Text

Proposed Tech Specs,Converting to Improved TSs
	ML20199J528
Person / Time
Site:	Calvert Cliffs
Issue date:	01/28/1998
From:	; BALTIMORE GAS & ELECTRIC CO.
To:	;
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ML20199G949	List: ML20199G945; ML20199J528;
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	NUDOCS 9802050336
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ATTACllMENT Gi)

IMPROVED TECilNICAL SPECIFICATIONS, REVISION 12 REVISION llY ITS SECTION

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! !Do!Ko!oo$$17 PDR llaitimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant January 00,1998

Page Reg.lscement lytructions VOLUME 8 Section 3A Note: Underlired titles indicate tabs in volumes. Regarding CIS markups: Pages are referenced by citing the unit number as uvlias the specyication number locatedin the upper right hand cortwr ofthe CISpage.

Key:

DOC = Qiscu.usion ofChanges DOD = Olscussion W TechnicalSpecylcation Deviation or Dhcussion WBases [.}eviation i REMOVE INSERT

- OSerview of Channes ,

f No pages changed.

LT.$

4 3.4.12 1 3.4.12 1 ITS Bases B 3.4.5 2 through B 3.4.3 6 9 3.4.3 2 through B 3.4.3 3 CTS Markun & Discussion of Channes No Pages Changed.

NSHC Findinas ;

No Pages Changed.

t ISTS Markun & Justification '

No Pages Changed.

ISTS Bases Markun & Justification il 3.4 22 113,4 22 ,

i 4

1 Note: Italicked entries indicate uneven exchanges. Pleasefollowpage replacement tratructions car < fully,

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LTOP System 3.4.12 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP) System LC0 3.4.12 An LTOP System shall be OPERABLE with:

a. 1. A maximum of one high pressure safety injection (HPSI) pump only capable of manually injecting into H the RCS, and

2. When HPSI suction is aligned to the refueling water tank, the HPSI pump shall be in manual control and either:

a) HPSI flow limited to s 210 gpm, or b) An RCS vent of 2 2.6 square inches established; AND 5

b. HPSI loop motor-operated valves (MOVs) only capable of manually aligning HPSI pump flow to the RCS;

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

HPSI loop MOVs may be capable of automatically aligning HPSI pump flow to the RCS fer the purposes of testing.

AND

c. 1. TwoOPERABLEpower-operatedreliefvalves(PORVs),

and associated block valves open, with PORV lift settings on or below the curve in Figure 3.4.12-1 when the Shutdown Cooling (SDC) System is not in operation and PORV lift settings s 429 psia i t.

(Unit 1), s 443 psia (Unit 2), when the SDC is in operation, or

2. One OPERABLE PORV, and associated block valve open, with PORV lift setting on or below the curve in CALVERT CLIFFS - UNITS 1 & 2 3.4.12-1 Revision S la

RCS Loops - H0DE 3 8 3.4.5 BASES _

RCS Loops MODE 3 satisfy 10 CFR 50.36(c)(2)(ii), <

Criterion 3.

LC0 The purpose of this LC0 is to require two RCS loops to be available for heat removal, thus providing redundancy. The LCO requires the two loops to be OPERABLE with the intent of requiring both SGs to be capable (> -50 inches water level) of transferring heat from the reactor coolant at a controlled rate. Forced reactor coolant flow is the required way to transport heat, although natural circulation flow provides adequate removal. A minimum of one running RCP meets the LCO requirement for one loop in operation.

Note 1 permits a limited period of operation without RCPs.

All RCPs may be not in operation for s 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months fi period and s 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period for low flow testing. This means that natural circulation has been established. When in natural circulation, a reduction in boron concentration is prohibited because an even concentration distribution throughout the RCS cannot be ensured. Core outlet temperature is to be maintained at least 10'F below the sturation temperature so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

In H0DE 3. it is sometimes necessary to stop all RCPs (e.g.,toperformsurveillanceorstartuptesting). The l "! n.

time period is acceptable because natural circulation is adequate for heat removal and the reactor coolant temperature can be maintained subcooled.

Note 2 requires that all of the following three conditions be satisfied before an RCP can be started when any RCS cold leg temperature is s 365'F (Unit 1), s 301*F (Unit 2):

a. the pressurizer water level is s 170 inches, CALVERT CLIFFS - UNITS 1 & 2 -B 3.4.5-2 Revision //lr,

RCS Loops - H0DE 3 8 3.4.5 BASES b, the pressurizer pressure is s 300 psia (Unit 1),

s320 psia (Unit 2),and

c. the secondary water temperature of each steam generator is s 30"F above the RCS T.,,.

Ensuring the above conditions are satisfied will preclude a PORV from opening as a r:sult of the pressure surge in the RCS when an RCP is started.

An OPERABLE loop consists of at least one OPERABLE RCP and an SG that is OPERABLE in accordance with the Steam Generator Tube Surveillance Program. An RCP is OPERABLE if it is capable of being powered and is able to provide forced flow if required.

APPLICABILITY In MODE 3, the heat load is lower than at power; therefore, one RCS loop in operation is adequate for transport and heat removal. A second RCS loop is required to be OPERABLE but not in operation for redundant heat removal capability.

Operation in other MODES is covered by:

LC0 3.4.4, "RCS Loops - MODES 1 and 2;"

LC0 3.4.6, "RCS Loops - MODE 4;"

LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled;"

LC0 3.4.8, "RCS Loops - MODE 5, Loops Not filled;"

LC0 3.9.4, "ShutdownCooling(SDC)andCoolant Circulation - High Water Level" (MODE 6); and LC0 3.9.5, "ShutdownCooling(SDC)andCoolant Circulation - Low Water Level" (MODE 6).

ACTIONS Ad If one required RCS loop is inoperable, redundancy for forced flow heat removal is lost. The Required Action is CALVERT CLIFFS - UNITS 1 & 2 B 3.4.5-3 Revision A l

RCS Loops - MODE 3 8 3.4.5 ;

i BASES restorstion of the required RCS loop to OPERABLE status .

within a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This time allowance is a justified period to be without the redundant, ,

nonoperating loop because a single loop in operation has a heat transfer capability greater than that needed to remove the decay heat produced in the reactor core. !

E.d l If restoration is not possible within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the unit

-must be placed in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In MODE 4 the plant may be placed on the SDC System. The Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is compatible with required operation to achieve ,

cooldown and depressurization from the existing plant conditions in an orderly manner and without challenging

[ plant systems.

C.1 and C.2 -

If no RCS loop is in operation, except as provided in Note 1 in the LCO section, all operations involving a reduction of RCS boron concentration must be imediately suspended. This is necessary because boron dilution requires forced circulation for proper homogenization. Action to restore one RCS loop to OPERABLE status and operation shall be initiated immediately and continued until one RCS loop is restored to OPERABLE status and operation. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal.

SVRVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR requires verification-every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the required number of RCS loops are in operation. Verification

. includes flow rate, temperature, and pump status monitoring, which help ensure t% t forced flow is providing heat CALVERT CLIFFS - UNITS 1 & 2 B'3.4.5-4. Revision O'

RCS Loops - MODE 3 B 3.4.5 BASES removal. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within safety analyses assumptions. In addition, control room indication and alarms will normally indicate loop status.

SR 3.4 M This SR requires verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the secondary side water level in each SG is > -50 inches. An adequate SG water level is required in order to have a heat sink for removal of the core decay heat from the reactor coolant. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within the safety analyses assumptions.

SR 3.4.5.3 Verification that the required number of RCPs are OPERABLE ensures that the single failure criterion is trat and that an additional RCS loop can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power availability to the required RCPs. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience.

REFERENCES None CALVERT CLIFFS - UNITS 1 & 2 B 3.4.5-5 Revision 0

I RC$ Loops-MODES 3 8 3.4.5 '

BASES (continued)

LCO The purpose of this LCO is to requireitwo[ loops to be available for heat removal thus providin edundancy. The LCO requires theaftwo of esquiring both $Gs}4 loop,s(>to be with to be capable OPERAB the intent trt.isferring heat from the reactor coolant at a controlled water level) of kncsi rate. forced reactor coolant flow is the required way to 08 8Sh.'^ e,I transport heat, although natural circulation flow provides N yg,jgg adequate removal. A minimum of one runnin A LCO requirement for one loop in operation.g RCP meets the LU N Not parwits_a limited _

All RCPs mamm-=----~= period of operation without RCPs.

= for s I hour per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months peri h ~

'This means that natural circulation has been estabitshed. ,nj f 2 k.m When in natural circulation, a reduction in boron i p,. t w e concentration is prohibited because an even concentration J distributton throughout the RCS cannot be ensured. Core ?p.,4ot ce outlet temperature is to be maintained at least 10'r below , y ri.s the saturation temperature so that no vapor bubble may fors and possibly cause a natural circulation flow obstruction.

eI

' In M00th,(4XnM)tt is_ sometimes necessary to stop all RCPs(or jnutoown cou nny p uy pump rp sco circ ion (e.g. V,o chance eneratisn from o_ne,5DC tral the et to_ perform surveil' ance or startur testin ,

o perfo the tion to and fr e c System cooli or to av d a d on below the minimum net tt ye suct n he eJ (i. Ine time perioa is acceptacle pecause nature circu' ation is adequate for heat removal,-** tne reactor coolant temperature can be maintained subcooled M h.

tL-P."i;;ti;:. "P; - activit;, .... J ;; :./. . .

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se #4 3 @

An_0PtRABt lo . nsists of at least one gregunnb Unene now far heat tranmearh and an SG t at OPERABl[ in -

'3 accordance Program. with the Steam Generator Tube survet An RCP is OPERABLE if it is capable of being lance" X c. v powered and is able to provide forced flow if r) quired. b, teAARG -

APPLICABILITY In MODE 3, the heat load is lower than at power; therefore, one RCS loop in operation is adequate for transport and heat removal. A second RCS loop is required to be OPERABLE but not in operation for redundant heat removal capablitty.

Operation in other MODES is covered by:

(continued)

Ct0C $15 8 3.4-22 Rev1,04/07/9a

t P;3e Replacement I:structions ,

VOLUME 10 Section 3.6 Note: Underlined titles imlicate tabs in volumes. Regarding CTS markups: Pages are referenced by citing the unit number as util as lie specylcation numbe locatedin the upper right-hand corner of the CISpage.

Key:

DOC = Qiscussion ofChanges ;

DOD = Discussion gf TechnicalSpecy1 cation Deviation or Olscussion gfBases Deviation ,

REMOVE INSERT O$ erslew of Chanatt ,

. No Pages Changed.

II!i 3.6.31 3.6.31 ITS Beset .

Il 3.6.8 4 and B 3.6.8 5 113.6.8 4 and Il 3.6.8 $

CTS Markun & Discussion of Channes Specification 3.6.3, Unit I specification 3.6.3, Unit i Page 6 of 6 Page 6 of 6 DOC 3.6 31 through 3.6.3 8 DOC 3.6.31 through 3.6.3 6 NSilC Findinas No Pages Changed.

ISTS Markun & Justineation "o Pages Changed.

ISTS Bases Markup & Justification il 3.6 23 B 3.6 23

!! 3.6-84 and 113.6 85 !! 3.6-84 and 13 3.6-85 DOD 3.6-1 through DOD 3.6-3 DOD 3.6 I through DOD 3.6 3 i ,

Note: Italici:cd entries imlicate uneven exchanges. pleasefollow page replacement instructions carefully.

Containment Isolation Valves l 3.6.3 :

3.6 CONTAINMENT SYSTEMS ,

3.6.3 Containment Isolation Valves LCO 3.6.3 Each containnent isolation valve shall be OPERABLE. ;

U P

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

.................................... NOTES---.--.--..----.----.--------.------

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path. ,

, 3. Enter applicable Conditions and Required Actions for system (s) made inoperable by containment isolation valves. ;

4. Enter applicable Conditions and Required Actions of LCO 3.6.1,

' Containment," when leakage results in exceeding the overall containment leakage rate acceptance criteria.

5. Shutdown cooling isolation valves may be opened when RCS temperature is gg

< 300*F to establish shutdown cooling flow.

J

.CALVERT CLIFFS UNIls 1 & 2 - 3.6.3-1 Revision #'/t.

.:a _, . ~ . _ .. - . . - - - - _ , . _ - 4 .. - - . . --

IRS B 3.6.8 BASES brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least .

MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The 4

allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full powar conditions in an orderly manner and without :

chai.enging plant systems.

SVRVEILLANCE SR 3.6.8.1 REQUIREMENTS Initiating each IRS train from the Control Room and operating it for 215 minutes ensures that all trains are '

OPERABLE and that all associated controls are functioning properly. It also ensures that motor failure can be "

detected for corrective action. The 31 day Frequency was 7 developed considering the known reliability of fan motors and controls, the two train redundancy available, and the iodine removal capability of the Containment Spray System independent of the IRS.

