ML20210T863

Forwards Response to 970529 RAI Re Section 3.4 of Application to Convert to Improved TS & Rev 5 to Original License Amend Application

ML20210T863
Person / Time
Site:	Calvert Cliffs
Issue date:	09/10/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210T868	List: ML20210T863 ML20210T870
References
TAC-M97363, TAC-M97364, NUDOCS 9709160162
Download: ML20210T863 (40)

Text

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lis.Itimore C,as and Electric Company Vice President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 2W.c 7 410 495-4455 September 10,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 Revision 5 to the License Amendment Request to Convert to the Improved Technical Snecifications (TAC Nos. M97363 and M973641 i

REFERENCE:

(a)

Letter from A. W. Dromerick (NRC) to C. H. Cruse (BGE), dated May 29, 1997, Requeo for Additional Information Regarding the Technical Specification Change Request to Convert to the Improved Technical Specifications (TAC Nos. M97363 and M97364)

The referenced letter transmitted questions regarding Section 3.4 of Baltimore Gas and Electric Company's application to convert to the Improved Standard Technical Specifications.

The responses for Section 3.4 sre provided in Attachment 1 of this letter. Also attached to this letter is Revision 5 to the original license amendment application. These changes result from the responses

_ provided in Attachment 1, as well as other c'nanges identified by plant personnel. Changes to the No Significant Hazards Considerations discussions are included where appropriate.

To assist in reviewing this revision, a table describing each of the changes is provided (Attachment 2).

All of the material for each change is grouped by change in Attachment (3). Attachment (4) provides the revision by Impicved 'lechnical Specification Section for case of replacing pages in the origin:1 amendment request. Page replacement instructions are provided. All changes are marked with revision jhf j bars and are labeled Revision 5.

The Plant Operations and Safety Review Committee and a subcommittee of the Offsite Safety Review Committee hav: reviewed revisions resulting in changes to the No Significant llazards Considerations and concur that operation with the proposed revisions will not safety of the public.

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9709160162 970910 r," = " 8' 7 W R M'@l

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, Document Control Desk September 10,1997 Page 2 Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, x/

STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT 1, Charles H. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimoic Gas and Electric Company (BGE), and that I am duly authorized to execute and file this License Amendment Request on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

/

/

W

/

Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of

&/tJert

.this /0 day of Sekmher,1997.

WITNESS my Hand and Notarial Seal:

Od Notary Public My Commission Expires:

c2 /hh8 PJ2e' CHC/ PSF / dim Attachments: (1) Responses to Request for Additional Information (2) Summary of Changes (3) Amendment Revision by Change (4) Amendment Revision by ITS.Section cc:

M. L. Reardon, NRC (With Attachment 2 only)

R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate I-1, NRC R.1. McLean, DNR A. W. Dromerick, NRC J. H. Walter, PSC

ATTACilMENT (1) i 1

i-IMPROVED TECIINICAL SPECIFICATIONS, REVISION 5 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION i

l' Baltiraore Gas and Electric Company Calvert Cliffs Nuclear Power Plant September 10,1997 m,

h ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATsONS SECTION 3.4 3.4.1 DOC JFD

- CHANGE / DIFFERENCE COMMENT STATUS 3.4.1-1 L1 JFD.1 CTS 3.2.5 ACTION requires THERMAL POWER reduchon to Provide justin M for the STS deviaton based

< 5% of RATED. THERMAL POWER (RTP) if co8d leg on current licensing basis, syMem dmign, or temperature cannot be restored to s 548'F within two hours.

operational constraints.

Under the same condition, ITS 3.4.1 ACTION D only requires Provide additional discussen and jus 0Trc M THERMAL POWER reduction to s 30% RTP.

demonstrating that power reduchon to s 30%

acce@ W on pbnt s@ anayses '

• STS 3.4.1 ACTION D includes the 30% of RTP value as a Oracketed figure, indicating that a plant-specific value may be used in lieu of the STS value. However, the change from 5%

to 30% of RTP is not consstent with the STS because the plan *-specific value in CTS 3.5.2 ACTION is 5%, not 30%.

h s

urthermore, the acceptability of this change is justified merely by stating that the potential for violating the DN3R limit is very remote when operating at s 30% RTP while cold leg temperature is not within limits. The No Significant Hazards Consideration (NSHC) also states that reducing power to s 30% RTP ensures the potential for a DNB anoma!y is remote. The NSHC further states that operating in accordance with this change results in meeting the DNBR criterion in the event of a DNB limited transient, and that operation in this manner ensures that a DNB limit will not be violated. No specific quantifiable information is provided or l

referenced, however.

t CCNPP Response:

{

The Current Technical Specification (CTS) 3.2.5, Improved Standard Technical Specification (ISTS) 3.4.1 and improved Technical SpeciTn M (ITS) 3.4.1 f

markups will be modified to retain current licensing basis. DOC L1 wi!! not be used, and Justification for Deviation (JFD) 31 will be added 1

i t

i coc = Discussion of Change 1

JFD = Justificabon for Deviahon l

t

ATTACHIAENT (1)

RESPONSES TO REQUEST FOR ADDmONAL INFORRAATION IRIPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.1.

DOC

-JFD CHANGE / DIFFERENCE -

COMMENT

. STATUS.

3.4.1-2 L3 JFD.1 -

Performance of CTS Surveihace Requirement 4.2.5.2 is BEYOND SCOPE required atleast once per 18 months.

In f1 S SR 3.4.1.4, this Frequency is extended to 24 months.

STS SR 3.4.1.4 specifies an 18-month Frequency for this surveillance. The 18-month Frequency is a bracketed figure in the STS, indicating that a plant-specrfic value may be used in lieu of the STS value. The change from 18 months to 24 months is not consistent with the STS, however, because the plant-specific value in CTS Su%Ilcnce Requirement 4.2.5.2 is 18 months, not 24 months.

This change represents not only a relaxed CTS requirement, but also a deviation from the STS.

CCNPP Response:

The 18-month frequency will be retained, and appropnate jwGTducns provided DOC = Discussion of Change 2

JFD = Justfreation for Deviabon

ATTACHMENT fil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.1 DOC JFD CHANGE /DlFFERENCE COMMENT STATUS 3.4.1-3 L2 CTS Surveillance Requirement 4.2.52 requires determining Correct or delete the L2 DOC, and correct the -

the Reactor Coolant System (RCS) total flow rate to be within CTS markup and/or the ITS accordingly.

its limit by measurement.

Discussion of change (DOC) L2 states a note is added in ITS SR 3.4.1.4 which a!!ows not performing this surveillance i

l until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 2 90% RTP. The DOC goes on to say this change is required to ensure the test results are representative of RCS total flow, because the test results are more acci; rate when obtained at power levels > 90% RTP.

ITS SR 3.4.1.4 requires verifying measured RCS total flow rate is within limits. There is no note in ITS SR 3.4.1.4 to a!!ow deferring this surveillance until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 2 90% RTP. Therefore, in this regard, there is no difference l

between CTS Surveillance Requirement 42.5.2 and ITS SR 3.4.1.4.

CCNPP Response:

The RCS total flow requirements were corrected as part of a supplemental amendment request dated June 9,1997.

DOC = Discussion of Change 3

JFD = Just;fication for Deviatson

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.1.

. DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.4.1-4 A.2 Most of the requirements contained in CTS 3/42.5. DNB Correct the CTS Markup pages for ITS 3.4.1 to Parameters, are placed in ITS 3.4.1, RCS Pressure, indicate that CTS 3.2.5.d and its associated Temperature, and Flow DNB Limits.

ACTION and Survei!!ance Requirement are discussed in the conversion submittal DOCS for However, CTS 3.2.5.d requiring AXIAL SHAPE INDEX (ASI)

ITS 32.5, rather than being deleted as an and THERMAL POWER within specified limits, and its "9

associated ACTION and Surveillance Requirements, are not placed in ITS 3.4.1, but are retained as ITS 3.2.5, Axial Shapeindex.

Accordingly, any changes to these ASI requirements are addressed in the Discussion of Changes (DOCS) for ITS 3.2.5.

Since these requirements are retained, but are ne=J,.T placed in ITS 3.4.1, the CTS Markup should be annotated as such, rather than indicating the requirement is deleted, and then classifying this change as Administrative.

CCNPP Response:

CTS Limiting Condition for Operation (LCO) 3.2.5.d markups will be revised to indicate that the requirements regarding Axial Shape Index are discussed in the DOCS for CTS 3.2.5. DOC A.2 will not be used.

