to consider the DG inoperable when the FOST volume is only slightly low since this condition does not result in immediate inability of the DG to perform its safety function. Therefore, ITS 3.8.3 Condition A provides a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time for reduced No. lA FOST fuel oil volume which is still sufficient to provide for six days of DG operation. This change is consistent with NUREG-1430.

Current Technical Specifications 3.8.1.1 and 3.8.1.2 requirea three FOSTs to be Operable for Unit 1, i.e., Nos. l A,11, and 21, and two FOSTs to be Operable for Unit 2, i.e., Nos. I1 and

21. Improved Technical Specification 3.8.3 will require only No. l A FOST and No. 21 FOST to be Operable to meet the LCO. Number I A FOST is addressed above as supporting only No. l A DG and providing sufficient volume to operate No. lA DG for seven days.

Number 21 FOST is addressed below as supporting Nos.1B,2A, and 2B DGs. Number 11 FOST is not required by ITS 3.8.3 except as a backup to support a degraded No. 21 FOST.

Only two of these three DGs are required to operate in response to a LOCI on one unit coincident with a required shutdown of the other unit, or for a required shutdown of both units, and with 85,000 gallons, No. 21 FOST contains sufficient fuel oil volume to support this required operation of two DGs.

Therefore, FOST is not required to support the emergency power safety function for either Unit i or Unit 2.

Current Technical Specification 3.8.1.1 Unit 1 Action h acknowledges that No.1I FOST is not required by allowing unlimited continued operation with No. 21 FOST Operable and No.11 FOST inoperable.

This is reflected in ITS 3.8.3 Condition B.

(Current Technical Specification 3.8.1.1 Unit 1 Action h would also allow unlimited continued operation with CALVERT CLIFFS - UNITS 1 & 2 3.8.3-5 Revision 10

DISCUSSION OF CHANGES

- SECTION 3.8.3 - DIESEL FUEL OIL No.11 FOST Operable and No. 21 FOST inoperable. This is acceptable for Unit I since No,IA FOST remains available to support a required shutdown should a tornado make No.11 FOST unavailable. This would not be acceptable for Unit 2 since No l A FOST does not fully support a required shutdown of Unit 2 if only No. l A FOST and No.1 I FOST were available and No.11 FOST was subsequently made unavailable due to a tornado.) Current Technical Specification 3.8.1.1 Unit 2 Action g does not similarly provide for unlimited continued operation with No,11 FOST inoperable, but does recognize its lesser importance by providing a seven day AOT. Since No.11 FOST is not required to support the emergency power safety function for either Unit 1 or Unit 2,ITS 3.8.3 does not require No,11 F0ST except to support a degraded No. 21 FOST as discussed below. With no LCO requirement for an Operable No,11 FOST, the CTS 3.8.1.1 Unit 1 Action h, CTS 3.8.1.2 Unit 1 Action b, CTS 3.8.1.1 Unit 2 Action g, and CTS 3.8.1.2 Unit 2 Action b requirements for an inoperable No. II FOST are also omitted, as is the SR to verify the required fuel oil volume of No. I1 FOST.

Current Technical Specification 3.8.1.1 Unit 1 Action g provides a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT when No. I1 FOST and No. 21 FOST are both imperable. This 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is similarly consistent with and based on an inoperab:e DG AOT. Namber 11 FOST and No. 21 FOST both support Unit I required Nos. IB and 2B DGs Number 2B DG is required for Unit I since it supports some Unit I required equipment such as CREVS which is redundant to equipment supported by No IA DG. Number 21 FOST is also addmssed in the Unit 2 CTS and changes to CTS 3.8.1.1 Unit 2 Action f are addressed below. However, as indicated above, it is overly conservative to consider the DG inoperable when the FOST volume is only slightly low since this condition does not result in immediate inability of the DG to perform its safety function. Therefore,ITS 3.8.3 Condition B provides a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time for reduced No. 21 FOST fuel oil volume as long as the combined volume of No. 21 FOST and an Operable No. I1 FOST remains sufficient to provide for 6 days cf DG operation (as required -

by ITS 3.8.3 Required Action B.1). He 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time of ITS 3.8.3 Required Action B.2 is actually more restrictive than the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed with no action by CTS 3.8.1.1 Unit i Action g. In addition, if No. 21 FOST is not restored and No.11 FOST continues to be relied upon, Required Action B.2 must be repeated every 31 days. This effectively replaces the SR 3.8.3.1 periodic surveillance of available DG fuel oil for the inoperable No. 21 FOST. The I hour Completion Time ofITS 3.8.3 Required Action B.1 is consistent with the AOT for verification of the backup fuel oil supply allowed by CTS 3.8.1.1 Unit 1 Action g. Current Technical Specification 3.8.1.1 does not generally allow for consideration of the combined volumes of No.1I FOST and No. 21 FOST as l

provided for in ITS 3.8.3. However, this is acceptable since both FOSTs provide fuel to the same set of required emergency DGs. Further, No.11 FOST will be required to be l

considered Operable prior to allowing its contents to be considered. The Bases will indicate i

that No. I1 FOST may not be considered Operable unless the fuel oil volume meets l

SR 3.8.3.2 and SR 3.8.3.3, and is capable of being delivered to the required DG, i.e., the necessary piping and valves are capable of performing their safety function. The Bases will l

also reflect that any fuel oil which is credited for DG use in No. I1 FOST above the 33,000 gallons reserved for emergency DG use, must be administrative!y controlled to assure its retention for this purpose.

Current Technbal Specification 3.8.1.1 Unit 2 Action f.1 provides a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT when No.21 FOST is inoperaHe provided No.1I FOST can provide the required seven day fuel oil volume. This 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is similarly consistent with and based on an inoperable DG AOT.

CALVERT CLIFFS - UNITS I & 2 3.83-6 Revision 10

DISCUSSION OF CHANGES SECTION 3.83 - DIESEL FUEL OIL Number 11 FOST and No. 21 FOST both support Unit 2 required Nos. 2A and 2B DGs.

Number I A DG is also required for Unit 2 since it suppcrts some Unit 2 rcquired equipment such as CREVS which is redundant to equipment supported by No. 2B DG; however, it is provided fuel oil by No. l A FOST. Number 21 FOST is also addressed in the Unit 1 CTS and changes to CTS 3.8.1.1 Unit 1 Action g are addressed above. However, as indicated above, it is overly conservative to consider the DG inoperable when the FOST volume is only slightly low since this condition does not result in immediate inability of the DG to perform its safety function.

Herefore, ITS 3.83 Condition C provides a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time for reduced No. 21 FOST fuel oil volume as long as the combined volume of No. 21 FOST and an Operable No. I1 FOST remains sufficient to provide for six days of DO operation (as required by ITS 3.83 Required Action C.1). The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time ofITS 3.83 Required Action C3 is actually more restrictive than the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed with no action by CTS 3.8.1.1 Unit 2 Action f.l. He I hour Completion Time ofITS 3.83 Required Action C.1 is consistent with the AOT for verification of the backup fuel oil supply allowed by CTS 3.8.1.1 Unit 1 Action f.l. Current Technical Specification 3.8.1.1 does not generally allow for consideration of the combined volumes of No. I1 FOST and No. 21 FOST as provided for in ITS 3.83. However, this is acceptable as discussed above for ITS 3.83 Condition B. Improved Technical Specification 3.83 Condition C also contains Required Action C.2 to require verification that the " tornado protected" No. 21 FOST contains at least a six day supply of fuel oil within two hours during tornado season since no other tornado protected FOST is available to support the shutdown requirements of Unit 2.

The two hour Completion Time is consistent with CTS 3.8.1.1 Unit 2 Action f.2 while the requirements for a six day supply is consistent with the NUREG 3.83 Condition A allowances for continued operation for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Current Technical Specification 3.8.1.2 (Unit I and Unit 2) Action c provides a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AOT when No. 21 FOST is eequired and inoperable during MODE 5 or 6. This 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is similarly consistent with and based on an inoperable FOST during operation in MODE 1,2, 3, or 4. However, as indicated above, it is overly conservative to consider the DG inoperable when the FOST volume is only slightly low since this condition does not result in immediate inability of the DG to perform its safety function. Therefore,ITS 3.83 provides for reduced fuel oil volume of No. 21 FOST during MODES 5 and 6 just as for operation in MODES 1, 2,3, and 4. The justifications are the same as for operation in MODES 1,2,3, and 4 above, except that the Unit 2 additional restriction for tornado season is not required during MODE 5 or 6. This is reuccted in an ITS 3.83 Required Action C.2 Note.

L.2 Current Technical Specification LCO 3.8.1.1 Unit 1 Actions f and g require the redundant l FOST volume and flow path to be verified within one hour and once per eight hours thereafter, when one FOST is inoperable. Improved Technical Specification 3.83 will not contain this requirement since the ITS 3.83 will provide Conditions allowing continued operation only when the degraded condition of the fuel oil (volume or chemistry) does not immediately impact the Operability of the DG. Therefore, it is not necessary to check the volume (since sufficient fuel remains available to initiate and maintain the safety function of the DG) and the flow path need not be changed (and therefore, a new flow path need not be verified). If the Operability is affected, ITS 3.83 will require the DG to be declared inoperable and ITS 3.8.1 will provide the appropriate actions. Cross train checking of equipment is approximately addressed in ITS 3.8.1 for inoperable power sources. Therefore, increased Frequency testing of the Operable FOST is unnecessary when one is inoperable.

Also, the normal SR Frequency (performed every 31 days) is adequate to ensure that a l CALVERT CLIFFS - UNITS 1 & 2 3.83-7 Revision 10

DISCUSSION OF CHANGES SECTION 3.8.3 - DIESEL FUEL OIL sufficient supply of fuel oil is available, since low level alarms are provided to alert the operator of low level in-between performances of the SR. Finally, the operators would be l aware of any large use of fuel oil during this period. The deletion of an unnecessary Action constitutes a less restrictive change. His change is consistent with NUREG 1432.

L.3 Current Technical Specification 3.8.1.2.c requires the No. 21 FOST to be restored to Operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when inoperable. If the FOST cannot be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , CTS require Core Alterailons, irradiated fuel movement, and positive reactivity additions to be suspended improved Technical Specification 3.8.3 will require the FOST to be restored to Operable status within 7 days for particulate concentration and 30 days for new fuel oil properties not within limits. If tha required FOST cannot be restored within the AOT, the associated DG must be declared inoperable, which requires the immediate suspension of Core Alterations, movement of irradiated fuel, and positive reactivity additions, nis change increases the AOTs when the No. 21 FOST is inoperable from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 7 days for particulate concentration, and 30 days for new fuel oil properties not within limits. He 7 day AOT, when particulate concentration is high, is acceptable because a high level of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, particulate concentration is unlikely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recently demonstrated (within the previous 31 days). He 30-day AOT, when new fuel oil properties are not within limit, is acceptable because the DG will still perform its intended function. Relaxation of the AOTs constitutes a less restrictive change. His change is consistent with NUREG-1432.

L.4 Current Teche' al Specification 3.8.1.2.d requires Core Alterations, irradiated fuel movement, an6 positive reactivity additions to be immediately suspended when the No. l A FOST is inoperable. Improved Technical Specification.18.3 will require the FOST to be restored to Operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for level,7 cays for particulate concentration, and 30 days for new fuel oil properties not within limits. If the required FOST cannot be restored within the AOTs, the associated DG must be declared inoperable, which requires the immediate suspension of Core Alterations, movement of irradiated fuel, and positive reactivity additions. This change essentially increases the AOT when the No, l A FOST is inoperable from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for level, 7 days for particulate concentration, and 30 days for new fuel oil properties not within limits. The 48-hour AOT for FOST level not within limits allows time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. He time is also acceptable based on the remaining capacity, the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. The seven-day AOT, when particulate concentration is high, is acceptable because a high level of particulates does nct meen failure of the fuel oil to burn properly in the diesel engine, particulate concentration is en.likely to change significantly between Surveillance Frequency intervals, and proper engine performance has been recemly demonstrated (within the previous 31 days). The 30-day AOT, when new fuel oil properties are not within limit, is acceptable because the DG will still perform its intended function. Relaxation of the AOTs constitutes a less restrictive change. This change is cor.sistent with NUREG-1432.

L.5 Current Technical Specification SR 4.8.l.l.2.a.2 requires the verification that each FOST level is within limits eve y 31 days on a Staggered Test Basis. Improved Technical Specification SR 3.8.3.1 will not require FOST testing on a Staggered Test Basis. The intent of a requirement for staggered testing is to increase reliability of the component / system CALVERT LLIFFS - UNITS I & 2 3.8.3-8 Revision 10

.. - _.. =

DISCUSSION OF CHANGES SECTION 3.8.3 - DIESEL FUEL OIL being tested. A number of studies have been performed which have demonstrated that 1 staggered testing has negligible impact on component reliabilit). As a result, it has been determined that staggered te. sting: 1) is operationally difficult,2) has negligible irnpact o'i component reliability,3) is not as signiiicant as initially thought, d) has no impact on failure frequency,5) introduces addhicanal stress on con.;onents such as DGs potentially causing increased component failure rates and component wearout, and 6)lacreases likelihood of,

human error by increasing testing intervals,

'lherefore, the FOST staggered testing requirements have been deleted. Tnic change is consistent with NUR]!G 1437, CALVERT CLIFFS - UNITS 1 & 2 3.8.3-9 Revision 10

Diesel fuel 011CletFeDW, dstartf5 h

J 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel fuel 011ClutfDC dStytfng Adj h

LCO 3.8.3 1he stored diesel fuel ci1C.hlbe t univsgshall be within T1alli,gd. Mstartino e Q

for each required diesel genera ;or (DG).

APPLICA8ILITY:

When associated DG is required to be OPERA 8LE.

gy AC110NS

.. NOTE- - ------------

Separate Contittion entry is allowed for each DC.

fONDITION

' REQUIRED ACTION OMPLETION TIME

' A.

One more DGs wt A.1 Restore f oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months jtd$6R'I f

level level within 3.2.3

>l28,285,; gal

33,000 nd lim

. in I

/ storage J

I B.

On r more DGs th P/ Restore oil 48 h s

I be ell iny ory

/

inven y to within Q

500 nd 11 s.

>;425;ga j

j One or more DGs with 1

Restore fuel oil 7 days

(, jJeg \\

stoted fuel oil total total particulates to r

particulates not within limits, within limits.

I (continued)

CEOG STS 3.8-22 Rev 1, 04/07/95

=.

. INSERT 3.8.3 e

t 3.9.l.1 A.

-Fuel oil storage tank A.1 Restore fuel oil 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months s-h-

~ A* 4

'(FOST).1A with fuel volume to within'

]$il oil volume l limits.

a wo-O

< 49.500 gal and-

,=

2 [42,430] gal.

- 9.#

t (Goa t y) 8.

NOTE------.--

B.1 Verify combined -

I hour

'j-Only applicable to available-fuel oil Unit 1.

volume of FOST 21

-- g,.;,, 2 and OPERABLE F0ST-11 FOST 21 with fuel oil-volume < 85,000 gal.

AND B.2 Verify combined 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months available fuel oil i

volume of FOST 21 AND and.0PERABLE FOST 11 2 85,000 gallons.

Once per 31 days-thereafter-J 6

J

+

y e

- INSERT 3.8.3 I

F

-C.

NOTE----

C.1 Verify combined 1-hour Only_' applicable to available fuel = oil Unit-2.

volume of FOST-21' and OPERABLE FOST-11 2 [72.860] gallons; FOST-21 with fuel' oil

+

~

volume < 85,000 gal.

MQ 4

C.2

NOTES--------

1. Only applicable during MODE 1, 2.

3. or 4.

2. Only applicable between April 1 and September 30.

Restore F0ST 21 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months fuel oil volume to within limits.

MQ C.S Restore FOST 21 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel oil volume to within limits.

k Y

__ _....i.,

Diesel Fuel 011Datis QW, 4#3tytingM h g

J.s.3

. ~

g ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME fh One or more DGs with 1

Restore stored fuel 30 days g'g.g*""t d new fuel oil oil pro erties to rties not within within imits.

Me.skiL r

<d(ut eh I.

E e or more with Restore s ting air 48 urs starting a receiver receive ressure to E'f25)

/

I F.

Required Action and F.1 Declare associated DG Innediately h

associated Completion inoperable.

Time not met.

DE

' One or more DGs' 31.l. l diesel fuel oil h%, Og) h

, r rta l r gg ggQ is lnot with'n

'g limits for reasons p

bic other than nouas S T " " ^ '

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

.I.lI2.A.2-SR 3.8.3.1 VerifyFeae@ fuel of ge A conH Tns) 31 days p,00A rga y f

.) g

g. '

[

( 4 POST IA h 49,foO Sano*% A$d (continued) 1 lh FotT 21 t ?f,000 S ANo*S.

CEOG STS 3.8-23 Rev 1, 04/07/95

Diesel Fuel 011fjeffe Ip( pn(Star,Hno M/) h J.5.3 j

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY h

S 2

V 1

ica 1 invento 3

SR 3.8.3.

41.1.1.2.

Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of.

Fuel 011

[

y, the Diesel Fuel 011 Testing Program.

Testing Program S

.4 h

a receiver re 3

4. 2. l.l. Z. b SR 3.8.3.

Check for and remove accumulated water from days each fuel oil Itorage tank.

