ML20199G945

Submits Rev 12 to Util 961204 Application for Amends to Licenses DPR-53 & DPR-69 to Convert to Improved Tss,As Result of Discussion W/Nrc.Revised Pages for Tables,Min Rev to Summary of Changes & Rev 12 to Improved TS Encl

ML20199G945
Person / Time
Site:	Calvert Cliffs
Issue date:	01/28/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199G949	List: ML20199G945 ML20199J528
References
TAC-M97363, TAC-M97364, NUDOCS 9802040374
Download: ML20199G945 (8)

Text

.. .

CHet1211. Ctt'st lidtimore Ces t.nd Electric Company Cahett Cliffs Nuclear Power Plant Vice President l Nuclear Energy if60 Cahett Cliffs Parkway 1.usty. Maryland 20657 410 495-4455 January 28,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk SUluECT: Calvert Clifts Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 Revision 12 to the License Amendment Request to Convert to the improved Technical Specifications (TAC Nos. M97363 and M97364)

REFERENCE:

(a) Letter from Mr. C.11. Cruse (BGE) to Mr. A. W. Dromerick (NRC),

dated December 4,1996, License Amendment Request to Convert to the improved Technical Specifications (TAC Nos. M97363 and M97364)

Reference (a) was the initial application to convert to the improved Standard Technical Specifications.

Revisions to Reference (a) have been submitted in response to Nuclear Regulatory Commission questions and comments. Additionally, discussions have been held between the Nuclear Regulatory Commission Staff and Baltimore Gas and Electric Company personnel to clarify the information contained in the application and revisions. As a result of these discussions, additional changes are being made to the initial application. This letter provides Revision 12 to Reference (a).

At:achment (1) contains revised pages for the tables submitted previously in response to various requests for additional information. A'tachment (2) provides a minor revision to the Summary of Changes provided for Revision 1. Atta iment (3) contains Revision 12 by improved Technical Specifications section, for case of replacing pal,es in the original amendment request. Page replacement instructions are provided. All changes are marked with revision bars and labeled Revision 12, I

lU4Vbbb h l I k 9002040374 900120 "

PDR ADOCK 05000317 P PDR;

e s.

i Document Control Desk Januany 28,1998 j Page 2 l Should you have questions regarding this matmi, we will be pleased to discuss them with you.

/ Very truly yours, k for -

C.11. Cruse Vice President Nuclear Energy STATE OF MARYLAND TO WIT

COUNTY OF CALVERT

1. R. E. Denton, being duly sworn, state that I am Senior Vice President Generation, llaltimore Oas and Eletric Company (llGE), and that I am duly authorized to execute and file this License Amendment Request on behalf of IlGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upor information providcQy other flGE employees and/or consultants. Such

- Information has been reviewed it: accordance with compa d I belige it to be reliabic.

l

- NW Subscribed and . worn before me, a Notary Public in a. for the State of Maryland and County of (d)JAAk.) .this & ay of 00AtIL 1998.

0 WITNESS my lland and Notarial Scal: A >

Notary Public My Commission Expires: bI O9 Date '

' CllC/ PSF /bjd Attachments: (1) Revision to Responses to Request for AdditionalInformation (2) Revision to Summary of Changes t (3) Revision by ITS Section cc: M. L. Reardon, NRC -

(With Attachment 2 only)

R. S, Fleishman, Esquire 11. J. Miller, NRC ,

J. E. Silberg, Esquire . Resident inspector, NRC Director, Project Directorate 1 1. NRC R.1. McLean, DNR

' A. W. Dromerick, NRC ' J.11. Walter, PSC

- i

w. -.

.-g.._.. i. ..w_...-,,wgnw.w;+

. - . .a--. w.

ATTACIIMENT (1)

IMPROVED TECIINICAL SPECIFICATIONS, REVISION 12 REVISION TO RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION I ,

1 l

Haltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant January 00,1998 l-

ATTACHIRENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.11 CTS 4.9.12.d2 DESCRIPTION OFISSUE CTS Sunnn!!ance 4.9.12.d2 requ:res nunitoum9 5/30/97

[ COMMENTS Delete ttus ch:Jge.