DOC = Disevssion of Change 4

JFD = Justification for Dmiation

ATTACHIENT (il RESPONSES TO RECIUEST FOR ADDITIONAL INFORRIATION IRIPROVED TECHNICAL SPECII9 CATIONS SECTION 3.4 3A.1 :

' DOC

JFD;

. CHANGE / DIFFERENCE -

COMMENT =

STATUS:

3.4.1-5 JFD.1, STS 3.4.1.a and STS 3.4.1.b arnpose requirements on the Provide discussson and jushin,.bvis for not value of pressurizer pressure and RCS cold leg temperature, irn,vi rxeLi g the STS format and content with respecbvely. Each of these parameters' required values is regard to the requirement for a specified range stipulated as a range of acc.e ab;e values, the lower limit of c.c.cpteb;c values for pressunzer pressure r

designated with a 2 sign, and the upper limit dessgnated with and RCS cold leg temperature.

asshn.

Base the justirn,.0v6 on current licensing basis, ITS 3.4.1.a and ITS 3.4.1.b do not include both upper and system design, or operational constraints.

lower limits for these parametne requirements. Instead, ITS 3 4.1.a requires pressurizer pressure 22200 psia, and ITS 3.4.1.b requires RCS cold leg temperature s 548'F.

Likewise, while. STS SR 3.4.1.1 and STS SR 3.4.1.2 respectively require venfication that pressurizer pressure and RCS cold leg temperature are within the sperjf.ed upper and lower limits, ITS SR 3.4.1.1 requires verirn,aLun of pressurizer pressure 22200 psia, and ITS SR 3.4.1.2 requires verification of RCS cold leg temperature s 548'F.

Beyond inc,vipocesun of plant-specific numbers into the brackets,. there is no discussion of the reason (s) for not adopting the STS format and content.

CCNPP Response:

Justification based on current licensing basis is included in JFD 32.

DOC = Discussion of Change 5

JFD = Justificabon for Devistoon

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.1 DOC JFD CHANGE / DIFFERENCE

. COMMENT STATUS 3.4.1-6 JFD.1 STS 3.4.1.b imposes requirements on the value of RCS cold Provide discussion and justfcation for not leg temperature, with a specified a!!owable band for < [70]%

mcorporating the STS format and content with RTP, and a different specified allowable band for 2[70]%

regard to including two separate bands of RTP. Likewise, STS SR 3.4.1.2 requires verification that acceptable values for RCS cold leg RCS cold leg temperature is within its specified range for temperature, depending on rwetor power level.

operation at either < [70]% RTP, or 2[70]%. RTP, as Base the justification on current licensing basis, applicable.

system design, or operational constraints.

ITS 3.4.1.b and ITS SR 3.4.1.2 merely state the required value for RCS cold leg temperature as s 548'F, regardless of reactor power level.

Beyond incorporation of plant-specific numbers into the brackets, there is no discussion of the reason (s) for not adopting the STS format and content.

CCNPP Response:

Justification based on current licensing basis is included in JFD 32.

3.4.1-7 STS SR 3.4.1.4 requires RCS total flow rate venfed by Acceptance of this change is contingent on performing a precision heat balance (a calorimetric NRC approval of TSTF-105.

calculation).

ITS SR 3.4.1.4 stipulates this verifcation by measuring the RCS total flow rate.

This STS deviation is based on TSTF-105.

CCNPP Response:

The RCS total flow rate verifcation based on current licensing basis is justifed by JFD 29 as part of a supplemental arnendment request dated June 9,1997.

CDC = Drscussion of Change 6

JFD = Just:fkation for Deviation f

t ATTACHRIENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORIAATION

+

IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.4

+

13A2D DOC:

JFD CHANGE / DIFFERENCE COMMENT

.ESTATUS 2

A.3 CTS Survedlance Requirement 4.1.1.5 b includes a stipulation Provide decussion and jonkabc6 for the more

[

that the surveillance is required when the RCS T, is < 525*F.

restnctive change, including why it is N'...tAa j

M to N d me ITS SR 3.4.2.1 changes this stipulation by specsfying T W

"' " "* " Y "

< 525*F in anyRCSlopp.

loop's T.,, is < 525'F, rather than when the RCS This change constitutes a more restnctive change rather than T.,, of unspecified loop (s) is < 525'F

.l an administrative change in addition, this change constitutes up n E W 13.

Has Was, W an STS deviation, the basis for which is CEOG-113.

rejected. What is the TSTF number.

.f CCNPP Response:

The RCS T, requirements were restored to current licensing basis as part of a supplemental r=nerntneid request dated June 9,1997 3

M.1 ITS SR 3.4.2.2 is added,- requiring RCS T.,, in each loop Contingent upon CEOG-113. Has this been l

venfied 2 515'F once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when T.,, in any RCS loop rejected WhatistheTSTFnumber is 2 525*F.

?

This requirement is not included in CTS 3.1.1.5.

This change from the j

CTS requirements is based on CEOG-113.

CCNPP Response:

}

The RCS T., requirements were restored to current licensing basis as part of a supplemental anendment request dated June 9,1997.

4 STS 3.4.2 Appik ot,;;.ti is MODE 1 with T.,, in one or more CunGnys,d upon CEOG-113. Has this been RCS loops < [525]*F, and MODE 2 with T.,, in one or more rejected What is the TSTF number.

i RCS loops < [535]*F and K,,21.0.

t ITS 3.4.2 Apphcability is merely MODE 1, and MODE 2 with K,r 2 1.0.

The discussion and ju=Griration for this STS deviabon is contained in CEOG-113.

i CCNPP Response:

The RCS T and K, applicability requirementswere restored to current licensing basis as part of a suppleinental amendment request dated June 9,1997.

j i

1 coc = Discussion or change.

7 JFD = Jus *.ircation for Devotion I

ATTACHRAENT f1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4

'3.4.3

-DOC-JFD CHANGE / DIFFERENCE COMMENT STATUS 1

A.1 JFD.2 CTS 3.4.9.1 requires maintaining RCS temperature and Add informaton showing where hnwts are pressure yrithin the limits indicated on Figures 3.4.9-1 and specified As in

.maantained within the limits 3.4.9-2.

shown in Fgures_and.

These curves, CTS Figures 3.4.9-1 and 3.4.9-2, are included on two pages in ITS 3.4.3, as Figures 3.4.3-1 and 3.4.3-2.

However, the wording of ITS 3.4.3 includes no direchon to maintain RCS temperature and pressure according to the limits on these curves, nor does ITS3.4.3 provide reference to another document wherein specific limits may be obtained ITS 3.4.3 merely requires RCS temperature and pressure *...

maintained within limits."

STS 3.4.3 requires maintaining RCS temperature and pressure within the limits specrfied in the PTLR but,' again, ITS 3.4.3 neither states nor references the specific required limits.

CCNPP Response:

Surveillance Requirement (SR) 3.4.3.1 identifies where the limits are located.

2

' A.1 The Apphcability of CTS 3.4.9.1 is stated as, "At all times," but, Add reference to cnbcality, and inservce leak within the text of CTS 3.4.9.1, this Apphcability is further and hydrostatic testing in ITS 3.4.3 or provide modified to, "... during heatup, cooldown, entcality, and justificahon why it s,%;Id nio be added STS inservice leak and hydrostatic testing..."

sciwiences PTLR which has this. Since you are not using PTLR., include all pasand;;s in the LCO.

CCNPP Response:

The markup of CTS 3.4.9.1 will be revised to properly reflect these changes. The acceptance criteria for ITS 3.4.3 will be contained on Fgures 3.4.3-1 and 3.4.3-2.

ITS SR 3.4.3.1 will invoke the figures. DOC A.2 will be added to justify these ch =-@.

3.4.4 -

DOC JFD CHANGE / DIFFERENCE COMMENT STATUS No comments for 3.4.4 DOC = Discussion of Change 8

JFD = Justification for Deviation

ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION

!MPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.5 :

DOC JFD CHANGE /DIFFEAENCE -

COMMENT STATUS Bases TSTF 177 (CEOG 83) pending Changes dependent upon aing;e^uun of rennew ofTSTF.

CCNPP Response:

[ Technical SpwAM -i Task Force] TSTF-177 references were removed, anb ITS changed to match ISTS or changes were justified by current licensing basis, using JFD 27. The Bases were also modified to better reflect the LCO, justified in JFD-27.

1 LA.1 The details of CTS 3.4.12.a.1 and 3.4.1.2.a2, specifying Provide plant procecure(s) change conrol precisely which two RCS loops shall be OPERABLE, and how process. (50.59%

many reactor coolant pumps in each of these two RCS loops must be OPERABLE, are moved to plant procedures.

CCNPP Response:

Details will be moved to the Bases, and the change will be justified in LA.1.

2 A.1 CTS 3.4.1.2 Appicability is modified by footnote ~ which states Provide descussion and justificabon for the more that a reactor coolant pump shall not be started with the RCS restrictive change, including, as applicable, how

~

temperature s 365'F (Unit 1), s 301*F (Unit 2).

CTS 3.4.1.2 footnote is L-despicted by plant Y

in ITS 3.4.5 NOTE 2, the term "RCS temperature" is changed

• }'

to "RCS cold leg temperature." There is no discussion or

"" "?se es M W. &

justification for this change.