10 bSR 3.8

.6 for each fu oil storage tan 10 y rs

sff-2 e.

D n the fuel oil; kBA 1 b

Remove the sedi

and

(

c.

Clecn the t j

l CEOG STS 3.8-24 Rev 1, 04/07/95 l

l l

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-I432 SECTION 3.8 - ELECTRICAL POWER SYSTEMS coolant accident (LOCA) loading is less than the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating of the DGs. Not including these SRs in the Calvert Clifts ITS is consistent with Calvert Cliffs current licensing basis.

IL NUREG 1432 SR 3.8.1.16 verifies that each DG synchronizes with an offsite power source while loaded with emergency loads upon a simulateo restoration of offsite power; transfers loads to the offsite power source; and returns to ready-to load operation. Calvert Cliffs ITS SR 3.8.1.14 verifies that each DG synchronizes with an offsite power source while loaded with emergency loads upon a simulated restoration of offsite power, and the load (s) can be transferred to tlie offsite power source. He Calvert Cliffs ITS will not contain tbc requirement for the DG to return to ready to-load operation, and also will be clarified that the loads can be transferred to the offsite power source. Calvert Cliffs system does not return to ready-to-load, and the loads have to be manually transferred to the offsite power source. This test is not currently a Technical Specification SR at Calvert Cliffs, but was added because it is currently performed outside of the Technical Specifications. This change is consistent with Calvert Cliffs current licensing basis.

12.

NUREG 1432 Specification 3.8.3 contains an LCO, Actions, and SRs for fuel oil storage, lubricating oil and starting air for the DGs. Calvert Cliffs ITS 3.8.3 will not contain requirements for lubricating oil and starting air. Calvert Cliffs' starting air system is a very diverse system for three of the four DGs, because any air start receiver can feed any DG through a common header. This system is unlike the standard in that one air start receiver does not feed one DG (except for the 1 A DG), therefore, it does not fit the standard and will not be incorporated into the Calvert Cliffs ITS. The lubrication oil requirements at Calvert Cliffs are sufficient to ensure that enough oil is present onsite to provide oil to the DG until more can be obtained. A lubricating oil consumption rate does not exist for '

-e of the Calvert Clifts DG (except for the 1 A DG), therefore, providing a specific number for lubricating oil is not feasiMe.

Herefore, consistent with curreat licensing basis, Calver Cliffs will not add Specifications for starting air and lubricating oil to the Calvert Cliffs ITS.

13.

NUREG-3.8.3 Condition A provides Required Actions and associated Completion Times for one or more fuel oil storage tanks (FOSTs) not within their volume limits but still with volume sufficient for approximately six days of required DG operation. The standard Condition is appropriate for FOSTs which are tornado protected and either singular (providing all DGs), or separate and redundant for each DG. The DG fuel oil system design at Calvert Cliffs does not conform to these standard presumptions. There are four DGs. Three of the DGs, i.e., Nos. IB, 2A, and 28, are fueled from two FOSTs, i.e., No. I1 FOST and No. 21 FOST, and No. l A DG is fueled from No. l A FOST. Further, No. l A FOST and No. 21 FOST are " tornado protected" while No.11 FOST is not. Due to this design, ITS 3.8.3 Condition A is revised to reflect CTS 3.8.1.1 Actions as much as possible within the ITS format.

Improved Technical Specification 3.8.3 Condition A addresses only No. l A FOST which is

" tornado protected" and which contains sufficient fuel for seven days of required operation of No. l A DG. It supports both Unit I and Unit 2 equipment, and most closely reflects the NUREG Condition A. Note that all DG FOST Conditions refer to volume rather than level since volume is the required parameter in the SR ar.d is the parameter used in the analysis for DG operation.

Also, Note that the reduced volmes for allowing 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of operation are based on a simple 6/7 of the required volume of each tank which will provide for approximately six days of operation Improved Technical Specification 3.8.3 Condition B addresses only No. 21 FOST which is

" tornado protected" and which contains sufficient fuel for seven days of required operation of CALVERT CLIFFS - UNITS 1 & 2 3.8 3 Revision 10

DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SI " TION 3.8 - ELECTRICAL POWER SYSTEMS two DGs. It supports both Unit I and Unit 2 equipment, but Condition C is written for Unit 1 only to reflect the Unit I requirements for Nos. IB and 2B DGs. For an accident, Unit I requires either No. l A DG or both Nos. IB and 2B DGs (since No. 2B DG powers equipmenf. which is redundant to soma equipment powered by No. l A DG, e.g., CREVS. Since No. tA DG is supported by No. l A FOST and the redundant required equipment is powered by Nos. IB and 2B DGs which are supported by No. 21 FOST, at least one full train of required equipment is supported by a " tornado protected" FOST even with an inoperable FOST or DG. Herefore, low fuel oil volume in No. 21 FOST can be supplemented by the fuel oil volume of an Opersble No,11 FOST to assure the necessary vo!ume. Current Technical Specification 3.8.1.1 Unit 1 Actions g and h address the inoperability of No. 21 FOST.

Current Technical Specification 3.8.1.1 Unit 1 Action g requirements for the combined inoperability of Nos.11 and 21 FOST are the same as the CTS 3.8.1.1 Unit 1 Action f requirements for No. l A FOST.

Therefore, it is appropriate to allow their combined volume to provide the 7 day required volume in ITS. His is reflected in ITS 3.8,3 Required Action B.2 which requires the combined volume of No. 21 FOST and an Operable No.11 FOST to be 2 85,000 gallons within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This is consistent with the NUREG 3.8.3 Required Action A.1 and its Completion Time to restore the full seven day required volume. In addition, if No. 21 FOST is not restored and No.11 FOST continues to be relied upon, Required Action B.2 must be repeated every 31 days. This effectively replaces the SR 3.8.3.1 periodic surveillance of available DG fuel oil for the inoperable No. 21 FOST. Improved Technical Specification 3.8.3 Required Action B.i requires the combined volume of No. ?! FOST and an Operable No. I1 FOST to be verified O be greater than the 65 of the required volume within one hour. This is consistent with the one hour provided by CTS 3.8.1.1 Unit 1 Action h to verify No.11 FOST volume and delivery capability when No. 21 FOST is inoperable. Since FOST is not required by the ITS 3.8.3 LCO, Bases are included to indicate that No.11 FOST is considerci Operable when the fuel oil volume meets SR 3.0 3.2 and SR 3.8.3.3, and is capable of being delivered to the required DG, i.e., the necessary piping and valves are capable of performing their safety function. The Bases will also reflect that any fuel oil which is credited for DG use in No,11 FOST above the 33,000 gallons reserved for emergency DG use, must be administratively controlled to assure its retention for this purpose, improved Technical Specification 3.8.3 Condition C addresses only No. 21 FOST which is

" tornado protected" and which contains sufficient fuel for seven days of required operation of two DGs. It supports both Unit I and Unit 2 equipment, but Condition C is written for Umt 2 only to reflect the Unit 2 requirements for Nos. 2A and 2B DGs. For an accident, Unit 2 requires either No. 2B DG or both Nos. l A and 2A DGs (since No. l A DG powers equipment which is redundant to some equipment powered by No. 2B DG, e.g., CREVS. Unlike Unit 1, at least one full train of required equipment is not supported by a " tornado protected" FOST with an inoperable FOST or DG since most of the redundant required equipment is powered by Nos. 2A and 2B DGs which are both supported by No. 21 FOST. Therefore, low fuel oil volume in No. 21 FOST can only be supplemented by the fuel oil volume of an Operable No I1 FOST to assure the necessary volume when the probability for a tornado is sufficiently low. This is reflected in CTS 3.8.1.1 Unit 2 Action f which addresses the inoperability of No. 21 FOST from October I to March 31. During this time of low tornado probability, CTS 3.8.1.1 Unit 2 Action f.! requirements for the inoperability of No. 21 FOST are the same as the CTS 3.8.1.1 Unit 1 Action g und h requirements for No.11 FOST and No. 21 FOST. Therefore, it is not appropriate to allow their combined volume to provide the seven day required volume. Itis acceptable, however, for their combined volume to be considered in providing 65 of the required volume in ITS for the 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowed in NUREG 3.8.3 Condition A. This is reilected in CALVERT CLIFFS - UNITS 1 & 2 -

3.8-4 Revision 10

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREC-1432 SECTION 3.8 - ELECTRICAL POWER SYSTEMS ITS 3.8.3 Required Action C.l which requires the combined volume of No. 21 FOST and an Operable No.11 FOST to be verified to be greater than 6/7 of the required volume within one hour, improved Technical Specification 3.8.3 Required Action C.3 would the require the volume of No. 21 FOST to be restored to within volume limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This is consistent with the NUREG 3.8.3 Required Action A.1 and its Completion Time to restore the full seven day required volume. Ilowever, during tornado season, i.e., from April I to September 30, the fuel oil volume of No.11 FOST is not allowed to be credited (per CTS 3.8.1.1 Unit 2 Action f.2) and the fuel oil seven day volona of No. 21 FOST must be restored within two hours. This is reflected in ITS 3.8.3 Required Action C.2 which is modified by a Note such that it is only required during the tornado season. An Operable No.11 FOST is determined as described above in the discussion for Condition B.

14.

. An Action was added to Specification 3.8.4.

The Action allows four hours to replace an inoperable battery with the reserve battery. These changes are consistent wnh the Calvert Cliffs current licensing basis, as approved in Amendment Nos. 58 (Unit 1) and 40 (Unit 2), and discussed in the NRC Safety Evaluation Report dated November 2,1981. In conjunction with this change, the phrase, "other than Condition A," was added to Condition 13 (NUREG-1432 Condition A) to account for other reasons the DC electrical power channel may be inoperable.

15.

The Mode restrictions presented as Notes in the SRs of Specification 3.8.4 are being deleted.

Calvert Cliffs has a reserve batten and two battery chargers per battery. This enables Calvert Cliffs to perform Surveillances while in Mc. des 1-4. His change is consistent with current Calvert Cliffs practice and licensing basis.

16.

All Reviewers Notes will be deleted. These Notes are for the NRC reviewers and are not intended to be included in the specific plants' ITS.

17.

Not used.

18.

Not used.

19.

Not used.

20.

Not used.

21.

Not used.

l 22.

Not used.

l 23.

Not used.

24.

NUREG-1432 SR 3.8.4.2, "DC Sources Operating," is a requirement to verify each battery charger supplies 2 400 amps at 2125 Volt for a bracketed time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The time is not contained in the CTS. Ilowever consistent with current practice and vendor recommendation, each battery charger is required to supply current for 30 minutes during this test. This change incorporates current Calvert Cliffs requirements into bracketed information.

25.

[NUREG-1432 SRs 3.8.1.11 and 3.8.1.12 are not included in ITS 3.8.1. These tests separately verify the 4.16 kV Engineered Safety Feature (ESP) bus sequential loading logic associated with CALVERT CLIFFS - UNITS I & 2 3.8-5 Revision 10

DISCUSS!ON OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 3

SECTION 3.8. ELECTRICAL POWER SYSTEMS an ESF initiation and a loss of offsite power. Calvert Cliff's ofTsite ci tuits are designed to accept all LOCA loading from one unit simultaneously and support safe shutdown of the non.

LOCA unit. As such, the sequential loading logic will only initiate upon closure of the respective DG output breaker. Therefore, NUREG 1432 SR 3.8.l.12 is not applicable to Calvert Cliffs. Upon a loss-of offsite power (LOOP) in conjunction with a LOCA signal, the load sequencer allows load blocks to be loaded onto the DG The load blocks are necessary LOCA loads. Improved Technical Specification SR 3.8.1.8 (CTS 4.8.1,12.a.7) is performed every 31 days. His test consists of ensuring the correct load interval equipment response for a LOOP /LOCA. NUREG 1432 SR 3.8.1.11 is not necessary to verify the loading sequence of an ESF actuation. Not including these Surveillances in ITS 3.8.1 is consistent with Calvert Cliffs current licensing basis. The Surveillances are renumbered, where applicable, to reflect this deletion.)

26.

NUREG 1432 SR 3.8.l.4 and NUREG 1432 SR 3.8.1.14 require a DG loading range. Improved Technical Specification SR 3.8.1.4 and SR 3.8.l.11 do not include an upper load limit. The continuous service rating for the No. l A DG is $400 kW, the continuous service rating for the No. til DG is 2500 kW, and the continuous service rating for both the Nos. 2A and 211 DGs is 3000 kW. The predicted accident loading arsociated with each DG is as follows:

No. I A DG

< 4000 kW No.1B DG

< 2700 kW No. 2A DG

< 3000 kW No. 2B DG

< 3000 kW As stated in the Safety Evaluation for Technical Specification Amendment Nos. 214 (Unit 1) and 191 (Unit 2), DG load testing greater than the expected accident load is acceptable to determine DG capability to perform its acquired safety function. Also, since No. l A DG accident loading requirements are below the continuous rtting, Calvert Cliffs will trend any degradation in the DG's perfonnance between the continuous rating and the capacity needed to perform the safety function. In addition, exceeding the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months anci 200 hour0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months DG design limits (which provide the basis for the values specified 5 NUi'.EG 1432 SR 3.8.1.4 and SR 3.8.1.14) may introduce long-term DG degradation but does not impact the immediate OPERABILITY of the DGs.

Preventative maintenance and DG visual inspNtions ensure DGs Operability is not impacted when operated above the continuous ratings. Therefore, the ufper DG loading limit is not required to be included in ITS and the Note to ITS SR 3.8.1.11 has been revised to reflect the change. This deviation is consistent with Calvert Cliffs wrrent licensing basis.

27.

NUREG 1432 SR 3.8.1.20 is noi required by Calvert Cliffs to verify a DG's capability to respond to any analyzed transient or accident. This Surveillance verifies the independence of the DGs.

As stated in Updated Final Lfety Analysis Report (UFSAR) Section 8.4, the DGs and associated emergency distribution are sepute and independent. Any modification or procedure change that alters the facility are governed by 10 CFR 50.59. The 10 CFR 50.59 control process and current plant procedures are adeqaate to prevent any activity from compromising DG independence, in addition, not including this SR in the Calvert Cliffs ITS is consistent with Calvert Cliffs current licensing basis.

28.

NUREG-1432 SR 3.8.1.14 contains Note 2 which precludes the Surveillance from being performed in Mode 1 or 2. Current Technical Specification 4.8.1.1.2.d.4 does not have this restriction. In addition, Generic Letter 91-04 states that licensees may omit the Technical CALVERT CLIFFS - UNITS 1 & 2 3.8-6 Revisioi3

l DISCUSSION OF TECilNICAL SPECIFICATION DEVIATIONS FROM NUREGol432 SECTION 3.8 - ELECTRICAL POWER SYSTEMS Specification qualification that a refuel;ng interval surveillance is to be performed during shutdown. 'Iherefore, this Note is not included in ITS SR 3.8.1.11 consistent with Calvert Cliffs current licensing bash and the guidance provided in Generic Letter 9104.

29.

NUREO 1432 SR 3.8.l.14 requires the DO to be operated for 2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Current Technical Specification 4.8.1.1.2.d.4 only requires the DO to be operated for 2 60 minutes. Testing the DO for 2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is consistent with the requirements of Regulatory Guide 1.108. Ilowever, Calvert Cliffs Nuclear Power Plant Units 1 and 2 are not committed to the requirements of Regulatory Guide 1.108. Additionally, operating the DO for at least one hour ensures that the DO temperatures are stabilized and minimizes the time the DO is connected in parallel with the offsite AC power sources. It is reasonable that any degradation of DG performance that will prevent the DO from performing its safety function can be detected within the one hour period.

Therefore, it is not necessary to run the DO for an extended period of time. Also, operating the dos for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months may increase the stress and wear on the dos. As such, ITS SR 3.8.1.11 only requires the dos to be operated for 2 60 minutes consistent with Calvert Cliffs current licensing basis.

30.

NUREG 1432 SR 3.8.1.8 contains a Note which precludes the Surveillance from being performed in Mode 1 or 2. [ Currently, this test is performed by momentarily paralleling the 500 kV offsite AC power source and performing a dead bus transfer of the 69 kV offsite AC power Paralleling the offsite power sources or placing them on a dead bus is a controlled source.

evolution and the increased risk associated with the performance of this test while the unit is at power is not significant for the following reasons: (1) the frequency and voltages are verified within range prior to paralleling two offsite AC power sources; (2) the dead bus transfer of the 69 kV offsite power source is a controlled evolution that only de-energizes a 13 kV bus whose 4.16 kV buses have been aligned to the other 13 kV bus, and would only be performed if the 69 kV offsite power source was needed to be Operable because two of the three 500 kV offsite power sources were not Operable; (3) the test does not result in de-energization of any 4.16 kV ESF bas and the potential of electrical perturbations on the grid system is the same whether performing the transfer while the unit is at power or while shutdown; (4) operating history indicates that transferring offsite AC power sources while the units were in Mode i or 2 has been performed satisfactorily during unplanned evolutions; and (5) operating history (e.g.,31 day DO load run) indicates that paralleling two dissimilar AC power sources while in Mode 1 can be performed satisfactorily. Also,] Generic Letter 9104 states that licensees may omit the Technical Specification qualification that a refueling intenal surveillance is to be performed during shutdown. Therefore, the specific requirement te perform this suncillance during shutdown is deleted not included in ITS SR 3.8.1.10 consistent with the guidance provided in Generic Letter 91-04, 31.