3.7.11-4 L3 JFD 1 ITS SR 3.7.11.3 the SFPEVS measurable negatve pressure Bases and Assocsated Bases relatve to the outsde obW.ere once per 18

^ --

JFD 1 rnonths ITS SR 3.7.11.3 requires nou.ou-g the SFPEVS rneasurable negatve pressure relatve to the outside .Linsprere once per 24 rnonths. The change from 18 rnonths to 24 months is justfied based on cpa^og history (L3)and using a generalized juGTcaton (JFD 1/ Bases JFD 1) that aa upwales CCNPP-specrfic uJuneLvn into the bracketed ~ u Junebuu. The latter jusLTa.oLen used is wrorg. The change in frequency is enaccepioue and is beyond the scope of revew for this converson CCNPP Response This change in surveillarce frequency from 18 to 24 rnonths is similar to other changes approvt:d as part of ITS subrn: als. This is one of four such changes discussed with the Calvert CICs Project Manager and tumed over to the appropnate technical branch DOC L3 for ITS 3.7.11 was revised to provde add. tonal jusLin obuu as part of Revtson 1 to the ITS Amendment Request dated June 9 1997.

3.7.11-5 JFD 1 STS SR STS SR 3.7.14.5 verk 's that each FBACS fdier 5r30/97 Erdier include STS SR Bases 3.7.14.5 bypass damper can be opened ITS B3.7.10 3.7.14.5 in the ITS or provde JFD 1 ITS B3 7.11 Bases - Bases-BACKGROUND states that dunng normal aditional discusson and BACKGROUND cpmobun the ci=woi adsort)ers are bypassed justficabon based on current and it is impred that during e riegency cpecsacn in.,ensirg basis, system the SFPEVS danvers are realigned to initiate desyt, or cpeituvi=l filtracon STS SR 3.7.14.5 is deleted from ITS w i d oints to justfy the 3.7.11 based on a generaljustficaton on items not deleton of STS SR 3.7.14.5.

consistent with the CCNPP design. The jt&Mt- n in this case are the wrong just.Tn,obvi6 since the desgn does include bypass dan ve is.

CCNPP Response The STS survei!!ance was wntien for desgns that have a bypass line to provde cooling to a loaded filter train that has been shut down post-accdent. The CCNPP design does not include this feature This change is based on the survehnce not being in CTS and the STS surveillance being in brackets. Therefore, etule D-e. inn of Deveton 1 does not provde specifo details, it is accurate This system is crmied manualty and the ITS venfies system Op=.Lun dunng fuel movement No ad&Lunal surveillances are necessary Doc = Discuss.on of Change 34 JFD = Just:5 cation for Densbon

r ATTACI6 (1)  ;

t RESPONSES TO REQUEST FOR ADDITIONAL WFORMATION N TECHNICAL SPECFICATIONS SECTION 3.7 ,

'3.7.12i DESCRIPTION OFISSUE

[ CORSENTS

' 3.7.12 JFD 1 CTS d 6.6.1.d2 CTS 4.6.6.1.d.2 requwes verff ing at least once 5/30I97 Delete this change.

Bases I- A 3.7.12.3 per 18 months that PREVS starts on a JFD 1 ITS Contamment Isoiabon Test signal ITS SR l B3.7.12 3.7.12.3 requres venfying that each PREVS l

. Bases trams actuates on an actual or swnulated .

SR 3.7.12.3 actuabon segnal once per 24 months. The change from 18 months to 24 months is justmed in the ITS Based on a generalized just6cahon  ;

(JFD1/ Bases JFD 1) that inwrporates CCNPP-specific ;iJui ni.Lun into the bracketed oformabon This' ju=Lis Lun is wrong in j L addsbon, the CTS markup does not show this  ;

change or provide a justscahon for it. The i change in frequency is unacceptable and is  :

beyond the scope of review for this conversion. '

CCfrP Response *

[ DOC L1 was provided to jushfy the change from a frequency of 18 to 24 months. Frequency extenssons from 18 to 24 months have been irduded as unihm the i scope of the ITS conversson, and this was a change rhmM with the NRC Project Manager for Calvert Cliffs.

3.7.12-3 ' JFD 1 STS SR ' STS SR 3.7.15.5 venfies that each PREACS filter 5/30/97 Esther melude STS CR i Bases 3.7.15.5 bypass damper can be opened ITS B3.7.12 3.7.15.5 in the ITS or  ;

l JFD 1 ITS B3.7.12 ' Bases-BACKGROUND states that "Dunng provide addebonal Bases- emergency operabons, the PREVS dampers are den =m and just4cahon  :

, BACKGROUND realigned. " STS SR 3.7.14.5 is deleted from ITS based on current heensmg 3.7.12 based on a general justdcabon on stems bass, system desegn or  ;

1 not consisterd with the CCNPP desagn. The operabonal constramts to I justmcahons in this case are the wrong jushfy the desecon of STS  ;

, ju=LTn uns, since the design does include SR 3.7.15.5.  !

bypass dampers CCNPP Response  !