Specifying which RCS temperature is applicable in meeting the limit enhances the Technical Speedicabons by removing ambiguity which exists in CTS 3.4.12 footnote The enhancement constitutes an additional restnchon not found in CTS 3 4.1.2; therefore, this is a more restrictive change CCNPP Response:

DOC A.3 will be added to justify changes made to clarify revisions to ITS 3.4.5 Note 2.

DOC = Discussion of Change 9

JFD = Justifcation for Deviaton

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.5.

-DOC

'JFD CHANGE / DIFFERENCE COMMENT STATUS 3

STS 3.4.5 NOTE b includes a enterion that core outlet Provide justification for the "genenc editoriar'.

temperature is ma;ntained at least 10*F below saturation Was this a TSTF7 temperature.

Likewise, CTS 3.4.12b footnote ' states that core outlet temperature is maintained at least 10*F below saturation temperature However, ITS 3.4.5 NOTE 1.b changes the phrase, "

at least 10*F.. " to ".. ;t 10*F..."

Placing the symbol meaning " greater than or equal to" and its associated numeric value directly adjacent to the word "below" causes the reader's mind to stumble. The intended meaning is more quickly grasped by using the phrase "at least 10*F below The reason for this STS deviation is not clear, but it is justified by a handwritten comment in the STS 3.4.5 margin which states,"edi*orial generic."

CCNPP Response:

Notes for LCOs 3.4.5, 3.4.6, 3.4.7, and 3.4.8 will be changed to say *at least 10'F below" to be consistent wit') CTS and ISTS, and to be consistently applied, where appropriate.

3.4.6 -

DOC JFD CHANGE /D!FFERENCE COMMENT STATUS 1

t.A1 The details of CTS 3.4.1.3.a 1,

.2,.3, and.4, specifying Provide iniviiiWuc6 &=,uT0ing the plant precisely which two cooling loops of the four RCS and SDC procedure (s) to which the details of CTS loops possible shall be OPERABLE, and how many RCPs in 3.4.1.3.a.1,.2,.3, and.4 are moved, and how the any defined OPERABLE RCS loop (s) must be OPERABLE, plant procedures are controlied are moved to plant procedures.

CCNPP Response:

Details will be moved to the Bases, and the change will be justified in LA.1.

Doc = orscussion of change 10 JFD = Justification for Deviation

ATTAChAAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION lAAPROFdD TECHNICAL SPECIFICATIONS SECTION 3.4

3. 4.6 -

DOC JFD-CHANGE / DIFFERENCE

-COMMENT STATUS.

- 2 STS 3.4.6 NOTE b includes a cnterion that core outlet Same as before.

terrperature is maintained at least 10*F below saturabon terrperature.

~

Likewise CTS 3.4.1.3.b footnote states that core outlet temperature is maintained at least 10*F below saturabon temperature.

However, ITS 3.4.6 NOTE 1.b changes the phrase, "... at least 10*F..." to ".. 210*F..."

Placing the symbol meaning " greater than or equal to" and its associated numenc value directly adjacent to the word "below" can cause the reader to stumble. The intended meaning is more quickly grasped by using the grammatically correct phrase "... at least 10*F below..."

The reason for this STS deviabon is not clear, but it is justified by a handwntien comment in the STS 3.4.6 margin which states," editorial genenc."

i CCNPP Response:

Notes for LCOs 3.4.5, 3.4.6, 3.4.7, and 3.4.8 will changed to say *at least 10*F below" to be consistent with CTS and ISTS, and to be consistently applied, where appropnate.

Doc = Discussion of change 11 JFD = Just#ication for Deviabon

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4 6 '

DOC-JFD CHANGE / DIFFERENCE -

COMMENT

STATUS 3

A6 Footnote associated with CTS 3.4.1.3.a3 and 3.4.1.3.a4, Correct or venfy the "A5" DOC desagnator in the allows the norrnal or emergency power source INOPERABLE CTS markup for CTS 3.4.1.3.a3 and 3.4.1.3.a4.

for the SDC loops in MODE 5. ITS 3.4.6 does not include this allowance it is presurned that the handwntien "AS" discussion of change (DOC) designator in the CTS markup for CTS 3.4.1.3.a3 and 3.4.1.3.a4 is in error, and was intended to be wntien "A6." It u on the basis of this presumption that review of the A6 change is performed if this presumphon is incorr=ct, then the conclusion reached during the review of change A6 must be re-addressed.

CCNPP Response:

The CTS 3.4.1.3.a3 and 3.4.1.3.a4 will be modified to reference DOC A6 instead of AS.

4 A5 CTS 3.4.1.3 Applicability footnote " reie ernes CTS Special in the CTS markup, correct or venfy the Test Excephon (STE) 3.10.5. ITS 3.4.6 deletes tre reference handwntien lines extending from the "A5"

~

to STE 3.10.5.

des;grein to the footnote %naw for CTS

~ ~ ~ ~ "

' ' ' ~ * '

it is presumed that in the CTS markup, the igerntwdnen lines extending from the "A5" DOC %naivi to the footnote designator for CTS 3.4.1.3.a3 and 3.4.1.3.a4 are in error, and 8

were actually intended to extend to the footnote des;gnatur for CTS 3.4.1.3 Applicability MODE 4.

It is on the basis of this presumphon that revew of the A5 change is pedunrad.

If this presumphon is irnuicci, then the conchssion reached during the review of change A5 must be re-addressed CCNPP Response:

The CTS 3.4.1.3.a3 and 3.4.1.3.a4 will be modified to reference DOC AS instead of A6.

~

DOC = Discussion of Change 12 JFD = Just:rscation for Deviationi

ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION lAAPROVED TECHNsCAL SPECIFICATIONS SECTION 3.4 3.4.6' DOC-JFD-

- CHANGE / DIFFERENCE CODIENT STATUS-5 M.3 CTS 3.4.1.3 ACTION b presenbes operator acbons in the Provide dsscussson and fmikobu6 for the more event that no coolant loop is in operaton. ITS 3 4.6 ACTION C restnctive change of adding the Condebon of indudes the equivalent Condition of no RCS or SDC loops in requwed RCS or'SDC loops INOPERABLE to aperituen, but also adds the Condition of required RCS or SDC iTS 3.4.6 ACTION C.

loops INOPERABLE; the two dwsbed Cciniu6 are linked by an OR statement.

The justification focuses on changing the one-hour wryletks tirne of CTS 3.4.1.3 ACTION b to a conyWuc0 time of immediately in ITS 3.4.6 ACTION C, but does not address the further enhancement of adding the Condition of required RCS or SDC loops INOPERABLE.

While reasoning for this enhancement may be intuitively obvious, the change must be discussed and justified in the license imiddTrent sutmttal CCNPP Response:

DOC M.3 will be provided for the addition of the Condition with required RCS or shutdown cooling (SDC) loops being kw.bic.

r DOC = Dscussion of Change 13 JFD = Justificate for Deviata m.

ATTACHMENT fil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.7 DOC JFD CHANGE /D!FFERENCE COMMENT STATUS 1

L1 If credit is taken for RCS loop (s) OPERABLE for decay t. eat Provide addtbonal dscussion aN justificaton for removal, then CTS 3.4.1.3.a.1 and 3.4.1.3.a2 stipulate at least the changed CTS requirement to quantifiably one associated RCP OPERABLE in the OPERABLE loop (s).

demonstrate adequacy of the SGs* corrbined heat sink capabihty, with both SG sc,.wdary side in iTS 3.4.7, RCP OPERABILITY is not a requirement, if credd waw % at -M h, aM e W is taken for the RCS loops as the backup decay heat removal RCS flow.

Development of ths justficabon

,g' should indude analysis or venficaton, using the The justification states that acceptability of this change is most conserva* ave case (full power history and based on:

minimum time to get to MODE 5), of heat transfer ra es. h WN Rems hM M WM,

- The large contained vo!ume of secondary side water as a#M providing a heat sink for the RCS, and

- Maxmum core decay heat generation rate,

- Forced RCS flow not necessary because natural circulation is sufficient to remove the small decay heat load generated by

- Total primary to secu 4ary heat transfer area, the reactor core until at least one SDC loop is made

- Heat transfer coefficent(s)*

OPERA 3LE and/or placed in operation.

There is no specrfic information provded or desenbed upon ea# d F M aM W which to measure acceptability of the change.

- Total ratural circu!aton flow rate.

- Combined SGs* ambent heat loss rate.

CCNPP Response:

DOC L.1 will be modified to state that the evaluation of natural circulation was conducted to meet the intent of NUMARC Guidance document 91-06 (Guidelines for industry Actm to Assess Shutdown Management).

