Text

Proposed Tech Specs Pages Re Rev 10 to Convert to Improved TS
	ML20198R733
Person / Time
Site:	Calvert Cliffs
Issue date:	11/05/1997
From:	; BALTIMORE GAS & ELECTRIC CO.
To:	;
Shared Package
ML20198R723	List: ML20198R718; ML20198R733;
References
	NUDOCS 9711130375
	Download: ML20198R733 (195)
	v • d • e

{{#Wiki_filter:._ Diesel Fual Oil B 3.8.3 B 3.8 ELECTRICAL POWER' SYSTEMS B 3.8.3. Diesel Fuel Oil 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 - 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. 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 2B, are fueled from two fuel oil storage tanks (FOSTs), i.e., FOST 11 and FOST 21, and DG 1A is fueled from FOST 1A. FOST 1A and F0ST 21 are enclosed such as.to be considered " tornado p;otected' but F0ST 11 is not protected. As such, F0ST 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 fuel oil it contains becomes degraded. The operability of FOST Nos. 21 and 11 ensure that at least 7 days of fuel oil-will L; reserved below the internal tank standpipes fe operation Li one DG on 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 CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-1 Revisionp/o E O N !17 P PDR

l l Diesel Fr 4 iil L 4.a.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 fueloilstoragetank(tornado /missileevent),atleast 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 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. APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter-6 (Ref. 2), and in the UFSAR, Chapter 14 (Ref. 3), assume Engineered Safety 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 op2 ration of the ttandby AC power sources, they satisfy 10 CFR 50.36(c)(2)(11), Criterion 3. I I LCO FOST 1h 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,B.3-2 Revision /so

Diesel Fuel Oil B 3.8.3 BASES quality. 1his 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 operationaloccurrence(A00)orapostulatedDBAwithloss 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 LC0 3.8.2) are required to ensure 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 on1v DG 1A. For Unit 1, the FOST 21 associated DGs are DG 1B and DG 28. For Unit 2, the FOST 21 associated DGs are DG 2A and DG 28. Alignment does not affect the association of 10 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 separate Condition entry is allowed for each DG. This is acceptable, s!nce 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. i l L CALVERT CLIFFS - UNITS 1 & 2 8 3.8.3-3 Revision A'/o

Diesel Fuel Oil B 3.8.3 BASES A.1. 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 6/7 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 feet 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 hours is considered sufficient to complete restoration of the required level prior to io declaring the DG inoperable. This period is acceptable basedontheremainingcapacity(approximately6 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 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 (CREYS). Condition B 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 1 and Unit 2 equipment, but Condition B is written for Unit 1 only to reflect the Unit I requirements for DGs 1B and 2B. For an accident, Unit I requires either DG 1A or both DGs 1B 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 the redundant required equipment CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-4 Revision y fo

Diesel Fuel Oil B 3.8.3 BASES is powered by DGs 18 and 28 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 fu-1 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 hour. The Completion Time of 1 hour 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 it 85,000 gallons within 48 hours. 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 to 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 F0ST 11 above the 33,000 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 F0ST 21.which is " tornado 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 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 Doth DGs IA and 2A (since DG 1A powers equipment which is redundant to CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-5 RevisionA/ci

~ Diesel Fuel Oil B 3.8.3 i BASES someequipmentpoweredbyDG2B,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 DGs 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 F0ST 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 I 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 48 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 hour. Required Action C.3 then requires the volume of FOST 21 to be restored to within volume limits within 48 hours. 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 hours 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 H0DE 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. E.d This Condition is entered as a result of a failure to meet the acceptance criterion of SR 3.8.3.2. Normally, trending of particulate levels allows sufficient time to correct high /o particulate levels prior to reaching the limit of l - CALVERT CLIFFS - UNITS-1 & 2 B 3.8.3-6 Revision F M l l ,-y. e-p..,, 3 .w -e r-, r n w

r m-

-e + v+ y m. e-v c.o -e a- --w-.,. ~,----n-e--e - ' = ~:~~

Diesel Fuel Oil B 3.8.3 l i l , BASES I acceptability. Poor sample procedures (bottom sampling), i contaminated sampling equipment, and errors in laboratory analysis can produce failures that do not follow a trend. Since the presence of particulates does not mean failure of the fuel oil to burn properly in the dieal engine, and particulate concentration is unlikely to change i significantly between Sur"eillence Frequency intervals, and l 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 allors for further evaluation, resampling, and re-analysis of the DG fuel oil. 10 Ld 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. L1 lci 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 Le imediately declared CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-7 Revision 9'/o

i Diesel fuel Oil 8 3.8.3 i BASES t inoperable. " Associated DG(s)" are identified in the p Applicability Bases, j 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 e place the unit in a safe shutdown condition and to bring in replenishment fuel from an offsite location. The 31 day frequency is adequate 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. 4 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 ininediate, 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, anu 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 4/o ~ a

Diesel Fuel Oil B 3.8.3 BASES b. Verify in accordance with the.ests specified in ASTMD975-1996(Ref.4)thatthesamplehasanabsolutelI# specific gravity at 60/60'F of 2 0.8155 and s 0.8871, or an American Petroleum Institute gravity at 60*F of k 28' and s 42', a kinematic viscosity at 40*C of 21.9 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 (ASTMD975-1996). 10 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, the fuel oil is analyzed to establish that the other properties specified in Table 1 of ASTM D975-1996 (Ref. 5) 10 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 immediate 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 gravimetric analysis (based on ASTM D2276-1989) 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 IB, 2A, and 28 is contained in two interconnected tanks, each tank must CALVERT CLIFFS - UNITS 1 & 2 B 3.8.3-9 Revision h/o i

~. Diesel fuel 011 B 3.8.3 BASES 4. ASTM Standards: D4057-1995; D975-1996 l# 5. ASTM Standards, D975, Table 1 6.. Regulatory Guide 1.137 CALVERT CLIFFS - UNITS 1 & 2 8 3.8.3 Revisiong/o ?

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4/4:4-ELECTRICAL NhfEp $Y$ TEM 5 __ F {$ ] E.9 3 -=-m-. M TAa_ i 4Ws n/ faa/ o,'/.1/r// 6e ar$n IMo,n s ,,p,a,sa,J,wf, Qs), LIMITING CONDITION FOR OPttATION - ^^$7 / ^ e.e.:.-- e : 295. :t; :.L.

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---.;- ; h:1 te L C 0 Lt.'& 488AA865e (a. Two physically independent circuits between the offsite 1 transmission network and the onsite Clan IE Of stribution System consisting of either: 1. Two 500 kV offsite power circuits, or as necessary

2. The 69 kV SMECO offsite power circuit described in the dj [\\

i January 14. 1977 Safety tvaluation and one 500 kV offsite 4 power circuits ( : and '. c* .Two sepalate and independent die'sel generators with: l j Separate fuel oil day tanks containing a sinfaum volume ofi(l 3 4.*" 1. { s <.j ? a. 326 gallons for No.1A Emergency Diesel Generator, and 27$ callons for No. IB Emeroency Diesel Generator. o +[ l-Fuel Oil Storage Tanks containing a minimum volume of: 4 N a. 49.f00 gallons for No.1A Fuel Oil Storage Tank, and M3.0p0'h11on346r No.1 #u'el Oil pdNge % and ) [85.000callent for Nae n ru.1 nn tearane Tank. and; hq. A <anarete fuel transfer pump for each diesel generator] APPLICABILITY: : Z

nL' -

f.CllQ!is [k With two offsite circuits of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the u remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per 8 hours thereafter: and 4.8.1.1.2.a.4 within 24 hours unless the Qie_sc1generatorsarealresdveneratino, Restore at I*att two CALVERT C1.lFFS - UNIT 1 3/4 8-1 Amendment No. 214 1 lQ

hac'ihcAMcm3I.3 i [{ { 3/4.8 ILtCTRICAL POWER $YSTEMS y!TINGCONDITIONFOROPERATION(Continued) "A C, S oarsn - 4p ert iq (2 hours or er in at least NOT $ TAN 08Y within the next 6 hours andI in COLD $NUTDOWN within the following 30 hours. Restore at least 4'l two diesel generators to OPERABLF. status within 72 hours from time of initial loss or be in at least NOT $1AND8Y within the Lnext 6 hours and in COLD $NUTDOWN within the followins 30 hours. ) A

f. With the No.1A fuel 011 Storage Tankdnoperable.]ilemonstrate the C10 Acteous

'UFERABILuv ci sne remaining A.U. sources Oy Perromi.ig Surveillance Requirement 4.8.1.1.1.s within one hour and at least once per 8 hours thereafter, and by performing Surveillance A,E 4 F Requirement 4.8.1 1.2.a.a on me. in r-.re.arv ni...i r..rator J/ ' within 24 hours.l emonstrate he OPERAS ITY of e No. 21 el 1 W orage Ta ~ by perfo g Sury' ell nce Re rament 4 .1.1.2.a. verifying 0l000 gall s) and rif In

flowJl, theNo.gt i

ath from e No. 21 F 1 Stor e Tank _ rgen Diesel stor with I hour.1 Astore No. IA fuei. ~ [Ull Storage Tant _ Ge to UFEMELE status within@hourspr se m aT) 1 east nus >Imusi wiUdu ihs u n 0 hu m ano in LutD 111HTDonal A within the followino 30 hours.f g'g With the Nos. (11 and)21 Fuel 011 Storace "anks finonerable.1bel g. ' demonstrate tne urt.uBILHT of the remain' ng A.C. sources by~ perfoming Surveillance Requirement 4.8.1.1.1.a within one hour /l.5 M ct:005 and at least once rar 8 hours thereafter, and by )erforming Surveillance Requirement 4.8.1.1.2.8.4 on No. lA meroency Diese S s/F 1 Generator within 24 hoursa Demonstrate the OrtRAIILITY of the 3 I lo. IA f uel 011 Storage Tank by perforining Surveillance Requirement 4.8.1.1.2.a.I (verifying 49,500 gallons) and l verifying the flow path from the No. IA fuel 011 Storese Tank to J * /,/ t_he No. IA Emeroency Diese' Generator within I hour 1 Restore Cwithin 72 hourspr peln a6efTher No. ll or_21_f uel O'l Storage Tanks to OPfdtABLE s g,3 nus alMusT witnin tne nen) .m6 (b hours _end_in COLD SHUTDOWN within the following 30 hoursd% h. Withleitherlihe No.111 or}21 Fuel Oil Storage Tank (iloserab1h Scftdal O (demonstrate the OPERABILITY oT the other tuei vii Storage Tanu [l lby: 1) perfomina Surveillance Requirement 4.8.1.1.2.a.E ~Iyer1 Tying 85.000 gallons) within 1 hour )and at least once perj ~ .J [8 hours Entrealter;Jand 2) veritying tne rio, patn"irom tne, operable twel 01F5torage Iank to the No. IB Emercency Diese1N tGenerator within I hour.J p,3 3 /M TtMERT Acrou) D CALVERT CLIFFS - UNIT 1 3/4 8 3 Amendrmit No. 214

INSERT fl 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. 9 8 4 l P se 4 d 11

5 5pM.~ 34,3 3 w-CS g) 3/4.8 ELatfalcAL peute systets setVIILLANCE ttqWitOENTS (Caettened) M . it least pselst b r ur .itt 3.41.1. (At a sample e"f elesaq-fuel f a the acceptar e Ilmits specif' in Table 1 of 7 e yaset checked fg viseestty," _ g 343 matarA sedtsent._I r 320suends.sLi;;"d;;ii re MJ' ram Ta"He" srii%'I'"""" ) i d. At i.ast e,er nemtim immt by:

3. Subjecting the diesel to an inspection in accordance with precedures prepared in conjunction with its.:anufacturer's receanendations for this class of standby service.

2. Vertfying the generator ca a 500 hp without tripping.pability to reject a load of 3. $1mulatty a loss of offstte power in conjunction with a safety injection actuetten test signal, and: a) Verifyihg de.energisction of the emergency busses and load shedding from the emergency busses. b) Verifying the diesel starts free ambient condition on the auto. start stenal energines the emergency busses with - pennenently connected loads. snetstats the auto-connected r emergency loeds through tte lead sequencer and operates for g 5 minutes wh 1 emergency loads.' ile its generator is loaded with the ' c) Verifying that automatically bypassed diesel trips are automatically bypassed on a Safety injection Actotton Signal. 4 Vertfying the diesel generator operates for 160 minutes I i while loaded to > 4000 kW for No.1A Emergency Diesel Generator or a 2700 kW for No. It Emergency Olesel Generator. 5. Verifying that the auto-connected loads to each diesel - generator do not exceed 4000 kW for No.1A Emergency Diesel Generator or 2700 kW 'or No.1B Emergency Olesel Generator. All engine starts for the purpose of this Surveillance Requirement may be preceded by an engine pre. lube period recommended by the manufacturer so that mechanical wear and stress on the diesel engine is minimized. o s u D eco,3,.s,r A. A p spee /ic.4.* 3 5.1, 'A.c, Cwse.. op.J,g 4 CALVERT CLIFF $ - UNIT 1. 3/4 8 5 Amendment No. 214 1 p,y 6 of Il b 1 ..-.,_.,,-._.,:,.~ .,,,._-.,,.._.-,-..,v,.

S & f'"$ *< 3.s.y \\ 3,g g aternICAL Paura SYSTD S 4/4,4,4 A.C. 100RCEI

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%.Au4m 3.t.t, " AL p. sW4Jn4al' LINETIst COMITIN P9A SPERATIN w 3.8.1.2 As a minimum, the following A.C. electrical power cources shall be OPERABLI:

a. One circuit between the offsite transmission network and the onsite Class IE Distributton System, and 6.

One diesel generator. withe

1. A fuel oil day tank containing a minimum volume of

a. 325 gallons for No. IA Emergency Diesel Generators or b.

275 sellons for No.19 Emeroency Diesel teneratort and A twel 0115tbrage zystem containing a minimum volume of T No.1A ballons in No.lA Fuel 011 Storage Tank for the 49.500 a. rgency Diesel Generators or : M b. I 85.000 callons in No. 21 Fuel 011 Storese TankranO3J05h A (,.(no.Tonsan sname. ILJeri giLmeraam mrifpr the,- DH J il yo as,ese G w y piessi venerator, and, m ,3 m. (s. A ruel transfer pumpM 3 Ahme.Pahtlfty. "^"# 2 J f I 43

a. With less than the above minimum requirea A.c. electrical pow'e sources OPERABLE:

l 1. lunediately* suspend all operations involving CORE ALTERATIM5 positive reactivity changes. movement of irradiated fuel and movement of heavy loads over irradlated fuel, and 2. Inmediately initiate corrective actions to restore the I minimum A.C. electrical busses to OPERABLE status, and ( estabitsh a safe conservative position.Perfonnance of ACTIM a. shall not preclude CALVERT C.FFS. UNIT 1 3/4 8 6 Amendment No. 214 .t ey 8 af Il b

S ten!ca.Ocm SI,3 P fee E scussim d k es 4 s st@icab hf.2 3/4,3 ggggggteg e 3 LIMITING CONDITION FOR OPERATI0h (Continued) 3.F All containment penetrations provfdtng direct access f'res t @ containment atmosphere to the outside atmosphere shall be either closed by an isolation valve, b1thd flanse valve, or be capable of being closed by an OPtalthor manuel automatic t purge valve. A minimum of one door in each afrlock shall be ) (closed and the equipment door shall be closed and held in place by a minimum of four bolts.f l

b. rWith th

o. 18 Emerg fDie Generator requi d to be OP and the No.

11 $torate Tank

operable, d

trate the OPERABIL of No. 21 Fuel Storsge Tank b [,) { Performing Surve ance Requireiment .6.1.1.2.a.2 (ve ying 85,000 gallon within 1 hours a 2. Verifying e flow' path fren . 21 Fuel 011 Sto geTankto/ QB rgency Diesel Gen stor within 1 hou.

c. With the No. It Emergency Diesel Generator required to be OPERAS.E and the No. 2 Fuel 011 Storana "anInnoneracle.;

d'I i gg+ deiions ; rate the OPEus;uTY of No. Il Fue' 015torage Tant Dyp l .1.\\ Perfemina hrvat ' ancaTheautrement '4.8.1.1.2.a.2f(vert fying g3 l 8,64 F-si,oo0 gaiions) w uhin i novr e _ . the No.:g the flow path from No.ill Fuel.011 Storage Tank to ' e,j Verifyin 2. l 18 Emergency Diesel Generator within't haur.' ' J ' Restore No. 21 Fue' 011 5torene "ank to apraanLE status w thin 72 h r suspenU a i operations.' nvolving CORE ALTERATIONS,' ive, reactivity chahgess movement of irradiated fuel and\\ pos (Mement OT neDr sveva e ~1rrapaTee fjief; 4 d. ith th! No ' 1A Emerg c Olesel Generator required to be ^ A fuel 011 Storage Tank inoperable. gg [ OPERABL 'a the No. f ilbenedlaLe unysuu sai vywistions involvmv win ALTERATIONS. 8 . oositive reactivity chinees. mov'aent of irradiated fuel and 'j A cdF gCn1 OTAsvy ayura vvws ps0181e,jVrUel.] j \\ ((. l $fJS 62.T Aerica Q [ Per e of /,

d. shall reclude letion of ions to k

est ish a safe nservative ition, f u CALVERT CLIFFS - UNIT 1 3/4 8 7 Amendment No. 214 l E O .w,-r,, .%,,e,v,-s v c.,w.w, -.e.-, -.-y,. ,-,..,---,pe.,,. w c,.,,r...m ._,-,,,-.-w. .,e.,.,, %,-.ow,.w-...

INSERT I 0. 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. i 5 + 4 4 4 4

5 n.c.,. 4.o ~3. 8. 7 3.7 $/4:4 ELECTRICAL pmKR BYSTDi$ u.s ~.1 naw M rw i&..t J..,, A<lEl IA '" n asa,,I u.s./,e.1J jo~M')* i: a LDt! TIM Com! Tits Pet tco i '$.v.3 3.8.1.1 As a sintaus the following A.C. electrical power searces shall be 9ptRABLE: {. a. Two lea 11yi and the onsite Class 1E 01stributton Systen] ndent circuits between the offatte tren sten netwo g g consisting of eithers i 1. luo 500 kV offstte power circuits, or as necessary g I 2. 'he 69 kV SMEC0 offstte power circuit described in the 3 8 6 ,t January 14 tt1977 Safety Evaluation and one 500 kV offstte power circu f y CE j and

I.'

b. Two separate and independent diesel generators withs r k. y '[ 0 1 1. Separate fuel oil day tanks containing a stalmum volume of L5 gallons of fuel for each diesel _ generator, f;I [2. 'A copwi Fuel 5torage 3ystem consisting of ) ') %

a. No. 21 Fuel 011 Storafuel 011. ande Tank containing a st$

A. 4 j ( of 85.000 gallons of. g "i'3haikEeI'"'.E "'*["" L.1 b ',, d A separate fuel _t'ransfer pump for eactidlesel generatoQ APPLICABILITY: 400DEG-h-fr-8-4h4 gg f _ lt(' - -== v a. Wlth two offsite circuits of the above required A.C. electricah power sources inoperable. demonstrate the OPERA 81LITY of the remainin 4.8.1.1.g A.C. sources by performing Surveillance Requirement 1.a within one hour and at least once per 8 hours thereafter and 4.8.1.1.2.a.4 within 24 hours, unless the diese generators are already operating. Restore at least two CALVERT CL1FFS. UNIT 2 3/4 6 1 Aniendment No. 191 I o F Ik page

8peckca.43,t.3- .TMS68.7 d.Tip tJ 9... m.m. ; mi. s ma:~f a, % speci h 4. n.t.t.I LIMITING CGIg!TItil'FOR OPERATIO11 (Caettsued) W.gsg,g,ppu.4.ga ' f I hours or be in at least Off STAleBY within the next 6 hours a in Cete SOUT981sl within the following 30 hours. Restem at least two diesel genomters to GPERABLE status within 72 hours fmm l time of. initial less or be in at least OST STAlW8Y within the 1 u.= a ' m and in ma mutamAl wtthin the feitasma na '

f. With the lie. 21 Fuel Oil Storage Tanklineseret1b fdiifing the perted from:

ACfobAU l '** l,Re.vi,ement.A.N!ke'daT!""d"U 00.'NoT"*I@iI u l@l@r8 E c, d F 1 .nd aneast on.e -r. rip =ing.a. afi.a.ithioi ..>.i.e.a. ve n, i verlmns no 1, -n r,s. toe.e. II -.<> --noen L Tank no t te d' ese' r m'aN within 1 ' _I Restore No. E ru n n: LEarage. Tant to --mule slatus within 72'heurspr av m as swe=6 a. es r within Ene next ) ] nours and in COLD 51NT90601 within the~fallawina no E =.. A* oS' I M6d ( Z. Aorf' no sentember 30.fdamenstrate the OPERASILITY of v g,,og,,,n,6, m,,ss by performing Surveillance Requimment 4.4.1.1 1'.a within 1 ' and at 1amat er= eier U i ' ij hours *kaseafter.1 Restore No. Il Fuel Oil Storese Tant to L-LyranABLE status within ! 'ours sr os in at least evi air,1J M I rwunin.nr n,.. . ;,.. a a in COLD $11U790481 within the _ > (following 30 hours. f g 1,

g. fWith fle. 1 uel 011 Storage fa dnoperable, denen to the OPERABI of No. 21 Fuel Oil
orage Tank b 1 rformine ;

Surve ance Requirement 4.8.lat.a.2 (verif i ) 5.000 gallons 'l wit I hour and at least ce,per 8 hours t after, and verifying the fic.s p from No. 21 Fuci Storace Tank /,l ' he diesel generators thin I hour. Rest No. 11 Fuel Storage Tank to OPE LE status within 7 ays or be in a east NOT STAllD8Y withi he next 6 hours a in COLD SH within) the following 3 ours. 7 MS

T McTioA)

SURVEILLANCE REQUIREMEllTS 4.5.1.1.1 tacn required independent circuit between the offsite transmission network and the onsite Class 1E Distribution System shall bet a. Demonstrated OPERABLE. as follows: 1. For each 500 kV offstte circuit, at least once per 7 days by verifying correct breaker. alignments and indicated power j s agallablit ty. p CALVERT CLIFFS. UNIT 2 3/4 6-3 Amendr.ent No.191 I s m._ ou +2.{, A Spedbum 7 w w w opr % g g 1 ok !! 1 a _..,. _.... ~... _. _ _..... -... _. ~... _ ..._,.m._.-,-.,.__.-,-._..,._.-,._....,..__,...m, ,,,,.,-.a.

INSERT A. Fuel oil storage tank A.1 Restore fuel oil 48 hours (F0ST) 1A with fuel volume to within oil volume limits. < 49.500 gal and 2 [42.430] gal. 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 D

a as -2 k 4 a.6-- -,s .h -J, a+ -a,,,-, % -c. A a b

3. g, 5 J

3 Tr* -4/44. ELECTIICAL POKt $Y3fDIS 5,,, D, y,,, u..,,.r c L..g, g h/4.8.1 A.C.$0 UKES p, S r* *

E' * * + ' ' a ' a 8 ' '2, Shutdown

^4.C. S o.c, s - Or <a4 g LDehTING Com! TION Pet OPERAT10N 3.8.1.2 As a stalmus, the following A.C. electrical power sources shall be OPERABLE: 1

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

onsite Class 1E Distribution Jystem, and / b. One diesel generator with: 1. A fuel oil day tank containing a minimum volme of 275 gallons of fuel, f-'A conson ruel 5torage 3ystem consisting of:

a. Ilo. 21 Fuel 011 *torage Tank containing a minimum volume of 85.000 gallca. of fuel oil, and j

3 oI f A fuel transfer pump. 7 ets EEum_anEULad4<-

a. With less than the above minimum required A.C. electrical power sources OPERA 8LE:

l 1. Innedtately* suspend all operations involving CORE ALTERATIONS. 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 OPERA 8LE Datus, and ( Performance of ACTION a. shall not preclude con:pletion of actions to estabitsh a safe conservative position. CALVERT Cliff $ = UNIT 2 3/4 6 6 Amendment No. 191 he 8 oE l)

_ _ ~ _ _.. _ _ _ _ _ _.. _. _.. Aprisb'cAAib 3J.*3 l i f = =. 1 See b;seussim ok kes f g,, gg y gg h Specilledh 1.t.7,3 - Ltuttras censiteN tea optaAtlas (contiamed) - ~M 3 ' " " r -3. 'Allcontainmentpenetrationspmvidingdirectaccessfmmthle 5 containment atmosphem to the outside atmos m shall be either closed by an isolation valve, blind a or annual i valve, or be le of being closed by an automatte. i pune valve. minteus of one door in each airlock shall be L closed and the equipment door shall be closed and held in uplace hv a mint af four bolts. L

b. With the No.11 fuel Oil Storage Tank ino rable.demonstratethle 1

OPERABILITY of No. 21 Fuel 011 Storage Ta k by: ,I 1. Pdfomino survettlance Requirepent d.8.1.1.2.a.! (verifying 85.000 gallons) wtthin 1 hours and Verifying the flow path from No. 21 Fuel 011 Storage Tank to) 2. de diesel oeneratar within 1 h"Ar.

c. With No. 21 Fuel 011 Storane "an c anonerable-II5emonstrate t T

t

gygg, vrr.uszuTT or no. aa ruel Ol'.5sorage Tant py gJ g g p~

<1. Performina turval n hce *^-"f rement a.a.1.12 a 2 (vertfying a 85.000 gallons) w L,htn I hourgg ~ (2. Verifying the flow path from No.11 Fuel 011 Storace Tank to] b*l l L the diesel generator within 1 hour. r FRestor U o. ga

ues v-atorno'i Tan t to a.orna_"_'! status w th n

.3 72 hoursior sus #ne a' operat ons nvoly no was AUuunTLOWh. ' positive reactivity channes. movement of irradiated fuel and myement of neavy loads over irraviewo Tuvi.j ~ l 4. -taswr AcsNA A) .I __ -- w StJCC(L T b orson) b l 3 CAlytRT CLIFFS. UNIT 2 3/484 Amendment No. 191 t

a INSERT i I A. Fuel oil storage tarik A.1 Restore fuel oil 48 hours (FOST) 1A with fuel volume to within oil volume limits. < 49,500 gal and 2(42,430) gal, i O. 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, 4 4 4 g .b ? d f =.aq.. ve & 4 c 4 .e 1 ? P i jne 10 d ll h _...-s..._.-__..~,..__ ._-_-__..._._--._-._-._--_,~.,-_,_-,.,._.._...s-.

DISCUSSION OF CHANGES SEC110N 3.8.3 - DIESEL FUEL OIL ADMINISTRATIVE CHANGES A.1 ne proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change ofintent, 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 Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional information does not change the intent of the CTS. The refonnatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Current Technical Specification 3.8.1.1 applies to AC Sources dttring Modes 1,2,3, and 4, and CTS 3.8.1.2 applies to AC Sources during Modes 4 and 5. He Improved Technical 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"). His change separates 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. De moving of requirements within the Technical Specifications constitutes an administrative change. This change is consistent with NUREO 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 Tecimical Specification 3.8.3 requires the Diesel Fuel Oil Technical Specification to be applicable when the associated DG is required to be Operable. He AC Sources are required to be Operable in Modes' 1,2,i3,4,'5, and 6,'asJ ~ 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. His change is consistent with NUREG 1432. A.4 Current Technical Specifications. 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 l Specification 3.8.3 will move this requirement from the LCO to the SRs. Moving l l requirements within the Technical Specifications constitutes an administrative change. This change is consistent with NUREG 1432. A.5 Current Technical Specifica.oa 3.8.1.1 Unit 1 Actions f(No I A FOST inoperable) and g l (FO,ST Nos,11 and 21 inoperable) require the performance 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 DO Specification must be followed, which are consistent with i I the above listed CTS requirements. This change to the CTS is a result of other changes to CALVERT CLIFFS - U ITS I & 2 3.8.31 Revision 10

DISCUSSION OF CIIANGES SECTION 3.8.3 DIESEL FUEL OIL the Specification (to declare the DO inoperable) in a less restrictive discussion of change. Derefore, 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 cavaot be met when the fuel oil storage requirements are not within limits, improved Technical Specifications will not contain these requirements. De ITS will require the associated DO to be declared inoperable and the Actions of Specification 3.8.1 be entered. If the Actions of the DO cannot be completed in the required time limit, the Actions will require the plant to enter a shutdown track. He movement cf requirements from one Specification to another constitutes an administrative change. His change is consistent with NUREO 1432. A.7 Current Technical Specification SR 4.1.1.2.b requires verifying that a sample of diesel fuel frorp the FOST is within the acceptance limits specified in Table 1 of American Society for Testing Material D975 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. His 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 adrninistrativt change. His change is consistent with NUREG 1432. TECIINICAL CIIANGES - MORE H53TRICTIVE 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 . Gwill help eliminate microbiological fouling, which is a major cause of fuel oil degradation. %e 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. His 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 hours when it is inoperable due to the level not within limits. Improved Technical Specification 3.8.3 Actions will require it to be restored wi*hin 48 hours. In the CTS, if the level cannot be restored within 72 hours, Core Alterations, t movement of irradiated fuel, and positive reactivity additions must be suspended. In the ITS, the DO 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, nnrefore, this change decreases the allowed outage time (AOT) when l the No. 21 FOST is inoperable due to level, from 72 hours to 48 hours. The 48 hour AOT for the No. 21 FOST level allows sufficient time for obtaining the requisite replacement j volume and performing the analyses required prior to addition of fuel oil to the tank. l Decreasing an AOT constitutes a more restrictive change. This change will not adversely affect plant safety because 48 hours allows enough time to restore the appropriate level in a FOST. This change is consistent with NUREG 1432 M.3 Improved Technical Specification 3.8.3 Condition F addresses inoperabilities other than l 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 hour Completion Time for an inoperable DG. Since No. l A FOST only CALVERT CLIFFS - UNITS 1 & 2 3.8.32 Revision 10

DISCUSSION OF CHANGES SECTION 3.8.3 - DIESEL FUEL OIL supports No, l A DO, ITS 3.8.3 Condition F and ITS 3.8.1 (wh ch allows 72 hours for an inoperable No. l A DO) are consistent with the 72 hours allowed for an inoperable No. l A FOST by CTS 3.8.1.1 Unit 1 Action f. Ilowever, No. 21 FOST supports two Dos 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 hours with the FOST (and therefore, two dos) inoperable. This AOT for this condition is not retained in ITS since ITS 3.8.1 requires one of these Dos to be restored to Operable status within two hours. Therefore, for No. 21 FOST, the adoption ofITS 3.8.3 Condi' ion F is consistent with the CTS 3.8.1.1 Unit 2 Action f.2 AUT but more restrictive than CTS 3.8.1.1 Unit 1 Action g and CTS 3.8.1.1 Unit 2 Action f.1 AOTs. Rese changes are consistent with NUREG 1432. Current Technical Specification 3.8.1.1 Unit 1 Action h allows for the fuel oil volume in No. I1 FOST to fulfill the Unit I requirements for a seven day supply for No. IB DO when No. 21 FOST is inoperable. Number 11 FOST and No. 21 FOST both support Unit I required Nos.1B and 2B Dos. Number 2D DO is reqdred for Unit I since it supports some Unit I required equipment such as CREVS which is redundant to equipment supported by No. l A DO. Derefore, the allowance for No.11 FOST fuel oil to be used in lieu of or in cordunction with the fuel oil in No. 21 FOST is also applicable to No. 2B DO in ITS 3.8.3. Since the capability to support No. 2B DO 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 hour AOr. The equivalent ITS 3.8.3 Conditions, i.e., Required Actions A.1, B.2, and C.3, will include Completion Times of 48 hours. Since no action was required by CTS for 72 hours, these changes are more restrictive than CTS. These changes are consistent with NUREG 1432. With No. 21 FOST fuel oil volume less than required, CTS 3.8.l.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 I 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. M.4 Current Technical Specification 4.8.1.1.2.b references ASTH. J975-81 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 compliance with ASTM D975 96. This change will commit Calvert Clifts Nuclear Power l Plant to the updated ASTM which contains additional testing requirements. The requirement to include additional testing constitutes a more restrictive change..nis change does not impact plant safety because the updated ASTM includes better testing methodology along with additional testing which allows for a more thorough test of the diesel fuel oil. 1 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 CAINERT CLIFFS UNITS I & 2 3.8.33 Revision 10

DISCOSSION OF CHANGES 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 iajection equipment, which can lead to DG failure. Since no requirements exist in the CTS for particulates, these changes are more restrictive than CTS. Rese changes are consistent with NUREG 1432. IECIINICAL CIIANGES - IIFI OCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROT3rn 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 suspencion of heavy load movement over irradiated fuel assemblies are to be relocated to the UFSAR. He bour. ding design basis fuel handling accident assumes an irradiated fuel assembly is dropped cod damaged, ne 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. Screfore, 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 (*) requNes that the performance of Action d. not preclude completion of actions to establish a safe conservative position. His requirement is being moved to the Improved Technical Specification Bases. He ITS Bases states that suspension of these activities do::s not preclude completion of actions to mablish a safe, conservative condition. The movement of this requirement to the Bases will sa nnsure that the actions taker will establish a safe, conservative posi ion. His type af t sp: clue information is being moved to the Bases as part of the conversion te 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 Current Technical Specifications 3.8.1.1 and 3.8.1.2 Actions for a FOST inoperabb require verification that the Opera $le FOST is aligned to the appropriate DG. Improved Technical Specification 3.8.3 Actions will not specifically delineate this requirenyent. His requirement is a condition of Operability and is discussed as such for No,11 FOST in the Bases. This is acceptable because Technical Specifications should only contain specific requirements for system Operability (requiring the FOST is sufricient), and the Bases should clarify what constitutes the required Operability. His type of specific information is being moved to the Dases 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. His will ensure that any changes to these requirements will be appropriately reviewed. His change is consistent with NUREG 1432. CALVERT CLIFFS - UNITS I & 2 3.8.3-4 Revision 10

DISCUSSION CF CHANGES SECTION 3.8.3 DIESEL FUEL OIL -9 IECHNICAL CHANGES. IM MFETRICTIVE L.1 Current Technical Specification 3.8.1.1 Unit 1 Actions f, g, and h, and CTS 3.8.1.1 Unit 2 Actions f and g, provide AOTs when one or more FOSTs are inoperable. He AOT is generally consistent with and based on the consideration that if the FOST is inoperable, the DO is inoperable, llowever, it is overly conservative to consider the DO 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 DO to perform its safety function. Dese parametern, while supporting diesel generator Operability, contain substantial margin in addition te 'he limits which would be absolutely necessary for DO Operability. Herefore, certain leven of degradation in these parameters are justified to extend the allowances for restoration. Improved Technical Specification 3.8.3 Condition E provides a 30 day Completion Time for new fuel oil discovered to have fuel oil properties which do not conform to the limits after the new fuel oil has been added to the FOST. nis Completion Time is appropriate since the fuel replenishments are made in relatively small amounts compared to the size of the tank and the probabilities are high that the DO remains capable of performing its function. TI,e 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. De Actions for fuel oil volume are addressed for each FOST below. Current Technical Specification 3.8.1.1 Unit 1 Action f provides a 72 hour AOT when No. I A COST is inoperable. uls 72 hours 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, l A FOST. Ilowever, since No. lA DG supports required Unit 2 equipment, mi e.g., CREVS, the inoperable support system, i.e., No. l A FOST, results in an inoperablei DG ' a e and correspondingly, the supported inoperable CREVS components.' ' As indidated'aboVe,^1tn Mg is overly consermtive to consider the DG inoperable when the FOST volume is only slightly low since tbbondition does not result in I nmediate inability of the DG to perform its safety function. Derefore,ITS 3.8.3 Condition A provides a 48 hour Completion Time for reduced No. lA FOST fuel oil volume which is still sufDelent to provide for six days of DO operation. His change is consistent with NUREG 1430. Current Technical Specifications 3.8.1.1 and 3.8,1.2 requires three FOSTs to be Operable for Unit 1, i.e., Nos. I A,11 and 21, and two FOSTs to be Operable for Unit 2, i.e., Nos.11 and

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

Nuinber 21 FOST is addressed below as supporting Nos. IB 2A, and 2B DGs. Ncmber 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 LOCl 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. Herefore, 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.11 FOST is not required by allowing unlimited continued operation with No. 21 FOST Operable and No.1I FOST inoperable. His 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 3.8.35 Revision 10

t DISCUSSION CF CIIANGES - SECTION 3.8.3 Drrmas FUEL OtL i Noi 11' FOST Operable and No. 21 FOST inoperable. His is acceptable for Unit I since i No. lA POST remains available to support a required shutdown should a tornado make No.11 FOST unavailable. His would not be acceptable for Unit 2 since No l A FOST does not fully support a requirw3 shutdown of Unit 2 If only No. I A FOST and No. I1 FOST wers i 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 i 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 3.83 does not require No.11 FOST l except to support a degraded No. 21 FOST as discussed below. With no LCO requirement for an Operable No.11 FOST, the CT3 3.8.1.1 Unit 1 Action h, CIS 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.11 FOST are also omitted, as is the SR to verify the required fuel oil volume of No.11 FOST. Current Technical Specification 3.8.1.1 Unit 1 Action g provides a 72 hour AOT when No.11 FOST and No. 21 FOST are both inoperable. This 72 hours is similarly consistent with and based on an inoperable DG AOT. Number 11 FOST and No. 21 FOST both support Unit I required Nos.1B and 2B Dos. Number 2B DO 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 DO. : Number 21 FOST is also addressed in the Unit 2 CTS and changes to CT3 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 [ Iow since this condition does not result in immediate inability of the DO to perform its safety function. Herefore; ITS 3.83 Condition B provides a 48 hour Completion Time for reduced ) 'No.;21'FOST fbel oil yolume'as,long as _the comuaed; volume of No. 21 FOST and an. Operable No. I1 FOST remains sufficient to provide for 6 days of DO operation (as required by ITS 3.83 Required ~ Action B.1).: he'48 hour Completion Time of ITS 3.83 Required Action B.2 is actually more restrictive than the 72 hours allowed with no action by CTS 3.8.1.1 Unit 1 Action g. In addition, if No. 21 FOST is not restored and No.11 POST continues 'to be relied upon, Required Action B.2 must be repeated every 31 days. His effectively replaces the SR 3.83.1 periodic surveillance of available DG fuel oil for the inoperable No. 21 FOST. De I hour Completion Time ofITS 3.83 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.11 FOST and No. 21 FOST as provided for in ITS 3.83. 'Ibwever, this is acceptable since both FOSTs provide fuel to the same set of required emergency DGs. Fuither, No. I1 FOST will be required to be considered Operable prior to allowing its contents to be considered, ne Bases will indicate that No.11 FOST may not be considered Operable unless the fuel oil volume meets SR 3.83.2'and SR 3.833, and is capable of'veing delivered to the rquired DG,- i.e., the necessary piping and valves are capable of performing their safety function. The Bases will t also reflect that any fuel oil which is credited for DG use in No.11 FOST above the 33,000 gallons reserved for emergency DO use, must be administratively controlled to assure its retention for this purpose. E Current Technical Specification 3.8.1.1 Unit 2 Action f.1 provides a 72 hour AOT when No.21 FOST is inoperable provided No.11 FOST can provide the required seven day fuel oit volume. His 72 hours is similarly consistent with and based on an inoperable DG AOT. CALVERT CLIFFS s UNITS 1 & 2_ 3.83-6 Fevision 10

EISCUSSION OF CIIANGES SECTION 3.8.3 - DIESEL FUEL OIL Number 11 FOST and No. 21 FOST both support Unit 2 required Nos. 2A and 2B dos. Number 1 A DO is also required for Unit 2 since it supports s.ome Unit 2 required 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. Ilowever, as indicated above, it is overly conservative to consider the DO inoperable when the FOST vohme is only slightly low since this condition does not result in immediate inability of the DO to perform its safety function. Herefore, ITS 3.8.3 Condition C provides a 48 hour 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 (a2 required by ITS 3.8.3 Required Action C.1), ne 48 hour Completion Time ofITS 3.8.3 Required Action C.3 is actually more restrictive than the 72 hours allowed with no action by CTS 3.8.1.1 Unit 2 Action f.l. De I hour Completion Time ofITS 3.8.3 Required Action C.I is consistent with the AUT for verification of the backup fuel oil supply ellowed 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.1I FOST and No. 21 FOST as provided for in ITS 3.8.3. Ilowever, this.is acceptable as discussed above for ITS 3.8.3 Condition B. Improved Technical Specification 3.8.3 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. De 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 3.8.3 Condition A allowances for continued operation for up to 48 hours. Current Technical Specification 3.8.1.2 (Unit I and Unit 2) Action c provides a 72 hour AO f when No. 21 FOST is required and inoperable during MODE 5 or 6. His 72 hours is similarly consistent with and based on an inoperable FOST during operation in MOD',1,2, 3, or 4. Ilowever, as indicated above, it is ovenly conservative to consider the DO 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 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. He 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 reflected in an ITS 3.8.3 Required Action C.2 Note.