The STS survedance was wreen for designs wluch have a bypass line to provide cooling to a loaded finer train that has been shutdown post-ment. The CCNPP j design does not include this feature. This change is based on the survemen= not being in CTS and the STS survemance bemg in brackets. Theresore, while DOD 1 does not provide specde details, it is accurate, this system is operated meaually and the ITS venlies sysium operabon dunng fuel movement. No addibonal  !

surveisancesareiv =f. ,

DOC = D-m of Change 37  ;

XD = JussAcehon for Devishon  !

~

. ., ,. . . s - . . -n. - o - -~ ...,- ,..--~,- . . . . , . . , . . ....n- , , , -

I

! 1 NrTACIIMENT (2) 4 l

4 4

IMPROVED TECilNICAL SPECIFICATIONS, REVISION 12 -

1 REVISION TO

SUMMARY

OF CIIANGES i

d I

llattimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant January 00,1998 i

- _ . . , - . . , . . . _ . _ . . _ . _ ~ . . . . . . _ . . . _ _

ATTACHMENT (1)

SUMMARY

OF CHANGES 22.1his change incorporates the justification for a Note added to SR 3.3.7.2. This justification was

, inadvertently omitted from the original submittal. In addition, the word " driver" is being added to the ITS Note. This term is included in the CTS and NUREG 1432 markups, but was omitted from the draft ITS.  ;

i

23. 'lhia change revises the SR 3.8.3.2 Ilases to refer to the 1992 version of ASTM D975 instead of the currently ut,d 1981 version.

24.1his change replaces Technical Specifications Task Force (TSTF)-83. The change will revise ITS 3.3.3 to remove the Condition A Note (regarding three Matrix Logic channels inoperable due to a common power source failure de energizing three matrix power supplies). The Condition would be satistled without the Note, thereby rendering the Note unnecessary.

25. The changes associated with TSTF.1 have been removed. TSTF 1 incorporated an allowance for inoperable equipment to be returned to service to verify variables to be within limits. TSTF 1 was withdrawn from NRC review by the industry.

16. 'the changes associated with TSTT 27 Revision 1 (and other related changes) have been added to the

submittal. TSTF 27, Revision I removes SR 3.4.2.1 and removes the Note for SR 3.4.2.2, eliminating the conditional surveillance of Reactor Coolant System (RCS) temperature and replaces it with a Oxed frequency surveillance.

27. This change revises the SR 3.4.12.1 Bases to add,". . or by verifying their discharge valves are locked shut" as an alternate means of verifying that the high pressure safety injection pumps are rendered incapable of injecting into the RCS This allowance is contained in the CTS and was inadvertently omitted from the Ilases.

28. This change replaces the reference to TSTF 65 with a plant specific justification. TSTF-65 has not yet been approved by the NRC.

29. This change incorporates TSTF 92, Revision 1. Revision i deleted the phrase, " . . . that is not locked, scaled or otherwise secured in position," from SR 3.9.3.2. That phrase was added in Revision 0.

30. TSTF 62, whkh as approved by the NRC on September 18, 1996, revised the Note to SR 3.4.1.3 from "Only requi-d in Mode I with all RCPs running," to "Only required in Mode 1." llowever, the Applicability of Specification 3.4.1 is Mode 1. Therefore, the Note is unnecessary and confusing. This change climinates the remaining portion of the Note. A generic change will be written to correct NUREG 1432. Also, a Discussion of Change and No Significant llazards Consideration for Specification 3.4.1, L2 is deleted. The associated changes were not included in the submittal, but this information was not deleted.

31. This change to the 3.7.10 and 3.7.11 liases modifies the discussions of what constitutes the equipment necessary to meet Operability requirements. This change is made to be consistent with

' the Calvert Cliffs design.

3

.. - . . _ . _ . . - . _ - _ _ _ _ - . - . . _ . - -..-.._--.. _ _ _ - - -. . . . -. .- e-. - .-. -

t ATTACllMENT (2)

AMENDMENT REVISION HY CHANGE

31. This change to the 3.7.10 and 3.7.11 Bases modifies the discussions of what constitutes the equipment necessary to meet Operability requirements. This change is made to be consistent with the Calvert Cliffs design.

i a

m w - y wm w-, w--w-m-