DOC = Discussion of Change 14

.7D = Justirication for Deviaton

ATTACHMENT M)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.7 '

DOC JFD CHANGE / DIFFERENCE COMMENY STATUS:

2 L2 The requirements of CTS 3.4.1.3 stipulate both RCS loops in Provide additional discussion for the less OpersGen if both SDC loops are removed from Operation while restnctrve change based on plant Operouvus.

^

in MODE 5.

Address factors relating to backup (standby)

ITS 3.4.7 NOTE 4 allows removing both SDC loops from n t.N m wown, N aW to mstore one w M operation during planned heatup from MODE 5 to MODE 4

^

requ S

to w s,s N h to when at least one RCS loop is in Operouen. This effectrvely reduces the CTS 3.4.1.3 requirement from both RCS loops to heatup path obviatog the need for the same level only one RCS loop in operation' of required decay heat removal capability as when no heatup is intended, and so forth, as appivpriate.

CCNPP Response DOC L2 will tra revised to explain why the addition of the Notes is acceptable. ISTS Bases markupt were appropiiotely changed DOC L1 fc-lTS 3.4.8 was also revised.

'3 L2 The CTS 3.4.7 markup includes an insert for placement as ITS Provide dscussion and justification for this 3.4.7 NOTE 2, which allows removing one required SDC loop change from the CTS markup, including why the

)

from Opcis'uvii for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided the other SDC loop is term " train" is preferable to the term " loop

• in tnis OPERABLE andin operation instance However, ITS 3.4.7 NOTE 2 changes the word " loop" to the Since, h: some places in thu ITS, the term train is word " train," so the las' of the sentence reads, ".. provided left in, explain when there is a difference the other SDC trein is OPERABLE and in Opersuon."

The terms loop and train are not equivalent; there is no discussion orj%tT--r--i for this change from the CTS markup CCNPP Response:

Changes will be made to ITS 3.4.7 and 3.4.8 to resect that the term loop is oppivpiiste.

Doc = Discussion of change 15 JFD = Jusf5caton for Deviation

ATTACHMENTfil RESPON3ES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.7.

DOC-l JFD CHANGIhlFFERENCE COMMENT STATUS 4

f.A2 CTS Surveillance Reauirement 4.4.1.3.1 requires venfying Provide addkne inhn Wucri in the Bases.

conect breaker alignments and indicated power availability for SDC loop valves associated with required OPERABLE SDC loop (s) which are not in (pera*Jon. Note that this requirement refers to the SDC loop (s) required OPERABLE, but not in operation (the standby loop).'

j

!TS 3.4.7 does not retain the requirement to venfy correct breaker alignment and indicated power availabiirty for SDC '

loop valves associated with required OPERABLE SDC loop (s) which are not in operaton.

The discussion of change ind~ ates that this detailis moved to c

the ITS 3.4.7 Bases. However, the ITS 3.4.7 Bases only infers that SDC loop valve power must be available, and this inference is with regard to venfy5g one required OPERABLE coolant loop in operation (italics added) by verifying flow rate, temperature, or pump status monitonng.

CCNPP Response:

ITS SR 3.4.7.3 will be revised to include the requirement regarding the SDC valves.

Doc - oscussion of change 16 JFD = Justrreation for Deviation

.... ~.

'l ATTACM (1)

RESPONSES TO REM 3UEST FOR ADDITIONAL WFORIAATION BRIPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 CHANGEOlFFERENCE CORfhENT STATUS :

3.4.7--

. DOC:

JFD 5

STS 317 NOTE 1.b mclude a cntenon 'that core outlet Swne as before.

temperature is mantar'ed at least 10*F below saturabon temperature

~

Likewise. CTS 3.4.1.3.b footnote states that core outlet temperature is mamtained at least 10*F below saturabon temperature.

However, ITS 3.4.7 NOTE 1.b disivas the phrase.... at least 10*F..." to ".. 210*F.."

Placog the symbol meanog " greater than or equal to" and its associated numenc value drectly aj.-w st to the word "below"

.l can cause the reader to stumble The intended meaneg is more queldy grasped by using the y i.n.G-Aly correct phrase ".. at least 10*F below..."

The reason for this STS densbon is not clear, but it is justdied by a handwntlen con =ioni in the STS 3.4.6 marge whch states,"edstonal genenc."

CCNPP Response:

Notes for LCOs 3.4.5,3.4.6,3.4.7, and 3.4.8 will dvsiged to say "at least 10'F below" to be consstent with CTS and ISTS, and to be consstently applied, where isprvri.ic.

6 1.A.1 CTS 3.4.1.3.a.3 and 3.4.1.3.a.4 xlentfy, by soop number, the Prowde addsbonal mformahon desenbeg the SDC loops required OPERABLE. ITS 3.4.7 also unposes plant procedure (s) control (50 597).

requeements on SDC loop (s) OPERABILITY,.but does not ident#y the speedic soc loop numbers. This detaa is need to plant pro dures. Theplant procedures to which this detail is moved are notidenbfici CCNPP F :;-:x:

Details will be moved to the Bases, and the change wiB bejustdied in (A1.

DOC = Discussion of Change 17 TD = Jushficebon for Demsbon

\\

1 ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.8 -

. DOC-JFD-CHANGE / DIFFERENCE

. COMMENT

STATUS:

1 LA1 CTS 3.4.1.3.a.3 and 3.4.1.3.a.4 identify, by loop number, the Provde change control process (5 597).

SDC loops required OPERABLE. ITS 3.4.8 atso irnposes requieieiits on SDC loop (s) OPERABILITY, but does not identify the specific SDC loop numbers This detailis rnoved to plant procedures. The plant procedures to which this detail is rnoved are notidentified.

CCNPP Response:

Details will be moved to the Bases, and the change will be justified in LA1.

2 LA2 CTS Surveillance Requirement 4.4.1.3.1 requires venfying Provde Bases discusson that clearly indicates correct treaker alignments and indicated power availability for veitrats of power to the valves SDC loop valves associated with required OPERABLE SDC loop (s) which are not in operabon. Note that this requirement refers to the SDC loop (s) required OPERABLE, but not in vpedui(the standby loop).-

ITS 3.4.8 des not retain the requirement to venfy correct breaker alignrnent and indicated power availatxlity for SDC loop valves a==ca.wied with required OPERABLE SDC loop (s) which are not in operation.

The discuscion of change indicates that this detail is moved to the ITS 3.4.8 Bases. However, the ITS 3.4.3 Bases only infers that SDC loop valve power must be available, and this inference is with regard to verifying one required OPERABLE coolant loop in qperation (italics added) by verifying flow rate, iciipci8uJre, or pump status iiu divih 9 Because CTS Surveillance Requirement 4.4.1.3.1 addresses the required loop which is not in operation, this change is a less restnchve change for which there is no justifats.

CCNPP Response:

ITS SR 3.4.8.2 will be revised to include the requirement regarding the SDC valves.

Doc - orscussion of change 18 JFD = JustMcahon for Deviation L_

ATTACHMENT fin RESPONSES TO REQUEST FOR ADDITIONAL. !*2 FORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2

JFD.26 The discussion of change states that ITS 3.4.9 requires two Retain statement,"... capable of being powered pressurizer heater banks OPERABLE, each with the capacity of from and emergency power supply. It is in the 2150kW and capable of being supplied by an emergency CTS and bracketed material stays in the LCO if power supply source. ITS 3.4.9 does not specify that each it is applicable.

heater bank must be capable of being supplieo by an emergency power source. Not specifying that each heater bank must be capable of being supplied by an emergency

)

power source deviates from STS LCO 3.4.9.b which requires j

two banks or pressurizer heaters OPERABLE with the capacity of each group 2150 kW and capable of oeing powered from an emergency power supply. JFD 26 does not adequately discuss and justfy this deviation from the STS.

CCNPP Response:

The Bases will be modified to state that the pressurizer heaters are permanently powered by Class 1E power supplies, and JFD 26 was revised to provide additional justification.

3 JFD.27 ITS SR 3.4.9.2 adds a new requirement to venfy pressunzer Acceptance of this change is contingent upon heater bank capacity 2150 kW every 24 months.

CTS NRC approval of TSTF-93. TSTF is pending.

Survei? lance Requirement 4.4.4 does not contain this However, it has been rewumei4ed that the

)

requirement. The STS SR 3.4.72 markup shows that the STS NOTE be placed in the SR if we a!!ow the Frequency of 92 days is changed to 24 months. This change change in sisrveillance frequency. Also, this references TSTF-93 as its basis.

There is inadequate may be further review. Since the SR is not in discussion and justification for this deviation from the STS.

your CTS and you are changing the frequency to 24 months rather than the br.rketed 18, we may need to revisit this.

CCNPP Response:

JFD-27 will be modified to justify acceptability of 24-month SR frequency. This is a more restrictve change that is not contained in the CTS.

4 JFD21 STS SR 3.4.9.3 is deleted. There is inadequate discussion and Provide discusson of the semming confict justrfication for this STS deviation.

between Discussion of Deviations from NUREG # 21 and 26. Retain the SR.