L2 Current Technical SpecMication LCO 3.8.1.1 Unit 1 Actions f and g require the redundant l FOSI volume and flow path to be verified within one hour and once per eight hours thercefter, when one FOST is inoperable. Improved Technical Specification 3.8.3 will not contain this requirement since the ITS 3.8.3 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 afTeeted, ITS 3.8.3 will require the DG to be declared irmperable and ITS 3.8.1 will provide the appropriate actions. Cross unin checking of equipmen,..; approximately addressed in ITS 3.8.1 for inoperable power sources. Therefore, increased I;rcquency 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 I & 2 3.8.3-7 Revision 10

DISCUSSION OF CHANGLS SECTION 3.8.3 - DIESEL FUEL OIL sufficient supply of fuel oil is availnble, 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 NUREO 1432. L.3 Current Tecimical Specification 3.8.1.2.c requires the No. 21 FOST to be restored to Operable status within 72 hours wiien inoperabS. If the FOST cannot be restored within 72 hours, CTS require Core Alterations, irradiated fue' riovement, and positive reactivity additions to be suspended. Improved Technical Spe< *h n 3.8.3 will require the FOST to be restored to Operable status within 7 days for paip;... concentration and 30 days for new fuel oil properties not within limits. If the required FO5T cannot be restored within the AOT, the associated DO must be declared inoperable, which requires the immediate suspension of Core Alterations, movement of irradiated fuel, and positive reactivity additions. His change increases the AOTs when the No. 21 FOST lt inoperable from 72 hours 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 particulate does riot 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 prop:r engine performance has been recently demonstrated (within the previous 31 days). The 30-day AOT, when new futl oil properties are not within limit, is acceptable because the IXi will still perform its intended function. Relaxation of the AOTs constitutes a less restrictive change. His change is consistent with NUREO-1432. L.4 Current Technical Specification 3.8.1.2.d requires Core Alterations, irradiated fuel movement, and positive reactivity additions to be immediately suspended when the No. l A FOST is inoperable. Improved Technical Specification 3.8.3 will require the FOST to be restored to Operable stetus within 48 hours for level,7 days for particulate concentration, and 30 days for new fic' 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 Attemtions, movement of irradiated fuel, and positive reactivity additions. His change essentially increase, the AOT when the No. I A FOST is inoperable from 72 hours to 48 hours for level, 7 day. for particulate concentration, and 30 days for new fuel oil properties not within limits. The 48-hour AOT for FOST level not within limita allows time for obtaining the requisite replacement volume and performing the analyses required prior to addition of fuel oil to the tank. The 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 not mean failure of the fue! oil to burn properly in the diesel engine, particulate concentration is unlikely to change siguicantly between Surveillance Frequency intervals, and proper engine i performance has 'ocen recently demonstrated (within the previou, 31 days). The 30 day AOT, when new fuel oil properties are not within limit, is acceptable because the DG will still perfonn its intended function. Relaxation of the AOTs constitutes a less restrictive change. This change is consistent with NUREG-1432. L.S Current Technical SpecihMon SR 4.8.1.1.2.a.2 requires the verification that each FOST i j level is within limits every 31 days on e Staggered Test Basis, improved Technical Specifica' ion SR 3.8.3.1 will not require FOST testing on a Staggered Tert Basis. The intent of a requirement for staggered testing is to increase reliability of the component / system i l CALVERT CLIFFS - UNITS 1 & 2 3.8.38 Revision 10

CISCUSSI2N OF CHANGES SECTION 3.8.3 - DIESEL FUEL OIL being tested. A number of studies have been performed which have demonstrated that staggered testing has negligible impact on component reliability. As a result, it has been determined that staggered testing: 1) is operationally difficult,2) has negligible impact on component reliability,3) is not as significant as initially thought,4) has no impact on failure frequency,5) introduces additional stress on components such as dos potentially causing increased component failure rates and component wearout, and 6) increases likelihood of human error by increasing testing intervals. Therefore, the FOST staggered testing requirements have been deleted. This change is consistent with NUREG-1432. cal. VERT CLIFFS - UNITS 1 & 2 3.8.39 Revision 10

Diesel Fuel 011MD6. a#startfna MA h 3.8.3 3.8 ELECTRICAL POWCk SYSTEMS 3.8.3 Diesel Fuel 011D,uoIDC MStMng AW) h LCO 3.8.3 The stored diesel fuel ci1C41rbe# mrstatino C Q m3shall be within limits for each required diesel generaser(DG). APPLICA81LITY: When associated DG is required to be OPERA 8tE. (CTS} ACTIONS -NOTE-------------- Separate Condition entry is allowed for each DG. CONDITION REQUIRED ACTION COMPLETION TIME 'A. One 'more DGs wi A.] Restore f I cil 48 hours jA) SERT fu level level within

33,000'I nd 11e 3.2.3

>L28,285l gal in storage d m [ B. O r more DGs th 8/ Restore e oil 48 h s p be oil iny cry. / inven y to within 100 nd 11 s. > ;425; ga j g One or more DGs with 1 Restore fuel oil 7 days b)ce \\ stored fuel oil total total particulates to N / particulates not within limits, within limits. I (continued) CEOG STS 3.8-22 Rev 1, 04/07/95

INSERT 3.8.3 k 3.9.l.) A. Fuel oil storage tank A.1 Restore fuel oil 48 hours A*4 (FOST) JA with fuel volume to within Mi*a oil volume limits. (us i-O < 49.500 gal and sea 2 [42.430] gal. (G.:t t.g B.

NOTE---------

B.1 Verify combined I hour jf;' g Only applicable to available fuel oil Unit 1. volume of FOST 21 3,,,,, 2 and OPERABLE FOST 11 m,w e tuai4s 2 [72.860] gallons. F0ST 21 with fuel oil volume < 85.000 gal. A@ B.2 Verify combined 48 hours available fuel oil volume of F0ST 21 AND and OPERABLE F0ST 11 2 85.000 gallons. Once per 31 days thereafter

u INSERT 3.8.3' l ' C. ~--------NOTE..--..... C.1 Verify combined I hour -_0nlytapplicable to available fuel oil Unit 2. volume of FOST 21 and OPERABLE F0ST 11' 2 [72.860] gallons. FOST-21 with fuel oil- , volume < 85.000 gal. MQ C.2

NOTES--------

1. Only applicable.

during H00E 1. 2.

3. or 4.

2. Only aslicable between April 1 and September 30.

Restore F0ST 21 2 hours fuel oil volume to-within'11mits. 't: MQ C.3 Restore FOST 21 48 hours fuel oil. volume to within limits. i 1 F r t ,m-, w ' 4 .--.,,..g .-..,.,g-,re-,...,,, u-y+.,

Diesel Fuel OllDatie QW. 4#3tytingM h g s.s.3 j ACTIONS (continued) com! TION REQUIRED ACTION COMPLETION TIME,

I l h, Q 3

One or more DGs with Restore stored fuel 30 days 'N"gd new fuel oil oli pro withinfertiesto ( gropertiesnotwithin inits. a s. A s h d t-4d(ut e ,1 I I. E e or more with (/ Restore s ing air 48 ers starting receiver / receive ressure to h I 25) ( / I F. Required Action and F.1 Declare associated DG Isumediately h associated Completion inoperable. Time not met. g QB One or more DGs' 3.3,i. I dtesel fuel oil kbr fd$ h re g-du Q \\ s _ Jnot with<n Ilmits for reasons 'Qgg other than M/plorl@ h o SURVEILLANCE REQUIREMENTS SURVEILLANCE l FREQUENCY 1 I S. S.I I 2 ' A. 2-SR 3.8.3.1 Vertfy/G 20 fuel of gem cons 1rins] 31 days a>>.? m. w ( .>ra -.c 3 Od EOST 18 h 49 f00 Sano4, and (continued) FotT 21 t IIff,000 SCS**5 CEOG STS 3.B-23 Rev 1, 04/07/95

Diesel Fuel 011[Jeffe M patf5tarAfng Adj h 3.5.3 j SURVEILLANCE REQUIREMENTS (continued) i SURVEILLMCE FREQUENCY [* h S 2 V lu ca 1 invento 3 STil.l.h b> SR 3.8.3 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 I jy the Diesel Fuel 011 Testing Program. Testing Program y < ic e,n, & '- Y - "Y] 4, L l.i. Z.b SR 3.8.3. Check for and remove accumulated water from days each fuel oll atorage tank. Q ISR 3.8 .6 For each fu oil sto age tan 10 y rs -rs-rF-1 a. D n the fuel oil; kV. i b Remove the sedi

and

^ / c. Clean the t j a CEOG STS 3.8-24 Rev 1, 04/07/95 ^'

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 l SECTION 3.8 - ELECTRICAL POWER SYSTEMS coolant accident (LOCA) loading is less than the 2000 hour rating of the DGs. Not including these SRs in the Calvert Cliffs ITS is consistent with Calvert Cliffs current licensing basis. I1. NUREG 1432 SR 3.8.1.16 verifies that each DG synchronizes with an offsite power source while loaded with emergency loads upon a simulated restoration of offsite power; transfers loads to the offsite power source; and returns to ready-to-load operation. Calvert Cliffs ITS SR 3.3.1.14 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 the offsite power source, ne Calvert Cliffs ITS will not contain the 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 his test is not currently a Technical Sj nification SR at Calvert Cliffs, but was added because it is currently performed outside of the Technical Specifications. His change is consistent with Calvert Cliffs current licensing basis. 12. NUREG 1432 Specification 3.8.3 contains an LCO, Actions, and SRs far 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 sht receiver can feed any DG through a common header. His system is unlike the standard in t-nne nir start receiver does not f~d one DG (except for the 1A DG), therefore, it dce., ne standard and veill not be incorporated into t6e Calvert Cliffs ITS. The lubrication oli requirements at Calvert Cliffs are suflicient 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 three of the Calvert Cliffs DG (except for the l A DG), therefore, providing a specific number for lubricating oil is not feasible. Therefore, consistent with current licensing basis, Calvert Cliffs will not add Specifications forf _ Ma 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 Gel oil storage tanks (FOSTs) not within their volume limits but still with volume sufficient for approximately six days of required DG operation. He standard Condition is appropriate far 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. Here are four DGs. Bree of the DGs, i.e., Nos. IB, 2A, and 2B, are fueled from two FOSTs, i.e., No. I1 FOST and No. 21 FOST, and No.1 A DG is fueled from No. l A FOST. Further, No. l A FOST and No. 21 FOST are " tornado protected" wh!!c 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 eupports 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 and is the parameter used in the analysis for DG operation. Also, Note that the reduced volumes for allowing 48 hours 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 l CALVERT CLIFFS - UNITS 1 & 2 3.8-3 Revision 10

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.8 - ELECTRICAL POWER SYSTEMS two DGs. It supports both Unit 1 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 equipment which is redundant to some equ!pment powered by No. IA DG, e.g., CREVS. Since No. IA DG is supported by No l A FOST and the redundant required equipment is powered by Nos.1B 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, law fuel oil volume in No. 21 FOST can be supplemented by the fuel oil volume of an Operable No. I1 FOST to assure the necessary volume. 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. I1 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. This is reflected in ITS 3.83 Required Action B.2 which requires the combined volume of No. 21 FOST and an Operable No.11 FOST to be d 85,000 gallons viithin 48 hours. His is consister.t with the NUREG 3.83 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. I1 FOST continues to be relied upon, Required Action B.2 must be repeated every 31 days. This effectively replaces the SR 3.83.1 periodia surveillance of available DG fuel oil for the inoperable No. 21 FOST. Improved Technical Specification 3.83 Required Action D.1 requires the combined volume of No. 21 FOST and an Operable No. J1 FOST to be verified to be greater than the 6n of the required volume within one hour. His 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 3.83 LCO, Bases are included to indicate that No.11:FOST is considered Operable when the fuel oil volume meets ~ i SR 3.83.2 and 'SR 3.833,3and;is capable of b'eirif delivered to.the required DG,t.e., the. necessary piping and valves are ca"pable of performing their safety function, no Bases will 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 administratively controlled to assure its retention for [ this purpose, l improved Technical Specification 3.83 Con <lition C addresses only No. 21 FOST which is "tomado protected" and which contains sufficient fuel for seven days of required operation of two DGs. It supports both Unit I and Unit 2 quipment, but Condition C is written for Unit 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. I 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 Net 21 FOST. Therefore, low fuel oil volume in No. 21 FOST can only be supplemented by the fuel oil volume of rn 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 nction f.1 requirements fcr the inoperability of No. 21 FOST are the same as the CTS 3.8.1.1 l Unit 1 Action g and h requirements for No. I1 FOST and No. 21 FOST. Herefore, it is not appropriate to allow their combined volume to provide the seven day required volume. It is acceptable, however, for their combined volume to be considered in providing 65 of the required volume in ITS for the 48 hours allowed in NUREG 3.83 Cendition A. This is reflected in CALVERT CLIFFS - UNITS 1 & 2 3.8-4 Revision 10

DISCUSSION CF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.8 - ELECI'RICAL POWER SYSTEMS ITS 3.83 Required Action C.1 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 3.83 Required Action C3 would the require the volume of No. 21 FOST to be restored to within volume limits within 48 hours. This is consistent with the NUREG 3.83 Required Action A.1 and its Completion Time to restore the full seven day required volume. However, during tornado season, i.e., from April 1 to September 30, the fuel oil volume of No. I1 FOST is not allowed to be credited (per CTS 3.8.1.1 - Unit 2 Action f.2) and the fuel oil seven day volume of No. 21 FOST must be restored within two hours. This is reflected in ITS 3.83 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. He Action allows four hours to replace an inoperable battery with the reserve batterj. Rese changes are consistent with the Calvert Cliffs current lica.ng basis, as approved in Amendment Ncs. 58 (Unit 1) and 40 (Unit 2), and discussed in the NRC Safety Evaluction Report dated November 2,1981. In conjunction with this change, the phrase, "other than Condition A," was added to Condition B (NUREG-1432 Condition A) to account for other reasons the DC electrical power channel may be inoperable. 15. He Mode restrictions presented as Notes in the SRs of Specification 3.8.4 are being deleted. Calvert Cliffs has a reserve battery and two battery chargers per battery. This enables Calvert Cliffs to perform Surveillances while in Modes 1-4. His change is consistent with current Calvert Cliffs practice and licensing basix 16. All Reviewers Notes will be deleted.- Rese Notes are for the'NRC reviewers and are not intended to be included in the specific plants' ITSl 17. Not used. l I 8. 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 hours. The time is not contained in the CTS. However 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 requireinents 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 CAINERT CLIFFS - UNITS I & 2 3.8-5 Revision 10

Diesel Fuel Di1{ Lybe111. and St3pting Air) ~ p 3.8.3 83.8 ELECTRICAL POWER SYSTEMS 8 3.8.3 Diesel Fuel 011Qube3W. and Startino Air) BASES storge4ank]l BACKGROUND I itsel enerator (DG) s provided stitL h ng a -f Mil capact sufficient to ate tint di e Tk'fododsb for a pe od of 7 days, 11e the 'DG is s plying maxi i post I s of coolant; a ident load dema as discusse in M Y4

c. A u the

,$cction(9 Art} (Ref.1). he maxt:=um 1 d .r.fr.o A c.f.i (u. d' ' nd is calculata urina 'ha = m aa +ha+ at 1 st two I c are available f This onsite fuel'otl capacity fs O Mc.scl sufficient to operate the DGs for lo er than the time to replenish the onsite supply from outs de sources. r.4.,, (0(,) %

F"' t#

'#^4

^

Fuel oil is transferred from storage tan o day tank r -8" eithe-f tS transfer pumps assoc' ated with each ee g. L A L.k n) Gi jh;...; M ui vo.va anu y W rj pn '.C; ;r.e....m a i' w rupiuis vi v.ve, ee 6,.. t xi t: m = ; ;;, v. n .. y hN l' $'ll? SN" "

E' ""

' I"""e' t_[ f a

- MM h

gg g, e-_----- Thc3,s but ;, For proper operation of the standby DGs, it is necessary to ensure the proper quality of the fuel oil. ( ulato y L>Fi% chit 4 i suice. m pur, o soars.. G. m nii fu oli pre ces as supplemented ANSIN195-1976(!te 3). The __ _ )F f rties.cov d bY these SRs ar he\\ water and gg7 _f g' sediment content, the kinematic viscosity 3 specific gravity (or API gravity), and iz;:uritylwel4 j The Dra luDr1 cation sy a is designed to provide suf cW 4I. p rf' es) lubrication to persi proper operation of its asso ated DG i under all loading nditions. The system is requ ed to ( t'*5 W 5 I C-4gb* circulate the lu oil to the diesel engine war n surfaces and to remo e ess heat generated by frictio du ing operation. h engine oil 4 ump contains an nventory capable of pporting a minimum of [7] day of operation. (Theonst storage in addition to the en ne oil sump is suffici to ensure 7 days of continuo operation.) This{ suppl s sufficient supply to allow 3, operator to l repl ish lube ett frna eutside sour s.l ) [ Tach has an air start stem with a quate capacity C') five uccessive start a empts on th without rech ing LIV r th air start receive s)., - {84fMRollt)b; k (continued) CEOG STS B 3.8-41 Rev 1, 04/07/95 I i-1

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.1B, 2A, and 28, are fueled from two fuel oil storage tanks (FOSTs), i.e., F0ST 11 and FOST 21 and DG 1A is fueled from FOST 1A. FOST 1A and FOST 21 are enclosed such as to be considered " tornado protected" but F0ST 11 is not protected. As such, F0ST 11 is not used as the primary source for the energency DGs, but rather is used as a backup to support FOST 21 if it or the fuel oil it contains becomes degraded. 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, tne 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 4000 kW. 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 1B, 2A, and 28 are loaded to 3500 kW. i

_~ Diesal Fuel 011[lujp tI11, and StarKne Air) 8 3.8.3 BASES (continued) 7 M APPLICABLE The itial condit of sis A ci nt ( and SA. TTY ANALYSES tra tent analyses the Chapter 4 (Ref. , and in the SAR, Chapter (Ref. , assume..nginee afety h f Feature (ESF) sys ens are 0P LE. The DGs are destgried to f'oS7 /A a. reabjbtewW provide sufficient capacity, capability,f necessary power to redundancy, and Sg@Ql reliability to ensure the availabilltfant System and o ESF systems so that fuel, Reactor Coe ek pa'dabic. d'iess\\ 6el oN. containment design Itaits are not exceeded. These limits I are discussed in more detail in the Bases for LC0 ukiek'es sd(Meat s.N ute Section 3.2, Power Distribution Limits; Section 3.4, Reactor } opera.h b&lA en acdJent Coolant System (RCS); and Section 3.6, Containment Systems. Lloads%r%s.F0M(1'd Sh dWel fM m %. mum m Tequired te CMam A M8M gutspffM4 supporp he operation of the standby AC power of tr,ecop\\,*s ef pa%kle_.J sources, they satFsfy Criterion 3 of the NRC Policy , Statement. C -- LC0 diesel fuel ofi isfoiRndfevto mv41 sufficient supply g days '" " :. --- -- m. 1111s<also required to I

9. eprAlc on vad M m.oreet specific standards for quality.Em eltionais.

j "$Wb1 7 r 7'd vs. acttk d l**I5*ad '" $nS I W e$$NI 1 + { h rt sa M J., loa h This requirement in conjunction with an: ability to obtaln ' ' ~ ~ replacement suppIles withinidays,* supports;thet i PN ' availability of DGs required to shut down:the reactor and to maintain it in a safe condition for an anticipated - i operational occu nce (A00)' or a postulated 08A with loss of offsite power. DG day tank fuel requirements, as well as lA transfer capabil y from the ($crans' tmuoto the day tank. ggy g I go are addressed in LCO 3.8.1, 'AC Sources--Operating," and LCO 3.8.2, 'AC Sources-Shutdown." / e stir ng air system is quired to have a sin mum Th .capact for five success e DG start attempts thout (rech ing the air star receivers. 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 maintain it in a safe shutdown condition after_an A00 or a postulated DBA. Since_storeddQselfuel nr u nnars t -a supportsLCO 3.8.1 011C htbe oil, and tr arrina and~ LCO 3.8.2, stored diesel fuel oilflube m i ana martSne (continued) CEOG STS B 3.8-42 Rev 1, 04/07/95

. ~. Diesel fu*1011Gube Wand stuffna Air] h 8 3.8.3 iA$ts CD r'fA)$fRf APPLICABILITY re utred to be within limits when the associated DG (continued) s requir to be OPERABLt. ACTIONS The ACTIONS Table 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. 4 /,,/ gf 1[B 2. c.I. e.L a=1 f. M cdon U /4;/,g. I In this Condition,ltht 7 day fuel oil supply for a DG is not availa ile. However',v".h te.-uion.. m.,3,Mmeltion is mmJLa to rue 2lJ 6 eh om roe,rd intain.t i.ast. .u.oiv l Musue di% wil These circumstances may be caused by events such as full load operation required after an inadvertent start while at p i provide, sdhdtd etpodtI minimum required level; increasing particulate levels or any or feed-and bleed operations, which may be necessitated by U 0/'"'k

M number of other oil: quality degradations.':This restriction

/ og allows sufficient time for obtaining the requisite -

on o n, l d Eap I*4 ",g replacement volume and performing.the analyses required prior to addition of fuel oil to the tank. A period of ou D6 44, aM 48 hours is considered sufficient to complete restoration of the required level prior to declarin va,f ** SNA. ThisperiodisacceptablebasedontbtheDGinoperable. I remaining capacity ( Ioa al* [n aNroMt)(. o.atn replenishment, and the low probability of an event I f 6 days) the fact that procedures will be initiated to C} so b hf. j during this brief period. y} b With lube 01 inventory < 500 gal, ufficient lubricating oli to sup rt 7 days of continuo DG operation at full load con tions may not be avat le. However, the Conditi is restricted to lu cil volume reductions at maint n at least a 6 day su ly. This restriction a ows suf cient time to obtain t requisite replacement alume, r l A erlod of 48 hours is c sidered sufftetent to lete ) 8 gggy be k O 5 (continued) e l CECG STS B 3.8-43 Rev 1, 04/07/95

k BASES INSERT APPL

For both Unit 1 and Unit 2, the F0ST 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 cay tank provides sufficient volume for the DG to perform its safety. function while re-alignment is accomplished, if necessary.w BASES INSERT A. B. & C Condition A addresses only FOST 1A which is " tornado protected" and which k ~ 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 p'ower 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. FOST 21 . supports both Unit 1 and Unit 2 equipment. but Condition B is written for Unit 1~ only to reflect the Unit 1 requirements for 'vh 18 and 28. For an accident. Unit 1 requires-either DG 1A or beth DGs 1B and29 (since DG 2B powers equipment which is redundant to stme equipment powered by DG 1A, e.g., CREVS. Since DG 1A is supported by F0ST 1A and the redundant required equipment is powered by DGs 18 and 28 which are supported by F0ST_21. at least one full train of required equipment is supported by a " tornado protected" F0ST even with an inoperable F0ST 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 OPERABLE FOST 11 to be verified to be greater than 6/7 cf the required - volume within 1 hour. The Completion Time of 1 hour 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 hours. 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 periedic surveillance of available DG fuel oil volume for the inoperable FOST 21. Since F0ST 11 is not required by the LCO. F0ST 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 capule 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 33,000 gallons reserved for emergency.DG use to 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-1 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 OGs 1A and 2A (since DG 1A powers equipment which is redundant to some equipment powered by DG 28, 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 F0ST 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 F0ST 21 can only be. supplemented by the fuel oil volume of an OPERABLE F0ST 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 F0ST 21 are very similar to the Unit I requirements for inoperability of F0ST 21._ It-is acceptable for the combined volume of F0ST 11 and F0ST 21 to be considered in providing 6/7 of the required volume for the 48 hours allowed by Required: Action C.3. Required Action C.1 ~ requires the combined volume of F0ST 21 and an OPERABLE F0ST 11 to be verified to be greater than 6/7.of the required-volume within 1 hcur. Required Action C.3 then requires the volume of.F0ST 21' to be restored to within volume limits within 48 hours. -However, during= tornado season, i.e.. from April 1 to September _30, the fuel oil volume of FOST 11 is not illowed to be credited and the fuel oil 7 day volume of FOST 21 must be restored within 2 hours 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 F0ST 11 is determined as described above in the discussion for Condition B. t 7-w .e

_~ ~ Otesel Fuel 011 Lube 011; and Starting Air B 3.8.3 BASES ACTIONS f L1 (coat )( restera on of the requirsd volume fortodeclaringtheOGI inoper le.' This period is acc '. vesed on the i low rate of usage, t = thNcapacity(>6d$)I resa procedures wil1 lated to obtain fa r enishment, and the low p 111ty of an event dur is brief period. h ^ S This Condition is entered as a result f a failure to meet the acceptance criterion of SR 3.8.3. Nomally, trending of particulate levels allows sufficient time to correct high particulate levels prior to reaching the limit of acceptability. Poorsampleprocedures(bottoasaapilng), contaminated sampling equipment, and errors in laboratory analysis can pmduce failures that do not follow a trend.- Since the presence of particulates does not mean fa11ere of-the fuel oil to burn properly in the diesel engine,- and t - particulate concentration is unlikely to change significantly between Surveillance Frequency intervals; and - proper engine perfomance has been recently demonstrated. -(within 31 days), it is prudent to allow a brief periodF prior to declarine the associated DG;inoperableQThe 7:dayr Completion Time allows for further evaluation, resampling.c and re-analysis of the DG fuel ell ? b a With the fuel oil properties defined in the Bases for SR 3.8.3. not within the required limits, a period of 30 days is allowed for restoring the stored fuel ott rtiew This period provides sufficient time to test 6re~d fuel oil to detemine that the new fuel oil, when +a w h &. a1xed with previously stored fuel oil, remains acceptable, h Mw &l mi or restore the stored fuel oil oroperties, This restoration /** h may involve feed anc oleoa procedures, filtering, or combinations of these procedures. Even 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 Itke11 hood that the DG would stP1 be capable of performing its intended function. (continued) CEOG STS B 3.8-44 Rev 1, 04/07/95 ~ --- v.-

= /. i t Diesel Fuel Dil, Lube Dil, and Starting Air B 3.8.3 BASES ACTIONS Ed -9 Q9 (continued) l With starting tr elver pressure 4 '225] ;;'; ufficient capacity for successive DG start attempts s not exist. However as long as the receiver press e is >[125]psig, here is adequate capacity for least one start att , and the DG can be considered ERABLE while the air re tver pressJre is restored to t required limit. A period f 48 hours is considered suffic nt to complete restora on to the required pressure pri to declaring the DG ino rable. This period is acceptab based on the ing air start capacity the fac hat most DG starts. resa are, ccomplished on the firsl atteep and the low ppbabilityofaneventduringthis rief period. I:51 ) With a Required Action and associated Completion Time net 3 l l 933*ciated DGI4a met f or one or more DGs with diesel fuel c11( mes ovoD - are Identi4tel in de not within 1imits for reasons other I than addressed by Conditions A thnugh En the associated DG b N'AM EdM* may be incapable of perforal its intended function and Pt 3 must be immerlistely declared noperable.Q y g m SURVEI'LLANCE SR

3. 8 3.'1 -

REQUIREMENTS M M *N This SR provides vertiteation a ere s an adequate inventory of' fuel oil in the torage tanks to support 4 @ uY ea. cc, A-/- .m_, for 7 days St.2pHeef. The 7 day period is M we sufficient time to place th: unit in a safe shutdown /,* 4 dal #^8 * *i condition and to bring in replenishatnt fuel free an offsite Oh S Q ) m jo,j, location. The 31 day Frequency is adequate to ensure that a sufficient supply of fuel oil is available, since low level alams are provided and unit operators would be aware of any large uses of fuel oil during this period. 3.BA2 { 1 SR 0 Thi urveillance ensures that fficient lube oil.inve ry i vallable to support.at t 7 days cf full lead (continued) CEOG STS B 3.8-45 Rev 1, 04/07/95 s,

Diesel Fuel 011, Lube Oil, and Starting Air 8 3.8.3 BASES SURVEILLANCE 3 3.a.3.2 (continu 1 REQUIREMENTS .ir consumptio]n values forgal requirene is based The[500 ac e run time on the DG mapufac it in this SR is the requi nt to verify the capabi1 R,ap1 transfer the lube oil f its storage of the DG. location to t DG, when the DG lube oil s does not hold adequate iny tory for 7 days of full los operation without the level r chthg the manufacturer roc nded minimum levely A 31 d Frequency is adequate to ens e that a sufficient lube supply is onsite, since'DG arts and ran time are @ s y monitored by the unit staf SR 3.a.3 ,tb er abio.o,sul a The tests Itsted below are a means of determining whether o4E "d(#g'# new fuel oil is of the appropriate gra7eband has not been pf, A ,1 refersu.ct$ +0 ASTN 2D contaminated with substances that would have na immediate, Q/o fwel oi\\ jndwde bon detrimental itsact on diesel engine combustion.4 If results - I from these tests are within acceptable limits, the fuel oil (2,bedEble.o.rulb"' 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 t)me between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limits, and applicable ASTM Standards are as follows: a. Sample the new fuel oil in accordance with ASTM h o'@ h 1995 b. Verify in accord a with the tests s ecified i ASTM 2, gg, 0975 M (Raf, that the sample s an abso ute q specific gravit at 60/60'F of 1 0 and s or z, 3 1 at API gravity at 60'F of 2

and s G', a nematic I

at istokes kd s 4.1 viscosit{es, 40'C of k 1.9 ce centisto and a flash point 125'F; ano g c. Verify that the new fuel oil has K ci r ano ongnt -- EtNTYD tb [/ d O'O bAYI.O.wb S b neNt.. (as-r x w q w - 199 Q. e (continued) CE0C STS B 3.8-46 Rev 1, 04/07/95

.= -. - - _ ~ Diesel Fuel 011, Lube Oil, and Starting Air 8 3.8.3 i BA$ES SURVE!LLAleCE ER 3.3.3. (continued) REQUIRDIENTS 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 LC0 concern since the fuel oil is not added to the storage tanks. Within 31 days following the initial new fuel oil sample' M9 6' to ties fuel oil is analyzed to establish that the othe properties specified in Table 1 of ASTM 0975-(Ref. are met for new fuel oil. T r

e + d i= **** *
with

(=r' gE.. Asm ;;;7", ' .n.iya is 3 .u..

nulfu, L

a tith ETM 0 1] JRaf.Nr ASEi m-D2622-f (Raf. /The31sayperion 3 acceptable because the fuel otl p wrties of interest, even if they were not withtA~ stated limits, would not hue an immediate effect on DG operation. This Surveillance ensures the availability of high quality fuel oil for the DGs. I i Fuel oil degradation during long tens storage shows up as an increase in particulate, due mostly to oxidation. The presence of particulate does not man the fuel oil wil(l not burn properly in a diesel engine. The particulate cat cause fouling of. filters and fuel of) injection equipment, however, which car cause engine failure. SUo Particulate concennrations should be determined Mdg5$5haseckn / ccordane th ASMuo- ~ I M non a mem M Ts) g/or' b f 10 l ASTPtbt17(,,-lqpq} tiiith ' veWFWgrammetr ic co.wrwinar onior sotal ? particulate concentration in theTTuel oi'~4nd has a limit of [l8,24' to ag/1. It is acceptable to olitain a field sample for a26 subsequent laboratory testing in lieu of field testina. bAA LIS-tWe eP-* "M~ " the total stored fuel 011' volume Qi is contained in two interec.inected tanks sust be considered andTested separately.f, each tank 7/w/c & 4 scesra-The Frequency of this test takes into consideration fuel oil /'ed.4/.s/v 7./.A degradation trends that indicate that particulate /er 4614 concentration is unlikely to change significantly between Frequency intervals. l (continued) CEOG STS B 3.8-47 Rev 1, 04/07/95 l l

Diesel Fuel Oil, Lube 011, and Starting Air-B 3.8.3 BASES SURVEILLANCE M.a.3.s 1 REQUIREMENTS N (continued) Draining of the fue oil stored in the supply tanks val of accumulated s ment, and tank cleaning are requ at 10 year interva by Regulatory Guide 3.137 (Ref. 9 paragraph 2.f This also requires the perfoma e of the UME Code, tion XI (Ref. 8), examinations the tanks. fM 1 44 f To preclud the introduction of surfactants the fuel oil

system, e cleaning should be accomplish using sodium hypochi te solutior.s. or their equival

, rather than soap detergents. This SR is for p ntative .a t enance. The presence of sedine does not necessarily r sent a failure of this SR. pr ded that accumulated 1 inent is removed durino perfo nee of the Surveillanceg dbhr6

1. hSAR, r=>"aa !?.5.0.G.