NUREG 1432 SR 3.8.1.18 contains a Note which precludes the Surveillance from being performed ir. Mode 1,2,3 or 4. Current Technical Specification 4.8.1.1.2.a.7 does not have this restrictior.. [At Calvert Cliffs, the automatic load sequencer is an electronic device with a test mode feature that allows the sequencer to be tested on-line without interfering with normal or abnormal operations. Upon a LOOP in conjunction with a LOCA signal, the load sequencer allows load blocks to be loaded onto the DO. The load blocks are necessary LOCA loads.

Improved Technical Specification SR 3.8.1.8 (CTS 4.8.1.1.2.a.7) is performed everv 31 days.

This test consists of initiation of a simulated LOOP /LOCA test signal into the load sequencer and ensuring the correct load sequence relays for a LOOP /LOCA are energized. Generic Letter 91-04 states that licensees may omit the Technical Specification qualifbuon that a CALVERT CLIFFS - UNITS 1 & 2 3.8-7 Revision 10

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.8. ELECTRICAL POWER SYSTEMS refueling interval surveillance is to be performed during shutdown. Herefore, this Note is not i

included in ITS SR 3.8.1.8 consistent with Calvert Cliffs curront licensing basis and the guidance provided in Generic Letter 9104, 32.

- NUREG 1432 SR 3.8.1.9 contains Note I which precludes the Surveillance from being performed in Mode I and 2. Current Technical Specification 4.8.1.1.2.d.2 does not have this restriction. In addition, Generic Letter 9104 states that licensees may omit the TS qualification that a refueling inten al surveillance is to be performed during shutdown. Therefore, this Note is not included in ITS SR 3.8.1.12 consistent with Calvert Cliffs current licensing basis and the guidance provided in Generic Letter 91 04.

33.

NUREG-1432 SR 3.8.1/l requires the DG to meet an upper and a lower voltage and frequency value within 10 seconds, improved Technical Specification 3.8.1.9 only requires the lower voltage and frequency limita to be met within 10 seconds. On a DG start without automatic loading, only the lower '. oltage and frequency limits are required to be met within the associated time limit because the upper limits are unnecessarily conservative for an unloaded DG, Under an actual LOOP condition, the DG would be immediately loaded once the minimum speed and voltage requirements, as applicable, are met, thereby limiting the overshoot. The proper steady state frequency and voltage limits are provided to ensure the unloaded DG does maintain these limits.

Additionally, the word " achieves" in NUREG 1432 SR 3.8.1.19 is changed to

" maintains" in the ITS SR 3.8.1.15 to be consistent with ITS SR 3.8.1.9.

34.

NUREG 1432 SR 3.6.1.19 (ESF/ LOOP test) contains Note 2 which precludes the Surveillance from being performed in Mode 1,2,3, or 4. Current Technical Specification 4.8.1.1.2.d.3 does not have this restriction. In addition, Generic Letter 91-04 states that licensees may omit the Technical Specification qualification that a refueling laterval surveillance is to be performed during shutdown. Therefore, this Note is not included in ITS SR 3.8.1.15 consistent with Calvert Clifts current licensing basis and the guidance provided in Gen:ric Letter 91 04 35.

Not used.

36.

NUREG 1432 SR 3.8.1.4 Note 2 (ITS SR 3.8.1.3 Note 2) provides an allowance that momentary transients outside the load range do not invalidate this test. The bracketed load range provided in NUREG 1432 SR 3.8.1.4 has been modified in ITS SR 3.8.1.3 to only require a minimum load value, consistent with Current Licensing Basis. Si ce ITS SR 3.8.1.3 now has only a single n

value. The Note has been modified to reflect a single value load limit.

37.

NUREG-1432 LCO 3.8.9 ACTIONS A and B are revised to be consistent with CTS 3.8.2.1 to address the inoperability of one or more AC or AC vital buses. While ACTION E is no:

currently part of the CTS, it will be retained to ensure proper actions are taken if a loss of function occurs, in addition, for clarity, the word " subsystem (s)" is added to Condition B to be consistent with the associated Required Action and Condition E is modified to be consistent with the terntinology used in the LCO.

38.

We bracketed values of resistance specified in NUREG 1432 SR 3.8.4.2 and SR 3.8.4.5 are vendor recommended values; that is, values at which some action should be taken, not necessarily when the Operability oithe battery is in question. In addition, the safety analyses do not assume a specific battery resistance value, but typically assume the batteries will supply ndequate pawer.

~

F CALVERT CLilFS - UNITS 1 & 2 3.8-8 Revision 10

DISCU8SION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.8. ELECTRICAL POWER SYSTEMS Connection resistance is determined by the contact resistance between the connector and battery post, as well as the material, shape, and length of the connector bar/ cable. Contact resistance is affected by the irregularity of contact surfaces, the level of corrosion between contact surfaces, and the tightness of the connection. The type of connection is determined by the location of the connection (inter-cell, inter tier, and inter rack) and is characterized by connectors varying in shape and length. The allowable resistance range for each type of connection is different for a particular battery. Since batteries of different sizes may require connectors of different sizes and lengths, connection resistance is often different from one battery to another.

A single Operability resistance value for each battery connection type is not practical. The key issue is the overall battery resistance. The resistance of each connection varies independently from all the others. Some of these connection resistances may be higher or lower than others, and the oattery.nay still be able to perform its function and should not be considered inoperable.

Calvert Cliffs ITS SR 3.8.4.2 requires verification that no visible corrosion at battery terminals and connectors exist or verification that the connection i sistances are within limits and Calvert Cliffs ITS SR 3.8.4.5 requires verification that the battery connection resistance is within limits.

These battery connection resistance limits are specified in the ITS Bases for these Surveillances.

This allows appropriate battery resistance values to be specified and the levels at which action will be taken: 1) if the manufacturer recommended values are exceeded, and 2)when the Operability of a battery is questioned. In addition, this change is consistent with the Calvert Cliffs current licensing basis since the CTS do not contain battery resistance values.

39.

The bracketed 12 month Surveillance Frequencies specified in NUREG 1432 SR 3.8.4.3 and SR 3.8,4.4 are revised to reflect the Calvert Cliffs current licensing basis reflected in CTS 4.8.2.3.2.c.1 and 4.8.2.3.2.c.2 (i.e.,18 month Surveillance Frequencies). Plant operating experience has shown that the 18 month Surveillance Frequencies for these Surveillances are adequate for maintaining battery Operability, in addition, the bracketed 12 month Surveillance Frequency specified in NUREG-1432 SR 3.8.4.5 (which is not included in the CTS and is added as a result of the conversion to ITS) is revised to 18 months for consistency with the changes made to SR 3.8.4.3 and SR 3.8.4.4.

l 40.

Average electrolyte temperature of the battery cells supports OPERABILITY of the DC electrical source channels as reflected in NUREG 1432 Specification 3.8.6 Condition B (second Condition) and SR 3.8.6.3. The LCO for NUREG 1432 Specification 3.8.6 states that battery i

cell parameters shall be within the limits of Table 3.8.61.

Ilowever, average electrolyte temperature is not included in this Table. Therefore, to be consistent with the ISTS format, the requirement to maintain battery cell average electrolyte temperature within the required limit is l

added to the LCO statement of Calvert Cliffs ITS 3.8.6 (NUREG-1432 Specification 3.8.6).

41.

The word " values" in the third Condition of NUREG 1432 Specification 3.8.6 Condition B is changed to " limits" to more closely match the LCO description, in addition, the word l

" Allowable" in NUREG 1432 Table 3.8.6-1 is deleted in Calvert Cliffs ITS Table 3.8.61 to be consistent with the manner in which Category C " Limits" are described in the ACTIONS. This also avoids confusion with the term " Allowable Value" used in the Instrumentation Section (Calvert Cliffs ITS Section 3.3).

l CALVERT CLIFFS - UNITS 1 & 2 3.8 9 Revision 10

DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG.1432 SECTION 3.8 - ELECTRICAL POWER SYSTEMS

+

42.

The one time frequency requirements of NUREG 1432 SR 3.8.6.2 associated with a severe battery discharge or overcharge are not included in the Calvert Cuifs ITS. This change is consistent with Calvert Cliffs current liansing basis reflected in CTS 4.8.2.3.2.b.

43.

NUREO 1432 Table 3.8.6-1 only includes one Category B limit for speci0c gravity (2 [1.195]).

Calvert Cliffs ITS Table 3.8.61 is revised to include an additional Category B limitation for battery cell specific gravity. Calvert Cliffs ITS Table 3.8.61 Category B limits for specific gravity are 21.195 "AND Average of all connected cells 21.205." His additional limitation is consistent with the battery manufacturer's recommendations.

44.

De words "and following" are added to Footnote (a) of NUREG 1432 Table 3.8.61 to allow the electrolyte level to be temporarily above the limit fallowing the equalize charge as well as during the charge. As reflected in the NUREC.1432 Bases for this footnote (in Table 3.8.6-1 description), IEEE-450 recommends that electrolyte level readings not be taken until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the equalize charge. This allows time for the electrolyte temperature to stabilize and the level reading to be a "true" reading. Without the added words, the limit may not be met upon completion of the charge and unnecessary ACTIONS would have to be taken.

47.

He NUREG SR 3.8.7.1 and SR 3.8.8.1 bracketed requirement to verify correct invener frequency has been deleted. While the Calvert Cliffs design does include a frequency meter for the inverters, the installed meter does not provide the necessary accuracy to properly verify the required frequency. For this reason, the meter is also not calibrated, ne verification of proper voltage and alignment to the vital buses provides adequate assurance of inverter Operability, nis is also consistent with the current Calvert Cliffs licensing basis, which does not include a frequency check in the Technical Specifications.

48.

The ACTIONS ofITS 3.8.2,3.8.5,3.8.7, and 3.8.10 have been modified by a note stating that LCO 3.0.3 is not applicable. His note is necessary since LCO 3.0.3 does not provide any actions if moving irradiated fuel, but irradiated fuel movement can occur in Modes 1,2,3, and 4, when LCO 3.0.3 is applicable. Herefore, to preclude confusion, the Note has been added to preclude entry into LCO 3.0.3; the Actions of the applicable Specification must be completed.

This change is also consistent with TSTF-36, Revision 2 and other similar changes previously approved by the NRC for other ITS conversions (e.g., WNP-2).

49.

He words "from standby conditions" of NUREG 1432 SR 3.8.1.2 are not included in the Calvert Cliffs ITS SR 3.8.l.3. The DGs are started from standby conditions every 184 days as part of ITS SR 3.8.1.9 (CTS 4.8.1.1.2.c). His is a sufficient interval to verify that the DGs will start from ambient conditions, in addition, the monthly surveillance may be a hot start, increasing the range of conditions under which the IXis are tested, nis change is consistent with Calvert Cliffs current licensing basis reflected in CTS 4.8.1.1.2.aA.

50.

A note requiring the DG load reject test be performed at a specific power factor if performed with the DJi synchronized with offsite power (part of NUREG 1432 SR 3.8.1.9) will not be included in the Calvert Cliffs ITS SR 3.8.1.13. Requiring a particular power factor for this test is not compatible with the Calvert Cliffs design and is not required in the Current Licensing Basis, his change is consistent with Calvert Cliffs Current Licensing Basit reflected in CTS 4.8.1.1.2.d.2.

CALVERT CLIFFS UNITS I & 2 3.8 10 Revision 10

Diesel Fuel 011( igWtt1. and stpeing_A_iJr h

s 3.af.T l

B 3.8 [LECTRICAL POWER SY$1[MS 8 3.8.3 Diesel Fuel 011GupW. and $tstfna Air)

BA$[$

BACKGA00ND Iaciudiesel-enerator (DGpsufficient to o storegetant}l s provided t(itit l

h;rfng a f

)11 capact rate that di z-Tb C.d ods,6 v for a pe od of 7 days, 11e the'DG is s plying mart ~

~e g

i r

post I s of coolant ( a ident load dama as discusse in M b i-

c. h the AR, Section

.4.2 ndiscalculata[9 nef u)the meni(Ref. 1).

he maximus I d 1

i j/ p ( C o e,M c.f.irka (w d d'

= that at '

it two 1 I

i e are avatishim f This onsite fuel'oti capacity "s Me dk f 4d sufficient to operate the DGs fur lon er than the time to p.,,,. 4.c., (0 Q.4, replenish the onsite supply from outs de sources.

o f us lf se,4 e Fuel all is transferred from storane tan to day tank by en 4 M transfer p g s assoc' 113 9'M-Q.Woi pumf@ypgp{,,gith each 6qyn n,3.__ p ce e. t.. A l.k am i

__%..-<.nm.,.,,,,,,.......

[=6 N M.

su.ld

, y t j[.);.j j e f E,} b o.

M. Mi s= u 6, 15 g go,. m

=-w-----------------a Tg 's f tgt ;,

For proper operation of the standby DGs it.is necessary to ensure the proper quality of the fuel oII.1Regulato y l'OAP, chajigB(4 l),

.m ver.<

Um

-u -_noed fu c11 yuice ces as supplem# sovem. ANSI N195-1976 (Re 3h The ente pra 1

ett-eranerties acy.

d_bv these SRs a water and G.

f % g,,

sediment content, the kinematic viscosity, spec c gravity A

Q f _f g p (or API gravity). and is: purity level 4 (QO The p6 luorication sy a is designeo to provide sur c 2

~

hfAIpehmUrs) lubrication to peral proper operation of its also ated DG under all loading nditions. The systes is reo ed to

( t'^5*t e s 4(c 4"*g 4 y circulate the lu oil to the diesel. engine wor ng surfaces and to remo e ess heat generated by frictio during h

^-"

operation.

h engine oil 4 ump contains an nventory

, capable of pportingasinimumof(7) day of operation.

(Theonsi storage in addition to the e ne oil sump is suffici to ensure 7 days of continuo operation.) This suppi s sufficient supply to allow 1 operator to i

rep 1 ish lube eli fram outside sour sl.

)

flach has an air start stem with adsquate capacity for7 m

fivt uccessive start a emptsonth/eGwithoutrechrging)

LV 3

th air stari,eceive.>. z

,,)

m 8kK6Rol10b) 4 (continued)

Ct0C STS B 3.8-41 Rev 1, 04/07/95

i I

INSERT BACKGROUND The DG fuel oil system design at Calvert Cliffs supports four emergency DGs, and other non safety DGs. Three of the four emergency DGs, i.e.. Nos. IB. 2A, i

and 28. are fueled from two fuel oil storage tanks (FOSTs), i e.. FOST 11 and FOST 21, and DG 1A is f:eled from FOST 1A. F0ST 1A and F0ST 21 are enclosed

+

such as to be considered

tornado protected" but FOST 11 is not protected. As such, FOST 11 is not used as the primary source for the emergency DGs, but rather is used as a backup to support FOST 21 if it or the fuel oil it i

contains becomes degraded, i

l The operability of FOST Nos. 21 and 11 ensure that at least 7 days of fuel oil b will be reserved below the internal tank standpipes for operation of one DG in each unit, assuming one unit under accident conditions with a DG load of 3500 kW, and the opposite unit under normal shutdown conditions with a DG load of 3000 kW. Additionally, the operability of FOST 21 ensures that in the event of a -loss of offsite power, concurrent with a loss of the non bunkered fuel oil storage tank (tornado / missile event), at least 7 days of fuel oil will be t

available for operation of one'DG on each unit, assuming both Dgs are loaded to 3000 kW.

The operability of the FOST 1A ensures that at least 7 days of l

fuel oil is avulable to support operation of DG 1A at 4000 kW.

l The operability of the fuel oil day tanks ensures that at least one hour of diesel generator operation is available without makeup to the day tanks, assuming DG 1A is loaded to 4000 kW and Dgs 18, 2A, and.28 are loaded to 3500 kW.

i o

f I

i I

l l

Diesel fuel 011(Luktfil, and sterMine Air) 8 3.8.3 Basts (continued) h 7

APPLICABLE The itial condit of s n sis A ci ont (

and the $AR, Chapter Il(Ref.

J. assume 4rigin(Ref.

Chapter l4

, and in SAFETY ANALY$ES tra tent analyses 1 the F$

eer efety h

o e -- _

A feature (ESF) sys ens are OP RM LE. The DGs are designed to (bS7 /A s.s tystrd h ndain l provide sufflctent capacity, capabilit'y,f necessary power to redundancy, and reliability to ensure the availability o g,, gam '( qq soo g&g I ek oddMe Mess \\ bd oik

cor.tainment design Ilmits are not exceeded.ystem and ISF systees so that fuel, Reactor Coolant S 8

These Ilmits i4 are discussed in more detail in the Bases for LC0 uLit Jes sN:6,a so t

8 section 3.2, Power Distribution Limits: Containment $ystees.

Section 3.4 Reactor l operde, bGIA ew wi sat Coolant system (RCS): and section 3.5, lesJs for %ys. F011'11 is l

Since diesel fuel IL1"W. anc tra,e stars I't nite d b Ce d oid A M W *'

[

suppor IFe operation of the s,andby AC power of(it',eD og,Am e( ovdbtdt.,J sourc s, hey sat fy Criterion 3 of the NRC Policy Statoment.