SR 3.6.8.2 This SR verifies that the required IRS filter testing is performed in accordance with the Ventilation Ftiter Testing Program (VFTP). The IRS filter tests are in accordance with g portions of Regulatory Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-4 Revisiongp.

IRS B 3.6.8 BASES SR 3.6.8.3 The automatic startup test verifies that botn trains of equipment start upon receipt of an actual or simulated test signal (ESFAS). The 24 month Frequency is based on the need to perform this Surveillance under the cciditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Furthermore, the frequency was developed considering that the system equipment OPERABILITY is demonstrated on a 31 day Frequency by SR 3.6.8.1.

REFERENCES 1. UFSAR, Appendix IC

2. UFSAR Section 6.7

3. UFSAR, Section 14.21

4. Regulatory Guide 1.52 Revision 2 it CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-5 Revisionglt.

i Sg & &aJa,3 3/4.6 CMTAllBENT SYSTDil 3/4.6.1 PRIMARY CONTAllMENT l

.s Containment Puree $rstem I

\LIN!!DIC CMDITIM FOR OPERATIM

[

/ j.

3.6.1.7 containment u supp); and exhaust isolation valv closedb{yvalish air supp deting air i t energized.

air cierate and maintaining i shallbe[ltq.g) solenoid APPLICABILITY: 1. 2, 3 and 4.

81L88

a. With one contai t purge supply or one exhaust isolation close t open valve within one hour or be in at valveopenITAND8Ywit least NOT the n 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SMUTDOWN within the following 30 ur

b. With one containment pu s ly and/or one exhaust isolation valve inoperable due t iph ka e repair the valve (s) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in C0 $NUJ3Wil hIn the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

$URVEILLANCE REQUI ENTS 4.6.1.7 The 4 inch containment purge supply and exhaust isola n valves shall be det ined~ closed at least once per 31 days, by verifying at , ,

power to t solenoid valve is removed, i

.CALVERT Cliff $ - UNIT 1 3/4614 Amendment No. 212 [

fay NN

D!SCUSSION OF CIIANGES I

SECTION 3.6.3 - CONTAINMENT ISOLATION VALVES l _

I l ADMINISTRATIVE CIIANGES

. . . . The proposed change will reformat, rene.ber, and reword the existing Technical Specifications, with nc. chang: of intent, to be consistent with NURF'i 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, cenain wording preferences or conventions wem adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added te more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional information does not change the intent of the current Technical Specificati;ns. The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications.

A.2 Current Technical Specification 4.6.4.1.2 requires the verification that the containment isolation valves (CIVs) actuate to the isolation position on a Containment isolation Signal (CIS) Channel A or B test signal, and on a Safety injection Actuation Signal Channel A or B test signal, improved Technical Specifications allow the SR to be performed with a simulated signal or credit to be taken with an actual signal. This change allows credit to be taken for an actual signal if the CIVs can be verified as having been isolated. The actual signal is as valid as a simulated signal because it places a demand on the valves to isolate.

This is consistent with current plant practice if all the functions can be verified. Adding this additional information to the SR is an administrative change. This change is consistent with NUREG 1432.

A.3 Current Technical Specification 3.6.4.1 Action a contains a requirement to restore th:

inonerable valve (s) to Operable status within four hours, or to isolate the affected penetration or to shut down. Improved Technical Specification 3.6.3 will not contain the requirement to restore the valve to Operable status. The option to restore the CIV(s) to Operable status, however, still exists. Once the valve (s) is retumed to Operable status, the Actions do not have to be completed, and the LCO can be exited. Therefore, requiring the valve (s) to be restored is not required in the ITS. Deleting an unnecessary requirement is an administrative change. This change is consistent with NUREG-1432.

A.4 Current Technical Specification 3.6.4.3.e states that the provisions of Specification 3.0.4 are not applicable, provided that the affected penetration is isciated. Improved Technical Specification 3.6.3 will rot contain this requirement. Improved Technical Specification LCO 3.0.4 states that entry into a Mode or other specified condition in the Applicability shall not be made, except when the asrociated Actions to be entered permit continued operation in the Mode or other specified condition in the Applicabilip for an unlimited period of time.

Since the ITS 3.6.3 Actions allow continued operation, Mode changes are allowed. Deleting a requirement that exists through the LCO 3.0 requirements constitutes an administrative change. This chang: is consistent with NUREG-1432.

A.5 Improved Technical Specification 3.6.3 will contain an Actions Note (Note 2) which allows separate condition entry for each penetration flow path. Current Technical Specification 3.6.4.1 Actions do not contain this requiren.en*,. This Note provides explicit instructions for proper application of the actions for Technical Specification compliance. In conjunction with the proposed Specification 1.3 ' Completion Times," this note provides t

l CALVERT CLIFFS - UNITS I & 2 3.6.3- 1 Revision 12

DISCUSSION OF CilANGES l

SECTION 3.6.3 - CONTAINMENT ISOLATION VALVES direction consistent with the intent of the existing Actions for the containment isolation valves. This change is consistent with NUREG 1432.

A.6 Improved Technical Specification 3.6.3 will contain an Actions Note (Note 3) which requires entry into applicat.e Conditions and Required Actions for system (s) made inoperable by CIVs. Current Technical Specification 3.4.3.1 does not contain this requirement. This change adds a requircraent to declare system (s) inoperable that are made inoperable by inoperable CIVs. This Action was added beca se, per ITS LCO 3.0.6, only the Actions of the CIVs would have to be entered. Ilowet r, since inoperable CIVs require isolation of penetrations to the affected system (s) with continued operation, cascading to the affected systein b prudent. This requirement is necessary because unlimited continued operation with a system inoperable could severely affect the mitigation of accidents and violate the safety analyses. The CTS does not contain a Specification similar to LCO 3.0.6 and, therefore, already requires cascading. The addition of a requirement which is already required in the CTS is an administrative change. This change is consistent with NUREG-1432.

A.7 Not used.

A.8 Current Technical Specificatien 4.6.4.1.3 requires the isolation time of each pcwer-operated or automatic CIV to be determined to be within its limit when tested pursuant to Technical Speci'hation 4.0.5. Improved Technical Specification will require the SR to be performed in accordance with the Inservice Testing Program. This change is administrative because ITS moved CTS 4.0.5 and incorporated it into the Inservice Testing Program, which is required per ITS Section 5.0. The requirement to perform the SR has not changed. This change is consistent with NUREG 1432.

A.9 Current Technical Specification 3.6.4.1 does not specifically have different Actions for different types of penetrations. Improved Technical Specification 3.6.3 contains Actions for different type penetra*. ions with different numbers of valves inoperable. Improved Tchnical Specificatict. 3.6.3 Actions A and D will contain a Conditions Note which specifies that these Conditions only apply to penetration flow paths with two CIVs and not a closed system. Improved Technical Specification 3.6.3 Action C will contain a Conditions Note which specifies that this Condition only applies to penetration flow paths with one or more CIVs and a closed system. Adding Notes which specify which Actions are applicable is an administrative change because tb vequirement is not affected technically.

A.10 Not Used. l A.1 i Unit 1 CTS SR 4.6.4.1.2.b requires verifying that on each Containment Radiation- High Test Channel A or Channel B test signal, both required containment purge valves actuate to their isolation position. Improved Technical Specificatioa 3.6.3 SRs will not contain this Surveillance. Current Technical Specification SR 4.9.9 and ITS SR 3.9.3.2 also require verifying the containment purge valves actuate on a Containment Radiation - High Test signal. Therefore, deleting an SR which is duplicated in another Specification constitutes an administrative change. This change is consicent with NUREG-1432.

I 1

1

~

CALVERT CLIFFS - UN'TS 1 & 2 3.6.3-2 Revision 12

DISCUSSION OF CilANGES SECTION 3.63 - CONTAINMENT ISOLATION VALVES r

IECHNICAL CIIANGES - MORE HERTRICTIVE M.1 Current Technical Specification 3.6.4.1 Actions require the penetrations to be isolated within four hours if two CIVs are inoperable, improved Technical Specification 3.6.3 Action B will require the penetration to be isolated within one hour, his change decreases the Completion Time to isolate a penetration, when two CIVs in the penetration are inoperable, from four hours to one hour. With both CIVs in one penetration inoperable, the means to isolate containment is hindered. The one-hour Completion Time is consistent with the urgency to ,3 isolate containment, and is also consistent with the Actions of LCO 3.6.1. In addition, the affected penetration flow path must be isolated with an isolation barrier that cannot be adversely cffected by a single active failure (closed and deactivated automatic valve, a closed manual valve, or a blind flange). Decreasing the Completion Time to complete an Action constitutes a More Restrictive change. This change will not adversely affect safety because when two CIVs are inoperable, the ability to isolate the penetration is hindered, and rapid isolation is warranted. This change is consistent with NUREG 1432.

M.2 Improved Technical Specification 3.6.3 Required Actions A.2 and C.2 contain requirements '

to verify that the affected penetration flow path is isolated once per 31 days foi isolation devices outside containment, and Action A.2 contains an additional Completion Time to verify the affected penetration flow path is isolated prior to entering Mode 4 from Mode 5, if not performed within the previous 92 days for isolation devices inside containment. The added Required Actions are modified by a Note which allows the isolation devices in high radiation areas to be verilled by use of administrative means. Current Technical Specification 3.6.4.1 does not pain these requirervents. This change will add requirements to Technical Specificanons to periodically verify that the affected penetration flow path is isolated. This verification is necessary to ensure that containment penetrations required to be isolated following an accident, and no longer capable of being automatically isolated, will be in the isolation position should an evc at occur. The addition of requirements to the Technical Specifications constitutes a more restrictive change. This change will not adversely affect safety Lecause it ensures that the isolated penetrations remain isolated. This chang is consistent with NUREG 1432.

M.3 Current Technical Specification 3.6.1.1 Footnote

allows the h' cogen purge containment vent isolation valves to be opened for containment pressure control, airborne radioactivity control and Surveillance testing purposes only, improved Technical Specification 3.6 3 creates an SR (SR 3.6.3.1) from this allowance. The ITS SR will require the verification that the containment vent is only opened for the above listed purposes (and air quality considerations as heribed in a less restrictive Discussion of Changes) once per 31 days.

This SR ensures that the containment vent valves are closed as required or, if open, open for an allowable reason. T' in-day Frequency is consistent with other CIV requirements.

Adding an SR to verify . C iwance constitutes a more restrictive change. The addition of this SR is not adverse to plant safety because it ensures that this CIV is only opened for approved purposes. This change is consistent with NUREG-1432.

TECIINICAL CIIANGO - RELOCATIONS None TECilNICAL CilANGES - MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED CALVERT CLIFFS - UNITS 1 & 2 3.6.3-3 Revision 12

I DISCUSSION OF CIIANGES SECTION 3c6.3 - CONTAINMENT ISOLATION VALVES DOCUMENTS LA.1 Current Technical Speci0 cation SRs 4.6.4.1.2.a and c specifically list the types of test signals (CIS Channel A or B, and Safety injection Actuation Signal Channel A or B) required for testing that the CIVs actuate to their isclation position. Improved Technical Specification SR 3.6.3.5 will rcluire that the CIVs be verified to isolate on an actual or simulated test signal. The test signal will no longer be specified in the SR. The test signal wH1 be moved to Section B 3.6.3 of the ITS Bases. This is acceptable because these details do not impact the requirement to verify that the CIVs will isolate when required. These details can be adequately controlled in the Bases which require change control in accordance with the Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process.

Safety is unaffected by the change because there is no change in the requirement for the CIVs to isolate. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This is a less restrictive movement of information change with no impact on safety. This change is consistent with NUREG-1432.

LA.2 Not used.

LA.3 Not Used. l LA.4 Not Used. l TECllNICAL CllANGES - LESS RESTRICTIVE L.1 Current Technical Specification 3.6.4.1 Actions b and c require that a penetration with one or more inoperable CIVs be isolated with one deactivated automatic valve secured in the isolation position, or by use of at least one closed manual valve or blind flange. Improved Technical Specifications 3.6.3 Action A (when only one CIV is inoperable) will additionally allow the penetration to be isolated by a check valve with flow through the valve secured.

This change adds an additional method for isolating a penetration when one CIV is inoperable. One CIV for the affected penetration is still Operable. This valve, combined with the check valve with Dow through the valve secured, is as effective in isolating the penetration as a secured automatic valve, a closed manual valve, or a blind flange.

Therefore, the check valve with flow through the valve secured will perform the intended safety function of isolating the penetration. Adding methods to the Technical Specifications on how to isolate a penetrations constitutes a less restrictive change. This change is consistent with NUREG-1432.

L.2 Current Technient Specification 3.6.4.1 Actions b and c require the penetration flow path to be isolated within four hours when the CIV is inoperable. These Actions can be applied to penetration flow paths in a closed system. Penetration flow paths in closed systems are only required to have one CIV, improved Technical Specification 3.6.3 Action C will require the penetration to be isolated within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the CIV is inoperable in a penetration with a closed system. The penetration is required to be isolated with a closed and deactivated automatic valve, a closed manual valve, or a blind flange. This change will increase the Completion Time for this Action fu m 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This time is reasonable, considering the reliability of the closed system to act as a penetration isolation boundary.