REFERENCES % Regulatory Guide 1;137. h, 3. ^."!! "!";-;"M f;; xf f" *- h h/.hSAR,Chapteri6[ /@FSAR, Chapter-gg lgg(, 7N M I l /. ASTN Standards: D4057- _ .D975- @h . ] {bsz-j; ucou- @ /. ASTM Standards, D975. Table 1. 4. r =, s. n u..a r. a = = e -i c a. - - -ena t l l' l l l l CEOG STS B 3.8-49 Rev 1, 04/07/95 ( l i l

DISCUSSION OF BASES 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. The NUREG-1432 Bases for SR 3.8.13 states that the reason for precluding performance of the DG load run Surveillance on more than one DG at a time is to avoid common cause failuras that might result for offsite circuit or grid perturbations. His statement implies that the DGs can never be paralleled to the grid simultaneously even if Calvert Cliffs is not performing this Surveillance, since the reasons listed would apply when paralleling the DGs to the grid for a reason other than performing this Surveillance. His Note only applies to performing this Surveillance: it does not preclude Calvert Cliffs from paralleling to the grid more than one DG simultaneously for reasons other than performing 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. Therefore, 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. The Bases for NUREG 1432 SR 3.833 indicatepat fuel oil particulate concentrations should be determined "in accordance with ASTM D2276-[ ), Method A (Ref. 6). His method involves a gravimet+ determination of total particulate concentration in the fuel oil. " This Base statement is revised to read: " Particulate concentrations should be detennined by gravimetric' analysis (based on ASTM D2276-1989) of total particulate concentration in the fuel (oil....:."- Calvert Cliffs has included the requirement to test for particulates in SR 3.83.2, but the testing is' not in full accordance with ASTM D2276 [ ], Method A. As indicated in the change, total-particulate concentration is determined by gravimetric analysis based on ASTM D2276-1989. However, ASTM D2276 Method A-2 is a test method for fuel systems under pressure. He 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 A3 method are evaluated and determined to not impact the ability of the method to provide accurate results. These deviations are: The reagents used are different: Calvert Cliffs uses iso-octane, while the ASTM requires n. freon (1,1,2-trichloro-1,22-trifluoroethane) and petroleum ether. A filter dispenser is not always used, as Calvert Cliffs purchases ultra-pure reagents for use in this analysis, b. The preparation, handling and storage of apparatus is different: Removable glass supports are not used in petri dishes. The 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. The apparatus used is prepared just prior to use, thus the equipment is not plastic 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 1 & 2 3.8-4 Revision 10

l DISCUSSION OF DASES DEVIATIONS FROM NUREG-1432 l SECTION 3.8 - ELECTRICAL POWER SYSTEMS c. He sampling is different. Calvert Cliffs samples in accordance with ASTM D4037. Calvert Clifts also uses less than the 3.785 - 5 liter sample volume suggested in ASTM D2276. De sample vohmic is measured prior to filtering. The 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 lirr.its are used 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 fuci oil. Specifically, the emergency DGs require between 19,810 BTU /lbm and 19350 BTU /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. Rese are based on a conversion of: API gravity = (141.5/ specific gravity)- 131.5 The Bases for NUREG-1432 SR 3.8.3.3 state: " Verify the new fuel oil has a clear and bright appeart.nce with proper color when tested in accordance with ASTM D4176-{ ] (Ref. 6)." The " clear and bright appearance with proper color" parameter is not currenJy a requirement for determining acceptability of emergency DG fuel oil at Calvert Cliffs because the fuel oil is dyed. Rather, a " water and 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. Herefore, this requirement is retained with a limit of 0.05% based on ASTM D975-1996 (the latest revision), and the " clear and bright" Bases statement is replaced with a " water and sediment" requirement and reference. ne 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 DMS 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 ASTM D1552-{ ] (Ref. 6) or ASTM D2622-{ ] (Ref. 6)." The IU 3.8.3.2 Bases will refer to ASTM D975-1996 for this testing which includes the exception for analysis of sulfur. Herefore, an additional reference to an " exception" to the standnd is unnecessary. However, the ASTM D975-1996 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 p-rfonnance discharge test in the NUREG-1432 Bases for SR 3.8.4.7 is moved to Calvert Cliffs ITS S~R 3.8.4.8 Bases. His 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 dischstge test being located in the description of the service test are deleted. In addition, the reasor, for the N( te to CALVERT CLIFFS - UNITS I & 2 3.8-5 Revision 10

2. He Current Technical Specification 3.1.1.2.b SHUTDOWN 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 Hazards Considerations were not used.

SDM 3.1.1 3.1. REACTIVITY CONTROL SYSTEMS -3.1.1 SHUTDOWN MARGIN (SDM) LCO 3.1.1 SDM shall be within limits as specified in the COLR, AND when in MODE 5 with pressurizer level < 90 inches, the reactor coolant system level shall be above the bottom of the hot leg to nozzles and all sources of non-borated water shall be s 88 gpm. APPLICABILITY: MODES 3, 4 and, 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. - - - - - -- - N OTE - - - - - - - - A.1

NOTE -------

Only applicable in Not required if MODE 5 with SHUTDOWN MARGIN has pressurizer level been increased to < 90 inches. compensate for the additional sources of io non-borated water. Non-borated water sources > 88 gpm. Suspend positive Immediately reactivity changes. AND CALVERT CLIFFS - UNITS 1 & 2 3.1.1-1 Revisionjito

SDM 3.1.1-ACTIONS (continued) CONDITION REQUIRED-ACTION . COMPLETION TIME _A. (continued) A.2 Initiate action to Immediately increase SHUTDOWN-MARGIN to compensate for the additional non-borated water sources. AND A.3 Verify SHUTDOWN Once per MARGIN has been 12 hours increased to IO compensate for the additional sources'of non-borated water. .B. -- - - ---- NOT E --- ---- - B.1 Suspend positive Imediately ."~ Only applicable in-reactivity charqes. ' 7' ,y: MODE'S with pressurizer level AND < 90 inches. B.2 Initiate action to Imediately increase reactor Reactor coolant coolant system level system level at or to above the bottom below the bottom of of the hot leg the hot leg nozzles. nozzles. C. SDM not within limit C1 Initiate boration to Immediately for reasons other restore SDM to within 'than Condition A or limit. ID B.- f s CALVERT CLIFFS - UNITS 1 & 2 3.1.1-2 Revisiong/o 4

SDM 3.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SDM is within limits specified in the 24 hours COLR. SR 3.1.1.2

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

Oniy required in MODE 5 with pressurizer level < 90 inches. Verify reactor coolant system level is above Once within the bot. tom of the hot leg nozzles. I hour after achieving MODE 5 with 10 pressurizer level < 90 inches AND 12 hours thereafter CALVERT CLIFFS - UNITS 1 & 2 3.1.1-3 Revision glo

. _ _ _.._. ~ ~ _ . - - _. ~ _ _. i ' l p i SDN i 3.1.1 4 t [URVEILLANCEREQUIREMENTS(continued)- l $'JRVEILLANCE FREQUENCY l i SR 3.1'.1.3

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

Only required in MODE 5.with pressurizer l 1evel.< 90 inches.- Verify non-borated water sources s 88 gpm. Once within 1 hour after-achieving 10 H00E 5 with pressurizer level < 90 inches ale ^ 12 hours thereafter i i + i r i .i 3 i 4 i e i CALVERTiCLIFFS. UNITS 1-&2 3.1.1-4 RevisionfIo. i e .u m...--.-,,1. ..l.,,w', ,+m ,vv-+-r- ,,y,..,.,_,-. -rv+,~,,1.-... ~, -,..-.-~~--r,--- ..n-,,--,-- ,w<,,-.-. ,.,-..,--.....-__--,-,,---r,,-.-,e

SDM B 3.1.1 BASES Depending on the system initial conditions and reactivity insertion rate, the uncontrolled CEA withdrawal transient is teminated by either a high power trip or a high pressurizer pressure trip. In all cases, power level, RCS pressure. linear heat rate, and the DNBR do not exceed allowable limits. Shutdown margin satisfies 10 CFR 50.36(c)(2)(ii), Criterion 2. LCO The MSLB and the boron dilution accidents (Ref. 3) aN the most limiting analyses that establish the SDM value of the LCO. For MSLB accidents, '.f the LCO is violated, there is a potential to exceed the DNb.1 limit and to exceed tha g acceptance criteria given in the UFSAR (Ref. 3). For the boton dilution accident, if the LCO is violated, then the minimum required time assumed for operator action to terminate dilution may no longer be applicable. Because both initial reactor coolant system level and the dilution-flow rate also signifiantly impact the boron dilution event to in MODE 5 with pressurizer level < 90 inches from the bottom of the pressurizer, the LC0 also includes limit:1 for these parameters during these conditions. Shutdown margin is a core physics design condition that can be ensured through CEA positioning (regulating and si tdown CEA) in MODES 1 and 2 and through the soluble boron concentration in all other MODES. APPLICABILITY In MODES 3, 4, and 5, the SDM requirements are applicable to provide sufficient rsgative reactivity to meet the assumptions of the safety analyses discussed above. In MODES 1 and 2, SDM is ensured by complying with LCO 3.1.5, "ShutdownControlElementAssembly(CEA)InsertionLimits," and LCO 3.1.6, " Regulating Control Element Assembly (CEA) i l-CALVERT CLIFFS - UNITS 1 & 2-B 3.1.1-4 Revision E/o

5 SDM B 3.1.1 BASES Insertion Limits." In MODE 6, the shutdown reactivity requirements are given in LCO 3.9.1, ' Boron Concentration." l ACTIONS A.I. A.2. and A.3 With non-borated water sources of > 88 gpm available, while the unit is in MODE 5 with the pressurizer level < 90 inches, the consequences of a boron dilution event may exceed the analysis results. Therefore, action must be initiated immediately to reduce the potential for such an event. To accomplish this, Required Action A.1 requires immediate suspension of positive reactivity additions. However, since Required Action A.1 only reduces the potential for the event and does not eliminate it, immediate action must also be initiated to increase the SHUTDOWN MARGIN to compensate for the non-borated water sources (RequiredActionA.2). Finally, Required Action A.3 requires periodic verification,-once per 12 hours, that the SHUTDOWN MARGIN im.rease is maintained sufficient tot compensate' for the additional sources of non; borated water. IcW Required Action A.1 is modified by a Note which indicates that the suspension of positive reactivity additions is not required if SHUTDOWN MARGIN has been sufficiently increased to compensate for the additional sources of non-borated water. The insnediate Comple+1on Time reflects the urgency of the corrective actions. The periodic Completion Time of 12 hours is considered reasonable, based on other administrative controls available and operating experience. B.1 and B.2 With the reactor coolant system level at or below the bottom of the hot leg nozzles, while the unit is in MODE 5 with the pressurizer level < 90 inches, the consequences of a boron dilution event may exceed the analysis results. Therefore, I action must be initiated immediately to reduce the potential for such an event. To accomplish this, Required Action B.1 l l l CALVERT CLIFFS - UNITS 1 & 2 B 3.1.1-5 Revision #/o

SDH B 3.1.1 BASES requires immediate respension of positive reactivity additions. However, since Required Action B.1 only reduces the potential for the event and does not elia:inate it, insnediate action must also be initiated to increase the 10 reactor coolant system level to above the bottom of the hot legnozzles(RequiredActionB.2). The imediate Completion Time reflects the urgency of the corrective actions. Ed If the SDH requirements are not met for reasons other than addressed in Condition A or 8, boration must be initiated promptly. A Completion Time of 1 mediately is required to meet the assumptions of the safny analysis. It is assumed that boration will be continued ur,il the SDH requirements are met. In the determination of the required combination of boration flow rate and boron concentration, there is no unique requirement that must be satisfied. -Since it is imperative to raise the boron concentration of the RCS as soon as possible, the boron concentration should be a highly concentrated solution, such as that normally found in the boric acid storage tank or the refueling water tank. The operator should borate with the best source available for the plant conditions. However, as a minimum, the boration flow rate shall be h 40 gpm and the boron concentration L/ shall be 2 2300 ppm boric acid solution or equivalent. Assuming that a value of 1% Ak/k must be recovered and a boration flow rate of 40 gpm from the boric acid storage tank, it is possible to increase the boron con. centration of the RCS by 100 ppm in approximately 15 minutes. If an inverseboronworthof100 ppm /% is assumed, this combination of parameters will increase the SDM by 1% Ak/k. These boration parameters of 40 gpm and 100 ppm represent cal. VERT CllffS - UNITS 1 & 2 B 3.1.1-6 Revision 9jo

SDM B 3.1.1 t BASES I 1B_L1.1.2 and SR 3.1.1.3 These Surve111ences periodically verify the significant assumptions of a boron dilution event are maintained. A non-borated water source of s 88 gpm allows for only one charging pump to be capable of injection during these conditions since each charging pump is capable of an injection rate of 46 gpm. Each Surveillance is modified by a Note which indicates that it is only required when the i unit is in MODE 5 with the pressurizer level < 90 inches. Since the applicable conditions for the Surveillance may be 10 attained while already in MODE 5, each Surveillance is provided with a frequency of once within one hour after achieving MODE 5 with pressurizer level < 90 inches. This provides a short period of time to verify compliance after the conditions are attained. Additionally, each Surveillance must be completed once each 12 hours after the initial verification. The Frequency of 12 hours is considered reasonable, in view of other administrative controls available, and operating experience. - REFERENCES 1. UFSAR Appendix IC 2. UFSAR, Section 3.4 3. UFSAR, Chapter 14 CALVERT CLIFFS - UNITS 1 & 2 B 3.1.1-8 Revision # /o

S pac. Cet Mu b l. \\ i .3 1 4/+rt' REACTIVITY CONTROL SY$Tfg 1/',9 maestinn enutant (gggg) g N E 8IN 3, ), l y + i, J h LIMIT!!fG CONDITION FOR OPERA',lM 4.3.4,3-The $NVfDOWN MR$!N shall be within the 11m11 provided in 4he LCO I+bl _ gp*3 COLR. Thd' when pressurifg,l'< vel is less~ than CO inchelf trm sag poj.e m X u i nr tMistarT;* gall, sources of non borated water shall be 5; M ppm. /0 APPLICABillTY: MODE 5. '8 d U' 4'M I'"WU *" "E N'I ]\\ejehem ok 4ht kot (tq nettles and ACTION:

a. With the $NUTDOWN NARGIN outside the limit A'"*C i = 8 ' "' d a"" t"a' =" ~"6o"" o" d in the etLR, l

3 '- a ' 28 68 GM boric ac7U Eolupon y eQulvaIRht'Eli[1 The required $WV100WN NARGIN is restored. b.~With the pressuriter drained to < 90 inches and all sources of N A0TN b non borated water > 88 ps f amedittely suspend all operations involving positive renc ivlty changes while the $NUTDOWN MARGIN is increased to compensate for the additional sources of non. borated waterfor ef5uce)fft sougn o(,sfDn.bp(ted waM to3-08 f V9VI % d E t. T n w A c tub rJ 8) V SURVEILtlNCEREQUIREMENTS ift.3\\.{.l 44,$,2.1. The $HUTDOWN MAGIN shall be determined to within the limit provided in the COLRs 'a. Within one ur af ter detection of a inoperableCEA(s)and l least one per 12 hours thereafter iletheCEA(s)is /),q inope e. If the inoperable C is untrippable. the abo e requi $NUTDOWN NARGIN shall increased by an amount t least; unum) te the withdrawn wneth the untrbnnble f[Af t)f % At least once per 24 hours)y "nsideration of th cllowing \\ f 1 1. .eactor Coolant S CEA position., yst boron concentra n) 2 CALVERT CLIFFS - UNIT 1 3/4 1 3 Amendment No. 186 p Acf 3 'I $

t INSERT new ACTION B i hl B.. ........N0TE--------- B.1 ^ Suspend positive Immediately Only applicable in. reactivity changes. MODE 5 with - pressurizer level MD < 90 inches. B.2 Initiate action to Immediately i increase reactor Reactor coolant system coolant system level i level at or below the to above the bottom- . bottom of the hot leg of the hot leg

nozzles, nozzles, j

k t e i f k E I l I i i f(t O ---.._a._.....,_ .____..-_...,-.~.--.m.,-,_,..,_.,~ .-,,-,m, -,- -,--.,,,._,... - w m.-._,

6.i #e. A,. a /, / 3/4.1 REACTIVITY C NTROL SYSTEMS SWRYt!LLAllCE REQUIRDetNTS (Continued) I

i. Rea r Coolant $yst 6verag'e t reture.

g,q 4. T burnup based o gross the energygenerettend 5. non concentrattatIonnd[ a 6. Samarite concen L 4.1.1.2.2 With the pressuriser drained to < 90 inches dete$ibes g 3*g*g*g

a. Within one hour and every 12 hours thereaf ter that the level in the Reactor Coolant System is above the bottom of the hot leg

/, - ncztles. and si 3,l, g,3 b. Within one hour and every 12 hours thereafter that the sources of -- non borated water are _< 4 comier une nauwvun musan has oeen increases to compensate 'or the additional non borated water ACTff*JO sources. e 9 -1 . yt - 9 + t i l CALVERT CLIFF $ - UNIT 1 3/4 1 4 Amendment No. 186 l fQ 6 db

I h e e M e = tie 3. I. l 3.I -5/44. REACT!YITY CONTROL SYSTDt$

v. s. t h-Wenri-B0PATION. CONTROL O%J CD rm.-

=

Litt!T!uG COWITIN FOR OPttATIM ( C.o '5.t.) 04.1,0'n(The SWT90WI HAAGIN shall be within the Itait provided in the __ COLR, s _yhen pressurf aer level in less than 90 inches ffmedi bgMbe## g (pJerurfzarull sources of non borated water shall be 5 as eps. APPLICABILITY: M00Z 5. c rmfer uplot syshm level shdl bc. Q eVp Oc beltM of &o kt leponlet m_d k $110118 M10W D With the SWT90W MARGIN outside the limit provided in the COLR, lh a. 1enediately intilate and continue boration n u n a S .. m,e svi m,....memp1Fntti the required VTDOWI puumsu is restored. b. With the pressurtzer drained to < 90 inches and all sources of non-borated water > M SIty changes while the $WTDOW MARGIN gO M g tenedtately suspend all operations involving posttive reac is increased to_ compensate for the additional sources of non. % rated waterfosoecurytne socces nMort.beated t;attr) f [M 88#. f ~ &il%SO.TneioActiow2] h $URVEILLANCE ret lUIRDIDITS % 7.1.l') .i.i.4.2.1 The SMTD0tal NARGIN shall be deterutned to bs within the Iteit provided in the COLRs er while the CCA(s)ks) and at Within hour after detection an inoperable C least ce ino. able.per 12 hours there is If the inopera CEA is untrippable, t above utred SWTIWAi MARGIN 11 be increased by an unt at least ual to the withdrawn rth of the untrippable A(s g) h At least once w 24 houj7c sideration of the fo owint qactors } fLd. , 1. eactor Coolant Syst oron concentration, y CEA position, f l t j CALVERT CLIFFS - UNIT.2 3/4 1 3 Amendment No. 163 y a F.5M 1

i INSERT new ACTION B i B.-

NOTE----------

B.1 - Suspend positive Immediately { Only applicable in reactivity changes. MODE 5 with pressurizer level 6ND l < 90 inches, B.2 - Initiate action to Imediately increase reactor -Reactor coolant system coolant system level level at or below the to above the bottom I bottom of the hot leg of the hot leg _ nozzles, nozzles. e r h 5 m T 4 g' ,T .y I c t i =

a pe e [i r gtie T. I. l 3/4.1 REACTIVITY CONTROL SY$TDi$ SilRVEILLAllCE REQUIRDWITS (Cestinued)

5. Rea r cociant aystem evere temperature.

(4. F burnup based on press naal energy gener ton g 4* 5. enon concentration a f SamariumconcenytI f 4.1.1.2.2 With the pressuriaer drained to < 90 inches determine:

a. Within one hour and every 12 hurs thereafter that the level in gg 3'3';'g the Reactor Coolant System is above the bottom of the hot les nozzles, and gg 3,l,1,3 b.

Within one hour and every 12 hours thereafter that the anucces of non borated water att 5 85 spetor the 518UTDOWil NAAGIN has been increased to compensate for the additional non-borated water sources. g,g A CALVERT CLIFF $ - UNIT 2 3/41-4 Amendment No. 163 l l b* O 9

DISCUSEON OF CHANGES I SECTION 3.1.1 - SHUTDOWN MARGIN ADMINISTRATIVE CilANGES A.1 he proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change of intent, to be consistent with NUREG 1432, " Standard l Technical Specifications, Combustion Engineering Plants." 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 Improved Technical Specifications (ITS) development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more i fully describe each Limiting Condition for Operation (LCO) and to be consistent with NUREG 1432. However, the additional information does not change the intent of the current Technical Specifications, ne reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Current Technical Specification (CTS) Surveillance Requirements (SRs) 4.1.1.1.1.a and 4.1.1.2.1.a require that the Shutdown Margin (SDM) be increased by at least the amount equal to the withdrawn worth of the untrippable control element assembly (CEA) within I hour after the CEA is inoperable, and every 12 hours thereafter. Improved Technical Specification 3.1.1, will not require this requirement because this condition is required to be accounted for in the definition of SDM. He definition requires the calculation of SDM to-account for any CEA not capable of being fully inserted. Herefore, this change is administrative because appropriate Actions exist elsewhere in the ITS that address this condition, nis change is consistent with NUREG-1432. A.3 Current Technical Specifications 3.1.1.1 and 3.1.1.2 (SDM T,y, > 200*F and SDM T.y, s200'F, respectively) are being combined into one Technical Specification in ITS 3.1.1. He LCO Actions and SRs are identical; therefore, combining the two Specifications is logical. Combining Technical Specifications, while retaining requirements, constitutes an administrative change. His change is consistent with NUREG 1432, TSTF.136. A4 Current Technical Specification 4.1.1.1.1.b requires the SDM to be detennined by verifying the CEA groups are within the power dependent insertion limits (PDILs) when in Modes 1 and 2 with 14r 21.0. His requirement is being deleted because it exists in the Regulating CEA Insertion Limits Technical Specification (CTS 4.1.3.6 and ITS SR 3.1,6.1). The deletion of a requirement that exists in another Technical Specification constitutes an administrative change. His change is consistent with NUREG-1432. A.5 Current Technical Specification 3.1.1.2 Action b includes a final requirement option of "or reduce the sources of nen borated water to s 88 gpm." His is essentially an action to restore the parameter to within the limits required by the LCO. Since this is always an option, it need not be specifically delineated when other actions are also required. Herefore, this action is not specifically included in ITS 3.1.1. Ilowever, since it remains an option, the change is one of format only, and is therefore, administrative in nature. CALVERT CLil FS - UNITS I & 2 3.1.1 1 Revision 10

DISCUSSION OF CIIANGES SECTION 3.1.1. SilUTDOWN MARGIN IEC11NICAL CIIANGES - MORE NETTRICTIVE M.! Current Technical Specification 4.1.1.2.2.a includes requirement to periodically verify the RCS level is above the bottom of the hot leg n921es. His SR assures this initial assumption of a Boron Dilution Event is maintained in accordance with the analysis. Ilowever, the Current Technical Specification does not include an actual LCO requirement, nor an action to fulfill should the SR not be met. Herefore, the appropriate LCO requirements and Required Actions are incorporated for this SR. His change is consistent with the structural content requirements of the improved Technical Specifications, and with the current licensing basis. IECIINICAL CII ANGES. Rrti) CATIONS None TECHNICAL CIIANGES. MOVEMENT OF INFORMATION TO LICENSEE-CONTROI I En DOCUMENTS 1A.1 Current Technical Specifications 3.1.1.1 and 3.1.1.2 Actions require that boration be continued at 2 40 gpm of 2300 ppm boric acid solution or equivalent until the SDM is restored. nese specific procedural requirements regarding the rate of boration will be relocated to the Bases, nese details are not necessary to ensure the SliUTDOWN MARGIN will be restored to within the limit specified in the COLR. Improved Technical Specification 3.1.1 AC110N A, which requires action to be immediately initiated, is adequate for ensuring the SilUTDOWN h'ARGIN is restored. As such, these details associated with this Action are not necessary to be in the Technical Specifications to ensure the SilUTDOWN MARGIN is restored to within the limit in the COLR. Changes to tbc Bases will be controlled by the provisions of the Bases Control Program described in I Chapter 5 of the ITS His change is consistent with NUREG 1432. LA.2 Current Technical Specifications 4.1.1.1.1.c and 4.1.1.2.1.b require the SDM to be determined at least once per 24 hours by considering the following factors: boron i l concentration, CEA position, Reactor Coolant System (RCS) temperature, fuel burnup, and xenon and samarium concentration. The list of factors used to determine SDM is being moved to the Bases. Specific details on the calculation of the SDM is not appropriate for the Technical Specifications and can be adequately controlled in the Bases. Any changes to the Bases will be performed in accordance with ITS Section 5.0 Bases Control Program. The Bases Control Program will ensure that any changes to this requirement receive an appropriate review. This change is consistent with NUREG 1432. LA.3 Current Technical Specification 3.1.1.2 contains additional requirements associated with the pressurizer level and indicates that the pertinent pressuriter level is based on level measurement "from the bottom of the pressurizer " This detail of the requirement is being moved to the Improved Technical Specification Bases since it is not necessary to delineate the actual requirement. He ITS will rnaintain the requirements based on pressurizer level, with the Bases indicating that the required pressurizer level is based on measurement from the bottom of the pressurizer. He movement of this detail to the Bases as part of the conversion to NUREG 1432. Any changes to these requirements will be in accordance with the llases Control Program in Section 5.0 of the ITS. This will ensure that any chang,es to CALVERT Cl.lFFS - UNITS 1 & 2 3.1.1 2 Revision 10

1 DISCUSSION OF CHANGD!i SECTION 3.1.1 - SHUTDOWN MARGIN these requirements will be appropriately reviewed. This change is consistent with NUREG 1432. TEC11NICAL CILWGES ITM B53TRICTIVE L.1 Current Technical SpeelGeation 3.1.1.1 (SDM T,y > 200'F)is applicable in Modes 1,2,3, and 4. Improved Technical Speel0 cation 3.1.1 will require this SpeciHcation to be applicable in Modes 3 and 4. In Modes 1 and 2 the SDM is maintained within limits by complying with the CEA alignment limits for the Shutdown and Regulating CEA: in ITS 3.1.5 and 3.1.6, respectively. The CEA alignment limits do not apply in Modes 3 and 4, which is why the ITS 3.1.1 SDM requirement is needed. Eliminating plant conditions from the Mode of Applicability for Technical Specincations constitutes a less restrictive change. This change is consistent with NUREG 1432. In conjunction with this change, CTS 4.1.1.1.1.c and d will be deleted because they require an SDM calculation in Mode 2. These SRs will no longer be required because the SDM in Modes I and 2 are detennined by s *ifying the CEAs are within the PDILs. L,2 Not used. l l l CALVERT CLIFFS - UNITS 1 & 2 3.1.1 3 Revision 10 l

= - NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.1 - REAC1NITY CONTROL SYSTEMS t maintained by complying with the control element assembly (CEA) insertion limits Technical i Specifintions for the Shutdown and Regulating CEAs. His change is consistent with the assumptions relative to the mitigation of accidents or transients. He proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident prevluusly evaluated. I 2. Dow the change create the possibility of a new or different kind of accident from any accident previously evaluated? He proposed change revises the Modes of Applicability for the SDM T.,, > 200'F Technical Specification from Modes 1,2,3, and 4 to Modes 3 and 4. He SDM in Modes 1 and 2 will be ' maintained by complying with the CEA insertion limits Technical Specifications for the Shutdown ard Regulating CEAs, His change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction la a margin of safety? He proposed change revises the Modes of Applicability for the SDM T.,, > 200'F Technical Specification from Modes 1,2,3, and 4 to Modes 3 and 4. His change will not affect the SDM requirements because the SDM will be maintained in Modes 1 and 2 by complying with the Technical Specifications for shutdown and argulating CEA insertion limits. His change does not affect the SDM assumed in the safety analyses. Herefore, the proposed change does not involve a sic,nificant reduction in a margin of safety. ~ 11.1 Channe L,2 Not used. l AL2JChanscL1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? He proposed change will replace the cmrent Actions to immediately borate with Actions to perform an engineering evaluation and set up appropriate operating limits within seven days when the core reactivity balance is not within limits. He failure to borate during a readivity anomaly is not an initiator of any analyzed eveni. Tin!s change allows time to evaluate the reactivity anomaly, rather than borating to increase SDM, when the cause of the reactivity anomaly is not known. Horating may not resolve the reactivity anomaly. An engineering evaluation will resolve the problem by allowing the cause of the reactivity anomaly to be identified and the correct actions to be taken to resolve the reactivity anomaly. He engineering evaluation is required to be completed within seven days, which allows sufficient time to assess the physical condition of the reactor and complete the evaluation of the core design and safety analysis, if the evaluation determines the core is not unacceptable for continued operations or appropriate restrictions and Surveillance Requirements are not established, a unit shutdown will be required. His change will not significantly affect the assumptions relative to the mitigation of accidents or transients. %e proposed change does not significantly affect initiators or ' VERT CLilTS UNITS I & 2 3.1-6 Revision 10 mi-.- -:m m y y-g - y -w g y _ 97-g3m- --,.a_=a--- yeq

? g -

si r g3 6

$DN-(T J W'O M ap) [ CTS) 3.1.1 3.1 REACT!YlTY CONTROL SYSTEMS 3.1.1 $WTDOWN MARGIN ($DN)61J t#3)(AnelMt $0N shall be i " "': dl+kts llmili at spechted In Oc @h3 TJff*1 I 3.1. l. LC0 3.1.1 g. g g'{ f,;4.p,g g;,,e LI' l' h 4 , leve'. (AD 16 kes, Oe. ren+er coetat svs4fn b

* #0 15fF-L cou\\es A4 on""searces of vWherated APPLICABILITY:

MODES Tand j s2G (WaAer s kal\\ he. (f f 69 me _f ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME SONnotwithinItal[ ] Initiate boration to g (Aorreestuse4Eer \\'!)*I n1 (cmAttim A or B. j (.TtJ5Cf.T nesa ACTl0A).5 A 4 B $URVEILLANCE REQUIREMENTS $URVEILLANCE FREQUENCY git $hs.'WsFe 't..I Q ' }.l.l.7 l.b(] 4 4.1.1.l.l. c. $R 3.1.1.1 Verify $DN is g,_ -,. col (t 24 hours

0 d$f RT nese SR 3,l.12. d SR J.l.l.3 i

CEOG $15 3.1-1 Rev 1, 04/07/95 e.w -..,--,,-,7

INSERT 3.1.1 A.

- NOTE---------

A.1

NOTE ----- -

Only applicable in Not required if MODE 5 with SHUTDOWN MARGIN has pressurizer level been increased to < 90 inches. compensate for the additional sources of non borated water. Non borated water sources > 88 gpm. Suspend positive Imediately reactivity changes. MD A.2 Initiate action to Inunediately increase SHUTDOWN MARGIN to compensate for the additional non borated water f

sources, AND A.3 Verify SHIJTDOWN Once per MARGIN has been 12 hours increased to compensate for the additional sources of non borated water.

B.