C __

diese fuel oil is FoMmWe640 %wisufficient supply h

days fl_" n r 7 - ~ ^.

LC0 It_'s also required to or le oprait, on

/ meet specific standards for quality. lAccitionali I acd Ad lad 6 **d "d. Cn N M e" $ I

,U N S1 ifaf;tre 7 d vs, kor). A lj. q ca h This requirement in conjunction with an ability to obtain l

replacement suppites within 7 days, supports the availability of DGs required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occu ence (A00) or a postulated DBA with loss y from the FMfuel requirements, as well as DG day tank l

of offsite power.

@ lI erans' LMFl.to the dayan gosy transfer capatti l

so l

are addressed in LC0 3,8.1, 'AC Sources-operating,' and l

LC0 3.8.2, 'AC Sources-$hutdown.'

ihestar ng air system is equired to have a si mum for five success e DG start attempts thout (capaci rech ing the air star receivers.

I APPLICABILITY The AC sources (LC0 3.8.1 and LC0 3.8.2) are required to ensure the availability of the required power to shut down the reactor and eatntain it in a safe shutdown condition after_an A00 or a postulated DBA. Since stored dissel fuel m mnm'=a succor 9tC0 3.8.1 ollEMe oli. ana uninaa and' LCD 3.8.2, stored diesel fuel otidutw m i una murune (continued)

CEOG $TS B 3.8-42 Rev1,04/07/gs

Diesel fuel 011(Luke QYand starfThe Atr7 h

8 3.8.3 BAS [$

{

r 7

'fAj$(f7 APPLICAtiLITY s requireguired to be within Ilmits when the associated DG re (continued) to be OPERABLE.

ACTIONS The ACTIONS Tablo is modified by a Note indicating that separate Condition entry is allowed for each DG. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem. Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem (s) are governed by separate Condition entry and application of associated Required Actions.

[ </ o,/ n /w bM d1}B2 f ( M ad g )

f'deden U /4;/,f ) *In this Condition, L 7 day fuel oil supply for a DG is not k 4/7 of Ac typirr/

1 MbuY'[.-E $l E N N dt M U o Ir [

I volume WMtk (4*Il "hese circumstances may be caused by events such as full load operation required after an inadvertent start while at hp l provMc sdDeird eqwdI minimum required level; or feed and bleed operations, which U OF'M W M may be necessitated by increasing particulate levels or any number of other oil quality degradations. This restriction l

en ou,,oif g allows sufficient time for obtaining the requisite (i d " d a p #'" 4 " j replacement volume and performing the analyses required prior to addition of fuel oil to the tank.- A period of J one 06 n A.4/e 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is considered sufficient to complete restoration of 1

t,, / on SMJr^

This period is acceptable based on the remaining capacity the required level prior to declarin the DG inoperable.

t I** *l*

th dn aipresid)(.

o.atn replenishment, and the low probability of an event 6 days) the fact that procedures will be initiated to b dA f.

during this brief period.

Mj With lube oi inventory < 500 gal, uffittent lubricating oli to sup rt 7 days of continuo DG operation at full load con tions may not be avat le. However, the Condit is restricted to lu oil volume reductions at p -

maint n at least a 6 day su ly. This restriction a ows suf cient time to obtain t requisite replacement clume.)

g q

pg gp,7 A

riod of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is c sidered sufficient to lete b bdb.

5 (continued) u CEOG $1$

B 3.8-43 Rev1,04/07/95 4

w * -

=.

4 BASES INSERT APPL For both Unit 1 and Unit 2, the FOST 1A associated DG is only DG 1A.

h For Unit 1, the FOST 21 associated DGs are DG 18 and DG 28. For Unit 2, the FOST 21 associated DGs are DG 2A and DG 28. Alignment does not affect the association of DG and FOST since the individual DG fuel oil day tank provides sufficient volume for the DG to perform its safety.

function while re alignment is accomplished, if necessary.w BASES INSERf A. 8, & C Condition A addresses only FOST 1A which is

tornado protected" and which h

contains sufficient fuel for 7 days of required operation of DG 1A.

It supports both Unit 1 and Unit 2 equipment since DG 1A provides power for equipment which is shared by both units, e.g., the control room emergency ventilation system (CREVS).

Condition B addresses only FOST 21 which is " tornado protected' and which contains sufficient fuel for 7 days of required operation of two DGs. F0ST 21 supports both Unit 1 and Unit 2 equipment, but Condition b is written for Unit 1 only to reflect the Unit I requirements for DGs 18 and 28. For an accident.

Unit ) requires either DG 1A or both DGs IB and 28 (since DG 28 powers equiraent which is redundant to some equipment powered by DG 1A, e.g., CREVS.

Sin.e DG 1A is supported by FOST 1A and the redundant required equipment is powered by DGs 18 and 2B which are supported by F0ST 21 at least one full train of required equipment is supported by a " tornado protected" FOST even with an inoperable FOST or DG.

Therefore, low fuel oil volume in F0ST 21 can be supplemented by the fuel oil volume of an OPERABLE FOST 11 to assure the necessary volume.

Required Action B.1 requires the combined volume of FOST 21 and an OPEPABLE FOST 11 to be verified to be greater than 6/7 of the required volume within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is consistent with the time needed to verify through administrative means that the backup FOST is OPERABLE.

Required Action B.2 requires the combined volume of FOST 21 and an OPERABLE FOST 11 to be 2 85,000 gallons within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

In addition, if FOST 21 is not restored and FOST 11 continues to be relied upon, Required Action B.2 must be repeated every 31 days. This effectively replaces the SR 3.8.3.1 periodic surveillance of available DG fuel oil volume for the inoperable F0ST 21. Since FOST 11 is not required by the LCO, FOST 11 may be considered OPERABLE only when the stored fuel oil meets SR 3.8.3.2 and SR 3.8.3.3, and is capable of being delivered to the required DG, i.e., the necessary piping and valves are capable of performing their safety function.

Specific alignment to a particular FOST is not required since the individual DG fuel oil day tank provides sufficient volume for the DG to perform its

i safety function while re-alignment is accomplished, if necessary. Further, if any fuel oil in FOST 11 above the 33,000 gallons reserved for emergency OG use

'O is credited for DG use, appropriate administrative controls must be in place to assure its retention for this purpose.

Condition C also addresses only FOST 21 which is

tornado protected" and which contains sufficient fuel for 7 days of required operation of two DGs.

F0ST 21 supports both Unit I and Unit 2 equipment, but Condition C is written,for Unit f

2 only to reflect the Unit 2 requirements for DGs 2A and 28.

For an accident.

Unit 2 requires either DG 28 or both DGs 1A and 2A (since DG 1A powers equipment which is redundant to some equipment powered by DG 2B, e.g., CREVS).

Unlike Unit 1. at least one full train of required equipment.is not supported by a

tornado protected" FOST with an inoperable FOST or DG since most of the redundant required equipment is powered by OGs 2A and 28 which are both supported by FOST 21. - Therefore. low fuel oil volume in FOST 21 can only be supplemented by the fuel oil volume of an OPERABLE FOST 11 to assure the necessary volume when the probability for a tornado is sufficiently low.

This is reflected in Note 2 for Required Action C.2 which addresses the inoperability of FOST 21 from April 1 to September 30.

During the time of low tornado probability. the Unit 2 requirements for the ihoperability of FOST 21 are very similar to the Unit I requirements for inoperability of FOST 21.

It is acceptable for the combined volume of FOST 11 and FOST 21 to be considered in providing 6/7 of the required volume for the 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowed by Required Action C.3.

Required Action C.1 requires the combined volume of FOST 21 and an OPERABLE FOST 11 to be verified to be greater than 6/7 of the required volume within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Required Action C.3 then requires the volume of FOST 21 to be restored to within volume limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

However, during tornado season, i.e.. from April 1 to September 30. the fuel oil volume of FOST 11 is not allowed to be credited and the fuel oil 7 day volume of FOST 21 must be restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months as indicated in Required Action C.2.

Required Action C,2 is also modified by a Note such that it is only required during the operation of Unit 2 in MODE 1, 2. 3. or 4 since the unit is already shutdown if it is in another MODE or condition. An OPERABLE FOST 11 is determined as described above in the discussion for Condition B.

t J

S I

,,, _,..,.. ~

-..m.-.

~s,m

- - -. ~

-m w

Diesel fuel 011 Lube 011, and Starting Air 8 3.8.3 BA$[$

ACTION $

RJ (cont ed)k restora on of the required volume for to declaring the DGl inoper le. This period is acce le based on the resa ing capacity (> 6 days), t low rate of usage, th fac that proct +res will be i ttated to obtain entshment, and the low p ability of an event dur is brief period.

This Condition is entered as a result f a f ailure to meet the acceptance criterion of SR 3.8.3. Nonna11y, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptablitty, poor sample procedures (bottom samp1tng),

contaminated sampilng egulpent, and errors in laboratory analysts can produce failures that do not follow a trend.

Since the prasence of particulates does not mean failure of the fuel oil to burn properly in the diesel engine, and particulate concentration is unitkely to chanae significantly between Surveillance Frequency Intervals, and proper engine performance has been recently demonstrated (within 31 days), it is prudent to allow a brief period prior to declaring the associated DG inoperable. The 7 day Completion Time allows for further evaluation, ressapling, and re-analysis of the DG fuel oil.

b With the fuel oil properties defined in the Bases for

$R 3.8.3.

not within the required limits, a period of 30 days is allowed for restoring the stored fuel oil propertie:L This period provides sufficient time to test thriTErid fuel oil to determine that the new fuel oil, when

[+D' ~"

v w h W.

mixed with previously stored fuel oil, rowins acceptable h

or restore the st ored fuel oil properties. ThisrestoratIon w 4: ni I,,,,4,

c' may inV6TWTiiif ana cieed 16csaures, filtering, or

%f _J combinations of these procedures. Evin if a DG start and I

load was required during this time interval and the fuel oil properties were outside limits, there is a high likelthood that the DG would still be capable of performing its intended function.

(continued)

CEOG STS 8,.8-44 Rev 1, 04/07/95

l Diesel fuel 011, Lube 01), and Starting Air B 3.8.3 DA$[3 ACTIONS LJ

-q (continued)

Q9 With starting tr elver pressere 4 '000 ;:f; ufficient 4

capacity for successive DG start attempts s not exist. However as long as the receiver press is

>(125]ttpsif, here is adequate capacity for least one start a

, and the M can be considered RABLE while the air tver pressure is restored to t required limit.

A period 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months is considered suffic nt to complete restore en to the required pressure pri to declaring the

. DG in rable. This period is acceptab based on the rena ind air start capacity the fac hat most DG starts ccesplishedonthefirslatteep and the low are p

bility of an event during this rief period.

i f.d With a Required Action and associated Cbilt use ourne 3

lation Time not Associated DGM.i are met one er more DGs with diesel fue j

[ ldentific) In Oc not witigin lietts for reasons other t an ss enditions A through En the associated DG pPig'AN. p g#8' 3

may be incapable of perfo mt its intended function and mustbeismedistelydeclared1noperable.]

g k

5 V[l'LLANCE 1R 3.a.3.1 REQUIREMENTS Of M *N This SR provides vertftcation a

ee s an adequate inventory of' fuel oil in the torage tanks to support (Hb dM Mn.truld

~ es to place the un't in a safe shutdown for 7 days ugge:tegg. The 7 day period is 9

su c en j,g* 0") 8^*

Y condition and to bring in replenishment fuel free an effsite l

eh It//n,,,/,,,1,

location, s ~-.

The 31 day frequency is adequate to ensure that a sufficient supply of fuel oli is available since low level alarus are provided and unit operators would be aware of any large uses of fuel oil during this period.

YER 3.aA t }

O Thi urveillance ensures the fficient tube ot) iny ry i

vallable to support.at 1 t 7 days cf full load (continued)

CEOG iTS B 3.8-45 Rev 1, 04/07/95 l

.s.

, - ~,.,,-

,v.

,, - ~,.

~-.__.___.__._...-__._._.__m._._

i I

Diesel fuel 011. Lube Oil, and Starting Air l

8 3.0.3 J

BAlt$

n

$URVilLLANCE sa 2.a.I.2 (conti At0UIREMENTS l

The[600 gal regui is based r censumptio]n values for

_; M r " r :eci run ties en the DS e4pufac of the DS.

it in this $R is the reget t te verify the capab11 R, api transfer the lube ett f its storage location to t 06, when the 08 lube oil s does not held adeguate inv tory for 7 days of full le operetten without the level chtng the manufacturer roc need einlaum level.')

Q l

7 A 31 d Frequency is adeguate to ens that a sufficient lube suerly is ensite, sincedOS arts and run time are

{es y men'1L'ered by the unit staf h.,2betablownha st 1 a.1

[M h b 'f g" the tests Itsted below are a means of termining whether W

new fuel oil is of the appropriate er has not been 2/,

A f9 te +srauri +a ALTN 2.D conteeinated with substances that would have an iemediate, Q/o b\\ oi\\ inchde 10%

detrisental insact en diesel enaine combustion.A 11 results

- I free snese tests are within acceptanle limits, the fuel all 2.b A4 Zb Iw.rulbr.

may be added to the storage tanks withest concern for i ~

contaminating the entire volume of fuel oil tu the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank (s), but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and appitcable ASTM Standards are as follows:

s.

le the new fuel ell in accordance with A5 040 7 % (Ref.

,,ff 3,991 gqqg

/0 I

b.

Veriff in accord e with the tests s i led i ASTM 2(,

i Dg % d (Ref.

that the sample s an abse ute q

spect'ic gravit t 60/60'F of n 0 and s or 2,

3 an API gravity at 60'F of n and s B '. a nematic I

at 40'C of 1 1.9 e stokes h d s 4.1 viscosit{et, and a flash point contiste It5'F: ana g

-c.

VerifythatthenewfuelellhasJ r ano or c-mawmx n g

(Eo.os % dF.o s se L eic.

g k:

.' [A5YM. 'b 9'IP 199Q.

I (continued) e l

l CE04 Sf$

8 3.3 46 Rev 1, 04/07/95

~.. - _- -

i I

Diesel fuel 011 Lube 011, and Starting Air l

8 3.8.3 Bast $

SURVf!LLA18CE 1R 3.8.1.

(continued)

At0VIREMElfi$

Failure to meet any of the above limits is cause for rejecting the new fuel oil, but does not represent a failure to meet the LCO concern since the fuel oil is not added to the storage tanks.

Within 31 days following the initial new fuel oil sample, g o

the fuel oil is anained to establish that the othe properties specified in Table ! of ASTM 0975-are met for new fuel oil.when ***td i= =~

---a w(th Ref.

i g

A$fM M 7" "

l '*-' g 'sw ance eith MTM DMs 3

.e.

.e, vn iin r

wlfu2r%A59,D2A22-f fanf.

/The31gayperion

... - in h

Ref.

3 acceptable because the fuel oil p porties of interest, even if they were not withth' stat 6d limits, would not have an twediate effect on DG operation. This Surve111ance ensures the availability of high quality fuel oil for the DGs.

Fuel oil degradation during long tem storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not mean the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however, which can cause engine failure.

r,-

particulate concan" rations should be detemined

- M@

6 f edysi5 balm os Eccordanc th A5 pmm C Ieng a me' r.

s 'Ar -

10

,r -#0' IL _TM ht14-iggq)

Mth vo1Veppgrmee,r lc tv= wrwinsw onior '.0161

/\\S

~'---

particulate concentration in theTfuel o'1 'and has a limit of I8.24**

to ag/1. It is acceptable to obtain a field sample for

'28 subsequentlaboratorytestinfhetotalstoredfuelolivolume in lieu of fleid testing LfFe st'-!= W --

4-

Q:

bAAA is contained in two @

interconnected tanks, each tank must be considered ant.ested separately.}-[-

N"" #4 't 8 f/*"

The Frequency of this test takes into consideration fuel oli Ad vi/,s/v.I.4A degradation trends that indicate that particulate h 46 #

concentration is unitkely to change significantly between Frequency intervals.

(continued)

Ct0G STS B 3.8-47 Rev 1, 04/07/95 rr-

-m-r-

-"*---w

---s-

-e*

e

i 5

Olesel fuel 011 Lube 011, and Starting Air.

B 3.B.3 8A$t$

^

$URVIILLAleCE f SR 1.u.La 7

REQUIREMElfTS sures that, without the at f the (continued)

This Surveillance refill compressor sufficient air start capac y for each DG is available. T system design requirement provide for a ft } engine start cycles wit recharging.

minimumef(1

[A stcrt cyc is defined by the CG vender but usus11y 17 measured in rus of time (seconds or cra ing)erengine ref)ectthelowestvalueatThe pressure specified n this SR is cranking :

l ichthe[ftve]

3 intended t i starts c be accespitshed.

The 31 sy Frequency takes into acc t the capacity, capabiIty,redundanc)lableinth and divers y of the AC sources and other Indications avai cor. trol room including ala s, to alert t's operator to low normal alr start (prssure.

J SR 1.8.3 g

Micrchiological fouling is a major use of fuel oil degradation. There are numerous b teria that can grow in fuel oil and cause fouling, but al must have a water environment in order to survive. Removal of water from the fuel storage tanks once every days eliminv. 3 the necessary environment for bact I survival. 'nts is the most effective means of controlling microbiological fouling.

in addition, it altninates the potential for water cr.trainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, round watir, rain water, and contaminated fuel oil, and from breakdown of the fuel ot) by bacteria. Frequent checking for and removal of accumulated water minimites fouling and provides data regarding the watertight integrity of the fuel oli system. The Surveillance Frequencies are estabitshed by Regulatory Guide 1.137 (Ref.