CALVERT CLIFFS - UNITS I & 2 3.6.3-4 " ' Revision 12

DISCUSSION OF CIIANGES l

SECTION 3.6.3 - CONTAINMENT ISOLATION VALVES The closed system will perform the safety function ofisolating the penetration until the valve isisolated. Increasing the Completion Time to complete the Actions constitutes a less restrictive change. This change is consistent with NUREG 1432, TSTF.30.

L.3 Not used.

L.4 Current Technical Specification 4.6.1.1.a and Footnote " to CTS 4.6.1.1.a require all penetrations required to be closed during accident conditions, which are not capable of being closed by OPERABLE containment automatic isolation valves, be verified closed by valves, blind flanges, or deactivated automatic valves. Improved Technical Specification SRs 3.63.2.nd 3.6.3.3 also require verification that the containment isolation manual valves and blind Danses that are required to be closed during accident conditions are closed; hmver, the ITS SRs do not require containment isolation manual valves and blind Ha' p. .t are locked, sealed, or otherwise secured to be verined closed. Current Technical Specification 4.6.1.1.a and Footnote " to CTS 4.6.1.1.a have been changed to include the exception regarding manual valves and blind flanges that are locked, scaled, or otherwise secured. His proposed change is acceptable, because containment isolation manual valves and blind Danges that are locked, sealed, or othenvise secured in position are verified to be isolated prior to locking, sealing, or securing. ARer locking, sealing, or securing, it would take an intentional act to remove the lock, seal, or securing device prior to opening the valve or blind Dange. Administrative controls are provided to assure that manual valves and blind Danges which are locked, sealed, or secured closed are not inadvertently opened.

Additionally, this proposed change is consistent with the requirements of a number of CTS SRs (e.g., 4.5.2.b.1, 4.7.1.2.a.4, 4.7.3.1.a, 4.7.4.1.a, and 4.7.5.1.a) which do not require the position of valves that are locked, sealed, or othenvise secured in position to be verified.

L5 Current Technical Specification 3.6.1.1 footnote

requires the containment vent to be '

opened only for containment pressure control, airborne radioactivity control, and Surveillance testing purposes, improved Technical Speci0 cation SR 3.63.1 requires the verification once per 31 days that the containment vent is closed, except for containment pressure control, airborne radioactivity control, air quality control, and Surveillance ating purposes. This change essentially adds an allowance for the containment vent to b; yned for air quality control purposes. This is reasonable because containmen w quality in containment is critical for personnel entry. Also, the containment vent is capable of closing in the environment following a loss-of-coolant accident. Adding an additional allowance for the containment vent to be opened constitutes a less restrictive change. This change is consistent with NUREG-1432.

L.6 Not used.

L7 Current Technical Specification SR 4.6.1.1.a requires all penetrations (inside and outside of containment) not capable of being closed by Operable CIVs, and are required to be closed during accident conditions, to be verified closed. Improved Technical Specification SR 3.6.3.2 (outsile containment) and SR 3.6.3.3 (inside containment) will require the penetration to be verified closed; however, the ITS will contain a Note which allows valves and blind Danges in high radiation areas to be verified by administrative means. This Note is acceptable since access to these areas is typically restricted for as low as reasonably achievable radiation exposure reasons. Also, sirice these areas are restricted, the chances of CALVERT CLIFFS - UNITS 1 & 2 3.6.3-5 Revision 12

l DISCUSSION OF CIIANGES SECTION 3.6.3 - CONTAINMENT ISOLATION VALVES these isolation devices being misaligned once they have been verified to be in the proper position is small. This change is consistent with NUREG 1432.

L.8 Not Used. l L.9 Not Used. l L.10 Current Technical SpeciDcation SR 4.6.4.1,1 requires each containment isolation valve to be demonstrated OPERABLE prior to returning the valve to se vice after maintenance, repair, or replacement work is performed on the valve or its associated actuator, control, or power cixuit. Improved Technical SpeciDcation 3.6.3 will not contain this SR. Current Technical Specification 4.6.4.1.1 is being deleted. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrate OPERABILITY of the system or component.

After restoration of a component that caused a required SR to be failed, ITS SR 3.0.1 requires the appropriate SR (i.e., ITS SR 3.6.3.4) to be performed to demonstrate OPERABILITY of the affected components. Therefore, explicit post maintenance Surveillance Requircments (i.e., CTS SR 4.6.4.1.1) are not required and are not included in the Calvert Cliffs ITS.

L.11 Current Technical Specification LCO 3.6.4.1 is modified by Footnote

which states:

"Vaives that are normally closed may be opened on an intermittent basis under adminhtrative control." Improved Technical Specification 3.6.1.3 ACTIONS, Note 1 permits the penetration flow paths to be unisolated intermittently under administrative controls, While the CTS Footnote is siinitar to Actions Note 1, there la a subtle difference.

Footnote

of CTS LCO 3.6.4.1 only applies to valves that ere normally closed (i.e., manual valves), while ACTIONS Note i for ITS LCO 3.6.3 applies to any penetration flow path that has been closed to comply with an action. The CTS have been modified to include ACTIONS Note 1 of ITS LCO 3.6.3. Opening of containment penetrations on an intermittent basis is required for performing surveillances, repairs, routine evolutions, etc.

Intermittently opening CIVs which are isolated in accordance with an action requirement is acceptable due to the low probability of an - mt that could pressurize the containment during the short time in which the penetre ow path is open and the administrative controls established to ensure the affected pe ... ration can be isolated when a need for containment isolation is indicated.

l CALVERT CLIFFS - UNITS 1 & 2 3.63-6 Revision 12

f 1

e Containment Isolation Yalves (?.t-- 1 :-u nd R B3.6.$

h 8ASES (continued)

ACTIONS The ACTIONS are modified by a Note allowino oene< ration flow path nex w for ! 4 M nch purge x ve penetpft' to be unisolated intermittently under idn'nislrative on w M W

con s. These administrative controls consist of sittioning a dedicated operator at the valve. controls, who is in continuuus communication with the control room. in this way, the penetration can be rapidly isolated when a 4.g g *jj,**##

4 %iJ=.C 14 3(Q;sJ.l.'

need for containment isolation is indicated. Wue to t e 1

' sue of Ine containment purge line penetranon and t that ose penetrations exh st directly from the fact h con ineent atmosphere to e environment these alves may

f"'

0 M tfmd 'e opened under ads istrativecontroIt _

I

- - $CC pT"durC A secor.d Note has been added to provide clarification that,

C 4 300*F -/o for this LCO, sept ate Condition entry is allowed for each i

e c/,f/;,/ #o< [/J' i

er keq.atration uired Actions flowfor path.eachThis is acceptable, Condition since the prcvide appropriate s

b, compensatory actions for each inoperable containment

/lah 4. n I .re .) isolation valve. Complyin with the Required Actions may ff OperM/* ,o ,

allow for continued operat on, ar.d sut, sequent inoperable containment isolation valves are overned by subsequent i MJM f Io * //M Condition entry and application o associated Reqd red Jag .A, g Actions, c.th.UM a The ACTIONS are further modified by a third Note, which ensures that appropriate remedial actions are taken, if necessary, if the affected syst6ms are rendered inoperable by an inoperable containment isolation valve.

A' fourth Note has been added that requires entry into the applicable Conditions ard Required Actions of LCO 3.6.1 when '

leakage results in exceeding the overall containment leakage limit.

Q A.1 and A.2 In the event one containment isolation valve in one or more_

onnetration flow oaths is inoperable (except purge va ji e, leak and shieMTuiioing bwerss is akaae within / i

,) ,

the affected penetration flow pith must be isolated.

The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic -

containment isolation valve, a closed manual valve, a blind ,h s

(continued)

CEOG STS B 3.6-23 Rev 1, 04/07/95

l l

sw . -

7, ,

BASES (continued)

SURVEILLANCE REQUIREMENTS SR 3.6.

1 Mh /

k ** '

endrAtpha each V5 train'for 115 minutes ensures that all trains are OPERABLE and that all associated ram enin are A l functioning pranariv. It also ensures that6Pookalie. faMff) motor failurfor1xces244 vibremotDean be detected for QD

' corrective action. ffor systems w ,(h heaters, operatio withl lthe neaters n (automatic heater ycling to maintain j temperatur for 110 continuou hours eliminates no ture

>n the a orbers and HEPA fil rs. Experience fr filter testi at operating units i icates that the 10 ur period is ad unto for maisture el innian an na um - -d NEP litersJ The 31 day frequency was developed considering the known reliability of fan motors and controls, the two . rain redundancy available, and the lodine removal capability of the Containment Spray System independent of the ifs. g 6

SR 3.6. 1 This SR verifles that t e re u red IJS filter testing is performed in accordanc with the Ventilation Filter Testing '

Program (VFTP). 4he 10 fil er tests are in accordance with yRegulatory Guide 1.52 (Ref. ). The VFTP includes testing i HtPA tilter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.6. 3

The automatic st rtup est verifles that both trains of

\ equipment start upon receipt of an actual or simulated test f[' f#4S/ signal. The month Frequency is based on the need to perf6rs this urvelliance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operattng experience has shown that these e <

ts usually pass the Surveillance when performed at f a conci month Frequenc . Therefore, the Frequency was dtobeacceptaflefromareliabilitystandpoint. @

Furthermore, the Frequency was developed considering that (continued)

CEOG STS B 3.6-84 Rev 1, 04/07/g5

l l

ghz . .r.

(D BASES SURVEILLANCE SR 3.6. 3 (continued)

REQUIREMENTS the system equipment OPERA 8ILITY is demonstrated on a 31 day frequency by SR 3.6. .1.

' ~

SR 3.6.1d4 The ICS 11ter bypass dampers are teste to verify OPERAB ITY. The dampers are in the b ass position during norma operation and must reposition or accident operation to d W air through the filters. T [18] month Frequency is nsidered to be acceptable bas on the damper re ability and design, the mild vironmental conditions n t vicinity of the dampers, and he fact th6t operating xperience has shown that the d spirs usually pass the urveillance when performed a the[18)monthFrequen .

REFERENCES 1. }0J#1t 50, Appprfdix A, CDC 41,/6C 42, and GDC/.} 3

( 2. (3/SAR, Section@

Q Regulatory Guide 1.51, fevision .

@, SAR, Section I u (3A C /1preal** A L-'

CEOG STS B 3.6-85 Rev 1, 04/07/95

l DISCUSSION OF BASES DEVIATIONS FROM NUREG-1432 i SECTION 3.6 - CONTAINMENT Si, '31S PLANT SPECIFIC CllANGES

1. This change deletes the term Atmospheric and the terms Atmospher and Dual in parenthesis in the Bases. These terms were placed in the NUREG-1432 Bases titles i > inform the users that the Specification is for atmospheric and/or dual containment plants. Rese informational terms are not required for the Calvert Cliffs Improved Technical Speci6 cations (ITS). Calvert Cliffs has an Atmospheric containment and will adopt the applicable Specifications. This change also applies to the deletion of NUREG 1432 Speci0 cations that do not apply to Calvert Cliffs and any designations in the titles that relate.

2. This change incorporates Calvert Cliffs-specific information into brackets. Bracketed information located throughout NUREG 1432 will be replaced with the speci0c Calvert Cliffs information. This change also includes the deletion of the bracketed information.

3. This addition, deletion, or modiGeation to references, or the changing of reference numbe s was performed to ensure that the references are applicable to Calvert Cliffs, and to ensure consistency between references in the text and the reference section.

4. Calvert Cliffs has an Updated Final Safety Analysis Report, therefore,"FSAR" will be changed to "UFS AR" throughout the ITS Bases.

5. The containment purge supply and exhaust isolation penetrations are being blind Ganged outside containment as described in Calvert Cliffs Technical Speci6 cation change request from Mr. C.11. Cruse (Baltimore Gas and Electric Company) to NRC Document Control Desk, dated August 1,1996, License Amendment Request, Use of Blind Flange in Place of Containment Purge Valves During Operations. Revisions were made (changes, additions, or deletions) throughout the 3.6 Bases to reDect this.

6. This change to the ITS Bases incorporates changes made to the ITS. This change ensures consistency between the ITS and ITS Bases.

7. This addition to the Bases represents speci0c Calvert Cliffs information moved from the Current Technical Speci0 cations. These additions will provide infomiation in the ITS which are deemed necessary to help clarify the Bases This change is consistent with the Calvert Cliffs design.

8. This change to the non-bracketed value, system name, or terminology was made to be consistent with the Calvert Cliffs-specific number, system name, or terminology. This change also includes e changes made which correct speci6c references to the Accident analyses, and other changes which clarify the Bases.

9. This change deletes the bracketed information labeled Reviewers Notes. This is acceptable because the Reviewers Notes are information for the NRC reviewers and not intended to be maintained in the individual plants' Technical Speci6 cations.