NOTE----- ---

B.1 Suspend positive Immediately Only applicable in reactivity changes. MODE 5 with pressurizer level MD < 90 inches. B.2 Initiate action to Immediately increase reactor Reactor coolant system coolant system level level at or below the to above the bottom bottom of the hot leg of the hot leg nozzles. nozzles. i

INSERT 3.1.1 SR 3.1.1.2

NOTE----

Only equired in MODE 5 with pres:,urizer level < 90 inches. Verify reactor coolant system level Once within i is above the bottom of the hot leg 1 hour after nozzles. achieving MODE 5 with pressurizer level < 90 inches MD 12 hours thereafter SR 3.1.1.3

NOTE-------

Only required in H0DE 5 with 9:!"":'.'!:.'.!M.!.??"c":...... lA Verify non borated water sources Once within-s 88 gpm. I hour after achieving MODE 5 with pressurizer level < 90 inches MD 12 hours thereafter l l

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.1 - REACTIVITY CONTROL SYSTEMS j 8. ne specific Calvert Cliffs figure will replace the NUREG 1432 figure. 9. Not used. 10. Specification 3.1.6, " Shutdown CEA Insertion Limits," was changed to reflect that Calvert Cliffs' current licensing basis allows one Shutdown CEA to be withdrawn 2121.5 inches and < 129 inches. Ilowever, the time limit in this configuration is limited to s 7 days per occurrence, and s 14 days per 365 days. His change is acceptable for the short duration of time allowed because the Power Distribution Limit Technical Specifications in Section 3.2 will ensure that the power distribution limits will remain acceptable. If not, appropriate Actions will be entered. 11. De Note to ISTS SR 3.1.4.1 (ITS SR 3.1.3.1) and Note 2 to ISTS SR 3.1.4.2 (ITS l SR 3.1.3.2) have been deleted. He Notes state that the SR does not have to be performed prior to entering the Applicability of the LCO. Ilowever, the Note is not needed since the actual Frequencies for the two Surveillances already provided this allowance. Improved Technical Speelfication SR 3.0.4 states that entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. He Applicability ofITS 3.1.3 is MODES I and 2. Ilowever, the Frequency for the first SR includes the words " prior to entry into MODE 1" and the Frequency of the second SR is "each fuel cycle prior to reaching 47 EFPD." Each of these Frequencies allows entry into the Applicability of the LCO, without the use of a special note. In addition, the Bases for ITS SR 3.0.4 describes this concept, and ITS 1.4 provides an example (Example 1.4-2) where this type of I requency is used. Herefore, the addition of these Notes is not necessary and their deletion is consistent with current licensing basis (He CTS does not have these notes). $. 12. He words in ISTS SR 3.1.4.1 (ITS SR 3.1.3.1) describing the location where the MTC upper limit is specified (i.e., COLR) has been deleted. Improved Standard Technical Specification LCO 3.1.4 (ITS LCO 3.1.3) requires the upper limit to be within the limit specified not only in the COLR, but also within the maximum positive limit specified in ISTS Figure 3.1,41 (ITS Figure 3.1.3-1). Herefore, to remove any ambiguity, the SR now reads " Verify MTC is within the upper limit." 13. Improved Standard Technical Specification SR 3.1.7.1 (ITS SR 3.1.6.1) has a Note that l l allows entry into MODE 2 without having the Surveillance current (i.e., entry into MODE 2 is allowed without performing the SR within the previous 12 hours, as required by ITS SR 3.0.4). The Bases for this Note states that this is allowance is needed since the unit must be in the Applicable MODES in order to perform the Surveillance. Calvert Cliffs can perform this Surveillance, to verify each regulating CEA group position is within its i insertion limit, prior to entering MODE 2. The only CEA insertion limit applicable in MODE 2 is the transient insertion limits, and these can be verified prior to entering MODE 2 (i.e., while the unit is in MODE 3). Therefore, this Note allowance is not necessa;y and has not been included in the ITS. This is also consistent with the current Calved Cliffs licensing basis (this allowance is not in the Current Technical Specifications). 14. Improved Standard Technical Specification 3.1.5.1 ACTION A requires power reduction to 70% RTP within I hour and CEA alignment restoration within 2 hours when one or more i 1 CALVERT CLIFFS - UNITS 1 & 2 3.1 2 Revision 10

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.1 - REACTIVITY CONTROL SYSTEMS I CEAs are misaligned by >7.5 inches and s 15 inches or when one CEA is misaligned by > 15 inches. Under the same conditions, the Calvert Cliffs CTS (CTS 3.1.3.1 Actions e, f, and g) requires restoration within I hour for CEAs misaligned > 7.5 inches and s 15 inches and within the time specified in the COLR (or by the full core monitoring system) for CEAs misaligned > 15 inches, and if not restored, allows an additional 2 hours to restore alignment provided power is reduced within I hour. Improved Technical Specification 3.1.4 has been modified to reflect the current Calvert Cliffs allowance. Improved Technical Specification 3.1.4 AC110NS A and B have been added to provide this additional time prior to requiring a power reduction. Improved Technical Specification 3.1.4 ACTION C is the default Condition if the CEA is not restored to within its alignment limits. Improved Technical Spe:ification 3.1.4 ACTION C is essentially ISTS 3.1.5.1 ACTION A, modified i I by approved /pending TSTF changes. Due to the addition of these new ACTIONS, the subsequent ACTIONS have been renumbered, where appropriate. 15. ne first froquency of NUREG 1432 SR 3.1.4.2 requires verification that MTC is within the lower limit specified in the COLR "Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core burnup." He first frequency ofITS SR 3.1.3.2 requires verification that MTC is within the lower limit specified in the COLR "Each fuel cycle within 7 EFPD of initially reaching an equilibrium condition with THERMAL POWER 2 90% RTP." nis change to the first frequency is consistent with the Calvert Cliffs current licensing basis reflected in CTS 4.1.1.4.2.b and has been shown to be adequate, based operating experience, for ensuring MTC is maintained within limits. 16. NUREO 3.1.1 is. revised < to incorporate the requirements o' Current Technical Specification 3/4.1.1.2..;nese changes include 1an addition to the LCO, and associated ' Actions ~and Surveillan'cesalti' MODE'5, the most limiting event with regard to reactivity control is a Boron. Dilution Event with the pressurizer level <90 inches. The initial conditions for the event include a reactor coolant system level above the bottom of the hot leg nozzles, and the sources of non-borated water restricted to s 88 gpm. He CTS requirements provide assurance that the available Shutdown Margin will exceed the most limiting MODE 5 Shutdown Margin requirement at any time in the cycle. These changes are consistent with current licensing basis. CALVER'. dE,lFFS - UNITS 1 & 2 3.1-3 Revision 10

I57f*I34 SDMET4)60'fWf B3.1.1 BA$ES therefore/produceaydurnth g APPLICABLE An idle RC annot SAFETY ANALYSE *, r from the stand condit)6n.f (continued) $DM satisfies Criterton 2 of the NRC Policy Statement. LC0 The MSLB M4 and the boron dilution Ref. I accidents + are the mo'It lie ting analyses that estab s e 50M value of the LCO. For MSLB accidents if the LC0 is violated, re is a potential to exceed he DNBA limit and to exceed 74 **'effovst Iou. Reac = m a-Er n ri-N = n mar 4 P. For /N c r dn'a ss l,, the boron dilution accident, if the LC0 is violated, then LLJ the etnimum required time assumed for o erator action to g), m,gg g gyg g yj teminate dilution may no longer be app icable.*y ' JMT[ SDM is a core p ysics design condition that can be en fed l through CEA pos tioning (regulating and shutdown CEA) and i , LC o through 'be soluble boron concentratio, l 2 APPLICABILITY In MODES 3 the SDM requirements are appitcable to TMI'I3 5 provide sufficient negative reactivity to meet the I assumptions of the safety anal ses discussed above. In MODES I and 2 SDM is ensured complying with LCO 3.1 T57f-/34 1 Element Asse 1v (CEA) Insertion tielts.' an If the i ertion limits or 3.1.5 or aut ically violat The SDM must calculated by I57f 67 i Lco J. i are not bein complied with, 5 s not pe oming a react ity balance calcu ton (consider' i stad raictivit efforte in Rater tion M 3,1,1.f TS TF 134 gg)ff/tf H00[ 5, SDM is addrestad_ hy irn L t.2. 'sHU")gwN MARG N r 1 JSDM1-T_ g 200'F.*f in MODE 6 the shutdowff reactivity Db 6quirements are gwen in LCO 3.3.1, ' Boron Concentration.' L ACTI0lts Mk ((or tensons o Aer kw odAtested m d,,vlf.en_/l er B) If the SDM requirements are not metf boration must be s mne hu h 'is, re y'v' d initiated promptly. A Completion Time ofli5J,d start th('

r. etel W

.g g4 Rg or an operator surrectly a11 M n 'g" eau d svitems and . onents. 3 It is assumed that a ss...qb m 4 boration will be continued until tne SDM requirements are "'t' uM3 andpo. (continued) CE0G STS B 3.1-4 Rev1,04l07/95

BASES INSERT LCO Because both initial reactor coolant system level and the dilution flow rate also significantly impact the boron dilution event in M HODE 5 with pressurizer level < 90 inches from the bottom of the pressurizer, the LC0 also includes limits for these parameters during these conditions. \\ e 4 9

BASES INSERT ACTIONS A.1. A.2. and A.3 With non borated water sources of > 88 gpm available, while the unit is in MODE 5 with the pressurizer level < 90 inches, the consequences of a boron dilution event may exceed the analysis results. Therefore, action must be initiated immediately to reduce the potential for such an event. To accomplish this. Required Action A.1 requires imediate suspension of positive reactivity additions. However, since Required Action A.1 only reduces the potential for the event and does not eliminate it, imediate action must also be initiated to increase the SHUTDOWN MARGIN to compensate.for the non-borated water sources (Required Action A.2). Finally. Required Action A.3 requires periodic verification, once per 12 hours, that the SHUTDOWN MARGIN increase is maintained sufficient to compensate for the additional sources of non borated water. Required Action A.1 is modified by a Note which indicates that the suspension of positive reactivity additions is not required if SHUTDOWN MARGIN has been sufficiently increased to compensate,for the additional sources of non borated I water. The imediate Completion Time reflects the urgency of the corrective actions. The periodic Completion Time of 12 hours is considered reasonable, based on other administrative controls available and operating experience. B.1 and B.2 With the reactor coolant system level at or below the bottom of the hot leg nozzles, while the unit is in MODE 5 with the pressurizer level < 90 inches, the consequences of a boron dilution event may exceed the analysis results. Therefore. action must be initiated imediately to reduce the potential for such an event. To accomplish this. Required Action B.1 requires immediate suspension of positive reactivity additions. However, since Required Action B.1 only reduces the potential for the event and does not eliminate it, imediate action must also be initiated to increase the reactor coolant system level to above the bottom of the hot leg nozzles (Required Action B.2). The immediate Completion Time reflects the urgency of, the corrective actions.

Whm-SosT/> rx&y-- hv A ce, o., o. v v v %% ,ws,un a su e bwan cme-agen sNdi 14 2. t3co ppn h W ES tem W . boc i c_ acid colo 6 er c oo,o it t emt. "h W k (con % N j' _ u u _A AC1!ONS tinued) h In the determination of the required combination of boration flow rate and boron concentration, there is no unique requirement thtt must be satisfied. Since it is taperative to raise the boron concentration of the RCS as soon as possible, the boron concentration shou H be a hi hly concentrated solution,k or the_i:nt:f r:t;; ;;;.n 1.1 such as that normally fou d in the U4),,), 4 lcr boric acid storane tan The o trator should borate with the best source available g for t e plant conditions. 1 [Indeterm g,q ng the boration flow te, the time c Itfe must be nsidered. For Inst e the most dif uit time h in co itfe to increase th CS ron concen ation is at I the ginning of cycle, who the han raae tration sav J L ma ^^rh ar exceed 2000 com/ Assuming that a value of ~ lif Ak/k must be recovered thd a boration flow rate of it is possible to increase the ron concentration o h $ by pproximately -sinut t if a _ boron rth of is assumed thti combination of ____ m % 4 (M >arameters wt1 increase the $0M by X Ak/k. These boration C Jarameters of gpa and ppe represent typical values g and are prowl at the pu ose of offering a specifte I ^ 40 ;,.5_,h E SbRVEILLANCE SR 3.1.1.1 REQUIREMENTS SDM is verified by perfoming a reactivity balance talculation, considering the listed reactivity effects: \\ a. RCS boron concentration; b. CEA positions; RCS average temperature; e Fuel burnup based on gross themal energy generat19t; a. e. Xenon concentration; f. Samartum concentration; and g. Isothermal temperature coefficient (!TC). 4 (continued) CE00 STS B 3.1-5 Rev 1. 04/07/95 l l l r

D..&.d$4 sofr/> po w=n; q) 8 3.1.- BASES SURVEILLMCE 1R L1.1.1 (continued) REQUIREMENTS Using the ITC accounts for Doppler reactivity in this caleslation becaus6 the reactor is subcritical and the fuel temperature will be changing at the same rate as the,YS. I The Frequency of 24 hours is based on the generally slow change in required boron concentration and also allows rygggg71 suffletent time for the operator to co$1ect the required data, which includes performing a boron concentration SRs analysts, and complete the calculation. %m 10 -___,n_ 1.(::..-~;I,-^,,...;;J;..QL ursstt ApqueQiu. REFERENCES -. C *0. 2.@$AR,feetion gg

3. @$AR, !*>Haa M.

Q@ Nlt CfRdP9 Q l CEOG STS B 3.1-6 Rev1,04/07/95 1 l

BASES INSERT SRs SR 3.1.1.2 and SR 3.1.1.3 These Surve111ances periodically verify the significant assurrptions of a boron dilution event are maintained. A non-borated water source of f 88 gpm allows for only one charging pump to be capable of injection during these conditions since each charging pump is capable of an injection rate of 46 gpm. Each Surveillance is modified by a Note which indicates that it is only required when the unit is in H0DE 5 with the pressurizer level < 90 inches. Since the applicable conditions for the g Surveillance may be attained while already in MODE 5. each Surveillance is provided with a Frequency of once within one hour after achieving MODE 5 with pressurizer level < 90 inches. This provides a short period of time to verify compliance after the conditions are attained. Additionally, each Surveillance must be completed once each 12 hours after the initial verification. The Frequency of 12 hours is considered reasonable, in view of other administrative controls available, and operating experience. f .-r

3. A clarifying stateent was added regarding the reduced reactor trip setpoint formula in the Bases for ITS 3.7.1. 1 l i l

MSSys B 3.7.1 BASES Maximum relieving capacity of any one safety valve Y = in1bs/ 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 transient analyses. The operator should limit the maximum steady state power level to some value slightly below this setpoint to avoid an inadvertent overpower trip. The 4 hour Completion Time for Required Action A.2 is consistent with A.I. An at'iitional 8 hours is allowed to reduce the setpoints in i. cognition of the difficulty of resetting all channels of this trip function within a period of 8 hours. The Com letion Time of 12 hours for Required r Action A.3 is based on operating experience in resetting all channels of a protective 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 LC0 does not apply. To achieve this sta'.us, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within 12 hours. 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'fo

MsSVs B 3.7.1 basis ACTIONS A.1 and A.2 (continued) Alleurtble THERMAL POWER = ( ) x 109.2 With one or more MSSVs insperab1'e, the calling on the varlai,le av fpower trip is repsced to an amount pver the allowable ERNAL POWER equa) to the band giveyfor this trip, ac rding to Table 3. 1-1 in the accompanying LCO. Allowable THE L POWER + 9.8 SP gg = ( d 't.7. I wh e: 'Idd # Reduced r actor trip setpo t in percent RTP. 3 SP = This is ratio of the av lable relieving capact over the total' team flow at rated power 8 ,To 1 number of MSS persteamgeneptor. $1 umber of inoper 61e MSSVs on the team generator N = with the greate number of inop rable valves.,. Ratio of MSS relieving capa ty at 1105 stepsi 109.2 = generator rign pressure t calculated ste a flow rate t 1005 RTP + instrument unc ainty' express as a percentag (seetextabov Band between the maxi THERMAL POW and the 9.8 variable overpower t psetpointce)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 overpower trip. The 4 hour Completion Time for Required Action A.2 is h consistent with A.I. An additional 8 hours is allowed to f reduce the setpoints in recogrition of the difficulty of re.ntting all channels of this trip function within a period of 8 hours. The Completion Time of 12 hours for Required Action A.3 is based on operating experience in resetting all channels af a protective function and on the low probability of the occurrence of a transient Phat could result in steam generatcr overpressure during this period. (continued) CEOGSTy B Rev 1, 04/07/95 NCC ~Ew b % hon Mohcm 9 'l %o s.kk %._ bu,,- re bhw.1 p ~kbh., 3.'7-i_ h g is nok 49 vahcl, koec.r, % r.d po d s m ban 6 verdd b/ % ~s u d o d sts. ~ 3 k

. _..~.-.. _. ...-.--.. -...~-.-.- I b \\ s J - 4i. ' Clarifying statements' regarding refononces for ful oil pipls we & rw m SmW - ~ -Justification for Deviation 25 was revised. I i 4 g -? i 5 4 i e f 5 I i 1 - =... _., _ _ _

i ~ Programs and Manuals 5.5 '5.5-Programs and Manuals-2.- A flash point and kinematic viscosity within limits for ASTM 2D fuel' oil, and 3. Water and sediment 5 0.05%. b.. Within 31 days following addition of new fuel oil to the 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-i _ Total particulate concentration of the stored fuel oil, -c. determined by gravimetric analysis based on ASTM D2276-1989, l4 is s 10 mg/1-when tested every 92 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 Specificatio:,s Bases Control Procram This-programprovidesta;means;for, 'of'the'se'TechtiicilESpecificatidns processing; changes to the Bases ~~ '" ' a. Changes-to 'the Bases of the Technical Specification shall be - made under t.9ropriate administrative controls and reviews. b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following: 1. A change in the Technical Specification incorporated in the license; or

2. - A change to the UFSAR or Bases that involves an unreviewed safety question as defined in 10 CFR 50.59.

c. The' Bases Control Progra:n shall contain provisions to ensure that the Bases are maintained corisistent with the UFSAR. CALVERT_ CLIFFS - UNITS 1 & 2 5.0-26 RevisionAfo ~ - - -

.5pc.Ge <A.e 5.0 l INSERT 5.5.13 p.2.F 2 5.5.13 Diesel Fuel Oil Testinn Procram A diesel fuel oil testmg program to implement required testing of both new fuel oi' and stored fuel oil shall be established. The 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 followhg: a. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fueloil has: 1. An American Petroleum Institute (API) gravity or an absolute specific gravity within limits, 2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and 3. Water and sediment s 0.05%. b. Within 31 days following addition of the new fuel oil to storage tanks, verify that tle 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 stored fuel oil, determined by gravimetric analysis is s 10_mg/l when tested every 92 days. suoA m prn sthw999') The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the diesel fuel oil testing Frequencies.

INSERT 5,5.13 fpe 2d k 5.5.13 h Fuel Oil Testina Proaram A 6esel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. 'Ihe 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. Acceptability of new fuel oil for use prior to addition to storage tasks by letermining that the fueloil has: 1. An American Petroleum Institute (API) gravity or an absolute specific gravity within limits, 2. A flash point and kinematic viscosity within limits for ASTM 2D fuel oil, and 3. Water and sediment s 0.05%. b. Within 31 days followmg addition of tim 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 particuiste ccacentration of the stored fuel oil, determined by - gravimetric analysis is s 10 mg/l when tested every 92 days. g Lasody MTM bn%-199Q \\ 'Ihe provisions of SR 3.0.2 and SR 3.0.3 areiipplicable to tIie diesel fuel oil testing Frequencies. h

.. ~ _ i 1 Programs and Manuals-- 5.5 - I c,rsh 5.5 Programs and Manuals (continued)~ 5.5.13 Diesel Fuel 011 Testina Proaram A diesel fuel etl testing as to I lement required testi (4,%.t.t.2.b) both new fuel all and sto nelellrgsallbeestabitshed. bof program shall include sampling and testing requirements, and acceptance criteria, all in accordance with appilcable ASTM Standards. The purpose of the program is to establish the following: a. Acceptability of new fuel oil for use prior to addition to - storage tanks by detemining that the fuel oli has: 9""

E

,i M 3At.4,7go,g An API gravity or an absolute specific gravity within R 1.

11alts, 7"I#*//8

' # (TF3k*IAt M &, z. A flash point and kinematic viscosity within limits for (i 0.e,,1 tao.)T,4) ASTM 20 fuel oil, and, g,,j;a/- - 3. e clair and bright appearangwith procarc'olo); 6 def*h QthWorcarMas for ASTM W7ual all are wMhi U hg b. within 31 czys fclicwir.s Wiin -Mit_lenf infib to naraa. _ " p 7.577-/ + tankg;and (perA $4 W eripseNFW -94 e..e tsd.NeW'

^

aku_ata l s s p _ e %_m_1 e rt.,o Sh t:Je Ar AW*b M @ w Total particulate ~ concentranon of the fuel elJ1 c. th ".. ;s to mo/1 / ]f s_ pentestedevery days in a w..:...m

': 70 g

.~..----.m. 5.5.14 Technical sneciff ritions (TS) Bases control-Procras ~

{g g g g g g g y 4 h*5'k This program provides a means for processing changes to the' Bases - f 7gp/MNz.

of these Technical Specifications. 7 a. Changes to the Bases of the T5 shall be made under " if h.fA appropriate administrative controls and reviews. b. Licensees may make changes to Bases without prior NRC bo. sed og ~ 3 apfroyal provided the changes do not involve either of the fo lowing: /\\S7M b21H.-l% f,g,4,gg) h A change in the TS incorporated in the license; or 4. G 4.L h. h A change to the SAR or Bases that involves an unreviewed safety question as defined in 10 CFR 50.59. (continued) iCEOG STS 5.0-16 Rev 1, 04/07/95 6 + 4 w, m -n m-r e

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 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. This 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 High Radiation Area (as depicted in NUREG-1432 Section 5.7.1 as a bracketed specification) consistent with the current licensing basis. 22. He proposed change to NUREG-1432 adds a requirement that licensed operators counted towards the minimum shift crew composition shall be licensed for both unitt. His is a specific 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 lodide from less than 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 efficiency of methyl iodide. 24. He proposed changes to Specifications 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%. This 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 partidulate concentrations should be determined "in accordance with ASTM D2276-[ ], Method A (Ref. 6). This method involves a gravimetric determinatior> of total particulate concentration in the fuel oil...." nis Bases statement is revised to read: = " Particulate conceatrations should tye determined by gravimetric analysis (based on ASB( D2276-1989) of total particulate concentration in the fuel oil...." Calvert Cliffs has included the requirement to test for particulates in SR 3.8.3.2, but the testing is not in full accordance with ASB( D2276 [ ], Method A. As indicated in the change, total particulate concentration is determined by gravimetric analysis based on ASTM D2276-1989. However, 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 resulta. These deviations are: a. The reagents used are different: Calvert Cliffs nes iso-octane, while the ASTM requires freon (1,1,2 trichloro-1,22 trifluoroethane) and petroleum ether. A filter dispenser is not always used, as Calvert Clif s purchases ultra-pure reagents for use in this analysis, b. The preparation, handling and storage of apparatus is different: Removable glass supports are not used in petri dishes. The multiple solvent rinse steps are climinated as the equipment used is dedicated for use with diesel fuel oil. Container caps are handled by the exterior surfaces, but not with tongs. CALVERT CLIFFS - UNITS I & 2 5.0-3 Revision 10 1.

DISCUSSION CF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 5.0 - ADMINISTRATIVE CONTROLS ne appara:us 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. c. The sampling is different. Calvert Cliffs samples in accordance with ASTM D4037. Calvert rliffs also uses less than the 3.785 - 5 liter sample volume suggested in ASTM D2276. The sample volume is measured prior to filtering. 26. The Calvert Cliffs CTS Administradve Controls uses generic titles provided in American National Standards Institute /American Nuclear Society 3.1 instead of plant specific titles. The plant-specific titles that correspond to the generic titles are given in the Updated Final Safety Analysis Report. The use of generic titles in the Administrative Controls was encouraged in a let+er from C.I. Grimes (NRC) to Lee Bush (WOG), Brian Mann (CEOG), Clinton Szabo (B&WOG), and Andrew Maron (BWROG), dated November 10,1994. nese 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. His is consistent with the November 10,1994 letter. His change has been proposed as a change to the ITS NUREG as TSTF-65, but has not yet been approved by the NRC. 27. He 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 licensci at Calvert Cliffs. This requirement is being retained in the ITS. AX wwl, 4 28. His change incorporates the burrent Calvert Cliffs requirements for the Iodine Removal System into the Ventilation Filter Testing Program. His requirement is consistent with the Calvert Cliffs current licensing basis. 29. He gas storage tank radioactivity limit in NUREG-1432 Specification 5.5.12.b has been changed to be consistent with the Calvert Cliffs current licensing basis. The Calvert Cliffs ITS radioactivity limit, :ll 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 Occupational Radiation Exposure Report for the Independent Spent Fuel Storage Installation is reported separately from the Units I and 2 Occupational Radiation Exposure Report. Therefore, for clarity, the Note to ITS 5.6.1 has been modified to preclude combining the reports into a single submittal. 31. The phrase ", as modified by approved exemptions" has been added to the ITS 5.6.3 requirement that the Radioactive Effluent Release Report be submitted in accordance with 10 CFR 50.36a. Current Technical Specification 6.6.3 footnote """ 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 that allow exemptions (e.g., ITS 3.6.1). CALVERT CLIFFS - UNITS 1 & 2 5.0-4 Revision 10

5. De term " gross specific activity".was changed to " gross activity" in ITS 3A.15. De clause -- restricting the cumulative amount of time the unit may remain in Action A is removed, and DOC.- L.5 and associated No Significant Hazards Considerations are added.- N ll g 't. ~-' e ' -

RCS Specific Activity 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Specific Activity LCO 3.4.15 The specific activity of the reactor coolant shall be within limits. APPLICABILITY: - MODES 1 arid 2 MODE 3 with RCS average temperature (T,y) 2 500*F. ACTIONS CONDITION REQUIRED ACTION COMPLETION. TIME A. DOSE EQUIVALENT I-131 - -- - - - - - -- - - N OTE --- - - - - - - - - - > 1.0 Ci/gm. LCO 3.0.4 is not applicable. A.1 L Verify DOSE - Once per , ' EQUIVALENT I-131' 4-hours 1 + -within the acceptable-region of Figure 3.4.15-1. AND A.2 Restore DOSE 100 hours EQUIVALENT I-131 to within limit. CALVERT CLIFFS - UNITS 1 & 2 3.4.15-1 Revision 0

RCS Specific Activity 3.4.15 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3 with 6 hours associated Completion T.,, < 500'F. Time of Condition A not met. 9B DOSE EQUIVALENT I-131 in the unacceptable region of Figure 3.4.15-1. C. Gross activity of the C.1 Be in MODE 3 with 6 hours lo reactor coolant not T.,, < 500'F. within limit. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Verify reactor coolant gross activity 7 days lo

s; 100/l pCi/gm.

CALVERT CLIFFS - UNITS 1 & 2 3.4.15-2 Revision g to

RCS Specific Activity B 3.4.15 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.15 RCS Specific Activity BASES BACKGROUND The Code 'of Federal Regulations,10 CFR Part 100 specifies I the maximum dose to the whole body and the thyroid an-individual at the site boundary can receive for 2 hours during an accident. The limits on specific activity ensure that the doses are held to within the acceptance criteria given in the UFSAR (Ref.1) during analyzed transients and I accidents. The RCS specific activity LC0 limits the allowable concentration level of radionuclides in the reactor coolant. The-LCO limits are established to minimize the offsite radioactivity dose consequences in the event of a steam generator tube rupture (SGTR) accident. The LLO cordains specific-activity limits for both DOSE EQUIVALENT I-131 and gross activity. The allowable levels-5 1C are intended to limit the-dose ~at the site boundary to within the acceptance criteria'given in the UFSAR (Ref.1). I APPLICABLE The LC0 limits on the specific activity of the reactor SAFETY ANALYSIS coolant ensure that the resulting doses at the site boundary will not exceed the acceptance criteria given in the UFSAR 1 (Ref.1). The SGTR safety analysis (Ref. 2) assumes the specific activity of the reactor coolant at the LC0 limits l and an existing reactor coolant steam generator (SG) tube leakage rate of 1 gpm. l The rise in pressure in the ruptured SG causes radioactivsly l contaminated steam to discharge to the atmosphere through I the atmospheric dump valves and the main steam safety l valves. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-1 Revision gro

RCS Specific Activity B 3.4.15 BASES The safety analysis shows the radiological consequences of an SGTR accident are within the Reference 1 acceptance criteria. Operation with iodine specific activity levels greater than the LCO limit is permissible, if the activity levels do not exceed the limits shown in Figure 3.4.15-1 for more than 100 hours. The remainder of the above limit permissible iodine levels shown in Figure 3.4.15-1 are acceptable because of the low probability of an SGTR accident occurring during the established 100 hour time limit. The occurrence of an SGTR accident at these permissible levels could increase the site boundary dose levels beyond the acceptance criteria given in the UFSAR (Ref. 1). Reactor Coolant System specific activity satisfies 10 CFR 50.36(c)(2)(ii), Criterion 2. LCO The specific activity is limited to 1.0- 01/gm' DOSE EQUIVALENT I-131, and the gross activity in the primary I.lO' coolant is limited to the number of Ci/gm equal to 100 divided by F (average disirtegration energy of the sum of the average beta and gamma energies of the coolant nuclides). The limit on DOSE EQUIVALENT I-131 ensures the thyroid dose to an individual at the site boundary during the Design Basis Accident (DBA) will be within the acceptance criteria given in the UFSAR (Ref.1). The limit on gross activity ensures the whole body dose to an jo individual at the site boundary during the DBA will be within the acceptance criteria given in the UFSAR (Ref.1). The SGTR accident analysis (Ref. 2) shows that the site boundary dose levels are within acceptable limits. Violation of the LCO may result in reactor coolant radioactivity levels that could, in the event of an SGTR, CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-2 Revi"on No

l RCS Specific Activity B 3.4.15 BASES s lead to site boundary doses that exceed the Reference 1 acceptance criteria. O' APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS average temperature 2 500'F operation within the LC0 limits for DOSE EQUIVALENT I-131 and gross activity is necessary to contain the to potential consequences of an SGTR to within the acceptable site boundary dose values. For operation in MODE 3 with RCS average temperature < 500*F, and in MODES 4 and 5, the release of radioactivity in the event of an SGTR is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the atmospheric dump valves and main steam safety valves. ACTIONS A.1 and A.2 WiththeDOSEEQUIVALENTI-131greaierthantheLCOlimkt, samples at intervals of 4 hours must be taken to demonstrate the limits of Figure 3.4.15-1 are not exceeded. The Completion Time of 4 hours is required to obtain and ana tze a sample. Sampling must continue for trending. The DOSE EQUIVALENT I-131 must be restored to within limits within 100 hours. The Completion Time of 100 hours is required if the limit violation resulted from normal iodine spiking. A Note to the Required Action of Condition A excludes the MODE change restriction of LC0 3.0.4. This exception allows entry into the applicable MODE (S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown. This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-3 Revisionpfo

RCS Specific Activity B 3.4.15 BASES limiting due to exceeding this limit, and the ability to restore transient DOSE EQUIVALENT I-131 specific activity 10 excursions while the plant remains at, or proceeds to power operation. !!.d If a Required Action and associated Completion Time of Condition A is not met or if the DOSE EQUIVALENT I-131 is in the unacceptable region of Figure 3.4.15-1, the reactor must be brought to MODE 3 with RCS average temperature < 500*F within 6 hours. The allowed Completion Time of 6 hours is required to reach MODE 3 below 500'F without challenging plant systems. C.1 With the gross activity in excess of the allowed limit, the lo unit must bs placed 'in'a MODE in which the requirement does " not apply. The change within 6 hours to MODE 3 and RCS average temperature < 500'F lowers the saturation pressure of the reactor coolant below the setpoints of the main steam safety valves ano prevents venting the SG to the environment in an SGTR event. The allowed Completion Time of 6 hours is required to reach MODE 3 below 500'F from full power conditions and without challenging plant systems. SURVEILLANCE SR 3.4.15.1 REQUIREMENTS The Surveillance requires performing a gamma isotopic analysis as a measure of the gross activity of the reactor lo coolant at least once per 7 days. While basically a quantitative measure of radionuclides with half lives longer than 15 minutes, txcluding iodines, this measurement is the CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-4 Revision g/o I i

RCS Specific Activity B 3.4.15 BASES sum of the degassed gamma activities and the gaseous gama activities in the sample taken. This Surveillance provides an indication of any increase in gross activity. P Trending the results of this Surveillance allows proper retnedial action to be taken before reaching the LC0 limit under normal operating _ conditions. The Surveillance is applicable in MODES 1 and E, and in MODE 3 with RCS average temperature at least 500'F. - The 7 day Frequency considers the unlike11 hood of a gross fuel failure during the time. SR 3.4.15.2 This Surveillance is performed to ensure iodine remains within limit during normal operation and following fast power changes wnen fuel fcilure is more apt to occur. The 14 day Frequency is adequate to trend changes in the iodine activity level considering gross activity is monitored every 7 days. The Frequency, between 2 hours and 6 hours lafter a-power change of 215% RTP within a 1 hour period; is' established because the iodine levels peak during this time following fuel failure; samples at other times would provide inaccurate results. The SR is modified by a Note which requires the Surveillance to only be performed in MODE 1. This is required because the level of fission products generated in other MODES f s much less. Also, fuel failures associated with fast power changes is more apt to occur in MODE 1 than in MODES 2 and 3. SR 3.4.15.3 A radiochemical analysis for i determination is required every 184 days (6 months) with the plant operating in MODE 1 equilibrium conditions. The i determination directly i l CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-5 Revision A'/0

6 8cE'0 M 3.4,15" P 34 @ REACTOR C00iJulT SYSTEM g @ h SPECIFIC ACTIVITY ggg LINITING CONDITION FOR OPERATION t.c.o 3,4jg @ The specific activM of the primary coolant shall be limited to

a. 51.0 pC1/ gram DOSE EQUIVALENT I-131, and

b. 5 100/I pC1/ gram.

APPLICABILITY: N00E$ , (J. Macro A' ACTION: (IDjr61. 2 p6 33 A With the specific activity of the primary coolant > 1.0 pCi/bram Apg DOSE EQUIVALENT I-131 but within the alloi 'able limit (below and to the left of the line shown on Figure (S operation may i g i e

"" ""* $s"' *, *n

'"_4"Po"/r/fo?PQ ogo ..NrNanerat a IThe provisidns of specification 3.0.4 are} ~ i 4*hg Enot appitcable. f A cr/*# h With the specific activity of the primary coolant > 1.0 pCi/ gram DOSE EQUIVALENT I431 for more thart 100 hours during one B continuou time intervai or exceeding the limit itne shown on.

Figu

. be in at east NOT STANDBY with T, < 500*F A./ within 6 hours N g g f. 4 15, With the specific activity of the primaty coolant > 100/l pC1/ gram, be in at least HOT STAND 8Y with T.., < S00*F C-within 6 hours. Glopt11, 2.g. 4 anf4) Wr/h ,/ / ~ % With the specific activity of the primary coolaid > 1.0 pC1/ gram d e rr'd DOSE EQUIVALENT I-131 or > 100/I tici/ gram.gtr fonn the sampiin - r A fanu analyan requirements of item 4 a) or table a.a.a imtt1 the [* neri fi c activity of the crimary coolant _islrestor@ to within its limits. yTm l00*y gmy,g p ,,,j,,,j,l} CALVERT CL1TFS - tjNIT 1 1/4-4-24 %endment No. 316 f*f

SMon 3415 3.4 @ REACT 0lt COOLANT $Y$ TEM M h PECIFIC ACTIVITY 3,4,fg LIMITING CONDITI M TOR OPERATION t,co 3,4,ff @ The specific activity of the primary coolant shall be limited tot

a. $ 1.0 pC1/ gram DOSE EQUIVALENT I-131 and b, s 100/l pC1/ gram.