This SR is for preventative maintenance. The pressace o water does not necessarily represent failure of this $R vided the accJoulated water is removed during perforza e of the furveillance, i

(continued)

CEOG STS B 3.8-48 Rev1,04/07/95

Olesel Fuel 011 Lube 011, and starting Air B 3.8.3 BA$ts

$URV(ILLANCE 1h.R.3.5 \\

REQUIREMENTS T

(continued) katning of the fu oli stored in the supply tanks val of accumulated s ment, aM tank cleaning are requ at by Regulatory Guide 1.137 Ref.

9 This aise reoutres the perfor(an eofthe 10 year interva paragraph 2.f tien XI the tanks, ferr* & /ed l the introdu(Ref. 8)f examinattens LSME Code, ction o surfactants the fuel oil To preclud systes e cleaning should be accomplis using sodium hypochi tte solutions, or their equival

, rather than soap deterpents. This $R is for p ntative mal enance. The presence of sedine does not necessarily sent a failure of this $R, p ded that accumulated 1

inent is removed durina perfo nee of the surveillanceg Ckshe 6 n

REFERENC[$

1. g 5AR, r***i

.!.'.;).

h Regulatory Guide 1.137.

h

^ 7',.";; n f 5 ?.

h h/.h5AR,Chapteri6d

/@FSAR, Chapter gg gg (,

g%

g f.

ASTM scandards: D4057-.

_D975-

@Q g Q f M y Jivin Y )

l

@ /.

ASTM standards, 0975, Table 1.

4.

f r :, s wi r..w

... =, - -i r a u - < -

ma '-

l I

CEOG STS B 3.8-49 Rev 1, 04/07/95

DISCUSSION OF HASES DEVIATIONS FROM NUREG 1432 SECTION 3.8. ELECTRICAL POWER SYSTEMS This change will be reviewed for applicability to other Combustion Engineering plants and other vendors. Based on these results, a generic change will be proposed accordingly.

24.

Not used.

25.

He NUREG.li32 Bases for SR 3.8.1.3 statn that the reason for precluding performance of the DG toad nm Surveillance on more than one DG at a time is to avoid common cause failures that might result for offsite circuit or grid p.rturhations. His statement implies ti.at the DGs can never be paralfeled to the grid simultaneously even if Calvert Chffs is not performing this Surveillance, since the reasons listed would apply when paralleling the DGs to the grid for a reason other than perfonning this Surveillance. His Note only applies to performing this Sun'elliance: it does not preclude Calvert Cliffs frorn paralleling to the grid more than one DG

imultaneously for reasons other than pensrming this Surveillance. For instance, when a DG is started for any reason (e.g., due to an inadvertent engineered safety feature signal), the DG manufacturer recommends loading the DG for approximately one hour as soon as possible after starting. Then. fore, the Bases have been modified to provide adequate reasons why this specific Surveillance should not be performed simultaneously on more than one DG, nis change is consistent with Current Licensing Basis, since this restriction (precluding performance of this Surveillance on more than one DG at a time) is not currently provided in the Calvert Cliffs Technical Specifications.

26.

He Bases for NUREG.1432 SR 3.8.3.3 indicatepint fuel oil particulate concentrations should be determined "in accordance with ASTM D2276-[

], Method A (Ref. 6). His method involves a gravimetric determination of total particulate concentration in the fuel oil...." His Bases statemet.: is revised to read: " Particulate concentrations should be determined by gravimetric analysis (based on ASTM D22761989) of total particulate concentration in the fuel oil...."

Calvert Cliffs has included the requirement to test for pasticulates in SR 3.8.3.2, but the testing is not in full accordance with ASTM D2276 [

), Method A. As indicated in the change, total particulate concentration is determined by gravinetric ant. lysis based on ASTM D2276-1989.

Ilowever, ASTM D2276 Method A.2 is a test method for fuel systems under pressure. The Calvert Cliffs diesel FOSTs are not under pressure, so this is not an appropriate test method.

American Society for Testing and Materials D2276 Method A 3 is a gravimetric analysis and is the basis for the testing done at Calvert Cliffs. The deviations from ASTM D2276 89 Annex A 3 method are evaluated and determined to not impact the ability of the method to provide accurate results, nese deviations are:

He reagents used are different: Calvert Cliffs uses isoatane, while the ASTM requires a.

freon (1,1,2 trichloro 1,22 trifluoroethane) and petroleum ether. A F.!!er dispenser is not always used, as Calvert Clitfs purchases ultra pure reagents for use in this analysis.

b.

Mc preparation, handling and storage of apparatus is different:

Removable glass supports are not used in petri dishes.

Ta multiple solvent rinse steps are eliminated as the equipment used is dedicated for use with diesel fuel oil, Container caps are handled by the exterior surfaces, but not with tongs.

e ne apparatus used is prepared,just prior to use, thus the equipment is not plastic e

wrapped for storage. For the period of time it is not in use, the equipment is stored in a dust free environment.

CALVERT CLIFFS UNITS I & 2 3.8-4 Revision 10

DISCUSSION OF BASES DEVIATIONS FROM NUREGo1432 SECTION 3.8. ELECTRICAL POWER SYSTEMS c.

He sampling is different. Calvert Cliffs samples in accordance with ASTM D4037.

Calvert Cliffs also uses less than the 3.785 5 liter sample volume suggested in ASTM D2276. He sample volume is measured prior to filtering.

He Bases for NUREG 1432 SR 3.8.3.3 provide specific limits for absolute specific gravity and API specific gravity which are not applicable to Calvert Cliffs. Unit specific emergency DG fuel oil limits are useu at Calvert Cliffs for these parameters which are based on unit specific fuel oil consumption of the DGs and the related requirements for energy required to be obtained from the futi oil.

Specifically, the emergency DGs reqehe between 19,810 DTU/lbm and 19350 DTU/lbm which correspond to a specific gravity of 0.8155 (6.8 lbm/ gal,42 API) and 0.8871 (7.4 lbm/ gal,28 API), respectively. These are based on a conversion of:

API gravity = (141.5/ specific gravity) 131.5 ne Dases for NUREG 1432 SR 3.8.3.3 state: " Verify the new fuel oil has a clear and bright appearance with proper color when tested in accordance with / STM D4176-[ ] (Ref. 6)." ne

" clear and bright appearance witn proper color" parametei b not cunently a requirement for determining acceptability of emergency DG fuel oil at Calvert Cliffs because the fuel oil is dyed.

Rather, a " water aad sediment" limit is required per CTS SR 4.8.1.1.2.b. Calvert Cliffs is not currently using dyed fuel, which would preclude the " clear and bright" requirement, but would like to retain the option of using dyed fuel. Therefore, this requirement is retained with a limit of 0.05% based on ASTM D9751996 (the latest revision), and the " clear and bright" Bases statement is replaced with a " water and sediment" requirement and reference.

He Bases for NUREG-1432 SR 3.8.3.3 indicates that for new fuel oil, analysis is required to establish that the other properties specified in Table 1 of ASTM D975 are met for new fuel oil "when tested in accordance with ASTM D975-[

] (Ref. 6), except that the analysis for sulfur may be performed in accordance with ASnt D1552-[ ](Ref. 6) or ASTM D2622-[

] (Ref.

6)." ne ITS 3.8.3.2 Dases will refer to ASTM D9751996 for this testing which includes the exception for analysis of sulfur. Therefore, an additional reference to an " exception" to the standard is unnecessary, llowever, the ASTM D9751996 standard addresses both ASTM 2D and ASTM 2D low sulfur fuel oil. Both of these two types are considered to be encompassed by the ITS references to ASTM 2D, and a Bases statement is included to eliminate potential for confusion associated with the acceptability of ASTM 2D low sulfur fuel oil.

27.

Not used.

28.

He Reviewer's Note associated with the NUREG 1432 Bases for SR 3.8.4.4 is not included in the Calvert Cliffs ITS Bases. This information allows the NRC reviewer to identify what is needed to meet the requirement. The Note is not meant to be retained in the final version of the plant specific submittal.

29.

The description of a modified performance discharge test in the NUREG 1432 Bases for SR 3.8.4.7 is moved to Calvert Clifts ITS SR 3.8.4.8 Dases. This is done since Calvert Cliffs ITS SR 3.8.4.8 is the Surveillance that requires the modified performance discharge test. Due to this move, the references to the description of the modified performance discharge test being located in the description of the service test are deleted. In addition, the reason for the Note to CALVERT CLilTS - UNITS 1 & 2 3.8 5 Revision 10

DISCUSSION OF CASES DEVIATIONS FROM NUREG-1432 SECTION 3.8. ELECTRICAL POWER SYSTEMS Calvert Cliffs ITS SR 3.8.4.7, which allows performance of the modified perfortnance discharge test in lieu of the r,ervice test, is provided consistent with the ISTS Writer's Guide.

30.

Editorial changes are made for clarification or to be consistent with similar statements in other places in the ITS Bases.

31.

Battery cell parameters support the operation of the DC electrical source channels and the Battery Cell Parameter Specification is required to be applicable during the same MODES and conditions as in LCO 3.8.4, "DC Sources. Operating," and LCO 3.8.5, "DC Sources.

Shutdown." The same safety analyses discussions as those discussed in the Pases for LCO 3.8.4 and LCO 3.8.5 aie also applicable to the Battery Cell Parameter Specification. As a result, the NUREG 1432 Bases for the Battery Cell Parameter Specification (H 3.8.6) in the Applicable Safety Analyses Section are revised accordingly.

32.

The example provided in the Bases that describes an dditional DO capability that must be demonstrated to meet required Surveillances has been changed to be consistent with the actual Surveillances in the Calvert Cliffs ITS. De Calvert Cliffs ITS did not retain the Surveillan:e that verifies the DO reverts to standby status on an Emergency Core Cooling System signal, thus the example is not used in the Calvert Cliffs Bases. The exeple provided in the Calvert Cliffs Dases is that the DG rejects a load 2 500 hp without tripping, since this is one of the Surveillances in the Calvert Cliffs ITS.

CAINERT CLIFFS - UNITS 1 & 2 3.8-6 Revision 10

Pcge Replacement I:structions :

VOLUME 15 i

Section 5.5 Note: Underlined titles indocate tabs in volumes. Regarding CIS markups: Pages are referenced by citing the unit number as well a. the spec @ cation number located in Ihe upper right hand corner ofthe CTSpage.

Key:

DOC = Discussion ofDunges DOD = Discusston QJTechnicalSpec@ cation Deviation or Discussion QfBases Deviation RF. MOVE INSERT Ovenlew of Chanitt None 114 5.0-26 5.0-26 JTS Bases l

None CTS Markun & Discussion of Chanrew Spec @ cation 10, Unit i Page 49 of 61 Page 49 of 61

.:pec@ cation 50, Unit 2 Page 45 of 57 Pr;c 45 of $7 NNilC l'indinas None INTS Markun & d)ficalion 5.0 16 5.0 16 DOD 5.0-3 through 5,0-5 DOD 5.0-3 through 5.0-5 ISTS Hases Mukyo & Justification None i

Programs and Manuals 5.5

[

5.5 Programs and Manuals 2.

A flash point and kinematic viscosity within limits for ASTN 20 fuel oil, and 3.

Water and sediment s 0.05%.

b.

-Within 31 days following addition of new fuel oil to the storage tanks, verify that the properties;of the new fuel i

_ oil, other than those addressed in a., above, are within limits for ASTM 20 fuel oil; and l

c.

Total particulate concentration of the stored fuel oil, determined by gravimetric an61ysis based on ASTM D2276-1989, lo iss10mg/lwhentestedevery92 days.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil-Testing Frequencies.

- 5.5.14 Technical Soecifications Bases Control Prggtam This program provides a means for processing changes to the Bases of.these Technical Specifications, a.

Changes to the Bases of the Technical Specification shall be made under appropriate administrative controls and reviews.

b.

Licensees may make changes to Bases without prior NRC t

approval provided the changes do not involve either of the following:

i 1.

A change in the Technical Specification incorporated in the license; or 2.

A change to the UFSAR or Bases that involves an unrovicwed safety question as defined in 10 CFR 50.59.

c.

The Bases Control Prigram shall contain provisions to ensure that the Bases are mai.*.tained consistent with the UFSAR.

CALVERT-CLIFFS - UNITS 1 & 2 5.0-26 RevisionA/o 1

t y

e r - -..

,,,, -, ~ -

-m evm~r--,,

r,

.t

-w.--*.

--e

- -~

i Sp n.G. ken 5 0 f

l IN35RT1113 I

P L J 2-l 5.5.13 Dianal Fuel OilTesting Program f

A desel fuel oil testang program to implement required testing of both new fuel oil and i'

stored fuel oil shall be established he program shall include sampling and testing requirements, and acceptance criteria, all in ash with appliable American i

Sockty for Testing Materials (ASTM) Standards. De purpose of the program is to ertablish the following-a.

Acceptability of new fuel oil for use prior to addition to storage tanks ' y determining that the fuel oil has:

1.

An American Petroleum institute (API) gravity or an absolute specific gravity within limi*.s, 2.

A flash point and kinematic viscosity withir. limits for ASTM 2D fuel oil, and 3.

Water and sediment s 0.05%.

b.

Within 31 days following addition r f the new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil; and c.

Total particulate concentration of the ctored fuel oil, determined by gra timetric analysis is s 10 mg/l when tested every 92 days.

g bued aw Mrn bli%-14f4)

De provisions of SR 5.0.2 andlSR 3.0.3 are applicable to the dicsci fuel oil testing Frequencies, pyc//9*SO

INSERT 5.5.13 fyt 2dk 5.5.13 Digel Fuel Oil Testing Progam A diesel fuel oil testing program to implement required testmg of both new fuel oil and stored fuel oil shall be established, ne program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable American Society for Testing Materials (ASTM) Standards. The purpose of the program is to establish the following:

a.

Acceptabiiity of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:

1.

An American Petroleum Institute (API) gravity or an absolate specific grasity within limits, 2.

A flash point and k.inematic viscosity within limits for ASTM 2D fuel oil, and 3.

Water and sediment s 0.05%

b.

Within 31 days following addition of t..e ncw fuel oil to storage tanks, verify that the proparties of the new fuel oil, other than those addressed in a., above, are within limits for ASTM 2D fuel oil; and c.

Total particulate concentration of the stored fuel oil, octermined by gravimetric analysis is s 10 mn/l when tested every 92 days.

g 1,ased_em AST/1 b22*4 -l@]i, he provisions of SR 3.0.2 and SR *.f.0.3 are ~apiilicable to the diesel fuel oil testing Frequencies.

c 45 0

Programs and Manuals 5.5 (c,yJ) 5.5 Programs ant 'anuals (continued) 5.5.13 D.itjel rue) 011 Tettina Procram A diesel fuel all testing program to taplement reeutred testino of (4.% t.t.2.b) both new fuel oli and stored fuel oil'shall be established. &

program shall include sampling and testing requirements and acceptance criteria, all in accortlance with appitcable ISTM Standards. The purpose of the program is to estabitsh the followings a.

Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel all has:

L

T'* # 1 *E 1.

An API gravity or an absolute specific gravity within IE p M 3.o. t.,A y %,g limits.-

[ //8 I "4 ofy h l>< 4.. K [ 2.

A flash point and kinematic viscosity within limits

sr 0 <,d IM o.) %4, y ASTN 20 fuel oil, and,

y y,)ld

~

3.

Oclair' and bright appearangwith prooveo1D; f def*h b.

Q1bDropertiss for ASTM 2 Fuel all are inkthierftw within 31 days following w I W 4dditionho staraon--

W-/0h

j tank}tand {per'.h +J 4A& % Tr.pa,W< W F 4an red f* 5 e N eAbir

'^

afJia_Ia Ay e 4% e et a e4Ma_ ll= 4<

R_* A6 R8_0 M 8

t Total particulate ~ concentration of the fuel oilgs s 10 mall _

A c.

when tested every days to ecced..m; wit'; ff C;,-

2r J.

72

(() ;

5.5.14 Technical Specificatient (TS1 Bates Control Procram

[Lge gy,gh h'6'h This program provides a means for of these Technical Specifications.procsssing changes to the Bases g7 7 p p;me/st (I,. M A) a.

Changes to the Bases of the T5 shall be made under

" 'V appropriate admit.istrative controls and reviews.

\\

j b.

Licensees may make changes to Bases without prior NRC

%gej M (iL4.1.)

M g$r vided the changes do not involve either of the 4

h A change in the TS incorporated in the licenst 4,g,4,g g) h A change to the or SAR or Bases that involves an

<k. 0 4 M*h unreviewed safety c%stion as defined in 10 CFR 50.59.

(continued)

CCOG STS 5.0-16 Rev 1, 04/07/g5

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG.1432 SECTl*lN 5.0 - ADMINISTRATIVE CONTROLS 20.

He Calvert Cliffs CTS 4.4.5.5 requirements for steam generator tube inspection reports were inserted into NUREG 1432 Section 5.6.9, Steam Generator Tube inspector Report. His change is consistent with the Reviewer's Note for this section, which requires the licensee to incorporate their current licensing basis regarding steam generator tube inspection reports.