10. All references to Calvert Cliffs being in compliance with the General Design Criteria (GDC) are being deleted. Although Calvert Cliffs meets the intent of the GDC, it wcs licensed as a pre-GDC plant. Therefore, all references to GDC are being replaced with a reference from the Updated Final Safety Analysis Report Updated Final Safety Analysis Report Appendix 1C, which is the draft GDC. T his change is consistent with the Calvert Cliffs current licensing basis.

CALVERT Cl.lFFS - UNITS 1 & 2 3.6-1 Revision 12

, DISCUSSION OF llASES DEVIATIONS l' ROM NUREG-1432

{ SECTION 3.6 - CONTAINMENT SYSTEMS

11. This change to the Bases reflects the Calvert Cliffs-speciGe safety analysis, plant system or operation, er design basis.

12. NUREG 1432 contains Speci6 cations in 3.6 that are not applicable to the Calvert Cliffs ITS.

These Specincations are B 3.6.1, " Containment (Dual)," B 3.6.48, " Containment Pressure (Dual)," B 3.6.6B," Containment Spray and Cooling Systems (Atmospheric and Dual)," B 3.6.7,

" Spray Additive System (Atmospheric and Dual)," B 3.6.9,"flydrogen Mixing System (llMS)

(Atmospheric and Dual)," B 3.6.11, " Shield Building (Dual)," and B 3.6.13, " Shield Ruilding Exhaust Air Cleanup System (SBEACS)(Dual)." These Specincations were not include . the Calvert Cliffs ITS. This change is consistent with Calvert Cliffs' current licensing basis.

13. NUREG-1432 B 3.6.4 Applicable Safety Analyses Section contains information ccncerning the containment design. Calvert Cliffs' ITS will not contain this information because it is not applicable. The Calvert Cliffs containment was designed for the event described in B 3.6.4 Background. This change is consistent with the Calvert Cliffs current licensing basis.

14. Speci6 cation 3.6.3, Containment isolation Valves, Condition C applies to Containment isolation Valves on a closed system. At the request of the licensed operators, we have included a list of containment penetrations which are in a closed system in the Bases. This list is taken from the Calvert Cliffs Updated Final Safety Analysis Report, Figure 510 and Table 5.3 and will assist the operators in accurately following the To %ical Speci0 cations. In addition, a reference to the Standard Review Plan description of closed systems was eliminated. Calvert Cliffs is not licensed to the Standard Review Plan for containment isolation valves and the referenced description does not match the Calvert Cliffs licensing basis.

15. Not used. l

16. TSTF-17, Revision 1, added the following statement to the Bases of NUREG 1432 SR 3.6.2.2.

"The 24 month Frequency is based on the need to perform this Surveillance under the conuitions that apply during a plant outage, and the potential for containment OPERABILITY if the Surveillance were performed with the reactor at power." The last half of the statement is incorrect. During power operations, containment OPERABILITY is required. Performing the tot d iring an outage, avoids the potential for a loss of containment OPERABILITY, Thus, the Bases should state: "...and the potential .~or loss of containment OPERABILITY if the Surveillam:e were performed with the reactor at power." Additionally, TSTF-17, Revision 1, revised the NUREG-1432 Bases for SR 3.6.2.2 to state: " . . .given that the interlock mechanism is not normally challenged when containment is entered . . ." This statement is also inaccurate.

It should state: "given that the interlock mechanism is not normally challengod when the air lock is entered . . ." The Bases for ITS SR 3.6.2.2 have been ievised to inco porate the changes discussed above, as well as several editorial enhancements.

17. Typographical / grammatical error corrected.

18. This change incorporates correct terminology from 10 CFR Part 50, Appendix J. Op. ion B, for deGning the term P, as the calculated peak containment internal pressure related to the design basis loss-of-coolant accident.

l CALVERT CLIFFS - UNITS I & 2 3.6-2 Revision 12

c- -

y.

DISCUSSION OF BASES DEVIATIONS FROM NUREGol412 )

SECTION 3.6 - CONTAINMENT SYSTEMS l 1

19. NUREG 1432 B SR 3.6.8.1 states that operr. ting each lodine Removal System train for l

215 minutes " . . . also ensures that blockage. fan or motor failure, or excessive vibration can be detected for corrective action." Improved Technical Specifications will not include the alarms ,

for bicekage or excessive vibration becauso this equipment is inside Containment, and the only l way to make the determination is by golig inside Containment. Containment entries while operating at power will not be made for this wrveilbnce. l l

CALVERT CLIFFS - UNITS I & 2 3.6-3 Revision 12

Pcge Replacemnt IIstructio:s VOLUME 11 Section 3,7 Note: Urulerlined titles indicate tabs in volumes. Regarding CIS markups: Pages are referenced by citing the unit number as well as the specification number locates in the upper right handcorner ofthe CISpage. - ,

Key:

DOC = Discussion ofChanges DOD = Discussion Of TechnicalSpecylcation Deviation or Dhcussion QfBases Deviation REMOVE INSERT hrview of Channes No Pages Changed.

LTE 3.7.8-4 3.7.8 4 ITS Bases -

B37.8-8 B 3.7.8 8 8 3.7.10-4 8 3.7.10-4 B 3.7.1I 4 and B 3.7.115 B 3.7,11-4 and B 3.7.11 5 B 3.7.12 4 B 3.7.12-4 B 3.7.15 1 B 3.7.15 1 CTS Markup & Discussion of Channes Specification 3.7.8, Unit i Specification 3.7.8, Unit i Page5of6 Page 5 of 6 Specification 3.7.8, Unit 2 Specification 3.7.8, Unit 2 Page 5 of 6 Page 5 of 6

- DOC 3.7.11-1 through DOC 3.7.113 DOC 3.7,Il 1 through DOC 3.7.11-3 NSHC Findinas No Pages Changed.

ISTS Markup & Justification 3.7 5 3.7-5 3.7 26 3.7 26 DOD 3.7-6 DOD3.76

'i

[ Note: Italici:ed entries indicate uneven exchanges. Pleasefollow page replacement instructions carefulty.

Pege Repl: cement Instructions

[

VOLUME 11 l Section 3.7 Note: Underlined titles indicate tabs in volumes. Regarding CIS markups: Pages are referenced by citing the unit number as wil as the specification number located in the upper r!ght-hand corner ofthe CTSpage.

Km:

DOC = Discussion OfChanges DOD = Discussion Qf TechnicalSpectfication Deviation or Discussion OfBases Deviation REMOVE INSERT ISTS Bases Markup & Justification B 3.713 B 3.7-13 B 3.7 59 and B 3.7-60 B 3.7 59 and B 3.7-60 B 3.7 68 and B 3.7 69 B 3.7-68 and B 3.7-69 B 3.7 74 B 3.7 74 B 3.7 76 B 3.7 76 B 3.7-80 B 3.7-80 B 3.7 82 B 3.7-82 DOD 3.71 through DOD 3.7-4 DOD 3.7-1 through DOD 3.7-4 ii Note: Italici:ed entries indicate uneven exchanges. Pleasefollowpage repiccement instructions carefully.

CREVS 3.7.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY lL SR 3.7.8.3 Verify each CREVS train actuates on an 24 months actual or simulated actuation signal, l

CALVERT CLIFFS - UNITS 1 & 2 3.7.8-4 Revision #lt l

CREVS B 3,7.8 BASLS SR 3.7.8.2 This SR verifies that the required CREVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREVS filter tests are in accordance g with portions of Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing 11 EPA filter perfonnance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and ,

followingspecificoperations). Specific test frequencies and additional information are discussed in detail in the VFTP.

t SR 3.7.8.3 This SR verifies each CREVS train starts and operates on an actual or simulated actuation signal (CRRS). This test is R conducted on a 24 month Frequency. This Frequency is adequate to ensure the Cr . ', capable of starting and operating on an actual e lated CRRS.

12 REFERENCES 1. UFSAR, Section 9.8.2.3 UFSAR, Chapter 14 2.

3. Regulatory Guide 1.52, Revision 2 gg CALVERT CLIFFS - UNITS 1 & 2 B 3.7.8-8 Revisiongg

ECCS PREFS B 3.7.10 BASES SR 3.7.10.2 This SR verifies that the required ECCS PREFS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The ECCS PREFS filter tests are in p accordancewithportionsofRegulatoryGuide1.52(Ref.3).

The VFTP includes test 1 . HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physic.a1 properties of the activated charcoal (general use andfollowingspecificoperatioas). Specific test frequencies and additional information are discussed in detail in the VFTP.

REFERENCES 1. UFSAR, Section 9.8.2.3

2. UFSAR, Section 14.9 b

3. Regulatory Guide 1.52, Revision 2 g CALVERT CLIFFS - UNITS-1 & 2 B 3.7.10-4 Revision git.

SFPEVS B 3.7.11 BASES were to occur to cause cessation of operation of the SFPEVS, it would be quickly identified. S SR 3.7.11.2 This SR verifies the performance of SFPEVS filter testing in accordance with the Ventilation Filter Testing Program (VFTF). The SFPEVS filter tests are in accordance with g portionsofRegulatoryGuide1.52(Ref.6). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following'specificoperations).-Specifictestfrequencies and additional information are discussed in detail in tM VFTP.

SR 3.7.11.3 This SR verifies the integrity of the spent fuel storage pool area. The ability of the spent fuel storage pool area to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the SFPEVS. During operation, the spent fuel storage pool area is designed to maintain a slight negative pressure in the spent fuel storage pool area, with respect to cdjacent areas, to prevent unfiltered LEAKAGE.

This test is conducted on a 24 month Frequency. This frequency is adequate to ensure the SFPEVS is capable of maintaining a negative pressure.

REFERENCES -1. UFSAR,-Section 9.8.2.3

2. UFSAR Section 14.18 CALVERT CLIFFS - UNITS 1 & 2 B 3.7.11-4 Revision glt

SFPEVS B 3.7.11-BASES

3. Regulatory Guide 1.25

. 4, 10 CFR 100.11

5. Regulatory Guide 1.52. Revision 2' 12.

CALVERT CLIFFS - UNITS 1 & 2 B 3.7.11-5 Revision 7;c

PREVS B 3.7.12 BASES for 2 15 minutes. The 31 day Frequency is based on the known reliability of the equipment and the two train b redundancy available.

}R 3.7.12.2 This SR verifies tlie performance of PREVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP). The PREVS filter tests are in accordance with g.g portions of Reference 4. The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated chcrcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.12.3 This SR verifies that each PREVS train starts and operates on an actual or simulated actuation signal (Containment 6 IsolationSignal). This test is conducted on a 24 month Frequency. This Frequency is adequate to ensure the PREVS g is capable of starting and operating on an actual or simulated Containment Isolation Signal.

REFERENCES 1. UFSAR, Section 6.6.2

2. UFSAR, Chapter 14 3.- UFSAR, Section 14.24 g

4. Regulatory Guide 1.52. Revision 2 g CALVERT CLIFFS - UNITS 1 & 2 B 3.7.12-4 Revisiontil

MFIVs B 3.7.15 8 3.7 PLANT SYSTEMS B 3.7.15 Po l Feedwater Isolation Valves (MFIVs)

BA$ES BACKGROUND The MFIVs isolate main feedwater (MFW) flow to the secondary side of the steam generators following a high energy line break (HELB). The consequences of HELBs occurring in the 4

main steam lines or in the MFW lines downstream of the MFIVs will be mitigated by their closure. Closure of the MFIVs effectively terminates the addition of feedwater to an affected steam generator, limiting the mass and energy reieaseforsteamlinebreaks(SLBs)/orFWLBsinside g7 containment upstream of the reverse flow check valve, and reducing the cooldown effects for SLBs.

The MFIVs isolate the non safety related portions from the safety related portion of the system. In the event of a secondary side pipe rupture inside containment upstream of gg the reverse flow check valve, the valves limit the quantity of high energy fluid that enters containment through the break.

One MFIV is located on each MFW line, outside, but close to, containment. The MFIVs are located so that AFW may be supplied to a steam generator following MFIV closure. The piping volume from the valve to the steam generator must be accounted for in calculating mass and energy releases.

The MFIVs close on receipt of a steam generator isolation signal (SGIS) generated by low steam generator pressure.

The SGIS also actuates the main steam isolation valves (MSIVs) to close. THE MFIVs may also be actuated manually.

In addition to the MFIVs reverse flow check valve inside containment is available to isolate the feedwater line penetrating containment, and to ensure that the consequences of events do not exceed the capacity of the containment heat removal systems.

CALVERT CLIFFS - UNITS 1 & 2 B 3.7.15-1 Revisionp' 12

Sp.< Mn 3.7. 9 3/4.7 PLANT 3Y3 tdt 3 *

(v Jpr ,{. .k. .Q SURVEILLANCE REQUIRDIDIT5 (Continued) " A J mW .4<.1,x c.r+ > 4 i 3. Verifying within 31 days after removal that a laboratory ~

ana1*sts of a npresentative carbon sample obtained from an adferber tray or from an adsorber test tray in accordan e with Regulatory Position C.6.b of Regulatory Guide 1.62 Revision 2. March 1978. demonstrates a removal efficiency of 2 90% for radioactive methyl todine when the sample is tested in accordance with ANSI N510-1975 (30*C 954 R.H.).