APPLICABILITY: MODES 2.Q~.A'4nd41 5'h 5 ACTION: QEDDJrl 2 and4) K With the specific activity of the primary coo nt >. pC1/ gram DOSE EQUIVALENT I-131 but within the allowab limit (below and ,<i65/' # to the left of the line shown on Figure operation may g"Mner:atina tibhe provisions of Specification 3.0 4 ea are A#/**' A y o_ applicable. f Ne1& 'h. With the specific activiiv of the primary coolant > 1.0 pC1/ gram s DOSE EQUIVALENT I-131 for more than 100 hours'during one continuous time interval or exceeding the' limit line shown on"- A411'# Figure be in at least H0T STANDBY with T, < 500*F 8 within 6 ours, g g., g,/ s With the specific activity of the primary coolant > 100/l Ac118# Ci/ gram, be in at least NOT STANDBY with T.,, < 500'F.within C 6 hours. h 2, 3 g and 53 h With the specific activity of the primary coolant _> 1. 0 nci/ gram DOSE EQl!! VALENT I-131 or > 100/l pC1/ gram, onn the sem 1 g'* g pnu aptlysts requiremen, tsp nem 4 4 di A 4 4 imti h e. A ynadfic activity of tworimary coolant restof8D to within V its limits. s,,Q o r o s '3 a:R;, f,,, 2. 4.15-I 1th T,,, > y pggn p /1pp h $ Ik CALVERT CLIFFS - UNIT 2 3/44-24 Amendment No. 193 (*}'

DISCUSSION OF CHANGES SECTION 3.4.15 - RCS SPECIFIC ACTIVITY unlikely tent a gross failure could occur during this time without prior indication. This change is c.msistent with NUREG 1432. L.3 Current Technical Specification 3.4.8 SR Table 4.4-4 Item 4.b requires the Dose Equivafent I 131 specific activity be verified in Modes 1,2, and 3. Improved Technical Specific ation 3.4.15 SR 3.4.15.2 adds a Note which only requires the SR to be performed in Mode 1. His change will delete the Modes 2 and 3 requirements for this Surveillance, nis is accepttble because the level of fission products generated in Modes 2 and 3 are much less, and fuel failures associated with fast power changes are more apt to occur in Mode 1. This change is consistent with NUREG 1432. L.4 Current Technical Specification 3.4.8 SR Table 4.4-4 Item 3 requires E-Bar to be determined from a sample taken in Mode 1 after a minimum of 2 Effective Fuel Power Days and 20 days of Mode 1 operation have elapsed since the reactor was last sub.a.tical for h 48 hours. Improved Technical Specification 3.4.15 SR 3.4.15.3 allows the Surveillance to be delayed for 31 days after a minimum of 2 Effective Full Power Days and 20 days of Mode 1 operation have elapsed since the reactor was last suberitical for 2 48 hours. The 31 days ensure the radioactive materials are at equilibrium so the analysis for E-Bar is representative and not skewed by a crud burst or other similar abnormal event. This change is consistent with NUREG-1432. L.5 Current Technical Specification 3.4.8 Action a contains a clause stating that plant operation may continue for up to 100' hours when specific activity of the primary coolant is > 1.0pCi/ gram DOSE EQUIVALENT I-131 but within the ellowable limit shown on Figure 3.4.8-1, provided that operation under these circumstances shall not exceed 10 percent of the units total yearly. operating time. ; Improved Technical Specification 3.4.15 will not contain this clause regarding 10 percent of the units total yearly operating time. Generic Letter 85-19, Reporting Requirements on Primary Coolant Iodine Spikes, states that requirements to shutdown a plant if coolant iodine activity limits are exceeded for 800 hours in a 12-month period can be elimmated. He quality of nuclear fuel in the decade preceding the generic letter had greatly improved with the result that normal coolant iodine activity (i.e., in tb absence ofiodine spiking) is well below the limit. Appropriate actions would be initiated long before accumulating 800 hours above the iodine activity limit. In addition,10 CFR 50.72(b)(1)(ii) requires the NRC to be immediately notified of fuel cladding failures that exceed expected valves or that are caused by unexpected factors. Therefore, this limit is no longer necessary based on proper fuel management and existing reporting requirements precluding ever approaching the limit. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.4.15-2 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. 2.' Does the change create the possibility of a new or different Idad of accident from any previously evaluated? De proposed change allows 31 days to elapse, after a minimum of 2 Effective Full Power Days and 20 days of Mode 1 operation have elapsed since the reactor was suberitical for 2 48 hours, prior to determining the gross activity. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different hind of accidnt from any accident oreviously evaluated. 3. Does this change involve a significant reduction in margin of safety? He proposed change allows 31 days to elapse, after a minimum of 2 Effective Full Power Days and 20 days of Mode 1 operation have elapsed since the reactor was suberitical for 2 48 hours, pnor to determining the gross activity. He results of the E-Bar determination will be more representative of the RCS due to the 31-day allowance. The 31 days ensure the radioactive materials are at equilibrium so the analysis for E-Bar is representative of the actual gross activity. Also, the value of E-Bar changes slowly. Therefore, the change does not involve a significant reduction in a margin of safety. 3.4.15 Chanoe L.5 1. Does the change involve a significant increase in the probability or consequences of an acciden,t previously evaluated? The proposed change removes a clause to an Action which limits the time that the plant can be operated within specified Iodine-131 criteria. The clause removed, requires that operation under the specified Iodine-131 criteria does not exceed 10 percent of the units total yearly operating time. Removing this requirement is acceptable based on the improved quality of nuclear fuel since the time that the clause was created, making normal iodine activity well below limits, and appropriate action would be initiated long before accumulating the time above the limit. The requirement to notify the NRC is contained in other requirements. The RCS gross activity is not an initiator of any analyzed event. The change will not after assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an acc: dent previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? The proposed change removes a clause to an Action which limits the time that the plant can be operated within specified lodine-131 criteria. The clause removed requires that operation under the specified Iodine-131 criteria does not exceed 10 percent of the units total yearly operating time. The change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any new accident initiators. Therefore, the chenge does not create the possibility of a new or different kind of accident from any previously evaluated. CALVERT CLIFFS - UNITS I & 2 3-4-32 Revision 10

f NO SIGNIFICANT IIAZARDS CONSIDERATIONS ) SECTION 3A - REACTOR COOLANT SYSTEM l 3. Does this change involve a significant reduction in margin of safety? He proposed change remcves a clause to an Action which limits the time that the plant can be operated within specified lodine-131 criteria. The clause removed requires that operation under the specified lodine-131 criteria does not exceed 10 percent of the units total yearly operating time. Removing this requirement is acceptable based on the improved quality of nuclear fuel since the time that the clause was created, making normal iodine activity well below limits, and appropriate action would be initiated long before the accumulating the time above the limit. The requirement to notify the NRC is contained in other requirements. Herefore, the change does not involve a significant reduction in a margin of safety. ENVIRONMENTAL ASSESSMENT This proposed Technical Specification changes have been evaluated against the criteria for and identification oflicensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed changes meet the criteria for categorical exclusion as provided for under 10 CFR S t.22(c)(9). He following is a discussion of how the proposed Technical Specification changes meet the criteria for categorical exclusion. 10 CFR S t.22(c)(9): Although the proposed change involves changes to requirements with respect to inspection or SRs, (i) proposed change involves No Significant Hazards Consideration (refer to the No Significant Hazards Consideration section of this Technical Specification Change Request); (ii) th:re is'no significant change in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed chenges do not affect the generation of any radioactive effluents nor do they affect any of the permitted release paths; and (iii) there is no significant increase in individual or cumulative accupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR Sl/22(c)(9). Based on the aforementioned and pursuant to 10 CFR 51.22 (b), no environmental assessment or environmental impact statement need be prepared in connection with issuance of an amendment to the Technical Specifications incorporating the proposed changes of this request. CALVERT CLIFFS - UNITS I & 2 3-4-33 Revision 10

i 5gw. Man 3.4, f 5 3.4 @ REACTOR COOLANT. SYSTEM 3,4,g O/(. g8) h PECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION t co 3,4,ff @ The specific activity of the primary coolant shall be Ilmited to

a. 51.0pC1/gramDOSEEQUIVALENTI-131,and b.

1100/lpCi/ gram. APPLICABILITY: MODES 2, % CT3 77kk[5 ACTION: Q4DDJfl. 2 ann) %, With the specific activity of the primary coo nt >. pC1/ gram DOSE EQUIVALENT I-131 but within the allowab limit (below and ACT/*M to the left of the line shown on Figure _. operation may ENENaNOt 7f Aeb A.2, na Nok e narattna ti he provisions of Specification 3.. are . M/*** A nit appl 1 cable. f s No16 % Wtth the spectfIc activity of the primary coolant > 1.0 itCi/ gram DOSE EQUIVALENT I-131 for more than 100 hours during one.. tontinuous time interval or exceeding the Itatt line shown on 4-No# Figure ~ be in at least NOT STAND 8Y with T, < 500*F S within 6 ours. 3,4,,g., g,/ With the specific activity of the primary coolant > 100/l s AC'If W pct / gram, be in at least H0T STANDBY with T,, < 500'F.within C 6 hours. h. 2. 3 / and 53 % With the specific activity of the primary coolant _> 1.0 nCt/ gram pnu aN1ysts requireme, tsp nem e a) oi igfDOSE EQi]IVALENT I-131 or g,g n a.g.a innti d ynarffic activity of tworimary coolantMestof2D to within T its limits. pt,& D&D Z 0 aoJLa fy. s.4.st-I th T.,> K F ggo p,4p k $ CALVERT CLIFFS - UNIT 2 3/4 4-24 Amendment No.~193 f*)'

1 ) l 'RCS Spectfic Activit 3.4. ACTIONS (continued) CONDITION REQUIRED ACTION COMPLET!0d TIME B. Reqvtred Action and 8.1 Be in M00C 3 with 6 hours 34% associated Completion T.,,< 500*F. A,.:n.4 L. Time of Condition A not met. - Qg DOSE EyJIVALENT I-131 in the unace able region of Figure 3.4.1 O C. Gross ['se e Kel [C ! [Perfopr$f 3.4.16.2/ 4hoprs] n-r F - zg activity o1 the / I jo 5A.b reactor coolant not g g' y e _ within Italt. 1 I l C. Be in MODE 3 with 6 hours } T, < 500*F. l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY (3 l SR 3.4.lf.1 Verify reactor coolant gross (sjictficl 7 days h/o l %)* 4.4-4 (D activity 5100/E pct /ga. (continued) t I i i i CEOG STS 3.4-41 Rev 1, 04/07/95 1

RCS Specific y B 3.4 TOR COOLANT SYSTEM (RCS) B 3.4 RCS Specific Activity BASES BACKGROUND The Code of Federal Regulations,10 CFR 100 diiTNb specifies the maximum dose to the whole body and the thyroid gg . gg;, g an individual at the site boundary can receive for 2 hours gina ;we a,bl, during an accident. anyf The limits on specific activity ensure anku that the doses are held to - - ni QE4 t5,.nst. G B javv vietty curing analyzed transients'and~ accidents. g vraguon of sno i g ( The RCS specific activity LC0 limits the allowable concentration level of radionuclides in the reactor coolant. The LCO limits are established to minimize the offsite radioactivity dose consequences in the event of a star.a [ generator tube rupture (SGTR) accident. The LC0 contains spe-ific activit:r limits for both DOSE EQUIVALENT I-131 and gross tspecitoactivity. The allowable 6 O/o ,A l -levels are intended to 11 alt theG555Ubdose at the site boundarv in ta small. frac len er ins ir i.iR/suu cose i e Tgdeline 11 fts. The l talt: in the LCO af uations of offst% e standardized'24 A based on pa tric ev wIiCa N,***(f-*e pose conse uences for typical site locaMonf radioactivit c,c h ugews.e W urm(0.t.lh Ihe rasetric ev untions showed tio potential off ite dose leve s for an SGT accident were ar/ appropriately 11 -' fra ton of the 0 LFR 100 dose g deline limits. Each' eva untion ass s a broad range f site applicab e' at eric dit_ ersjpn factors i a carametrie e lustion i APPLICABLE The LCO 11alts on the specific activit of the reactor SAFETY ANALYSES i coolant ensure that the resulting u doses at the site ---m boundary wi'1 not enende 41i fras_uon ci sne JD UR 10D j Na bt l "'%n ef .ose auMabe 11alts ff'llowing an JGTR accidentr. sda ed safety analysis The SGTR the reactor coola(nt at the LCO lialts and an exidingRef.~f) assu I ka ufJ4ttpd. Ih I reactor coolant steam generator (SG) tube leakage rate of I gpa. The = 1y:H L'a r!"-r i =t:r tr',, eies t r: 6 i. r 1 th; :Z: I'r: M I 4 ZI^ - -"1. -Ihe 1".!!y h-f r th; CCT", ess6n. u i.. ' 2 m a M " '!:!!; ', Z.,,....^. .u....h. 4he E:' -~* to (coatinued) CEOG STS B 3.4 88 Rev1,04/07/95 l 1

RCS Specific Activit 8 3.4.1 BASES L APPLICABLE

" - - - ' - ^ ' ' '

"---*a ' "- ^- ~~ SAFETY ANALYSLS W E' ~ " " C' M '" (continued) mer=C'U ~ ~ ' ' ~ ' ~~ an The rise in pressure in the t SG causes radioactively C/o contaminated steam to discha e to the atmosphere through the atmospheric dimp valves the main staas safety valves. Tk=_ t ^.-tri; d ;_f.;-- r*- : d;r. tM t;-;;r.; l;;;;;;; to the e.J...m. - n i m n...vi..../.21,. f___ m are ametum.a,'::: t;,,,,o, ,,,,,,,u,,. k- : d;.y ,, ventini.w- .; ;;.. ;;;tf: r. The safety analysis shows the radiological consegrances of hb an SGTR_ accident are within a snaioragnon cDthe fo,Ter,Q xeterenceWfneAi nw. Operation ~with iodine h specific activity levels enlater than the LC0 limit is permissible, if the fylty levels do not exceed the limits @b shown in Figure 3.4. for more than # hours. The remainder of the ve limit permissible iodine levelsg shown in Figure 3.4.1F 1 are acceptable because of the low probability of an SGTR accident occurrino durino the estabitsbed As hour ties llan. sne occurrence of an SGTR accident at these permissible levels could increase the site Qea h 4 s bocndary dose levelst but Attle av ritain JU CFR lj0 dose 3 j l 3(S.c*.f,b et t % h a gu w line 1)m g ,,. n ursa g i3 RCS specific activity satisfies Criterion 2 of the NRC Policy Statement. 1 LCO The specific 4e4&ne activity is li_aited to 1.0 pC1/ga DOSE MN EQUIVALENT 1-131, and the grossGMetfR) activity in the h [ 14 primary coolant is limited to the number of pCf/ga equal to 100 divided by E (average disintegration energy of the sta of the average beta and gassa energies of the coolant nuclides). The limit on DOSE EQUIVALENT I-131 ensures the COND thyroid dose to an individual at the site boundary s A durin _ the Design Basis Accident (08A) will be dTa'aH7 Ol ra inn ov ihe assoeda inyroia asset. The limit on gross 4

44 cY4[g (spec _11tt) activity ensures the CBEDwhole body dose to an h i

,o hes ;u individual at the site boundary during the DBA will be/D i gg g OM l 4 Iysu.WH W AUT 54iUwvu WME uvyy u u p, (continued) CEOG STS 8 3.4 89 Rev 1, 04/07/95

-.. - = ~ RCS Specific Activit B 3.4.1 BASES LC0 The SGTR accident analysis (Ref. 2) shows that the 2 hour (continued) site boundary dose levels are within acceptable 11alts. Violation of the LCO may result in reactor coolant radinactivity levels that could, in the event _of an SGTR, gpggg lead to site boundary doses that exceed the@ cp auy cosg) ( <guwe u nA neus. - '2-M 4 APPLICABILITY In MODES 1 and 2, ar.d in MODE 3 with RCS average temperature 2 500*F, operation within the LC0 limits for DOSE EQUIVALENT I I-131 and grossfEM ETM D activity is necessary to contain lo I the potentla1 consequences of an SCTR to within the acceptable site boundary dose values. For operation in MODE 3 with RCS average temperature < 60'F, and in MODES 4 and 5, the release of radioactivity in the event of an SGTR is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the atmospheric dusp valves and main steaa safety valves. = c= [Seguired Askn of Cod.h.e A ACTIONS IA Note to the MIjgS) excludes the~ MODE change restriction S of LCO 3.0.4. -This exception allows entry into the C applicable MODE (S) while relying' n the ACTIONS even though - i f PT.V $.~ ' the ACTIONS may eventually require plant shutdown. This 4 exception is acceptable due to the significant conservatism T F-N l 2%g incorporated into the specific activity Itait, the low probability of an event which is limiting due to exceeding /> 6 5 4.D I this limit, and the ability to restore transien pecific j activity excursions while the plant remains at, r proceeds o power operation, gg A.1 and A.2 With the DOSE EQUIVALENT l-31 greater than the LCO limit, samples at intervals of 4 hours aust be taken to demonstrate the limits of Figure 3.4.lA-1 are not exceeded. The Completion Time of 4 hours is required to obtain and analyze a sample. Sampling must continue for trendi The DOSE EQUIVALENT 1-131 must be restored to within 1 mits withi ours. (continued) l-CEOG STS B 3.4-90 Rev1,04/07/95 I (.. l

fh a RCS Specific Activit I 8 3.4. BASES ACTIONS A.1 and A.2 (continued The Completion Time of urs is required if the limit vicistion resulted from nomal iodine spiking. rautM R* y TSIF. l q to 6 3. 4 ' 9 0 5 If a Required Action and associated Comp etion Time of Condition A is not met or if the DOSE E IVALENT I-131 is in the unacceptable region of Figure 3.4. -1, the reactot must be brought to MODE 3 with RCS average temperature < 500*F within 6 hours. The allowed Completion Time of 6 hours is required to reach M00E 3 below 500'F without challenging plant systems. c.16-dE.? ~h' gh g With the gross (sp(c1He) activity in excess of the allowed ( 4 '**p M limit n snaiym sust be pq ormea within 4 hoursjo 7 $7g@-z[ h pl<ud ;4 A eem DOSE EQUIVALENT ./ The Complat -of l (neog gg -h_ e it reautred to om)ain and analvre a efion my ) O "(4aad . The change within 6 hours to MODE 3 a'nd RCS averaget a Ap. ak.ppy i temperature < 500'F lowers'the saturation pressure of the S -_-Q reactor coolant below the~ set valvesandpreventsventingtpeSGtotheenvironmentinanints of the main steam safety SGTR event. The allowed Completion Time of 6 hours is - required to reach MODE 3 below 500'F from full power conditions and without challenging plant systems. h SURVEILLANCE SR 3.4.1 1 REQUIREMENTS The Surveillance requires performin a ama isotopic i /\\ analysis as a measure of the gross activity of the I UD reactor coolant at least once per 7 days. While basically a quantitative measure of radionuclides with half lives longer than 15 minutes, excluding iodines, this measurement is the sum of the degassed gama activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in gross (spfeif,/c) activity. fh (continued) CEOG STS B 3.4-91 Rev1,04/07/95 L -c +

4 DISCUSSION OF BASES DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM assumed that the turbine has not tripped. Herefore, this statement was deleted from the Specification 3.4.16 Bases, Applicable Safety Analyses Section. 15, ne Calvert Cliffs Specification 3.4.15 Action, when the Dose Equivalent Iodine is out-of limit but within limits of the Figure 3.4.15-1, was changed from 48 hours to 100 hours. l 16. Specification 3.4.11 Bases (Background Section) states the power-operated relief valve setpoint is above the high pressure reactor trip setpoint. This change will incorporate changes that specify the power-operated relief valve setpoint is equal to the high pressure reactor trip setpoint. This change is consistent with Calvert Cliffs current trip settings. 17. He word analog is deleted from places in the Bases where it is used to modify Specifications. Calvert Cliffs is an analog plant and it is unnecessary to specify this for Specifications. 18. His portion of the Applicable Safety Analyses Section of Specification 3.4.12 Bases is being deleted because the pressurizer safety valves do not protect the Pfr limits at all temperatures above minimum pressurization temperature. His change is consistent with Calveit Cliffs' design. 19. NUREG-1432,3.4.2 Bases, Applicable Safety Analyses Section was changed to accommodate that Calvert Cliffs is not standard in its analysis of the minimum temperature for criticality, ne analyses assume a minimum temperature consistent with normal hot zero power opuntion instead of the Technical Specifications limit. His discrepancy was justified by Combustion Engineering Owners Group Task 889, as documented in CENPSD-1026, " Evaluation of NRC Notice 94-75." 20. NUREG-1432,3.4.14 Bases, Background Section was changed to delete reference to eneasuring dew point temperatures and to delete that humidity Icvel is useful as an indirect alarm. Calvert Cliffs does not measure dew point temperature, nor does it use humidity level as an alarm. This change is consistent with Calvert Cliffs' design. 21. A requirement was added to NUREG-1432 Bases Section 3.4.3 (Calvert Cliffs ITS bases l l Section 3.4.3) Actions A.1 and A.2, which requires the engineering evaiuation when P/r limits are exceeded to include a determination of the effects of the out-oflimit conditian on the fracture toughness properties of the RCS. His change is a result of moving a requirement out of the Current Technical Specifications into the ITS Bases. 22. These changes to NUREG 1432 incorporate Calvert Cliffs speciSc requirements, allowances, or exemptions currently located in the Calvert Cliffs Current Technical Specification. These items were relocated out of the Current Technical Specification to the ITS Bases. These changes are l consistent with the Calvert Cliffs current licensing basis. l l CALVERT CLIFFT - UNITS I & 2-3.4-2 Revision 10

1 6. A statement in ITS 3.5.4 liases regarding when control element assemblies are credited aAer a loss-of-coolant accide-t was clarified, j 5 l I I l l 1 i

RWT B 3.5.4 BASES flow from all ESF pumps prior to reaching a low level switchover to the containment sump for recirculation; and b. The containment sump water volume must be sufficient to support continued ESF pump operation after the switchover to recirculation occurs. This sump volume water inventory is supplied by the RWT borated water inventory, ihen ESF pump suction is transferred to the sump, there must ce sufficient water in the sump to ensure adequate net positive suction head for the HPSI and containment spray pumps. The RWT capacity must be sufficient to supply this amount of water without considering t'e inventory added from the safety injection tanks or Reactor Coolant System (RCS), but accounting for loss of inventory to containment subcompartments and reservoirs due to containment spray operation and to areas outside containment due to leakage from ECCS injection and recirculation equipment. The 2300 ppm limit for minimum boron concentration was established to ensure that, following a LOCA with a minimum level in the RWT, the reactor will remain subcritical in the cold condition following mixing of the RWT and RCS water volumes with all control rods inserted, except for the b control element assembly (CEA) of highest worth, which is withdrawn from the core. The most limiting case occurs at to beginning of core life. The maximum baron limit of 2700 ppm in the RWT is based on boron precipitation in the core following a LOCA. With the reactor vessel at saturated conditions..the core dissipates heat by pool nucleate boiling. Because of this boiling phenomenon in the core, the boric acid concentration will increase in this region. If allowed to proceed in this manner, a point will be reached where boron precipitation will occur in the core. Post LOCA emergency procedures direct the operator to establish simultaneous hot and cold CALVERT CLIFFS - UNITS 1 & 2 B 5.5.4-3 Revision 9'/o l.

i RWT j B 3.5.4 BASES leg injection to pievent this condition by establishing a forced flow path through the core regardless of break location. These procedures are based on the minimum time in which precipitation could occur, assuming that maximum boron ecocentrations exist in the borated water sources used for injection following a LOCA. Boron concentrations in the RWT in excess of the limit could result in precipitation eariter than assumed in the analysis. The upper limit of 100'F is only required for MODE 1 operation and the lower limit of 40'F on RWT temperature are the limits assumed in the accident analysis. The RWT satisfies 10 CFR 50.36(c)(2)(ii) Criterion 3. LCO The RWT ensures that an adequate supply of borated water is l available to cool and depressurize the containment in the event of a Design Basis Accident (DBA) and to cool and-cover the core in the event of a LOCA, that the reactor remains-9 suberitical following a DBA, and that an adequate-level exists in the containment sump to support ESF pump operation in the recirculation mode. To be considered OPERABLE, the RWT must meet the limits established in the SRs for water volume, boron concentration, and temperature. APPLICABILITY In MODES 1, 2, 3 and 4, the RWT OPERABILITY requirements are dictated by the ECCS and Containment Spray System OPERABILITY requirements. Since both the ECCS and the Containment Spray System must be OPERABLE in MODES 1, 2, 3, and 4, the RWT must be OPERABLE to support their operation. Core cooling requirements in MODE 5 are addressed by LCO 3.4.~i, "RCS Loops - MODE 5. Loops Filled," and LC0 3.4.8, "RCS Loops - MODE 5. Loops Not Filled." MODE 6 i l l CALVERT CLIFFS - UNITS 1 & 2 B 3.5.4-4 Revision 0 l l

RWT B 3.5.4 BASES core cooling requirements are addressed by LCO 3.9.4, " Shutdown Cooling (SDC) and Coolant Circulation - High Water Level"andLCO3.9.5,'ShutdownCooling(SDC)andCoolant Circulation - Low Water Level." ACTIONS Ad With RWT boron concentration or borated water temperature not within limits, it must be returned to within limits within 8 hours. In this condition neither the ECCS nor the Containment Spray System can perform their design functions; therefore, prompt action must be taken to restore the tank to OPERABLE condition. The allowed Completion Time of 8 hours to. restore the RWT to within limits was developed .considering the time required to change boron concentration or temperature and that the contents of the tank are still - available'for injection. -Required Action A.1 only applies.to the maximum borated ' water temperature in M00E 1.- L.1 With RWT borated eter volume not within limits, it must be returned to within limits within 1 hour. In this condition, neither the ECCS nor Containment Spray System can perform their design functions; therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the und in a MODE in which tnese systems are not required. The allowed Completion Time of 1 hour to restore the RWT to OPERABLE status is based on this condition simultaneously affecting multiple redundant trains. CALVERT CLIFFS - UNITS 1 &-2 B 3.5.4-5 Revision 0 [

i RWT B 3.5.4 BA$[$ i i h APPLICABLE Twenty tes is the point at wh 755 of the dest flow SAFETY ANALYSES of one 1 pump is capable of ting or exceedt the (continued) deca at belloff rate. 3 When [$F pump section is transferred to the sump, there must be sufficient water in the sump to ensure adequate set positive section head (NPSH) for the HPS! and containment spray pumps. The Rrf capacity must be sufficient to supply this amount of water without considerin1 the inventory added i free the safety trJection tanks or Reactor Coolant System (RCS), but accounting for loss of invcatory to containment subcompartments and reservoirs due to containment spray operation and to areas outside containment due to leakage from ection and recirculation equipment. O The limit ft,r sintaum baron concentration was esta lished to ensure that, following a LOCA with a sinimum level in the RWT, the reactor will remain subcritical in the g cold condition following mixing of the RWT and RCS water i volumesvseers -nu umu assess thalall control rods @) inserted, except for the control element assembl or highest worth, which is withdrawn from the core.y1CE_A JL e br dar assuusr inminctn maain watWdre ren se most limit' ng case occurs at beginning of core r e. The maximum boron limit of ppe in the RWT is based on boron precipitation-in the core ellowing a LOCA. Lith the reactor vessel at saturated conditions, the core dissipates heat by pool nucleate bolitag. Because of this belling phenomenon in the core, the boric acid concentration will increase in this region. If allowed to proceed in this manner, a point will be reached where boron precipitation will occur in the core. Post LOCA emergency procedures direct the operator to estabitsh simultaneous hot and cold leg injection to prevent this condition by establishing a forced flow path through the core regardless of break location. These procedures are based on the etn:aus time in which precipitation could occur, assuming that maximum boron concentrations exist in the borated water sources used for injection following a LOCA. Bors.: concentrations in the RVT in excess of the limit could result in precipitation earlier than assumed in the analysis. The upper limit ofk its\\and tholower limit ofh F on RWT temperature are its assumed in the accid t (continued) CEOG STS B 3.5-25 Rev1,04/07/95 m y.a n. = # e

Clarif ing statements were added to ITS 3.7.9 DOC L.2 and ITS 3,711 DOC L.3. 7. f 1 l l { l l r m

DISCUSSION OF CHANGES SECTION 3.7.9. CONTROL ROOM EMERGENCY TEMPERATURE SYSTEM TECHNICAlcCHANGES - LESS_]ESTRICTIVE L.! Current Technical Specification 3.7.6.1 Action b allows 7 days to restore an inoperable air r 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 CRETS train is inoperable. His change is acceptable because the remaining CRETS train is adequate to maintain the Control Roan temperature within limits. It is also tased on the low likelihood of an event occurring requiring Control Room isolation, and that backup Control Room air conditioning system is available. Extending the allowed outage time for the CRETS constitutes a less restrictive change. His change is consistent with NUREG.1432. L2 Current Technical Specification SR 4.7.6.1.a requires the CRETS to maintain Control Room temperature s 104'F for at least 12 hours 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 temperature s 104*F for at least 12 hours; however, the ITS requires the SR to be performed 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. His has been shown by evaluating the previous 10 years of operating experience which show that this test has not had any failures. He ChETS contains redundant electrical and mechanical compe nents and is operated once per 31 days to verify operability. Herefore, per Generic Letter 9104, the effect of the change on plant safety is small. Also, instrument drift will have no affect on this test. Here is na instrumentation tested by this Technical Specification requirement. l nis change is consistent with NUREG-1432 and the guidance in Generic Letter 91-04. l l l 1 i CALVERT CLIFFS - UNITS 1 & 2 3.7.93 Revision 10

- ~ _ _ l DISCUSSION CF 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 Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. His change is a less restrictive movement of information change with no Impact on safety. Als change is consistent with NUREG 1432. LA.2 Action a and b of CTS 3.9.12 require the suspension of Mi operations involving craae 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 associated with the suspension of crane operation with loads over the storage pool are to be relocated to the UFSAR. He bounding design basis fuel handling accident assumes an irradiated fuel assembly is dropped and damaged, ne movement of loads (loads other than fuel assemblies) is administratively controlled based on heavy loads analyses, ne 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. IECitNICAL CIIANGES LFER 12FETRICTIVE 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 3.7.11 Applicability is during movement of irradiated fuel assemblies in the Auxiliary Building. Als change reduces the Modes of Applicability from whenever irradiated fuel is in the storage pool to whenever 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 fuel pool, ne reduction of the Mode of Applicability is considered a less restrictive change. nis 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 relative 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. His change decreases the Surveillance Frequency from 18 months to 24 months. He 24-month 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. Herefore, 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. Here is no instrumenta.on associated with this Technical Specification requirement. Decreasing Survei!!ance Frequencies constitutes a less restrictive change. His change is consistent with NUREG 1432 and the guidance in Generic Letter 91-04. CALVERT CLIFFS - UNITS 1 & 2 3.7.11 3 Revision 10

ATTACHMENT (4) IMPROVED TECIINICAL SPECIFICATIONS, REVISION 10 AMENDMENT REVISION BY ITS SECTION f Italtimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 5,1997

. = _ -. -.. -. -. Page Replacessent lastructioos YOLUME 5 Section 3.1 Note: Underlined titles indicate tabs I; volumes. Regarding C75 markups: Pages are referenced by citing the unit number as neII as the spec @ cation numb :r located in the upper right-hand corner ofthe CTSpage. Key: EX)C = QiscussIon ofChanges DOD = Discussion Gf TechnicalSpec@ cation Deviation or Discussion Q(Bases Deviation REMOVE INSERT Overview of Channes None Ilft 3.1.1 1 3.1.1 1 through 3.1.1-4 ITS Bases il 3.1.14 through B 3.1.17 B 3.1.1-4 through B 3.1.1 8 CTS Markun & Discussion of Channes Spec @ cation 3.1.1, Unit ? Page I of 4 through Page 4 of 4 Page I of 5 through Page 5 of 5 Spechkation 3.1.1, Unit 2 Page 1 of 4 through Page 4 of 4 Page 1 of 5 through Page 5 of 5 DOC ? l.1 1 through 3.1.13 DOC 3.1.1 1 through 3.1.13 NSHC Findinas 3.16 through 3.121 3.1-6 through 3.121 ISTS Markup & Justification 3.1 1 3.1 1 and " INSERT 3.1.l" DOD 3.12 and 3.13 DOD 3.1-2 and 3.1 3 ISTS Bases Markup & Justification B 3.1-4 B 3.14," BASES INSERT LCO" and " BASES INSERT ACTIONS" il 3.15 B 3.1 5 11 3.1-6 B 3.16 and " BASES INSERT SRs" 1

SDM 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM) LC0 3.1.1 SDM shall be within limits as specified in the COLR, AND when in MODE 5 with pressurizer level < 90 inches, the reactor coolant system level shall be above the bottom of the hot leg 10 nozzles and all sources of non-borated water shall be s 88 gpm. APPLICABILITY: MODES 3, 4 and, 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. - - --- - - - NOTE - - - -- - - - A.1

NOTE -------

Only applicable in Not required if MODE 5 with SHUTDOWN MARGIN has t pressurizer level been increased to < 90 inches. compensate for'the # additional sources of to non-borated water. Non-borated water sources > 88 gpm. Suspend positive Imediately reactivity changes. AND CALVERT CLIFFS - UNITS 1 & 2 3.1.1-1 Revision glo

~. SDN 3.1.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 Initiate action to Immediately increase SHUTDOWN i MARGIN to compensate for the additional non-borated water sources. M A.3 Verify SHUTDOWN Once per MARGIN has been 12 hours increased to IO compensate for the additional sources of non-borated water. 1 B. - - - - - - - - N OT E - - - - - - - - B.1 Suspend positive Immediately Only applicable in reactivity changes. MODE 5 with pressurizer level M < 90 inches. B.2 Initiate action to Innediately increase reactor Rehetor coolant coolant system level system level at or to above the bottom below the bottom of of the hot leg .the hot leg nozzles, nozzles. C. SDM not within limit C.1 Initiate 1 oration to In.wdiately for reasons other-restore SDM to within -than Condition A or limit. ID .B. CALVERT CLIFFS - UNITS 1 & 2 3.1.1 't Revisiong/0 . - -. - =. -.. - -. - -. - -

SDM 3.1.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SDM is within limits specified in the 24 hours COLR. i SR 3.1.1.2

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

Only required in MODE 5 with pressurizer level < 90 inches. Verify reactor coolant system level is above Once within the bottom of the hot leg nozzles. I hour after achieving MODE 5 with ID pressurizer level < 90 inches 8.N_Q 12 hours thereafter CALVERT CLIFFS - UNITS 1 & 2 3.1.1-3 Revision glo

_- -. - - - =. _ _ _ = SDN 3.1.1 SURVEILLANCE REQUIREMENTS (continued) SURVFILLANCE FREQUENCY l SR 3.1.1.3-

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

Only required in MODE 5 with pressurizer level < 90 inches. Verify non-borated water sources s 88 gpm. Once within 1 hour after achieving IO MODE 5 with pressurizer level < 90 inches 8!!Q 12 hcurs thereafter 1 t i i CALVERT CLIFFS - UNITS 1 & 2 3.1.1-4 Revision g to

SDM B 3.1.1 BASES Depending on the system initial condicions and reactivity insertion rate, the uncontrolled CEA withdrawal transient is terminated by either a high power trip or a high pressurizer pressure trip. In all cases, power level, RCS pressure, linear heat rate, and the DNBR do not exceed allowable limits. Shutdown margin satisfies 10 CFR 50.36(c)(2)(ii). Criterion 2. LCO The MSLB and the boron dilution accidents (Ref. 3) are the most limiting analyses that establish the SDM value of the LCO. For MSLB accidents, if the LCO is violated, there is a potential to exceed the DNBR limit and to exceed the g acceptance criteria given in the UFSAR (Ref. 3). For the boron dilution accident, if the LC0 is violated, then the minimum required time assumed for operator action to terminate dilution may no longer be applicable. Because both initial ructor coolant system level and the dilution-flow rate also significantly impact the boron dilutionivent' lo in MODE 5 with pressurizer level < 90 inches from the bottom of the pressurizer, the LCO also includes limits for these . parameters during these conditions. Shutdown margin is a core physics design condition that can be ensured through CEA positioning (regulating and shutdown CEA)inMODES1and2andthroughthesolubleboron concentration in all other MODES. l APPLICABILITY In MODES 3, 4, and 5, the SDM requirements are applicable to provide sufficient negative reactivity to meet the assumptions of the safety analyses discussed above. In MODES 1 and 2. SDM is ensured by complying with LCO 3.1.5, " Shutdown Control Element Assembly (CEA) Insertion Limits," and LC0 3.1.6, " Regulating Control Element Assembly (CEA) l CAlitRT CLIFFS - UNITS 1 & 2 B 3.1.1-4 Revision Elo

SDM B 3.1.1 BASES Insertion Limits." In MODE 6, the shutdown reactivity requirements are given in LCO 3.9.1, " Boron Concentration." ACTIONS A.I. A.2. and A 3 With non-borated water sources of > 88 gpm available, while j the unit is in H0DE 5 with the pressurizer level < 90 inches, the consequences of a boron tiilution event may exceed the analysis results. Therefore, u. tion must be initiated immediately to reduce the potential for such an event. To accomplish this, Required Action A.1 requires imediate suspension of positive reactivity additions. However, since Required Action A.1 only reduces the potential for the event and does not eliminate it, immediate action must also be initiated to increase the SHUTDOWN MARGIN to compensate for the non-borated water sources (Required Action A.2). Finally, Required Action A.3 requires periodic verification, once per 12 hours, that the SHUTDOWN MARGIN increase is maintained sufficient to compensate for the additional sources of non-borated water. 10 Required Action t.1 is modified by a Note which indicates that the suspension of positive reactivity additions is not required if SHUTDOWN MARGIN has been sufficiently increased to compensate for the additional sources of non-borated water. The imediate Completion Time reflects the urgency of the corrective actions. The periodic Completion Time of 12 hours is considered reasonable, based on other administrative controls available and operating experience. B.1 and B.2 With the reactor coolant system level at or below the bottom of the hot leg nozzles, while the unit is in MODE 5 with the pressurizer level < 90 inches, the consequences of a boron dilution event may exceed the analysis results. Therefore, action must be initiated immediately to reduce the potential for such an event. To accomplish this, Required Action B.1 CALVERT CLIFFS - UNITS 1 & 2 8 3.1.1-5 Revision #/o