CCNPP Response:

JFD 21 will be revised to provide additional justifcation.

Doc = orscussion of change 19 JFD = Justification for Deviation

ATTACHRENT (1)

RESPONSES TO REGUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.10 DOC JFD

- CHANGE / DIFFERENCE :.

COMMENT

~ STATUS 1

Change in Applicabihty ' rom MODES 1,2,3, and 4 Possible Beyond Scope issue. Aduibonal ju;4; Tic inxi is needed to deviate from the STS.

The STS has an LTOP sph also that i

covers a different terw Lare. MOPDE 4 in i

this LCO is > [285], while the LTOP LCO is <

[285}. Retain the LCO as is in the STS.

Change Bases accordingty.

[

t CCNPP Response:

DOC L1 will be revised to provide additionaljustificabon for the change in applicability. The pressurizer safety valves provide pressure pivia.;ticai above the LTOP enable temperature. DOC M.1 is withdrawn because the resulting changes eliminate any need for DOC M.1.

j 2

JFD CTS 3.4.2.1 LCO statement specifies the actual pressurizer if the valve setbngs win be moved to the SR, safety valves that shall be OPERABLE and provides their the As-Left Tolerences, which ceiic=,pviids to respechve As-Found and As-Left tolerances as a percent the STS s.%2ld be leftin also.

funcbon of their lift setbngs ITS 3.4.10 LCO statement requires 2 pressurizer safety valves OPERABLE. The above detads for L

each valve are moved into ITS SR 3.4.10.1.

CCNPP Response:

r The as-left tolerances are left in the SRs as desenbed in JFD-8 and in accordance with the writer's manual.

i DOC = Discussion of Change 20 JFD = Justificaten for Deviation t

i ATTACHMEi(T (1)

I RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.10 DOC JFD-CHANGE / DIFFERENCE -

COMMENT STATUS-3 M.1 The dtscussion of change states that ITS 3.4.10 adds an Correct the discussen of change to accurately intermediate step to the shutdown track required by CTS reflect the content of ITS 3.4.10.

I 3.42.1. This is not the case. CTS 3.42.1 requires shutdown to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with one pressurizer safety valve inoperable. ITS 3.4.10 only requires shutdown to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reducing RCS co!d leg temperatures to s 365'F (Unit 1; s 301'F Unit 2) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ITS 3.4.10 does not require further shutdown to MODE 4. Therefore, the shutdown to MODE 3 is not an intermediate step.

i CCNPP Response:

DOC L1 will be revised to provide additionaljustification for the change in appreability. The pressurizer safety valves provde pressure piviedkaa above the I. TOP enable temperature. DOC M.1 is withdrawn because the resulting changes eliminate any need for DOC M.1.

4 L1 CTS 3/4.2.1 contains a footnote speofying that both pressunzer Provde dissw. and p_ W hr_mi for this safety va!ves may be removed in MODE 5 provded that at change to CTS requirements. Speofy where least one valve i; replaced by a spool piece whch allows the this requirement is now located. Relocate to pressurizer to relieve directly to the quench tank. This footnote Bases?

is referenced to the L1 discuss'en of change. ITS 3.4.10 does not contain any mention of the requirements contained in this footnote. There is no discussion orjustircation for this change.

CCNPP Response:

DOC L1 wi!! be revised to address elimination of the footnote

• of CTS LCO 3.42.1.

DOC = Discussion of Change 21 JFD = Justrfication for Deviation

. _. _ = _ _ _ _.

ATTACHMENT (1)

~

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4

]

3.4.11' DOC

-JFD

= CHANGE / DIFFERENCE COMMENT STATUS 1

JFD25 ITS 3.4.11 Required Action A.1 broadens the aMV of This May & Beyond h 1

CTS 34.3 Action a through a Note which allows delaying the N does consistent with the current licenssng Required Action for s 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> if one block valve s g s.

? Is it or is it not?

Provide inoperable and s 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if two block valves are inoperable.

justificabon for the STS deviabon based on However, adding this Note to ITS 3.4.11 Required Acbon A.1 current 6-ng basis, system design, or is a devsabon from the STS. There is inadequate discussion ind consaits.

and justification for this STS deviation CCNPP Response:

This change will be withdrawn and current licensing basis instated, and JFD 25 withdrawn.

2 LA1 CTS Su.vestlance Requirement 4.4.3.1.a requires perfomwng Specify the controls for the change process a Channel Funcbonal Test at least once per 31 days in (50.597) accordance with the Reactor Protective System (RPS)

Pressurizer Pressure Surveinance Test Procedure. ITS SR 3.4.11.1 requires performing the CHANNEL FUNCTIONAL TEST, but does not specify that it be done in accordance with the RPS Pressurizer Pressure Surveillance Test Procedure, thereby moving the CTS requirement outside of the ITS into licensee-ccubvred documents The discussion of change does not specify whk:h f~m Lv5ed documents contain th's requirement CCNPP Response:

DOC A.5 will be added to explain that the change is actually Edministrative, the requirements win be retained in the ITS, and DOC LA1 will be withdrawn.

3 JFD.12 CTS Surveillann Requirement 4.4.3.1.a requires pc,1 vin-ig Provide discussion based on current licensang a CHANNEL FL,tJCTIONAL TEST once per 31 days. ITS

basis, system

design, or Ope.duvie SR 3.4.11.1 retains this CTS requirement. However, adding constraents.

ITS SR 3.4.11.1 is a deviation from the STS. There is inadequate discussion and justificabon for this STS deviation CCNPP Response:

JFD.12 will be enhanced to provide addibonal justificabon and system desu yLun.

DOC = Discussion of Change 22 JFD = Justification for Deviabon

- - - - - - - = - - - - - - - -

ATTACHMENT fil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 1

3.4.11.

DOC

-JFD CHANGE / DIFFERENCE COMMENT STATUS 4

L1 ITS 3.4.11 Acton A relaxes the CTS 3.4.3 Achon a Provde additional discusson and je+1A+t--i requirement of having one or more PORV(s) with excessive for the CTS 5.4.3 Achons b and c cle,p.

seat leakage to one or more PORVs inoperable and capable of being manua!!y cycled. CTS 3.4.3 Acbons b and c specify Required Acbons and Completion Times for one PORV NOTE THIS LCO HAS TO BE REVIEWED IN (Action b) and both PORVs (Action c) inoperable for causes ITS ENTIRETY BEFORE THE MAGNITUDE other than excessive seat leakage. ITS 3.4.11 Achons B OF CHANGES ARE ALL ACCEPTED.

and D change these CTS requirements to one PORV (Acbon B) and two PORVs (Achon D) inoperable and not capable of being manually cycled respecbvely. are briefly addressed.

'Ihe only discussion and jusbfication for these changes to CTS Acbons is a reference to the ITS 3.4.11 Achon A less restrictive change. Ahhough related to the ITS 3.4.11 less restrictive change, these changes.:re separate issues.

There is inadequate discussion and justifcation for the CTS 3.4.3 Actions b and c changes.

l CCNPP Response:

DOC L1 will be enhanced to provde additionaljustifcation for the changes to Achons a, b, and c of LCO 3.4.11.

5 L2 CTS Surveillance Requirement 4.4.3.1.a requires performing This change is not necessaufy acceptable the PORV STE every 31 days. ITS SR 3.4.11.1 extends the simply because of the approval of the SR-Frequency to 92 days. The discussion of change states amendments. These have to be evaluated in that the PORV actuation instrumentation it the same as that their own right.

I used for the RPS High Pressurizer Pressure Funcbon The RPS High Pressurizer Pressure Funcbon STE Surveillance Frequency was decreased from 31 days to 92 days in the RPS and ESFAS ' monthly to quarterly" Technical Specification change (approved in an NRC Safety Evaluabon Report for Amendments 193 and 170 for Units 1 and 2.

respecbvely, dated August 24,1954).

CCNPP Response:

DOC L2 will be modified to enhance the justifcation for this change.

DOC = Discussion of Change 23 JFD = Justification for Deviation

ATTACHIENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRIPROVED TECHNICAL SPECIFICATIONS SECTION 3.4

' 3.4.11-DOC JFD CHANGE / DIFFERENCE COMMENT

. STATUS Pronde juste abon for the = STS deviaton 6

JFD.12 -

CTS Surveillance Requirements 4.4.31a and b.y s

performmg a CHANNEL FUNCTIONAL TEST once per 31 based on current licensmg basis, system days, and performmg a CHANNEL CALIBRATION once per design, or c4mrabonalmnstramts REFUELING INTERVAL inspacEdi. ITS 3.4.11 retams these requ' ements by addog two SRs, ITS SR 3.4.11.1 and v

ITS SR 3.4.11.4. Adding these SRs is a deviabon frcm the STS. There is ir** discussion and just".cabon in for this STS deviabon.