4. Vertfying a system flow rate of 2000 cfm + 10% during system operation when tested in accordance with XNSI N5101975.

d. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by:

Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained from an adsorber tray or from an adsorber test tray in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2. March 1978, demonstrates a removal efficiency of 2 90% for radioactive methyl todine when the sample is tested in accordance with ANSI N5101975 (30*C 95% R.H.).

subsequent to reinstalling the adsorber tray used for obtaining the carbon sample, the fliter train shall be demonstrated OPERABLE by also verifying that the charcoal adsorbers remove t 99% of a hal enated hydrocarbon refrigerant test gas when they are tested in- ace in accordance with Regulatory Positions C.5.a gulatory Guide 1.52. Revision 2. March 1978, while (and C.S.d ofoperating the ventilation system at a flow of 2000 cfm i 10

e. Atleastonceperhoonthsby F

1. ' Verifying that the pressure drop across the combined HEPA i filters and charcoal adsorber banks is < 4 inches Water ]

j Gauce wh

_ of innn :ile operating the ventilation system at a flow rate f f-4-- - - -

SR 3.7,6 3 K Vnifying that on p(Control Rocefhigh raffa

~thesystenfaut ncasiy switcnes nio a rectrculatio

. .u on Ith flow through de lk HEPA filters and arcoal A, f adsorber of . 6 s and that both the isolation valv in each inlet d and coemon exha duct, and the isol ion valve (nthe'toiletareaexhau duct. close.

M acLk ael.,I .c 6 lad a c A ,4.w A-CALVERT CLIFFS - UNIT 1 3/4 7-18 Amendment No. 202 l

_ - - .-. - . _ - __.-.- - .. .._ = - - -- - - . -_. _- - .. ,.

Speedw$'ul 3 7.9 i

P J

fee D;& & f s'J/J k $1/ ft'(

4

, . pLM1 SV$1En5 I'^ # #

SURVEILLMCE REQUIREMEllTS (Continued) 0* M" $ MI{%

f sit bA N j

/

f 4. Verify ng a system flow rate of 2000 cfm 10% duri operat on when tested in accordance with $1M510N75. system}g,j' ,

d. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by:

I Verifying within 31 days after removal that a laboratory analysts of a representative carbon sample obtained from an adsorber tray

. or from an adsorber test tray in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2. March 1978, demonstrates a removal efficiency of 2 90% for radioactive methyl lodine when the sample is tested in accordance with ANSI M510-1975 (30*C, 95% R.H.).

Subsequent to reinstalling the adsorber tray used for obtaining the carbon sample, the filter train shall be demonstrated OPERARLE by also verifying that the charcoal adsorbers remove 1 99% of a hal enated hydrocarbon refrigerant test gas when they are tested in- ace in accordance with Re ulato Positions C.S.a a

and C.S.d of R gulatory Guide 1.52. Revis on 2 rch 1978, while

( operating the venttistion system at a flow of 2000 cfm i 10%. j

\ '

e.

y At least once per 3 months bys"h -

' F 1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is < 4 inches Water

( Gau N of ge while 000 cfaoperating i 10%. the ventilation system at a flow rate /p Y. Verifying t a fs drol edahdi raatar 5 R3 74. 3 the syst e-ny - n m a rec reviou _3 I e

'si oper on with flow th h the HEPA filters and rcoal 1 4 adsor banks and that h of the isolation valv in each inle duct and connon e aust duct, and the isol J _n e inflet area exh st duct, closev -- onva]1ve'

~

.ze k e s l

.L A.

CALVERT CL!fFS - UNIT 2 3/4 7-18 heendment No. 163 l fAfc ( Jh b

DISCUSSION OF CHANGES SECTION 3.7.11 - SPENT FUEL POOL EXIIAUST VENTILATION SYSTEM ADMINISTRA' LIVE CIIANGES A.1 The proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change of intent, to be consistent with NUREG 1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users.

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

A.2 Current Technical Specification 3 9.12, Spent Fuel Pool Exhaust Ventilation System (SFPEVS), Action c exempts the provisions of Specifications 3.0.3 and 3.0.4.

Specification 3.0.3 requires the plant to shut down when a condition exists that is not covered by the LCO, or one in which an Action is not provided. Specification 3.0.4 exempts Mode changes if the LCO is not met unless ecAued operation is allowed by the Actions.

Improved Technical Specification 3.7.11 will not contain this exemption. The provision to exempt Specification 3.0.3 is not required because there is no condition of inoperability that is not encompassed by the Action, therefore LCO 3.0.3 would never be entered. The provisions to exempt Specification 3.0.4 are not required because upon completion of the Required Action, the plant will be outside the Mode of Applicability for the LCO. The deletion of requirements that do not apply is considered an administrative change. This change is consistent with NUREG-1432.

A.3 Improved Technical Specification SR 3.7.11.2 requires the performance of the required SFPEVS filter testing in accordance with the VFTP. The requirements for VFTP are outlined in ITS Section 5.0. Current Technical Specification 3.7.6.1 contains the actual testing requirements. This change moves these testing requirements from Section 3.7 to Section 5.0. The movement of requirements with the Technical Specifications constitutes an administrative change. This change is consistent with NUREG 1432.

IEQlNICAL CIIANGES - MORE RFSTRICTIVE M.1 Current Technical Specification LCO 3.9.12 requires the spent fuel pool ventilation system to be operable with one llEPA filter bank, two charcoal adsorber banks, and two exhaust fans. When one adsorber bank and/or one exhaust fan is inoperable, CTS 3.9.12 Action a requires the Operable exhaust fan to be placed in operation discharging through an Operable train of IIEPA filters and charcoal adsorbers. If this action is taken, fuel movement can continue for an indefinite period of time. No requirements exist to restore the inoperable exhaust fan or charcoal adsorber bank. Improved Techr.ical Specification LCO 3.7.11 will require the spent fuel pool exhaust ventilation system to be operable and in operation.

Operation will be required during the Mode of Applicability, even if both exhaust fans and charcoal adsorber banks are Operable. The Bases will also define "in operation" to be one exhaust fan in operation discharging through an Operable train of HEPA filters and one Operable charcoal adsorber bank. This proposed change is essentially more restrictive, since CALVERT CLIFFS - UNITS 1 & 2 3.7.11-1 Revision 12

DISCUSSION OF CHANGES SECTION 3.7.11 o SPENT FUEL POOL EXHAUST VENTILATION SYSTEM it will require the SFPEVS to be in operation during the Mode of Applicability even if both exhaust fans and chvcoal adsorber banks are in fact Operable. It is appropriate, because the spent fuel pool ventilttioh system is a system which is manually initiated. Rus, in the event of a fuel handling accident occurring during the movement of irradiated fuel assemblies in the auxiliary building, the system would only be initiated some time after the event. The delay in initiating the system could permit a radioactive release to the outside environment.

Thus, anytime irradiated fuel assemblies are being moved within the auxiliary building, the spent fuel pool ventilation system should be operable and in operation. This change is consistent with current practice, which requires the SFPEVS to be in operation when moving irradiated fuel assemblies in the auxiliary building. This requirement will provided additional assuranca of public health and safety.

To support thN change, it was necessary to revise CTS SR 4.9.12.a. Currently, this SR requires the spent feel pool ventilation system to be verified operable at least once per 31 days by initiating flow through the llEPA filter bank and both charcoal adsorber banks and verifying that each charcoal adsorber bank and each exhaust fan operates for at least li minutes. The revised LCO requires the spent fuel pool ventilation system to be in operation at all times during the conditio t of Applicability. Thus, operability of the system will continuously be confirmed. Instead of the performance check, an SR wish verifies the spent fuel pool ventilation system is in operation is required. Improved Technical Specification SR 3.7.11.1 will require the spent fuel pool ventilation system to be verified to be in operation at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This SR provides additional asaurance of public health and safety by ensuring that system operation is verified on a periodic basis. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate, because plant personnel will be focused on the fuel handling activities occurring in the auxiliary building. Thus, if anything were te occur which would result in t'.e cessation of the operation of the spent fuel pool ventilation system, it would be quickly identified.

TECIINICAL CllANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED DOCUMENTS

- LA.1 Not Used. l LA.2 Action a and b of CTS 3.9.12 require the suspension of all operations involving crane operation with loads over the storage pool. Since crane operation over the storage pool is not necessarily affected by the loss of the SFPEVS or its components, the requirements associated with the suspension of crane operation with loads over the storage pool are to be relocated to the UFSAR. The bounding design basis fuel handling accident assumes an irradiated fuel assembly is dropped and damaged. The movement of loads (loads other than fuel assemblies) is administratively controlled based on heavy loads analyses. The heavy loads analysis methodology and crane operation which dictate tbc controls are described in the UFSAR. Therefore, 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.

CALVERT CLIFFS - UNITS I & 2 3.7.11-2 Revision 12

DISCUSSION OF CilANGES SECTION 3.7.11 - SPENT FUEL POOL EXIIAUST VENTILATION SYSTEM i

LA.3 Not used.

TECIINICAL CllANGES - LESS RESTRICTIVE L.1 Not used.

L.2 Current Technical Specification 3.9.12 Applicability for the SFPEVS, is whenever irradiated fuel is in the storage pool, improved Technical Specification 3.7.11 Applicability is during movement ofirradiated fuel assemblies in the Auxiliary Building. This 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. This change is acceptable because the fuel handling accident assumes an irradiated fuel assembly is being moved in the spent fuel pool. The reduction of the Mode of Applicability is considered a less restrictive change.

This change is consistent with NUREG 1432. ,

L.3 Current Technical Spec.acation 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. This change decreases the Surveillance Frequency from 18 months to 24 months. The 24-month Surveillance frequency is suflicient to ensure that the SFPEVS can maintain a measurable negative pressure in the spent fuel pool area of the Auxiliary Building. After reviewing the previous ten years of Surveillance history, the SFPEVS has never failed to maintain a measurable negative pressure in the spent fuel pool area of the Auxiliary Building. The SFPEVS contains redundant electrical and mechanical components and is operated once per 31 days to verify operability. Therefore, per Generic Letter 91-04, the effect of this change on plant safety is small. Also, instrument drift will have no affect on the test. There is no instrumentation associated with this Technical Specification requirement. Decreasing Surveillance Frequencies constitutes a less restrictive change. This change is consistent with NUREG-1432 and the guidance in Generic Letter 91-04.

l l

CALVERT CLIFFS - UNITS I & 2 3.7.11-3 Revision !2

MSIVs

_ (C7S}

3.7 PLANT SYSTEMS 3.7.2 Mair Steam Isolation Valves (MSIVs)

(3.7,t.5) LC0 3.7.2 Two IVs shall be OPERABLE. '

i APPLICABILITY: MODE 1 MODES 2 and 3 except when all MSIVs are closedQ Qdp4ct13n(ed) {h ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 30,i.5- A. One MStV inoperable in A.1 Restore MSIV to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months kn a MODE 1. OPERABLE status.

' %s s)l B. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

/ssociatedCompletion Time of Condition A Ih not met.

M ;'g- C. ------- NOT E------- C.1 Close MSIV. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AW'g Separate Condition

"" entry is allowed for E each MSIV.

- - - - - - - - - - - - - - - - - - - - - C.2 Verify MSIV is Once per 7 days closed.

One or more MSIVs inoperable in MODE 2 or 3.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C M not met.

D.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months CEOG STS 3.7-5 Rev 1. 04/07/95

f /J 3.7)

SURVEILLANCE REQUIREMENTS (continued)

$URVEILLANCE FREQUENCY ggy SR 3.7 8

.2 Perform required . S filter testing in In accordance h

c4,4 accordance Program ("I'*))

Vin with ,#

ation Filter Testing i the 'Ym! Y $--

uh wT.ufr /

hl

- ( p fvt esf!" W K '

d.*7,Ll.c.2 3.7 3-Verffa tra actua or simulated actuation signal.

untos on an nths h

[5R 3.7.11. Verify one CREACS train an maintain a [18]mont

[ positive pressure of 2 0.125) inches water a STAGGE D on]

' gauge, relative to t adjacent [ ares] TEST $

during the emergent radiation state of the emergency mode of eration at a emergency g ventilation flow ate of s (3000) cfs.

w

- i l

CEOG STS 3.7-26 Rev 1, 04/07/95

DISCUSSION OF TECilNICAL SI'EC!!ICATION DEVIATIONS FROh! NUREG 1432 SECTION 3.7 - PLANT SYSTEMS Actions A.1 and A.2 are structured to retlect the cunent licensing bas: 2 requirement. This is necessary based on existing plant con 0guration.