SDM i B 3.1.1 i BASES requires immediate suspension of positive reactivity additions. However, since Required Action B.1 only reduces the potential for the event and does not eliminate it, imediate action must also be initiated to increase the 10 reactor coolant system level to above the bottom of the hot leg nozzles (Required Action B.2). The immediate Completion Time reflects the urgency of the corrective actions. ful If the SDM requirements are not met for reasons other than addresseo in Condition A or 8, boration must be initiated promptly. A Completion Time of imediately is required to meet the assumptions of the safety analysis. It is assumed that boration will be continued until the SDM requirements are met. In the determination of the required combination of boration flow rate and boron concentration, there is no unique requ.rement that must be satisfied. Since it is imperative to raise the baron concentration of the RCS as soon as possible, the boron concentration should be a highly concentrated solution, such as that normally found in the boric acid storage tank or the refueling water tar.k. The operator should borate with the best source available for the plant conditions. However, as a minimum, the boration flow rate shall be 2 40 gpm and the boron concentration 4 shall be 2 2300 ppm boric acid solution or equivalent. Assumingthatavalueof1%Ak/kmustberecoveredanda boration flow rate of 40 gpm from the boric acid storage tank, it is possible to increase the boron concentration of the RCS by 100 ppm in approximately 15 minutes. If an inverseboronworthof100 ppm /% is assumed, this combination of parameters will increase the SDM by 1% Ak/k. These boration parameters of 40 gpm and 100 ppm represent L \\ CALVERT CLIFFS - UNITS 1 & 2 B 3.1.1-6 Revision 9fc3 L

SDN B 3.1.1 BASES typical values and are provided for the purpose of offering a specific example. SVRVEILLANCE SR 3.1.1.1 REQUIREMENTS Shutdown margin is verified by performing a reactivity balance calculation, considering the listed reactivity effects: a. RCS boron concentration; b. CEA positions; c. RCS average temperature; d. Fuel burnup basel in gross thermal energy generation; e. Xenon concentration; f. Samarium concentration; and g. Isothermal temperature coefficient. Using the isothermal temperature coefficient accounts for Doppler reactivity in this calculation because the reactor is subcritical and the fuel temperature will be changing at the same rate as the RCS. The Frequency of 24 hours is based on the generally slow change in required boron concentration, and'also allows sufficient time for the operator to collect the required data, which includes performing a boron concentration analysis, and complete the calculation. l l l 1. CALVERT CLIFFS - UNITS 1 & 2 B 3.1.1-7 Revision 0

i SDM B 3.1.1 l BASES SR 3.1.1.2 and SR 3.1.1.3 These Surveillances periodically _ verify the significant assumptions of a boron dilution event are maintained. A non-borated water source of s 88 gpm allows for only one charging pump to be capable of injection during these conditions since each charging pump is capable of an injection rate of 46 gpm. Each Serve 111ance is modified by a Note which indicates that it is only required when the unit is in MODE 5 with the pressurizer level < 90 inches. Since the applicable conditions for the Surveillance may be IO attained while already in MODE 5, each Surveillance is provided with a Frequency of once within one hour after achieving MODE 5 with pressurizer level < 90 inches. This i provides a short period of time to verify compliance after the conditions are attained. Additionally,each Surveillance must be completed once each 12 hours after the-initial verification. The 7requency of 12 hours is considered reasonable, in view of other administrative controls available, and operating experience. .s ~; ~ REFERENCES 1. UFSAR, Appendix 1C 2. UFSAR, Section 3.4 3. UFSAR, Chapter 14 CALVERT CLIFFS - UNITS 1 & 2 B 3.1.1-8 Revision g /o

%84de ~$l.) 5.l W 4 d REACTIVITY CONTROL SYSTEMS ?!'_:.: n./ := _.oa ,WT W .R.,. m., = O LIMITING Com ! TIM FOR DPERATI M M o 1 1.1 . :.;.7 The SMTDOW MAGIN shall be within the 11mit provided in the COLR. APPLICABILIIY: MMA 3 and 4. l With the $Np ERCIN outside the limit croy1ded in the C0',R. l t depe.# A <m tielf Anttiste _n"m:n% ration Jtpan owa nuo one herJ /).l [ac'4 so' utiest or-coulvafent(untif the requiru 5WTDOWN MRGIN is resttired. SURVEILLANCE REQUIREMENTS M I (' -l' l tui.i.i.i The $NUTDOW ERGIN shall be determined to be within the limit provided in the COLR. a. within o our after detection o an inoperable CEA(s) and tl letst on per 12 hours there f while the CEA(s) is inoper

e..!f the inoperabi EA is untrippable, the ve.

requ' d 5."UTDOW MAGIN sha be increased by an at least eqd to the trithdrawn weri of the~untrinnahl_e CEAf -J u a or z wun N ^ icsu un6: per ' hours ) l h*4, . unen in 4.v. a6 by veri Ing that CEA group,, thdrawai is within the tient Inser on Limits of Specif ation 3.1.3.6. M ee $ptefai Test g ption M. N CALVERT CLIFFS. UNIT 1 3/4 1 1 Amendment No. 186-was le

- ~ ~ ~. - -. _. - _ -. _. _ - ~. ~. -.. - -. -..... _. - SparfwM Udel 3/4.1 REACTIVITV CONTROL SYSTEMS SWRVE!LEANCE REQUtaEMENTS (Continued)

c. When E T withT(,,,

, within 4 hours prior t chTeving' l criticalit rest fan is with_1'y by fying that the predicted itical CEA q so the in of $secification 3. . 6.__ _ l ,l 1 Prior t nits' operat above M RAT W su- ~ F0WER after ors of (e) below,]I j-each 1 lo' is, by sideration of the f wit he C' aps the Transient insert Limits of g _1 s - M LI,I*g af When in N06 3 or 4tat least once per 24 hourspy consideration' pf the follb 51suorn 1. Reacto Coolant System boron c

riration, 2.

CEA sition. d' 3. te or Coolant Systes avers temperature 4. el burnup based on gross real energy g,eneratio. 5. enon concentration, and Samar_fue concentration. /- [4.1.1.1.Z The overall core reactivity balance shall be compared to predicted values to demonstrate acreement within i 1.M Ak/k at least onc]e per 31 Effective full Power Days (EFPD). This tem least those factors stated in Spect:-ication 4.1.1.parison shall consider at 1.1.e. above. The predicted reactivity values shall be adjusted'(normaltred) to correspond to the actual core conditions prior to exceeding a fuel burnup of 60 Effective g1 Power Days after each fuel indina. J. i S.M D ctuJcus <.>F c k p M i b Hvfn. k~ 3. l,2, " feat.h4 i Udmg" l CALVERT CLIFF 5 - UNIT 1 3/412 Amendment No. 186 l l l fY-L i ~'~~ ~~

Spa $ Ut*M " 3.l.\\ J.) 4/4rr REACT!YITY CONTROL SYSTEM $ 1/ w annattnw enutom (S DW h 3.y - =R== 3, v a D e LIMITING CONDITION FOR OPERATION 4.4.1.3-.The SWTDOWN MARGIN shall be within the Itait provided in the l C0 3* h l COLR-nd' when pressurifer level is lesn'than 90 inchesrrrm tse poleems g*3 h A WnefssurfrerDs11, sources of non borated water shall be s; 88 ppe. y/0 APPLICABILITY: MODE 5. " '8 d U

Y '^**I* M O * * ""

s bdex ok b kot b nottlr5 clad 4 ACTION: With the $NUTDOWN MARGIN outside the Ilmit provided in the COLR, l a. Mf1* C '"*dt'1r d ai t ' * * * *ad eaat 'a** f 6'1* * "*'> d o '"- "' "6S 68 3 @lLbor.LCJcru sosunon or eautvaien_tantil the required $NUTDOWN sutGTN is restored. b. With the pressurizer drained to < 90 inches and all sources of non borated water > 88 ppm immediately suspend all operations MT'W S involvingpositivereactivItychangeswhilethe$NUTDOWNMARGIN i is increased to comoensate for the additi_onal sources of non-l berated waterfoWuce)tft sougs opton-bytted waM 103 b8 V9VI V fa%P.T nesa Aciocu 8 ) SURVEILLANCE REQUIREMENTS ift 3.1 l. \\ 4rl,4.2.3. The $NUTDOWN MARGIN shall be determined to within the Ilmit provided in the COLR (s. Within one ur af ter detection of a inoperable CEA(s) and 1 least one per 12 hours thereafter 11etheCEA(s)is /),Q i inopera e. If the inoperable C is untrippable, the abo requir d $NUTDOWN MARGIN shall increased D an amount t unumi in the withdrawn werth t he untrinnah{e CEAf s)./-t leas # j % _At least once per 24 hoursyy nsideration of th ollowing rTactor ; @,*L 1. eactor Coolant S CEA position., yst boron concentra n. CALVERT CLIFr$ - UNIT 1 3/413 Amendment No. 186 pq 3d5 h

i INSERT new ACTION B B, .-..-...N0TE.......-- B.1 Suspend positive -Immediately k -Only applicable in reactivity changes. MODE 5 with pressurizer level 6HQ < 90 inches. + B.2 Initiate action to Imediately increase reactor - Reactor coolant system coolant system level i level at or below the to above the bottom bottom of the hot leg of the hot leg -nozzles. nozzles. l 4 ) = 9 l I' i. 'h

l I 8 pes. [ce b s* 2 /e / f I i 3/4.1 ktAff!VITY CONTROL SYSTEMS i suert1Lugtt tigp!REMENTS (Continued) --- r s- ' 3. Rea r Cociant $yst everap'e t retum. g,rg 4. F burnup based gross the energy generation.J 5. concentratiatIon d[ an 6. 5 rium concen 4.1.1.2.2 With the pressurit' drained to

90 inches deterstnes t

the Reactor Coolant System is above the bottee of the hot leg (pD - g'g'g'g

a. Within one hour and every 12 hours thereafter that the level in nozzles, and i

s g. 3, l, g,3 b. Within one hour and evev 12 hours thereafter that the sources of - non. borated water are <. l8 eneror Ine awverveur puuuizu has Deen increaTes to compensate 'or sne addittunal non borated water - AC.WW O sources. ,1 J e .ty 3:; n w 3 n :,, y >v s. t i l l . i CALVERT Cliff $. UNIT 1 3/4 1 4 Amendment No. 186 l

c. f. c w,.e,

3. l. !

i 3', l

$f4
REACT!YITY. CONTROL $YSTDi$

ipMitF CONfflet [oM "T. l. I S/4rl + HEFJtMAasts M ~p Q y,,, unna C0er.on rm munn _ O Dre,44 The $WTDOW EMIN shall be within the limit provided in the COLR. APPLICABILITYe hM3 and 4. l A c,Tior/ 4

With the $ WIDOW MAR $!N evtside the 11mit ortvided in the COLR.

l ately inittaty s i ~oorathi - - -- - -- = -- -.a the reqvf re4 5NT90let MAGIn i', restored. ~ s

ns spewnen or og 1

un SWVEILLAkEE RE0llIRDIDif$ D '. l. I 4.i.i.i.i The SWTDOW MARGIN shall be detenstned to be within the Italt provided-in the COLR

a. W1 hour after det of an inoperable

)andat 1 once per 12 hou reafter while the C s noperable. If the roble CEA is untrl le. the abcVe j required I shall-be*increas y an amount at 1 toqual to the rawn worth of the unt pobleCEA(s)_ ts.T When ES 1 or2 wt z 4.v..i b. vuu per 12 rs l by rt i that CEA withdrawal i thin the Tra ent serti mits e cification 3.1. .f i f Igest Ex[on 3.102) CAlvERT CLirrs - unir 3/4 s. Ameno.ent na is3 i.c s. S 7.,y

1 Sporf.r a4.o 3.\\.l 3/4.1 ptACTIVITY CONTROL SY$7Dt$ $URVEILLAllCE REQU!kDIDITS (Centineed) c. When 2 with l(,,,< 0, within 4 hours for to achiev M l or criticality fylgSpecif that the ted critic sition is within llott ton 3.1.1.8. C. ' Prf or el loading.perati nitial o ve M anias FUlfER after by sideration of t ctorsof(e) ese Iw the CEA groups the Transient In ton t.tatts of I 1fication 3.1 .6.- ' ' I pl When in HDDES 3 or 4. at least once f.er 24 hours [y considerat n' I sne roll ng 1.un.. 1 Rea r at System boron centration. acIorCoolantSystemav 3. ge temperatrie. 4 Fuel burnup based on gro thermal energy gene .on. Xenon concentration )

4. Samarfue concentrat j

T.1.1.1.2 The overall core reactivity esiunce shall av crearea to ' predicted values to demonstrate agreement within i1.0% Ak/k at least onc]e per 31 Effective Full Power Days (EFPD). This comparison shall consider at least those factors stated in specification 4.1.1.1.1.e. above. Th2 predicted reactivity values shall be adjusted (normalized) to correspond to l the actual core conditions prior to exceeding a fuel turnup of 60 Effective) gli Power Days after each fuel loading. [ 4 Iee di, <., s...,. I c L,. 5.$ P=r 4p# L +.. ~3.\\.7., Nr. b.4 7 Ea(a-ce

i i

l r l l CALVERI CLIFFS - UNIT 2 3/4 1 2 Amendment No. 163 l { o}t' 09 b

h

hocMe tim

3. l. l 3.1

-5/4,4. htACTIVITY CGETRAL SYSTDel f Stetri-DollATIQlf CopfTil0L $0% h i. is,f -,.. g ; r : LIIIITIst Cam!T!all Fet OptRATION l C o 3.t.1 0.3.;.i' d_when oressuriner level ta lent *ba 90 inchas ffssi Wyg The $ NUT 90tel114A615 shall be within the Itatt provided in the - COLR.'an tri-n>'T2rL411 sources of non borated water shall De 5 55 gym. be(t 06 bolm of[hekol'le3pitles aw e reacfer ceolast h level sid kc APPLICA8

MODE 5.

DON D

a. With the savTastal M446!N outside the Itatt provided in the c0LR, l

Ismediately initiate and continue bo_ ration 11 wo:-m fah 74,) C '- :: e in avi ;......ivaten/1Tntti the required 511U730hA1 mumsu is restored.

b. With the pressurtzer drained to < 90 inches and all sources of g04 g non-borated water > 88 gym tamediately suspend all operations involving positive mactivIty changes while the SNUTBotel MAR $1R 1s increased to_cospensate for the addttional sources of_ non.

horated wetenemouconne Aseces oPhoebbeteted settr) f {}e f 88A.J &%MSER.T t'ew Ac1 tor),8 f SURVEILLAllCE R10NIRDIDfTS % 3.1.l.) ii.i.4.i.i The $ NUT 90tAl MARGIN shall be detemined to be within the Itatt provided in the COLRs erwhiletheCEA(s)[is

a. Within hour after detection an inoperable CEA s) nd a least able.per 12 hours there ce

(} ino If the inopera CEA is untrippable, t above utred SIIUT90tal MARGIN 11 be increased by an unt at less ual to the withdrawn, rth of the untrippable (sl h At least once per 24 hoyu sideration of the fo owinh rfectors - I (. " \\ L.- r'\\. 1. eactor Coolant Syst ron concentration, CEA position, y p CALVERT CLIFFS - L*17 2 3/4 1 3 Amendment No. 163 ye of f

1 INSERT new ACTIO;' B t i i B.

NOTE----------

B.1 Suspend positive imediately Only applicable in reactivity changes. MODE 5 with pressurizer level 6@ < 90 inches. B.2 Initiate action to Imediately increase teactor Reactor coolant system coolant system level level at or below the to above the bottom _ bottom of the hot leg of the hot leg nozzles. nozzles. ,. - W?t ~ e 1 o I D

kpoc$ses+sm T. \\. \\ 3/4.1 RfACTIVITY CONTROL SYSTDIS SURVEILtAllCE RE453RDENTS (fsatinued) (5. Iles r um8M zystem evera temperature, i 4. F bornup based on gross mal energy gener ton g 4* 5. ron concentration a e y. _ Samarine concatratI f 4.1.1.2.2 With the presstriser drained to < 90 inches detemines gg 3'y'g'g

a. Within one hour and every 12 hours thereafter that the level in 10 the Reactor Coviru System is above the bottom of the hot les nosales, and gt 3,g,g,3

b. Within one hocr and every 12 hours thereafter that the sources of non-borated water am 5 88 contor the assisaal MARGIN has been increased to compensate for the additional non-borated Vater

' 8tTsoPJ 8 I' i ,V5 7

f. '

s CALVERT filFFS - UNIT 2 3/4 1-4 Amendment No. 163 l P O

DISCUSSION OF CHANGES SECTION 3.1.1 - SHUTDOWN MARGIN ADMIN 1fiIRAllYE_ CHANGES A.1 He proposed change will reformat, remimber, and reword the existing Technical Specifications, with no change of intent, to be consistent with NUREG-1432, " Standard Technical Specifications, Combustion Engineering Plants." 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 f'liffs improved Technical Specifications (ITS) development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each Limiting Condition for Operation (LCO) and to be consistent with NUREG-1432, liowever, the additional information does not change the intent of the current Te:hnical Specifications. He reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Current Technical Specification (CTS) Surveillance Requirements (SRs) 4.1.1.1.1.a and 4.1.1.2.1.a require that the Shutdown Margin (SDM) be increased by at least the amount a equal to the withdrawn worth of the untrippable control element assembly (CEA) within I hour after the CEA is inoperable, and every 12 hours thereafter. Improved Technical rpecification 3.1.1, will not require this requirement because this condition is required to be accounted for in the definition of SDM He definition requires the calculation of SDM to account for any CEA not capable of being fully inserted. Therefore, this change is administrative because appropriate Actions exist elsewhere in the ITS that address this condition. This change is consistent with NUREG-1432. A.3 Current Technical Specifications 3.1.1.1 and 3.1.1.2 (SDM-T,, > 200'F and SDM-T,, s 200'F, respectively) are being combined into one Technical Specification in ITS 3.1.1. The LCO Act?ons and SRs are identical; therefore, combining the two Specifications is logical. Combining Technical Specifications, while retaining requirements, constitutes an administrative change. This change is consistent wi.h NUREG-1432, TSTF-136. A.4 Current Technical Specification 4.1.1.1.1.b requires the SDM to be determined by verifying the CEA groups are within the power dependent insertion limits (PDILs) when in Modes I and 2 with Ker 2: 1.0. His requinment is being deleted because it exists in the Regulating CEA Insertion Limits Technical Specification (CTS 4.1.3.6 and ITS SR 3.1.6.1). The deletion of a requirement that exists in another Technical Specification constitutes an administrative change. This change is consistent with NUREG-1432. A.5 Current Technical Specification 3.1.1.2 Action b includes a final requirement option of "or reduce the sources of non-borated water to s 88 gpm." This is essentially an action to restore the parameter to within the limits required by the LCO. 'Since this is always an option, it need not be specifically delineated when other actions are also required. Therefore, this action is not specifically included in ITS 3.1.1. Ilowever, since it remains an option, the change is one of format only, and is therefore, administrative in nature. CALVERT CLIFFS - UNITS I & 2 3.1.1-1 Revision 10

l DISCUSSION OF CHANGES SECTION 3.1.1 - SHUTDOWN MARGIN TECIINICAL CIIANGES - MORE RMTRICTIVE M.I Current Technical Specification 4.1.1.2.2.a includes requirement to penodically verify the RCS level is above the bottom of the hot leg nozzles. His SR assures this initial assumption of a Boron Dilution Event is maintained in accordance with the analysis. Ilowever, the Current Technical Specification does not include an actual LCO requirement, nor an action to fulfill should the SR not be met. Therefore, the appropriate LCO requirements and Required Actions are incorporated for this SR. This change is consistent with the structural content requirements of the improved Technical Specifications, and with the current licensing basis. TECIINICAL CIIANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEF CONTROLI FD DOCUMENTS LA.1 Current Technical Specifications 3.1.1.1 and 3.1.1.2 Actions require that boration be continued at 2 40 gpm of 2300 ppm boric acid solution or equivalent until the CDM is restored. Rese specific procedural requirements regarding the rate of boration will be relocated to the Bases. These details are not necessary to ensure the SHUTDOWN MARGIN will be restored to within the limit specified in the COLR. Improved Technical Specification 3.1.1 ACTION A, which requires action to be immediately initiated, is adequate for ensuring the SHUTDOWN MARGIN is restored. As such, these details associated with this Action are not necestsry to be in the Technical Specifications to ensure the SHUTDOWN MARGIN is restored to within the limit in the COLR. Changes to the Bases will be controlled by the provisions of the Bases Control Program described in Chapter 5 of the ITS. This change is consistent with NUREG-1432. LA.2 Current Technical Specifications 4.1.1.1.1.e and 4.1.1.2.1.b require the SDM to be det rmined at least once per 24 hours by considering the following factors: boron concentration, CEA position, Reactor Coolant System (RCS) temperature, fuel b"rnup, and xenon and samarium concentration. The list of factors used to determine SDM is being moved to the Bases. Specific details on the calculation of the SDM is not appropriate for the Technical Specifications and can be adequately controlled in the Bases. Any changes to the Bases will be performed in accordance with ITS Section 5.0 Bases Control Program. The Bases Control Program will ensure that any changes to this requirement receive an appropriate review. This change is consistent with NUREG-1432. LA.3 Current Technical Specification 3.1.1.2 comains additional requirements associated with the pressurizer level and indicates that the pertinent presse6r level is based on level measurement "from the bottom of the pressurizer." This detail of the requirement is being moved to the improved Technical Specification Bases since it is not necessary to delineate the actual requirement. The ITS will maintain the requirements based on pressurizer level, with the Bases indicating that the required pressurizer level is based on measurement from the bottom of the pressurizer. The movement of this detail to the Bases as part of the conversion to NUREG-1432. Any changes u 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 CALVERT CLIFFS - UNITS 1 & 2 3.1.1-2 Revision 10 1

l DISCUSSION OF CHANGES SECTIO!. 3.1.1 - SHUTDOWN MARGIN these requirements will be appropriately reviewed. His change is consistent with NUREG 1432. TECIINICAL CHANGES - LESS RESTRICTIVE L.1 Current Technical Specification 3.1.1.1 (SDM - T,y, > 200 F)is applicable in Modes 1,2,3, and 4. Improved Technical Specification 3.1.1 will require this Specification to be applicable in Modes 3 and 4. In Modes 1 and 2 the SDM is maintained within limits by complying with the CEA alignment limits for the Shutdown and Regulating CEAs in ITS 3.1.5 and 3.1.6, respectively. The CEA alignment limits do not apply in Modes 3 and 4, which is why the ITS 3.1.1 SDM requirement is needed. Eliminating plant conditions from the Mode of Applicability for Technical Specifications constitutes a less restrictive change. His change is consistei.t with NUREG 1432. In conjunction with this enange, CTS 4.1.1.1.1.c and d will be deleted because they require an SDM calculation in Mode 2. These SRs will no longer be required because the SDM in Modes 1 and 2 are determined by verifying the CEAs are wi*hin the PDILs. L.2 Not used. l CALVERT CLIFFS - UNITS 1 & 2 3.1.1-3 Revision 10

NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS +3 maintained by complying with the control element assembly (CEA) insertion limits Technical Speci0 cations for the Shutdown and Regulating CEAs. This change is consistent with the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? De proposed change revises the Modes of Applicability for the SDM - T.,, > 200*F Technical Specification from Modes 1,2,3, and 4 to Modes 3 and 4. The SDM in Modes I and 2 will be maintained by complying with the CEA insertion limits Technical Specifications for the Shutdown and Regulating CEAs. His change does not involve a significant change in the design or operation of the plant. No bardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? The proposed change revises the Modes of Applicability for the SDM - T.,, > 200'F Technical Specification from Modes 1,2,3, and 4 to Modes 3 and 4. This change will not affect the SDM requirements because the SDM will be maintained in Modes 1 and 2 by complying with the Technical Specifications for shutdown and regulating CEA. insertion limits. His change does not affect the SDM assumed in the safaty analyses. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.1 Change I 1 Not used. l 3.1.2 Chnnee L.1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change will replace the :urrent Actions to immediately borate with Actions to perform an engineering evaluation and set up appropriate operating limits within seven days when the core reactivity balance is not within limp i. He failure to borate during a reactivity anomaly is not an initiator of any analyzed event. This change allows time to evaluate the reactivity anomaly, rather than borating to increase SDM, when the cause of the reactivity anomaly is not known. Dorating may not resolve the reactivity anomaly. An engineering evaluation will resolve the problem by allowing the cause of the reactivity anomaly to be identified and the correct actions to be taken to resolve the reactivity anomaly. He engineering evaluation is required to be completed within seven days, which allows sufficient time to assess the physical condition of the reactor and complete the evaluation of the core design and safety analysis. If the evaluation determines the core is not unacceptable for continued operations or appropriate restrictions and Surveillance Requirements are not established, a unit shutdown will be required. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or CALVERT CLIFFS - UNITS I & 2 3.1 6 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS mitigation of analyzed evene and, therefore, does not involve a significant increase in the probability or consequence of a a accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed change will replace the current actions to immediately borate with actions to perform an enginecting evaluation and set up appropriate operating limits within seven days when the core reactivity balance is not within limits. His change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change, ne proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? The proposed change will replace the current actions to immediately borate with actions to perform an engineering evaluation and set up appropriate operating limits within seven days when the core reactivity balance is not within limits, nis change allows timc to evaluate the reactivity anomaly, rather than borating to increase SDM, when the cause of the reactivity anomaly is not known. Thus, borating may not resolve the reactivity anoma!y. Allowing j seven days for the engineering evaluation will allow time to assess the physical conditions of the reactor and complete the evaluation of the core design and safety analysis. A plant shutdow1 may also be prevented because the most likely outcome of the evaluation is the adjustment of design calculations. During this 7 day period, there will still be adequate SDM, or else a correction of the problem in a short time or a plant shutdown would be required. In addition, if the evaluation determines the core.is not acceptable for continued operations, or appropriate restrictions, and Surveillance Requirements are not established, a unit shutdown will be required. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.2 Chanee IM 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? This change increases the due date for the second performance of the Surveillance by 29 EFPD (from 31 EFPD to 60 EFPD). After 60 EFPD, the Surveillance will be performed everv 31 EFPD. Core reactivity, as a result of extending the due date for the performance of the second core reactivity balance, is not an initiator of any analyzed event. This 60-EFPD delay after each fuel loading will allow time for core conditions to reach steady-state, which will produce more accurate results for final benchmarking the design calculations. This delay is acceptable because the results obtained and any adjustments made from the initial test provide confidence that the core recctivity is adequate to allow continued operation during the delay period. His change will not significantly affect the assumptions relative to the mitigation of accidents or transients. The proposed char.ge does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a signi6 cant increase in the probability or consequence of an accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 3.1-7 Revision 10

NO SIGNIFICANT IIAZARDS CONIIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 2. Does the change create the possibility of a new or different kind of accident from any accident previously evalnated? His change increases the duc date for the second performance of the Sumillance by 29 EFPD (from 31 EFl'D to 60 EFPD). After 60 EFPD, the Surveillance will be performed every 31 EFPD. His change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? His change increases the due date for the second performance of the Surveillance by 29 EFPD (from 31 EFPD to 60 EFPD). After 60 EFPD, the Surveillance will be performed every 31 EFPD. He initial reactivity balance is sufficient to allow continued operation until 60 EFPD after each fuel loading. At 60 EFPD, the core conditions have reached a steady state condition which allows performance of the reactivity balance and, if required, a benchmark to the design calculations, which yield results that should reflect core reactivity for the remainder of the fuel cycle, nerefore, the proposed change does not involve a significant redaction in a margin of safety. 312 Change L.3 I. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? He proposed change revises the Applicability for reactivity balance from Modes 1 and 2 to Mode 1. The reactivity balance in Mode 2 is not an initiator of any analyzed event.; The Mode 2 - Applicability for reactivity balance is not needed because, in Mode 2, sufficient operating margin exists between the operating conditions and the design limits to ensure the plant is being operated in a safe condition. Cantinued operation in Mode 2 allows diagnostic testing to be performed to determine the cause of the oot-of-limit condition. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or miti ation of analyzed events and, F therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed change revises the Applicability for reactivity balance from Modes 1 and 2 to Mode 1. This change does not involve a significant change in the design or operation of the pbut. No hardware is being added to the plant as part of the proposed Aange. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? The proposed change revises the Applicability for reactivity balance from Modes 1 and 2 to Mode 2. The change will allow continued operation in Mode 2, which is required to perform diagnostic testing. Continued operation in Mode 2 is allowed because sufficient operating CALVERT CLIFFS - UNITS 1 & 2 3.1-8 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTF.MS margin exists to ensure the plant is operated in a safe condition. Herefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.4 Chnnoe L.1 1. Does the change involve a significant increase in the probability or consequences of an sccident previously evaluated? The proposed change increases the allowed outage tii..e (AOT), when two CEAs are misaligned between 7.5 inches and 15 inches from I hour to 3 hours. Control element assembly misalignment between 7.5 and 15 inches is not u initiator of any an; yzed event. This increase in AOT is acceptable because the current AOT assumes the power distribution limits are not within limits. The proposed change allows the power distribution Technical Specifications to control the AOT for power distribution limits that are not within limit, rather than trying to control the AOT for power distribution limits in the CEA Alignment Techaical Specification. His change will not significantly affect the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident pre.viously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previossly evaluated? The proposed change increases the AOT when two CEAs are misaligned between 7.5 inches and 15 inches from I hour to 3 hours. His change does not involve a significant change in the design or op: ration of the plant. No hardware is being added to the plant as part of the proposed change, ne proposed change will not introduce any new accident initiators. Therefore, the e change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? The proposed change increases the AOT when two CEAs are misaligned between 7.5 inches and 15 inches from I hour to 3 hours. The 2-hour increase in AOT will allow for enough time to determine the cause of the problem and take appropriate action. Also, it reflects that power distribution concerns are not factored into the CEA Alignment Specification, but rather allow the plant to rely on the power distribution limit Technical Specifications, and follow their actions if power distribution limits are out-of-limits. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.4 Chnnoe L.2 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change requires Thermal Power to be reduced to s 70% Rated Thermal Power (RTP) when CEAs are misaligned by > 7.5 inches. Previously, power was requiied to be reduced to the greater of either 75% of Thermal Pov'er at the time of the deviation, or 50% RTP if nermal Power is greater than 50% RTP, or at the existing power if less than 50% RTP. The purpose of the power reduction is to ensure that acceptable power distribution limits are CALVERT CLIFFS - UNITS 1 & 2 3.1-9 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 7.1 - REACTIVITY CONTROL SYSTEMS maintained. Misaligned CEAs greater than 7.5 inches is not an initiator of any analyzed event. Thermal Power maintained less than 70% RTP provides reasonable assurance that acceptable power distributions due to CEA misalignments are maintained. Also, performance of power distribution Surveillances every 12 hours provide additional assurance that the power d stribution limits are being maintained. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. He proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? He proposed change requires Thermal Power to be reduced to s 70% RTP when CEAs are misaligned by > 7.5 inches. Previously, power ws required to be reduced to the greater of either 75% of Hermal Power at the time of the deviation, or 50% RTP if Hermal Power is greater than 50% RTP, or at the existing power if less than 50% RTP. He purpose of the power reduction is to ensure that acceptable power distribution limits are maintained. His change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? The proposed change requires hermal Power to be reduced to s 70% Rated Hermal Power when CEAs are misaligned by > 7.5 inches. Previously, power was required to be reduced to the greater of either 75% of Thermal Power at the time of the deviation, or 50% RTP if Hermal Power s greater than 50% RTP, or at the existing power ifless than 50% RTP. The purpose of the power reduction is to ensure that acceptable power distribution limits are maintained. This change is acceptable because the Thermal Power reduction to.70% RTP, along with the performance of the power distribution Surveillances every 12 hours, provide assurance the power distribution limits are maintained for CEA deviations greater than 7.5 inches. Herefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.4 Chance L3 Not used. r MdChance L4 1. Does the change involve a significant inercase in the probability or conseqaences of an accident previously evaluated? The proposed change decreases the Frequency of the Surveillance to move the CEAs 7.5 inches (CEA exercising) from 31 days to 92 days. No analyzed event is initiated as a result of exercising the CEAs. Extending the Surveillance interval is acceptable because there is other information in the Control Room available to the Operator, and other Surveillances are performed more frequently which add to the determination that the CEAs are Operable. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or mitigation of analyzed CALVERT CLIFFS - UNITS 1 & 2 3.1-10 Revision 10

-m +z/ J 4 ,ii. ..l r_4.. 4 .2.4 d-L J N0 SIGNIFICAP3 HAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? ne proposed change decreases the Frequency of the Surveillance to move the CEAs 7.5 inches (CEA exercising) from 31 days to 92 days. His change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. ne proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? He proposed change decreases the Frequency of the Surveillance to move the CEAs 7.5 inches (CEA exercising) from 31 days to 92 days. Other indication in the Control Room and Surveillances which are perforined more frequent provide assurance that the CEAs will trip when required. Also decreasing the Frequency may reduce the number of CEA drops which usually only occur during CEA exercising. While dropping a CEA usually does not result in a plant trip, it does cause perturbations in the power distribution limits, nerefore, the proposed change does not involve a significant reduction in a margin of safety. 31.4 Chance 13 1. Does the change involve a significant increase la the probability or consequences d u accident previously evaluated? The proposed change allows the CEAs to be either inserted or withdrawn during the CEA Surveillance which requires the CEAs to be moved 7.5 inches to prove CEA freedom of movement. Ensuring the CEAs have freedom of movement provides a level of assurance that the CEAs will trip when required. No analyzed event is initiated as a result of exercising the CEAs. Allowing the CEAs to be withdrawn, as well as inserted, provides the same confidence that the i CEAs have freedom of movement. Also, allowing the CEAs to be withdrawn is acceptable l because the withdrawal is limited to 7.5 inches, which is within the alignment limits for CEAs within c group. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Le proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed change allows the CEAs to be either inserted or withdrawn during the CEA Surveillance, which requires the CEAs to be moved 7.5 inches to prove CEA freedom of ( movement. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS I & 2 3.1-11 Revision 10 l