CCNPP Response:

JFD.12 will be enhanced to provide addibonalM'- 4-i and system desu yGcn.

7 JFD.11 STS 3.4.11 Achon D requires shutbng down to MODE 3 in 6 NOTE-THIS LCO HAS TO BE REVIEWED IN nours and to be in MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the Required ITS ENTIRETY BEFORE THE MAGNITUDE Achons and Coiry;cGun Times of Condition A, B, or C are OF CHANGES ARE ALL ACCtvito.

not met. ITS 3.4.11 Achons do not contam this requrement; it is deleted. Delebng this requirement in the ITS is a deviabon frcm the STS. The justricevun fior this deviabon includes reference to Amendments 188 and 165 (for Units 1 and 2 respechvely). There is inadequale <5='_=dvs and jo.cric. con for this STS deviaton.

CCNPP Response:

JFD.11 has been enhanced, and the ITS modified, to better explain and desenbe the current licensmg basis.

coc = oscussion or crenge 24 JFD = Justificate for Deviation

ATTACM (1)

RESPONSES TO REQUEST FOR AD3mONAL WIFORERATION IEEMOVED TECNNICAL SPECFICATIONS SECTION 3.4 CORAMENT eSTATUS:

l 3.4.11 -

DOC; JFD.

CHANGE / DIFFERENCE 8-JFD.11 STS 3.4.11 Acton E @ the Requred Actons and Same Complebon > Trnes for two ; PORVs inoperable and not capeble of being manuaby cycled. STS 3.4.11 Requred 2

Achon E3 and E4 requre shutdown to A40DE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and be in MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ITS 3.4.11 Achon D retams this raqurement However, ITS 3.4.11 Acton D deletes the requrements of STS 3.4.11 Achon E3 and E4. These STS requwements are replaced by ITS 3.4.11 Achon D.3 wtuch requres restonng one PORV to OPERABLE status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This is a demahon from the STS. The jusblicabon for this demabon mciudes reference to Amendments 188 and 165 (for Units 1 and 2 iWd;). There is inadequate 4armenn and jasblicebon for this STS densbon.

CCNPP Response:

JFD.11 has been enhanced, and the ITS modded, to beder explam and desenbe the current licenseg haaia 9

JFD.1 STS SR 3.4.11.4 is not included in the ITS 3.4.11 SRs. It is Pronde jusblicahon for the STS demaleon deleted Delebnq this STS SR is an STS dewabon There is based on current licenseg basis, system madequate desemaann and jusblicahon for delebng this STS deogn, oroperabonal constraints.

SR.

CCNPP Response:-

JFD.34 has been added to jushfy delebon of Standard Techmcal Speedcahon (STS) SR 3.4.11.4.

Doc = Docussen of change

.25-

.FD = Justecahon for Deviseen

ATTACHRAENT fil RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATKW IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 i

3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

Ths LCO wiB has to BE looked at in its entrety agan for Wnat does "to make i consstent wth"7 Yh

. eb o.c,a to your licensing bass and current the 6.odie4 :ssued for the parbcular I uc:;6wents. It is ddficult to know what is in the LCO change. Prtmde a detailed @m of the because of ATa 4 co Js and what is tnere for other reasons.

changes apowed based on the sTo4.o6 a road map would help.

Op~1, not those that were deemed w n 4 gum M Ce.p that wers anowed it is ne c 9

• to dishnguish actual Cp anowed trr amerx2 rents from those inferred by the arre di= 4.

Identff each ATo 4Ta 4 with each change and state W.c,.2y what T

these sTo 4T= 6 aHowed.

Add:bonaf q;esbons may then be gw.=.=1 CCNPP Response:

JFD 14 win be bygi ded to better explain what Ce p to the current :.c.anshg basis are Ensuc.ded we vanous sva 41= G b the CTS.

2 A4 CTS 3.4.9.3 Acbon g actors are deleted in the ITS 3.4.12 Provde add:bonal dscussen and p_5/M ->

Acbons because they are addressed in other ITS for delebng the requirernent to venfy a P/T requien aG. Speci5ca!!y, if excessrve flow is encountered, violaban dd not occur dunng an excessrve the LTOP System is had incgerate and the oppvr 6a HPSI flow event.

Speedy where ths Acbons of ITS 14.12 are entered. Sanitarty, if a P/T violation requirement now resdes is found to have occurred, the aprurde Accons of ITS 3.4.3 are entered The docussion of change also states that the CTS 3.4.9.3 Acbon g requirement to venfy that the excessive flow did not raise pressure above the P/T limits is addressed in ITS 3.4.3. This is not the case; IE 3.4.3 does not requ:re this Acbon. There is inadequate 6w=m and p.a^urduun for deleting ths parbcular element of the CTS 3.4.9.3 Acbon g requaenaits.

CCNPP Response:

DOC LS was added to justfy deletion of this Acbon from the CTS. DOC A4 was upgraced to better explain the %Iui of the C3 Achon statements.

i Doc = orscussen of change 26 JFD = JuerA. for Devuman

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3

LA.1 CTS 3.4.9.3 LCO statements b, c, d, and e; and CTS 3.4.9.3 Specfy wtuch portons of the CTS 3.4.9.3 LCO Acbons e and f speo*y requkwio6 for HPSI pump Malm>=G b, c, d. and e; and CTS 3.4.9.3 c;. ration when the LTOP System is oppn#v;e. ITS 3.4.12 Acbons e and f reman in ITS 3.4.12. Also does not contain these requirements. The discusson of state what goes to the Bases snd what to Plant change states that these requirements are moved either fu!!y Procedures.

3dentfy the change control cr parbaHy into plant procedures However, it remains process for Plant Procedures (50.597).

unclear which portons of the CTS requireiraG remain in the ITS.

CCNPP Response:

DOC LA.1 has been modified to state titat CTS 3.4.9.3 LCO statements b, c, e. and 3.4.9.3 Acbons e and f repdig high pressure safety ejecbon (HPSI) pump operation when the Low Taivettuare Ova preswre Protecbon (LTOP) System is opfA tde will be moved to the ITS bases. Detai!s in CTS 3 4.9.3 LCO d wiB be retained in LCO 3.4.12. The mark-up of the CTS 3.4.9.3 LCO will be rce%,ed to c!anfy which porton of the CTS reman in the ITS.

4 LA.1 CTS 3.4.9.3 LCO statements b, c, d, and e; and CTS 3.4.9.3 SAME AS ABOVE Acbons e and f speofy requrements for HPSI pump Opa bi when the LTOP System is n-Wh:e. ITS 3.4.12 does not contain these requierra6. The d:scusson of c'.a;*f 3 states that these requaese 6 are troved either fully or pa.tially into plant procedures.

CCNPP Response:

DOC LA.1 has been modrfied to state that CTS 3.4.9.3 LCO Statements b. c, e, and 3.4.9.3 Actons e and f regarding HPSI pump epw.bi when the LTOP System is applicable will be moved to the ITS bases Details in CTS 3.4.9.3 LCO d win be retaired in LCO 3.4.12.

1 DOC = Discussaan of Change 27 JFD = Justificaton for Deviaten

ATTACM (1)

RESPONSES' TO REQUEST FOR ADDmONAL INFORIEATION ErftOVED TECNNICAL SPECFICATIONS SECTION 3.4 13.4.12

? DOC JFD CHANGEOIFFERENCE CORAENT STATUS 5

JFD.14 The CTS 3.4.9.3 LCO statement a.1 requres tow PORVs SAME AS COMMENT # 1.

wilh a trip setpont below the curve in Figure 3.4.94. ITS 3.4.12 LCO statements a and b modify the CTS 3.4.9.3 LCO statement by adding the phrase *on or" to the CTS statement of"below the curve." This ITS 3.4.12 change to the CTS is a deviaton from the STS. The rear u===nn and P J ~ - for this STS deviaton m that the changes are made to the STS to make it consistent with Amendments 188,171,146, and 145 (Unit 1); and Amendments 178,165, and 131 (Unit 2).

l CCNPP Rooponse:

JFD 14 wit be upgraded to beDer explan what changes to the cunent licensmg basis are asso* wist vanous amendments to the CTS.

6 JFD.14 -

CTS 3.4.3.3 Acton c requres depressunz:ng and wentng tie see comment # 1 RCS and then mantaming the unit in the vented condihon.

ITS 3.4.12 Actons D and E retams the CTS 3.4.9.3 Acton c requrement to depressunze and went the RCS by requong depressunzing and wentng the RCS. Housever, ITS 3.4.12 Actons D is added to the STS 3.4.12 Achons, malung this a deviaban from the STS. The justicaten for this STS deviaton states in part tint the changes are made e the STS to make it consistent wdh Amendments 188,171,146, and 145 (Unit 1); and Amendments 178,165, and 131 (Unit 2).