21.

Calvert Cliffs will not include a section on liigh Radiation Area (as depicted in NUREG 1432 Section 5.7.s as r. bracketed specification) consistent with the current licensing basis.

22.

The proposed change to NUREG 1432 adds a requirement that licensed operators counted towards the minimum shift crew composition shall be licensed for both units. His is s specine requirement for Calvert Cliffs and is consistent with the current licensing basis.

23.

The proposed change to Specification 5.5.ll.c changes the penetration requirements of methyl iodide from less th m 10%, to less than or equal to 10%. His change is consistent with the Calvert Cliffs current licensing basis, which requires a 2 90% removed ernciency of methyl iodide.

24.

The propos. I changes to Speci0 cations 5.5.11.a and 5.5.11.b change the penetration system bypass requirements of the high efficiency particulate air filters and charcoal absorbers from

< l.0% to s 1.0%. His change is consistent with the current Calvert Cliffs licensing basis which requires a 2 99% removal efficiency.

25.

He Bases for NUREG 1432 SR 3.8.3.3 indicate that fuel oil particulate concentrations should be determined "in accordance with ASTM D2276-[

], Method A (Ref 6). This method involves a gravimetric determinatic a of totrl particulate concentration in the fuel oil...." His Dases statement is revised to read: " Particulate concentrations should be determined by gravimetric analysis (based on ASB1 D2276-1989) of total particulate concentration in the fuel oil...."

Calven Cliffs has included the requirement to test for particulates in SR 3.8.3.2, but the testing is not in full accordance with ASTM D2276 [

), Metiiod A. As indicated in the change, total particulate concentration is determined by gravimetric anal; sis based on ASTM D2276-1989, llowever, ASTM D2276 Method A 2 is a test method for fuel systems under pressure. The Calvert Cliffs diesel FOSTs are not unda pressure, so this is nc> an appropriate test method.

American Society for Testing and MaterirJs D2270 Method A-3 is a gravimetric analysis and is the basis for the testina done at Calvert ClitTs. He deviations from ASTM D2276-89 Annex A.3 method are evaluated and determined to not impact the ability of the method to provide accurate resulta. These deviations are:

He reagents used are different: Calvert Cliffs uses iso-octane, while the ASTM requires a.

freon (1,1,2 trichloro-1,22 tri0uoroethane) and petroleum ether. A filter dispenser is not always used, as Calvert Clifts purchases ultra pure reagents for use in this analysis.

b.

The preparation, handling and storage of apparatus is different:

Removable glas supports are not used in petri dishes.

He multiple solvent rinse steps are eliminated as the equipment used is dedicated for use with diesel fuel oil.

Container caps are handled by the exterior surfaces, but not with tongs.

CAINERT CLIFFS - UFITS I & 2 5.0-3 Revision 10

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 5 0 - ADMINISTRATIVE CONTROLS The apparatus used is prepared just prior to use, thus the equipment is not plastic e

wrapped for storage. For the period of time 's is not in use, the equipment is stored in a dust free environment.

c, The sampling is difTerent. Calvert Cilffs samples in accordance with ASTM D4037.

Calvert Cliffs also uses less than the 3.785 5 liter sample volume suggested in ASTM D2276.1hc sample volume is measured prior to filterint,.

26.

The Calvert Cliffs CTS Administrative Controls uses generic titles provided in American National Standards Institute /American Nuclear Society 3.1 irutead of plant specific titles. The plant specific titles that correspond to the generic titles are given in the Updated Final Safety Analysis Repon. The use of generic titles in the Administrative Controls was encouraged in a letter from C.I. Grimes (NRC) to Lee Bush (WOG), Brian Mann (CEOG), Clinton Szabo (B&WOG), and Andrew Maron (BWROG), dated November 10,1994. These generic titles are carried over into the Calvert Cliffs ITS. Also, some additional titles appear in NUREG 1432.

For consistency, generic titles have been used in those locations, in addition, a change was made to allow the corresponding plant specific titles to be placed in the Quality Assurance Policy or the Updated Final Safety Analysis Report. *lhis is consistent with the November 10,1994 letter.

This change has been proposed as a change to the ITS NUREG as TSTF 65, but has not yet been approved by the NRC, 27, lhe Calvert Cliffs current licensing basis requires the General Supervisor Nuclear Plant Operations to hold a license, and also requires the operations manager (the individual the General Supervisor Nuclear Plant Operations reports to) to hold or have held a Senior Reactor Operator license at Calvert Cliffs. This requirement is being retained in the ITS.

28.

This change incorporates the current Calvert Cliffs requirements for the lodine Removal System into the Ventilation Filter Testing Program. This requirement is consistent with the Calvert Cliffs current licensing basis.

29.

lhe gas storage tank radioactivity limit in NUREG 1432 Specification 5.5.12.b has been l

changed to be consistent with the Cahert Cliffs current licensing basis. The Calvert Cliffs ITS radioactivity limit will be that in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to a member of the public at the site boundary will not exceed accident guidelines.

30.

The CTS state that the Occupationai Radiation Exposure Report for the Independent Spent Fuel l

Storage installation is reported separately from the Units I and 2 Occupational Radiation l

Exposure Report. Therefore, for clarity, the Note to ITS 5.6.1 has been modified to preclude combining the reports into a single submittal, f

l 31, The phrase ", as modified by approved exemptions" has been added to the ITS 5.6.3 requirement i

that the Radioactive Effluent Release Report be submitted in accordance with 10 CFR 50.36a.

Current Technical Specification 6.6.3 fortnote """ allows an exemption to 10 CFR 50.36a that allows the Sr" and Sr* analysis results to be submitted at a later date. The addition of the phrase ", as modified by approved exemptions" is consistent with its use in other ITS tnat allow l

exemptions (e.g., ITS 3,6.1).

1 CALVERT-CLIFFS - UNITS 1 & 2 5.0-4 Revision 10

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 5.0 - ADMINISTRATIVE CONTROLS 32.

The current Calvert Cliffs licensing basis surveillance frequencies have been provided in ITS 5.5.11. In addition, for clarity the NUREG 1432 discussion concerning the provisions of SR 3.0.2 and SR 3.0.3 have been moved to the end of this specification after the discussion of frequencies, since it applies only to the frequencies.

l 33.

The statement in NUREG 1432 Specification 5.5.11,"at the system flowrate specified below [+.

10%]" has been deleted since it is redundant. Each of the requirements in NUREG 1432 Specification 5.5.11 that require a specific flowrate have the same statement.

34.

The requirement of NURE04 '32 Section 5.2.2.b has been climinated from ITS 5.0.

The requirements for shift manning are provi. t 10 CFR 50.54(mX2Xili) and 50.54(k). Title 10 CFR 50.54(mX2Xiii) requires: "when a nu. sear power unit is in an operational mode other than cold shutdown or refueling, as defined by the unit's technical specifications, nch licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at all times.

n addition to the senior o,erator, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times." Further 10 CFR 50.54(k) requires: "An operator or senior operator license pursuant to part 55 of this chapter shall be present at the controls at all times during the operation of the facility." The requirements of 10 CFR are required to be met. Thus, these requirements do not md to be reiterated in the ITS.

Additionally, a generic change (TSTF 121) has been proposed to resolve this issue.

35.

Current Tecbdcal Specification 6.5.6 provides the requirements for the Containment Leakage Rate Testir J rogram. This program was recently revised in Licena Amendment Nos. 219 and P

196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively. 1hese License Amendments were issued on February 11, 1997. They adopted Option B of 10 CFR 50, Appendix J. This program has been incorporated as ITS 5.5.16. The current licensing basis has been incorporated, because TSTF 52 has not been approved by the NRC. Additionally, requirements from Unit 1 CTS 4.6.1.2.b and 4.6.1.2.c have been added to the Containment Leakage Rate Testing Program. They require: a) the Unit I containment purge isolation valves to be demonstrated OPERABLE any time after being opened and prior to entering MODE 4 from shutdown modes by verifying that when the measured leakage rate is added to the leakage rates determined pursuant to the Containment Leakage Rate Testing Program for all other Type B or C penetrations, the combined leakage rate is less than or equal to 0.60 L.; b) leakage rate for the containment purs;e iv!6 tion valves are compared to the previously measured leakage rate to detect excessive valve degradation; and c) the containment purge isolation valve seals to be replaced with new seals at a frequency to ensure no individual seal remains in service greater than 2 consecutive fuel reload cycles. These requirements provide assurance that the Unit I containmen* 9 urge isolation valves are OPERABLE; they are being provided in lieu of NUREO-1432 SR 3.6.3.6. While the proposed Containment Leakage Rate Testing Program is not identical to the pagram proposed in TSTF 52 for incorporation into NUREG-1432, it is technically equivalent (except for the additional more restrictive requirements for the Unit I containment purge isolation valves)

CALVERT CLIFFS - UNITS I & 2 5.0-5 Revision 10 1

k 5

ATTACIIMENT (1)

IMPROVED TECHNICAL SPECIFICATIONS, REVISION 10 RESPONSFS TO REQUEST FOR ADDITIONAL INFORMATION e

s Haitimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 5,1997

9M M M -

ATTACIIMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8.3

. l NUREG DOC JFD CIIANGE/ DIFFERENCE COMMENT

' STATUS 3.83 NUREG LCO 3.83 The licensee has opted to not incuiporate the The licensee should explain why this Comment starting air and lube oil portions of the NUREG LCO.

decision was made and is considered

1 IIowever, nojustification has been provided.

acceptable.

BGE Response:

l Revised improved Standard Technical Specification (ISTS) 3.83 markup to show DOD 12 asjustification for this change.

NUREG 13,2 l Condition A The staffdoes not ag;N with the puposed The stalTrecommends retaining the NUE6 Comment revision to Condition A or Required Action A.I. As format, even though this will result in L

2 proposed, the revised Condition A does not simplify any lengthy Condition A. In this way, Condition issues, rather, it makes the LCO more cumbersome. The A, Condition D, and SR 3.83.1 all tie NUREG is organized such that the requirements are together without confusion.

completely stated in Condition A, and default Actions are contained in Condition D. As propcsed, an operator does not have a direct reference to what the LCO limits are.

SR 3.83.1 provides some insight, but is not a direct reference to Condition A. Then, insert A.1 directs the operator to Action D if there is less than 6 days supply of fuel oil in any tank, but fails to state what that 6 day

)

supply is. For this value, an operator must refer to the Bases. At best, this is cumbersome.

BGE Response:

Revised Condition A (and added new Conditions B and C) to reflect limits, design, and current licensing basis.

NUREG 12 Condition B See comment / Note under LCO 3.83, Comment above.

3 BGE Response:

j See response to NUREG LCO comment #1.

NUREG Insert Reauired Action A_1 Note lhe license:should g

Comment consider providing a Table or a matrix in t e Bases to h

4 provide an explanation of the Fuel Oil Storage System at i

USC = Discussion of Change JTD = Justifica' ion for Deviation EDD = Discussion of Devistkm s

ATFACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECliNICAL SPECIFICATIONS SECTION 3.S.3 i

NUREG

' DOC JFD CHANGE / DIFFERENCE COMMENT STATUS

'3.83 i

CCNPP. De Bases discussion of OPERABILITY should also emphasize the single DG for the DBA tmit, and the single DG for the shutdown unit.

BGE Response:

Condition A is revised to omit the Note, and the volume limits are included in the Condition. De Pres Background is revised to provide additional de=ription to more clearly describe the system.

NUREG Condition E See comment / Note under LCO 3.83, Comment above.

5 l

BGE Response:

See response to NUREG LCO comment #1.

NUREG 13 Insert Condition D Ris insert is not necessary if the Comment NUREG format is followed. See comments under

6 Condition A,above.

BGE Respor:se:

Revised to omi: Condition D INSERT since limits will be reflected in Condition.

NUREG 2

SR 3.83.1 What do the specific gallon figures Comment represent? A 7-day supply? A 6-day supply? Whae is

7 this information found? These questions would not be a problem if the NUREG format is retained.

l BGE Response:

l The LCO Bases are revised to provide additional descriptions of the required seven day values.

~

l NUREG 12 NUREG SR 3.83.2 and NUREG SR 3.83.4 His is a subset of he comment under LCO 3.83, and the Note.

Comment t

8 l

BGE Response:

See response to NUREG LCO comment #1.

DGE = Discussion of Change.

2 JFD = Justification for Deviation DOD = Discussion of Deviation i

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3

. BASES

' DOC JFD CHANGE / DIFFERENCE

. COMMENT -

STATUS 3.83 Bases 9

LCD Seecommentsre; deletionoflubeoil Comment and starting air from this LCO in staffcomments to LCO

1 3.83.

BGE Hesponse:

See response to NUREG LCO comment #1.

Bases Background The Background section of3.83 Commee Bases may have to be revised as a function of resolution

2 of staff comments to LCO 3.8.1. Also note that deletion of the term "and impurity level" from the 3rd paragraph of the Background is not consistent with the LCO Actions.

BGE Response:

See response to NUREG LCO comment #1. Also, Bases revised to restore "and impurity level" with parenthetical notation to indicate this refers to the total particulates.

Bases 9

Action A 1 Tne proposed Bases is inconsistent Comment with thejustifications for changes to the LCO.

3 Specifically, the numerical values for thel oil quantity are proposed to be moved to the Bases, but these values are not included in the Bases for Action A.I.

BGE Response:

See response to NUREG LCO comment #1.

Bases 9

Action D.I See comments re: Action D.I in Comment staffcomments to LCO 3.83. Also Note that 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months

4 should be 2 6 days.

BGE Response:

See response to NUREG LCO comment #1 which also deletes the reference to six hours.

Bases 1, 2, SR 3.8.4.2 What is th: justification for Comment 3

changing the Bases numbers for absolute specific gravity

5 l

and APIgravity? thesechangesarenotdiscussesin DOC = Discussion ofChange 3

JFD = Justification for Deviation DOD = Discussion of Deviation

ATTACIIMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8.3 BASES DOC JFD CilANGE/DIITERENCE COMMENT STARIS 3.8.3 justifications 1,2, or 3.

Are 1988 and 1981 the latest revisions of ASTM IM057 and D975, respectively? What is the ASTM standard for deterrrdning water and sediment in the new fuel?

BGE Response:

Discussion of Bases Deviation 1 is the properjustification since this is a change to non-bracketed information consistent with the Calvert Cliffs specific information.

Ilowever, a new Discussion of Bases Deviation 26 is included to provide more specificjustification for the change. Additionally, ASB1 D4057-1995 and ASB1 D975-1996 are the latest revisions. He Bases have been revised to reference these latest revisions to these standards. Ilowever, since ASTM D975-1996 has limits for both 2D and a "2D low sulfur" fuel oil, a change to the Bases is incorporated to indicate that Technical Specification and Bases references to ASTM 2D include both the grade 2D and 2D low sulfur fuel oil. De Bases are also modified to reflect that the applicable water and sediment standard is ASB1 D975-1996.

Bases 3, 2, SR 3.8.3.2 What is thejustification for deleting Comment 5

some of the NUREG material in the second paragraph on

6 this page. He deletion is not addresses injustifications 2,3, and 5?

BGE Response:

New Discussion of Bases Deviation 26 is provided to indicate that the material in the second paragraph is deleted since the identified exception is prcvided for in ASTM D975 1996; therefore, an additional exception to D975 in these Bases is not necessary.

Bases l

SR 3.8.3.2 What is the rationale for deleting Comment the Bases reference to ASB1 D2276 in the 4th paragraph

7 on this page? Justifications 1,2, and 3 do not address this change.

BGE Response:

New Discussion of Bases Deviation 26 is added to provide additional information for thisjustification which was originally identified only as a change to incorporate unit specific information.

DOC = Discussion of Change 4

JFD = Justification fiw Deviation tIDD = Discussion of Desiarion

ATTACIIMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3 l

3.83 DOC JFD CIIANGE/ DIFFERENCE COMMENT STATUS I

A.4 Unit 1: LCO 3.83 Moving these CIS requirements to De licensee should consider revising this SR is acceptable ad constitutes an Administrative DOC to delete reference to the Bases.

change. Ilowever, thejustification indicates some material may be moved to the Bases. His is/would not be acceptable. In addition, moving any of these CTS requirements to the Bases would not be an Administrative change This comment is also applicable to Unit 2.

BGE Hesponse:

DOC A.4 is revised to omit reference to Bases. Dese requirements are in Conditions and Surveillance Requirement (SR).

2 A.5 Unit 1: CTS Action f The proposed change is ne DOC should be revised to correct this acceptable. Ilowever, thejustification is misleading.

concern.

NUREG-1432 provides a period of time to restore fuel oil level, only. Inoperability of the fuel oil storage system for any other reason results in the associated DG being declared inoperable immediately. DOC A.5 gives the impression that a period of time is allowed to restore the fuel oil storage system to OPERABLE status, regardless of cause of the inoperability.

BGE Response:

DOC A.5 is revised to clarify the Improved Technical Specification (ITS) Condition is limited to a specific volume range.

3 L2 Unit 1: CTS Action f Hejustification makes an Absent this discussion, the proposed adequate case for deleting the CTS requirements relative changes associated with DOC L.2 are not to the volume of fuel oil. Ilowever, DOC L2 does not acceptable.

discuss why it is acceptable to delete CTS requirements associated with the flow path.