NO SIGNIFICANT IIAZARDS CONSIDERATIONS I SECTION 3.1 - REACTIVITY CONTRO!. SYSTEMS l 3. Does the change involve a significant reduction in a margin of safety? He proposed change allows the CEAs to be either inserted or whhdrawn during the CEA Surveillance, which requires the CEAs to be moved 7.5 inches to prove CEA freedom of movement. Ensuring the CEAs have freedom of movement provides confidence that the CEAs will trip when required. A 7.5 inch insenion or a 7.5-inch withdrawal will provides the same level of confidence that the CEA has freedom of movement. Allowing withdrawal of the CEA is also acceptable because the amount the CEA is withdrawn will not cause the CEA to be misaligned from the group. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 31.4 Change L(a Not used. 3.1.4 Change L7 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change increases the allowed outage time (AOT), when more than one CEAs are misaligned and any one of the misaligned CEAs is 215 inches from any other CEA in its group from no time to up to 3 hours. Currently, a shutdown is required, vehile the ITS will allow up to 3 hours to restore CEA alignment prior to requiring a shutdown. Control element assembly misalignment is not an initiator of any analyzed event. The consequences of an accident in the additional three hours are the same as the consequences during the current time provided to shutdown the unit. This increase in AOT is acceptable because the current AOT assumes the power disaibution limits are not within limits. The proposed change allows the power distribution Technical Specifications to control the AOT for power distribution limits that are not within limit, rather than trying to control the AOT for power distribution limits in the CEA Alignment Technical Specification. This change will not significartly affect the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different Idad of accident from any accident previously evaluated? The proposed change increases the AOT when more than one CEAs are misaligned and any one of the misaligned CEAs is 215 inclies from any oth;r CEA in its group from no time to up to 3 hours. Currently, a shutdown is required, while the ITS will allow up to 3 hours to restore CEA alignment prior to requiring a shutdown. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change oocs not create the possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS I & 2 3.1-12 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 3. Does the change involve a significant redaction in a margin of safety? The proposed change increases the AOT when more than one CEAs are misaligned and any one of the misaligned CEAs is 215 inches from any other CEA in its group from no time to up to 3 hours. Currently, a shutdown is required, while the ITS will allow up to 3 hours to restore CEA alignment prior to requiring a shutdown. The 3-hour increase in AOT will allow for enough time to determine the cause of the problem and take appropriate action. During this time the CEAs can still perform their required function of addir.g negative reactivity if a reactor trip is required and the effect on the ejected rod worth used in the accident analysis is small. While the misalignment of the CEAs also affects the thermal limits, the time is sufliciently short such that the effect ca the time dependent long-term power distributions relative to those used in generating the power distribution limits are not significant. The LCOs in Section 3.2 will continue to require that thermal limits be met. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 31.4 Change L.8 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated't ne proposed change deletes a requirement to declare the CEA misaligned by > 15 inches if a direct position indication is lost and cannot be restored within 10 minutes from the commencement of CEA motion or CEA withdrawal exceeds the testing insertion by > 7.5 inches, during the performance of the CEA motion. Control element assembly misalignments of 15 inches or more is not an initiator of any analyzed event. The pulse counter (Plant Computer CEA Position Indication System) can still provide information that can be used to reasonably determine the position of the CEA relative to other CEAs in its group. He CEA alignment limit is s 7.5 inches, and CTS 4.1.3.1.2 requires moving the CEA 7.5 inches, Thus, the CEAs are normally not moved outside the alignment limits during this test. In addition, ITS LCO 3.0.1 win still require the CEAs to be within their alignment limits. If the relative position of the CEA with respect to its group is unknown, then ITS SR 3.1.4.1 would not be met and ITS SR 3.0.1 would require ITS LCO 3.1.4 to be declared not met. His would result in the appropriate actions being taken for a misaligned CEA. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the poss!bility of a new or different kind of accident from any accident previously evaluated? The propost.d change deletes a requirement to declare the CEA misaligned by > 15 inches if a direct position indication is lost and cannot be restored wi.hin 10 minutes from the commencement of CEA motion or CEA withdrawal exceeds the testing insertion by > 7.5 inches, during the performance of the CEA motion. Ilowever, ITS LCO 3.0.1 will still require the CEAs to be within their alignment limits, if the relative position of the CEA with respect to its group is unknown, then ITS SR 3.1.4.1 would not be met and ITS SR 3.0.1 would require ITS LCO 3.1.4 to be declared not met. This would result in the appropriate actions being taken for a misaligned CEA. This change does not involve a significant change in the design or operation of the plant. No hardware is being add:d to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS I & 2 3.1-13 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 3. Does the change involve a significact reduction in a margin of safety? He proposed change deletes a requirement to declare the CEA misaligned by > 15 inches if a direct position indication is lost and cannot be restored within 10 minutes from the commencement of CEA motion or CEA withdrawal exceeds the testing insertion by > 7.5 inches, during the performance of the CEA motion. The pulse counter (Plant Computer CEA Position Indication System) can still provide information that can be used to reasonably determine the position of the CEA relative to other CEAs in its group. The CEA alignment limit is s 7.5 inches, and CTS 4.1.3.1.2 requires moving the CEA 7.5 inches. Thus, the CEAs are - normally not moved outside the alignment limits during this test. In addition, ITS LCO 3.0.1 will still require the CEAs to be within their alignment limits. If the relative position of the CEA with respect to its group is unknown, then ITS SR 3.1.4.1 would not be met and ITS SR 3.0.1 would require ITS LCO 3.1.4 to be declared not met. This would result in the appropriate actions being taken for a misaligned CEA herefore, the proposed change does not involve a significant reduction in a margin of safety. J.L4 Chance L.9 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? This change does not result in any hardware or operating procedure changes. The current requirement to verify CEA drop times are within limits prior to criticality for affected CEAs following maintenance on or modification to the CEA drive system which could affect drop times >f those specific CEAs is not assumed in the initiation of any analyzed event. _nis requircraent was specified in the current Technical Specifications to ensure the OPERABILITY of affected CEAs was positively verified following repair, maintenance, orfeplacement which could affect drop t' es. He deletion of this explicit requirement from the Calvert Cliffs ITS is considered administrative since ITS SR 3.0.1 requires the appropriate SRs to be performed to demonstrate OPERABILITY after restoration of a component that causes the SR to be failed. In this case, ITS SR 3.0.1 would require ITS SR 3.1.4.6 to be performed, which requires verification that drop times of the affected CEAs are within limia. As a result, the accident consequences are unaffected by this change. Herefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The possibility of a new or different kind of accident from any accident previously evaluated is not created because the change does not introduce a new mode of plant operation and does not involve physical modification to the plant. In addition, the ITS continue to require, after restoration of a component that caused a required SR to be failed, the appropriate SRs (in this case ITS SR 3.1.4.6) to be performed to demonstrate OPERABILITY of the affected components. 3. Does the change involve a significant reduction in a margin of safety? The deletion of the explicit requirement to verify CEA drop times are within limits prior to criticality for affected CEAs following maintenance on or modification to the CEA drive system which could affect drop times of those specific CEAs is considered administrative since ITS CALVERT CLIFFS - UNITS I & 2 3.1-14 Revision 10

NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS SR3.0.1 requires the appropriate SRs to be performed to demonstrate OPERABILITY after restoration of a component that causes the SR to be failed. In this case, ITS SR 3.0.1 would require SR 3.1.4.6 to be performed, which requires verification that drop times of the affected CEAs are within limits. As a result, the existing requirement to demonstrate, for affected CEAs, that drop time cf full length CEAs is within limits prior to criticality for affected CEAs follovring maintenance on or modification to the CEA drive system which could affect drop times is effectively maintained. Herefore, this deletica does not involve a significant reduction in a margin of safety. 3.13 Chance L.1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? This change increases the maximum time from 15 minutes to 12 hours, prior to withdrawing any regulating CEAs auring an approach to criticality, to verify the Shutdown CEAs are withdrawn 2129.0 inches. Verification of the Shutdown CEA group position is not an initiator of any analyzed event. Increasing the time before an approach to criticality that the Shutdown CEAs are verified to be withdrawn 2129.0 inches to 12 hours prior to withdrawng regulating CEAs is acceptable, ne Surveillance is still required to be performed; however, per SR 3.0.4, it will be performed at an interval equt! to its normal SR Frequency prior to entering the Modes of Applicability. Here is also an inarlock that prevents the regulating CEAs from being withdrawn if the Shutdown CEAs are withdrawn < 129.0 inches. This change will not significantly affect the assumptic'is relative to the mitigation of accidents or transients. The proposed change does not significantly afTect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? His change increases the maximum time from 15 minutes to 12 hours, prior to withdrawing an" regulating CEAs during an approach to criticality, to verify the Shutdown CEAs are withdrawn 2129.0 inches. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not inroduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? This change increases the maximum time from 15 minutes to 12 hours, during an approach to criticality and prior to withdraw;ng any regulating CEAs, to verify the Shutdrwn CEAs are withdrawn 2129.0 inches. The Surveillance will still be performed, per SR 3.0.4, at its normal Frequency. This extension in the time to verify the Shutdown CEAs are withdrawn 2129.0 inches is acceptable because an interlock will prevent the regulating CEAs from being withdrawn unless all the Shutdown CEAs are withdrawn 2129.0 inches. Therefore, the proposed change does not involve a significant reduction in a margin of safety. CALVERT CLIFFS - UNITS 1 & 2 3.1-15 Revision 10

l NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 3.1.5 Chandtil 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? His change increases the AOT from I hour to 2 hours to restore Shutdown CEAs to 2129.0 inches when they are withdrawn < 129.0 inches. Shutdawn CEA AOTs are not an initiator of any analyzed event. He main concern when CEAs are misaligned is the effects on the power distribution limits, his change is acceptable because the power distribution limits are being monitored in accordance with the power distribution Technical Specifications, which ensures that appropriate action is taken when power distribution limits are not within limits. This chuge will not significantly affect the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? This change increases the AOT from I hour to 2 hours to restore Shutdown CEAs to 2129.0 inches when they are withdrawn < 129.0 inches. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed chage. The proposed change will not introduce any new accideat initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? His change increases the AOT fror. I hour to 2 hours to restore Shutdown 'CbAs to 2129.0 inches when they are withdrawn < 129.0 inches. The power distribution limits are being monitored in accordance with the power distribution Technical Specifications, which ensures that appropriate action is taken if power distribution limits are not within limits. He additional AOT will enable the CEAs ta be adjusted in an orderly manner. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.5 ChangcL3 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? This change increases the AOT from no time to 2 hours to restore Shutdown CEAs to 2129.0 inches when they are withdrawn < 129.0 inches. Shutdown CEA AOTs are not an initiator of any analyzed event. This change is acceptable because the power distribution limits are being monitored in accordance with the power distribution Technical Specifications, which ensures that appropriate action is taken if power distribution limits are not within limits. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. He proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 3.1-16 Revision 10

NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 6 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? His change increases the AOT from no time to 2 hours to restore Shutdown CEAs to 2129.0 inches when they are withdrswn < 129.0 inches. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Derefore, the change does not create the possibility of a new or different kind of accident from eny accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? This change increases the AOT from no time to 2 hours to restore Shutdown CEAs to 2129.0 inches when they are withdrawn < 129.0 inches. The power distribution limits are being monitored in accordance with the power distribution Technical Specifications, which ensures that appropriate action is taken if power distribution limits are not within limits. The additional AOT will enable the CEAs to be adjusted in an orderly manner. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.14 Chanwe L1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? This change increases the AOT from no time to 15 minutes to ensure the regulating CEA groups do not exceed the short-term steady-state insertion limits, or that any power increases are limited to s 5% RTP per hour when CEA groups are inserted between the long term steady-state insertion limit for periods > 4 hours per 24-hour interval.' Regulating CEA AOTs are not an ' initiator of any analyzed event. The 15 minutes tr complete the Action is a short enough period such that the peaking factors which may develop are limited while allowing enough time for the operator to take the appropriate actions in a controlled manner. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. He proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? This change increases the AOT from no time to 15 minutes to ensure the regulating CEA groups do not exceed the short-term steady-state insertion limits, or that any power increases are hmited to s 5% RTP per hour when CEA groups are inserted between the long-term steady-state insertion limit for periods > 4 hours per 24-hour interval. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. i CALVERT CLIFFS - UNITS 1 & 2 3.1-17 Revision 10

I NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 3. Does the change involve a significant reduction in a margin of safety? His change increases the AOT from no time to 15 minutes to ensure the regulating CEA groups do not excxd the short-term steady-state insertion limits, or that any power increases are limited to s 5% RTP per hour when CEA groups are inserted between the long-term steady-state insertion limit for periocs > 4 hours per 24 hour interval, ne 15 minutes allow enough time for the operator to perform the Required Actions in an orderly manner, while minimizing the chances of an event occurring when the peaking factors may be outside limits. Herefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.6 Change L.2 I. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? His change deletes one of the two sets of time requirements limiting the amount of time a CEA could be inserted beyond the long-term steady-state insertion limit but within the transient insertion limit. Control element assemblies inserted beyond the long-term steady-state insertion limit are not considered initiators for any accidents previously evaluated, and therefore, cannot increase the probability of such accidents. Additionally, the consequences of an accident during the extended time proposed by this change are the same as the consequences of an acciderit during the time period allowed by the remaining set of time requirements. Therefore, this change does not increase the consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? ne proposed change does not involve a change in the design or operation of the plant. No hardware is being added to the plant as a part of this change. The proposed change will not introduce any new accident initiators, since the change is only allowing additional time to complete previously approved actions. Therefore, the change does not create the possibility of a new or different kind of accident from eny accident previously evaluated. 3. Does the change involve a significant reduction in a margin of safety? This change deletes one of the two sets of time requirements limiting the amount of time a CEA could be inserted beyond the long-term steady-state insertion limit but within the transient insertion limit. This change could allow a CEA to be inserted beyond the long-term steady-state insertion limit but within the transient insertion limit for a period of time longer than is currently allowed, however time limits are still imp. sed. With the CEA inserted beyond the long-term steady-state insertion limit but within the transient insertion limit, the SDM requirements are still maintained and the fuel design limits are not violated. in addition, at the reactor power level Calvert Cliffs normally operates (i.e., near 100% RTP), the deleted time requirement is less limiting than the requirement remaining in the ITS. Also during this time, the CEAs must not be inserted beyond the short. term steady-state Insertion limes or the transient in ertion limits of ITS 3.1.6 and the alignment limits of ITS 3.1.4 must still be met. If not, more restrictive requirements of ITS 3.1.8 and ITS 3.1.4 would be imposed. Therefore, the proposed change does not involve a significant reduction In a margin of safety. I 1 3.1 18 Revision 10 CALVERT CLIFFS - UNITS 1 & 2

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 3.1.7 Channe L.1 1. Does the change involve a significant increase in the probability or consequences of a.: - accident previously evaluated? His change expands the Applicability for the performance of the CcA worth measurement test from Mode 2 to Modes 2 and 3. Control element assembly worth measurement is not an initiator of any analyzed event. Control element assembly worth measurements are conducted in Mode 2. llowever, temporary dips into Mode 3 may occur due to the amount of negative reactivity being insened Expanding the Applicability to Mode 3 will allow entry into Mode 3 without having to borate to meet the SDM required in Mode 3. This is acceptable because the highest estimated CEA worth of the CEAs withdrawn is required to be available for trip insertion, and operation in Mode 3 is limited to six hours, nis change will not significantly affect the assumptions relative to the mitigation of accidents or transients. The proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in tbc probability or consequence of an accident previously evaluated. - 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? This change expands the Applicability fo-the performance of the CEA worth measurement test from Mode 2 to Modes 2 and 3. His change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not cccate the po.ssibility of a new or different kind of accident from any accident previously evaluated. 3. Does the change involve a significant reduction in a marg n of safety? 8 His change expands the Applicability for the performance of the CEA worth measurement test from Mode 2 to Modes 2 and 3. The change will allow entry into Mode 3 during the performance of this test. These entries into Mode 3 are the result of the amount of negative reactivity inserted into the core during the performance of this test. His is acceptable because the highest estimated CEA worth of the CEAs withdrawn is required to be available for trip insertion, and operation in Mode 3 is limited to six hours. Also, by expanding the Applicability, boration is avoided (due to the Shutdown requirements in Mode 3), and dilution is avoided to get back to Mode 2 in order to continue CEA worth testing, which is performed in Mode 2. Thus, a cycle of boration and dilution is avoided, which a plant transient. Herefore, the proposed change does not involve a significant reduction in a margin of safety. 3.1.7 ChangcL2 Not used. ,LI.8 Chance L1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? This change increases the AOT from no time to 15 minutes to reduce power back within the test power plateau (s 85%) when the test power plateau of the Special Test Exception has been CAINERT CLIFFS - UNITS 1 & 2 3.1-19 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS exceeded. The invocatien of Special Test Exceptions is not an initiator ef any analyzed event, nis change is acceptable because the AOT is a short enough period such that any affect on power distribution is limited while allowing a long enough period of time to take action to reduce power to back within the range of the test power plateau. Also, the linear heat rate Technical Specification Actions, which are still in effect, will work to minimize the likelihood of exceeding the power distribution limits, ne proposed change does not significantly affect initiators or mitigation of analyzed events and, therefore, does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change crecte the possibility of a new or different kind of accident from any accident previously evaluated? This change increases the AOT from no time to 15 minutes to reduce power back within the test power plateau (s 85%) when the test power plateau of the Special Test Exception has been exceeded. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from uy accident previously evaluated. 3. Does the change involve a sigulficant reduction in a margin of safety? His change increases the AOT from no time to 15 minutes to reduce power back within the test power plateau (s 85%) when the test power plateau of the Special Test Exception has been exceeded. The Linear Heat Rate Technical Specification, which is still in effect, minimizes the likefihood of exceeding the power distribution limits. The additional AOT will enable power to be reduced back to within the test power plateau.while the effects of exceeding the power distribution limits is limited. Also, an unnecessary plant shutdown may be avoided. Therefore, the proposed change does not involve a significant reduction in a margin of safety. ENVIRONMENTAL ASSESSMENT Rese proposed Technical Specification changes has been evaluated against the criteria for and identification oflicensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed changes meet the criteria for categorical exclusion as provided for under 10 CFR S t.22(c)(9). The following is a discussion of how the proposed Technical Specification changes meet the criteria for categorical exclusion. 10 CFR S t.22(c)(9): Although the proposed changes involve changes to requirements with respect to inspections or SRs, (i) proposed changes involve No Significant Hazards Consideration (refer to the No Signi'icant flazards Consideration section of this Technical Specification Change Request); (ii) there are no significant changes in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed changes do not affect the generation of any radioactive effluents, nor do they affect any of the permitted release paths; and CALVERT CLIFFS - UNITS 1 & 2 3.1 20 Revision 10

NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.1 - REACTIVITY CONTROL SYSTEMS (iii) there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(cX9). Based on the afirementioned and pursuant to 10 CFR 51.22 (b), no environmental assessment or environmental impact statement need be prepared in connection with issuance of an amendment to the Technical Specifications incorporating the proposed changes of this request. CALVERT CLIFFS - UNITS 1 & 2 3.1-21 Revision 10

I g --'Tsir g36 . W-{T/ 2pf*F](.'d ' 3.C [cr5) 3.1 REACTIVITY CGNTROL SYSTEMS s 3.1.1 SHUTDOWN MARGIN (SDN)('TM t#1)("ri4^ didlw llmits as speshied In Oc l' OLE, 736 1

3. l. l. l, LC0 3.1.1 SON shall be E ". :: C/3. gg gg
4 p,gg;,,,

3.1 1. E g , levet (ato inckes, tke. reet+,r e,obt vs+ca E h MODES 3 and PS [ leve,t slud be, oSeve se boitem of +(e het leg APPLICA8ILITY: nontes M d\\ semes of m.bnwd (uder skal\\ be. (ff $9 m. p -- ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME f.5 -""* "f-m25d I.1.1 l+ p Ac /,p., i. SDM not within 11 13 1 Initiate boration to e SM to wP.hin Tal.I[* Sor reascas oder n e.aat a a s. J G1pseer new awoas a< a; SURVEILLANCE REQUIRENENTS SURVEILLANCE -FREQUENCY-(k ai. skein. 4h Verify SDN is b,_'r,,'-. = 4.i.i.I.I.e \\SR 3.1.1.1 24 hours f.l.1.2. /.6) a A)SE P.T ne o 6 R 3. l.1.2. d SR.3. l.l.3 e CEOG ITS 3.1-1 Rev 1, 01/07/95

INSERT 3.1.1 A. NOTE--------- A.1

NOTE--------

Only applicable in Not required if MODE 5 with SHUTDOWN MARGIN has pressurizer level been increased to < 90 inches. compensate for the additional sources of non-borated water. Non-borated water sosces > 88 gpm. Suspend positive Immediately reactivity changes. MQ A.2 Initiate action to Imediately increase SHUTDOWN MARGIN to compensate for the additiorial non-borated water [ sources. AND A.3 Verify SHUTDOWN Once per MARGIN has been 12 hours increased to compensate for the additional sources of non-borated water. B.

NOTE---------

B.1 Suspend positive Immediately Onl; applicable in reactivity changes. MODE 5 with pressurizer level AND < 90 inches. B.2 Initiate action to Imediately increase reactor Reactor coolant system coolant system level level at or below the to above the bottom bottom of the hot leg of the hot leg nozzles. nozzles. 1

j 11NSERT43.1.14 m 'SR J3 1;1 2' ---.-------------NOTE---------------- 0nly required in MODE 5_ with . pressurizer level,< 90 inches.:

Verify reactor coolant ryitm level Once within

- l - is above the bottom of the hot leg l 1-hour aftert nozzles. achieving _ MODE 5' i with pressurizer; level < 90-inches-g: 12 hours thereafter -SR 3.1.1.3-

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

~ Only required in M00E.5 with $I _f$.$ $.. Once within Verify non borated water sources

lihour after-

s 88 gpm.

achieving MODE 5 with pressurizer level < 90 inches E 12 hours a thereafter p 4 A.. = + I M 9 i m ..,...,.-,,..r-v -,.y 7,.q.. ,,m ,.m, .r-* --'e

DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.1 - REACTIVITY CONTROL SYSTEMS 8. The specific Calvert Cliffs figure will replace the NUREO-1432 figure. 9. Not used. 10. Specification 3.1.6, " Shutdown CEA Insertion Limits," was changed to reflect that Calvert Cliffs' current licensing basis allows one Shutdown CEA to be withdrawn 2121.5 inches and < 129 inches. However, the time limit in this configuration is limited to s 7 days per occurrence, and s 14 days per 365 days, his change is acceptable for the short duration of time allowed because the Power Distribution Limit Technical Specifications in Section 3.2 ~ will ensure that the power dist ibution limits will remain acceptable. If not, appropriate Actions v.i!! be entered, 11. The Note to ISTS SR 3.L4.1 (ITS SR 3.1.3.1) and Note 2 to ISTS SR 3.1.4.2 (ITS l SR 3.1.3.2) have Men deleted. He Notes state that the SR does not have to be performed prior to entering the Applical,ility of the LCO. However, the Note is not needed since the actual Frequencies for the two Surveillances already provided this allowance. Improved Technical Specification SR 3.0.4 states that entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. The Applicability ofITS 3.1.3 is MODES I and 2. Ilowever, the Frequency for the first SR includes the words " prior to entry into MODE 1" and the Frequency of the second SR is "cach fuel cycle prior to reaching 47 EFPD." Each of these Frequencies allows entry into the Applicability of the LCO, without the use of a special note. In addition, the Bases for ITS SR 3.0.4 describes this concept, and ITS 1.4 provides an example (Example 1.4-2) where this type of Frequency is used. Therefore, the addition of these Notes is not necessary and their deletion is consistent with current licensing basis (The CTS does not have these notes). 12. The words in ISTS SR 3.1.4.1 (ITS SR 3.1.3.1) describing the location where the MTC upper limit is specified (i.e., COLR) has been deleted, improved Standard Technical Specification LCO 3.1.4 (ITS LCO 3.1.3) requires the upper limit to be within the limit specified not only in the COLR, but also within the maximum positive limit specified in ISTS Figure 3.1.41 (ITS Figure 3.1.3-1). Therefore, to remove any ambiguity, the SR now reads " Verify MTC is within the upper limit." 13. Improved Standard Technical Specification SR 3.1.7.1 (ITS SR 3.1.6.1) has a Note that l allows entry into MODE 2 without having the Surveillance current (i.e., entry into MODE 2 is allowed without performing the SR within the previous 12 hours, as required by ITS SR 3.0.4). The Bases for this Note states that this is allowance is needed since the unit must be in the Applicable MODES in order to perform the Surveillance. Calvert Cliffs can perform this Surveillar.ce, to verify each regulating CEA group position is within its insertion limit, prior to entering MODE 2. The only CEA insertion limit applicable in MODE 2 is the transient insertion limits, and these can be verified prior to entering MODE 2 (i.e., while the unit is in MODE 3). Therefore, this Note allowance is not necessary and has not been included in the ITS. His is also consistent with the current Calvert Cliffs licensing basis (this allowance is not in the Current Technical Specifications). 14. Improved Standard Technical Specification 3.1.5.1 ACTION A requires power reduction to 70% RTP within I hour and CEA alignment restoration within 2 hours when one or more CALVERT CLIFFS - UNITS I & 2 3.1-2 Revision 10

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECDON 3.1 - REACTIVITY CONTROL SYSTEMS CEAs are misaligned by >7.5 inches and s 15 inches or when one CEA is misaligned by > 15 inches. Under the same conditions, the Calvert Cliffs CTS (CTS 3.1.3.1 Actions e, f, and g) r quires restoration within I hour for CEAs misaligned > 7.5 inches and s 15 inches and within the time specified in the COLR (or by the full core monitoring system) for CEAs misaligned > 15 inches, and if not restored, allows an additional 2 hours to restore alignment provided power is reduced within I hour. Improved Technical Specification 3.1.4 has been modified to reflect the current Calvert Cliffs allowance. Improved Technical Specification 3.1.4 ACTIONS A and B have been added to provide this additional time prior to requiring a power reduction. Improved Technical Specification 3.1.4 ACTION C is the default Condition if the CEA is not restored to within its alignment limits. Improved Technical Specification 3.1.4 ACTION C is essentially ISTS 3.1.5.1 ACTION A, modified by approved /pending TSTF changes. Due to the addition of these new ACTIONS, the subsequent ACTIONS have been renumbered, where appropriate. 15. He first frequency of NUREG-1432 SR 3.1.4.2 requires verification that MTC is within the lower limit specified in the COLR "Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core bumup." The first frequency ofITS SR 3.1.3.2 requires verification that MTC is within the lower limit specified in the COLR "Each fuel cycle within 7 EFPD of initially reaching an equilibrium condition with THERMAL POWER 2 90% RTP." His change to the first frequency is consistent with the Calvert Cliffs current licensing basis reflected in CTS 4.1.1.4.2.b and has been shown to be adequate, based operating experience, for ensuring MTC is maintained within limits. 16. NUREG 3.1.1 is revised to incorporate the requirements of Current Technical Specification 3/4.1.1.2. These changes include an addition to the LCO, and associated Actions and Surveillances. In MJDE 5, the most limiting event with regard to reactivity: control is a Boron Dilution Event with the pressurizer level <90 inches. The initial conditions for the event include a reactor coolant system level above the bottom of the hot leg nozzles, and the sources of non-borated wato restricted to s 88 gpm. The CTS requirements provide assurance that the available Shutdown Margin will exceed the most limiting MODE 5 Shutdown Margin requirement at any time in the cycle. These changes are consistent with current licensing basis. CALVERT CLIFFS - UNiiS 1 & 2 3.1-3 Revision 10

.- -. ~ -. I57f-134 SOME TI>pog q) BASES APPLICABLE An idle RCP annot, therefore produceapdurnto) g-SAFETY ANALYSES r from the h standby condit f (continued) SOM satisfies Criterion 2 of the NRC Policy Statement. b LC0 The MSLB M4 and the boron dilution (Ref. 3)) accidents + are the acFst lin' ting analyses that establish the SOM value of the LCO. For MSLB accidents, if the LC0 is violated, ere is a potential to exceed the ONSR limit and to exceed l @kj,"9y ;,, " 'thnt w nm. neav-ia Cra-ra ~ =n r =ar. u. For 1 /N er the boron dilution accident. If the LC0 is violated, then LU (h orggg,p, yj the minimum required time assumed for o retor action to terminate dilution may no longer be app icable.*j jo,,gg ,i 'yggg7[ SOM is a core physics design condition that can be en red { l through CEA positioning (regulating and shutdown CEA and l L MO 2 through the soluble boron concentrati APPLICA81LITY In MODES 3 the SOM requirements are applicab1e to 75II'hI provide suffletent n ative reactivity to meet the-I- assumptions of the se ety anal ses discussed above. In MODES 1 and 2. SOM is ensured complying with LCO 3.1 l 73 Tf-/34r 1 Shutdown Contro1 El-at As* IV (CEA)-Insertion Limi / i and LCO 3.lgulf the i ertion limits of 3.1.6 or I$7f 67 ixo 3..a are not bein complied with, $ s not ^ aut

1cally violat The SOM must calculated by j

raing a react ity balance calcu ion (consider i tad ructivi afferte in anese tier nt 3.1.1, 75TF-l34 yp)3ffT iwDE 5, SOM is addressadyy im 1.1.2. "SHl")oEN MARG..N r ACTIOAlgd ISDN)-T_ s 200'F.*(In MODE 6, the shutcowir reactivity 3 requirements are given in LC0 3.9.1, ' Boron Concentration.' t ACil0NS k her hAsous oker NodAteuad 5 Qf,b A er B) If the SOM requirements are not met boration must be .imme4M*h 4 rep initiated promptly. A Completion Time ofli nites is WO Y

F 4 av,ve Tor an operator correctly all nd start th6' M

rs systus and nents.J It is assumed that as,..qbu d '4 boration will be continued until the SDM requirements are s,fy omLpm i (continued) CEOG STS B 3.1-4 Rev 1, 04/07/95 c

I BASES INSERT LC0 Because both initial reactor coolant system level and the dilution flow rate also significantly impact the boron dilution event in h MODE 5 with pressurizer level < 90 inches from the bottom of the pressurizer. the LC0 also includes limits for these parameters during these conditions. e 0

= BASES INSERT ACTIONS A.1. A.2. and A.3 With non-boratcd water sources of > 88 gpm available, while the unit is in MODE 5 with the pressurizer level < 90 inches, the consequences of a boron dilution event may exceed the analysis results, _ Therefore, action must be initiated immediately to reduce the potential for such an event. To accomplish this. Required Action A.1 requires imediate suspension of positive reactivity additions. However, since Required Action A.1 only reduces the potential for the event and does not eliminate it, imediate action must also be initiated to increase the SHUTDOWN MARGIN to compensate.for the non-borated water sources (Required Action A.2). Finally, Required Action A.3 requires periodic verification, once per 12 hours, that the SHUTDOWN MARGIN increase is maintained sufficient to compensate for the additionai sources of non-borated water. Required Action A.1 is modified by a Note which indicates that the suspension of positive reactivity additions is not required if SHUTDOWN MARGIN has been sufficiently increased to compensate for the additional sources of non-borated I water. The immediate Completion Time reflects the urgency of the -corrective actions. The periodic Completion Time of 12 hours is considered reasonable, based on other administrative controls available and operating experience. B.1 and B.2 With the reactor coolant system level at or below the bottom of the hot leg nozzles, while the unit is in MODE 5 with the pressurizer level < 90 inches, the consequences of a boron dilution event may exceed the analysis results. Therefore, action must be initiated immediately to reduce the potential for such an event. To accomplish this,- Required Action 8.1 requires immediate suspen51on of positive reactivity additions. However, since Required Action B.1 only reduces the potential for the event and does not eliminate it, immediate action ~must also be initiated to increase the reactor coolant system level to above the bottom of the hot leg nozzles (Required Action B.2). The immediate Completion Time reflects the urgency of, the corrective actions. r..-~..,,

Y'$hil'y Nmv vvv 50 G T Z > 196 & g* ' ' . bwee, as o. emne mom, %.%%. baaf.m 0 % 4 M I 6 - 40 sem ud A bocan comcana n shdl A A taco ppm h MSES he-w n es schM er-c oo, s a f es. - w w%% c k (contin'ied) h,h w ACT10M3 in the determination of the reeutrod cambiration of boration flow rate end boren concentration, there is ne unique requirement that must be satisfied. Stace it is taperative to raise the boren concentration of the RCS is soon as possible, the boren concentration should be a 61 1 concentrated solutinn, such as that normall a the N4);/ plcr beric acid stacame + tab er +ka i:nt;f n'_;y fe6

.L., Li.

The o rater should berate with the best source av,ellable -M for t plant conditions. 1 [Indeters g;4 sbthe beration flow te, the time life must be red. For inst e, the most dif uit time h in to Iffe to increase th C$ boron conce tion is at the inning of cycle, who tha ha-an n aar ratten mar J k - _

==>h ar amesed 2000 ene / Assuming that a value of ik Ak/k must De recoveres and a beration flow rate of g it is possible to increase the)oren concentration o he 5 by 300 nas in approximately M siantat Ir a u boren hof( 0 p elsesTis assumed thirceabination of- % & QET "ars v11L 1 rease the SOM by 5Ak/k. These beration + C araneo,ers or sps and ppe represent typical values and are i ppm /%g example.provi or the pu se of affering a specific i ft !9RVEILLANCE 1R 3.1.1.1 MOUIREMENTS SDN is verified by performing a reactivity balance i calculation, considering the listed reactivity effects: l a. RCS boron concentration; \\ b. CEA positions; c. RCS average temperature; d. Fuel burnup based on gross thermal energy generation; e. Xenon concentration; f. Samat te': concentration; and - g. Isothermaltemperaturecoefficient(lTC). L (continued) i CE M STS 8 3.1-5 g,y 3, o4foyjg5 i 9 ,n~ +-n

m..,

- ~.., -, +, _ _ -..n.- r, s nw ~. ~-

s D. 6.$4 -n 5 6 Y

N [ j', 6 O

BASES $VNEILLMCE 1R 3.1.1.1 (continued) REQLilREMENTS Using the ITC accounts for Doppler reactivity in this calculation because the reactor is subcritical and the fuel temperature will be changing at the same rate as the RCS. The Frequency of 24 hours is based on the generally slow I change in required boron concentration and also allows rygggg7) sufficienttimefortheoperatortocollecttherequired dets, which includes performing a boron concentration SRs analysts, and complete the calculation. w 10 upshtt AWah L 1.(::;.~~;.',.T,..;;.A,Q_00. REFERENCES r 2.@$AR,fectionj gg

3. @SAR, Sec CN CFQIK9

~~ ~~' Q ctg $ts B 3.1-6 Rev 1, 04/07/95

BASES INSERT SRs SR 3.1.1.2 and SR 3.1.1.3 These Surve111ances periodically verify the significant assumptions of a boron dilution event are maintained. A non borated wetw source of s 88 gpm allows for only one charging pump to be capable of injection during these conditions since each charging pump is capable of an injection rate of 46 gpm, Each Surveillance is modified by a Note which indicates that it is only required when the unit is in H00E 5 with the pressurizer level < 90 inches.. Since the applicable conditions for the g Surveillance may be attained while already in H00E 5, each Surveillance is provided with a Frequency of once within one hour after achieving ' MODE 5 with pressurizee level < 90 inches. This provides a short period of time to verify compliance after the conditions are attained. Additionally, each Surveillance must be completed once each 12 hours after the initial verification. The Frequency of 12 hours is considered reasonable. In view of other administrative cohtrols available, and operating experience. 4 5 h 9 4 i f I .-m e.-.. m -=_., _ _,m. ...,,,,.m.,, .,,o.,---wr.., ... _,. -. -,m_,--,,_ .._,_...m.,,,,-..r_---,,_.,.., .m.