24. NUREG 1432 Speci0 cation 3.7.2 Applicability contains a phrase that says, " . . . except when all MSIVs are closed and [de activated)." Current Technical Specincation 3.7.1.5 Applicability does not contain this phrase.1hc non bracketed portion of the phrase has been incorporated into ITS 3.7.2 Applicability, but the, "and (de activated]" portion has not been incorporated because it !s net an action that is consistent with the design of the MSIVs at Calvert Cliffs, tiracketed terms are intended to incorporate plant specinc infonnation, including deleting items tiot consistent with Calvert Cliffs design.1hus, the term is not included in ITS.

v CALVFRT CLIFFS UNITS 1 & 2 3.7-6 Revision 12

HFIVs Qand JNMYJ urpan va nHish

~

B 3.7.

b B 3.7 PLANT SYSTEMS d B 3.7.bain Feedwater Isolation Valves (MFIVs)aana WTvj @

cyg i

BASES BACKGROUND The MFIVs isolate main feedwater '

side of the steam generators follo(MFW) wing aflow hightoehergy the secondary Jine break (HELB). jclosure f tWMF ~~ ana de oypass 'vaWes>

leriiiliia ~ s Plow to b steam g ators,terminatingthe @

event of t orMFIVs feedwater ine breaks FWLBs) occurrinn u6 stream J The consequences of v occurrIna in t'e-

' main steam lines or in the MFW line@s downstream of the MFIVsQ will be mitigated by their closure. Closure of the MFIVs and h=hss v6nneffectively terminates the addition of feedwater to an affecte.d steam generator, limiting the mass @)

O g' and energy release for steam line breaks (SLBs) or FWLBs inside containmen and reducing the cooldown effects for SLBs. ,,,; . W u

( wpe cou esuk w The MFIVs N nass niver isol e t e nonsafety related portions from the safety related portion of the system. In @

( the event of a secondary side pipe rupture inside i containmentf the valves limit the quantity of high energy @

tluidJ ha ters -

conitinment through_,tAe,,brea ', una prov1dp T'pTessur oundary for theAtro11ed addl ^ of auxiliafy

[eedw @

r(AFW)totheindetloof One MFlV is located on eac FW line, outside, but close to, containment. The MFIVs are located (upttr2am or thcAF_W) kWM!t' tam-5MD so that AFW may be supplied to a steam generator following MFIV closure. The piping volume from the valve to the stean, generator must be accounted for in _

- iculating mutand energy _relealgsj. and retpied prior tje aching 1hegeamgeneratorAollowingeitheranSLBfr _ _ _

The MFIVs ind Whyanct-v1Rvey close on receipt of a @

A

" steamJisolation signal (MSM @

generator pressure (nrhiaw)nmnmenteressuya.enerated The by Gi (Utrey low also actuates the main steam isolation valves (MSIVs) to close. The MFIVs EWi b u.33 verves may also be actuated manually. In addition to the MFIVs ung. Muwa>> .vaives), 3 rtwnt - a e Clow heck valve inside containment is available to isolate the 3 feedwater line penetrating containment, and to ensure that -

the consequences of events do not exceed the capacity of the containment heat removal systems.

(continued)

CEOG STS --- B 3.7 Rev 1, 04/07/95

. ._ . . - _ - .. . -_. --- - -- =_ . . .- - ._ . . . - _ - .

- . _ . . _~ -.-. . . - - _ - - - . - ~__ - . _ __-- . -

CRt 83.74 @

SA$t$

$URVt!LtMCC SR 1. 7.' W.1 (continued piced CREVS kd4c) _

@ j REQUIREMENTS testing each Itrain sace every month provides an adequate 1

check on this system. @ lh !

l fMonthly etter operation dry out any mo ture accumul ed in the harcoal from h dity in tF am ent air. stems) -

with atfrs must be o rated for t 40 ontinuous h[ rs with the eaters one it . Systems with t heaters ne only be o ated tes to demonst ate the funct on of thal 3~ requency IsTased on the known Nsstem.] atril t avellable.y of the equipment, and the t train redundanfv Q' iher 1R 1.7. .f EtV5 is ThisSRveriflesthattherequired[tRt.testin$terTesting performed in accordati the[Veht tion Fi eda.s Pr ram (VITP) P. /The~ filter tests are in accordance of. wi Regulsiory Guide . The 't I es ing HEPA filter performa(Ref. 3).nce,charcoala[VFTP]' dsorber includesI i efficiency, minimum system flow rate, and the physical 4

properties of the activated charcoci (general use and following specific operations). Spectric test frequencies and additional information are discussed in detati in the Iku ied h,'Cohuhtd on) 3.,h3 Wem fregay. TW b **'y t D a dttVid '

1R psQ h lf 0 This SR verifies sach 5 train starts and anentan on an

"" 'pai or simuiat d aciv. tion iiana g 'e trequ J g g e,w c w cuvs a

,,e.w a aa., ..a . ern " " >r"""v ep4., an .a..i h hit &c,Rei I" 3^7'II"8

/

[. This SR vertfie the integrity of

, 4A e control room one sure and the ass inleakage rates e potentially conta ated (31 air. The c rol room positive ressure. with resp t to v potential contaminatedadja nt areas, is perio cally

/ tested verify proper func on of thr. CREACS. uring the rg cy radia ton state the emergency mod of (continued)

CEOG STS 8 7.7-59 Rev 1, 04/07/95 ,

.s

%- =

j B3 h MSES SURVElltANCE b A 1.7.11.4 (continued)

RLQUIREMENTS o pressurire the contro operation,1th/CREAC$isdesign roon k 0. inches water ga positive pressure with respect [to d;acent areas in er to prevent unfilter i W@

inleakap The CREAC$ is de pned to maintain this p itive Pressur with one train at n eastgenc;r ventilation ow rate [3000)cfs. The equency of 18 months a

$T (D TEST BA$l$ is onsistentwithtn)e ce to ded in NUREG- Section 6.4 (Ref. 4)guld .

R[f[RENCES 1.h5AR,Sectton

2. h $AR, Chapter M 9 hh

3. Reguintory Guide 1.12 (Rev. 2).

(4. / NURIG 0800,4$ citen 6.4 )(ev. 2. July 1pQ h

C[0C STS B 3.7-60 Rev 1. 04/07/95

~ , _ + #-. __y - y * -w -ww 9--M4W

[CC$ FR 83.7 10 h

bhUI O!It hCVW b !Of, AC710N$ .f (tontinued)

If the [CCS PREAr.$ (Mlb cannot be restored to OP[RA8L[

status within the associated Completion T1

@ (D' be in a MODE in which the LC0 does not apply., the unit must To achieve this status, the unit must be placed in at least MOD [ 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion limes are reasonable, based on operating experience

-9ver cond ltionsinanorderlymannerandwithoutto reach the required unit challenging unit systems.

$URV[lLLANCE 1R 3.7 1 R[QUIREMENi$ @

- Standb systems should be checked periodically to ensure g g3 that t ey function properly. Since the environment and n

ratino conditions on this system are not severe, 4 ih f

es nce a month provides an adequate check on thi es. ] Monthly Tesir eversiwns ury put any

[achtu tnat may have accu ated in the charcoal huel y in the ambient a 71 fees rffagy op ated for 2 10 conti ous hours with the he rs had. $ystems W hout hanters naad ani (Systemswithhette must be j

h

.s fesked by _mMiss Mdemonstpefe the fuoffinn'h fMcNgU g gam a ,Py h eauency is based on the known. ral'ahility of t.oDerattd1[

_o Lkfiaswied) equip' .tk and thytwo trafn recamffRy avplabi).

s, y

.A 03 of s f.f l- ( ( gM This $R verifles that the requir rdance wt e

[CCS s in is vattia on F lter festing Z

[8I ^ herformedinac)The TCC$

che/o4/ filter tes are in

, rogram(VFTP))Rogulatory ordance_wity ide 1.52 Ref 9' ad orberVFT A j584g4 foR,h /4 includes testing HLPA filter perfonnanc(e, . The ch.rcoal p;ng pkg , efficiency, minimum system flow rate and the physical i i4 roperties of the activated charcoal,(general ute and

'p ollowing specific operations and additional information are). Specific test frequencies VFTP .

discussed in detail in the (esntinued)

CC0G STS B 3.7-68 Rev 1. 04/07/95

i l

l ECCS PRE sn B 3.7.4 Q91 l

1 BASES l

$URVEILLANCE (SR 3.7.13g REQUIREl4ENTS (continued) This $R vert s that each [CC$ PRI $ train starts %

o erstes o 3 actual or simulate actuation signa The mon frecuency is consist t with that spec ied in

[ }la R u yGuide1.52(Ref.4}__

[1R 3.7.13.4 - --

This $R verifies the integri of the ECCS pump room enclosure. The ability of e ECCS pump room to maintain a i negative pressure, with r pect to potentially uncontaminated adjacent is periodically tested to verify proper function eas,ECCS PREAC$. During the st the accident mode of opera ton, the ECCS PREAC$ is designe to maintain a slight ne tive pressure in the ECC$ pump om with respect to adj ont areas to prevent unfiltered LEAKAGE. The ECC$ REACS is designed to maintain t s negative pressure t a flow rate of 5 ECCS pump room, he Frequency of [181[ months nsistent is20,000) cfm see the with the guidan e provided in the NUREG-0800, Se ton 6.5.1 (Ref. 6).

l This test i conducted with the tests for fil r penetratio thus an [18] month frequency, a STAGGERED Iscons,istentwithotherfiltrat n SRs.

dTESTBASI 1R .13.5 b

Op rating the [CCS PREACS filter bypas damper is necessary ensure that the system functions p perly. The PERAtiLITY of the bypass damper is erified if it can be closed. An m consistent with that ence 4.

j_s,ecifiedin(8le,onthFrequencyi _g REFERENCES 1.hSAR,Section$2.8)I @ (3 casAR, Seewlea A

($3 F$AR, Section(Qk,_9v7 hO l Q @ Pegulatory Gulde'l.$2 (Rev. 2).

(continued)

CE0G ST$ B 3.7-69 Rev1,04/07/95 1

l 1

f

, B L., @ @

h)%AT 110 bWs, A.1 o. A A A BA$[$ e -

(@J Qll ACTIONS .) f 1 and f.2 (conti ed) 1 If the systes not placed in operation this tion Net i a , 0P EM6LE, ',f Pt 6 requires sus sionoffuelmovement,whlch ecludes a fuel ira % or A ccan. opera n Ue"No"'a'safd'N;itidd"''" '""""h ,k

$f966 Ar.<j y op % .

v4(e r L Whends tsein of tht J4Ks aram rably during movement 1 ,L .-

of Irradiated fuel assemeltes in the Gmty butiding, action l aust be taken to place th unit in a cTndition in which the LCO does not apply. This Ives inmediately s pending movement of irr fuel assemblies in the building. This does no lude the movement of fuel 2 A g r,, ,y to a safe position. ]/,

$URVEILLANCE SR 3.7. '

1 REQUIREMENTS .> .

f$tandbysystemss Id be checked todically to ensur 1

}

that they functi properly. As t environment and real operating condi ons on this syst are not severe, t sting 1- '

each traln onc every month provi es an adequate che k on this sy.**pa. nthly heater ope ation dries out a

y moisture acc ulated in the che coal from humidit in the INSfKl" ambient air [systemswithh ters must be oper ed for I O 3 '7.ll- O h to cent uous hours with t heaters energize . Systems without stars need only operated ford 15 inutes to

,dee6att ate.the function the systes.1 .The I day frequ cy is based on th known reliability f the equipment and a two train redun ncy available.

1R 3.7. 2 gg., h This SR verifie t performance of filter testing in a accordance wi)h thet{ Ventilation Filter Testing Program %) ,

(VFTP f r ihe filter t sts are in accordance wit the . ..%

Regul) a tory Cut e .62 (Ref. .- Thet .( l HEPA filter performance, cha coal ads orber(VFTPl.

efficiency, includes testing minimum system flow rate, d the physical properties of the activated charcoal (genera use and following, specific (continue

CE06 STS B 3.7-74 Rev 1, 04/07/95

- _ _ _ . _ _ _ _ . . . _ _ _ _ _ _ _ _ _ . __.__._._.m_. _ . _ _ _ . _ _ _ . . . _ _ _ _ _ _ . _ _ _ . _ . . _ _ _ . _ _ _

frv.5 8 3.7.

BA5($ (continued)

Rtf(R[NCES h M ._$ectips([6.p d )] @ ;

M SAR. Section h ,

dharlyla, S.ctseaQi#e h l % J 91 story Guide 1.25. h

& CF&)

)

&(

$ h Regeistery Guide 1.52 JG-999hjelt. ion 6.l.l[Jul g h t

CCOG $i5 3 3.7 76 Rev 1. 04/07/95 ,

=.

, . , . , -, . - , , . . .,_..,.,.,,m. , . .