BGE Hesponse:

DOC L.2 is revised to also address the deletion of checking the flow path requirements.

4 L1 Unit 1: CTS Action f The Cis markup and DOC L1 He C7 markup should be revised to are confusing. He ITS reflects NUREG-1432 and is reflect what the ITS will be, and DOC L1 5

DCC = Discussion of Change JFD = Justification for Deviation DOD = Discussion of Deviation

l l

LTTACHMENT (1) i RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3 3.83 DOC-

. JFD CHANGE / DIFFERENCE

. COMMENT STATUS acceptable. De latter oart of DOC L1 addresses the less should also be revised to eliminate any restrictive aspects of adopting the NUREG requirements confusion.

regarding fuel volume, particulates, and new fuel quality, and is also acceptable. Ilowever, the CIS markup and the first half (approx) of DOC L1 address something totally different.

BGE Response:

DOC L1 is revised to address the revised markup of Current Technical Specification (CTS) 3.8.1.1 Unit 1 Action f based on comments on the ITS Actions. See NUREG LCO comment #1 and its response.

5 A.6 Unit 1: CTS Action f De requirements ofCTS Action De pn> posed changes to the CTS are finclude a requirement to go to shutdown if the fuel oil acceptable, but thejustification must be storage system is not restored to OPERABLE status in changed to address the Less Restrictive the specified time frame. There is no intermediate step aspects.

as in the NUREG and ITS (declaring associated DG inoperable). Herefore, mos ing the shutdown requirements to the r.ssociated DG LCO results in a Less Restrictive change, not an Administrative change.

BGE Response:

There are three possibilities for the change in the way the condition is addressed in ITS from the way the condition is addressed in CTS 3.8.1.1 Unit 1 Action f.

DOC A.6 is only appropriate for those conditions such as uhere No. I A Fuel Oil Storage Tank (FOST) is totally unavailable: Cunent Technical Specification Action f would allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to requiring a shutdown, and 113 3.83 Condition F would require No. I A DG to be immediately declared inoperable whereupon ITS 3.8.1 would allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to requiring a shutdown. He intermediate step is only format and does not change the requirement fer the unit to be shutdown if the FOST is not restored within the 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . More restrictive and less restrictive possibilities are addressed in new DOC M.3 and revised DOC Lt.

6 A.5 Unit 1: CTS Action g De proposed change is ne DOC should be revised to correct this acceptable. Ilowever, thejustification is misleading.

concern.

NUREG-1432 provides a period of time to restore fuel oil level, only. Inoperability of the fuel oil storage system for any other reason results in the associated DG being declared inoperable immediately. DOC A.5 gives the impression that a period of time is allowed to restore the fuel oil storage system to OPERABLE status, I

l regardless of cause of the inoperability.

DCI = Discussion of Change 6

JFD = Justific.aion for Deviation tX)D = Discussion of Devi. tion

ATTACIDfENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECrlON 3.8.3 '

3.83 :

DOC-JFD CHANGE /DIITERENCE COMMINr STATUS 1 BGE Response:

See response to Comment #2 above.

7 L.2 Unit 1: CTS Action g Thejustification makes an Absent this discussion, the proposed adequate case for deleting the CTS requirements relative changes associated with DOC L.2 are not to the volume of fuel oil. Ilowever, DOC L.2 does not acceptable.

discuss why.., acceptable to delete CfS requirements associated with the flow path.

BGE Response:

L See response to Comment #3 above.

8 A.6 Unit 1: CTS Action g The requirements ofCIS Action f De proposed changes to the CTS are include a requirement to go to shutdown if the fuel oil acceptable, but thejustification must be storage system is not restored to OPERABLE status in changed to address the less Restrictive the specified time frame. Dere is no intermediate step aspects.

as in the NUREG and ITS (declaring associated DG inoperable). Therefore, moving the shutdown requirements to the associated DG LCO resuhs in a Less Restrictive change, not an Administrative change.

BGE Response:

See response to Comment #5 above.

i 9

L.2 Unit 1: CFS Action h Hejustification makes an Absent this discussion, the proposed adequate case for deleting the CTS requirements relative changes associated with DOC L.2 are not to the volume of fuel oil. Ilowever, DOC L.2 does not acceptable.

discuss why it is acceptable to delete CTS requirements l

associated with the flow path.

BGE Response:

De markup of CTS 3.8.1.1 Unit i Action h is revised such that DOC L.2 is no longer applicable. This flow path check is now addressed in DOC LA3 and is considered as part ofITS 3.83 Condition B as explained in the Bases for Condition B.

I 10 LA3 Unit 1: CTS Action h The staffdoes not understand -

The licensee should review this DOC in this DOC. De DOC indicates that the material is being light of, the proposed ITS with the intent to moved to plant procedures, but the ITS do not include revise the DOC as appropnate.

i DOC = Discussion ofChange 7

JFD = justification for Deviation DOD = Discussion of Deviation

}

A'ITACIIMENT (1) l l

RESPONSES TO REQUEST FOR ADDITIONAL INFORA5ATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8.3 3.83 DOC-JFD CHANGE / DIFFERENCE COMMENT STATUS any requirements for a pcunissives to align any specific DG to any specific fuel oil storage tank. In light of this, the staff questions how this CTS material could be used l

even ifit was to be included in plant procedures.

BGE Response:

DOC LA3 is revised to indicate this information is moved to the Bases. He requirement will be included in the Bases for the associated Required Action which diows credit for the fuel oil volume in an OPERABLE No. I 1 FO3T.

1I L1 Unit 1: Insert Action D DOC L.I does not address ne licensee should review the submittal anything that is included in proposed Action D.

and the DOCS for the purpose ofidentifying (or providing) the correct DOC for proposed Insert D.

BGE Response:

Action D is revised and addressed by new DOC M.4.

12 L.5 Unit 1: SR 3.83.1 He proposed deletion of the U1s ne DOC should address what staggmd requirement to conduct SRs on a Staggered Test basis is testing means, the absence of safety impact acceptable. Ilowever, DOC L.5 could be improved.

if it is deleted, and any generic studies that i

may have been conducted on the subject.

BGE Response:

DOC L.5 is revised to provide an enhanced discussion.

13 A.4 Unit 1: CTS LCO 3.8.1.2.b.2 Moving these CTS Re licensee should consider revising this requirements to SR is acceptable and constitutes an DOC to delete reference to the Bases.

Administrative change. Ilowever, thejustification indicates some material may be moved to the Bases.

His is/would not be acceptable. In addition, moving any of these CTS requirements to the Bases would not be an Administrative change.

BGE Response:

See response to Comment #1 above.

8 DGC = Discussion of Change JrD = Justification for Deviation DoD = Discussion of Deviation

~.

'l ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL'INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8.3

-3.83

! DOC?

iJFD CHANGE /DifTERENCE COMMENT

?STATUSE l

14 -

M3-Unit 1: CIS Action b De CT3 Action addresses His is confusing, and the CIS markup is inoperability or the No.1I fuel tank and requires also confusing. The licensee should review,

demonstrating the OPERABILITY of the No. 21 fuel this part of the markup with a view towards tank. The DOC addressees adding a restoration eliminatingconfusian.

statement for the No. 21 fuel tank, but the No. 21 fuel tank is not the cause of being in the Action.

BGE Response:

Current Technical Specification 3.8.1.2 Unit 1 Action b markup revised such that DOC M3 is no longer applicable. De change to Action b is now addressed in ~

revised DOC Lt.

15 LA3 Unit 1: CTS Action b.2 and c.2 The staffdoes not The licensee should review this DOC in -

undmi.ud this DOC. The DOC indicates that the light of, the proposed ITS with the intent to material is being moved to plant procedures, but the ITS revise the DOC as appropriate.

do not include any requirements for a permissives to j

align any specific DG to any specific fuel oil storage tank. In light of this, the staffquestions how this CTS niaterial could be used even ifit was to be included in i

plant procedures.

BGE Response:

See response to Comment #10 above.

16 LA.1 Unit 1: CTS Action c and d (Also applies to LCO Justification LA.1 should be revised 3.8.2) Relocation of the CTS requirements regarding accordingly.

j movem:nt of heavy loads from TS is acceptable.

llowever, thejustification required additional work.

Specifically, endorsement ofNUREG-1432 means that movement of heavy loads will be conducted in a manner that will preclude dropping of the load on irradiate fuel.

The statement injustification LA.2 that heavy loads are not initiators of any event is not entirely true - the fuel handling accident assumes an irradiated fuel assembly is dropped.

1 i

DOC = Discussion ofChange 9

JFD = Justification for Devission i

DOD = Ducussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3 3.83

' DOC-JFD.

CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

DOC LA.1 is revised to enhance thejustification and indicate the requirements will be included in the Updated Final Safety Analysis Report (UFSAR).

17 LA.2 Unit 1: CIS Footnote * (Also applies to LCO 3.8.2)

De licensee should provide more details re:

He proposal to move this footnote to the Bases is not this annotation.

acceptable. De footnote modifies the TS required action and, as such,is not oppuri te Bases material. He purpose of the Bases is to explain why something is in the TS, not to establish requirements. In this case, the Bases should explain what constitutes a safe, conservative position, but the permissive to establish a safe, conservative position prior to implementing the Required Actions must remain in TS.

De CTS markup includes another LA.2 annotation.

However, it is not clear wint ifany change this annotation is associate with.

BGE Response:

The purpose of the footnote is to ensure that the phrase "immediately suspend" is not taken literally so an eperator would not stop fuel movement with a bundle j

hanging on the refueling machine. He footnote allows the movement to put the bundle in a storage location. This infonnation is appropnate for the Baser, since the l

Bcses describes what "immediately suspend" means. The NUREG Bases already contain these words under ITS 3.8.2 Actions A.2.1 through A.4. This method is also l

used in other locations throughout the NUREG where fuel movement is an Applicable condition, e.g., NUREG 3.93.

I.

I8 A.4 Unit 2: LCO 3.83 Moving these CE requirements to De licensee should consider revising this SR is acceptable and constitutes an Administrat:ve DOC to delete reference to the Bases change. However, thejustification indicates some material may be moved to the Bases. His is/would not be acceptable. In addition, moving any of these CTS l

requirements to the Bases would not be an Administrative change.

BGE Response:

See response to Comment #1 above.

DCI= Discussion ofChange 10 JFD o Justification for Deviation DOD = Discussion of Deviation

ATTACHMFNT f t)

I RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION -

IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3 19 A.6, Unit 2 CTS Action f.1 A_6 comment The The proposed changes to the CTS are LA3, -

requirements of CTS Action finclude a requirement to acceptable, but thejustification must be L1 go to shutdown if the fuel oil storage system is not changed to address the Less Restnctive restored to OPERABLE status in the specified time aspects.

frame. 'Ihere is no intermediate step as in the NUREG and ITS (declaring asociated DG inoperable).

Therefore, moving the shutdown requirements to the associated DG LCO results in a less Restnctive change, not an Administrative change.

Unit 2: CTS Action f.1' LA3 comment-The staffdoes The licensee should review this DOC in not understand this DOC. The DOC indicates that the light of, the proposed ITS with the intent to -

material is being moved to plant procedures, but the ITS revise the DOC as appropriate.

do not include any requirements for a permissives to align any specific DG to any specific fuel oil storage

nk. In light of this, the staff questions how this CTS material could be used even ifit was to be included in plant procedures.

Unit 2: CTS Action f.1 L1 comment The CTS markup The CTS markup should be revised to and DOC L1 are confusing. The ITS reflects NUREG-reilect what the ITS will be, and DOC LI 1432 ami is acceptable. The latter part of DOC L1 should also be revised to eliminate any addresses the less restrictive aspects of adopting the confusion.

NUREG requirements regarding fuel volume, particulates, and new fuel quality, and is also r=@le.

Ilowever, the CTS markup and the first half (approx) of DOC L1 address something totally different.

19 L2 Unit 2: CTS Action f.1 L2 comment: Thejustification Absent this discussion, the proposed continued makes an adequate case for deleting the CIS changes associated with DOC L2 are not.

requirements relative to the volume of fuel oil. Ilowever, acceptable.

DOC L2 does not discuss why it is acceptable to delete CTS requirements associated with the flow path.

BGE Response:

j

1) See response to Comment #5 above.

Doc - Discussion ofchange 11

. JFD = Justification for Devistion LOD = Discussion of Deviation t

+

v

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION' IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.83 -

iSTAh35 3.83 =

DOC

JFD CHANGE /DifTERENCE.,

COMMENT

2) See response to Comment #10 above.

3) ; See response to Comment #4 above.

[

4) See response to Comment #9 above.

20

- A.5, Unit 2: CTS Action f.2 A.5 comment: The proposed De proposed changes to the CTS are A.6 change is acceptable. Ilowever, thejustification is acceptable, but thejustifcaten must be misleadia.g. NUREG-1432 provides a period of time to changed to address the Less Restnctive restore fuel oil level, only. Inoperability of the fuel oil aspects. -

storage system for any other reason results in the associated DG being declared inoperable immediately.

DOC A.5 gives the impression that a teriod of time is allow::d to restore the fuel oil storage system to OPERABLE status, regardless ofcause of the inoperability.

i Unit 2: CTS Action f.2 A.6 comment-Tne The proposed changes to the CTS are l requirements of CTS Action finclude a requirement to acceptable, but thejustification must be go to shutdown if the fuel oil storage system is not changed to address the less Restrictive restored to OPERABLE status in the specified time.

aspects.

frame. 'Ihere is no intermediate step as in the NUREG and ITS (declaring associated DG inoperable).

Therefore, moving the shutdown requirements to the associated DG LCO results in a Less Restrictive change, notan Administrativechange.

20 L1 Unit 2: CTS Action f.2 L.I comment: The C13 markup The C13 markup should be revised to :

continued and DOC L1 are confusing. De ITS reflects NUREG-reflect what the ITS will be, and DOC L1 1432 and is acceptable. He latter part of DOC L.1 should also be revised to elim~ mate any addresses the less restrictive aspects of adopting the confusion.

NUREG requirements regarding fuel volume, particulates, and new fuel quality, and is also acceptable.

rtDe-Discussion orchange 12 iro -Justmcation for Deviation DoD = Discussion ofIkviation

f ATTACHMZhT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3 L 3.83 1 DOC 4 1JFD.

CHANGE / DIFFERENCE :

COMMEbff L STA1US:

However, the CTS markup and the first half (approx) of DOC L address something totally difTerent.

i BGE Response:

1) See response to Comment #2 above.

2) See response to Comment #5 above.

3) See response to Comment #4 above.

21-J A.6, Unit 2: CTS Action g A.6 comment The requirements The proposed changes to the CTS are

LA2, cf CfS Action finclude a requirement to go to shutdown sccq4able, but thejustification must be L.2 if the fuel oil storage system is not restored to changed to address the less Restrictive -

OPERABLE strus in the specified time frame. There is aspects.

no intermediate step as in the NUREG and 115 (declaring associated DG inoperable). Therefore, moving the shutdown requirements to the associated DG -

LCO results in a less Restrictive change, not an Administrative change.

Unit 2: CTS Action g LA3 comment The staffdoes lhe licensee should review this DOC in not understand this DOC. The DOC indicates that the light of, the proposed ITS with the intent to material is being moved to plant procedures, but the ITS revise the DOC as 3 pupiste.

do not include any requirements for a permissives to align any specific DG to any specific fuel oil storage tank. In light of this, the staff questions how this CTS ma; rial could be used even ifit was to be included in plant wocedures.

Unit 2: rTS Action g L.2 comment Thejustification Absent this discussion, the proposed makes an adequate case for deleting the CTS changes associated with DOC L.2 are not requirements relative to the volume of fuel oil. However, acceptable.

DOC L.2 does not discuss why it is acceptable to delete CTS requirements associated with the flow path.

DOC = Discussion of Change 13 JFD = Justification for Devlation i

DOD = Discussion of Deviation

r ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3 BGE Response:

1) See response to Comment #5 above.

2) See response to Comment #10 above.

3) See response to Comment #9 above.

l 22 Unit 2: Insert Action D DOC L1 does not address De licensee should review the submittal anything that is included in proposed Action D.

and the DOCS for the purpose ofidentifying (or providing) the correct DOC for Insert D.

BGE Response:

See response to Comment #11 above.

23 L.5 Unit 2: SR 3.83.1 De proposed deletion of the CTS De DOC should address what staggered requirement to conduct SRs on a staggered test basis is testing means, the absence of safety impact acceptable. However, DOC L5 could be improved.

ifit is deleted, and any generic studies that -

may have been conducted on the subject.

BGE Response:

See response to Comment #12 above.

24 A.4 Unit 2: CTS LCO 3.8.1.2.b.2 Moving these CTS De licensee should consider revising this requiren.ents to SR is acceptable and constitutes an DOC to delete reference to the Bases.

Administrative change. Ilowever, thejustification indicates some material may be moved to the Bases.

3 His is/would not be acceptable. In addition, moving any of these CTS requirements to the Bases would not be an Administrative change.

BGE Response:

See response to Comment #1 above.