CCNPP Response:

JFD 14 wM be upgraded to beDer explom what di w to the cunent licenseg basis are menrnead wth vanous amendments to the CTS.

- Doc = Docussen of Change 28

.ro = Jusemessen for Devissen

ATTACdMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.12 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 7

JFD24 CTS 3.4.9.3 MOD,ES OF APPUCABtUTY requires RCS Provide discusson re-A g system desgn.

tescga"uare s 365 F arri the RCS vented to < 8 square ulches. ITS 3.4.12 MODES OF APPUCABTUTY changes the CTS MODES OF APPUCABluTY to specfy MODE 3 wrth all RCS cold leg teTvecishres s 365 F (Unit 1) and s 301'F (Unit 2), and MODES 4. 5. and 6. This change in the CTS MODES OF APPUC#BlUTY is a deviaton trom the STS.

CCNPP Response:

JFD 14 will be upgraded to better explain what dwry to the current Ecensnig basis are assocat,j with vanous arra,-4 Ten' to the CTS.

s 8

JFD.14 The CTS 3.4.9.3 MODES OF APPUCABIUTY requirement SEE COMMENT

• 1 that the RCS is vented to < 8 square inches 4 rnoved to a Note in the ITS 3.4.12 MODES OF APPUCABIUTY. Addag this Note to the ITS 3.4.12 MODES OF APPUCABiUTY is a deviation to the STS. The judra,o^oca.- for this deviat;on states that the changes are made to the STS to make it consistent with Unit 1 ATa4nents 188.171,146, and 145 and Unit 2 ATerd,ac.s 178,165, and 131.

CCNPP Response:

JFD 14 will be upgraded to better exp!ain what dwges to the current in.cis g basis are assoca*ied with vanous cm 4 c6is to the CTS.

Doc = otscussen or change 29 JFD = Justificabon for Deviation

A1TACM (1)

RESPONSES TO REQUEST FOR ADOfTIONAL INFORABATION IW' ROWED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.12 DOC-

.JFD CHANGEOlFFERENCE l

CORWENT STATUS 9.

JFD.14 in addition to the HPSI pump reouvement, the STS 3.4.12 SAME LCO statement requres one C-yg pump capable of angechng into the RCS and having the SITS isolated. The ITS 3.4.12 LCO statement does not include the C-f g pump and SIT requrements. This is a deviabon from the STS.

There is inadequate denm and jusin iui for this STS deviabon The jusin iui for this deviabon states that the Cs,yc= are made to the STS to make it consstent with Unit 1 ATwers3 188,171,146, and 145 and Urut 2 ArseTse 178,165, and 131.

CCNPP Response:

JFD 14 will be ugy aded to bener explain what Cwaps to the current licensing basis are assocated with va ',us c=io eT= 3 to the CTS.

10 JFD.14 ITS 3.4.12 adds a new LCO statement requinng one SAME OPERABLE PORV with Trft sethng on or below the curve in Figure 3.4.12-1 and RCS vent of 21.3 square inches. TNs new ITS LCO statement is a deviabon from the STS. The jid ' 4-i for this deviabon states that the Cs,yc= are made to the STS to make it consistent with Unit 1 ATwersG 188, 171, 146, and 145 and Unit 2 Arseces 178,165, and 131.

CCNPP L.,,cca:

JFD 14 wiR be upy oded to better explain what G.@ to the current licenssng basis are assocated with vanous amendments to the CTS.

f 3e

.FD = Justecabon for Demsten

~... ~

N ATTACHM (1) f RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4

[

'3.4.12 DOC

'JFD CHANGE / DIFFERENCE COMMENT STATUS s

11 JFD.14 ITS 3.4.12 adds a new Note to the LCO statements y

speofying HPSI pump restnchons and PORV Idt setbngs when in shutdown cooling This new ITS LCO Note is a deviabon from the STS. The p c'-:4E-i for this devebon i

states that the Gwiyo= are made to the STS to make it i

i consestent with Unit 1 Amendments 188,171,146, and 145 and Unit 2 Aii.ciid...o 4= 178,165, and 131.

l CCNPP ReaMuse:

[

The Note to ITS LCO 3.4.12 will be icyi.c.ed with..-- - _ _ _ is to the LCO, and JFD 14 wiB be modrfied to reflect these dw.yes, and to better explan what dw.y==

to the current licenseg basis are assocated with vanous amendments to the CTS.

i 12 The STS 3.4.12 MODES OF APPUCABiUTY Note is Prowde ji T.c.i.ince for the STS deviabon deleted in the ITS 3.4.12 MODES OF APPUCABluTY. The based on cummt licensmg bass, system l

l STS MODES OF APPUCABIUTY Note specifies SIT design.oro aihi.iconstramts.

I v

i Imtabons related to RCS cold leg temperatures and P/Tlimit l

curves. Delebng ths Note in the ITS is a deviabon from the f

STS. There is no decussson or p_4'_-2_ _-i for delebng this t

I t

CCNPP Response:

JFD 14 will be upgraded to better explan why the SIT Note in the STS is removed f

13 JFD20 STS SR 3.4.12.4 requres venfying RCS vent 2 [1.3] square Prowde ju=i,T.c iice for the STS deviabon l

inches is open once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for uniocked open vent based on cur ent kcus.g basis, system vane (s) and once per 31 days for locked open vent valve (s).

dessgrt or cpoi. inn aisi constramt!L l

This requrement in contamed in iTS SR 3.4.122. 1-ic-a.r, Explari what the pressunzer manway has to do the ITS SR u._wivw= the STS requrement by addog a Note with this SR and why~

i i

to the 31 day Frequency sy=c4yig that the 31 day l

Frequency is W to the pressunzer manway. This THIS MAY BE A BEYOND SCOPEISSUE j

change is a devebon from the STS. There is inadequate de_M and jbauin im.s for this STS deviabort.

^

CCNPPP-,:- a 6

The Note to ITS SR 3.4.122 and JFD 20 have been withdrawn.

i 4

1 i

DOC = Discussion of Change 31 JFD = Just6cobon for Devisbon l

ATTACIM (1)

RESPONSES TO REQUEST FOR ADDITIONAL WFORMATION N TEC0GWCAL SPECFICATIONS SECTION 3.4 3.4.13

DOC.

-JFDf CHANGEKMFFERENCE CORAENT STATUS 2-A2 ITS 3.4.13 does not contart the RCS leakage ristrumentabon Speedy the ITS Spec 6cahons Riat nour Canteen referenced by CTS 3.4.62. The riar,==ri of change h that these SRs.

the deleted rnonslors are requred by other ITS Speedcahons, but does not speedy whch ones.

CCNPP Rooponse:.

DOC A2 wB be revised tojust#y the delebon of CTS sunellence requrements 4.4.6 a2 and 4.4.62n 4-A3 Most of the discussion focuses on the addihon of ITS SR 3.4.132 TSTF 138 was repected by NRC 4/11/97.

b the CTS 3.4 62 requrements. However, at the erd of the Revise LCO hJ.y;y.

discussson, the focus changes to the % of an *OR*

statement b ITS 3 4.13 Achon B. The riar'asswi m that the

• OR* statement is added b CTS 3.4.62 Acton a (Villh any PRESSURE BOUNDARY LEAKAGE,. be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cot.D SHUTDOWN withri the fogounng 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."). The new ITS 3.4.13 Acton B "OR*

statement W_ "One or more SGs inoperable." b arm =it for a Cond! hon with one or two SGs inoperable. The new ITS 3.4.13 Achon B "OR* statement auds a regurement to CTS 3.4.62 and is tierefore a more resenceve change. There is inadequate riar'a=n and justfran=ws to support this more restnchwe change. This more restnchve change is not conssstent with the STS. AddebonaRy, the STS rr.

up for tiis change A

referencesTSTF 138.

CCNPP Response: -

Changes associated with isi t -138 wiR be withdrawrt The ISTS h markup for ITS SR 3.4.132 wiR be changed b indcate fiat compliance wei LCO 3.0.3 is regured when one or more steam generators do not meet the requrements of the steam generator tube suneganm program. This deviaton wiR bejustmed by JFD 13, and DOCS A3 and A5 will be revoed. DOC M 1 wB be withdraunt JFD = Justulicaten for Devisten

i ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.13 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 5

A5 ITS SR 3.4.132 requires verfying SG tube integnty per the SAME AS ABO'E Steam Gene oh.iTube Surveil:ance Progrant CTS 3.6.42 does not contain this regurement, nor does the de_rmnn present issues W with CTS 3 6.42.