B

{

SA5[$ '

$URVIILLANCE R[QUIREM(NTS 1R 3.7. (continued) b I Month) etter operati dries out any no ure that 6\

' "/

i have the cumulated in tent air.

charcoal as a r stems with heat it of must be in sted fo W

1 Cf1 i 2 0 continuous urs with the hea s eneret ad ~5y W e,i""

as

[

rA4-4 A' Trequenc,y is based 5Ghe j f f "J & 1Til known rn 0f!':M,2Kn';ufg*

and the two train redundancy available.

Sy@M h McCM/off00**) st 3.7.Q2 1L 2 V g, ,4

%& gagg '

1 This $R veriftes t !perfomance of PRT filter testing in accordance with t 1 Ventilation filter Testing Program den hA Ah (ddVhoa(

(Vf1P Refere)n}fce 4. The P filter tests are in accordance with TheedVfTP}2 includes testing the the HCPA filter, charcoal adsorber efficiency, performance of k, h gg#p gU) '

system flow rate, and the physical properties of the minimum activated charcoal (general use and following specific 4t/j Vcrap7% operations). Specific test frequencies and additibnal I de s g infomation are discussed in detail in the4VfTPjt,p <'

et Na / NU , .)

Of 't }k%

2/foilA/ # h I

^^- #/-- ' This $R verifies that each Pp S train tarts and oneratet d g, ,,g q n s 1 a p r ,_. g

7't me e fetpfn,7.Tku [ ""*sR 3.7.15.4 ~

I F,ep.3 t 4p le 4. f This sR veriftes e integrity of the penetration r i

' enclosure. The 11ty of the penetration room t intain

( M T h NlE 6 is '

negative press e,'with respect to potentially uncontaminat adjacent areas, is periodically ested to Ca(ant of d a d.% 0 ad verify pro r function of the PREAC5. Durin the post accident de of operation PREAC5 is dest d to maintain a cyeraIt'nq o an u%l slight 1 negative pressure,at a flow rate fg(3000)cfmin J the p etration room with respect to ad cent areas to

@ Su.nddtf Coda lnnai pr4v t unfiltered LEAKAGE. The free cyof(16]monthsis to tstent with the in NURCG-0800 L'g*4*ti gpng. ,,,,, 5 tion 6.6.1 (Ref. guidance ). provid (continued)

CIOG ST$ 8 3.7-80 Rev 1, 04/07/95

l

'lr j

Basts

(

Rtr1RENC[$ 3.hSAR,Sectten C l

/h 4 - Repu1 story sute 1.5 4,

( NIOLIQNS A bf @ b r. kh s % ts p , Wlon.M.13 'h i

i 1

A a

4 CEOG STS B 3.7-82 Rev 1. 04/07/95'

.,_-,,y_. . . , . _ _ .- . .. . . . .

DISCUSSION Ol' HASES DEVIATIONS FROM NUREGol43i SECTION 3.7 o PLANT SYSTEMS l

PLANT SPECIFIC CllANGES j

1. nese changes incorporate Calvert Cliffs-specific information into brackets. Dracketed information located throughout NUREG 1432 will be replaced with the specific Calvert Cliffs requirements. This change also includes deleting bracketed items when it is not consistent with ,

the Calvert Cliffs design. l

2. The change to the non bracketed system name, number of systems / components, terminology, or value was changed to be consisten' with Calvert Clifts specific system name, nurr.ber of systems / components, terminology, or values. His change also includes any numbering changes due to the addition or deletion of Speci0 cations, Actions, or Surveillance Requirements (SRs).

3. This change either adds information to or deletes information from the flases to make it more understandable, or to conform to Calvert Cliffs' design or safety analyses.

4. This addition, deletion, or modification to references, or the changing of reference numbers, was performed to ensure that the references are applicable to Calvert Cliffs, and to ensure consistency between references in the text and the reference section.

5. NUREG 1432 Section 3.7.19 Dases (Secondary Specific Activity) in the Background rection contains a paragraph which contains a thyroid dose for a person at the exclusion area boundary, should the main steam safety valves open for two hours following a trip from full power, if the secondary activity level were at the Tecnnical Specification limit. nc Calvert Cliffs improved Technical Specifications (ITS) liases for 3.7.14 (Secondary Specific Activity) will not contain this requirement because this number is not analyzed fer Calvert Cliffs. His change is consistent with the current Calvert Cliffs accident analysis.

6. Calvert Cliffs has an Updated Final Safety Analysis deport; therefore, "FSAR" will be changed to "UFSAR" throughout the ITS Bases.

7. This change to the flases was made to conform with changes made to the Specification.

8. NUREG 1432 Section 3.7.7 Bases (Component Cooling System) in the Applicable Safety Analyses section contains a statement that the analysis assumes that a maximum saltwater temperature of 76*F occurs simultaneously with the maximum heat loads on the system. The Calvert Cliffs ITS will contain the statement that the analysis assumes that a ma4imum Chesapeake Hay water temperature occurs simultaneously with the maximum heat loads on the system. This change was made consistent with the Calvert Cliffs analysis, which assumes various temperatures depending on the time of year. These numbers can also be found in the Updated Final Safety Analysis Report.

9. NUREG 1432 0 3.7.2 SR 3.7.2.1 contains verbiage that the main steam isolation valves (MSIVs) should not be tested at power. This verbiage has been deleted in Calvert Cliffs ITS B 3.7.2 SR 3.7.2.1 because Calvert Cliff; perfonns a quarterly p.rtial stroke test on the MSIVs at power. This is consistent with the Calvert Cliffs current operating practice to perform ,

a partial stroke test on the MSIVs at power.

CALVERT CLIFFS UNITS 1 & 2 3.7 1 Revision 12

DISCUSSION OF HASES DEVIATIONS FROM NUREG 1432 SECTION 3.7 . PLANT SYSTEMS _

t

10. These additions or changes to NUREO 1432 are based on details moved out of the Current t Technical Speci0 cations . %ese details were moved into the Bases to capture the Calvert Cliffs :

current licensing basis, i

11. At Calvert Cliffs, the MSIVs are not containment isolation valves. Hus, they are not local leakage rate tested in accordance with 10 CFR 50, Appendix J. He containment is a barrier which limits the leakage of radioactive materials to the environment so that acceptal adiation limits are not exceeded in the event of an accident. For the secondary side o te steam generators, the barriers which provide protection against leakage of containment atnio , me to the environment following a loss of coolant accident will be the inside of the steam generator tubes and the outside of all lines connected to the steam generator shell side. These barriers serve the same ftmetion as the containment liner, and, as such, they are part of the containment following the accident. %e lines which emanate from the steam generator shell side will not be damaged during a LOCA, as the design is at least equivalent to or better than, the containment liner with regard to quality assurance, pressure, temperature, testing, and missile protecticn.

Also, in the event an accident were to occur when the plant was operating with steam generator tube leaks, an effective barrier would still be maintained. Following a LOCA, the RCS is depressurized and the higher shcIl side pressure prevents leakage of fission products through the steam generator tubes. Additionally, as the accident progresses, additional assurance that the barrier will be maintained is provided by head of water above the tube bundle. The total plant

release associated with a L JCA, including steam side leakage, is within the criteria of 10 CFR part 100.

12. NUREG 1432 Ilases Section SRs 3.7.3 and 3.7.8.3 state that the 24 month Surveillance interval is based on the need to perform the Surveillance under conditions that apply during a unit outage, and the potential for transients if the Surveillance is performed at power. Calvert Cliffs ITS Ilases Section SRs 3.7.3.5 and 3.7.6.3 will not contain the statement because Calvert Cliffs wrrently satisfies these SRs during the perfonnance of the quarterly Instrumentation Channel Functional Tests.

13. Not used. l

14. Calvert Cliffs ITS 3.7.3 Dases, Action F.1, revised NUEG 1432 3.7.5 Dases, Action D.l. to make the Action match the Action Note, and to not preclude a plant shutdown if deemed appropriate.

The clUllEO speci0es actions to be taken when there are no Operable auxiliary feedwater trains.

%c Note to Action D suspends all Technical Speci0 cation required shutdowns. The Bases for the Note states that not only are Technical Speci0 cation required shutdowns suspended, but no power changes or shutdown should be made. This is inconsistent wite the Note, and may preclude the plant being put in a safe condition if equipment is functional but not Operable. The added words clarify that a plant shutdown or power change may be made if it is the most prudent action. This change is necessary to ensure shat it is clear to an operator that plant power changes or a shutdown may be made ifit is the most safe course of action.

15. Calvert Cliffs ITS 3.7.3 Dases, Action F.1, revised NUREG 1412 3.7.5 Dases, Action D.1, to make it clear that if other Actions or plant conditions require entry into LCO 3.0.3, that an LCO 3.0.3 entry !s made, but the required Actions do not have to be taken. The NUREG specines actions to be taken when there are no Operable auxiliary feedwater trains. The Note to Action D suspends all Technical Specification-required shutdowns, including LCO 3.0.3. The Note states tht_t LCO 3.0.3 is suspended, but the 13ases state that LCO 3.0.3 is not applicable.

CALVERT CLIFFS - UNITS 1 & 2 3.7 2 Revision 12

DISCUSSION OF llASES DEVIATIONS FROM NUREG.1432

)

SECTION 3.7 PLANT fWSTEMS 1his is incorrect. '1he difTerences are signincant in terms of logging, reportability, and actions to be taken should Condition D be exited. This change corrects the error.

16. NUREG 1432 3.7.1 Dases, SR 3.7.1.1 Section, states that Table 3.7.12 (Main Steam Safety Valve Lift Scttings) allows a i 3% setpoint tolerance for Operability; however, the valves are reset to 1 1% during the Surveillance to allow for drin. Calvert Cliffs ITS 3.7.1. Ilases, SR 3.7.1.1 Section, states that Table 3.7.12 dennes the lin setting range for each MSSV for OPERADil ITY; however, the valves are reset to i 1% during the Surveillance to allow for drin.

This chsnge was made to be consistent with changes made to Table 3.7.12 which will not contain the i 3% setpoint tolerance because Calvert Cliffs' current licensing basis allows setpoint tolerances from 3% to 6%. A phrase is added to the Ilases stating that the ASME Code specines the as found lift acceptance range.1his change is consistent with the Calvert Cliffs current licens!ng basis.

17. Not used.

18. Ilases statements which refer to the Code of Federal Regulations or the Standard Review Plan as the source of offsite dose or other accident analysis acceptance criteria are changed to reference the Calvert Cliffs Updated Final Safety Analysis Report Plant specific acceptance criteria for Calvert Cliffs are approved by the NRC and stated in the UFSAR. The Code of Federal Regulations contains the maximum allowable limits, not the plant specinc limits which are typically more conservative. Calvert Cliffs is not committed to the Standard Review Plan and, therefore, the current licensing basis may not be the Standard Review Plan values.

19. Typographical / grammatical error corrected.

20. A clari0ce' ion is added to the llases of LCO 3.7.3 that clarines the application of a CTS allowance. The CTS allows AFW trains required for operability to be taken out of service under administrative control for the performance cf periodic testing. This allowance is retained in ITS 3.7.3 as an LCO note. While periodic tests clearly include surveillance tests, the Dases also clarines that this allowance may be used for post mainten mce tests and other required testing that is similar to periodic surveillance tests. This clarincation is consistent with current plant application of this allowance, the original license amendment which implemented the allowance, and plant design which makes the allowance necessary,

21. The requirement in the NUREG Dases for SR 3.7.5.5 to demonstrate a Dow and pressure to verify the CST to AFW Gow path is deleted. Current Technical Speci0 cation 4.7.1.2.b does not require a specine flow and pressure to be demonstrated as part of this surveillance (retained as ITS SR 3.7.3.7). A separate surveillance ITS SR 3.7.3.6 demonstrates the Dow performance of the AFW pumps, consistent with CTS 4.7.1.2.c.2. The SR is only sequired to demonstrate that the now path is operable and any amount of How would demonstrate this requirement. The addition of specinc How requirements to this SR would be an unnecessary more restrictive change to plant operations.

22. NUREG Dases for SR 3.7.11.3 explain that the surveillance verines each CREACS train starts and operates on an actual or simulated actuation signal, and that the Frequency of[18] months is consistent with Reference 3 (Regulatory Guide 1.52 (Rev. 2)). Regulatory Guide 1.52 (Rev. 2) does not specify a frequency for testing involving operation of systems. The Frequency for tests I

CALVERT CLIFFS - UNITS I & 2 3.7-3 Revision 12

IllSCUSSION OF IMSES I)EVIATIONS FROM NUREG 1432 NEcilON 3.7 o PLANT SYSTEMS l

\

in Regulatory Guide 1.52 (Rev. 2) is for lil!PA filter and carbon adsorber testing. A plant !

5pecific description is substituted for the Regulatory Guide 1.52 (Rev. 2) Justification. l I

r.

CALVERT CLIFFS UN)TS -1 & 2 - 3.7-4 Revision 12 -

Page Replacement lustructions ,

VOLUME 12 Section 3.8 Note: Underlined titles indicate labs in volumes. Regarding CTS markups: Pages are referenced by citing the un:t number as urlias the specylcation number locatedin the upper righi-hand corner ofthe CISpage.