25 M3 Unit 2: CTS Actien b The CTS Action addresses His is confusing, and the CTS markup is inoperability or the No.1 I fuel tank and requires also confusing. He licensee should review t

demonstrating the OPERABILflY of the No. 21 fuel this part of the markup with a view to wanis tank. He DOC addressees adding a restoration eliminating confusion.

statement for the No. 21 fuel tank, but the No. 21 fuel tank is not the cause of being in the Action.

doc = Discussion of Change 14 Ji D = Justification fo. Deviation EDD = Discussi m ofIktiation

A*ITACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION.

' IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3 :

8 BGE Response:

See response to Comment #14 above.

26 LA3 Unit 2: CTS Action b.2 and c.2 The staffdoes not ne licensee should review this DOC in i

understand this DOC. De DOC indicates that the light of, the proposed ITS with the intert to reaterial is being moved to plant procedures, but the ITS revise the DOC as prupiste.

do not include any requirements for a permissives to align any specific DG to any specific fuel oil storage tank. In light of this, the stafTquestions how this CTS material could be used even ifit was to be included m plant procedures.

BGE Response:

See response to Comment #10 above.

27 LA.1 Unit 2: CTS Action c (Also applies to LCO 3.83)

Justification LA.I should be revised Relocation of the CTS requirements regarding movement accordingly.

of heavy loads from TS is acceptable. However, the justification required additional work. Specifically, endorsement ofNUREG-1432 means that movement of '

heavy loads will be conducted in a manner that will preclude dropning of the load on irradiate fuel. He statement injustification LA.2 that heavy loads are not initiators of any event is not entirely true - the fuel handling accident assumes an irradiated fuel assembly is dropped.

BGE Response:

See response to Comment #16 above.

DOC = Discussion of Change 15 JFD = Justification for Deviation DOD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION i

IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ffEM DOC /

' CIS/ SIS DESCRIPTION OFISSUE

' DAY DATE COMMENTS i

^

NO.

JFD.

LCO. -

OPENEL CLOSED 3.6.6-1 A.I CTS 4.6.2.1.

CTS 4.6.2.1.a.1 and CTS 4.6.2.1.b.1 specify the 5/16/97 Provide additionaldiscussion and LA.4 a.1 Containment Spray System alignment for various justification forthese less

'l CTS 4.6.2.1.b.1 test signals. LA.4 justifies the relocation of the test Restrictive (LA)and signals to the ITS Bases B3.6.6. The alignment Administrative changes.

characteristics are deleted with nojustification and replaced with the words " activates to the correct position." This change is designated A.I. A 1 is a general reformattingjustification, and is the incorrectjustification C

'.s change. The deleted alignment requirem.,+ Amid be relocated to the ITS Bases B3.6.7 Ci a Restrictive (LA) change) and the replacemem wordsjustified i

(Administrative change).

CCNPP Response:

DOC A.6 will be provided tojustify the replacement of the alignment requirements ofCIS 4.6.2.1.a.1 with the phrase,"in the correct position." DOC A.7 will be provided to justify the deletion ofCTS 4.6.2.1.b.1 from ITS 3.6.6.

3.6.6-2 A.5 CTS 4.6.2.1.a.1 CTS 4.6.2.1.a.1,4.6.2.1.b.1,4.6.2.1.c.1,4.6.2.1.c.2 5/16/97 Provide additionaldiscussion and CTS and 4.6.2.2.b require that valves actuate to their justification to include the 4.6.2.1.c.

correct position and that the containment spray Containment Cooling Sptem.

CTS 4.6.2.1.b.1 pump starts on specific test signals. While this CTS 4.6.2.1.c.2 statement may be for the Containment Spray CTS 4.6.2.2.b System, CTS 4.6 ? ? b deals with the Containment Cooling System. The Containment Cooling System according to the ITS Bases and the CIS is an entirely different system not connected to the Containment Spray System.

CCNPP Response:

DOC A.5 will be revised to address the containment cooling system.

Dec-Discussion of change 16 JFD = Justification for Deviation DOD = Discussion of Devistion

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM DOC /

CTS /STS

~ DESCRIPT10N OF ISSUE DATE-DATE COMMENTS NO.

JFD-LCO OPENED CLOSED 3.6.6-3 M.1 -

CTS 4.6.2.1.a.1 Amendments 218 for Unit I and 195 for Unit 2 5/1667 Provide additionaldiscussion and L4 CTS 4.6.2.1.b.1 rearranged CTS 4.6.2.1.a.1, justification for this Administratne 4.6.2.1.A.2, 4.6.2.1.B.1 change.

4.6.2.1.b.2 and 4.6.2.1.c.2, to 4.6.2.1.b.1, 4.6.2.1.a.1,4.6.2.1.c.1,4.6.2.1.c, and 4.6.2.1.d respec:ively. ITS SR 3.6.6.1 requires verification that each containment spray manual, power-operated, and automatic valve in the flowpath that is not locked, sealed, or otherwise secured in position is in the correct position. M.1 states that CTS 3.6.2.1 does not contain this requirement. The staff has determined that ITS SR 3.6.6.1 is encompassed by the new CTS 4.6.2.1.a.l. Thus this part of thejustification is an Administrative change.

CCNPP Response:

DOC M.] will be revired to delete the reference to ITS SR 3.6.6.1, and the CTS will be marked to reflect retcution of the requirements as CTS requirements.

3.6.6-4 M.4 CTS 3.6.2.2 ITS 3.6.6 ACTION A and C contains a limit on the 5/16 S'1 Provide additionaldiscussion and ACTION a total combined duration ofoperation for one justification for this Less ITS 3.6.6 containment spray train (ACITON A) and one Restnctive change.

AC110N c containment cooling train (ACTION C) inoperable of 10 days from discovery or failure to meet LCO.

This will prevent continuous operation in a degraded condition by entering the twa Actions repeatedly. M.4 states that CTS 3.6.2.1 and 3.6.2.2 do not contain this limitation. However, CTS 3.6.2.2 does have this limitation associated with it when one containment spray system is inoperable.

CIS 3.6.2.2 ACIlON c, requires 7 days from iiJtial loss to restore the systems. Thus the change Doc = Discussion orchange 17 JrD = Justification for Deviation DOD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.6 ITEM COC/ -

CTS /STS DESCRIPTION OFISSUE DATE DATE COMMENTS P

NO.

JFD

- ICO OPENED CLOSED for CTS 3.6.2.2 is Less Restrictive not More Restrictive (7 days to 10 days).

CCNPP Response:

' In the event one group of required contairsment air recirculation and cooling units is inoperable and one containment spray system is inoperable concurrently, Action c of CTS 3.6.2.2 require 3 the Inopecable containment spray system to be restored to an Operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and the inoperable group ofcontainment air recirculation and cooling units to be restwed to an Operable status within seven days ofinitial loss. Action A and C ofITS 3.6.6 would be entered concurrently ifone train of the containment cooling system is inoperable and one containment spray system is inoperable concurrently. Rese actions require the cmtainment spray train to be restored to an Operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and the containment cooling train to be restored to an Operable status within seven days. Rese requirements are equivalent to Action C of CTS 3.6.2.2. In addition to these requirements, Actions A and C ofITS 3.6.6 possess a second completion time of"10 days from discovery to meet the LCO." n prevents attemating between Actions A and B indefinitely without ever fully restoring systems to meet the LCO. De purpose of this second completion time is to prevent a contim ous non-compliance with TTS LCO 3.6.6 from existing for an unlimited time period. Example 13-3 def mes how this second con:p:etion time is to be utilized. Action c of CTS 3.6.2.2 does not possess an equivalent requirement (does not address attematmg inoperabilities of tra' s); it m

addresses the inoperability of a single train of containment spray and a single train ofcontainment cooling. Hus, the addition of the second completion time is a more restrictive change.

3.6.6-5 LA3 CTS t.6.2.2.a.

CTS Surveillance Requirement 4.6.2.2.a3 requires 5/16/97 Provide a description of the plant 3

verifying cooling water flow when the flow service procedure to which the water flow ITS SR water outlet valves are fully open. ITS SR 3.6.63 requirement is relocate d and the 3.6.63 requires verifying the flow rate, but does not change control process forthis specify valve position. This requirement is moved procedure.

to piant procedures, placing t outside of the Technical Specifications inte Licensee controlled documents, resulting in a less Restrictive technical change.

CCNPP Response:

DOC LA3 will be revised to state that the details are being moved to the Bases, and apprcyriate changes will be provide-3.6.6-6 L1 CTS 3.6.2.1 CTS 3.6.2.1 ACTION requires the plant in MODE 5/16/97 Modify the Completion Time for ACT10N 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within t' following ITS 3.6.6 RA Bl1 to reflect the STS 3.6.6 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months when the Required Actions and associated actualtime needed to exit the ACflON B Completion Times cannot be met. STS 3.6.6 APPLICABILITY. Provide i

l CCC = Discussion of Change 18 l

JFD = hst.fication for Devistion DOD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INEDRMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 '

ITEM DOC /

CTS /STS DESCRIPTION OFISSUE-)

DATE-

?DATE; COMMENTS NO.;

JFD LLCOL OPENED CLOSED ITS 3.6.6 ACTION B requires that the plant be in MODE 5 additional discussion and..

ACTION B and within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . ITS 3.6.6 ACTION B requires justification forthis More/less Associated Bases that the plant be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in Restnctive change.

MODE 3 with pressurizer pie== < 1750 psia within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The STS Completion Times for RA B.2 was based on the APPLICABILITY being i

MODES 1 through 4. Since CCNPP's APPLICABILTIY only goes to MODE 3 with pressurizer pressure < 1750 psia, the Completion Times in the CTS (36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to MODE 5) and ITS (84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months to MODE 5) should be modified accordingly. This change may be More Restrictive or Less Restrictive depending on the Completion Time.

CCNPP Response:

Completion times will be revised to reflect the time needed to exit the applicable modes, end to be consistent v ith ITS 3.5.2.

3.6.6-7 L4 CTS 4.6.2.1.a.1 CTS Surveillance Requirements 4.6.2.1.a.1 and S/16/97 Provide additional dku.m'or.

s CTS 4.6.2.1.b.1 4.6.2.1.b.1 require verification that the justification and appropriate ITS Containment Spray system (including RAS) valves marked up CIS pages forthis SR 3.6.6.5 and pumps to perform (actuate to the correct Administrative /Less Restrictive ITS SR posiSon and start, respectively) as required on an change.

3.6.6.6 actuation signal once per 31 days and once per 92 days respectively. ITS SRs 3.6.6.5 and 3.6.6.6 require the test to be performed once per 24 4

months. ITS SRs 3.6.6.5 and 3.6.6.6 decrease th -

Frequency from 31 days and 92 days to 24 months.

Although the surveillance frequency is being.

decreased, verification that the valves actuate and pumps start when required will stm be performed i

in conjunction wi+h the ESFAS subgroup relay tests Doc-Discussion ofchange 19 JFD = Justification for Deviation DOD = Discussion of Deviation

ATTACHMENT (1) 1 RESPONSES TO REQUEST FOR ADDITIONAL IN'cORMATION l'

IMPROVED TECHNICAL SPECIFmCATIONS EC110N 3.6 i

ITEM DOC /

CTS /STS DESCRIPI'ON OF ISSUE

DATEf DATC COMMENTS L NO.

.- JFD LCO OPEN';D CLOSED which require end device actua: ion every 92 days.

Justification L.4 does not state where this test is located. Ifit is located in ITS 33 then this portion of the change is an administrative change. Ifit is located in plant procedures or other heensee controlled document then it is a less restrictive (LA) change.

CCNPP Response:

CTS 4.6.2.1.a.1 has been retained as ITS 3.6.6.1 (see response to NRC question 3.6.6-3). CTS 4.6.2.1.b.1 has been deleted. Justification for the change is provided as DOC A.7 for ITS 3.6.6. As a result of these two changes, DOC L4 for ITS 3.6.6 and its associated No Significant Hazards Considerations will be deleted, because they will no longer be appropriate.

3.6.6-8 JFD 6 IFS 3.6.6 JFD 6 states that a Note 5 has been added to ITS 5/16/97 Correct this dihy-cy ACTIONS 3.6.6 ACTIONS. ITS 3.6.6 ACTIONS show only Note one Note being added. There is no Note 5.

CCNPP Response:

JFD 8 will be revised to resolve the discrepancy.

3.6.6-9 BASES ITS B3.6.6 ITS B3.6.6 Bases-BACKGROUND " Containment 5/16/97 Delete this change.

JFD 8 Bases-Spray System" section second paragraph, i:rst BACKGROUND sentence changes the word " reduce" to " minimize."

'Ihis change was reviewed by the stafTas part of EDIT-18 ar.d rejected based on tiie fact that it was a technical change with insufficientjustification.

CCNPP Response:

This change will be removed.

3.6.6-10 None ITS B3.6.6 ITS B3.6.6 Bases-BACKGROUND " Containment 5/16/97 Provide a discussion and Bases-Spray System" section second paragraph, first justification forthese deletions.

1 BACKGROUND sentence and third paragraph deletes all reference to Spray Additive System. Nojustification is DCC = Discussion ofChange 20 JFD = Justification for Deviation ED3 - Discussion of Deviation

ATTACHWAT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM -

DOC /

CfS/ SIS DESCRIP110N OFISSUE'-

~b DA'IE -

1DATE7 COMMENTS NO.

-JFD:

eLCO-OPENED CLOSED provided in this secten for these deletions.

CCNPP Response:

JFD 8 will be provided for the justification.

b P

DOC = Discussion of Change 21 JFD -Justification for Deviation DOD = Discussion of Deviation T

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INTORMATION -

IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM DOC /

CTS /STS T DESCRIPTION OFISSUE.

. DATE --

DATE' COMMENTS NO.

tJFD :

LCO

. OPENED.

CLOSED >

3/4.6.6.1-1 None CIS CTS 3/4.6.6.1 is being moved 5/16/97 Provide a discussion andjustifx:stion for this Administrative 3/4.6.6.1 to ITS 3.7.12 Penetrath change.

Room Exhaust Ventilation System. Nojustification has been provided for this Administrative change.

CCNPP Response:

Movement of requirements from one specification to another only requires ajustification in the specification to which it is being moved. In this case, nojustifx:ation is provided in the 3.6 Section, but it is provided as part ofITS 3.7.12.

l DOC = Discussion of Change 22 JFD = Justification for Deviation DOD = Discussion of Deviation

ATTACHMENT (21 -

IMPROVED TECHNICAL SPECIFICATIONS, REVISION 10

SUMMARY

OF CIIANGES 1

Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Novemt er 5,19'7

1 A'ITACHMENT (2)

SUMMARY

OF CIIANGES 1.

Section 3.8.3 was substantially rewritten. The primary changes were: 1) The addition of additional detail describing our diesel generator (DG) fuel oil system; 2) Putting back the seasonal dependent criteria for the Nos. 21 and 11 fuel oil storage tanks (FOSTs); 3) Making No.

21 FOST the only FOST in the Limiting Condition for Operation for Nos. IB,2A, and 28 DGs, througn No.1I FOST is used in the Actions; and 4) Putting in seven day and six day limits for the FOSTs.

2.

De Current Technical Specification 3.1.1.2.b SIIUTDOWN MARGIN Actions regarding when the pressurizer is drained were retained and placed in Improved Technical Specification (ITS) format. Discussion of Change (DOC) L.2 and associated No Significant 11azards Considerations were not used.

3.

A clarifying statement was added regarding the reduced reactor trip setpoint formula in the Bases for ITS 3.7.1.

4.

Clarifying statemer,ts regarding references for fuel oil analysis were added for ITS 5.5.13 and

.lustification for Deviation 25 was revised.

5.

The term " gross specific activity" was changed to " gross activity" in ITS 3.4.15. The clause restricting the cumulatisc amount of time the unit may remain in Action A is removed, and DOC L.5 and associated No Significant IIazards Considerations are added.

6.

A statement in ITS 3.5.4 Bases regarding when control element assemblies are credited after a loss-of coolant accident was clarified.

7.

Clarifying statements were added to ITS 3.7.9 DOC L.2 and ITS 3.7.11 DOC L.3.

l l

1

ATTACHMENT (3)

IMPROVED TECIINICAL SPECIFICATIONS, REVISION 10 AMENDMENT REVISION BY CHANGE i

l l

l I

Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 5,1997 l

1..

> Section 3,8.3 was substantially rewritten. He primary changes wera: 'l) He addition of additional. detail describing our diesel generator (DG) fuel oil system; 2) Putting back the

. seasonal dependent criteria for the Nos 21 cnd 11 fuel oil storage tanks (FOSTs); 3) Making No.'

i 21 FOST the only FOST in the Limiting Condition for Operation for Nos._IB,2A, and 2B DGs, through No.11 FOST is used in the Actions; and 4) Putting in seven day and six day limits for the FOSTs.

4 w

w 4

v t e Letter Sequence Other
TAC:M97363, TSTF-19, TSTF-88, TSTF-64 (Approved, Closed) TAC:M97364, TSTF-19, TSTF-88, TSTF-64 (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance... Administration Meeting Questions 29 May 1997 6 June 1997 11 June 1997 16 May 1997 22 October 1997 Answers 5 December 2003 27 March 1997 Results Approval Other: ML20140H545, ML20141B944, ML20198K326, ML20198R718, ML20210K953, ML20210M679, ML20217G338, ML20217G370, ML20217K605
MONTHYEAR1997-06-11 [Table View]

ML20198R718

Text

REFERENCE:

-

SUMMARY

SUMMARY

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