Instead, the riiem focuses on CTS LCO 3.4.5," Steam Gooo-us, whch requires each SG Operable and spales requred SG tube Surved!ance Requrements CTS 3.4.5 is k wp Aeted into ITS 5.5.9 " Steam Germoiu- (SG) Tube Survei!!ance Progrant* Although ITS 3.4.13 neitner spc,-idy requres the SGs Operable, nor spmJes SG tube SRs, it does place limits on RCS leakage; indrecify requalng the SGs Operable. CTS 3.4.5 is inc!uded with the CTS 3.6.42 markup, and is the locabon of the A5 wmal The discussen states that CTS 3.4.5 is kwpuoimi into ITS 3.4.13. This is not the case. CTS 3.4.5 is awguaim2 into ITS 5.5.9. ITS SR 3.4.132 adds a requirement to the CTS and is therefore a more restncbve change. There is ro discussen or ju=LTic Lui for this rnore restnchve change. AdGLu ally, the d:scussen states that SG OPERABIUTY is delen.= col by SG tube a.=pm.,^uo per CTS 3.4.5 and ITS 5.5.9.

However, SG OPERABiUTY includes other factors besides tube aispecluo such as water level and tenye aiare. The discusson makes no reference to where those requacu=45 have gone. Firia:!y, the d@_W states the change is wWsterd with TSTF 138.

CCNPP Response:

Changes associated with Isi F-138 will be witteown. The ISTS Bases markup for ITS SR 3.4.132 wi5 be d@ to indcate that w upr.anc,e with LCO 3.0.3 is required when one or rnore steam geraciu s do not meet the requicucas of the steam gereoiu tube survenilance piujoui. This deviabon wiB bejusb5ed by JFD

13. and DOCS A3 and A5 win be revised. DOC M.1 wiH be wdtdowa.

I i

Doc = Discussen of Change 33 JFD = Justrricaten for Deviaten

ATTACM (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORERATION ENWOWED TECHNICAL SPECIFICATIONS SECTION 3.4

3.4.13 DOC JFD :

CHANGODIFFERENCE CORSENT STATUS 6

M.1 The riarmaansi states that the more restncine charge s SAMEASABOVE a)nsistent with both the STS and TSTF 138. The STS markup contasis a "doud" with the STS 3.4.13 Condeon B added "OR*

requwement for one or more SGs inoperable. The STS does not contart this requrement. Addeonally, tiis change is referenced to TSTF 138.

CCNPP Response:

Changes assooated with TSTF-138 will be withdrawn. The ISTS Bases markup for ITS SR 3.4.13.2 we be changed to indicate that comple. ice wei LCO 3.0.3 is requred when one or more steem gereretors do not meet the requrements of the steam generator tube surveiEance prograrn. This deviahon wW be justned by JFD 13, and DOCS A3 and A.5 wis be revoed. DOC M.1 will be withdrawrt 7

L1 The darm=arvi of change focuses on the deleton of CTS Are these same requeements in Leakage Sunellance ReqCi..~

in ITS 3.4.13.

However, the Detebon?

discussen and Jusblicahon oo not adequately desenbe hour performing the RCS water invetry belance requwed by ITS SR 3.4.13.1 J c:.;d ref ar** the rnonstonng funchons performed i

d by the CTS Sunemana Requrements CCNPP Rooponse:

DOC L.1 will be revised to pronde addsbonaljusblicahon for these changes.

3.4.14 DOC JFD CHANGBDIFFERENCE CORSENT STATUS-1 L6 Notes are added to ITS 3.4.14 Achons A.1 and B.12 that abow Am vu of tus change is cantingent upon waeng 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after staarty state aandibons are e=fahE=hed NRC approvalof TSTF-116.

before performing a RCS.%.ini belance. CTS 3.4.6.1 does not agow this wait The onginal STS 3.4.14 verson does not contain these Notes either. 1he STS 3.4.14 markup sneerts these notes wi!h a reference to TSTF-116.

CCNPP Response:

The d=r.y=. assooated with TSTF-116 have been withdrawrt Doc = D-- or change 34 JFD = JuebRcobon for Demobon

ATTACM (11 RESPONSES TO REQUEST FOR ADOmONAL SIFOREIATION N TECHNICAL SPECrtCATIONS SECTION 3.4

3.4.14

DOC

.JFD-CHANGE / DIFFERENCE CORAENT STATUS 2

CTS Survedance Requwement 4.4.6.1 a references the Provide reari==nn and jusb6cahno for me Frequencies anar$E=d in Table 43-3.'

There are numerous indicated changes. Speedcasy checi== hour changes b Table 43-3 with the only change referenced b A.1.

these requrements are addressed by the ITS There is inadequate drmann and justfr=hnn for the changes 3.4.14 SRs.

noeed.

CCNPP Response: -

R;';.sw in the CTS will be enhanmd. DOC LA.1 wiR be added, DOC L1 wiR be nic4' d, and ISTS markups w81 be revised.

3 The CTS 3.4.6.1 markup ancludes a Table 334 that contains Provide theri==nn and justAcahon for the several c,ti.w. The only reference b a docussion is A.1 and svte=hrt changes on Table 3.3.4 SpecAcasy b see the discussion of change for3.33.1 *R=rtshnn Monstanng address how these changes relate b CTS Instrumentabon." There is no eteriamnn or jusblicahon for the 3.4.6.1 and ITS 3.4.14.

noted changes in any of the ther===nn of change files for 3.4.6.1. In fact, CTS 3.4.6.1 does not reference Table 33.-6 at all CCNPP Response:

References in the CTS wWl be enhanced, DOC IA1 wiB be added, DOC L1 wiR be n M'., d. and ISTS markups wiE be revised.

3.4.15 DOC

.JFD CHANGE / DIFFERENCE COMMENT STATUS No comment for 3.4.15 3.4.16 -

DOC JFD CHANGE / DIFFERENCE CORAENT STATUS' No comments for 3.4.16 DOC = Dem of Change 35

.FD = Justinceton for Deviston

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4.17 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

A1 The markup for CTS Survedlance Requrement 4.10.52 Giorrges Provide adG^ ca J <*er'_m and p_4As^&i u

the original wording of, " prior to suspending reactor coolant for this specific change reic enced by A1.

circulation." to ". prior to suspending LCO 3.4.6 LCO 3.4.7, or Spec 4 Dy discuss the respectve LCO 3.4.8.* This Surve Hance Requrement is contoa ed in ITS regtuewieuG of ITS 3.4.6,3.4.7 and 3.4.8 and SR 3.4.17.1 which requires venfying xenon reactrvity is within justfy how stsgending them does not affect limits once wrtin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior to suspending LCO 34.6 LCO plant safety h

3.4.7, or LCO 3.4.8.

ITS 3.4.6, "RCS Loops - MODE 4,* ITS 3.4.7 'RCS Loops - MODE 5. Loops Fi: led," and ITS 3.4.8,"RCS Loops - MODE.5, Loops Not Filled" each have notes allowing exceptions to their ic4-Mve LCOs under certain risG^ucis.

Although this charx,Je is arguably an administrative change, it is not of the genenc nature addressed by A1. This change is consrstent with the STS, but there is no discussion orjustfication for this spectic element of the change g

CCNPP Response:

The CTS markups will be revised. DOCS LA1, t.A2, and A2 will be retracted, and DOC A3 will be added added to address the Co.wes.

2 8 A2 CTS 3.10.5.c requires venfying the shutdown margin per,the Correct the discusson of change to accuratefy requireg.cr/s of CTS 3.1.12, " Shutdown Margin - T, < 200 F,*

ref!ect the ITS 3.4.17 rixdei/6.

once per eighthou s when no SDC pumps or RCPs are in Opeicdagi.

This requirement is rnoved to ITS SR 3.4.17.4.

However, the discusson of change refeiciw two ITS SRs (i.e.,

ITS SR 3.4.17.4 and 3.4.17.5) that now cortain the ongmal CTS 3.10.5.c reque emenG, and two Notes that amplify and modify the ITS SRs. Nest!'er the STS 3.4.17 markup, nor ITS 3.4.17 contain SR 3.4.17.5 or the referenced Note 1. ITS SR 3.4.17.4 does have a Note that is the Note 2 referenced in the <*=rwinn of change. ITS 3.4.17 is ux6 stent with STS 3.4.17. This change is not adequately Justified in the discusson of change.

CCNPP Response:

The CTS markups wi!! be revised. DOCS IA1, LA2, and A2 will be ieL oded, and DOC A3 will be added added to address the changes Doc = Docussion or change 36 JFD = Ae% for Deviabon

ATTACM (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IgrROVED TECHNICAL SPECIFICATIONS SECTION 3.4 3.4 DOC JFD j CHANGE / DIFFERENCE COMMENT STATUS PIV Leakage spcv&.^uun should be retamed LCO should be retanned for w&.cy with the STS and also because there is nothmg to preclude the inc.luson of the LCO.

CCNPP Response:

JFD 16 will be revised to explain that the only asi--uW spedi.c G gi requwed for this LCO is CTS SR 4.52.e.1 which has been retamed as ITS SR 3.52.9 and will explain why the pnmary isolabon valve leakage spedrab does not need to be retamed.

1 Doc = Docussen et change 37 JFD = Jusencaten for Densbon