P ge Rept:cern::t instructio:s VOLUME 8 Section 3A Note: Underlined titles indicate tabs in volumes. Regardmg CTS markups: Pages are referenced by citing the unit number as urlias the spec $ cation number locatedin Ihe upper stht handcorner ofIhe CISpage. Key: DOC = Discussion ofChanges DOD = Dhcussion Qf TechnicalSpec$ cation Deviation or Discussion QfBases Deviation REMOVE INSERT Overview of Channes i None DB 3.4.15 2 3.4.15 2 ITS Bates B 3.4.151 through B 3.4.15 5 B 3.4.1$ 1 through B 3.4.15 5 CTS Markun & Discussion of Channes s Spec $ cation 3.4.13, Unit I 'Page1of4 PageIof4 Spec $ cation 3.4.13, Unit 2 Page1of4 Page1of4 DOC 3.4.15 2 DOC 3.4.15 2 NSHC Findians 3.4 32 3.4 32 and 3.4 33 ISTS Markup & Justification 3.4 41 3.4 41 ISTS lisses Markup & Justification B 3.4-88 through B 3.4-91 B 3.4 88 through B 3.4 91 DOD 3.4 2 DOD 3.4 2 i

RCS Specific Activity 3.4.15 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3 with 6 hours associated Completion T,y < 500'F. .l Time of Condition A j not met. ) 98 DOSE EQUIVALENT I-131 in the unacceptable region of Figure 3.4.15-1. C. Gross activity of the C.1 Be in MODE 3 with 6 hours 10 reactor coolant not T.,, < 500'F. within limit. SURVEILLANCE REQUIREMENTS ' SURVEILLANCE fkEQUENCY SR 3.4.15.1 Verify reactor coolant gross activity 7 days 10 s 100/l pCi/gm. CALVERT CLIFFS - UNIT 3 1 & 2 3.4.15-2 Revision # Io ~

RCS Specific Activity B 3.4.15 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.15 RCS Specific Activity BASES BACKGROUND The Code of Federal Regulations, 10 CFR Part 100 specifies I the maximum dose to the whole body and the thyroid an individual at the site boundary can receive for 2 hours during an accident. The limits on specific activity ensure that the doses are held to within the acceptance criteria given in the UFSAR (Ref.1) during analyzed transients and I accidents. The RCS specific activity LC0 limits the allowable concentration level of radionuclides in the reactor coolant. The LC0 limits are established to minimize the offsite radioactivity dose consequences in the event of a steam generatortuberupture(SGTR) accident. The LCO contains specific activity limits for both DOSE EQUIVALENT I-131 and gross activity. The allowable levels 5-10 are intended to limit the dose at the site bounoary to within the acceptance criteria given in the UFSAR (Ref.1). l APPLICABLE The LC0 limits on the specific activity of the reactor SAFETY ANALYSIS coolant ensure that the tesulting doses at the site boundary will not exceed the acceptance criteria given in the UFSAR l (Ref. 1). The SGTR safety analysis (Ref. 2) assumes the specific activity of the reactor coolant at the LCO limits and an existing reactor coolant steam generator (SG) tube leakage rate of 1 gpm. The rise in pressure in the ruptured SG causes radioactively contaminated steam to discharge to the atmosphere through the atmospheric dump valves and the main steam safety i valves. 1 CALVERT CLIFFS - UNITS 1 & 2 8 3.4.15-1 Revision glo l l

RCS Specific Activity B 3.4.15 BASES The safety analysis shows the radiological consequences of an SGTR accident are within the Reference 1 acceptance criteria. Operation with iodine specific activity levels greater than the LCO limit is permissible, if the activity levels do not exceed the limits shown in Figure 3.4.15-1 for more than 100 hours. The remainder of the above limit permissible iodine levels shown in Figure 3.4.15-1 are acceptable because of tne low probability of an SGTR accident occurring during the established 100 hour time limit. The occurrence of an SGTR accident at these permissible levels could increase the site boundary dose levels beyond the acceptance criteria given in theUFSAR(Ref.1). Reactor Coolant System specific activity satisfies 10 CFR 50.36(c)(2)(ii) Criterion 2. LC0 The specific activity is limited to 1.0 pCi/gm DOSE EQUIVALENT I-131, and the gross activity in the primary ' ilO - coolantislimitedtothenumberofpCi/gmequalto100 divided by 2 (average disintegration energy of the sum of the average beta and gamma energies of the coolant nuclides). The limit on DOSE EQUIVALENT I-131 ensures the thyroid dose to an individual at the site boundary during the Design Basis Accident (DBA) will be within the acceptance criteria given in the UFSAR (Ref.1). The limit on gross activity ensures the whole body dose to an jo individual at the site boundary during the DBA will be within the acceptance criteria given in the UFSAR (Ref.1). The SGTR accident ,ysis(Ref.2)showsthatthesite boundary dose levels are within acceptable limits. Violation of the LCO may result in reactor coolant radioactivity levels that could, in the event of an SGTR, CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-2 Revision //o

RCS Specific Activity B 3.4.15 BASES lead to site boundary doses that exceed the Reference 1 acceptance criteria. APPLICABILITY In MODES 1 and 2, and in MODE 3 with RCS average temperature 2 500'F, operation within the LCO limits for DOSE EQUIVALENT I-131 and gr'>ss activity is necessary to contain the lo potential consequences of an SGTR to within the acceptable site boundary dose values. For operation in MODE 3 with RCS average temperature < 500*F, and in MODES 4 and 5, the release of radioactivity in the event of an SGTR is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the atmospheric dump valves and main steam l safety valves. ACTIONS A.1 and'A.2 ~ 'With'the DOSE EQUIVALENT I-131' greater than the LCO limit, semples at_ intervals of 4_ hours must be taken to demonstrate the limits of Figure 3.4.15-1 are not exceeded. The Completion Time of 4 hours is required to obtain and analyze a sample. Sampling must continue for trending. The DOSE EQUIVALENT I-131 must be restored to within limits within 100 hours. The Completion Time of 100 hours is required if the limit violation resulted from normal iodine spiking. A Note to the Required Action of Condition A excludes the MODE change restriction of LC0 3.0.4 This exception allows entry into the applicable MODE (S) while relying on the ACTIONS even though the ACTIONS may eventually require plant shutdown. - This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is CALVERT CLIFFS - UNITS-1 & 2 B 3.4.15-3 Revision Afo

_ _ =- - -..- ~ - -_. - --- RCS Specific Activity B 3.4.1C BASES limiting due to exceeding this limit, and the ability to restore transient DOSE EQUIVALENT I-131 specific activity lo excursions while the plant reinains at, or proceeds to power operation. L.1 If a Required Action and associated Completion Time of Condition A is not met or if the DOSE EQUIVALENT I-131 is in the unacceptable region of Figure 3.4.15-1, the reactor must be brought to MODE 3 with RCS average temperature < 500'F within 6 hours. The allowed Completion Time of 6 hours is required to reach MODE 3 below 500Y without challenging plant systems. .C d With the gross activity in ncess of the allowed limit, the 10 unit must be placed in a MODE in which the requirement does not apply. The change within 6 hours to MODE 3 and RCS average temperature < 500'F lowers the saturation pressure of the reactor coolant below the setpoints of the main steam safety valves and prevents venting the SG to the environment in an SGTR event. The allowed Completion Time of 6 hours is required to reach MODE 3 below 500*F from full power conditions and without challenging plant systems. SURVEILLANCE SR 3.4.15.1 REQUIREMENTS The Surveillance requires performing a gamma isotopic analysis as a measure of the gross activity of the reactor lo coola:..it least once per 7 days. While basically a quantitative measure of radknuclides with half lives longer than 15 minutes, excluding iodines, this measarement is the CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-4 Revision //o

RCS Specific Activity B 3.4.1L BASES sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in gross activity. 10 Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The Surveillance is applicable in MODES 1 and 2, and in MODE 3 with RCS average temperature at least 500'F. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time. SR 3.4.15.2 This Surveillance is performed to ensure iodine remains wit;iin limit during normal operation and following fast power changes when fuel failure is more apt to occur. The 14 day Frequency is adequate to trend changes in the iodine activity level considering gross activity is monitored every 7 days. The Frequency, between 2 hours and 6 hours after a power change of 2 15% RTP within a 1 hour period, is established because the iodine levels peak during this time following fuel failure; samples at other times would provide inaccurate results. The SR is modified by a Note which requires the Surveillance to only be performed in MODE 1. This is required because the level of fission products generated in other MODES is much less. Also, fuel failures associated with fast power changcs is more apt to occur in MODE 1 than in MODES 2 and 3. SR 3.4.15.3 A radiochemical analysis for f determination is required every184 days (6 months)withtheplantoperatinginMODE1 equilibrium conditions. The E determination directly CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-5 Revision A'/0

SpeoGe4 4 3,4, Ig-34 @ MACTOR C00lANT SYSTDI g 6 h SPECIFIC ACTIVITY ggg LIMITING CON 91 TION FOR OPERATION LC.o 3 4/5 @ The specifte activity of the primary coolant shall be limited tot

a. I 1.0 pCi/ gram D0$E EQUIVALENT I 131, and

b. i 100/l pct / gram, g EDLICABILITY: JgDES

, (s.YanrU 5'0* ACTION: W l' E Y 3] 3._4.15-Q k With the specific activity of the primary coolant > 1.0 pct / tram Ag,yj,g D05t EQUIVALENT I 131 but within the alloi limit (below and to the left of the line shown on Figure ( operation may SE aNEEtEW an es n ..Ic N anaratbi( Mhe provisidns of specification 3.0.4 are) ~ ve g% Enot aco11 cable. f 4 Acr/e# A With the specifte activity of the primary coolant > 1.0 pct / gram DOSE EQUIVALENT I-131 for more than 100 nours during one 8 contin ime interval or exceeding the limit line shown on Figu be in at st NOT STANDIY with T,., < 500*F 9./ within 6 hours gj A With the specific activity of the primary coolant g* > 100/l pC1/ gram, be in at least NOT STAN0tY with T.,, < 500*F C within 6 hours.

1, ZvJf, 4 anA4J

%dh [ jJ/ / K With the specific activity of the primary coo ant > 1.0 pC17gra / c r7d DOSE EQUIVALENT I-131 or > 100/T ut1/ gram.JfiTors the sampon i /) innu ensiysis requirements of item 4 aJ oT inble a _a.a im+t1 ne f enari n e activity of the crimary coolant isfresto@ to within its limits. W I*n Y O ITiusb fp Ay/t l./d CALVERT CttFT3 - 1JNIT 1 1/4-4 24 -%endment No. 316 f*7 h

5pu.4cd.n 3.4. / 5' 3.4 @ REACTOR C00 TANT.$Y$ FEM h 3,4,jg M h PECIFIC ACTIVITY LIMITI M CodOITION FOR OPERATION L,co,:L4,tr @ The specific activity of the primary coolant shall be limited tot

a. 51.0 pC1/ gram DOSE EQUIVALENT I 131, and

b. 5 100/l pC1/ gram.

APPLICABillTY,3 N00ES 2 (yndA1 'M 77[45 ACTION: QupoJfi, 2 and49 % With the specific activity of the primary coo nt > pC1/ gram t D0$E EQUIVALENT I-131 bpt within the allowab limit (below and AC'f/*# to the left of the line shmm on Figure operation may aI W Acb A.2. t Note e Z n.arat N ti Mnhe provisions of $pecification 3.. are s na i AW/*** A --- g applicable. f Neff 'k. With the specific activity of the primary coolant > 1.0 pct / pram s D0$E EQUIVAL.ENT I-131 for more than 100 hours during one continuous time interval or exceeding the limit Ifne shown on AC7#'# Figure ' be in at least NOT STAhDIY with T.,, < 500*F 8 within 6 ours. g,I 3,,,y,, 's. With the specific activity of the primary coolant > 100/I AC17 8^' pC1/gr*a, be in at least NOT STANDBY with T, < 500'F. ithin w C, 6 hcers.

h. 2. _3[and 53)

% With the specific activity of the primary coolant _> '.0 utt/ gram 00$EEQUIVALENTI-131or>100/EpC1/ pram.f pmu aptlysis requireme, tsf item 4 af UT gT eaa.auntighm] ora tie sa g,, g n /4 Anarffic _ activity of tWorimary coolant /16esto@ to Yithin Y its limits, p p.,& Dl O $

O l'o.

'%. 4.15' I a:N.h j th T,,, > % _. g,g o p App MiAI. CALVERT CLIFFS - UNIT 2 3/4 4-24 Amendment No. 193 r> If 4

DISCUSSION OF CliANGES SECTION 3.4.15 - RCS SPECIFIC ACTIVITY unlikely that a gross failure could occur during this time without prior indication. This change is consistent with NUREG 1432. L.3 Current Technical Speci0 cation 3.4.8 SR Table 4.4-4 Item 4.b requires the Dose Equivalent 1131 specine activity be verified in Modes I,2, and 3. Improved Technical Specification 3.4.15 SR 3.4.15.2 adds a Note which only requires the SR to be performed in Mode 1. This change will delete the Modes 2 and 3 requirements for this Surveillance. His is acceptable because the level of fission products generated in Modes 2 and 3 are much less, and fuel failures associated with fast power changes are more apt to occur in Mode 1. This change 8.s consistent with NUREG 1432. L.4 Current Technical Specification 3.4.8 SR Table 4.4-4 Item 3 requires E Bar to be determined from a sample taken in Mode 1 after a minimum of 2 Effective Fuel Power Days and 20 days of Mode 1 operation have clapsed since the reactor was last suberitical for 2 48 hours. Improved Technical Specification J.4.15 SR 3.4.15.3 allows the Surveillance to be delayed for 31 days efler a minimum of 2 Effective Full Power Days and 20 days of Mode 1 operation have clapsed since the reactor was last suberitical r. 2 48 hours. The 31 days ensure the radioactive materials are at equilibrium so the analysis for E-Bar is representative and not skewed by a crud burst or other similar abnormal event. His change is consistent with NUREG 1432. L.5 Current Technical Specification 3.4.8 Action a contains a clause stating that plant operat!on may continue for up to 100 hours when specific activity of the primary coolant is > l.0 pCi/ gram DOSE EQUIVALENT l 131 but within the allowable li. nit shown on Figure 3.4.8-1, provided that operation under these circumstances shall not exceed 10 percent of the units total yearly operating time. Improved Technical Specification 3.4.15 will not contain this clause regarding 10 percent of the units total yearly operating time. Generic Letter 85-19, Reporting Requirements on Primary Coolant lodine Spikes, states that requirements to shutdown a plant if coolant iodine activity limits are exceeded for 800 hours tuality of nuclear fuel in the decade preceding in a 12-month period can be eliminatoA B t the generic letter had greatly improved with the result that normal coolant iodine activity (i.e., in the absence of iodine spiking) is well below the limit. Appropriate actions would be initiated long before accumulating 800 hours above the iodine activity limit. In addition,10 CFR 50.72(bXIXii) requires the NRC to be immediately notified of fuel cladding failures that exceed expected valves or that are caused by unexpected factors, nerefore, this limit is no longer necessary based on propei fuel management and existing reporting requirements precluding ever approaching the limit. His change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.4.15-2 Revision 10

N3 SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOL. ANT SYSTEM analyzed events, and therefore do not involve a significant increase in the probability or consequences of an acciden. previously evaluated. 2. Does the change create the possibility of a new or different kind of aceldent from any previously evaluated? He proposed change allows 31 days to clapse, after a minimum of 2 Effective Full Power Days and 20 days of Mode 1 operation have elapsed since the reactor was suberitical for 2 48 hours, prios to determining the gross activity. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the poposed change. The proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 3. Does this change involve a significant reduction in margin of safety? He proposed change allows 31 days to elapse, after a minimum of 2 Effective Full Power Days and 20 days of Mode 1 operation have elapsed since the reactor was suberitical for a 48 hours, prior to determining the gross activity. The results of the E-Bar determination will be more representative of the RCS due to the 31-day allowance, ne 31 days ensure the radioactive materials are at equilibrium so the analysis for E Bar is representative of the actual gross activity. Also, the value of E-Bar changes slowly. Herefore, the change does not involve a significant reduction h a margin of safety. 3 4.15 Change L5 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change removes a clause to an Action which limits the time that the plant can be operated within specified lodine-131 criteria. He clause removed, requires that operation under the specified lodine 131 criteria does not exceed 10 percent of the units total yearly operating time. Removing this requirement is acceptable based on the improved quality of nuclear fuel since the time that the clause was created, making normal iodine activity well below limits, and appropriate action would be initiated long before accumulating the time above the limit. The requirement to notify the NRC is contained in other requirements. The RCS gross activity is not an initiator of any analyzed event. De change will not after assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? He proposed change removes a clause to an Action which limits the time that :he plant can be operated within specified lodine 131 crit:ria. The clause removed requires that operation under the specified lodine-131 criteria does not exceed 10 percent of the units total yearly operating time. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new acc dent initiators. Herefore, the change does not create the possibihty of a new or different kind of accident from any previously evaluated. CALVERT CLIFFS - UNITS I & 2 3-4-32 Revision 10

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3A - REACTOR COOLANT SYSTEM 3. Does this change involve a significant reduction la margin of safety? He proposed change removes a clause to an Action which limits the time that the plant can be operated within specified lodine 131 criteria. The clause removed requires that operation under the specified lodine-131 criteria does not exceed 10 percent of the units total yearly operating time. Removing this requirement is acceptable based on the improved quality of nuclear fuel since the time that the clause was created, making normal iodine activity well below limits, and appropriate action would be initiated long before the accumulating the time cbove the limit, ne requirement to notify the NRC is contained in other requirements. Therefore, the change does not involve a significant reduction in a margin of safety. ENVIRONMENTAL ASSESSMENT His proposed Technical Specification changes have been evaluated against the criteria for and identification oflicensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed changes meet the criteria for categorical exclusion as provided for under 10 CFR S t.22(c)(9). The following is a discussion of how the proposed Technical Specifict(.on changes mec"hc criteria for categorical exclusion. 10 CFR S t.22(c)(9): Although the proposed change irvolves chh..ges to requirements with respect to inspection or SRs, (i) proposed change involves No Significant llazards Consideration (refer to the No Significant llazards Consideration section of this Technical Specification Change Request); (ii) there is no significant change in the types or significant inemase in the amounts of any ef11uents that may be released ofTsite since the proposed changes do not affect the generation c,f any radioactive effluents nor do they affect any of the permhted release paths; and (iii) there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR S t.22(c)(9). Based on the aforementioned and pursuant to 10 CFR 51.22 (b), no environmental assessment or environmental impact statement need be prepared in connection with issuance of an amendment to the Technical Specifications incorporating the proposed changes of this request. l CALVERT Cl.IFFS - UNITS 1 & 2 3433 Revision 10 \\

RCS Spectfic Ac t 670 ACTIONS (contingdd) CONDITION REQUIRED ACTION COMPLETION TIME B. Required Actten and B.! Be in MOE 3 with 4 hours <IAndb 346 associated Completion T,< S00'F. Tlas of Condition A not set. 2R DOSE EQUIVALENT I-131 in the unacce able region of Figure 3.4.1 O C. Grossfistc Mc) [C.1 / Perfoj r d 3.4.16.t g 4 hp] n-r F - 7.g h activity of the / B A.6 reactor coolant not M i A A m C. within 11olt. I T, < 50'J'F. 1 SURVE!LLANCE RIQUIRENENTS SURVEILLANCE FREQUENCY 3A0 g O SR 3.4.1).1 Verify reactor coolant gross upettic) I 1 days h %h 4.1-4 (0 activity s 100/E pCf/ge (continued) CEOG 515 3.4-41 Rev 1, 04/07/95 m-y._- v

l i i R05 Speelfic y B 3.4 TOR C00L#fi $YSTEM (RC$) B 3.4. RCS Specific Activity SASES BACKGROUND The Code of Federal Regulations,10 CFR 100 #ETNb specifies the maximum dose to the whole body and tSi thyroid g$ , gg;, g an individual at the site boundary can receive for I hours g af..,f.,t. c.,,],g, during an accident. 1he lletts on specific activity ensure g%n k o fW. 4at the doses are held tog

s 1

v aranion a two t tp. @ivv beiwauring analyzed transients'and accidents. .g ( The RC5 specific activity LC0 Itatts the allowable concentration level af radionucildes in the reactor coolant. The LC0 iteits are established to stataire tie offsite redloactivity dose consecuences in the event of a stens h generator tube rupture (SGYR) accident. The LCO contains specific activity Italts for both DOSE [0V! VALENT 1-131 and gross tspreit A cactivity. The allowable 6 i levels are intended to limit theGEEE bonahrv in a small. rrat tom ^ VD dose at the site { /j/o v U k ~vu cose 1 9deline 11 its. The tells in the LC0 standardized ba tric ev uations of offst radioactivit

W m e @ sed on pa ud

.) g uttLces for typical site loca onf croksa sa,w.o r,., he urm(cet.8) The remetric or uations showed t potential off ite dose leve' s for an SGT accident were a appropriately 11 fra ton of the O CFR 100 dose g deline limits. Each { untion ass s a broad range f site appitcab e erle dit, rsion factors 1 a marametric e lustion. 1 APPLICABLE The L(0 timits on the specific activit of the reactor SAFETY ANALYSES coolard ensure that the resulting _

u. doses at the site l

m--=- boundary wi' I not enand; i s trapuun or we IU_u._5.10D b k "' %o cf "* t qst_gyVeC De limits (Alowing an JGTR accidentC~The SGTR 94e-ed safety w1ysis the reactor coola(nt at the LC0 limits and an existingRcf. 2) assuees t I % ur.fu tpd.IN reactor coolant steam tri'..... ;..'. ys!! ! generator (SG) tube leakage rate of I gpe. The-entl . s e 2 :"-' : 5 "Mir trip s.4. L :.- t tr r ti. ;;; ..ma. 'The t d p h -S r th 00'" w 'Jo......./.. i. 4he m = M - ' !:i t ; '.. ^;;.n...^ 6 u ;...,. ": '- --- t o (continue 6 CEOG STS B 3.4 88 l Rev 1. 04/07/95 l i 1 (

. - _. -. _. - _ -.. -.. -.. ~.... -. - 1 1 RCS specific Activit i -8 3.4.1 84St$ 6 APPLICABLE ^^- U.;U4 * --*=" '-"3'5L~t A=iif "" SAFETY ANALYSTS (continued) wart =*= 18=1** Z,

y ' " ;

4-E ^ 1 h rise in pressure in the $$ causes redt6 actively Oio i contesinated steam to dischi, te the atmosphere th D. e,taespherjc depjalves,_,h majp staae,safptyya yes.

u are -. m. w * %...., _-.,.,-...n,.,7....e t

...... -... ~.,_ _ __ =-=== _ ,,, m, a . -.., venttelitsur1 pt H he eeeldsen onde,- h safety analysis shows the radielegical consequences of G) \\ u> t an $4TR accident are within m -n rrazion eDthe G:--Jy 2l: mererencews.. --u-m.. 0, oration ith 5. dine h specific activity le.els creater than the LC0 Itait is permissible, if the lvlty levels de phours.eaceed the 11eits g @ shown in Figure 3.4. for more than W remainder of the a va limit eersissible iodine levels @ m shown in Figure 3.4.19-1 are acceptasie pecause er the low W probability of_an $47R accident occurrine durina the i estabitsbod As near uns nun. sne occurrence of an SGTR accident at these permissiblo levels could increase the site b.3 a & 4 s - boundary do,se levem aut At n== wanin is cru A0 2:D Ot3 b 0 S(r.g.,#:. vi. u ne i. eeat.s % utSML ~ a,t,g) ' RC$ specific activity satisfies Criterien 2 of the NRC Policy Statement, a LC0 W specific 4ed4e+ activity is limited to 1.0 pC1/ 00$t MN primary coolant Is Itatted to the number of #C1/gm equal to h EQUlVALENT l-131 and the grossczaetiritlactivity i the j so j 100 divided by I (average disintegration energy of the sum of the average beta and gamma energies of the coolant eucildes). The limit en Oost EQUIVALENT l-131 ensures the G2iB thyroid dose to an individual at the site ary A ebr h the Design Basis Accident (0RA) will be Ql

pp rar naau - -onmaa u..m.

. Tne iteit on gross h W ec Mtlactivity ensures the whole body dose to n 4 1 U?hr;e, ' W *** ' * \\ N \\* W*'Y- "**.N # *U' ^ ,o % grgahreta s'n ,;) '""'"m""""'"- (continued) I CEOG STS a 3.4 39 Rev1,04/07/95 k f

._.. ~-_.. _ _ _ _____._..m__ I i RCS Specific Activit B 3.4.1 BA$ts LCO W SGTR accident analysis (kef. 2) shows that the 2 hour (continued) site boundary dose levels are within acceptab10 lietts. Violation of the LCO may result in reacter coolant r ui m tivii i m is m t c.id, in

evens of e, m R 7 a to site,boundar, doses mt mood amu wrChrgg APPLICA8!LITY In M0ts 1 and 2, and in M00t 3 with RCS aversee temperature k 500*F. eperation within the LC0 timits for 00st EQUIVAf.ENT l

1 131 and grosstammaric1 activity is necessary to contain I the potential consegeences of an SGTR to within the acceptable sitJ boundary dose values. + ) for operation in MODE 3 with RCS average temperature < 500*F, and in M00t$ 4 and 5 the release of rWiesctivity in the event of an $GTR is unlikely since the saturation 1 pressure of the reactor coolant is below the 11ft pressure settings of the atmospherte dump valves and main staam safety valves. g = = - - ( Neg<.in.l A< k n & Co dehse A ~- ACTIONS A Note to the Z T Dancludes the M00( change restriction of LC0 3.0.4. ' h's exception allows entry into the applicable M00E 5 tne ACTIONS may(ev)entually require plant shutdown.while relying on the ACTIO This M"y q exception is acceptable due to the significant conservatism TSTF-N ^ + 8# incorporated into the specific activity limit, the low r probability of an event which is limiting due to exceeding />6143l this Itait, and the ability to restore transion pecific activity excursions while the plant remains at. rproceedy dopoweroperation, gg g y A.1 and A.f r With the 00$E [0UlVAL[NT l-31 greater than the LC0 limit, samples at intervals of 4 urs must be taken to demonstrate the lietts of Figure 3.4. .I are not exceeded. The Completion Time of 4 hours is required to obtain and analyze a sample. Sampling must continue for trendl The DOSE EQUIVALENT l-131 aust be restored to within 1 mits withi urs. (continued) Ct0C STS B 3.4 90 Rev1,04/07/95 -~ .. -. - = -

\\ A 1 RCS Specific Activit I B 3.4. BA$t$ ACTIONS A.1 and A.f (continued The Completion Time of urs is required if the limit violation resulted from normal lodine spiking. TdJt'M f'* T'519.lq ()6 1.4'90 S If a Required Action and associated Camp etion Time of Condition A is not met or if the DOSE E IVALENT I-131 is in the unacceptable region of fi be brought to MODE 3 with RC$gure 3.4.-1. the reactor must average temperature < $00'T within 6 hours. The allowed Completion Time of 6 hocrs is required to reach MODE 3 below 500'T without challenging plant systems. c.1 W '."- ppg [][* With the gross (sMitidactivity in excess of the allowed h h lial - Tilysis must be ormec within 4 hours jo 7 g @, N P u d in A h w. SE EQUlvALENT 1. The Completion -sf l .p7f. zd,a. pt#pg g _he ._it ranuired to in and analvre a e og &Ae*= p.,,-t The change within 6 hours to MODE 3 and RCS average te nk.ppq I temperature < 500'T lowers the saturation pressure of the resctor coolant below the setpoints of the main steam safety valves and gavents ventin the SG to the environment in an SGTR event. The allowed C letion Time of $ hours is required to reach MODE 3 bel 500*f from full power conditions and without challenging plant systems. SURV[lLLANCE SR 3.4.1 1 REQUIR[ HINTS The Surveillance requires performing a came isotopic 1 (/\\ analysis as a measure of the gross reactor coolant at least once per 7(fKJlactivity of the I !D days. While basically a quantitative measure of radionuclides with half lives longer than 15 minutes, excluding lodines, this measuremert is the sum of the degassed gama activities and the caseous gama activities in the sample taken. This Surveillance provides an indication of any increase in gross [spfelpt' activity. lh (continued) CEOG STS B 3.4-g1 Rev 1. 04/07/g5 l l l

DISCUSSION OF BASES DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM assumed that the turbine has not tripped. Derefore, this statement was deleted from the Specification ?.4.? 6 Bases, Applicable Safety Analyses Section. 15. ne Calvert Cliffs Specification 3.4.15 Action, when the Dose Equivalent Iodine is out-of limit but within limits of the Figure 3.4.15 1, was changed from 48 hours to 100 hours. l i 16. Speci0 cation 3.4.11 Bases (Background Section) states the power-operated relief valve setpoint is above the high pressure reactor trip setpoint. This change will incorporate changes that specify the power-operated relief valve setpoint is equal to the high pressure reactor trip setpoint. His change is consistent with Calvert Cliffs current trip settings. 17. He word ana'og is deleted from places in the dases where it is used to modify Specifications. Calvert Cliffs is an analog plant and it is unnecessary to specify this for Specifications. 18. His portion of the Applicable Safety Analyses Section of Specification 3.4.12 Bases is being deleted because the pressurizer safety valves do not protect the P/T limits at all temperatures above minimum pressurization temperature. His change is consistent with Calvert Cliffs' design. 19. NUREG 1432,3.4.2 Bases, Applicable Safety Analyses Section was changed to accommodate that Calvert Cliffs !s not standard in its analysis of the minimum temperature for criticality. The analyses assume a minimum temperature consistent with normal hot zero power operation instead of the Technical Specifications limit. His discrepancy was justified by Combustion Engineering Owners Group Task 889, as documented in CENPSD-1026, " Evaluation of NRC Notice 94 75." 20. NUREG-1432,3.4.14 Bases, Dackground Section was changed to delete reference to measuring dew point temperatures and to delete that humidity level is useful as an indirect alarm. Calvert Cliffs does not measure dew point temperature, nor does it use humidity level as an alarm. This change is consistent with Calvert Clifts' design. 21. A requirement was added to NUREG-1432 Bases Section 3.4.3 (Calvert Cliffs ITS Bases "ection 3.4.3) Actions A.1 and A.2, which requires the engineering evaluation when Pfr liniits are c).: ceded to include a determination of the effects of the out-of-limit condition on the fracture toughness propertier of the RCS. This change is a result of moving a requirement out of the Current Technical Specifications into the ITS Bases. 22. These changes to NUREG-1432 incorporate Calvert Cliffs specific requirements, allowances, or exemptions currently located in the Calvert Clifts Current Technical Specification. These items were relocated out of the Current Technical Specification to the ITS Bases nese changes are casistent with the Calvert Cliffs current licensing basis. CALVERT CLIFFS-UNITS 1 & 2 3.4 2 Revision 10

Pcge Replacement Instructions VOLUME 9 Section 3.5 Note: Underlined titles indicate tabs in volumes. Regardsng C75 markups: Pqss eve refmnced by citing the unit number as well as the specification number located in the upper Hght hand corner ofthe CTSpage. Key: DOC ~ Qiscussion OfChanges DOD = Qiscussion Of Technical Specification Deviation or Discussion QfBases ()eviation REMOVE INSERT Overview of Channes None IUt None IM Bases B 3.5.4 3 through B 3.5.4 5 B 3.5.4 3 through B 3.5.4 5 CH Markus & Discussion of Channes None NSHC Findinats None ISTS Markun & Justification None ISTS Pases Markun & Justification B 3.5 25 - B 3.5-25 l l l l l l

RWT B 3.5.4 BASES flow from all ESF pumps prior to reaching a low level switchover to the containment sump for recirculation; and b. The containment sump water volume must be sufficient to I support continued ESF pump operation after the switchover to recirculation occurs. This sump volume water inven;ory is supplied by the RWT borated water inventory. When ESF pump suction is transferred to the sump, there must be sufficient water in the sump to ensure adequate net positive suction head for the HPSI and containment spray pumps. The RWT capacity must be sufficient to supply this amount of water without considering the inventory added from the safety injection tanks or Reactor Coolant System (RCS), but accounting for loss of inventory to containment subcompartments and reservoirs due to containment spray operation and to areas outside containment due to leakage from ECCS injection and recirculatinn equipment. The 2300 ppm limit for minimum boron concentration was established to ensure that, following a LOCA with a minimum level in the RWT, the reactor will remain subcritical in the cold condition following mixing of the RWT and RCS water volumes with all control rods inserted, except for the ID controlelementassembly(CEA)ofhighestworth,whichis withdrawn from the core. The most limiting case occurs at so beginning of core life. The maximum boron limit of 2700 ppm in the RWT is based on boron precipitation in the core following a LOCA. With the reactor vessel at saturated conditions, the-core dissipates heat by pool nucleate boiling. Because of this boiling phenomenon in the core, the boric acid concentration will increase in this region. If allowed to proceed in this manner, a point will be reached where boron precipitation will occur in the core. Post LOCA emergency procedures direct the operator to establish simultaneous hot and cold cal' VERT CLIFFS - UNITS 1 & 2 B 3.5.4-3 elevision F/o

RWT B 3.5.4 BASES leg injection to prevent this condition by establishing a forced flow path through the core regardless of break location. These procedures are based on the minimum time in which precipitation could occur, assuming that maximum boron concentrations exist in the borated water sources used for injection following a LOCA. Boron concentrations in the RWT in excess of the limit could result in precipitation earlier than assumed in the analysis, the upper limit of 100'F is only required for MODE 1 operation and the lower limit of 40'F on RWT temperature are the limits assumed in the accident analysis. The RWT satisfies 10 CFR 50.36(c)(2)(ii), Criterion 3. LCO The RWT ensures that an adequate supply of borated water is available to cool and depressurize the containment in the event of a Design Basis Accident (DBA) and to cool and cover the core in the event of a LOCA, that the reactor remains subcritical following a DBA, and that an adequate level exists in the containment sump to support ESF pump operation in the recirculation mode. To be considered OPERABLE, the RWT must meet the limits established in the SRs for water volume, boron i-concentration, and temperature. APPLICABILITY In MODES 1, 2, 3, and 4, the RWT OPERABILITY requirements are dictated by the ECCS and Containment Spray System OPEkABILITY requirements. Since both the ECCS and the Containment Spray System must be OPERABLE in MODES 1, 2, 3, and 4, the RWT must be OPERABLE to support their operation. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops - MODE 5 Loops Filled," and LC0 3.4.8, "RCS Loops - MODE 5. Loops Not Filled." MODE 6 r l l CALVERT CLIFFS - UNITS 1 & 2 B 3.5.4-4 Revision 0

RWT B 3.5.4 i BASES core cooling requirements are addressed by LCO 3.9.4, "ShutdownCooling(SDC)andCoolantCirculation-HighWater Level,"andLCO3.9.5,"ShutdownCooling(SDC)andCoolant Circulation - Low Water Level." ACTIONS A.1 With RWT boron concentration or borated water temperature not within limits, it must be returned to within limits within 8 hours. In this condition neither the ECCS nor the Containment Spray System can perform their design functions; therefore, prompt action must be taken to restore the tank to OPERABLE condition. The allowed Completion Time of 8 hours to restore the RWT to within 116 nits was developed considering the time required to change boron concentration or temperature and that the contents of the tank are still available for injection. Required Action A.1 only applies to the maximum borated water temperature in MODE 1. B.1 With RWT borated water volume not within limits, it must be returned to within limits within 1 hour. In this condition, neither the ECCS nor Containment Spray System can perform their design functions; therefore, prompt action must be taken to restore the tank to OPERABLE status or to place the unit in a MODE in which these systems are not required. The allowed Completion Time of 1 hour to restore the RWT to OPERABLE status is based on this condition simultaneously affecting multiple redundant trains. CALVERT CLIFFS - UNITS 1 & 2 8 3.5.4-5 Revision 0

l RdT B 3.5.4 SA$ES h APPLICABLE Twenty e Autes is the point at wht 155 of the dest flow SAFETY ANALYSES of one $1 pump is capable of ting or exceedt the, (continued) , decay at belloff rate. When ESF pump suction is transferred to the sump, there must be sufficient water in the sump to ensure adequate not positive suction head (NPSH) for the HPSI and containment spray pumps. The RWT capacity aunt be suffletent to supply this amount of water without considering the inventary added from the safety injection tants or Reactor Coolant Systes (RCS), but accounting for loss of inventory to containment subcompartments and reservoirs due to containment spray operation and to areas outside containment due to leakage from E ction anf recirculation equipment. h 3 The liett for minimum boron concentration was esta lish to ensure that, following a LOCA with a minimum level in the RWT, the reactor will remain suberitical in the cold condition following atxing of the RWT and RCS water volumeC75aan arsex unas assee thanall control rods @ inserted, except for the control element assembly CEA o highest worth, which is withdrawn from the_ core. e br acArassuusr inWaitaus zumiitn wMfidra rom The most limit' ng case occurs at beginning or core r e. g The maximum baron limit of ppe in the RWT is based on boron precipitation in the core ellowing a LOCA. With the reactor vessel at saturated conditions, the core dissipates heat by pool nucleate bolling. Because of this boiling phenomenon in the core, the boric acid concentration will increase in this region. If allowed to proceed in this manner, a point will be reached where boron practpttation will occur in the core. Post LOCA emergency procedures . direct the operator to estabitsh simultaneous hot and cold leg injection to prevent this condition by establishing a forced flow path through the core regardless of break location..hese procedures are based on the minimum time in which precipitation could occur, assuming that maximum boron concentrations exist in the bora hd water sources used for injection following a LOCA. Boron concentrations in the RWT in excess of the llait could result in precipitation earlier than assumed in the analysts. TWT to,.,lett of kl,00 qa,nd the lower,n the acc, he upper l limit of 0 f on h u,e a,a t e ts assu.ed (continued) CE0G STS B 3.5-25 Rev1,04/07/g5 g,,a n. m # e - - _ - - -. - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - ~ ^}}

ML20198R733

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