Key:

DOC = UlscussIon ofChanges DOD = Discussion Gf11chwal.\wcification Deviation or Discussion OfBases Deviation REMOVE INSERT -

Overview of Channes ;

No Pages Changed.

IIE No Pages Changed.

ITS Bases ,

No Pages Changed.

CTS Markun & Discussion of ChaBatt DOC 3.8.6 2 NSHCfindingt No Pages Clenged.

ISTS Markun & Justification No Pages Changed.

ISTS Bases Markun & Justification No Pages Changed.

1 1

- Note:Italici:cdentries indicate uneven exchanges. Pleasefollowpage replacement trutructions carefully.

DISCUSSION OF CHANGES SECTION 3.R.6 - HATTERY CELL PARAMETERS temperature within the required limit is provided in ITS 3.8.6, and ITS SR 3.',.6.3 is added to !

verify the average temperature of representative cells is within required limits on a 92 day Frequency. His change represents an additional restriction on plant operation necessary to ,

help ensure the batteries are maintained OPERAI1LE. I M.2 Current Technical Specification 4.8.2.3.2.a.3 and 4.8.2.3.2.b.1 require battery cell voltage to be 2 2.10 volts. Improved Technical Specification Table 3.8.61 Category A and il limits require battery cell voltage to be 2 2.13 volts. This change ensures that overall battery voltage is satisfactory and is consistent with the recommendations ofIEEE.450 which states that prolonged operation with cells < 2.13 volts en reduce the life expectancy of the cells.

This change represents an additional restriction on plant operation necessary to help ensure battery OPERA 131LITY is maintained.

ILGINICAL CilANGES - RELOCATIONS None IECilNICAL GIANGES . MOV" MENT OF INFORMATION TO LICENSEE CONTROI I ED 1)DEUMENTS LA.I Not used.

'ECIINICAL Cil4NGES . I ESS RESTRICTIVE L1 Current Technical Specifications 3.8.2.3 and 3.8.2.4 20 not contain specific Actions when battery cell parameters are not within hmits, except for CTS 3.8.2.3 Action d, which allows l 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore low cell voltage. Current Technical Specifications require the associated battery to be declared inoperable immediately, or a plant shutdown initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , as applicable, when a battery cell parameter is not within limits, or when voltage decreases more thai 0.10 Volts from the previous performance test. Improved Technical Specifica :s will provide Actions which allow additional time to restore the battery cell parametei. ,,crenced in ITS LCO 3.8.6, Action A. Specifically,ITS 3.8.6 Required Action A.1 requires the verification that pilot cell electrolyte level and float voltage meet Table 3.8.61 Category C limits within I hour,ITS Required Action A.2 requires verification that battery cell parameters meet Tath 3.8.6-1 Category C limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and once per 7 days thereafter, and ITS Required Action A.3 requires the battery to be restored to within Table 3.8.61 Category A and il limits within 31 days. Improved Technical Specification Action B, when the Required Actions and associated Completion Times cannot be met or when there is one or more batteries with battery cell parameters not within Category C limits, requires the associated battery to be declared laoperable immediately and its associated Actions entered. The addition of Action A is acceptable because, although the battery may be degraded when required parameters are not within Cctegory A or !! limits, there is still sufficient capacity to perform the intended function since the Category C limits are met. The category C limits are selected to provide assurance the battery is still capable of performing its intended function. De verification of pilot cell electrolyte level and ICV withh one hour providen a quick check of the status of the remainder of the battery cells.

One hour provides the time to inspect the electrolyte level and to confirm the ICV of the pilot cells. The verification of battery cell parameters within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and once per 7 days thereafter, will ensure that during the time needed to restore the battery parameters the CALYSRT CLIFFS UNITS 1 & 2 3.8.6 2 Revision 12 -

i Pcge Replacement I:st;uctions .

t VOLUME 15 Section 5.0 Note: Underfirwd titles indicate labs in volumes. Regarding CIS markups: Pages are referenced by citing the unit ;

number as wil as the spec {fication number locatcJ in the upper right-hand corner cfthe CTSpage.

Kn.:

DOC = Qiscussion ofChanges DOD = Olscussion Qf1&hnicalSpecification Deviation or Discussion {YBates Deviation RI'. MOVE INSERT Qurtlew of Channes No Pages Changed.

LIS t 5.0.ll $.0 Il 5.0 24 5.0 24

!' ITS Bases ;

No l' ages Changed.

CTS Markun & Qiscussion of Channes No Pages Changed.

NSilC Findians "

No Pages Changed.

ISTS Markun & Jnstification 5.0 10 $.0-10 5.0 13 $.0-13 DOD $.0-6 DOD 5.0-6 ISTS Bases Markun & Justincation No Pages Changed.

Note: llalicitedentries indicate uneven exchanges. Pleasefollowpage replacement instructions carefully.

f Programs and Manuals 5.5 5.5 Programs and Manuals J. Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary, to be limited to: l'

1. During any calendar quarter: Less than or equal to 10 mrads for gama radiation, and less than or equal to

'O mrads for beta radiation; and

.,uring any calendar years Less than or equal to 20 mrads for gama radiation, and less than or equal to 40 mrads for beta radiation;

k. Limitations on the annual and quarterly doses to a member of the public from Iodine-131 and all radionuclides in a It.

particulate form with half-lives greater than 0 days, in gaseous effluents released from each unit to areas beyond the n site boundary, to be limited:

1. During any calendar qu a .er: Less than or equal to 15 mrems to any organ:

2. During any calendar year: Less than or equal to 30 mrems to any organ; and

3. Less than 0.1% of the limits of 5.5.4.k(1) and (2) as a result of burning-contaminated oil; and

1. Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity, and to radiation from uranium fuel cycle sources to be limited to less than or equal to 25 mrems to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems.

5.5.5 Component Cvelic or Transient limit This program provides controls to track the UFSAR, Section 4.1 _ 3 cyclic and transient occurrences to ensure that components are maintained within the design limits.

- CALVERT CLIFFS - UNITS 1 & 2' 5.0-11 Revision $lt.~

i PrograQs and Manuals -

5.5 ,

5.5 Programs and Manuals d

Revision 2, and ANSI N510-1975, at the system flowrate ,

specified as follows i 10%:

ESF Ventilation System Flowrate CREVS 2,000 cfm ECCS PREFS 3,000 cfm PREVS 2,000 cfm SFP Ventilation System 32,000 cfm t IRS 20,000 cfm

c. Demonstrate for each of the ESF systems within 31 days after h t

il removal that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2 shows the methyl iodide telemental iodine for the IRS) penetration less than or equal to the value specified below when tested in accordance with ANSI N510-1975 at a temperature of s 30'C (130'C for the IRS) and greater than or equal to the relative humidity specified as follows:

ESF Ventilation System Penetrations Bjj CREVS 10% 95%

ECCS PREFS 10% 95%

PREVS 10% 95%

SFP Ventilation System 10% 95%

IRS 5% 95%

d. For each of the ESF systems, demonstrate the pressure drop '

across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, CALVERT CLIFFS - UNITS 1 & 2 5.0-24 Revisionfil

, ~ , - - , a- , - ,,,-., ,n,an <

Programs and Manuals 5.5 (c'15) 5.5 Programs and Manuals 5.5.4 Ruincitre tffluent controls Prooran (continued)

h. Limitations on the annual and quarterly air doses igs from noble gases released in gaseous of g

4%.h C

4"i>Sw2A6ga"%

gy'9 e

Limitations on the annual and pd the pubile*from iodine-131,0 a oses to a member of '

at- and all

p\ radionuclides in particulate form w s > 8 days

<M. / in gaseous effluents released free each unit to areas bevond y gtr # "

the site bourtdur gonjernina to W Ui su. Annendix I: Aff g, g,4, g t+'. E. TGle?1

([5[f Limitations 1htMTfrMrd)ose or dose coenitment to any member of the pubite due to releases of radioactivity and to radiation rps ura3 ele 6huina wtr2 sin- (T) v

<~. . J-(g3y. #, i;na,1umJeg, j % in m..sourcesj(tr.;,7~c iga m .

m..>.

o E , 6. iJu,,,

, .u ,,,. .,,,, ~g , ,y, a ,4 o, u ,, . . A L a. . . . Q

$rev 5.5.5 f amoonent evelic or TrariiTeiitTimt f s4 ff" *1 Thisprogramprovidescontrolstotrackthe(SARSection.ld cyclic and transient occurrences to ensare that components are

~3 maintained within the design 11mits.

5.5.6

[PPre4 tee **edConcrete_ContainmentTendonSurveillanceProcram]

This program provides controls for monitoring any tendon

[3,s.1,(,\ degradation in pre-stressed concrete containments, including

/ effectiveness of its corrosion protection medium, to ensure 9 containment structural integrity. The program shall include 1

b.Tseline measurements prior to initial operations. The Tendon '

A M U/

S'rve111ance Program, inspection fre criteria shall be in accordance wittkvencies, Regulatory and Guide acceptance 1.35 Revision . .

< 9 n.

The prov ion of R 3.0.2 and SR 3.0.3 are applicable to the lendon Surveillance Program inspection frequencies.

5.5.7 Reactor Coolant Pumo Fivvheet Insoection Prooram This program shall provide for the inspection of each reactor (4.4.103' coolant pump flywheel per the recomendations of regulatory position c.4.b of Regulatory Guide 1.14 Revision 1. August 1975.

(continued)

CEOG STS 5.0-10 Rev 1, 04/07/95

I ProgramsandMansj 1 i

(c'f3) g,$ Programs and k nuals

\

f

) 5,$.11 ilentilation filter fastina Proaram (Elf,1 (continued) ~

3 g,

/ .7. (.. ). c. 2.

N510-1989 A{i 105}P, at the systes flowrote specified as follows b*a /

\ 4.1, s.1. t C,5,e aa& C. E j g c

g4,3,3, ,, 6, g

' ESF Ventilation Systes Flowrate

\4.'M t A L.,se .c d4,,.e ,g,g 'i7> . @ ^

' U

b L\ -

t , bm. na g

N

Ih* b ' ' f 1 .[ '1,o. p . "

4 er.t.z. "; <- Rt LRS

.G=*** 1

~

LLm ' L';.

a,wcP \

f b.

.h f, J.I C- k 8 't.e Demons ate for each v. '.he ESF systems that sti inp1 est 4 a. r, . f. ' .

of the charco adsorbei hows a penetration a s te.

bypass when te4 4 in accordance wit Q,)

4 'l 6 'd egulatory Guide 1.5 , Revision 2 and ASMC N510-1 at t e systen 416b flowrote specified as follows"fi 105]1 ,g

{,#'.I' t$F Ventilation System Flowr

4.e b f %sgs "": ^ N, , , ate [ g

' 4.6 s.n 6d -

seu m r.4F's 4, g,,g,, i .e (pere, .

1.88' * /*

7,oa < /-

~~le I~~

~~--- pp~~

~~"'~~''~~~

~~i.1.~~

' ' ' ' ' ~ '

~~sr1~~

~~~~"~~

G

~~<4' '"~'~~

~~' ~~~

.v.itc/ 7/PI 5% 13 'f . ,

~~Lf, {,3, f 0 -~~
~~\e Qk *n-_ ,_c&~~
~
q,G 3. V h
~~(continued)~~
CEOG STS 5.0-13 Rev1,04/07/95 d
-..%,= . ~ - - , -,m..
,. . ,, ..,,-,,~..e..w y - , . . - -.~m-- u--.+o, ._,..e..- . _ - - . . . , . _ _ - - - _ . - - . _ . - - - - - -- -
DISCUSSION OF TECilNICAL SI'ECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 5.0 - ADMINISTRATIVE CONTROLS -
The oxygen concentrations in these systems are monitored and maintained within limits to avoid a hydrogen explosion. 'Iherefore, hydrogen concentration will not be monitored as part of the Explosive Gas and Storage Tank Radioactivity Monitoring Program.
38. 'the change to the non bracketed system name, number of systems / components, terminology, or value was changed to be consistent with Calvert Cliffs specinc system name, number of l systems / components, terminology, or values.
39. This change incorporates the current Calvert Clifts requirement to verify laboratory tests of charcoal adsorber samples be in accordance vith speciDed requirements within 31 days aller removal. Improved Technical Speci0 cations to not require the tests be performed within 31 days aller removal. This requirement is con *%ent with the Calve:1 Cliffs current licensing basis.
40. This change incorporates the current Can 'ert Cil is requirement for radionuclides specined in the litnits.tions on the annual and quarterly c nes to 4 member of the public in that gaseous effluents do not include lodine 133 or tritium. ';;.. .cquirement is consistent with the Calvert Clifts current licensing basis.
CAINLRT CLIFFS . UNITS I & 2 5.0-6 Revision 12
_ _ - _ _ - _ _ _ _ - _ - _ - _ - _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _

ML20199J528

Text

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